Effort Reporting - Policies and Policy Governance

1. Policy

Issued: 11/4/2025
Last Revised: New
Last Reviewed: New

Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California and its subsidiaries including Keck Medicine of USC (“USC employees”). This policy continues to apply to individuals on sabbatical, other leaves or while visiting other institutions.

2. Policy Purpose

Salaries and wages typically comprise the largest percentage of expenses on a sponsored project. Effort certification is the method by which the government and other sponsors verify that salaries charged to sponsored projects and committed cost sharing accounts reasonably reflect effort spent on a sponsored research project during the reporting time frame. Effort certification is required for every employee who receives a portion of their salary from a sponsored project or cost-sharing account. This policy explains these requirements as they relate to proposing, charging, and reporting effort on sponsored projects and committed cost sharing.

3. Scope

This policy applies to all university faculty members (including part-time and USC paid visiting faculty), staff and other employees, (such as postdoctoral scholars) who propose, conduct or report research on behalf of the university, regardless of funding source.

4. Definitions

Term	Definition
Institutional Effort for Exempt Individuals	Institutional effort is the total time spent by a faculty or exempt staff member on university activities, including teaching, research, patient care, service, and administrative duties. University responsibilities are reflected in the individual’s appointment letter, contract, or job description. For exempt staff and faculty, effort is not calculated on a 40-hour workweek or any other number of hours per week. Instead, it is based on 100 percent effort for USC (whether the employee is full-time or part-time).
Institutional Base Salary (IBS)	Institutional base salary (IBS) is the total guaranteed USC salary for the year paid to a faculty or staff member for institutional effort (e.g., teaching, research, administration, service and patient care activities). IBS provides the basis for determining how much salary should be charged to grants and contracts.
Salary Cap	The Salary Cap is a limitation on the IBS that an individual can receive under a Department of Health & Human Services (DHHS) award. The cap is annually determined by Congress and is currently tied to the Executive Level II salary level. The salary cap applies to all grants, cooperative agreements, and contracts from any DHHS agency.

5. Policy Details

Proposing Effort:

The Principal Investigator is responsible for ensuring that the research proposal accurately reflects the estimated effort for each individual expected to contribute to the research being proposed, regardless of whether salary support is requested for the effort.

As a general rule, any individual listed as key personnel on a project should commit some level of effort and a Principal Investigator should commit at least one percent (1%) effort in the proposal.

Any salary proposed to be paid from a sponsored project must be based on an individual’s proposed percentage of effort and be calculated based on the same percentage of an individual’s Institutional Base Salary. For example, if an individual proposes to devote 10% of his or her effort to the project, 10% of his or her IBS should be budgeted and charged over the life of the project.

Charging Effort:

Effort charged to a sponsored project should reasonably reflect actual time and effort devoted to the direct benefit of the project.

Principal Investigators and project personnel (investigators, key personnel, other project staff) are expected to charge salaries to the sponsored project according to the effort expended. If all or a portion of compensation is institutionally approved committed cost sharing, that portion of compensation should be charged to an appropriate cost sharing worktag.

It is generally not possible for a faculty member to allocate 100% of their total university effort and pay to sponsored research projects. A corresponding amount of effort for non-research activities (e.g. proposal preparation, committee service) must be allocated to a non-sponsored account.

As a general rule, Principal Investigators on federal projects must obtain prior approval from the sponsor if they are absent for more than three consecutive months or if effort is reduced more than twenty-five percent (25%) from what was awarded. Please consult with the Department of Contracts and Grants for sponsor specific rules regarding prior approvals.

PIs are responsible for agency specific terms and conditions. Please consult with D&C for sponsor specific rules regarding prior approval.

Certain sponsors (e.g. National Institutes of Health) limit the rate at which salaries can be directly charged to their projects. This rate is known as the “salary cap” and limits the total amount of compensation that can be charged to the award. If a faculty member spends 10% effort on the award, 10% of the salary cap for that period may be charged. Salary that exceeds the cap (i.e. the difference between 10% of the faculty’s salary and 10% of the salary cap) must be paid from institutional funds.

Certain types of pay, like “overload” payments and bonus payments should not be charged to sponsored projects without prior approval from the Office of Financial Analysis. If approved, these types of payments are not included in IBS.

Reporting Effort:

Faculty and exempt staff employees involved in research are responsible for certifying that the salary charged to a particular sponsored project accurately reflects the percentage of time/effort that they performed on the project for the time period being certified. The Principal Investigator or his or her authorized designee is responsible for certifying effort on behalf of his or her respective Research Assistants.

Non-exempt staff employee’s effort is tracked by USC’s timekeeping system which serves as documentation of their salary charges.

Failure to adhere to federal effort reporting requirements may result in expenditure disallowances and penalties. USC will take corrective action, including disciplinary measures. Grant spending will be frozen, and new charging will be limited until such time that the outstanding effort certifications are completed. Additionally, grant proposals may be suspended until compliance is achieved.

6. Procedures

Effort Certification

7. Forms

N/A

8. Responsibilities

POSITION or OFFICE	RESPONSIBILITIES
Principal Investigators (PIs)	Principal investigators (PIs) and other project personnel (including co-PIs, investigators, key personnel, and other project staff) are expected to charge salaries to the sponsored project according to the effort actually expended, and never above the actual effort. If salaries are above the National Institutes of Health (NIH) cap, the overage must be charged to an unrestricted institutional account.
Exempt Staff	Exempt staff members on federally sponsored research projects must accurately certify their effort to ensure compliance with federal regulations. They must reasonably estimate and confirm the percentage of their total institutional work spent on the project, ensuring it aligns with payroll charges and cost-sharing commitments. Effort certification must be timely and reflect actual work performed, not just budgeted estimates. Staff should coordinate with principal investigators and administrators to address discrepancies and maintain compliance.
Research Administrators	Research administrators ensure that effort certification processes comply with federal regulations and institutional policies by guiding faculty and staff through accurate reporting. They monitor payroll distributions, assist in resolving discrepancies, and ensure certifications are completed on time to avoid audit risks.
Office of Financial Analysis (OFA)	The Office of Financial Analysis oversees the financial compliance of effort certification, ensuring that salary charges to federally sponsored projects align with certified effort reports. They conduct audits, provide financial reporting, and support departments in maintaining adherence to federal and institutional policies to mitigate risks of disallowed costs.