The document is a formal response by the Council on Governmental Relations (COGR) to the A-21 Task Force regarding the federal requirement for effort reporting under OMB Circular A-21 and proposes its discontinuation. COGR argues that the current effort reporting system does not effectively or efficiently demonstrate compliance with federal cost principles, but instead imposes significant administrative burden and cost on research institutions and faculty without adding meaningful value. The document recommends that research institutions should be allowed to rely on their own compliance-based payroll distribution systems, underpinned by robust internal controls, to track and allocate payroll charges to federally funded projects. These systems, tailored to each institution’s business practices and supported by preventive, ongoing, and detective controls, are viewed as more appropriate for ensuring compliance than the prescriptive effort reporting framework.
COGR outlines a model framework for payroll distribution compliance, emphasizing flexibility, strong financial management practices, and ongoing internal review and audit. The proposed approach shifts the focus from standardized, after-the-fact effort certifications to proactive management of payroll allocation, verification, and audit processes, thereby fostering faculty productivity and reducing regulatory overhead. The model incorporates principles such as integration with institutional ledgers, electronic reporting, periodic reviews, reliance on responsible oversight personnel, and regular audits. COGR further recommends urgency in implementing policy changes, possibly through an OMB Clarification Memorandum and a phased institutional rollout. The Appendix provides draft amendments to Circular A-21 to codify these changes, dispensing with most prescriptive examples in favor of standards based on institutional best practices and mutually agreed-upon methods of verification. The overall objective is to support accountability in federal research funding while minimizing unnecessary compliance costs and administrative complexity.
Discontinuation of the Effort Reporting Requirement, November 2011.
for the proposal.
