Effort reporting policy
Guidelines that reflect the University’s practices regarding effort/payroll allocations for faculty members, staff members and others involved with a sponsored project.
Required departmental internal controls for sponsored research
An overview of University Audit’s expectations regarding departmental internal control procedures for key provisions found in the University’s Effort Reporting Policy (Appendix: “Required Internal Control Related to Management of Faculty Member/Investigator Effort Commitments” and E6: “Changes to Previously Certified Effort”).
Topics on this page:
This document is intended to complement, not supersede, the Effort Reporting Policy and to address common compliance audit findings. The overall objective is to assist research departments in complying with the policy, which is based on regulations set forth by the Uniform Guidance.
Quick links
Effort verification spreadsheet
A template to assist with documenting investigator committed, reported and actual effort. Includes an example of how to complete the spreadsheet.
Printable version of this document
A PDF version of this web page: “Required departmental internal controls for sponsored research”.
Required internal control related to management of faculty member/investigator effort commitments (appendix)
Policy Objectives – to ensure:
• Faculty member/investigator is not overcommitted
• Effort/payroll allocations are reasonable reflections of the actual work performed
• Any variance from committed effort requiring sponsor approval is identified and approval is obtained for:
o A change in a key person specified in the application or the award document.
o Absence for more than 3 months, or a 25% reduction in time devoted to the project, by the PI or
Project Director. The Project Director or PI will reach out to the Office of Research and Project Administration (ORPA) to make the communication to the sponsor if there’s more than a 25% reduction in time devoted (for non-federal sponsor, this may not always be the case).
• Timely changes in payroll allocations are identified and updated:
o At a minimum, if an effort change is at least 10% of the individual’s total effort or results in a reduction of documented effort on a single project (over a six-month period) of 25% or more of the original commitment for the current project period, an update to the respective person’s effort/payroll allocation must be done.
Expected controls that must be evidenced upon audit to verify the department is meeting the above policy objectives
The departmental Research Administrator or Financial Administrator responsible for grants must show evidence of a departmental process to actively and routinely monitor and verify effort and payroll allocations of all departmental faculty members / investigators (named on at least one award as key personnel).
* Note: These are not “one-time” procedures performed to satisfy an audit. The policy’s intent is that these controls are performed on an on-going basis.
Expected Control Descriptions
1. Maintain an Effort Monitoring spreadsheet
Utilize the Excel template from the ORPA website (Effort Verification Spreadsheet) or a similar spreadsheet for each faculty member/investigator to document and compare the three components of effort (Committed, Reported, Actual Devoted) and includes activities/responsibilities (research, clinical, teaching, admin, etc.)
Minimum requirement
The minimum requirement to update this spreadsheet is every three months (greater frequency may be necessary for larger / complex departments). This is an analysis of information at a point in time.
Example – During a fiscal year for a 12-month appointment, effort monitoring would be at least four times a year.
Important Notes
- The progress report effort verification process typically will not satisfy the policy control objectives.
- A department may need to maintain supporting workbooks to collect and track effort percentages to prepare for this control.
- All cost sharing (includes salary over the cap), that is charged to a non-sponsored account, has to be “added back” to Reported Effort as part of this analysis in order to accurately calculate the total for a given project.
- Regarding extra compensation: validate whether the associated effort should be included or excluded as part of this analysis. Consideration must be given to ensure the payments are truly extra comp (and are properly excluded from effort percentage calculations). Some extra comp payments (such as compensation for chairmanship) may need to be included in the calculation of Reported Effort.
The three components of effort
| Effort | Source | Description |
|---|---|---|
| Reported | per myURHR Workday | URHCM0391b Effort Distribution by Fiscal Period used to obtain effort/payroll allocations for selected researchers. (This report includes Salary Over the Cap and Cost Sharing) |
| Actual devoted | Per the interview with the faculty member/investigator | Interview the Principal Investigator and other key personnel as to actual activities/work performed: • All Total University Effort (TUE) - sponsored research, proposal writing, teaching, professional development, administrative duties, clinical practice regardless of when (daytime, evening, weekends) or where (on site, at home, traveling) the activities occur. • Total University Effort is not based on a specified number of hours (e.g., 40 hours per week). Cannot have greater than 100% effort. |
| Committed | Per the award | Effort promised in the award (agreed to by the Sponsor and PI); Review the IORA system and also government websites to obtain this information directly from the awards. |
2.Periodically meet with faculty members/investigators
Maintaining the spreadsheet and adequately performing this control procedure requires periodic meetings with faculty / investigators. This is an inferred policy requirement that is necessary in order to effectively complete the analysis (i.e., the analysis must include an exchange of information to verify a researcher’s “Actual Devoted” effort).
3.Document effort review and verification with faculty members/investigators
Departments will be expected to evidence completion of periodic effort/payroll verifications with their departmental faculty members / investigators, via signature or electronically, using the Effort Verification Spreadsheet described in Control 1.
Minimum requirements
- Document effort/payroll verifications at least quarterly (every three months); greater frequency, such as monthly, may be necessary for larger / complex departments).
- Include faculty member/investigator verification: faculty members/investigators must acknowledge that the Reported Effort (i.e., Workday payroll allocations), the Committed Effort, and the Actual Devoted Effort for the time period(s) indicated in the analysis (Control 1) have been reviewed.
4.Reach out to ORPA for sponsored approvals
For most sponsors, University Audit will expect evidence that the Administrator and/or PI reached out to the Office of Research and Project Administration (ORPA) to make any necessary award corrections or effort commitment adjustments related to the outcome of completing the above analysis. However, for non-federal sponsors, this may not always be the expectation.
Required internal controls related to changes to previously certified effort (section E6) or payroll accounting adjustments – PAA’s
Previously called “Reallocations”
Policy Objectives:
- Once effort certification has been completed, only in certain circumstances will retroactive subsequent effort/payroll allocation adjustments be permitted. If it is necessary to adjust the effort/payroll allocations for a previously certified effort period, submit a Payroll Accounting Adjustment (PAA) using myURHR and select the appropriate reason for the retroactive reallocation from the drop-down menu on the PAA process page.
- Reallocations of previously certified effort will require re-certification. Submit to the Office of Research, Accounting and Costing Standards (ORACS) a request for an off-cycle effort certification for such employee. Your request needs to include justification that clearly sets forth why the previous effort/payroll allocation was erroneously certified, and why the updated effort/payroll allocation is more appropriate within the context of sponsor regulations and University policies and procedures. Refer to the University’s Cost Transfer Policy – Sponsored Programs.
- At close out of a project, a PAA should not be used to retroactively change effort/payroll allocations from a sponsored account that is in deficit, if the underlying effort was truly expended on the project. Rather, the value of effort in excess of the project’s budget is to be a component of the journal entry that transfers the final deficit to an unrestricted account.
Audit procedures
- University Audit will run URHCM0441 Pay Accounting Adjustments Reports for the most recent three months, filtering by days > 90 days.
o Number of days: the number of days is calculated from the pay period begin date and the PAA date (date entered).
o Reasons: Workday myURHR has a dropdown box for the following reasons: Administrative Delay, Clerical Error, Funding Updates and Changes, Other Adjustment.
- University Audit will request more detailed reasons from the administrator for PAA’s > 90 days. University Audit will review for reasonableness and appropriateness.
Related offices and departments
ADMINISTRATION & FINANCE DEPARTMENTS
Other resources
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How-to