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 an effort report when an individual is compensated by, or has agreed to contribute time to, a federally-sponsored project. All faculty who serve as investigators on sponsored projects are personally responsible to certify the amount of effort that they and their employees spend on sponsored activities.
The purpose of this policy is to define effort reporting, as well as identify those individuals who must comply.
Definitions
"Effort" is defined as the 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 Rhodes College compensates an individual.
“Effort Reporting” is the mandated method of certifying to the granting agencies that the effort charged or cost-shared to each award has actually been completed.
Policy
In accordance with Uniform Guidance, Rhodes College requires effort reports for all faculty and staff who work on sponsored projects that are federally-funded, regardless of whether the effort is paid or unpaid. Rhodes uses after-the-fact certification. Faculty and staff submit time and effort reports annually in August to the Finance Office. 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:
- 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.
- 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.
- 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.
- 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.