Sponsored Programs Foundation
Effort Reporting Policy
Issued: June 2012
POLICY BACKGROUND
Humboldt State University Sponsored Programs Foundation (HSU SPF) requires that all salaries and
wages charged to sponsored projects are certified consistent with federal requirements. Effort reporting is
required by all individuals who receive compensation from a federal grant or contract directly, or through
cost sharing. As a condition to receiving federal funding, HSU SPF is required to maintain and certify the
percentage of time that employees devote to federally-funded sponsored projects.
Sponsored projects at HSU SPF are funded by state agencies, private foundations, organizations, and
other sponsors. HSU SPF’s time and effort certification process provides verification of time and effort
charged to these projects.
Adherence to this procedure is necessary to prevent cost disallowances and penalties by the federal
government and other sponsoring agencies. Humboldt State University Sponsored Programs Foundation
(HSU SPF) requires that all salaries and wages charged to sponsored projects be certified consistent with
federal requirements. As a condition of receiving federal funding, HSU SPF is required to maintain and
certify the percentage of time that employees devote to federally-funded sponsored projects. Time and
effort reporting is conducted three times per year: fall semester, spring semester, and summer
intersession.
SCOPE
2 CFR Part 220 (Formerly known as OMB Circular A-21 ― Cost Principles for Educational Institutions)
outlines the regulations governing time and effort reporting and the verification of salary distributions.
Specifically, Section (J)(10)(c)(2)(b) requires Time and Effort Reports to be completed to provide after
the fact verification of the salary charged to sponsored projects: “[effort] report[s] will reflect after the
fact reporting of the percentage distribution of activity of employees.” 2 CFR Part 220 requires that this
verification be completed for all “professorial and professional” staff. At HSU SPF, professorial staff
includes all faculty members and professional staff includes all salaried staff and hourly employees. 2
CFR Part 220, Section (J)(10)(b)(1)(c): “recognize[s] 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.”
DEFINITIONS
Sponsored Programs: Refers to programs sponsored in whole or in part by external sources for which
the sponsor expects performance, deliverables or outcomes. Sponsored programs are awarded through
Effort Reporting Policy
various mechanisms – grants, contracts, or cooperative agreements – and may be from public or private
sources. Gifts are not included in sponsored programs.
Principal Investigator: The individual primarily responsible for the technical (or programmatic) conduct
and management of the project to assure that contractual/award terms and conditions are met.
Total Effort: Includes an individual’s efforts on University, HSU SPF, and cost-shared activities. The
distribution of effort across categories reasonably reflects effort devoted to each area and shall be
expressed as a percentage of total effort. The sum of total effort on University, HSU SPF, and costshared activities shall equal 100%.
Documented Effort: Represents actual payroll charges expressed as a percentage of effort during the
specified time period.
Cost-Shared Effort: The effort devoted to a sponsored program that was donated or paid for by a
different source of funds.
PROCEDURES
Effort Certification Statements (ECSs) shall be compiled, distributed and certified three times per year to
cover the following time periods: Fall (September 1 - December 31), Spring (January 1 – May 31), and
Summer (June 1 – August 31).
For hourly employees paid solely through HSU SPF payroll, bimonthly timesheets will serve as the effort
certification.
Employees paid from multiple payroll sources (e.g., HSU SPF and HSU), those providing cost shared
effort, and exempt employees shall certify their effort with an ECS. The ECS shall include all pay and
effort sources for an individual including HSU SPF direct pay, additional employment (in accordance
with CSU system additional employment policies), release time, extended education, summer work,
teaching, cost shared effort, etc. Any corrections made by an individual to the documented effort shown
on their ECS which differs from the payroll distribution by more than 5% shall be corrected in the payroll
system.
2 CFR Part 215 (Formerly known as OMB Circular A-110 ― Uniform Administrative Requirements for
Grants and Agreements with Higher Education, Hospitals and Other Non-Profit Organizations, Section
25(c)(3) requires prior approval from the federal awarding agency if there is an “absence for more than
three months, or a 25 percent reduction in time devoted to the project, by the approved project director or
principal investigator.” Any deviations between the proposed effort and actual effort which may result in
the need for federal agency approval shall be referred to the Principal Investigator for additional
assessment.
Once an individual’s effort has been certified, only in rare circumstances will subsequent effort
adjustments be permitted. If it is necessary to adjust the salary charges for a previously certified effort
period, documentation must include a detailed explanation of the need for the adjustment and subsequent
recertification. This documentation must be approved by the Principal Investigator.
Effort Reporting Policy
Each ECS shall require a signature certifying the accuracy of the information. If an employee is no
longer available to certify an ECS, an individual who has direct knowledge or can demonstrate suitable
means of verification of the employee’s effort may certify on the employee’s behalf.
Return of the ECS to the HSU SPF will be required by the deadline clearly stated in the instructions
accompanying the ECS. ECSs not returned by the stated deadline shall be brought to the attention of the
Principal Investigator. Continued noncompliance shall be referred to the respective Chair/Dean or
AVP/VP, if applicable.
ROLES AND RESPONSIBILITIES
Each person involved in the HSU SPF's reporting and tracking process has a shared responsibility to help
assure that the effort reporting process is completed within the required time frame.
HSU SPF shall be responsible for gathering data on employee effort, producing and distributing the Effort
Certification Statements with completed documented effort information, monitoring completion of the
forms, comparing effort data against budgeted commitments, and maintaining the certification records.
Each individual receiving an ECS shall be responsible for reviewing the ECS for accuracy, completing
any cost-shared effort information, and signing and returning the ECS to the HSU SPF in accordance with
effort reporting deadlines.
The Principal Investigator shall be responsible for insuring the timely completion and return of ECSs
related to their projects. Each Principal Investigator shall certify effort corrections in excess of 5% for
any individual working on their project as well as any recertification of previously certified effort. The
Principal Investigator shall work with HSU SPF when the Principal Investigator’s effort is reduced by
25% or greater.
Department Chairs and College Deans (or AVP/VP, if applicable) shall be responsible for oversight in the
compliance of effort reporting within their respective areas.
RELATED DOCUMENTS
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2 CFR Part 220 (Formerly known as OMB Circular A-21 ― Cost Principles for Educational
Institutions)
2 CFR Part 215 (Formerly known as OMB Circular A-110 ― Uniform Administrative Requirements
for Grants and Agreements with Higher Education, Hospitals and Other Non-Profit Organizations)
OMB Circular A-133, ― Audits of States, Local Governments, and Non-Profit Organizations
California State University Policies and Procedures - 11000.003.006
Effort Certification Statement
Effort Reporting Policy