9.1 Time and Effort Reporting in Grant-Sponsored Programs
Related Policy from the Code of Federal Relations: Code of Regulations 2CFR200.430
Purpose: To define time and effort documentation requirements and to provide a process for faculty and staff to complete appropriate forms to comply with Federal regulations.
As a condition of receiving federal awards, Normandale is required to certify the time and effort spent by faculty and staff who work on federally funded grant projects. Normandale’s time and effort reporting policy and procedures are designed to meet federal requirements and Minnesota State auditing standards. Failure to adequately document time and effort on grant awards could result in financial penalty, the imposition of special conditions on Normandale’s public grant-funded programs, or other sanctions. In addition, it could jeopardize Normandale’s ability to secure future funding.
Part I: Definitions
Subpart A: Effort is defined as the time spent on any professional activity by an individual. It is expressed as a percentage of total effort for the college. The sum of all of an individual’s effort percentages must equal 100%.
Subpart B: Total college effort is the total amount of time spent by an individual on all professional activities for the college. This is not necessarily based on a 40-hour week but is instead based on the total hours spent on all work-related duties.
Subpart C: Cost-share effort represents the portion of total time spent by an individual on grant-funded projects that is not paid for out of grant funds. Cost share (or match or in-kind) effort is paid by the college or other sources rather than the public funding agency. Cost sharing may be required by the funding agency or may be voluntarily committed by the institution. In either case, the effort committed to the project must be included in time and effort reporting.
Subpart D: Effort reporting is the method of complying with federal requirements outlined in 2 CFR 200.430. Federal grantees must maintain records that accurately reflect the work performed and:
- be supported by a system of internal control to provide reasonable assurance that the time being charged is accurate, allowable, and properly allocated
- be incorporated into the institution’s official records
- reasonably reflect each employee’s total activity
- provide time or percentage spent on all federally funded and non-federally funded activities, for each employee
- comply with the institution’s pre-established accounting practices and procedures.
The uniform grant guidance recognizes that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to grant awards for Institutions of Higher Education, a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected1. Time and effort reports should therefore reasonably reflect the activities for which an employee is compensated and must represent the percentage distribution (not to exceed 100%) of activity for that employee.
Normandale uses the plan confirmation reporting method to certify effort on a semi-annual reporting cycle and to confirm that the reported effort reasonably reflects the amount of effort expended on grant related activities during the reporting period. Under this method, the distribution of salaries and wages of professorial, professional, and other staff applicable to sponsored agreements is based on budgeted, planned, or assigned work activity and updated to reflect any significant changes in work distribution.
Part II: Responsibilities
Subpart A: Principal Investigators/Project Directors
Principal Investigators (PIs) and Project Directors (PDs) are responsible for ensuring that all individuals working on grant-funded projects complete time and effort reporting in a timely manner. The PI/PD is responsible for reporting to the Office of Grants and Sponsored Projects and Human Resources on all individuals receiving release time, reassignment, or overload assignment for grant-funded projects, including in-kind effort as identified on the grant budget.
The PI/PD is responsible for collecting and maintaining files of the original time and effort reports per record retention requirements for the grant and Minnesota State and for providing copies to the Office of Grants and Sponsored Projects within the timeframe identified.
Subpart B: All Individuals working on projects supported with federal grant funds
All individuals working on federally funded grant projects must submit time and effort reports, regardless of whether their salary is paid with grant funds. Time and effort reports must be completed for all employees paid through grant funds, even if their position is 100% paid by the grant. Time and effort reports must account for all of an employee’s time, not only the portion paid for by the grant.
For all employees (professorial2 and professional3 and all other employees4) the reports should be prepared semi-annually. For non-exempt employees, additional documentation should be maintained on an ongoing basis to coincide with Normandale’s bi-weekly pay periods.
Individuals completing time and effort reports must return the signed form to the PI/PD no later than 30 days after the end of the reporting period. Forms must be signed and dated in ink or official e-signature by both the employee and their supervisor. The PI/PD will retain the original, signed Time and Effort Forms as part of the grant file.
Subpart C: Office of Grants and Sponsored Projects
The Office of Grants and Sponsored Projects will oversee compliance for Normandale’s time and effort reporting and provide training for new PIs/PDs and key personnel on grant-funded projects.
The Office of Grants and Sponsored Projects will provide time and effort forms to PIs/PDs for transmittal to individuals working on federally funded grant projects and confirm to the Vice President of Academic Affairs receipt of all certified forms by the due date.
The Office of Grants and Sponsored Projects will review certified time and effort forms and notify Fiscal Services and Human Resources if time and effort reports indicate a deviation of more than 10% from the projected budget.
Subpart D: Fiscal Services
Fiscal Services will work with Human Resources to ensure appropriate payroll adjustments are made in cases where a deviation in time and effort reports is greater than 10% compared to the projected budget.
Policy History:
Date of Adoption:
Date of Implementation: 12/2016
Department / Owner: Grants
Date and Subject of Revisions:
Next Review Date: 12/01/2020