Interim University Policy 4111: Time and Effort Reporting

Category: Academic Affairs
Subcatergory: Research
Covered Individuals: Employees Supported by Sponsored Awards
Responsible Executive: Vice President for Research
Policy Custodian: Sponsored Programs Accounting, Executive Director
Last Revised: 2026/06/01
Previous USU Policy Number: 582, 4101
Note: In January 2026, Policy 4101 was repurposed for the Sponsored Programs policy.
Download the PDF File for Policy 4111

4111.1 PURPOSE AND SCOPE

Utah State University (USU) is responsible for maintaining compliance with regulations governing personnel compensation charged to sponsored projects. Time and Effort Reporting is a means of confirming that both the effort paid for by the sponsor and the effort expended in support of a project, including Cost Sharing, have been performed as agreed with the sponsor. All USU researchers who engage in sponsored projects are required to follow USU policies, procedures and guidelines, as well as sponsoring agency regulations regarding the proposing, charging, and reporting of effort on sponsored projects.

4111.2 POLICY

2.1 Requirement for Effort Certification

The Uniform Guidance (2 CFR § 200.430) contains the federal regulatory requirements for internal controls over personnel compensation expended on sponsored projects. USU’s time and effort Certifications meet the Uniform Guidance standards for documentation of personnel services. USU uses the plan-confirmation and after-the-fact review methods to charge salaries in a reasonable allocation to sponsored awards or cost-share indexes, ensuring those salaries are consistent with the work performed.

USU requires effort Certification from exempt and non-exempt employees semi-annually, based on the two Certification Periods defined in Section 2.2. Certifications must be completed within the timeframe established by the University following the end of each Certification Period. Individuals certifying effort as required by this Policy must include effort on externally funded projects only to the degree it reflects charges that are Allowable by the sponsor and Allocable to the projects.

Payroll distributions and Time and Effort are not the same thing. Payroll distributions allocate an individual’s salary, while Time and Effort allocate an individual’s effort. Payroll distribution and effort may not be the same month to month, but by the end of the Certification Period, they must be in alignment within five percent or less.

Certification of Time and Effort is not required of employees for Extra-Service or Incidental Work. However, information regarding extra-service compensation is separately identified and documented within the University’s financial systems in accordance with Utah State University (USU) Policy 3201, Extra-Service Compensation and 2 CFR § 200.430(h)(4).

All individuals verifying and certifying effort for university employees must be knowledgeable of sponsor allowability and allocability criteria. Guidance and training are available through the Sponsored Programs Accounting (SPA) Office.

Failure to accurately report Time and Effort on sponsored projects can result in serious penalties for the University and/or the individual certifying effort. These penalties may include the disallowance of costs, debarment from further funding, and criminal charges against individuals in cases involving fraud. Salary expenditures are at a high risk for audit because of their potential for fraud and abuse by grantees.

2.2 Certification Period

USU requires effort Certification from employees semi-annually aligned with the University’s fiscal year based on the following defined Certification Periods:

Period Coverage Dates Certification Due
Period 1 July 1 – December 31 February 28
Period 2 January 1 – June 30 September 30

Certifications must be completed within the timeframe established by the University following each Certification Period. For sponsored projects that span multiple Certification Periods, effort must be reported and certified for each period separately.

Because effort Certification occurs semi-annually, payroll distributions must be monitored and reconciled at the close of each six-month Certification Period. Departments are responsible for ensuring that payroll distributions reasonably reflect actual effort within each period and are aligned within five percent or less of certified effort by the close of that period.

2.3 Type of Appointment

The type of appointment reflects the base period during which an individual’s Base Salary Rate is calculated. However, all employees working on sponsored projects, regardless of appointment type, certify time and effort based on the Certification Period.

2.4 Compensation for Non-appointment Period

USU allows exempt employees with appointments of less than twelve months to receive compensation from USU at their Institutional Base Salary Rate for periods up to a total of twelve months per fiscal year to conduct research, teaching, or other sponsored activities that are consistent with federal and USU policies, and do not conflict with the faculty member’s primary work assignment.

Non-appointment salary payments shall be made through the university’s payroll distribution system at an Institutional Payout Rate that reflects the individual’s Institutional Base Salary Rate. This salary is tracked using a unique account code, and—if applicable based on the individual’s receipt of external funding during that Certification Period—is subject to effort reporting and Certification within the applicable semi-annual period.

2.5 Allowability of Payment for External Incidental Work

This Policy shall not limit an employee’s opportunity to receive compensation for Incidental Work that is disclosed to the employee’s supervisor and is approved in accordance with appropriate University policies including USU Policy 3201 (Extra Service Compensation), USU Policy 3202 (Consulting Service), and USU Policy 2301 (Individual Conflicts of Interest).

2.6 Cost Sharing

Cost Sharing is a portion of total project or program costs related to a sponsored award that is contributed by someone other than the sponsor. Effort for committed Cost Sharing, whether mandatory or voluntary, is a part of the total effort rendered on sponsored projects and must be certified within each semi-annual Certification Period in which it occurs. Departments may not defer cost-share reporting to a subsequent period.

4111.3 RESPONSIBILITIES

3.1 Principal Investigators

Principal investigators are responsible for reviewing and certifying that salaries charged, or cost shared to sponsored awards are Allocable, Allowable, and consistent with the work performed during the applicable Certification Period.

3.2 Sponsored Programs Accounting (SPA)

Sponsored Programs Accounting is responsible for generating and distributing Time and Effort Certifications and for reviewing Time and Effort Certifications for completeness.

4111.4 REFERENCES

  • 2 CFR §200.430 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Compensation – Personal Services
  • 2 CFR §200.306 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Cost Sharing or Matching

4111.5 RELATED USU POLICIES

4111.6 DEFINITIONS

6.1 Allocable

  • Allocable. The cost has a direct benefit to the project being charged. Purchases benefiting multiple projects should be allocated amongst all projects proportionate to the benefit received.
  • Allowable. The cost is allowed by federal regulations, sponsor terms and conditions, including program specific requirements and university policy and is necessary for the performance of the award.
  • Certification. The assertion by the person who completes the Time and Effort Certification that the salaries charged to the sponsored awards as direct charges or Cost Sharing reasonably reflect the effort expended and work performed during the reporting period.
  • Certification Period. One of two six-month periods within the university fiscal year during which effort is accumulated and subsequently certified: Period 1 (July 1 – December 31) and Period 2 (January 1 – June 30).
  • Committed Effort. Amount or percentage of time an individual has communicated to the sponsor that they will work on a specific sponsored project over a specified period. Commitments are made in the project proposal to the sponsor and sponsor approval may be required to change the level of committed effort.
  • Cost Sharing. Any project costs that are not reimbursed by the sponsor. Cost Sharing of effort is the personnel time and related fringe benefits that were committed and provided in support of the project, but are paid for by other funding sources.
  • Extra-Service. Extra Service is defined in USU Policy 3201, Extra-Service Compensation.
  • Full Workload. Full Workload is defined in USU Policy 3201, Extra-Service Compensation.
  • Incidental Work. Incidental Work is defined in USU Policy 3201, Extra-Service Compensation.
  • Institutional Base Salary. Institutional Base Salary (IBS) is defined in USU Policy 3207: Wage and Salary Administration.
  • Institutional Base Salary Earning Rate. The Institutional Base Salary Earning Rate is defined in USU Policy 3201, Extra-Service Compensation.
  • Institutional Payout Rate. The Institutional Payout Rate is defined in USU Policy 3201, Extra-Service Compensation.
  • Payroll Distribution Methods. Payroll distribution methods are the mechanisms used by USU to compensate employees and record salary charges. These methods are not specifically prescribed by federal regulations and may be adjusted from time to time to meet USU's need for accurate accounting of personnel services.
    • Plan-Confirmation Method. Under the Plan-Confirmation method, salary is allocated to projects based on proposed/expected effort and then confirmed prior to Certification to ensure it matches actual effort, within the allowable variance.
  • Primary Work Assignment. The Primary Work Assignment is defined in USU Policy 3201, Extra-Service Compensation.

Information below is not included as part of the contents of the official Policy. It is provided only as a convenience for readers/users and may be changed at any time by persons authorized by the President, subject to review by the USU Policy Committee.

RESOURCES

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POLICY HISTORY

Original issue date: 2007/04/20
Last review date: 2026/06/01
Next scheduled review date: 2027/06/01
Previous revision dates: 2014/04/30; 2024/06/28; 2026/01/16