Effort Reporting at High Profile Research Universities

Policies, Procedures, and the Impact of the Latest OMB Uniform Guidance

Topics: Research Enterprise, Research Administration, Effort Reporting, Post-Award, Research Compliance, Pre-Award

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This research brief primarily examines the effort reporting policies and procedures currently in place at high-profile research universities. The procedures discussed include the roles and responsibilities of personnel, the general reporting process, the certification process, and tools and systems involved. Additionally, the report explores the impact of the latest OMB Uniform Guidance on institutions’ current policies and procedures.

  • Key observations from our research:

    1. Effort reporting requires administrators to document the total compensation for individuals employees who earn salaries or wages charged to federal awards.

    2. All of the institutions ranked in the top 30 institutions by research and development expenditures have a university-wide effort reporting policy.

    3. The Office of Management and Budget’s (OMB) new Uniform Guidance located in 2 CFR 200.430, commonly referred to as time and effort reporting, is considered by many as a compromise between previous requirements and desired reductions of the administrative burdens placed on institutions.

    4. The majority of institutions do not plan to alter their current effort reporting policies and practices pending the results of future effort audits from the Office of the Inspector General, as this will help administrators determine federal expectations related to the documentation of compensation charges to federal sponsored projects and associated internal control systems.

    5. Most administrators use estimates from award proposals to initially report the proportion of time employees anticipate devoting to sponsored projects compared to their other activities.

    6. Administrators in both the central Office of Sponsored Programs and school- or department-level coordinators work closely together to orchestrate a comprehensive, but streamlined effort certification process .

    7. Administrators can ensure compliance with current requirements as presented in the new Uniform Guidance through the utilization of effort reporting system technologies to verify effort reports in a timely manner through automation and structured mechanisms.