Costing Issues

COGR provides an in-depth analysis of how universities address federal requirements for effort reporting related to compensation on federally funded research awards. Triggered by recent audit findings and heightened oversight, the paper explores the relevant federal guidance—principally OMB Circular A-21 and A-110—and highlights the inherent challenges universities face in accurately tracking and reporting faculty and staff effort given the complex and flexible nature of academic roles. The guidance accommodates the reality that research and teaching activities are often commingled, making precise assessments of effort impractical, and thus allows for estimates within reasonable tolerances. The document details standard approaches in use, such as plan confirmation and after-the-fact methods, providing concrete examples of institutional adaptations and the mechanisms used to certify effort while maintaining compliance. Key issues discussed include the complexity of certifying effort in academic medical centers with multiple payroll sources, the challenges in verifying committed versus actual effort, and compliance with salary caps (such as the NIH cap). The document notes that while flexibility is a strength—permitting various institutional practices and minimizing administrative burden—the lack of standardized definitions and practices also introduces ambiguity and potential for non-compliance. Overall, the document underscores the ongoing tension between the need for accountability and the necessity for practical, adaptable systems in a diverse academic environment, while acknowledging the evolving landscape shaped by increased scrutiny from federal auditors and the resulting adjustments by universities in their effort reporting systems.