The Council on Governmental Relations (COGR) document offers a comprehensive analysis of federal policies, regulations, and institutional practices governing salary compensation, effort commitments, and certification at U.S. research institutions involved in federally funded research. Stemming from high-profile audit findings and significant financial settlements, the report emphasizes the urgency of clarifying compliance expectations to safeguard the integrity of research funding while maintaining the regulatory flexibility essential for advancing scientific inquiry.
A central theme of the document is the pivotal role of accurate compensation and effort reporting, given that salaries and related benefits constitute the largest portion of direct research costs. The report traces the historical evolution of effort reporting regulations, notably OMB Circular A-21, outlining the intricate responsibilities of faculty, administrators, and institutional leaders. Institutions are required to maintain clear, consistently applied policies regarding base and supplemental pay, full workload definitions, and the management of special circumstances such as consulting, summer salaries, multiple appointments, and vacation policies. The report highlights enduring ambiguities in federal guidance and the practical challenges faced by institutions in defining allowable practices, managing multiple funding sources, and addressing special federal awards with unique requirements, such as NIH K Awards and salary cap restrictions.
The document advocates for institutional autonomy in designing effort reporting mechanisms tailored to each institution’s mission, provided these systems align with federal requirements. It details recognized methodologies for effort reporting—such as Plan Confirmation and After-the-Fact Activity Records—while underscoring the necessity of a transparent, auditable connection between payroll records and effort certification. Robust internal controls, after-the-fact confirmations, and systematic documentation are deemed essential for compliance. The report also stresses the importance of proper handling of cost sharing, reconciliation of reported effort with payroll charges, prompt adjustment procedures, and routine independent evaluations of reporting systems.
Education and ongoing training for faculty and administrators are identified as critical to sustaining compliant systems, reducing administrative burden, and ensuring that compliance processes support, rather than impede, the core missions of research and education. The document concludes by urging sustained dialogue and partnership between institutions and federal agencies, promoting clear, pragmatic, and well-communicated standards. Ultimately, it calls for a balanced approach that upholds rigorous accountability and oversight, fosters mutual trust, and advances the nation’s research enterprise.
to view the full document.
to view the Executive Overview.
