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Policy 318 - Time and Effort Reporting for Employees Working on Sponsored Projects

Section: Compensation
Policy Number: 318
Responsible Office: Grants and Sponsored Research
Effective Date: 09/01/08
Revised: 05/10/11; 07/21/16

Purpose

To comply with the federal Office of Management and Budget, The Uniform Guidance 2 CFR 200 (Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards for Educational Institutions), which supercedes the previous requirements in OMB circular A-21, the University maintains and updates its comprehensive Time and Effort reporting process as specified in 2CFR 200.430

Policy

In order to certify that effort expended on a project is at least commensurate with the salary charged against the sponsored program, the University employs an after-the-fact effort reporting system for faculty, administrators, and staff who have a portion of their salary or time charged to a sponsored program. Individual effort reports are required for each cycle, as defined below, for all employees who have a portion of their salary or time charged to a sponsored program. The Office of Grants and Sponsored Research (OGSR) shall ensure full compliance with the University’s time and effort reporting requirements and along with Business Affairs, maintain full documentation, which will be available for inspection by the University’s auditors.

Faculty members’ effort commitments to sponsored projects must not exceed 95% in any effort cycle. Additionally, 100% annual or summer salary effort must never be committed to sponsored projects by any individuals who have other teaching, proposal writing, mentoring or advising students, clinical activity or other non-grant administrative duties. Departmental chairs, departmental assistant-chairs, core directors, assistant and associate deans must not exceed effort commitments to sponsored projects above 95% in any effort period. Rare exceptions may be granted in unique situations where the funding agency expressly approves of 100% effort, such as on career awards.  

Procedures

For purposes of meeting the standards in 2 CFR 200 and other federal requirements, the University defines three cycles of reporting:

Spring – defined as January 1 through May 31 (Unless summer pre-session applies; see below for further guidance on summer cycle).

Summer – defined as the immediate start of pre-session summer course offerings (on or about mid-May) and though August 31 of that year. (For further guidance on summer cycle, please see below).

Fall – defined as September 1 through December 31.

Further Guidance on Summer Cycle

Supplemental/Summer Salary - Faculty compensated for 9‐month academic appointments are permitted to earn up to an additional three months of supplemental/summer paid compensation on one or more sponsored and/or non-sponsored activities. Individuals can earn up to the equivalent of three months of additional salary for that effort, subject to University and sponsor policies (e.g., Uniform Guidance 2 CFR 200) and the appropriate school level approval.

If a faculty member has administrative or other non‐sponsor related responsibilities (including vacations) during the period for which he/she is requesting supplemental salary, the faculty member is precluded from devoting the maximum allowable 95% effort to sponsored projects and cannot request the full 95% of 3 months of salary.

The University defines the maximum (100% effort) summer course load as follows:

  • Any combination of three (3) courses (3 credits/each), which includes Pre-Session, Summer Session I and Summer Session II
  • Each summer month equates to 33.334% effort
  • Each summer course equates to 33.334% effort

Employee

  1. At the end of each cycle, OGSR will prepare and forward a Time and Effort Reporting form to each employee scheduled to expend any level of effort on a sponsored program.
  2. The employee shall review the form and complete the “Actual Effort” column. Actual effort stated shall be based on total current support provided by the University (which includes cost sharing), all grants and any other external funding for the time period specified. The employee shall sign and date the “End of cycle - Actual Effort” section at the bottom of the form and forward the form to the Principal Investigator for review and approval.
  3. If there are additional earnings (i.e. Overload, Additional Compensation or Special Earnings), these amounts will be based on amounts charged to any grants, amounts supported by the University and any other external funding for the time period specified.
  4. If employee is granted a course release to afford time to work on a grant, then overload or additional compensation is unallowable during the same effort cycle.
  5. The form shall be completed no later than six (6) weeks following the end of the cycle.
  6. If #5 results in non-compliance, employee grant accounts (overhead included) will remain frozen until Time and Effort reporting form is completed.

Principal Investigator (PI)

  1. At the end of each cycle, the PI shall review the form for all employees working on the grant for which he/she is responsible. The PI shall highlight any significant modifications in effort, and any grant budget adjustments that may be required.
  2. The PI shall sign and date the “End of Cycle - Actual Effort” section at the bottom of the form and forward the form to the Dean/Chair/Budget Administrator for review and approval.
  3. The PI is responsible for certifying their own effort as well as employees and students on their grant.
  4. Once the form has been reviewed and approved, the form is forwarded to the Director of Grants and Sponsored Research, Newman Hall.

Office of Grants and Sponsored Research (OGSR) and Business Affairs

  1. OGSR will review the forms for completion.
  2. OGSR will review the form for significant changes in effort from the original projections (as stated in the budget approved by the sponsoring agency) and review any modifications that may be required in the grant budget with the PI.
  3. OGSR will compare the actual effort reported to the amounts charged to the grants (through payroll distribution reports). Any significant variances will be reported to the PI and modifications, if any, identified.
  4. The Director of Grants and Sponsored Research shall sign and date the form only indicating that the form was completed by the employee.
  5. The Grants Manager in Business Affairs will review the effort form. The form will be signed and dated by the Grants Manager or proxy and a copy will be kept and the original forwarded to OGSR.
  6. OGSR will maintain the originals in the respective grant file to ensure compliance. 

St. John's University, New York
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