Effort Reporting
Effort Reporting
The federal government (per the Uniform Guidance Subpart E §200.430) sets requirements for internal controls over certifying time expended on sponsored projects and requires that salaries paid fully or partly from federal sponsored awards be “certified” in a process that is distinct from appointment and payroll procedures. This payroll certification process is known more generically as “effort reporting.”
Uniform Guidance Section §200.430(c) and Harvard Policy stipulate that:
- Salaries paid must “reasonably reflect the activity for which the employee is compensated by the institution….”
- An “after-the-fact confirmation” of activity must be performed, so that the certification is based on actual, not proposed, costs.
- Activities must be “confirmed by responsible persons with suitable means of verification that the work was performed.”
- Pay must be allocated proportionally among multiple activities in which the employee is involved.
- Salary certification “may reflect categories of activities expressed as a percentage distribution of total activities,” since different institutions define a “full workload” differently.
Faculty effort is certified annually in eCRT; non-faculty effort is certified quarterly by faculty PIs.
Effort reporting is not required for individuals who do not receive salary from Harvard.
Effort reporting is required for those paid on Harvard-sponsored funds through a non-Harvard payroll.
Frequently Asked Questions
Sponsors recognize that effort is often difficult to measure precisely. Per OMB Uniform Guidance, effort certification may rely on reasonable estimates, with some tolerance allowed.
- Faculty and annual certifiers: Variances up to 5% of total salary per award are allowed without adjustment. Variances over 5% must be corrected per the Cost Transfer Policy before certification approval.
- Quarterly certifiers: Variances up to 3% of total salary for the period are acceptable. Variances over 3% must be corrected before final approval, in accordance with the Cost Transfer Policy.
Negative effort often results from incorrectly coded journals, typically related to the period of work performed (PWP). To correct this, the journal may need to be reversed and re-submitted using the GL PCR with the correct PWP. Please contact Linda Ross at Linda_Ross@fas.harvard.edu with any other questions regarding negative effort adjustments.
Manual effort certification is generally discouraged; statements should be certified electronically by the appropriate owner whenever possible.
However, manual certification is acceptable in the following cases (with required backup documentation uploaded to eCRT):
- Certifier unavailable: If the certifier has left the University or lacks eCRT access, the PI may sign a PDF version of the statement without changing the printed percentages.
- Pending journal: If a journal is needed but won’t be processed before the eCRT deadline, effort percentages can be adjusted on a PDF. Backup documentation—and possibly an approved cost transfer form—must be included.
- Non-IBS activity: If non-Institutional Base Salary (IBS) activity is charged to a certifiable object code and skews effort, adjustments may be made. IBS includes guaranteed annual compensation for the appointment term (e.g., 9 or 12 months), but excludes bonuses, one-time payments, incentive pay, external payments, extra compensation from professional education, or outside consulting income.
Effort statements may be voided in two cases:
- The statement shows $0 and 0% effort (often due to miscoded salary later removed).
- Each individual's salary on the statement is ≤ $250 or ≤ 3% of their total salary.
Academic Year Effort
Harvard’s Office of Sponsored Programs has established a school-wide Effort Reporting policy. To support compliance, Harvard uses eCRT to manage effort certification on sponsored projects.
FAS faculty are typically paid over 12 months for 9 months of academic duties. At fiscal year-end, they must certify in eCRT that their effort matched what was performed and paid.
If an award enters a no-cost extension, any existing effort commitment is expected to continue through the extended period.
The Faculty Academic Year Salary Incentive Program (FASIP)
The Faculty Academic Year Salary Incentive Program (FASIP) was first introduced as a two-year pilot program (FY16 & FY17) to enable tenure track, or tenured, faculty to voluntarily charge up to three months of their nine month academic year salary to sponsored awards and receive an incentive payment. The FASIP program became permanent in FY18.
Enhancements effective July 1, 2020:
- Faculty receive 75% of salary and benefit costs charged to awards with the full indirect cost (IDC) rate as discretionary funds. IDC rates
- Awards with a reduced IDC rate now qualify for a 33% incentive.
- These changes broaden access, especially for faculty with foundation or non-federal funding at lower IDC rates.
Related program documents:
Annual Effort for Other Academic Appointments
Effort statements for Research Associates, Instructors, Preceptors, and other employees paid under object code 6030 on sponsored accounts are certified annually in eCRT.
Note: An individual’s classification in eCRT is based on their appointment status when the system goes offline in late June to early July for maintenance. At that time, Harvard loads appointment data for the upcoming fiscal year into eCRT. For example, if someone is appointed as a 6150 when eCRT goes offline, they will appear on their PI’s quarterly project statements for the next fiscal year, even if their appointment is later changed retroactively to 6030 effective July 1.
A Proxy for non-faculty annual certifiers is allowed when there is an assigned mentor or if the appointee is working under the direction of a faculty Principal Investigator. The form must be approved by the Tub Effort Coordinator. No approval by the Office for Sponsored Programs is required.
With sponsor and University approval, faculty may use sponsored funds to supplement up to 3/9ths of their academic salary as compensation for time spent on sponsored research. A supplemental salary request in a grant proposal constitutes a committed effort, which must be fulfilled—even if unpaid—creating a cost-sharing obligation for FAS if not covered by the award.
Since research is part of most faculty roles, sponsored salary usually reflects only part of their total research effort. Any Dean’s ninths, vacation, or non-Harvard activities during summer must be subtracted from the 3/9ths cap, setting the maximum allowable supplemental salary.
Unless otherwise specified, payments should be distributed over the applicable award period, adhering to sponsor and FAS limits. Typically, faculty may not be paid more than 25% of salary from sponsored funds in any one month, except under special circumstances (e.g., fieldwork). This ensures time is reserved for non-chargeable academic activities like proposal writing, course prep, and vacation.
At the end of each fiscal year, faculty must certify that the effort reported was performed and compensated as indicated.
To receive supplemental salary, faculty or authorized proxies must submit a request through the FAS Supplemental Pay, Effort Commitment Tracking and Request Application (SPECTRA). Requests are reviewed and approved by the Department Administrator and FAS Finance. Approved ninths are distributed evenly across the fiscal year and reflected in payroll. More information is available at FAS Finance – SPECTRA.
Faculty and academic appointees are ultimately responsible for proper use of sponsored funds and are best positioned to certify their own effort. Each fiscal year, they must review and certify in eCRT that:
- The effort charged is reasonable for the salary paid,
- The work occurred during the specified time period, and
- Any salary transfers accurately reflect effort performed.
If a faculty member departs before the fiscal year ends, the grant manager should print an off-cycle statement for certification prior to departure.
NIH, Effort, and No-Cost-Extensions
A no-cost extension (NCE) extends a project’s period without additional sponsor funding. Under NIH policy, key personnel must maintain a measurable level of committed effort during the NCE, though it may be reduced from the original level without prior approval—unless the grant terms prohibit it.
For details, see NIH Grants Policy Guide, section 8.1.1.3 – Extension of Final Budget Period.
Note: This applies specifically to NIH, though many sponsors follow similar rules. Always review award terms to confirm requirements for non-NIH projects.
Additional Resources:
- Supplemental Salary Exception Request Guidance and Form
- Supplemental Salary Exception Request Guidance and Form Effective 7/1/2026
- FAS Appointment Handbook. FAS faculty must follow FAS compensation policies regardless of funding source or administering school.
- FAS Guidance for Faculty Supplemental Salary During Medical Leave
Staff Salary Certification
Harvard’s Office of Sponsored Programs has established a University-wide Policy on Effort Reporting to guide certification on sponsored projects. To support compliance, Harvard uses eCRT for salary certification and effort reporting.
Certification is conducted quarterly for all exempt and non-exempt staff, graduate research assistants, postdoctoral fellows, and others whose salaries are partially or fully funded by federal awards.
Process
The Principal Investigator (PI) is ultimately responsible for proper use of sponsored funds and is best positioned to certify employee effort on their projects. Each quarter, the PI must review and certify project-based effort in eCRT, confirming that:
- Each individual paid by the federal award contributed the indicated level of effort
- The work occurred during the stated period
- Any salary transfers or adjustments reflect actual effort on the project.
Procedures
Completion and Certification of Quarterly Project Effort Certifications
Quarterly Project Effort Certifications are generated for each federal award with non-faculty salary charges at the subactivity level. Each certification includes all non-faculty personnel charged during the quarter and follows the fiscal calendar:
- Q1: July–September
- Q2: October–December
- Q3: January–March
- Q4: April–June
Once released, certifications must be completed within the 30 calendar day certification period.
The PI is expected to sign their certifications, confirming they have sufficient knowledge or oversight to verify the work was performed. In some cases, the PI may delegate certification to a qualified designee.
PIs must log in to eCRT each quarter to review and certify effort. Payroll percentages must reasonably reflect actual effort.
- Variances ≤ 3% of total salary per award are allowed without adjustment.
- Variances > 3% must be corrected per the Cost Transfer Policy before certification.
Example: A 40% charge is acceptable if actual effort was between 37%–43%.
FAS PI Designees
All PIs are required to certify their Quarterly Project Effort Certifications. In some cases, the PI may delegate certification to a qualified designee.
- Designee Approval Form – A designee approval form is required when a PI delegates Quarterly Project Effort Certification responsibility to another individual with first-hand knowledge of the PI's sponsored award. Designee requests must be approved by the Tub Effort Coordinator. The FAS Tub Effort Coordinator is Linda Ross.
Note: Lab Directors, administrative staff, and researchers certifying their own salary are not eligible to serve as designees, as they typically lack sufficient first-hand knowledge to verify effort.
Recertification of Quarterly Effort Certifications
If a payroll journal is posted to a sponsored award after certification and causes a variance over 3% (for non-faculty), the certification will be automatically re-opened and must be re-certified by the PI or designee.
Recertifications should be completed by the next certification deadline.
A full version of the University-wide Effort Reporting Policy can be viewed on the OSP website.
How do I avoid issues during my review?
Frequent salary transfers may signal poor grants management to auditors. To avoid this, salaries should be correctly allocated to grants from the start, and staff movement between grants should be minimized.
Administrators should regularly meet with PIs to review project assignments and funding sources and update appointments as needed to prevent future salary transfers.
If a transfer is necessary, add a note in the effort statement explaining the reason. All salary transfers to federal awards must comply with Harvard’s Cost Transfer Policy.