OMB Circular A-21 addresses acceptable levels of documentation and accountability for activities (effort) in relation to compensation (salary and wages) for personal services on federally sponsored agreements. Payroll charged to a federal project should of course never exceed effort expended; however, it is just as important to provide adequate documentation for all effort and labor costs. Both direct and indirect project costs may be disallowed (even after reimbursement) if auditors find that documentation has been inadequate. This Post-award Education Program (PEP) course examines not only the federal requirements that shape institutional policy but also the details of OHSU’s Effort Certification Procedure, including reporting frequency and shared compliance responsibility.