Effort Reports must be reviewed, corrected and approved within 45 days after initiation.

Section J.10 of the Circular defines allowable compensation for personal services on federal projects and describes methods for documenting personnel activity to ensure that the compensation costs are allowable.

Indiana University uses the “After-the-Fact Activity Records” method for documenting personnel activity. For each individual being compensated via salary or wages for effort being performed on a C&G account, an A-21 Effort Report is created which serves as the confirmation documentation required under OMB Circular A-21.

Per Circular A-21: “To confirm that the distribution of activity represents a reasonable estimate of the work performed by the employee during the period, the reports will be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed.”

A-21 Effort Reports are generated at standard intervals throughout the year. For each project/account in the employee’s regular pay distribution, Effort Reports are routed for approval in the Financial Information System (FIS) to the Fiscal Officer, Account Delegate, or A-21 Delegate. The Fiscal Officer, Account Delegate, or A-21 Delegate has the responsibility for verifying that the effort provided by the employee on the various projects corresponds to the pay distribution across those projects. 

The Fiscal Officer, Account Delegate, or A-21 Delegate may approve the FIS document only if they can personally verify the activity of the employee.

If they cannot personally verify the activity of the employee, they may do one of the following:

1. Ad-hoc route the document to another FIS user who can verify the individual’s activity.
2. Print the document (using the print button in the bottom right corner of the document) and have it signed by a person who can verify the individual’s activity (typically this would mean the employee, the employee’s supervisor, or the principal investigator).  The signed copy, retained by the Fiscal Officer, Account Delegate, or A-21 Delegate at the department, acts as authorization for that individual to approve the FIS document. The signed copy must be retained for 8 years. Storage in an electronic archive, such as OnBase, may be substituted for retaining the original paper copy.
3. Copy an email or other electronic document into the FIS Notes screen from an individual who can verify the individual’s activity, confirming the effort distribution.
4. Attach an electronic document to the FIS Notes screen from an individual who can verify the individual’s activity, confirming the effort distribution.

In most instances, the person signing the printed copy of the Effort Report will be the Project Director, as this person is responsible for the personnel working on the grant in question. Project Directors must sign at the bottom of the printed copy. Corrections to the employee’s effort must be made on all affected account lines. The Fiscal Officer, Account Delegate, or A-21 Delegate must reconcile and post these corrections on the FIS document.

Multiple Project Directors within a department or unit may sign a single printed copy of the Effort Report, and each Project Director should initial the lines for which they are confirming effort. For individuals who have worked in multiple departments or units, each department or unit that prints the Effort Report must maintain a separate copy in their files.

Project Directors or other individuals providing emails or other electronic documents confirming the individual’s effort must reference the FIS document number and also the account numbers for which they are confirming effort. Multiple notes and attachments are permitted on the FIS documents, so this method may be preferable for individuals who have worked for multiple Project Directors or who have worked in multiple units.

Some departments or units track employee effort through timesheets signed by the employee that record not only hours worked but also the specific projects or activities of the individual. In such cases, the timesheets may serve as sufficient documentation for the Fiscal Officer, Account Delegate, or A-21 Delegate to approve the Effort Report.

I-1, Role of Fiscal Officer, Account Manager and Account Supervisor

03-3, Important Notice 03-3

A-21, OMB Circular A-21