Effort Reporting Policy

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Background

The Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Final Rule, 2 CFR 200, December 26, 2014 ("Uniform Guidance"), sets forth standards for obtaining consistency and uniformity in organizations expending Federal awards.  The Federal government requires reporting when an individual is compensated by, or has agreed to contribute time to, a federally sponsored project. This policy applies to all Davidson College personnel that are charging effort to a sponsored award as a prime recipient, subrecipient or cost share. 

Purpose

The purpose of this policy is to define effort reporting, identify the relevant reporting period(s), as well as identify those individuals who must comply. 

Policy

In accordance with Uniform Guidance, Davidson College (non-Federal entity) requires effort reports for all faculty and staff who work on sponsored projects that are federally funded prime awards, subawards or cost sharing accounts, regardless of whether the effort is paid or unpaid. All faculty who serve as Principal  Investigators (PI) on sponsored projects are responsible to review and certify the amount of effort that they and their employees spend on sponsored activities.

Procedure

Davidson College uses after-the-fact effort certification.  Faculty and staff submit time and effort reports annually in October. The certification reporting period is July 1 through June 30.

Non-exempt employees who complete auditable timecards are not subject to effort reporting procedures.  Effort reports must comply with Uniform Guidance Standards for Documentation of Personnel Expenses as follows:

  1. Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.  These records must:
  • Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
  • Be incorporated into the official records of the non-Federal entity.
  • Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity.
  • Comply with the established accounting policies and practices of the non-Federal entity.
  • Support the distribution of the employee’s salary or wages among specific activities or cost objectives.
    Note: budget estimates alone do not qualify as support for charges to Federal awards.
  1. Because practices vary as to the activity constituting a full workload, records may reflect categories of activities expressed as a percentage distribution of total activities.
  2. Salaries and wages of employees used in meeting cost sharing or matching requirements on Federal awards must be supported in the same manner as salaries and wages claimed for reimbursement from Federal awards.
  3. It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting.  When recording salaries and wages charged to Federal awards, a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.

Responsibilities 

Principal Investigator (PI) – Will timely review all provided effort reports provided by the Office of Sponsored Programs. The PI is responsible for the approval of all personnel effort charged to their specified award. The PI will notify the Office of Sponsored Programs immediately if a corrected effort report is required. 

Office of Sponsored Programs – OSP will provide training on  the effort reporting process to all faculty and staff members that are required to report effort on a sponsored project. OSP will provide periodic, typically quarterly, reports of project expenses to the PI for review and consideration. The Office of Sponsored Programs will notify the PI when effort reports are ready for certification. 

Definitions

"Effort" is defined as the actual amount of time spent on a particular activity.  It includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost-shared effort).  Individual effort is expressed as a percentage of the total amount of time spent on work-related activities—instruction, research (including externally-funded research), service, and administration--for which Davidson College compensates an individual.

"Effort Reporting" is the Davidson College mandated method of certifying to the granting agencies that the effort charged or cost-shared to each award has actually been completed.

“After-the-fact” effort certification is the mandated method of certify to federal agencies that the effort/compensation charged to a sponsored award has actually been completed. 

Administration of Policy

The Assistant Dean for Research Development / Director of Sponsored Programs shall oversee this policy and review it at least once every three years. Changes to this policy shall be made in accordance with the college's Policy on Policies.

Adopted: August 18, 2008
Last Revised: September 28, 2015
Last Reviewed: June 27, 2024