This document from the Council on Governmental Relations (COGR) offers an in-depth analysis of federal requirements and university practices regarding effort reporting for salary and wage charges on federal research awards. It highlights the growing scrutiny from federal auditors concerning compensation on grants, prompting both agencies and higher education institutions to reevaluate and, in some cases, revise their reporting systems. The federal guidance, primarily OMB Circular A-21 and A-110, stresses flexibility, acknowledging the intertwined nature of research and teaching activities and permitting reliance on reasonable estimates rather than precise timekeeping. The document outlines key federal expectations: that salary charges reflect actual work performed and adhere to institutional policies, verified through official payroll or activity distribution systems. Notably, the term “effort reporting” does not explicitly appear in federal guidelines; instead, the focus is on substantiating that compensation corresponds to work conducted under grants.
Universities have responded with a variety of methods, including plan confirmation (forward-looking allocations verified by annual statements), after-the-fact activity records (retrospective reviews and certifications), and multiple confirmation systems. These approaches are exemplified by case studies and supported by internal review practices to ensure integrity and compliance. The document also details significant challenges, such as handling multiple compensation sources (especially in clinical settings), defining who is responsible for certifying effort, dealing with salary limitations like the NIH cap, and reconciling committed versus actual effort amid dynamic academic responsibilities. The guidelines’ strengths lie in their adaptability to diverse institutional environments and avoidance of rigid hourly reporting, yet they are hampered by ambiguities (such as in defining effort) and inconsistent standards across institutions. Overall, while current federal requirements and university responses strive for both compliance and practicality, ongoing debate and audit scrutiny indicate the need for continued refinement and clarity in effort reporting practices.
