Effort
Reporting
and the UG
Leading Excellence in Research
Costing Practices
Conference October 13 - 15, 2015
Topics
 How
does the implementation of the
Uniform Guidance impact my institution
 As an institution do you need to change
or upgrade your current effort reporting
system
 Changes to Certification Frequency
 New Certification Methodologies (Project
Certification, Payroll Certification, FDP
Pilot)
 Policy Updates
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Effort Reporting Basics
 Effort
reporting is the process by which the salary
charged to a sponsored project is reviewed after-thefact to assure that the salary charged was reasonable in
relation to the effort expended on that project.
 Effective
December 26, 2014, the OMB Uniform
Administrative Requirements, Cost Principles and Audit
Requirements for Federal Awards (the Uniform
Guidance) regulates effort reporting requirements for
recipients of federal funding. Like Circular A-21, the
Uniform Guidance requires an after-the-fact review of
charges made to Federal awards that were based on
budget estimates.
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Effort Reporting Life Cycle
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The Basic Idea
•
•
•
In a grant proposal, we offer effort
At award time, we make a commitment of effort
Throughout the project, we charge salary to the
sponsor
Periodically, sponsors want to know:
•
•
Have we devoted enough effort to justify the salary charges?
Even in cases where we are not charging salary to the sponsor, have we
fulfilled our commitments?
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What Changed with the
UG?
1.
Requirements and standards have been
streamlined across most entities that
receive Federal awards.
2.
Specific frequency and methodology
requirements have been eliminated.
3.
New standards for documentation of
personnel expenses have been defined.
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What are the New Standards
of Documentation?
Charges to Federal awards must be based on
records that accurately reflect the work
performed (2 C.F.R.§200.430(i)(1)). In addition,
the records must:



Be supported by a system of internal control that
provides reasonable assurance about the accuracy,
allowability, and proper allocation of the charges
Be incorporated into the entity’s official records
Reflect the total activity for which the employee is
compensated by the entity, not exceeding 100% of
compensated activities, or Institutional Base Salary
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What are the New Standards
of Documentation?
Charges to Federal awards must be based on
records that accurately reflect the work
performed (2 C.F.R.§200.430(i)(1)). In addition,
the records must:



Encompass both federally assisted and all other activities
compensated by the institution on an integrated basis, i.e.
reflect 100% of the employee’s activities
Comply with the entity’s established accounting policies
and practices
Support the distribution of the employee’s salary and
wages among specific activities or cost objectives if the
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employee works on multiple activities
Additional Guidance





Phrases “suitable means of verification” and “first hand knowledge”
are no longer in the regulations.
Budget estimates continue to be considered insufficient support for
charges
Charges for non-exempt personnel must be supported by records
indicating the total hours worked each day.
Charges for cost sharing or matching requirements must be
supported in the same manner as direct charges for personal
compensation.
The new guidance also encourages cognizant agencies to consider
and approve alternatives to traditional effort reporting, such as
milestone- or performance-based approaches for compensation.

These alternatives must be approved by the cognizant agency in
advance
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What are Other Institutions
Doing?
 Confirm
effort reports on a schedule that
works for your institution.
 Reflect 100% of the individual’s activities,
including IBS
 Determine exactly who reviews and
confirms effort statements
 Audit trail capabilities and management
reports supporting internal controls
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Quiz
Which of the following have specific federal mandates?
Which are Institutional Options?
Mandated?
1. Must be certified by individual with first-hand knowledge
2. Medium of certifying/documentation (paper vs. electronic)
3. Exact frequency of effort certification/review/documentation
4. Report on each individual federal award
YES
5. Results must be incorporated into institution’s official records
YES
6. Level of detail regarding non-sponsored effort categories
7. Records must be supported by system of internal controls
YES
8. Based on institutional base salary
YES
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Audits and Settlements
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Contact Information
Jennifer Miles; Director, Sponsored Programs Accounting
University of Kentucky; jennifer.miles@uky.edu
Marty Bergerson; Manager, Huron Consulting Group
mbergerson@huronconsultinggroup.com
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