Time and Effort Reporting Division of Research & Federal Relations Unit of Grants and Contracts Management

Time and Effort Topics  Definition of Effort  Time and Effort Reporting  Certification Process  Falsification of Reporting  Risks of Non-Compliance  Corrections to Effort Report

Definition of Effort “the portion of time spent on a given activity expressed as a percent of total activity for which an individual is employed by the institution” A “reasonable estimate” Degree of tolerance: up to 5% Must equal 100% Is NOT based on workweek of 40 hours

What is time and effort reporting? The “after-the-fact” mandated method of certifying to federal agencies that effort charged to an award has actually been completed. The records must be supported by a system of internal controls which provide reasonable assurance that the charges are accurate, allowable, and properly allocated.

Why do we do effort reporting? As recipients of federal funding, we are required to abide by OMB Circular A-21 § J10 (b) and the new Uniform Guidance 2 CFR

How do we certify effort? The after-the-fact verification is accomplished through the effort reporting system in JSU P.A.W.S.

Who needs to certify and review effort? All faculty and staff who receive any portion of their salary from a sponsored project. Principal investigators (PIs) must review. PIs must ensure that all effort reports for sponsored activities are certified and reviewed in a timely manner. You should not certify and review/approve your own certification report without the next level approver.

When do we report effort? Within thirty days after the end of each quarter QuarterDue January – MarchApril 30 th April – JuneJuly 31 st July – SeptemberOctober 31 st October – DecemberJanuary 31st

When is the process complete? Once an effort report is certified and reviewed by all PIs and/or supervisors involved, it is considered complete. The status of the effort report must be “completed and locked”. Upon completion, these reports are considered legal documents subject to internal and external audits.

Falsification of Effort Reporting Erroneously certifying effort can be viewed as fraud. Don’t certify unless the document is correct. Could result in consequences as outlined in the Federal False Claims Act.

Risks of Non-Compliance May not receive reimbursement for funds expended May be required to repay grant funds May impact future federal funding May suffer a damaged reputation

Corrections to Effort Report Salary reallocations/labor redistributions Certification process starts over after changes have been made.

Summary “After-the-Fact” accounting of committed time on a specific project. Must be certified by the employee. Must be reviewed by the PI or a responsible official of the institution with first-hand knowledge of the employee’s effort. Must be incorporated into official records of the university. Must be done in a timely manner.

Questions? Time and Effort Administrator * Illiad L. Kelly, Director Unit of Grants and Contracts *