Policy Statement

As a recipient of federal funding Montana State University (MSU) 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 other federal requirements for certifying effort expended on sponsored awards. MSU requires all individuals who receive federal sponsored funding to comply with University policies and sponsoring agency regulations regarding the proposing, charging, and reporting of effort on those awards.

University faculty and staff are expected to charge their time to sponsored awards commensurate with the committed effort expended on all activities they perform. Payroll charges to sponsored awards, and cost sharing recorded for faculty and staff, serve as the initial data points for the University’s effort reporting system.

Reason for Policy

The Uniform Guidance Subpart E §200.430 contains the federal regulatory requirements for certifying time expended on sponsored projects. The University’s practice is to utilize an after-the-fact effort reporting system to certify that salaries charged, or cost shared to sponsored awards and are reasonable and consistent with the work performed. The individual’s effort is first assigned to specific awards in the payroll system based on anticipated activities. Actual effort expended on each project is certified by a responsible person with suitable means of verification that the work was performed, generally the principal investigator on a monthly basis. The effort reporting should be a reasonable estimate of how time was expended. Section §200.430(c) states, “It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to Federal awards for IHEs [Institutions of Higher Education] a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.”

The Annual Time & Effort Certifications supported by the monthly reports are the primary means for complying with the federal regulations relating to effort certification.

Link to Time & Effort Distribution Reporting:


Who Must Complete Time & Effort

Employees paid from an OSP funding source are required to complete and submit Time & Effort reporting.
This includes for example, faculty (tenured and non-tenured), staff (professional and classified), GTA's, GRA's,
research appointments, contract administrators and summer session appointments.

Adherence to this policy is required for all effort related to federally sponsored awards as well as any non-federal
awards where the non-federal sponsor requires effort reporting.


  • Effort reporting is a federal compliance requirement. There are many individuals involved in this process and
    each one has a role in ensuring that certifications are accurate and completed on time.
    Principal Investigators (PIs)/Faculty Members
  • Understand their own as well as their staff members’ (non-faculty personnel) levels of effort committed,
    charged and reported on all applicable awards
  • Review, initiate corrections if necessary, and work with departmental personnel to ensure completion

Departmental Personnel

  • Monitor effort commitments, salary charges, and cost sharing on all applicable awards
  • Communicate to the central sponsored programs office (OSP or SPA) any changes that require sponsor
    notification and/or approval
  • Review salary charges with PI/faculty member and post any salary distribution updates and/or
    corrections in a timely manner
  • Coordinate with personnel to gather data and complete/submit TIme & Effort reports timely
  • Monitor that effort certifications are completed within the certification period

Office of Sponsored Programs (OSP)

  • Communicate significant changes in effort to sponsors

  • Provide effort reporting training, guidance on requirements, and oversee compliance with the Time
    & Effort reporting policy
  • Manage the business/functional aspects, security roles/rights, and provide user access to the
    electronic effort reporting system