POLICIES: TIME AND EFFORT REPORTING
As recipients of federal research funds, St. Cloud State University is required to certify through time and effort reporting to ensure charges to federally sponsored projects are reasonable in relation to the effort expended. Most federally funded grants should have some level of committed faculty, staff or student effort, paid or unpaid by federal funds. The university implements time and effort reporting in compliance with The Office of Management and Budget Circular A-21 Cost Principles for Educational Institutions.
St. Cloud State University utilizes an after-the-fact activity report to certify effort on a semi-annual reporting cycle as outlined in OMB Circular A-21, Section J.10 Compensation for Personal Services. Individual effort reports are required for faculty and staff in which all or a portion of their salary is paid from a federal/sub-federal source with effort limited to 100%. “Effort” is the proportion of time spent on any activity, expressed as a percentage of an individual’s total university effort, excluding de minimus activities which will be listed on the effort report but not included in the effort calculation. An employee’s base salary consists of those activities performed regularly consistent to their employment with the university.
Unless direct time is not denoted in the State of Minnesota or Minnesota State Colleges and University’s payroll systems, clerical/technical staff and undergraduate/graduate/doctoral students certify their effort on federally funded projects through the regular bi-weekly timesheet process, respectively. Signature is provided either electronically or originally signed for both the employee and the supervisor.
Committed cost sharing by university employees, whether cash or in-kind, will be certified through time and effort reporting. Voluntary uncommitted cost sharing is determined by the principal investigator and will not be monitored by the university.
Semi-annually the Director of Compliance and Ethics will generate time and effort reports for those employees paid on federal funds extracting salary information through the Cap_Server. Note changes to time and effort reporting will not be made when proposed changes fall within the level of tolerance or when related to retroactive pay due to contract changes after-the-fact. Certification of committed effort will be reviewed and approved by the person with first-hand knowledge of the employee’s assigned workload (employee, supervisor) or the person responsible for the fiscal management of the specified federal grant or subaward. Reminders will be sent every 30 days thereafter until effort reports are returned. Reports not returned within 60 days after issuance will have a reminder sent to the employee and his/her supervisor. Copies of time and effort reports are maintained electronically by Business Services and the Office of Research and Sponsored Programs. Business Services is responsible for retaining original time and effort reports according to the grant retention guidelines.
Failure to comply with The Office of Management and Budget Circular A-21 effort reporting requirements can result in audit disallowance of costs and penalties to both the university and the individual certifying effort. Salaries are considered high risk because of the potential for fraud and abuse by grantees of federal funds.
Base Salary - includes salaries and wages paid to an employee from any university source as payment for services provided under their standard employment agreement. Base salary does not include supplemental compensation such as overload, distance learning, extra duty pay, etc.
Certifier of Effort Report - ensures the effort reported is consistent, reasonable and accurately reflected on any time and effort report certified. Certifier possesses first-hand knowledge to verify sufficient work was devoted to the project to justify the salary charged and effort commitments have been met.
Committed Cost Sharing – represents dedicated services to the project which are not paid by the federal funding agency. Cost sharing will be approved by the appropriate university officials prior to the submission of the grant and disclosed in the budget to the funding agency as committed cash or in-kind.
De Minimus – activities performed on an infrequent or irregular basis which are not considered a normal part of an employee’s base salary and, therefore, will not be included in the effort calculations. Proposal writing cannot be de minimus.
Level of Precision - Federal regulations clearly acknowledge precise determinations are not expected and reasonable estimates are acceptable. To quote directly from OMB Circular A-21, "…it is recognized that, in an academic setting, teaching, research, service and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate." St. Cloud State University defines this “degree of tolerance” as five (5) percent of an employee’s total university compensated effort.
Salary Limitations – For NSF proposals submitted before 1/5/09, summer salary for faculty members on academic year appointments are limited to no more than two-ninths of their regular academic year salary. For NSF proposals submitted on or after 1/5/09, salary compensation is limited to two months or less of their regular salary in any one year. For NIH, if the annual salary exceeds the established salary cap, the amount of salary chargeable to the NIH grant will be limited. (For example, 10% effort to be paid by NIH grant but determination of the 10% will be based on the NIH salary cap vs. the employee’s actual salary if actual salary exceeds the NIH salary cap)
Semi-annual Reporting Periods - shall be equally distributed during the fiscal year and defined as July through December and January through June. Efforts reports will be generated within the first three months of the semi-annual reporting period.
Significant Change – In most cases, direct charges of payroll to sponsored agreements will be processed on the basis of estimates made before the services are performed, in compliance with procedures which require encumbrance of funds prior to the service being rendered. Significant changes in the corresponding work activity will be identified and entered into the payroll system. St. Cloud State University defines a significant change as five (5) percent or more of an employee’s total university compensated effort. The federal regulations specifically acknowledge that short term fluctuations (such as one or two months) need not be considered as long as the distribution is reasonable over the longer term, such as a six month cycle.
Total Effort - includes only those professional activities included as part of an employee’s normal base salary and sponsored activities for which an individual is compensated by or provided as in-kind contributions by the university regardless of when (daytime, evening, weekends) or where (on campus, at home, while traveling, etc.) the activities take place. For example, if an employee averages 60 hours per week during the six-month reporting period and spends on average of 15 hours per week on a sponsored project, the employee records 25% and 75% effort on the sponsored project and normal job duties, respectively.
Voluntary Uncommitted Cost Sharing - effort expended on behalf of the university which is over and above the committed and budgeted effort outlined in a sponsored agreement.
- Periodic review of your federally funded project and notify the compliance director of any change in effort paid by the funding agency or committed cost sharing
- Ensure the proposed level of effort is reasonable and appropriate for the research involved in the sponsored project
- Maintain appropriate documentation to support reported effort (calendar, project reports, time tracking, etc.)
- Ensure your other activities will not conflict with the proposed effort committed on federal grants, contracts or subawards
Certifiers of Time and Effort
- Ensure the effort reported is consistent, reasonable and accurately reflected on any time and effort report certified
- Review, sign and return time and effort reports within 30 days of receipt
Director of Compliance and Ethics
- Develop and implement time and effort reporting requirements across the university on all federally funded projects with effort paid by federal sponsor or university committed cost sharing
- Revise time and effort reporting policies and procedures as sponsor regulations change
- Twice each fiscal year generate time and effort reports based upon salary information extracted through the Cap_Server, grant budgets as approved by the funding agencies and any changes reported by the principal investigators
- Adhere to time and effort reporting timelines defined in the policy and monitor certifier adherence to such timelines
Semi-annually the Director of Compliance and Ethics will initiate time and effort reporting forms for each employee identified as being paid or having committed cost sharing on a federally-funding project during the reporting period. The time and effort reporting procedure is as follows:
- Based upon identified effort paid by federal sponsors, university committed cost sharing and any revisions received from the principal investigator, generate time and effort reports and distribute to the appropriate certifier of the effort
- Distribution of time and effort reports to occur within the first three months of the semi-annual reporting period
- Send reminders every 30 days thereafter until effort reports are returned
- For reports not returned within 60 days after issuance, send a reminder to the employee and his/her supervisor
- Review certified time and effort reports for potential salary adjustments, cost transfers or degree of tolerance limitations. Consider whether effort should be recertified.
- Cost transfers to National Institutes of Health grants by grantees or subawardees should be completed within 90 days of when the error was discovered, must be supported by documentation which fully explains how the error occurred and effort must be recertified.
- Electronically archive certified time and effort reports on the university’s file server which is backed up on a regular basis. Provide the original reports to Business Services to maintain according to grant retention guidelines.