Effort Reporting

VUMC complies with federal regulations as defined by the Office of Management and Budget (OMB) Circular Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. To adhere to Uniform Guidance Subpart E §​200.403 (formerly A-21), VUMC requires all individuals who performed work on a federally funded project or the project's principal investigator to report effort.

Effort reporting is used to provide assurance to federal or other external sponsors that salaries charged or cost shared to sponsored awards are reasonable in relation to the work performed.

Non-compliance with this regulation may result in the disallowance of cost for salary and wages, thereby limiting the recovery of F&A costs. Failure to follow this requirement may also jeopardize future funding.


Principal Investigator

  • Comply with effort reporting policy
  • Verify personnel under PI are familiar with effort reporting policy
  • Complete certification of own effort and personnel effort in a timely manner

Department, Institute, or Center

  • Comply with effort reporting policy
  • Verify faculty, staff, and students working on federally funded project understand and comply with effort reporting policy
  • Maintain systems to track and process new hire information, payroll changes, and earning distribution changes (EDCs)
  • Ensure payroll forms processed outside of ePAC have signed certification statements when appropriate

The VUMC Effort Reporting Policy can be found on VUMC Finance's website.