Grant and Contract Time and Effort Certification Procedures
As a recipient of federal funding, the University of Houston – Victoria is required to comply with the Office of Management and Budget Circular Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) as well as requirements for certifying effort expended on sponsored awards, 2 CFR Part §200.430, Compensation-personal services. Time and Effort Certification confirms the salaries and benefits charged to, or pledged as a cost share to, grant funded projects are reasonable and reflect the actual work performed. Section §200.430(i) states the standards for documentation of personnel expenses charged to Federal awards for salaries and wages must be based on records that accurately reflect the work performed, and that these records must:
- Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;
- Be incorporated into the official records of the non-Federal entity;
- Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensation activities (for IHE, this per the IHE’s definition of IBS);
- Encompass both federally and all other activities compensated by the non-Federal entity on an integrated basis (teaching, research, administrative) but may include the use of subsidiary records as define in the non-Federal entity’s written policy;
- Comply with the estimated accounting policy and practices of the non-Federal entity for Additional Compensation;
- Support the distribution of the employee’s salary or wages among specific activity or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity;
- Budget estimates (i.e., estimates determined before the services are performed) alone do not quality as support for charges to Federal awards.
The University of Houston - Victoria has adopted an “After-the-fact” Time and Effort activity reporting process, not to exceed 100% of the compensated activities covered by the Institutional Base Salary (IBS), for all employees working on federal and other sponsored programs. The Office of Research and Sponsored Programs is responsible for facilitating Time and Effort Certification or Effort Reporting for all sponsored projects.
Frequency of Effort Reports
Below are the effort reporting periods. Personnel compensated through sponsored-program activity must report their effort every fiscal year quarter.
|1||September 1 – November 30|
|2||December 1 – February 28|
|3||March 1 – May 31|
|4||June 1 – August 31|
Timing and Responsibility
The Office of Research and Sponsored Programs will complete Time and Effort Certification forms within twenty (20) calendar days of the end of the previous quarter; distribute the forms for certification purposes to all personnel compensated by sponsored program funds and contact faculty regarding outstanding effort forms.
Time and Effort Certification – Documentation
The Office of Research and Sponsored Programs maintains the Time and Effort Certification form. The Grants and Contracts Coordinator manually completes the form using existing PeopleSoft Human Resource Management System (HRMS) data from payroll, cost transfers and commitments then verifies the distributed amounts support the time and effort pledged in the award document. Each effort certification form will include all project or department cost centers from which salary up to 1.0 FTE (Full-time Equivalent) has been charged or transferred. The Principal Investigator or Co-PI will certify Undergraduate or Graduate personnel time and effort on their respective projects.
The electronic Position Request form (ePRF) is processed in HRMS, which separately lists each cost center an employee is assigned to with their corresponding percentage of FTE and payroll. It is vital that ePR’s accurately reflect the correct cost center and/or the related PeopleSoft cost share/match cost center number supporting the time commitment in the award document to certify effort properly and reflect the actual work performed.
Cost Share Reporting
Salaries and wages of employees used in meeting cost sharing or matching requirements of federal awards must be supported in the same manner as salaries and wages claimed for reimbursement from federal awards. UHV is required to track and report University funded cost share. A companion cost center is created in PeopleSoft to track and report personnel salary contributed as cost share. The Budget Office will create the companion cost center when the University is required to meet cost share requirements. Charges will be applied to the companion cost center by an electronic Position Request form (ePRF) for those employees contributing effort under the sponsoring agency grant, but are being compensated under a UHV cost share cost center.
The Office of Research and Sponsored Programs must review and approve all salary allocated to grant and cost share cost centers. When an employee’s salary is erroneously charged to an incorrect PeopleSoft cost center, a Payroll Reallocation form must be completed to move the charges to the correct grant cost center. All salary and wage reallocation requests must be processed within sixty (60) calendar days from the date the expenditures posted to PeopleSoft general ledger in support of UHV policy. Effort reports must then be adjusted to reflect the percentage of effort worked on the proper grant and contract project.