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Time and Effort Certification Policies and Procedures for Sponsored Programs

I. Background

In accordance with Federal requirements (§200.430) prescribed by the Office of Management and Budget (OMB), charges to Federal awards for salaries and wages must be based on records that provide reasonable assurance that the charges are accurate, allowable, and properly allocated. In order to receive and maintain eligibility for funding, sponsoring agencies require organizations to gather documentation to substantiate that the level of salary or wages charged to Federal awards is commensurate with the effort expended.

II. After-the-Fact Certification Reporting

The College utilizes an “After-the-Fact” reporting system to comply with the federal effort certification requirement. Under an after-the-fact system, distribution of salaries and wages for employees working on externally-funded projects will be supported by effort certification reports. Time and effort certification reports reflect an after-the-fact reporting of the actual percentage distribution of activity of employees.

III. Employee Effort Certification Reporting Policy and Procedures

Employees working on Federal awards are required to adhere to following procedures on Effort Certification:

  • Faculty and exempt employees will be asked to report the percent effort for all federally sponsored activity and curricular activities (i.e., instruction, administration, advising, etc.) using the Hood College Time and Effort Report form. Note: Hourly employees and student workers are not required to complete a report as their time is certified via electronic time sheets.
  • Time and Effort Reports will reasonably reflect the percentage distribution of effort by faculty and exempt employees charged to federally funded projects. Effort is not determined based on a 40-hour week but rather as a percentage of total employment activities. 100% effort is an employee’s total hours actually spent on work within the scope of his/her employment activities. The report includes activities for which the employee is being compensated, both sponsored and non-sponsored, within a given time period. The purpose of the report is to certify the level of effort expended on these activities.
  • Employees should provide an account of all effort expended on a sponsored activity, even if the sponsor did not compensate the employee for that activity, which constitutes “cost sharing.” This can occur on a mandatory or voluntary basis. Mandatory cost sharing occurs when it is required by the sponsor at the time of application. Voluntary cost sharing represents additional effort expended on a project that is not required by the sponsor. Although it is the College’s practice to minimize voluntary cost sharing, the Principal Investigator must record all effort expended on their projects regardless the source of compensation.
  • Faculty and exempt employees will complete and sign the Time and Effort Report. Principal Investigators / Project Directors (PI/PD) are required to verify the accuracy of information provided by employees working on the grant. Time and Effort Reports are required annually and at the completion of a grant. The Time and Effort Report is available on the Hood College website and completed forms are to be submitted to the Controller. The PI/PD is responsible for sending the form to any other faculty or administrative employees working on the grant and ensuring the forms are completed.
  • Completed Employee Time and Effort Reports are filed in the Accounting Office.