As a recipient of external funding, the University is required to demonstrate that the payment of salary and wages from external funds is consistent with records which accurately reflect the work performed. As such, the University has in place systems of internal controls to assure that compensation for personal services are accurate, allowable, and properly allocated to federal and non-federal sponsored activities.
The University of Houston’s Effort Reporting System tracks after-the-fact total activities, not to exceed 100% of the compensated activities covered by the Institutional Base Salary (IBS), for all employees working on federal and other sponsored projects. This system demonstrates to external sponsors that funding expended on the designated portion of an individual’s salary charged to a funded project is no greater than the individual's effort spent on that project.
Principal Investigators (PIs) must confirm for themselves and all others working on their project, that salaries charged to sponsored projects are consistent with the effort that was contributed.
The Federal requirement regarding effort reporting is outlined in the Uniform Guidance section §200.430, Compensation-personal services. It states that the standards for documentation of personnel cost charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, and that these records must:
- Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
- Be incorporated into the official records of the non-Federal entity;
- Reasonably reflect the total activity for which the employee is compensated by the University, not exceeding 100% of the IBS;
- Encompass both federally assisted and all other activities compensated by the University on an integrated basis (teaching, research, administrative);
- Comply with the established accounting policies and practices of the University for Additional Compensation.
- Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
- Budget estimates alone do not qualify as support for charges to Federal awards
Frequency of Effort Reports
The University of Houston issues effort reports on a quarterly basis for all Principal Investigators and other employees paid on sponsored projects or contributing effort towards it. Below are the effort reporting periods. The certification completion for each period depends on timeframe of the initiation and release of the reports.
|1||September 1 - November 30|
|2||December 1 - February 28|
|3||March 1 - May 31|
|4||June 1 - August 31|
Timing and Responsibility
Each department is responsible for establishing business processes to certify effort reports. The Department Business Manager is responsible for working with the PI and for follow-up to ensure effort forms are certified.
|Time Frame (180 days)||Responsibility|
|Correction - 90 days||Cost center financial reconcilers have 90 days after the close of every fiscal month to make necessary adjustments to payroll in accordance with the university’s Manual of Administrative Policy and Procedure (MAPP) which allows 90 days for expenditure review and correction.|
|Configuration – 30 days||The Office of Contracts and Grants (OCG) has 30 days after the correction period, to work with the Human Resources Department (HR) to bring payroll data into MAXIMUS and configure effort reports. During this period, OCG is also responsible for auditing reports that are subject to salary caps and other salary limitations.|
|Pre-review – 30 days||The Department Business Managers (DBA) has 30 days to review the effort forms and send them to the certifiers. OCG will send out an email notification to the DBAs when the forms are ready for pre-review.|
|Certification – 30 days||The PIs have 30 days to certify the effort forms. During certification, the PI can verify and update cost share contributions to projects.|
|Recertification||An effort form may be re-certified after the initial certification with sufficient back up documentation for the payroll reallocation justifying the recertification.|
References and Associated Links to the Effort Guidance
- Institutional Base Salary (IBS)
- Salary Cap Limitation for DHHS award including NIH
- Cost Sharing Policy
- Cost Transfer Policy
- MAXIMUS – Effort Reporting System