Policy & Certification
The University of Utah’s Effort Reporting Policy establishes requirements for certifying effort on sponsored awards in accordance with federal regulations and university standards. The policy helps ensure salary charges and cost sharing accurately reflect the work performed.
Policy Statement
As a recipient of federal funding, the University of Utah is required to comply with the Office of Management and Budget (OMB) Uniform Guidance (2 CFR §200.430), as well as other federal requirements for certifying effort expended on sponsored awards. The University requires all individuals who receive federal sponsored funding to comply with University policies and sponsoring agency regulations regarding the proposing, charging, and reporting of effort.
University faculty and staff are expected to charge their time to sponsored awards commensurate with the committed effort expended on all activities they perform. Payroll charges and recorded cost sharing serve as the initial data points for the University’s effort reporting system (e-Effort).
Reason for Policy
The Uniform Guidance contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The University utilizes an after-the-fact effort reporting system to certify that salaries charged or cost-shared are reasonable and consistent with the work performed.
Uniform Guidance §200.430 states: "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 for IHEs [Institutions of Higher Education], a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected."
Annual Faculty Effort Certifications and Quarterly Project Effort Certifications are our primary means of demonstrating compliance.
Roles and Responsibilities
| Role | Primary Responsibilities |
|---|---|
| Principal Investigator (PI) | Understand effort commitments; review and certify individual annual statements and quarterly project statements; communicate significant changes (>25%) to the department |
| Department Effort Coordinator (DEC) | Monitor salary charges and cost sharing; process salary distribution updates/corrections; ensure certifications are completed within the 30-day window. |
| Research Cost & Compliance (RCCP) | Maintain University policy; provide training; manage the e-Effort system. |
| Grant & Contract Accounting (GCA) | Oversee the financial reconciliation of certified effort and process post-certification payroll adjustments. |
Procedures for Certification
Quarterly Project Effort Certifications
- Timeline: Follows fiscal quarters (Q1: July-Sept, Q2: Oct-Dec, etc.).
- Certification: Effort must be certified by the individual employee or an authorized Responsible Official possessing direct, first-hand knowledge or suitable means of verifying the work performed.
Proxies and Designees
- Designees (Quarterly): A PI may delegate quarterly certification to another individual with first-hand knowledge of the project, e.g., a Lab Manager. Requires a Designee Approval Form.
- Proxies (Annual): Faculty proxies are only approved in extraordinary circumstances, e.g., long-term medical leave, and require OSP approval.
Effort Thresholds
Maximum Effort (The 95% Rule)
Generally, the University allows PIs to charge up to 95% of their annual effortto sponsored awards. The remaining 5% must be reserved for non-sponsored University responsibilities, including grant writing, committee service, etc. 100% research effort is rarely appropriate for faculty with administrative or teaching appointments.
Minimum Effort
All PIs and Key Personnel must have a "measurable" amount of effort on an active award unless specifically excluded by the sponsor. NIH policy states that "zero percent" or "as-needed" effort is not acceptable for Key Personnel.
Institutional Base Salary (IBS)
Annual compensation paid by the University for an employee’s appointment, excluding bonuses or outside consulting income.
Committed Effort
The percentage of time a PI communicated to the sponsor that they would work on a project.
Period of Work Performed (PWP)
The actual window of time the work was done, which may differ from when the payroll was processed.
uNID
The University of Utah unique identification number required for all personnel actions.