AAU, COGR and APLU recommend that OMB clarify in regulation that personal activity reports are not required under the Uniform Guidance (UG); that awardees do not have to certify payroll expenses; and that cognizant agency approval is not needed to implement alternatives to effort reporting that meet the UG standards of documentation.
The Uniform Guidance provides institutions with increased flexibility to document personnel costs. The preamble to the guidance indicates that while institutions may continue to use personal activity reports to meet the requirements, they are not required. However, the strong language in the preamble has not been codified and out of concern for costly audit findings the majority of institutions are likely to retain this expensive, burdensome and inefficient system, at least in the near-term, despite federal agency encouragement to implement alternatives.
To address institutions’ justifiable concerns about audit findings, OMB should issue a Memo of Clarification indicating that personal activity reports and certification are no longer required and that payroll confirmation and other alternatives to effort reporting that meet the UG standards of documentation are acceptable to the Federal Government, and codify the preamble to the Uniform Guidance (or clarify the regulations).