Effort reports are required by Federal research sponsors and are collected as part of required compliance with Federal regulations. Reports are retained by the Grants and Contracts Accounting Office, and must be produced when requested by Federal auditors. In recent years, several peer institutions have been fined substantial amounts as a result of effort reporting inaccuracies identified during audits. The following brief summary sets forth the guidelines that must be followed to produce an effort report that will be in compliance with Federal regulations.
Key Points in Effort Reporting
The following concepts must be understood to ensure that effort report forms are completed properly:
- The effort report form must account for all effort for which the University compensates the individual. Even where the number of hours of effort the individual expends each week substantially exceeds the "normal" workweek of 37.5 or 40 hours, effort percentages must be based on total effort, not hours
- University compensated effort includes all research, teaching, administration, clinical activity, and any other activity for which an individual received compensation from the University. Excluded from effort reporting is any compensation received from sources other than the University, such as compensation from the VA or outside consulting work permitted by the University. Incentive compensation is also excluded.
- Effort distributions should be reasonable estimates of activities, recognizing that research, instruction, and clinical activity are often combined and estimates will be necessary in many cases.
- Effort and payroll distributions are not the same thing. The effort reporting process is a method for certifying charges made to sponsored awards and for certifying that the effort expended is at least equal to the salary paid. Payroll distributions are used initially as a baseline for effort distributions and serve as a convenient reminder about activities on which the individual worked. Therefore, the payroll-based effort report form should be adjusted to report effort distributions that are less than the shown payroll distributions. Salary reallocations must be made in tandem with the changed effort report.
- The effort report form must be certified by the individual whose effort is being reported or by a responsible person with access to verifiable information on how the individual's effort was expended.
- Individuals whose compensation exceeds a sponsor imposed salary cap limit need to show a percentage of cost sharing for each such sponsored project.
- Mandatory and voluntary committed cost sharing must be reported. Where some or all effort an individual expends on a specific sponsored project is not funded by the sponsor but is mandated by the sponsor, or where the individual has clearly committed to uncompensated effort to the project in the application, that effort must be reported as cost sharing on the effort report form. The University maintains cost sharing accounts for this purpose.
- The total of the individual effort percentages reported on the effort report form must equal 100%.
- Effort and the corresponding salary distributions should be reviewed regularly and adjusted accordingly. Cost transfers must be completed in a timely manner.