Federal regulations issued by the Office of Management & Budget (OMB) require employees performing work on sponsored agreements to certify university work efforts as a distribution of 100% of total compensated time worked. UK has chosen the After-the-Fact effort reporting method described in Section J.8 of OMB Circular A-21 to meet the requirement for certifying effort on sponsored project agreements. 


Federal regulations for "after the fact activity records" requires that confirmation of the effort on Effort Reports be signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed. Having first-hand knowledge of the work performed and the ability to make a reasonable estimate of the effort expended on each sponsored project is key to fulfilling this requirement.