Effort Reporting

Effort Reporting Policies and Procedures

Responsible Office: Sponsored Projects Accounting
Effective Date: updated November 2023

Introduction/Overview

Purpose

The purpose of this policy is to provide clarification on Federal policies with respect to effort reporting and to help ensure that all effort certifications are accurate and in accordance with sponsor requirements. The  Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR 200 (“Uniform Guidance”), provides principles for determining the costs applicable to grants, contracts, and other agreements with institutions of higher education. (Under the “terms of acceptance” of grants from the federal government, the college or university agrees to comply with the provisions of Uniform Guidance.) The Office of Management and Budget has assigned the Department of Health and Human Services (DHHS) as our federal cognizant agency for costing and financial management issues.

The Department of Health and Human Services follows the cost principles set forth in Uniform Guidance in establishing the acceptability of charges to grants and contracts. Section 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses of Uniform Guidance provides the federal regulatory requirements for internal controls over certifying time spent on sponsored projects. The University complies with this section by requiring periodic after-the-fact certification of effort by each individual whose salary is charged to a sponsored fund and/or cost sharing account during an effort reporting period.

Audience

This policy applies to all University employees who conduct or assist with the administration of sponsored project activities.

Policies

Requirements

Uniform Guidance requires the grantee to confirm that the payroll costs charged to the project are reasonable in relation to the actual work performed during the period. It is, therefore, the University’s policy that all faculty and non-faculty (other academics, staff and students) involved in allocating salaries and wages to sponsored funds and completing effort reports are responsible for understanding the principles of timely and accurate effort reporting.

Effort

Effort is defined as the proportion of time spent on any activity expressed as a percentage of the total institutional activities for which an individual is compensated by the University, regardless of part-time or full-time status and/or number of hours worked. Accordingly, Total Effort is always 100% whether a person is employed on a full-time basis by the University (Full-Time Equivalent or FTE of 1.00) or on a part-time basis (FTE less than 1.00). Compensation is based on an individual’s total Institutional Base Salary (IBS), as denoted in the University’s payroll system (i.e., Workday (WD)) – see section below for more detailed information.

For University’s faculty, total institutional effort/activity (100%) is not defined as a single, standard number of hours or days per week, since it will likely be different for each individual during the year. The number of hours in an individual faculty member’s “100%” must be reasonable and supportable to department, school, university and external reviewers, if requested.

Proposed Effort

When proposals submitted by the University identify a quantifiable portion of effort for an employee, that effort is considered to be a commitment to the project. The level(s) of effort committed to a project must be reasonable with the actual effort that each individual is expected to expend on the project during the relevant project period(s).  Principal Investigators and other key personnel for whom such commitments have been made are responsible for ensuring that the commitments are met and, if necessary, sponsor approval is obtained to reduce the commitment.

For proposal purposes, proposed level of effort must be expressed in accordance with sponsor requirements. Some sponsors require that level of effort be proposed in terms of person months (e.g., three person months of a 12-month appointment). Other sponsors expect the proposed level of effort to be expressed in percentage terms (e.g., 25% of total effort).

Federal granting agencies (and some non-federal sponsors) expect the Principal Investigator (PI) of any sponsored fund to devote some level of effort (>0%) towards his/her project. Certain types of awards such as equipment, instrumentation and training (T32) grants are normally excluded from this requirement.  Please click the University’s Cost Sharing Policy for additional information regarding cost sharing.

Effort During a No Cost Extension (NCE)

The effort commitment percentage of key personnel during a no-cost extension period is assumed to be consistent with the commitment for the immediately preceding budget period, unless otherwise communicated to the sponsor. If the effort commitment for key personnel is anticipated to change, prior approval requirements established by the sponsor would still apply (see section below entitled “Reduction of effort on a project:” for additional detail).

  • Per NIH Grants Policy Statement (8.1.1.3):  With the exception of grant programs that have an effort requirement, or where terms and conditions prohibit such reductions, NIH will not require prior approval for the reduction in effort for Senior/Key personnel. The recipient is reminded that active awards must have a measureable level of effort.
Effort Reporting

Effort reporting is the process by which the University confirms and documents that the salaries charged are reasonable in relation to the actual effort expended on sponsored projects during each effort reporting period. The methodology used by the University is an “after the fact” certification process based upon an individual’s institutional base salary.

Faculty and non-faculty are required to review, adjust as necessary and certify their effort via the Effort Certification module in WD. The WD Effort Certification module documents the proportion of effort devoted to sponsored projects and all other activities (e.g., instruction/teaching, department administration, patient care…),  expressed as a percentage of Total Effort.

When an employee certifies his or her effort for a reporting period, they are creating a legal document that states that the effort certified for the period is a reasonable approximation (see Level of Tolerance section below) of the effort actually spent on the projects/activities during the period.

Institutional Base Salary

Salaries and wages charged to sponsored funds are allowable at the Institutional Base Salary (IBS) rate. IBS is the annual compensation paid by the University for an employee’s appointment, whether that individual’s time is spent on research, teaching, patient care or other activities. The IBS does not include bonuses or other miscellaneous pay. An employee’s IBS may not be increased as a result of replacing University salary funds with sponsored project funds.  Refer to the Human Resource’s Base Salary and Additional Pay Guidelines.

For University faculty, IBS is established by each School via his/her annual appointment which includes regular salary associated with their academic appointment(s). IBS would also include secondary administrative appointments such as chair of a department, as applicable. The IBS would not include items such as:

  • Honorarium payments or patient care incentives/bonuses
  • Salaries and wages paid directly to an individual by another organization including but not limited to the Veterans Administration Hospital or the Howard Hughes Medical Institute
  • Income that an individual is permitted to earn outside of their University responsibilities such as consulting fees

In some programs/departments, stipend payments are made to individuals to provide for their living expenses during the training period of a fellowship or training program. These amounts are not salaries/wages for work performed, thus they are excluded from the effort reporting process.

Effort Categories and University Activities

Faculty and non-faculty perform a number of activities associated with their respective jobs or appointments. Uniform Guidance requires the University to maintain specific activity classifications within its payroll system. Accordingly, a general description of these effort categories is provided below.

Organized Research (FN00002): Research and development activities that are sponsored by federal agencies, non-federal /private organizations and industry is department research that is separately budgeted and accounted on a project basis and reviewed by faculty committees. Includes activities such as:

  • Activities related to the scope, goals and/or objectives of sponsored project (e.g., grants, cooperative agreements, subawards , contracts and other agreements)
    • Writing progress (technical) reports for existing projects
    • Holding a meeting with lab staff, colleagues and graduate students to discuss direction and progress of sponsored projects
    • Attending a scientific meeting/conference held by an outside professional society to present research results
    • Training of individuals/trainees in research techniques, commonly call research training (e.g., NIH T-32 & F-32 projects)

 Department Research (FN00011):  Activities related to internally funded research development and scholarly activities; scholarly and investigative activities that are typically non-project oriented; labor and/or material costs associated with working in a lab on an unfunded research project, postdoctoral research trainees and research fellows (stipends, fees, trainee tuition, health fees).  A significant factor in determining the difference between department research and other activities is intent – if the major purpose is investigative but the support does not meet the criteria for Organized Research (FN00002) the account function is departmental research and the labor is coded as departmental research. Typically, department research support is paid from a pool of internal funds and is not identified by project. 

Instruction (Teaching) (FN00001) :  All teaching, course development and training activities (lecturing, tutoring, supervising independent study or laboratory course work, preparing for scheduled teaching, grading papers, preparing for future courses, devising new instructional techniques, revising manuals, tapes, slides…)

  • Offered for credit towards a degree /certificate or on a non-credit basis
    • Offered through regular academic departments or separate divisions
    • Excludes – supervision of residents enrolled in an ACGME accredited program (see Graduate Medical Education category below)

Academic Administration (FN00015): Activities to provide support services integral to instruction, research or public service and not part of the Central Fiscal Unit (CFU). Includes administrative time for Dean, Department Chair, and Division/Section Chiefs; expenditures for non-administrative computing support, ancillary support, audiovisual services, academic administration personal development and course administration and supporting services that benefit common or joint departmental activities; departmental administrative costs must benefit two or more departmental activities or objectives. Includes activities such as:

  • Participation in school/department committees
    • Review of department accounts and financial statements.
    • Selection/training of general staff
    • Selection/recruitment of faculty
    • Selection of graduate students, medical students and housestaff
    • Planning for building projects or renovations
    • The activity cannot be directly identified with an organized research project, instruction, patient care, or hospital administration activity…

Other Sponsored Activities (FN00010):  Programs and projects sponsored by Federal and non-Federal agencies and organizations which involve the performance of work that does not fall under the classification  Instruction, Organized Research or Department Research .  Examples of such programs and projects are health service projects, federally funded clinical trials that occur in patient care space and community service programs.

Direct Clinical with Unit’s Generated (i.e., patient care) (FN00016):  Direct patient care services to individual patients normally eligible to be billed to Medicare, commercial insurance or the patient. Represents the unit-generating activity (e.g. RVU or time Units) time spent on activities that focus on directly identifiable patient care services for which a professional fee to a patient is generated. Includes inpatient, outpatient, procedural, surgical, laboratory-based, or outreach activity for which an Internal professional generating bill could be generated; additional time spent delivering patient care due to the presence and supervision of residents, fellows or medical students; follow-up and documentation time required supporting direct patient care; tumor boards, multimodality clinics in which the participating physician cannot bill; and medical staff, billing staff (compliance), coders, insurance precertification, and credentialing.

Direct Clinical Without Unit’s Generated (i.e., patient care) (FN00017):  Direct patient care services to individual patients that do not generate Units (RVU or Time Units). Includes inpatient, outpatient, procedural, surgical, laboratory-based, or outreach activity for which an internal professional generating bill could be generated, but is not because there is a contract for purchased services that provide clinical care. These agreements have a specific corresponding revenue source, but the billing is not done by WashU so no Units are generated; additional time spent delivering patient care due to the presence of residents or medical students; follow-up and documentation time required supporting direct patient care; tumor boards, multimodality clinics in which the participating physician cannot bill medical staff (if applicable).

Clinical Studies (FN00018):  Externally funded activities related to a human subject research projects that are not funded by a government agency and as determined by the Joint Research Office for Contracts (JROC) and administered by the Center for Clinical Studies (CCS).

Graduate Medical Education (FN00014):  Activities related to the supervision and instruction of persons enrolled in accredited intern, residency, and fellow programs; Program Directors, Associate Program Directors or appointments that take a significant portion of a faculties’ time in support of the GME; faculty and support staff recruiting, scheduling rotations, and other support activities; teaching clinical procedures; preparing for and leading grand rounds. Excludes time instructing residents or fellows in a non-ACGME accredited program.

Hospital/Community Services (FN00013):  Contractual agreements for specific medical direction services, hospital administration and medical management of hospital/community agency based clinical service lines without direct patient care; includes programs such as anesthesiology, radiology emergency medicine, infection control, and laboratory/pathology. These specific agreement have a corresponding revenue source (including internal billings). Excludes supervision of residents and direct services to patients.

Research Administration (FN00019):  Scholarly activities associates with research administrative and supporting services. Includes directing and managing research operations of a business area; time spent writing/preparing a grant proposal, supervising purchasing and other research functions; ensuring compliance with Federal and WU guidelines; time spent working on an IRB Protocol committee or other business area committees; research or grant administrators benefiting both organized and departmental research; preparation of competitive grant proposals; research proposal development includes searching for funding opportunities, managing internal grants, facilitating cross-discipline team science, and programmatic activities such as hosting federal agencies or informational events for grant resources. Research proposal development may be at the department, school or university-level.

Dedicated Research Staff Administration (FN00032):  Used by cost centers to record only those staff related costs incurred predominantly to conduct administrative functions in support of organized research but excluding any such costs charged directly to sponsored projects. These centers capture administrative expenses incurred to administer (Pre and post award) sponsored projects, including such activities as grant and contract administration (Federal and non-Federal), administration, and editing and publishing of research and other reports.  They include all or an allocation of salaries (via payroll sourcing or payroll cost allocations) and expenses for the supervision of, assistants to, and immediate staff engaged predominantly in organized research support activities.  Example job types: research administrators, grant specialists, grant project managers and other personnel who are dedicated to supporting grants.  A separate cost center to capture these expenses is strongly recommended but not required.  Faculty time spent on research administration should continue to be recorded under Research Administration (FN00019).  Any other activities and expenses not dedicated to administrative support of organized research should be recorded under Research Administration (FN00019) or Academic Support (FN00003) as appropriate.

A complete list of Function Worktag and corresponding definitions can be found in Collibra under Function Worktag{Value Set}.

Summer Research Salary

Faculty with academic year appointments (typically nine month appointments) may expend additional summer effort on one or more sponsored projects in the months not covered by their academic year appointment and earn additional compensation for that work. The additional compensation provided to the individual is called Summer Research (SR) salary and it is charged to sponsored funds during the months of June, July and August. A faculty member’s SR rate of pay may not exceed his or her monthly

base salary amount (rate of pay) for their academic appointment. For example, a faculty member with a nine month appointment and an academic year salary of $90,000 may not receive SR at a rate in excess of $10,000 per month. The SR should be distributed to the appropriate sponsored funds based upon the expected effort on those projects.  Effort related to the receipt of SR must be performed within the summer period (June, July & August); effort performed during the academic year prior to or after the summer does not count toward summer period effort commitments. For the purposes of expending and certifying effort, and charging the related additional salary for activity outside the appointment period, the expectation for activity in a summer research period is consistent with the expectation for activity in a commensurate academic period.

If non-sponsored activities related to the faculty member’s appointment are performed outside of the appointment period, they should not interfere with or reduce the faculty member’s ability to expend summer effort on sponsored projects for which he/she is earning SR. If the effort associated with any such non-sponsored activities could not reasonably be conducted along with sponsored activities, the faculty member has an obligation to limit and/or adjust, and likely decrease, summer salary on sponsored projects.

While reasonable personal time off may be taken during the summer, it is not appropriate to concentrate significant time off during a period for which the faculty member is receiving SR. For example, taking a three-week break (non-working) during July when the faculty member is 100% funded by a sponsored project/fund that month would not be considered appropriate.

All Summer Research salary payments must be processed in accordance with the sponsoring agency guidelines and/or individual award terms and conditions.  As a general policy, NSF limits the salary compensation requested in the proposal budget for senior personnel to no more than two months of their regular salary in any one year. This limit includes salary compensation received from all NSF-funded grants. This effort must be documented in accordance with 2 CFR § 200, Subpart E. If anticipated, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice. Under normal rebudgeting authority, as described in NSF Proposal & Award Policies & Procedures Guide (PAPPG)   II.D.2.f(i), an awardee can internally approve an increase or decrease in person months devoted to the project after an award is made, even if doing so results in salary support for senior personnel exceeding the two month salary policy. No prior approval from NSF is necessary as long as that change would not cause the objectives or scope of the project to change. NSF prior approval is necessary if the objectives or scope of the project changes.

Faculty with academic appointments who receive Summer Research from projects funded by the National Institutes of Health (NIH) can only charge salary based on the applicable NIH cap amount. The balance of the summer salary should be funded as cost sharing from non-sponsored sources. Detailed information on the NIH Salary cap may be found in the NIH Salary Cap Policy.

Secondary Administrative Appointments

In some instances, faculty may have a secondary administrative appointment and responsibilities (e.g., department chairs). The compensation associated with this administrative appointment is considered part of the individual’s institutional base salary and it will be included in the effort report.

Special care should be given to summer effort and pay for faculty members who have secondary administrative appointments. If the faculty member’s administrative appointment is a year-round (12- month) obligation, then he/she cannot commit summer effort associated with their administrative responsibilities to sponsored projects, nor can he/she request reimbursement from or charge sponsors for pay associated with their administrative appointments.  Departments are encouraged to submit proposals reflecting both appointments to ensure that the effort is submitted accurately.

Procedures

Payroll Costing

The salaries of faculty, staff and students working on a sponsored project should be designated /charged to the corresponding award/grant and/or related cost sharing allocation. The PI or their designee should initiate prospective and retro-active payroll costing modifications due to significant and on-going changes in work activity (e.g., receipt of a new award and start of that work, shifts in personnel or work assignments).  Updates and revisions to payroll costing should be documented, as necessary, per HR guidelines and/or department requirements. Annual review of sources by the Principal Investigator is also required and is outlined in the University’s Principal Investigator Salary Authorization Policy.

Within WD, payroll costing, charging and retroactive changes of salaries and wages on sponsored funds should utilize the appropriate IBS salary rate of pay, pay components (see Appendix A ) and the applicable departmental/school approval processes. Additionally, specific guidance regarding payroll costing in WD is available in the Payroll Costing Allocation Reference Guide. 

Frequency

All faculty, staff and students whose salary is charged, in whole or part, to sponsored funds (including cost sharing allocations) are required to certify their effort on a semi-annual basis.  The applicable certification periods are January 1st through June 30th, and July 1st through December 31st.

Timing

In accordance with the University’s agreement with the Department of Health and Human Services, the certification period is 30 days. All certifiers should certify within 30 days of the start of the certification period to ensure i compliance with this agreement.  Prior to the certification start date, the department administrators are provided a time period to review the data and process any necessary changes.  SPA will communicate the timing of this review period to the academic units.  Noted below is an example of that effort cycle.

  • January 23, 202Y – SPA kicks off the effort certification process by sending all effort reports to the Effort Reviewers for administrative review for the July – December 202X effort period (three weeks)
  • February 13, 202Y – Effort Reviewers need to release all effort reports to the certifiers for the July – December 202X effort period (start of 30 certification period)
  • March 14, 202Y – Effort reports must be certified by this date for the July – December 202X effort period
Certification

The University supports the effort reporting requirements through the online certification of an effort report. Certification is completed through the WD effort certification module via the individual’s Workday (WD) inbox under the heading ‘Effort Certification’. Certifiers will be notified via task to their WD inbox when the certification period has begun.  The effort report  displays the individual’s salary distribution grants/cost centers and the corresponding salary percentage for each grant/cost center as it relates to the total institutional base salary for all months in the reporting period.

For more information on the WD effort reporting module please visit Effort Certification for Faculty and Staff Reference Guide.
Suitable Means of Verification

It is the University’s policy that each individual complete his or her own effort certification.  If an individual is no longer with the University or is unavailable at the time of the certification period, a proxy who has suitable means of verification may certify on his or her behalf. The proxy certification requires the documented review by an appropriate individual, such as the Principal Investigator, project manager, or supervisor.  Noted below are some examples of that process.

Level of Tolerance (Precision)

Federal guidelines recognize that research, instruction, patient care and department administration activities within an academic / medical center environment are often “inextricably intermingled”, therefore, a precise assessment of the corresponding effort percentages may not be feasible.

Accordingly, faculty and non-faculty/staff are required to review, modify as necessary, and certify that the effort percentages on the effort report are a reasonable estimate of the actual work performed.  The University has deemed this level of tolerance to be +/- five percentage points.

If the actual effort performed on a sponsored project differs (positively or negatively) from the percentage noted on the effort report by:

  • 0 to 5%, no adjustment to the effort report is necessary. The effort percentage is deemed to be a reasonable estimate that is within the University’s level of tolerance.

Note: If the original needs to be revised (between 0 to 5%) per the employee, the Effort Reviewer can process those changes directly within the effort certification module.  

  • > 5% the payroll costing allocation should be revised   to reflect the correct effort percentage. The Effort Reviewer can process those changes directly within the effort certification module.
Significant change/Retroactive Changes

Reduction of effort on a project: Many sponsors require prior approval for significant reductions of effort by the PI and/or other key personnel. It is the PIs responsibility to be familiar with terms and conditions contained in the award and/or sponsor’s policies.  Sponsored Projects Accounting SPA) and the Office of Sponsored Research Services (OSRS) can assist with any questions concerning prior approval requirements.

For most federal awards, prior approval from the sponsoring agency must be obtained when a 25% or more reduction in effort devoted to the project by the approved project director (PD) or principal investigator (PI) is expected for a substantial time period. Noted below are the specific guidelines for the University’s two primary federal funding agencies. Please refer to the applicable financial management guidelines for other federal agencies, as necessary.

National Institutes for Health (GPS 8.1.2.6):  The University (recipient) is required to submit a prior approval request to the Grants Management Official (GMO) if:

  •  The PD/PI or other Senior/Key Personnel specifically named in the Notice of Award (NoA) will withdraw from the project entirely, be absent from the project during any continuous period of 3 months or more, or reduce time devoted to the project by 25 percent or more from the level that was approved at the time of initial competing year award (for example, a proposed change from 40 percent effort to 30 percent or less effort or in calendar months a change from 4.8 to 3.6 calendar months). Reductions are cumulative, i.e., the 25% threshold may be reached by two or more successive reductions that total 25% or more. Once agency approval has been given for a significant change in the level of effort, then all subsequent reductions are measured against the approved adjusted level. Selecting Yes in the RPPR constitutes a prior approval request to the agency and the issuance of a subsequent year of funding constitutes agency approval of the request.
  • There is a change from a multiple PD/PI model to a single PD/PI model.
  • There is a change from a single PD/PI model to a multiple PD/PI model.
  • There is a change in the number or makeup of the PD/PIs on a multiple PD/PI award.

NIH must approve any alternate arrangement proposed by the recipient, including any replacement of the PD/PI or senior/key personnel named in the NoA, and the addition of any new PD/PIs.

The requirement to obtain NIH prior approval for a change in status pertains only to those personnel NIH designates in the NoA regardless of whether the applicant organization designates others as senior/key personnel for its own purposes.

National Science Foundation:  If the PI/PD or co-PI/co-PD will devote substantially less time to the project than anticipated in the proposal, (defined in the Research Terms and Conditions (RTC) and NSF Grant Conditions (GC-1) as a reduction of 25% or more in time) he/she should consult with SPA. Requests for changes to the person-months devoted to the project must be signed and submitted by the AOR via use of NSF’s electronic systems. This request must be submitted at least 30 days before the proposed change, or as soon as practicable after the prospective change is known. If the recipient organization or NSF determines that the reduction of effort will substantially impair the successful execution of the project, the NSF Program Officer will consult the NSF Grants and Agreements Officer.  The NSF Grants and Agreements Officer may:

  • Request the University to nominate a replacement PI/PD or co-PI/co-PD acceptable to the NSF Program Officer;
  • Initiate the award termination procedures; or
  • Negotiate an appropriate modification to the grant.

Retroactive Changes:  Changes in payroll costing (workload) involving sponsored projects may not normally be made for any prior pay period after the effort has been certified.  Accordingly, it is very important that the effort report data is carefully reviewed prior to certification. In the exceptional situation in which it is found that the original certification was not correct, retroactive changes may be made. When the payroll accounting adjustments cost transfers are submitted, they should contain a detailed explanation and include how the error occurred and when it was discovered. The revised payroll costing may also require recertification of the effort (see below).

Recertification:   Subsequent to the initial certification by the faculty/staff member, if a PAA is processed that increases/decreases the salary charged to an Award(s), a recertification is required (regardless of amounts involved).  On a monthly basis, SPA will initiate the recertification process within WD.  The Effort Reviewers will receive a WD notification that a recertification has been generated and it’s ready for review/approval.  After the Effort Reviewer has reviewed/approved the recertification, the notification will then route to faculty/staff member.  The faculty/staff member should recertify the effort report within 30 days of their notification.  Note: PAAs that modify the salaries charged to Grant lines within the same Award does not require a recertification.

Training

Training on effort reporting is required for faculty, and strongly recommended for other University personnel, who work on sponsored funds. The University has developed effort reporting training videos and other reference materials that are available under the Resources and Training section. This data will be updated and expanded as necessary to ensure compliance.

Additionally, the Effort Certification for Faculty and Staff and the Effort Certification for Department Administrators Reference Guides contains additional material about effort reporting.

Roles and Responsibilities

Washington University is committed to the objective, ethical, and responsible conduct of research. A Roles and Responsibilities document is maintained to provide comprehensive descriptions of the duties of key individuals and organizational units that design, conduct, report, and/or support research activities at Washington University. This detailed set of information is available at http://research.wustl.edu/Resources/Roles/Pages/default.aspx. For the purposes of this document, the roles and responsibilities for the primary positions associated with effort reporting is also provided below.

Principal Investigator
  • Reviews, adjusts, and legally certifies the accuracy of effort reports for all applicable personnel.
  • Completes effort reports for unavailable personnel within deadlines and in accordance with federal regulations and university and sponsoring agency policies and procedures.
  • Assures that all key personnel involved in effort reporting have met training requirements in accordance with federal regulations and university and sponsoring agency policies and procedures.
  • Supports and endorses cooperation with University compliance and monitoring efforts related to effort reporting and reports instances of noncompliance to the appropriate compliance office.
Department Effort Reviewer
  • Assists Principal Investigator to review, adjust, and certify effort reports for all applicable personnel.
  • Cooperates with the University’s compliance and monitoring efforts related to effort reporting and reports instances of noncompliance to the appropriate compliance offices.
  • Primary contact for answering questions from department certifiers and coordinating with SPA
Department Administrator
  • Assists Principal Investigator to review, adjust, and certify effort reports for all applicable personnel.
  • Certifies the effort reports in a timely manner, in accordance with University policy.
  • Assists Principal Investigator to assure that all key personnel involved in effort reporting have met training requirements in accordance with Federal regulations and University and sponsoring agency policies and procedures.
  • Cooperates with the University’s compliance and monitoring efforts related to effort reporting and reports instances of noncompliance to the appropriate compliance offices.
Department Chair
  • Provides direction, resources, and oversight to help ensure that accurate reporting of effort.
  • Requires that faculty and staff involved in the reporting of effort to complete and comply with required education and meet annual training requirements in accordance with Federal regulations and University and sponsoring agency policies and procedures Supports and endorses cooperation with the University’s compliance and monitoring efforts related to effort reporting and reports instances of noncompliance to the appropriate compliance offices.
Dean
  • Provides direction, resources, and oversight to help ensure the accurate reporting of effort in accordance with Federal regulations and University and sponsoring agency policies and procedures.
  • Requires that all faculty and key personnel involved in the reporting of effort complete and comply with the required education and meet annual training requirements in accordance with Federal regulations and University and sponsoring agency policies and procedures.
  • Supports and endorses cooperation with the University’s compliance and monitoring efforts related to effort reporting and reports instances of noncompliance to the appropriate compliance offices.

This information, as well as other policies and procedures related to sponsored projects, will be posted on SPA’s web page https://financialservices.wustl.edu/wfin-topic/sponsored-projects-accounting/.

If you have any questions regarding the information presented in this document, please contact me at 314-935-7089 or jgindhart@wustl.edu.