What evidence should support an effort certification.
The certification is the attestation. It is not the evidence.
The circular file
Ask an institution for the evidence behind a certification and a common answer is the certification. A signed record saying the distribution was correct, offered as proof that it was correct.
That is circular and an auditor will say so. The attestation is a statement about the evidence, which means it cannot also be the evidence.
A system of internal control, not a form
The standards are at 2 CFR 200.430(g). They moved there in the April 2024 revision, published at 89 FR 30136, and were previously at paragraph (i).
Records must be supported by a system of internal control giving reasonable assurance that charges are accurate, allowable and properly allocated. The word supporting all of it is system.
No certification form is required. The regulation does not mandate one, and NIH's notice accepts various certification systems.
The question is whether the control around the form produces reasonable assurance. That is what the evidence has to show.
Four things behind every certification
These are categories rather than a template. How you hold them is your choice, and whether you hold them is not.
01The distribution as actually charged
The payroll posted to each award for the period, from the accounting records rather than the certification screen. This is the thing being attested to, and it has to exist independently of the attestation.
02The basis on which that distribution was set
Why the split was what it was. An appointment, a salary cap calculation, a cost share commitment, or a documented change in assignment.
Where charges were made on planned effort, the basis is the estimate, and the regulation then requires an after-the-fact review. That review becomes part of the file.
03The certifier's means of knowledge
A record of why this person was in a position to know. The regulation names no signatory, which is why many institutions require the principal investigator or a direct supervisor.
04The date, and what happened afterwards
When the certification was made relative to the period it covers, and every payroll adjustment posted to that award afterwards.
A retroactive adjustment after certification means somebody attested to a distribution that no longer exists. The file has to show how that was resolved.
Budget estimates are allowed, and they are not support
Estimates may be used for interim accounting, on three conditions:
- The estimating system produces reasonable approximations.
- Significant changes are promptly recorded.
- Periodic after-the-fact reviews are performed, with adjustments made.
Budget estimates alone do not qualify as support for final charges. An institution charging on planned effort with no evidenced after-the-fact review has the first half of an allowed method, not the second.
That is a documentation finding rather than a misspending one, which is why it is easy to carry for years unnoticed. It is also why the after-the-fact review, not the certification, is usually the real control.
What this page does not give you
This is what belongs in the file, and why. It does not give you the evidence log, the sampling approach, the scoring, or the reconciliation to the ledger.
Those instruments are what the paid review is, the same line the free health check holds.
Check these yourself
2 CFR 200.430, eCFR. Paragraph (g) carries the documentation standards, including the conditions on using budget estimates.
NIH NOT-OD-18-108, standards for documentation of personnel expenses.
Two ways to take this further
The free Effort Certification Review checks the population, the routing and the evidence trail on your own export, in your browser, and nothing leaves your machine.
Testing effort certification in Workday is the companion to this page.
The free health check costs nothing and takes about twenty minutes. The Sponsored Award Review is the scored version, where every check carries a second column asking whether you hold the evidence today.