The United States Office of Management and Budget issued OMB Circular A-21
, Cost Principles for Educational Institutions. A-21 contains regulatory requirements for acceptable methods of certifying time worked on sponsored projects. A-21 requires universities to maintain effort-reporting systems (time certifications) for employees working on federal projects. The effort reporting system provides the principal means for certifying that salaries and wages charged to sponsored projects are consistent with the effort actually spent working on the projects. Time certifications represent a reasonable estimate
of an employee’s effort. A-21 states, “In the use of any methods for apportioning salaries, it is recognized that, in an academic setting, teaching, research, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate.”
The University has a planned confirmation system to certify that salaries charged or contributed to sponsored projects are reasonable and consistent with the work performed. 100% of an individual’s effort is identified to specific cost centers in the Payroll system based on estimates of planned activities. The individual’s effort distribution is adjusted for any significant changes in actual work performed. A significant change is 5% or more of the total workload. Effort is certified at the end of specified reporting periods by the employee or a responsible official who has suitable means of verifying the activities performed by the employee. Each department has primary responsibility for compliance with this standard. PI’s and other department personnel are responsible for ensuring salaries charge appropriately.
Effort is measured as a percent of the individual’s total University employment obligation. Percent effort represents the proportion of time an individual spends on each University activity and is expressed as a percent of the individual’s total University activity. Total University activity = 100% effort. The percent effort is not based on a typical 40-hour workweek. Total University effort is 100% whether a typical workweek is 20 or 60 hours. Total effort may not exceed 100% and should include only those activities for which an individual receives University compensation, including work performed on sponsored projects, whether reimbursed by a sponsor or University funded.
For questions regarding effort reporting or the online ERS system, please contact Jerome Moses at 215-895-6327 or firstname.lastname@example.org