Compliance Requirements for Activity (Effort) Reporting

College of Charleston Academic Affairs - Office of Research & Grants Administration

Compliance Requirements for Activity (Effort) Reporting:

I. Overview

Questions regarding activity reporting systems and procedures should be addressed to the Office of Research and Grants Administration at 953-5885 or Grants Accounting at 953-7357.

This procedure explains the requirements for Activity (Effort) Reporting at the College. As a recipient of Federally Sponsored Agreements, the College is required to have internal management control systems and cost accounting procedures that are in compliance with all applicable laws, rules, and regulations.   These controls and procedures provide for the proper allocation of allowable costs including, but not limited to, the direct charging of salaries and fringe benefits, to the appropriate sponsored research agreement.

II. General Guidelines

A. Activity Reporting Systems:

The College uses two methods of reporting work effort, depending on employee status.  These methods have been developed in accordance with the applicable provisions of Office of Management and Budget (OMB) Circular A-21 (Cost Principles for Educational Institutions, Section J. 10, Compensation for Personal Services):

1. Annual Activity Reporting System for Unclassified and Classified Employees:

The Annual Activity Reporting System is used as the basis for the allocation of salaries and wages for Unclassified and Classified employees. Under this system, the allocation of salaries and wages is initially charged to the appropriate sponsored agreement based on a budgeted salary and allocation of effort contained in that sponsored research agreement. This allocation must subsequently be supported by annual plan-confirmation activity reports that reflect the employee's reasonable estimate of his/her activities being directly compensated under that sponsored agreement.

2. Time-Reporting System for Temporary and Student Employees:

The allocation of salaries and wages for Temporary and Student employees is documented separately by College’s electronic time reporting system, manual time cards, or manual time sheets. No further certification or documentation is required.

B. Employees Covered by Annual Activity Reporting Requirements:

All Classified and Unclassified College personnel who direct charge or provide cost share effort to one or more sponsored agreements are subject to annual activity reporting requirements.

C. Covered Employee Responsibilities:

1. Each covered employee (as described under B. above) must review and certify his/her Annual Activity Report within 90 days of the annual end date of the Annual Activity Report period.

2. The employee must provide a reasonable estimate of the allocation of his/her activities by activity category for each Sponsored Agreement that funded part or all of his/her salary and fringe benefits for the year.

3. The employee’s reported effort percentages will be compared with the allocation of actual payroll charges to each relevant sponsored agreement in order to determine if retroactive adjustments to his/her salary allocation are necessary.

4. The employee is responsible for informing his/her supervisor, principal investigator(s), or other responsible official during the year if the allocation of salary charges should be modified based on a change in the proportion of time actually spent on his/her activities during that period.

D. Office of Research and Grants Administration and Grants Accounting Responsibilities:

The Office of Research and Grants Administration (ORGA) will act as the central distribution point of the Annual Activity Reports between the departments and Grants and Contracts Accounting. ORGA’s responsibilities include:

1. Distributing the Annual Activity Reports, when they are available, to covered employees for their review and certification.

2. Ensuring that the reports are submitted to Grants Accounting by the appropriate due date.

3. Notifying appropriate personnel if significant variances are reported between the employee's effort percentages recited in each sponsored agreement and the actual allocation of direct payroll charges to those sponsored agreement(s).

Grants Accounting will maintain adequate documentation, that will meet internal and external audit requirements, to substantiate any changes of an employee's salary allocation. .

III. Procedures

A. Distribution of Annual Activity Reports:

The Office of Research and Grants Administration will distribute the Annual Activity Reports, when they are available, to covered employees for their review and certification.

B. Completion and Review of Activity Reports.

1. Each covered employee must review, sign, and submit to ORGA his/her own annual activity report.  Each employee is responsible for ensuring that the activity report is true, complete, and accurate in all material respects. The employee's effort percentages must total 100% and must be allocated among the following categories.

· Sponsored Projects

· Cost Share

· College Activities

2. When submitting the activity report, each employee will be required to certify the truth of the following statement: "I certify that the percentages listed represent a reasonable estimate of the total work effort for the period covered by this report."

3. For terminated employees and other employees unavailable to submit reports, a responsible official with firsthand knowledge of the employee's activities must sign the activity report.

C. Significant Changes in Effort Distribution:

If a significant change on the Activity Report is necessary to reflect the actual effort of an employee then, if necessary, the relevant principal investigator under that sponsored agreement must submit retroactive adjustments to salaries and fringe benefits charges on a timely basis.  Although there is no precise definition for the term "significant", it has been construed as a general rule that a change applicable to a given project or activity of 5% or more of an employee's total effort warrants an adjustment. These adjustments should be implemented immediately following the employee's certification of the Activity Report.

D. Due Dates and Delinquent Reports:

1. Due dates will be indicated on the Activity Report cover memo. Activity Reports are due 15 calendar days after distribution.

2. Activity Reports are considered delinquent if not completed within 75 days after the due date.

E. Retroactive Changes to a Certified Activity Report

The employee must inform ORGA and provide a full explanation to Grants Accounting as to why the previously certified report requires re-certification. The employee must contact Grants Accounting for instructions on re-certifying the Annual Activity Report.

January 16, 2009