Policy Number: IV-1
Last Reviewed: June 10, 2025
Responsible Dept.: Grants Development & Special Projects
A signed copy of this policy is available in the President’s Office.
Purpose:
To ensure that all wages and other personnel compensation charged to projects sponsored by federal, state, or other public or private funding sources are consistent with the actual percentage of time and effort given to each such project as supported by certified records. Funding agencies require reasonable assurances that labor costs charged to a grant project reflect the actual effort expended on the project.
Definitions:
Effort: Is the amount of time spent on a particular activity. It includes time spent on a grant project in which salary is charged directly or time contributed but not paid, including match and leverage. Individual effort is expressed as a percentage of the total amount of time spent on work-related activities for which the college compensates an employee. Effort reporting is the method of certifying to the federal granting agency that the effort charged to each grant award has actually been completed.
Effort report: Is the method used to verify the effort expensed is in compliance with the grant. Effort reports are based on percentage on grant programs regardless of hours worked. They are not based on hours. Example: 10% effort equates to 4 hours in a 40-hour week. Salary and effort are not the same. Salary distributions distribute salary costs based on budgeted amounts; effort reporting confirms the time dedicated to those activities and ensures that the actual overall effort expended is at least equal to the expected effort described in the project proposal and budget.
Cost Objective: Is the designation used to define the specific purpose for which costs are incurred and therefore, from which funding source an employee’s time can be charged. A single cost objective means an employee’s entire time is dedicated to one specific grant or project, while multiple cost objectives indicate time is split across different projects or grants.
Policy:
Any employee whose salary (wage) is funded in whole or in part by grant funds is required to complete an effort report form. This is required by the Office of Management and Budget (OMB), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), as well as other federal requirements for certifying effort expended on grant awards. 2CFR, Part 220, Cost Principles): Subpart E §200.430 (Compensation-Personnel Services) of the Uniform Guidance includes the federal regulatory requirements for compensation for personal services.
The OMB Uniform Guidance requires that allocation of salaries will be accomplished by a method which will be in accordance with the criteria in Uniform Guidance, will produce an equitable distribution of charges for the employees’ activities, and distinguishes employees’ direct activities from the facilities and administrative activities.
Under 2 CFR 200.430, charges to federal awards for salaries and wages must be supported by records that accurately reflect the work performed. These records must:
- Be supported by a system of internal controls ensuring accuracy and proper allocation.
- Reasonably reflect the employee’s total activity.
- Include all activities, both grant-related and non-grant-related.
- Be signed by both the employee and their supervisor
Failure to comply with this requirement will result in questioned costs and the possibility of returning grant funds with financial penalties.
While the OMB Uniform Guidance is the authoritative source for federal grants, non-federal agencies may also refer to OMB Uniform Guidance. Therefore, employees expending effort on any grant project, federal and non-federal will be included.
Procedure:
Time and effort will be reported on a standard effort report form and must be submitted on schedule and be signed by the employee and the principal investigator/supervisor. If the principal investigator is the employee completing the effort report, a dean must certify the percent effort level. The employee and principal investigator/supervisor signature certify that the effort report is accurate.
Faculty, and full- and part-time staff whose salary is paid in whole or partially by grant funds must indicate the percentage of effort devoted to the total grant activity and note other non-grant activity to reflect a total 100% of work committed by an employee.
If a faculty or staff member is involved in more than one grant, or a faculty member has release time and a portion of their salary is charged to a grant, they will submit a single effort report highlighting the separate and committed effort, and grant activities for each individual grant, or the grant and teaching responsibilities.
Effort reports will be completed and signed after the fact (never in anticipation of work to be performed).
Signed copies of the effort reports either a hard copy or by scanned pdf attachment to an email, are to be sent to the Grants Office for review and filing. The project director/supervisor should also keep a copy of each report. Copies should be maintained for five years from the final date the grant ends.
The effort report will be reviewed semiannually by the Grants and Finance Office for compliance.
The Grants Office will provide effort reporting training to every new project director and employees involved in external projects, which will be included in the Initial Grants Management Meeting.
Frequency of Reporting
Effort reporting ensures that employees are compensated accurately for time spent on grant-related activities (cost objectives). The requirements vary depending on the type of contracted employment and the number of cost objectives an employee works on.
Faculty
Faculty participating in grant activities and funded under a single cost objective (100% funded by a grant), must submit an effort report to the Grants Office no later than 10 days following the end of each semester (fall, spring and summer). Faculty participating in grant activities or working on multiple cost objectives (multiple grants or split duties) submit monthly effort reports to the Grant Office no later than the 10th of the following month. This includes faculty on grant funded release time. This report will detail the percentage of time spend on each cost objective (grant vs. teaching), reflecting the actual work distribution across projects.
Classified Staff
Full-time and part-time classified staff must submit an effort report monthly, due to the Grants Office by the 10th of the following month, noting 100% of effort and accounting for both grant and non-grant funding activities.
Student Workers
Students approved to participate on grant projects under the personnel category must submit time sheets as certification and documentation of effort spent on a project. Time sheets for students are retained by the project director responsible for the grant project. A detailed list of duties must be included in the student worker’s job duties.
Reviewed/Revised: 8/2013, 4/2021, 5/2025
