Following the issuance of Uniform Guidance (2 CFR 200), the Office of Management and Budget (OMB) confirmed that effort certification is not a requirement of §200.430; rather, that strong internal controls are the key to compliance with §200.430. Consequently, Arizona State University recently retired our Effort Reporting System following the completion of effort certification for the 2017-3 effort period ended 12/31/2017.
OKED is developing an After-the-Fact Review Report tool which will be used in place of effort certification to meet the compliance requirements of 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses. This tool, in combination with our existing strong internal control system, will provide a less cumbersome, more intuitive means for ensuring compliance with OMB requirements.
Announcements about the launch date for the After-the-Fact Review Report tool and the availability of related training and reference materials will be posted to the Research Operations News site. Stay tuned!