Certification of Effort

The OMB Uniform Guidance (2 CFR 200) requires that personnel associated with sponsored activity certify their effort after the effort has been expended. A certified effort report is the only auditable document the university has to support salary costs on an award.  Failure to have a certified effort report on file for payroll costs on an award could result in the disallowance of the related salary, fringe and F&A costs. 

Uniform Guidance 2 CFR § 200.430 requires that each grant recipient document time expended towards a sponsored program. Recognizing the unique nature of universities, Uniform Guidance 2 CFR § 200.430 requires documentation and certification of percent of effort, totaling 100%, in support of one’s total commitment toward sponsored programs. To meet this requirement for documentation and certification, individuals paid monthly and who has some commitment towards a sponsored program, shall certify their effort based on the distribution of total compensation paid to the individual during that month.    

Reports for Faculty are to be generated on a quarterly basis (January – March, April – June, July – September, and October – December) and reports for other Employees and Staff are generated monthly by the Office of Research and Sponsored Programs utilizing the University financial management system (Banner). A reminder email is automatically generated by Banner and sent to Employees whose Effort certification is not completed within 30 days of the report being generated.

DU has administrative consequences for failing to certify effort.  

Consequences for individuals who do not fulfill their responsibilities include the removal of services associated with: 

• Submitting grant proposals or other project applications to sponsors for extramural projects. 

• Negotiating and executing award agreements. 

• Establishing accounts for spending external funds for new or continuing projects. 

In addition to the consequences outlined above, DU has fiscal consequences for uncertified effort. If effort reports are not certified before the conclusion of fiscal year end (June 30), the payroll expense may be determined to be unallowable and will not be reimbursed by the Sponsored Program fund causing the applicable payroll expense to be borne by the employee’s department. All incidences where Effort is not timely certified will be reported to the Vice Provost for Research.

Employees certify their own effort report. 

• Principal Investigators must: 
  • Certify their own effort quarterly 
  • Coordinate with their grant staff to ensure they are certifying their effort 
• Staff Members (post-docs, graduate research assistants, etc) must: 
  • Certify their own effort monthly 
• Department Administrators must: 
  • Be responsible for onboarding and employee departure processes 
  • Review the document “Open Effort Certification Report” (could we link to this?) to help identify open effort certifications  
  • Provide reminders to PIs 
• Sponsored Programs Administration Staff must: 
  • Work with department administrators to gather necessary information to approve effort for employees who have left the University 
  • Keep effort certification records up to date by working with PIs, staff, and DAs.  

If an employee is no longer employed at the university, the sponsored programs team will work with the appropriate person in the department to certify. 

See attachment for “How to Run Data Insights Report” for data insights instructions.

Instructions for Certifying Effort

If changes to an Effort Report are needed, do not certify the report. Communicate the correct effort percentages for the period to your Department Administrator or Budget Officer. The appropriate person in your department will prepare a Payroll Redistribution Request. Once the payroll changes are posted, a revised Effort Report will be generated. 

As a Department Administrator you are responsible for:

• Onboarding new faculty and introducing the effort certification process, as well as ensuring departing employees certify their effort before they depart.
• Help identifying open effort certifications by running the Effort Certification Report on a regular basis. See “How to Run Data Insights Report” for instructions on how to run this report.
• Providing reminders to PIs and students/grant employees.