Payroll Certification

The Payroll Certification methodology and pilot was performed under OMB Circular A-21 regulations.

Update for OMB Uniform Guidance (UG) §200.430 Compensation – Personal Services: 

The Uniform Guidance is less specific than OMB A-21 about the methodologies to document payroll charges for personal services provided to federally sponsored projects. The UG allows, but does not require, effort reporting and certification. The UG emphasizes strong internal controls and written institutional policies and procedures. Please see Uniform Guidance § 200.430 Compensation – Personal Services for detailed requirements. Several universities intend to adopt methodologies similar to the FDP Payroll Certification methodology described below.

The Payroll Certification methodology: 

OMB Circular A-21 requires institutions to confirm, on an after-the-fact basis, that payroll changes to sponsored programs are commensurate with the effort provided. The A-21 requirements (section J.8) are overly complicated, burdensome and out of date. Regulations require institutions to distribute thousand of “effort reports” to be approved and returned even when there is no change to the payroll data. More importantly, there is widespread recognition that the regulations are not an effective means of assurance. This working group will examine ways to simplify the regulations and find and effective and efficient means to assure that the distribution of salaries and wages to sponsored agreements is appropriate.


  • Survey payroll certification practices at FDP institutions
  • Identify current issues within section J.10 of OMB Circular A-21
  • Develop whitepaper which contains a set of core payroll certification principles.


Pilot Completion Letter to George Mason University
Pilot Completion Letter to Michigan Technological University

Payroll Certification Proposal (January 2011)

Effort Reporting – How Universities Meet the Current Federal Requirements, Council on Governmental Relations, June 1, 2005 (PDF)
Side-by-side Comparison of Proposed Revisions to Current A-21 Section J.10 – September 2005 (PDF)
Proposed Revision to OMB Circular A-21 (Section J.10) – April 2005 (PDF)
Streamlining of the Payroll Certification Requirements Workshop – August 23-24, 2004 (PDF)

Lessons LearnedRich Andrews 

Michigan Tech Update January 2012
Michigan Tech Update May 2012
Michigan Tech Update August 2012
Michigan Tech Update May 2013
Michigan Tech Update January 2014

George Mason Update Sept. 2011
George Mason Update May 2012
George Mason Update May 2013
George Mason Update January 2014

University of California Update January 2014





Debbie Rafi (Co-chair)


Office of Naval Research