Time and Effort Report Processing

Purposes of Time and Effort Reporting

The University of Montana’s time and effort reporting system is maintained to meet the requirements of OMB Circular No. A-21. The time and effort report is generated from Banner HR and serves two purposes:

1. Certify that time paid to an individual from a grant was actual time spent working on that particular grant (Time and Effort Certification, left side of the report), and/or

2. Certify that time shown as cost sharing was actual time spent working on that particular grant but charged to another Banner Index Number (Cost Match Certification, right side of report). Funds from a federal grant cannot be used as cost match to another federal grant. State and private funding can be used as cost match on all funding sources.

People are selected for the report in two ways:

1. They are paid directly from a grant.

2. They have been added to FRAGRNT in Banner with a TE indicator because there is a cost match commitment of part of their time on at least one sponsored project. Each ORSP budget analyst maintains a log of cost match commitments for all of their assigned grants that includes source, description, and amount. When the time and effort cost match commitment on a grant has been met, the ORSPS budget analyst notifies the Budget Analyst responsible for TE reporting (TE Budget Analyst) so the TE indicator can be removed in FRAGRNT.

Reports must be certified by individual departments promptly and accurately on a monthly basis. It is a federal requirement that the person signing the reports must have first-hand knowledge of the work performed. This can be direct knowledge (i.e., the employee or their supervisor certifies the time) or indirect knowledge (i.e., a department administrator can certify based on written assurance from someone with firsthand knowledge of the time worked). Each person initialing the report must also sign on the last page. The use of rubber stamps or signing another person’s name followed by initials is not allowed.

Sending Out Time and Effort Reports

Time and Effort Reports are distributed to the departments/units by the TE Budget Analyst within one week after printing of the reports. The Distribution memo explaining time and effort reporting procedures and requirements accompanies the reports. The memo clearly indicates that the time and effort reports are due back within one month of distribution, giving the specific due date. The TE Budget Analyst initiates the Time and Effort Report Distribution Checklist, recording the date the reports were mailed out to each department/unit and the due date for return of the completed reports.

If for any reason it appears the reports may not be sent out within the one-week period, the TE Budget Analyst contacts the Director of Grant Accounting as soon as possible to determine the next course of action. It may be necessary to rearrange duties to ensure the reports are distributed in a timely manner. If the reports do not go out on schedule for any reason, the departments/units are notified by the TE Budget Analyst by memo, indicating when distribution of the reports is anticipated and anticipated due dates for their return. This should allow department personnel ample time to make alternative arrangements to ensure timely submission of the completed reports.

Receiving Completed Time and Effort Reports

When the time and effort reports are received back from departments/units, the TE Budget Analyst logs them in on the Distribution Checklist and carefully checks to make sure that (1) every salary line has either been initialed or marked to indicate that it is not correct and a payroll cost transfer is forthcoming, and (2) everyone who initialed the individual salary lines also signed the certification at the end of the report. If the reports have been completed properly, that is recorded on the T&E checklist. The completed time and effort reports are then distributed to the appropriate grant accountants for their review and the data entry of any cost-sharing information. The budget analysts initial the report and return it to the TE Budget Analyst. Once all reports for the month are returned and verified as completed properly, the Distribution Checklist for that month is filed in the “Completed” section of the Time and Effort Reports notebook and the reports are filed in ORSP.

If the reports have not been completed properly, the TE Budget Analyst immediately returns them to the department/unit with a Deficiency memo, indicating the specific deficiency and giving the department/unit one week to correct it. The date the reports were returned to the department/unit and the due-back date are recorded on the T&E checklist for that department/unit by the TE Budget Analyst. At the same time, this individual initiates a Problem Checklist for each department/unit with incomplete or problem reports.

Dealing with Payroll Redistributions

When ORSP receives a request for payroll redistribution, the budget analysts first verify that the department noted the need for a change on the time and effort report for that period. If the time and effort report has not been completed and returned to ORSP, the budget analyst may process the payroll redistribution (assuming appropriate approvals) but must make a note to verify once the time and effort report is received by ORSP that it includes notation of the need for a payroll redistribution. If no such annotation is included on the time and effort report or the original time and effort is certified as correct on the report, the grant accountant immediately notifies the Director of Grant Accounting to determine the next action to be taken.

If the time and effort report was already returned to ORSP, the budget analyst first verifies that the time and effort report included a notation of the need for payroll redistribution. If that annotation is present on the report, the budget analyst processes the payroll redistribution according to standard procedures. If the report previously submitted to ORSP certified the time and effort as correct, ORSP the budget analyst contacts the department/unit requesting additional documentation from the department/unit to explain why the time and effort was certified as correct when it was not. Upon receipt of the additional requested documentation, the ORSP budget analyst submits to the Director of Grant Accounting the originally certified time and effort report, request for payroll redistribution, and subsequent documentation by the department/unit explaining why the time and effort was certified as correct when it was not. The Director of Grant Accounting will take appropriate action to resolve the situation and will clearly document for the record the action taken.

Once the payroll redistribution is completed, the grant accountant gives a copy of the payroll cost transfer form to the TE Budget Analyst, who files it with the relevant time and effort reports.

Dealing with Past-Due Time and Effort Reports First Notice – Two Weeks Past Due. If the completed time and effort reports are not returned within two weeks of the due date indicated in the distribution memo, the TE Budget Analyst sends a First Notice to the PIs, with a copy to the department/unit support staff person (if applicable), appropriate ORSP budget analysts, and Director of Grant Accounting. This memo notifies the department/unit that the reports are past due, explains the seriousness of not completing the reports in a timely manner, and requires that the completed reports be submitted within two weeks. The TE Budget Analyst initiates a T&E Problem Checklist, noting the date the memo is sent and the date the reports are due back to ORSP. Copies of all correspondence and any other communications concerning this matter (i.e., memos or notes from telephone conversations) are attached to the Problem Checklist and filed under “Current Past-Due Reports.” If the PI responds that more time is needed, the TE Budget Analyst will immediately confer with the Director of Grant Accounting to determine the next action. The TE Budget Analyst and/or the budget analysts cannot agree to any time extensions without the Director of Grant Accounting’s approval. If the completed time and effort reports are returned by the noted due date, the TE Budget Analyst proceeds with the steps outlined under “Receiving Completed Time and Effort Reports” above. If the reports are not submitted by the due date, proceed to the next action.

Second Notice – Four Weeks Past Due. If the two weeks go by and the reports have still not been received, the TE Budget Analyst sends a Second Notice memo to the PIs, with copies to the department/unit support staff person (if applicable), department chair/unit head, appropriate ORSP budget analysts, and Director of Grant Accounting. This memo again indicates the need to complete the report, explains the seriousness of failure to comply, and gives an additional week to get the reports in. The TE Budget Analyst records back on the T&E Problem Checklist the date the memo is sent and the date the completed reports are due back. Copies of all correspondence and any other communications concerning this matter (i.e., memos or notes from telephone conversations) are attached to the Problem Checklist and filed under “Current Past-Due Reports.” If the PI responds that more time is needed, the TE Budget Analyst immediately confers with the Director of Grant Accounting to determine the next action. The TE Budget Analyst and/or the ORSP budget analysts cannot agree to any additional time extensions without the Director of Grant Accounting’s approval. If the completed time and effort reports are returned by the noted due date, the TE Budget Analyst proceeds with the steps outlined under “Receiving Completed Time and Effort Reports” above. If the reports are not submitted by the due date, proceed to the next action.

Final Notice – Six Weeks Past Due. If two weeks go by and the reports are still not received, the TE Budget Analyst immediately notifies the Director of Grant Accounting. The Director of Grant Accounting sends a Final Notice memo to the PIs, with copies to the department/unit support staff person (if applicable), department chair/unit head, dean or executive officer, and appropriate ORSP budget analysts, Associate Vice President for Research, and Director of Internal Audit. This memo again indicates the need to complete the report, explains the seriousness of failure to comply, and states that if the delinquent reports are not received within two weeks the accounts involved will be shut down and ORSP staff will cost transfer uncertified personnel costs to the department/unit’s default account. The TE Budget Analyst records on the T&E Problem Checklist the date the memo is sent and the report due date. Copies of all correspondence and any other communications concerning this matter (i.e., memos or notes from telephone conversations) are attached to the Problem Checklist and filed under “Current Past-Due Reports.” If the completed forms are submitted, the TE Budget Analyst proceeds with the steps outlined under “Receiving Completed Time and Effort Reports.” If the reports are not submitted, proceed to the next action.

Shut Down Notice – Eight Weeks Past Due. If the additional two weeks go by and the completed reports are still not received (the reports are now 8 weeks past due), either the Director of Grant Accounting or the Associate Vice President for Research sends the Shut Down Notice memo notifying the PIs that the accounts are being shut down immediately and uncertified personnel costs are being cost transferred to the department/unit’s default account. Copies are sent to the department/unit support staff person (if applicable), department chair/unit head, dean or executive officer, appropriate ORSP budget analysts, TE Budget Analyst, Director of Grant Accounting, Associate Vice President for Research, and Director of Internal Audit. Upon receipt of the Shut-Down Notice, the appropriate ORSP budget analysts immediately close the accounts and begin transferring unsupported personnel costs. The TE Budget Analyst records these actions and their dates on the T&E Problem Checklist. Copies of all correspondence and any other communications concerning this matter (i.e., memos or notes from telephone conversations) are attached to the Problem Checklist and filed under “Resolved Past-Due Reports.”

Reinstating Shut-Down Accounts. Once accounts are shut down due to non-compliance with time and effort reports, the TE Budget Analyst, Director of Grant Accounting, and Associate Vice President for Research meet with the Director of Internal Audit to determine what corrective measures must be taken before the accounts are reinstated If the certified time and effort reports are subsequently received, the Director of Grant Accounting or Associate Vice President for Research sends a memo to the PIs indicating what actions must be taken to reinstate their accounts and what will be the final dispensation of the transferred salaries and benefits. Copies are sent to the department/unit support staff person (if applicable), department chair/unit head, dean or executive officer, appropriate grant accountants, TE Budget Analyst, Director of Grant Accounting, Associate Vice President for Research, and Director of Internal Audit.

Dealing with Chronic Offenders. At six-month intervals, the TE Budget Analyst reviews files of current and past overdue time and effort reports to determine any chronic offenders. If any department/unit has had more than one past-due notice in the previous six month period, the TE Budget Analyst forwards this information along with copies of all correspondence concerning the past-due reports to the Director of Grant Accounting for review. If there is a pattern of non-compliance (rather than isolated incidents), the Director of Grant Accounting forwards copies of all the documents to the Director of Internal Audit with a cover memo outlining the reason for concern. Copies are sent to the Associate Vice President for Research and appropriate dean or executive officer. The Director of Internal Audit reviews department/unit procedures and reports back to the relevant management personnel with recommendations for the department/unit to improve compliance with time and effort reporting requirements.

Retention of Completed Time and Effort Reports. Time and effort reports need to be retained for the longest retention period applicable to any of the accounts included in the report. When these reports are archived, the latest applicable retention date needs to be clearly indicated on the top of the report, preferably in red ink. The archived reports will be filed in retention date order. Before any reports are destroyed, the retention dates should be verified to ensure that there has not been a subsequent modification to any of the awards that extended the retention period.