Uniform Guidance Requirements: Time and Effort Reporting Policy
The Uniform Guidance Subpart E §200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored awards. The University’s practice is to utilize an after‐the‐fact effort reporting system to certify that salaries charged, or cost‐shared to sponsored awards, are reasonable and consistent with the work performed. Section §200.430(c) states, “It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to Federal awards for IHEs (Institutions of Higher Education) a precise assessment of factors that contribute to costs is therefore, not always feasible, nor expected.” Failure to comply with the OMB Uniform Guidance effort reporting requirements can result in serious penalties for the individual certifying to effort and/or the University. This can include financial audit disallowances and in some cases criminal charges may be brought against an individual certifying to a falsified effort report. It is therefore incumbent on the University and individuals certifiers to maintain and document how individuals spend their time on all sponsored awards. The semi‐annual Time and Efforts Reports are the primary means for complying with the federal regulations relating to effort certification.
As a recipient of federal Funding, Seton Hall University is required to comply with the Office of Management and Budget Circular Uniform Administrative Requirements, and Audit Requirements for Federal Awards (“Uniform Guidance”). In compliance with these standards, this policy establishes the requirements of and includes the procedures for recording and reporting time and effort. This policy applies to all regular full‐time faculty, administrators and staff of the University whose compensation is charged in whole or in part to sponsored awards of any type (including non‐federal sponsors) and/or who provide cost‐shared efforts to sponsored awards. This policy applies to all University regular full‐time faculty, administrators and staff whose compensation is properly chargeable in whole or in part to a sponsored award of any type.
The University uses an after‐the‐fact effort reporting system to meet the OMB Uniform Guidance requirements for reporting effort. Under this method, the reporting will reflect the percentage of distribution of the employee’s activity during the period of reporting.
Time & Effort reports will be submitted twice yearly
- The first report will cover the period July 1 – Dec 31.
- The second report will cover the period July 1 – June 30.
Uniform Guidance standards for reporting effort:
- Effort reports will reflect the distribution of activity expended by employees.
- The effort reports will reflect an after‐the‐fact reporting of the percentage distribution of activity of employees.
- An individual’s workload will reflect categories of activities expressed as a percentage distribution that must add up to 100% total effort.
- Efforts reports will be based on an employees’ academic base salary and will also include any additional compensation received for the academic year or summer for effort on any sponsored awards. Additional compensation for teaching or service will not be included.
- The system will provide for modification of an individual’s salary or salary distribution, commensurate with any significant (over 5%) changes in the employees activities.
- Department of Finance
Approved by the Division of Finance.
November 7th, 2017