Testing effort certification in Workday.
Configuration documentation explains how to set it up. This is about finding out whether yours works.
The testing layer is not written down
In September 2026 I asked ChatGPT, Perplexity and Google AI Mode how to test effort certification. The first pointed to Workday's documentation, which explains how to configure it.
That is the closest thing that exists. The setup layer is well documented and the regulation layer is public, and I found little written about the layer in between.
Check which paragraph your policy cites
The documentation standards are at 2 CFR 200.430(g). They were at paragraph (i) before the April 2024 revision, published at 89 FR 30136.
Paragraph (i) is now a different subject. It covers Institutions of Higher Education, so a policy citing 200.430(i) for documentation standards points at the wrong text.
NIH's 2017 notice cites 45 CFR 75.430(i). HHS moved to 2 CFR 200 from 1 October 2025, so newer awards fall under 200.430(g).
Do this before an auditor does. A policy citing a paragraph that no longer says what it claims is a problem before anyone opens a certification.
Six requirements, and no required form
Records charged to federal awards for personnel costs must meet all six. The wording below is the regulation's, condensed.
- Supported by a system of internal control. The control has to give reasonable assurance that the charges are accurate, allowable and properly allocated.
- Incorporated into the official records. A spreadsheet held by one administrator is not the official record of the institution.
- Reasonably reflect total activity. Not exceeding one hundred percent of the activity the employee is compensated for.
- Cover federally assisted and all other activity, on an integrated basis. Effort on a federal award cannot be documented in isolation from the rest of the person's work.
- Comply with the institution's own accounting policies. Your own written policy becomes the standard you are tested against.
- Support the distribution across activities where the employee works on more than one award or activity.
There is no required certification form
The regulation mandates no certification form or effort system, and NIH accepts various systems. Records may express activity as a percentage distribution.
Budget estimates alone do not qualify as support. They 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 happen, with adjustments made.
Many institutions sit right here. Charges follow planned effort and the after-the-fact review is the control, so test the review, not the certification screen.
Seven questions worth asking about your own tenant
None of these require access to anything confidential. All of them are answerable by the people who already run the process.
01Does the population match
List who should have certified from payroll charged to awards, then compare it to who the system asked. The two lists drift, and nobody notices until they sit side by side.
02When was it certified
Date each certification against the period it covers, not the task. Eleven months late is a different control from one month late, yet both show as complete.
03Who actually certified
Check that whoever clicked is the person the policy names, and whether delegation was used. The regulation requires internal control. An unexplained delegation breaks it.
04What could the certifier see
Find out what was in front of the person when they certified. If they saw a percentage with no underlying distribution, the attestation is about a number, not about work performed.
05What happens to payroll charged after certification
Retroactive payroll adjustments change a distribution someone already attested to. Does your configuration re-open the certification? In many tenants, nothing does.
06Does it reconcile to the ledger
The certified distribution and the payroll posted to the award are two separate records. A difference is not always an error. An unexplained one is a finding.
07Could you reproduce it in eighteen months
An auditor asks for one certification from two years ago and everything behind it. Can you produce the distribution, its basis and the certifier without working from memory?
What this page does not give you
This is the list of questions and the reasoning behind them. It does not give you the sampling approach, the scoring, the reconciliation logic or the evidence log.
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. The page shows the amendment note.
NIH NOT-OD-18-108, standards for documentation of personnel expenses.
Two ways to take this further
The free Effort Certification Review runs this test on your own export, in your browser, and nothing leaves your machine.
What evidence should support an effort certification is the companion to this page.
The free health check runs sixteen checks per area across four areas and costs nothing. The Sponsored Award Review is the scored version, forty-four checks with an evidence column.