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Effort Reporting

Chapter 7080
Revised March 4, 2025

Table of Contents

.010 General Information
.020 Effort Reports
.030 Certification of Effort Reports
.040 Importance of Accuracy and Timeliness
.050 Questions
Sample Forms:
.100 Effort Report

.010 General Information

Office of Management and Budget Code of Federal Regulations 2 CFR 200 Subpart E, Section 200.430(i) contains the federal regulatory requirements that institutions of higher education must account for 100% of the compensated activities of each employee and to prepare and maintain documentation to verify the specific faculty and staff time devoted/committed to a sponsored project that shall be commensurate with the effort expended, whenever the payment for such time is directly charged to  or claimed as cost sharing for a sponsored project.

Time directly charged to a sponsored project is the amount of an employee's allocable time spent working on a sponsored project where payment for that time is from that project's funds.

Time committed as cost sharing is time spent working on a sponsored project during the project or program period, but where the payment for that effort is from KSU funds (non-project, non-federal funds). Cost sharing is defined by the Federal Government in 2 CFR 200 Subpart A, Section 200.1  as follows "cost sharing or matching means the portion of project costs not paid by Federal funds or contributions (unless otherwise authorized by Federal statute)." Additional information regarding federal cost sharing requirements can be found in 2 CFR 200 Subpart D, Section 200.306.

Cost sharing commitments are made at the time of the proposal submission. If the proposal is awarded, the institution is then obligated to meet those commitments (“committed cost share”). Federal regulations require that only committed cost shared effort be certified. Uncommitted cost sharing (effort that was spent on the project but was not included as part of the proposal or award) and non-effort-based commitments, such as equipment or supplies, are not part of effort certification.

.020 Effort Reports

Effort Reports are the method deployed by institutions of higher education to meet the federal reporting and documentation requirements and are prepared for each employee which had cost sharing reported and/or had salary directly charged to a sponsored project during the reporting period.

K-State must maintain an effort reporting system that:

  • Encompasses all employee activities (100% effort).
  • Confirms effort expended after-the-fact.
  • Requires certification to be performed by an individual who has first-hand knowledge or used suitable means of verification to determine if the work was performed.
  • Requires certification to be encompassed in the institution’s official records.

Effort associated with non-sponsored University activities will be aggregated for the purpose of certification while committed sponsored project effort will be certified at the account/project level through Effort Reports or payroll records, as the case may be.

The reporting periods coincide with academic semesters and will approximately match the following schedule: January through mid-May, mid-May through mid-August, and mid-August through December.

The Office of Sponsored Programs (OSP), Sponsored Programs Accounting team will send Effort Reports to departments approximately three weeks after the end of the last payroll period and cost share period in a semester.

.030 Certification of Effort Reports

The Effort Report identifies which sponsored and non-sponsored activities funded an employee, which should reflect how an employee spent their time during the reporting period.  Detailed instructions for verifying Effort Reports are located on the Office of Sponsored Programs webpage, including a sample Effort Report.

If any information on the Effort Report under review is incorrect, the department should either contact the OSP Sponsored Programs Accounting team, to make cost share corrections or contact the Division of Human Resources to make timely payroll corrections. It should be noted that federal auditors consider an extensive amount of payroll transfers to be an indication of deficient internal controls and could trigger more in-depth audit analysis to determine the underlying cause of excessive project cost transfers.

Each Effort Report must be certified by the employee or the individual responsible for that employee's time.   Title 2 Code of Federal Regulations (2 CFR), part 200.430 (formerly OMB Circular A-21), indicates that "Reports will reasonably reflect the activities for which employees are compensated by the institution. To confirm that the distribution of activity represents a reasonable estimate of the work performed by the employee during the period, the reports will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed."  Personnel Specialists, Accountants and other Administrative Officers are not considered by the federal government to be suitable “certifiers” for employees’ time and effort and therefore, certification signatures from these staff would not meet regulatory requirements.  Further, Federal auditors have also indicated that stamped or initialed signatures are not an acceptable means of certification.

For clarity, the federal government considers “certification” to mean the assertion by a PI/faculty or responsible official that the salaries charged to sponsored projects as direct charges or as committed cost sharing reasonably reflects the effort expended and work performed during the reporting period. Certified Effort Reports should be returned to OSP Sponsored Programs Accounting team by the due date printed on the report.

.040 Importance of Accuracy and Timeliness

Federal auditors will use Effort Reports and substantiating institutional records to audit and approve or disapprove federal payments to Kansas State University. Therefore, it is very important that the reports be prepared and reviewed carefully, accurately, and on a timely basis.

Failure to certify effort accurately and on a timely basis may result in the charge being disallowed by the federal agency funding the research. K-State is committed to ensuring that Effort Reports made in connection with federally sponsored agreements are accurate, timely, reasonably reflect the actual level of effort expended, and comply with all federal requirements. K-State is further committed to ensuring that Effort Reports are certified within 120 days of the end of the reporting period, in compliance with federal requirements. Each department is responsible for establishing a business process to certify Effort Reports on a timely basis. If certification is past due, OSP SPA will implement Effort Report escalation processes and work with departments who must follow up with their PIs and other certifiers to ensure that the delinquent effort reports are certified as quickly as possible. Effort Reports that are not certified within 120 days may result in action being taken by the campus, in response to federal agency penalties, including the reversal of the charges on the award, limiting submission of future proposals, requiring a proposal to be withdrawn, and/or jeopardize the acceptance of future awards and lastly, result in departmental funds having to cover disallowed or unsubstantiated project expenditures.

.050. Questions

Questions on this chapter should be referred to the OSP Sponsored Programs Accounting team at spaaccts@k-state.edu.