Time and Effort Certification

Background and Federal Regulatory Basis

Time and Effort Certification is the mechanism by which USU confirms that personnel compensation charged to sponsored projects and associated cost share commitments reasonably reflects work performed. This requirement derives from federal regulations (Uniform Guidance) governing all institutions receiving federal funding:

2 CFR § 200.430 – establishes requirements for internal controls over personnel compensation on sponsored projects. USU’s certification practices must meet the Uniform Guidance standards for documentation of personnel services.
2 CFR § 200.306 – governs Cost Sharing or Matching, including the requirement that committed cost-share effort be documented and certified.

Salary expenditures are among the highest-risk areas for federal audit due to their potential for fraud and abuse. Accurate and timely certification is therefore both a compliance obligation and a critical protection for USU, its researchers, and the continued receipt of sponsored funding.

What Is Changing

Previously, employees were required to complete Time and Effort Certification once per year. Under the revised Policy 4111, certification is now required semi-annually, aligned with USU’s fiscal year. The two Certification Periods and their deadlines are as follows:

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 by the deadlines above, following the close of each Certification Period. For projects spanning multiple Certification Periods, effort must be allocated during the Certification Period in which the work is performed and certified separately for each period.

Why This Change Is Being Made

The transition to semi-annual Time & Effort Certification strengthens USU’s compliance posture and internal controls in the following ways:

More timely detection and correction of discrepancies between payroll distributions and actual effort, promoting stricter adherence to USU Policy 4102 Cost Transfers by catching errors within institutional correction windows.
Better alignment with the Uniform Guidance requirements by ensuring payroll charges reasonably reflect actual work, while reinforcing expectations that variances exceeding five percent (5%) are identified through ongoing monitoring and resolved within each Certification Period rather than accumulating over a full year.
Reduced risk of disallowed costs, which can require USU to return funds to sponsors.
Alignment with best practices adopted by peer research universities nationwide.

Key Requirements Under the Updated Policy

The following requirements apply to all covered employees under Interim Policy 4111:

Payroll distributions must be monitored continuously to ensure they reasonably reflect actual effort throughout the Certification Period; at the close of each six-month Certification Period, distributions must align within five percent (5%) of certified effort.
Cost Sharing – both mandatory and voluntary committed cost-share effort – must be certified within each semi-annual Certification Period in which it occurs. Departments may not defer cost-share reporting to a subsequent period (2 CFR § 200.306).
Elimination of Single-Block Summer Reporting: Due to the June 30 fiscal year cutoff, a single 3-month summer must be split across two reporting cycles: 1.5 months (July/August) will be reported at the start of Period 1, while the following year's 1.5 months (May/June) will be captured at the end of Period 2.
Certification is not required for Extra-Service or Incidental Work, which is separately documented in accordance with USU Policy 3201 and 2 CFR § 200.430(h)(4). However, Extra-Service Compensation will be reflected on the Time & Effort Certification to document all compensation received within the Certification Period.
All individuals certifying effort must be knowledgeable of sponsor allowability and allocability requirements.
Principal Investigators are responsible for reviewing and certifying that salaries charged or cost-shared to sponsored awards are allocable, allowable, and consistent with work performed during the applicable Certification Period. PIs are required to certify their own effort, as well as that of their project personnel (including graduate students and postdocs), based on direct knowledge or suitable means of verification.

Consequences of Non-Compliance

Failure to accurately and timely report Time and Effort on sponsored projects can result in serious consequences for both the University and the individual certifying, including:

Disallowance of personnel costs charged to sponsored awards, requiring repayment to the sponsor.
Debarment from future federal funding.
Criminal charges against individuals in cases involving fraud or willful misrepresentation.

Resources and Assistance

Sponsored Programs Accounting (SPA) is responsible for generating and distributing Time and Effort Certifications and will provide notifications to affected employees at the start of each certification window. Guidance on the certification process is available through the SPA Office.