SystemResearch Administration & Compliance

Effort Reporting & Certification

Effort reporting that puts payroll and committed effort on one line, so investigators certify what they understand

Certifications close on time, with cap errors and missed approvals fixed before the audit.

See one case, screen by screen ↓
demo486certificationsmarked by the agents overnight, of 6,900 due February 26, 2027, on the sample period
demo97certificationsover the NIH salary cap this period, $286,915.40 charged above it before fringe
target95%of certifications closed by the due date
typical$13millionpaid by one health science center in 2018 to settle claims over unreliable effort certification
In short

What is Effort Reporting & Certification?

Effort Reporting & Certification is effort reporting in which agents reconcile payroll with the effort committed in each notice of award and with the NIH salary cap, then route each certification to the investigator, with a reviewer check before it closes. Effort reporting is how a university shows that the salary it charged to each federal award matches the work the person did on it, usually through a statement each investigator certifies twice a year.

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Updated

The problem

Why effort reporting turns into audit findings

Effort reporting is how a university shows that the salary it charged to each federal award matches the work the person really did on it. Twice a year, a statement goes to every investigator and staff member paid from a sponsored project; the investigator certifies it, and post-award staff keep it for the auditors. Under 2 CFR 200.430, budget estimates alone are not support for salary charges, and after-the-fact review is the control.

Today the statement is a form of payroll percentages. Nobody compares it with the effort committed in the notice of award, with current and pending support, or with the NIH salary cap, until an auditor does. A new role quietly moves salary off an award, and a reduction of 25% or more needs the sponsor's prior approval. A new NIH award set up at full salary charges the over-cap amount every pay date. Corrections arrive as cost transfers after the 90-day window. Effort Reporting & Certification puts seven agents in front of that comparison, so the department administrator fixes the right rows before the investigator certifies.

typical$13millionsettlement in 2018 over unreliable effort certification at one health science center
typical$20millionpaid by another university in 2015 over time-keeping on federal grants
estimated$6.4million a yearat risk of disallowance at the demo university if 1% of $640 million in sponsored salaries is charged in error
Where a department's certification business days go each periodestimated
By hand36 days
With the solution5.5 days
  • Loading payroll, appointments and awards for the period10 → 1 d
  • Comparing each statement with notices of award and other support6 → 0.5 d
  • Checking the NIH salary cap and the 25% prior-approval rule3 → 0.3 d
  • Drafting cost transfers and prior-approval requests4 → 0.5 d
  • Chasing late certifications8 → 3 d
  • Assembling evidence for the auditors5 → 0.3 d

Estimated split of one department's business days in a semi-annual period, by hand and with the agents: our arithmetic, kept modest, not a measured result.

How it works

How every certification closes

Seven agents reconcile payroll with commitments, apply the cap and draft requests and transfers; the investigator certifies and a reviewer checks.

What comes in
Records in5 sources · payroll, HR, awards, effort system, policy
Agents at work
Load agentpayroll, HR, awards
Then
Reconcilerpayroll vs commitment
Cap agentNIH salary cap
Then
Change agent25% rule, request drafted
Correction agenttransfer and payroll fix
Then
Audit Pack agentredacted, sealed
A person decides
Administrator, investigator and reviewerthe administrator prepares · the investigator certifies · the reviewer checks
What comes out
Marks explained
Certified and checked
Audit pack
One case, step by step

One statement through the effort certification process, from the overnight marks to a checked record

Halden State University, July–December 2026. Statements were released on January 27 and are due February 26, 2027. It is Wednesday, February 17, 2:14 p.m., nine days before the due date. Here is what happens to Dr. Marguerite Solano's statement, screen by screen, in the working solution.

  1. 015:00 a.m.

    Payroll against commitment, one line per person

    Reconciler, Cap agent and Change agent

    Overnight the Reconciler compared payroll for 61 people in Neuroscience with the effort committed in 48 awards and their current and pending support. The Cap agent checked every NIH award against the $225,700 cap, and the Change agent read the notices of award for reductions of 25% or more. Dr. Solano's row leads the effort board: R01 −12 points, and an R21 set up at full salary.

    Nobody can certify a row until its marks are explained.

  2. 022:14 p.m.

    Her statement, award by award

    Kofi Brennan · Department Research Administrator

    Kofi opens the statement. The NIH R01 HSU-24-0412 committed 30% and has been charged 18%; the NIH R21 HSU-25-0877 committed and charged 25%, but at full salary; the NSF award matches at 10%; institutional effort was committed at 35% and charged at 47%. The agents' work is listed step by step, with the confidence of each and who it goes to next.

  3. 03One click

    Every value opens its source

    Kofi Brennan

    Clicking a citation opens the labor distribution from ERP payroll with the charged lines highlighted: period pay $131,000.00, the R01 at 18.0% from 07/01/2026 at the capped rate, the R21 at 25.0% at full salary, $32,750.00. Opening a source is logged in the audit trail.

  4. 04Drafted at 5:04 a.m.

    A 40% reduction, and the prior-approval request already drafted

    Change agent

    The notice of award commits Dr. Solano at 3.6 calendar months, 30%. Since July 1 payroll has charged 18%, because her new Director of Graduate Studies appointment took 12%. That is a 40% reduction against a 25% threshold, so the Change agent drafted request PA-2027-031 with co-investigator Dr. Felix Ortmann rising from 10% to 20% and no budget change, every claim cited. Kofi edits it and sends it to the signing official at 2:21 p.m.

    Change agent drafted at 5:04 a.m., Kofi Brennan sends, Martin Hale submits.

  5. 05The arithmetic

    Over the NIH salary cap, shown line by line

    Cap agent

    Her base salary of $262,000 is above the $225,700 cap. July–December the R21 charged 25% × $262,000 × 6/12 = $32,750.00, where the cap allows 25% × $225,700 × 6/12 = $28,212.50. That is $4,537.50 over the cap, plus $1,270.50 fringe at 28.0%, and $9,075 a year at 25% effort. Cap agent confidence 0.99.

  6. 062:26 p.m.

    The cost transfer and the payroll fix, so the error stops at the source

    Kofi Brennan, with the Correction agent

    Cost transfer CT-2027-0388 moves $4,537.50 salary and $1,270.50 fringe, $5,808.00 in all, off the R21 to department account 10-4410-NEU. From January 1, 2027 payroll charges the R21 at the $225,700 cap, $756.25 a month to the department. Moving costs off a federal award is not limited to 90 days, and the check says so.

  7. 07Both marks explained

    The certify button turns blue

    Kofi Brennan

    Back on the effort board, Dr. Solano's two marks show their explanations: the R01 request is with Martin Hale, and the R21 transfer is with Ines Calloway. Her certification button is now active. At 2:34 p.m. Martin Hale, the signing official, submits the request to NIH; at 2:41 p.m. Ines approves the transfer and the ERP posts it.

  8. 082:50 p.m.

    The investigator certifies in plain words

    Dr. Marguerite Solano · Principal Investigator

    Dr. Solano sees where her effort went: R01 18% (committed 30%), R21 25% charged at the cap, NSF 10%, Halden State 47%, 100% of $131,000.00 for the period. Both changes are explained with their sources. She certifies, then certifies for three people on her awards, including a graduate research assistant whose statement is a student employee record under FERPA.

    I certify that this is a reasonable estimate of the effort I devoted to each activity from July 1 to December 31, 2026, and that I have suitable means of verifying it.

  9. 093:05 p.m.

    A reviewer checks before the record closes

    Ines Calloway · Post-Award Compliance Reviewer

    The agents pre-checked the statement: every mark explained, 2 of 2; CT-2027-0388 approved and posted; PA-2027-031 submitted by the signing official; certified before February 26; the certifier did not prepare the corrections; 9 sources attached. Ines closes it. The 112 statements with no marks close together only after she opens a 12-statement sample.

  10. 10Audit-ready

    Who, what, when, why, and a redacted pack

    Gregory Achebe · Internal Audit

    Every step of the afternoon is on the audit trail, for people and agents alike. The export pack for NIH R01 HSU-24-0412 holds 9 certifications and 46 sources, with employee IDs and the student employee record redacted, built and sealed. Only Dana Whitfield can release it, never the person who requested it.

Who it’s for

Built for everyone who touches an effort statement.

The same statement, seen by the five people who carry it: what their period looked like, and what it looks like now.

KB
Kofi BrennanDepartment research administrator · 61 people on 48 awards
Department Research Administrator, Neuroscience
Before
Compares statements with proposals and notices of award kept in folders, and writes cost transfers after the investigator has already certified.
Now
Opens a row with the gap, the cap and the 25% rule already marked and cited, and sends the drafted fixes before anyone certifies.
MS
Dr. Marguerite SolanoPrincipal investigator · certifies her statement and three on her awards
Professor of Neuroscience, Principal Investigator
Before
Is asked to confirm a form of payroll percentages, without the commitment she made to the sponsor in front of her.
Now
Sees what changed and why in plain words, with the source for each line, and can ask about any line before she certifies.
IC
Ines CallowayPost-award reviewer · checks certifications, approves cost transfers
Post-Award Compliance Reviewer
Before
Samples certified statements after the fact and chases the evidence across email, PDFs and the ERP.
Now
Gets each certified statement pre-checked, with its evidence attached, and closes it or returns it with a reason.
MH
Martin HaleSigning official · submits prior-approval requests to the agency
Sponsored Programs Officer, signing official
Before
Hears about a 25% reduction when an auditor finds it, long after the request should have gone in.
Now
Receives a drafted request with every claim cited, and is the only person who can submit it.
DW
Dana WhitfieldDirector · owns on-time certification for 6,900 a period
Director of Post-Award Compliance
Before
Wants every statement closed by the due date and nothing in it an auditor can pull apart, but sees the problems only at the deadline.
Now
Sees the marks, the deadlines and the escalations in one place, and releases redacted export packs that someone else requested.
Built on the engine

7 agents. Each with one job, and hard limits.

Seven agents reconcile payroll with commitments, apply the cap and draft requests and transfers; the investigator certifies and a reviewer checks.

Load agent

Loads labor distribution, appointments, awards and other support for each period from ERP payroll, the HR system and the research administration system, and checks the totals.

  • Never edits payroll
  • Stops the period when statement totals differ from payroll
Reconciler

Compares payroll with committed effort for every person and award, and with current and pending support month by month; marks gaps of 5 points or more and over-commitment, citing both sides.

  • Never marks a gap explained
  • Below 0.85 confidence, the department administrator decides
Cap agent

Applies the NIH salary cap for each pay date to every NIH certification and computes the over-cap amount with fringe.

  • Never moves money; drafts only
Change agent

Finds reductions of 25% or more for PIs and key personnel named in the notice of award, and drafts the prior-approval request with every claim cited.

  • Never submits to an agency; the signing official does
Correction agent

Drafts cost transfers and payroll distribution changes, and checks the 90-day rule in the effort policy.

  • Never posts; a post-award reviewer approves
Reminder agent

Sends routine reminders by rule and drafts escalation notices to chairs and deans for the director.

  • Escalation notices need the director's approval
Audit Pack agent

Builds the export pack from the audit trail and document management, redacts personal and student data, and seals it.

  • Release needs a request and a different person to release it
Administrator, investigator, reviewer

Prepare, certify, check. The agents propose; a named person decides.

Ask in plain words

Ask about any person, award, mark or request

The assistant answers with citations to the notice of award, the payroll record, the HR record or the policy, and can take you to the screen where the work is done. It cannot certify or submit anything.

Why does Dr. Solano's R01 need NIH approval?

The notice of award commits her at 3.6 calendar months, 30%. Payroll has charged 18% since July 1, because her Director of Graduate Studies role took 12%. That is a 40% reduction, and NIH requires prior approval for a cut of 25% or more by the PD/PI. The Change agent drafted PA-2027-031 with Dr. Ortmann covering Aim 2; Martin Hale submits it. I cannot submit it.

How much of the R21 is over the salary cap?

Her base salary is $262,000; the cap is $225,700. At 25% effort that is $9,075 a year over the cap. July–December: charged $32,750.00, allowed $28,212.50, so $4,537.50 plus $1,270.50 fringe moves to 10-4410-NEU in CT-2027-0388, and payroll charges the cap from January 1. Ines Calloway approves it; nothing posts before she does.

Why is my R21 still 25% if the dollars move?

Effort is your time, and the cap limits dollars. You still spent 25% of your effort on the R21; NIH just pays no more than $225,700 a year for it. The department pays the rest, so you certify 25%.

Build the export pack for the NIH review of the R01

Building it now: the 9 certifications on HSU-24-0412 for July–December 2026, with marks, explanations, sign-offs, the drafted request and 46 sources, with employee IDs and the student employee record redacted. Dana Whitfield releases it; the requester never does.

Every screen

The working solution, as it ships.

12 screens from the working solution, on its sample data. Pick one to see it large.

The effort board: payroll against committed effort, one line per personEffort reporting for July–December 2026 in the Neuroscience department's view. Each person is one row: a lighter bar shows the effort committed to each award, and the bar below shows what payroll charged. Gaps of 5 points or more and the NIH salary cap are marked, and the certify button stays gray until every mark is explained.
One investigator's effort statement, award by awardDr. Marguerite Solano's statement: committed and charged effort for each award, institutional base salary $262,000, the salary-cap status, the marks to explain, and the agents' work step by step with confidence and hand-off.
Every value opens its sourceA citation opens the labor distribution from ERP payroll for July–December 2026 with the charged lines highlighted. Opening a source is logged in the audit trail.
The NIH salary cap arithmetic, shownWhy the R21 is over the NIH salary cap, in plain words and line by line: $32,750.00 charged, $28,212.50 allowed, $4,537.50 over the cap plus $1,270.50 fringe, $9,075 a year at 25% effort.
An NIH prior-approval request for a reduction in effort, every claim citedRequest PA-2027-031: committed 30%, charged 18% since July 1, 2026, a 40% reduction against the 25% threshold, with co-investigator coverage and no budget change. The administrator can edit any paragraph; only the signing official submits it.
The cost transfer and the payroll fix, maker and checkerCost transfer CT-2027-0388 moves $5,808.00 in over-cap salary and fringe off the NIH R21 to the department account, and changes payroll from January 1, 2027 so the error stops at the source. One person prepares it; a reviewer approves it.
Marks explained, the certify button turns blueDr. Solano's two marks show their explanations, the request with the signing official and the transfer with the reviewer, and her certification button is active. Nobody can certify a row until its marks are explained.
Effort certification in plain wordsThe investigator's own view: where her effort went, what changed and why, with sources, and the statement she signs. Only she can certify; she also certifies for three people on her awards.
A reviewer checks before the record closesEach certified statement arrives pre-checked by the agents, and the reviewer closes it or returns it with a reason. Statements with no marks close in bulk only after a 12-statement sample is opened.
Over-commitment caught with current and pending supportCommitted effort month by month for 2027, with a pending U01 and required teaching against the 100% line: 120% for five months from April 1. The Reconciler offers three options for the administrator to pick and the investigator to decide.
Every NIH certification checked against the salary cap97 NIH certifications over the cap this period, $286,915.40 charged above it before fringe: 52 set up at full salary and 45 from summer or supplemental pay, with the cap rates the Cap agent applies and transfers drafted in bulk.
The audit trail and a redacted export packWho did what, when, why and on which evidence, for agents and people, with an export pack for the agency review: 9 certifications and 46 sources, employee IDs and the student employee record redacted. The requester can never release it.
Governance

Effort reporting built for the audit: cited, certified, checked.

Separated duties: nobody approves their own workThe department administrator prepares corrections, the investigator certifies, the post-award reviewer checks and approves cost transfers, the signing official submits to the agency, the coordinator prepares escalations and the director approves them and releases export packs. An auditor reads everything and changes nothing.
Agents never certifyAgents never certify, never post a transfer, never submit to an agency and never send an escalation. The certify button stays gray until every mark is explained, and a reviewer checks the record before it closes.
Every value cites its sourceEach value and agent statement cites the notice of award, the payroll distribution, the HR record, other support, the policy or the rule. Click it to see the passage; every opening is logged.
Student employee records under FERPAStatements of graduate research assistants and student hourly staff are education records. Salary is visible only to the department, the PI and post-award staff, and export packs redact employee IDs, home addresses and student data.
Versioned prompts, models and thresholdsEach agent has a prompt version and a confidence threshold, and a threshold changes only with a reason. A mark dismissed as not a problem needs a reason code, such as an approved rebudget on file, and the reviewer sees it.
A complete audit trail, kept for 3 yearsWho, what, when, why and which evidence, for people and agents alike, with an export pack for internal audit, the Single Audit and agency reviews. Records are kept 3 years after the final financial report (2 CFR 200.334).
Configuration

Your effort policy, as settings

The rules every statement is checked against come from the institution's effort policy. Only the system administrator changes them, each change with a reason and a new version on the audit trail.

SettingDefaultChoose from
Gap threshold5 points between committed and charged before a mark3 to 10 points
Prior-approval reduction25% for a PI or key personFixed by 2 CFR 200.308(f)(3)
NIH salary cap$225,700 from January 1, 2025Earlier rate $221,900 kept for past pay dates; add a new rate with its effective date
Statements due30 days after release20 to 45 days; reminders every 7 days until certified
EscalationChair 3 days, dean 10 days after the due dateChair 1 to 7 days, dean 5 to 20 days
Cost transfers onto a federal award90 days after the charge60 to 120 days
Reviewer check and transfer approval5 and 3 business daysCheck 3 to 10, approval 2 to 7 business days
Keep records3 years after the final financial report3 to 7 years; 2 CFR 200.334 minimum
Connections

Works with the systems a research office already runs on

ERP payroll and labor distributionpay dates and distributions in; approved transfers and payroll changes posted
HR systemappointments and appointment changes
Research administration systemawards, notices of award and other support
Effort certification systemstatements, certifications and signatures
Document managementnotices of award, proposals and letters
Agency grants portalprior-approval requests submitted by signing officials
What it changes

The difference, in numbers.

Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.

target
100%
of NIH salary charged at or below the cap before each period closes
Every over-cap charge drafted
97 of 97 in the demo period
target
0
reductions of 25% or more left without a prior-approval request
caught in the period
31 found and drafted in the demo
target
95%
of certifications closed by the due date
Demo period today76.5%
Target95%

Sources: 2 CFR 200.430 (compensation, personal services) and 2 CFR 200.308(f)(3) (prior approval), Uniform Guidance as revised October 1, 2024 · NIH Grants Policy Statement 8.1.2.6 and 7.5 · NIH salary limitation, NOT-OD-25-085 ($225,700 from January 1, 2025) · 2 CFR 200.334 (record retention) · FERPA, 34 CFR 99.3 · US Department of Justice, 2018 settlement of $13 million over effort certification at a health science center; a 2015 settlement of $20 million over time-keeping on federal grants · "demo" = seen in the working solution, on its sample data · "target" = design goal, measured in the live solution · "typical" = published figures · "estimated" = our arithmetic from the demo university's inputs. Halden State University, its awards and accounts, and the people named on this page are fictional: characters and sample data in the working solution.

Questions

What research offices ask about effort reporting.

What is Effort Reporting & Certification?

Effort Reporting & Certification is effort reporting in which agents reconcile payroll with the effort committed in each notice of award and with the NIH salary cap, then route each certification to the investigator, with a reviewer check before it closes. Effort reporting is how a university shows that the salary it charged to each federal award matches the work the person did on it, usually through a statement each investigator certifies twice a year.

What does the Uniform Guidance require for time and effort reporting?

2 CFR 200.430 requires salary charges to be based on records that accurately reflect the work performed, supported by internal controls; budget estimates alone are not support, and after-the-fact review is the control. The solution makes that review a comparison with what was committed, with every value cited to its source.

How does the effort certification process work with the agents?

Overnight, agents compare payroll with committed effort for every person and award and mark every gap of 5 points or more, every NIH certification over the cap and every reduction that needs prior approval. The department administrator sends the drafted fixes, the investigator certifies once every mark is explained, and a post-award reviewer checks the record before it closes.

When does a reduction in effort need NIH prior approval?

A reduction of 25% or more in the time the PD/PI or key personnel named in the notice of award devote to the project needs NIH's prior approval (NIH Grants Policy Statement 8.1.2.6; 2 CFR 200.308(f)(3)). The Change agent finds these reductions from the notice of award and the HR appointment record and drafts the request; only the signing official submits it.

Does it check the NIH salary cap and draft the cost transfer?

Yes. The Cap agent applies the cap rate for each pay date, $225,700 from January 1, 2025, and computes the amount charged over it with fringe. The Correction agent drafts the cost transfer and the payroll distribution change so the over-cap amount stops at the source, and a reviewer approves it before the ERP posts it.

Does it check current and pending support for over-commitment?

Yes. The Reconciler adds current and pending support and required teaching to committed effort month by month, flags anyone over 100% before the next award starts, and offers options such as a teaching buyout or a lower commitment at Just-in-Time. The administrator picks an option and the investigator decides.

Do people stay in control of every certification?

Yes. Agents never certify, post a transfer, submit to an agency or send an escalation. The investigator certifies, because only they know where the effort went; a reviewer approves every cost transfer and checks every certified statement, and nobody can approve their own work.

How long does it take to go live?

The Agentic Solution Engine builds and deploys it from your requirements and documents, such as your effort policy, your payroll and award data and a sample of past statements, and it goes live once every quality gate has passed. We will walk you through it on your own statements first.

See it on
your effort statements.

We'll run Effort Reporting & Certification on a sample of your own payroll, awards and statements.