The requirement for time and effort certification on federally sponsored programs originated under Office of Management and Budget Circular A-21 Cost Principles for Educational Institutions, Section J.10. The release of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) on 12/19/14 superseded Circular A-21 and extended many of the same requirements (see note, below) under Section 200.430 Compensation - Personal Services. The University uses effort certifications completed via the our internal reporting system (Effort@UVa) to fulfill the following requirements regarding compensation for personal services on sponsored programs:
- ensure that committed effort on sponsored activities is documented, whether or not the financial support for the effort is provided by the sponsor or other University funding sources;
- verify that payroll costs charged to specific sponsored activities is commensurate with the certified effort expended toward those activities;
- document effort toward various clinical activities; and
- account for 100% of University effort.
University policy FIN-027 Time and Effort Certification establishes the roles and responsibilities of various parties and offices with regard to effort reporting and certification.
Note: The University believes that Uniform Guidance Section 200.430 may provide some additional flexibility not previously available; therefore, we we have included the time and effort policies, systems and processes in our ongoing comprehensive review of the University's internal control environment to see what efficiencies and compliance enhancements may be gained by a different approach to fulfilling our financial obligations and requirements.