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EFFORT REPORTING

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University policy it's just good business. 5. What's the standard? ... East Carolina University - $2.60 million. Harvard/Beth Israel Deaconess MC - $3.25 million ... – PowerPoint PPT presentation

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Title: EFFORT REPORTING


1
EFFORT REPORTING
  • Research Administration Finance
  • October 2009

2
What is Effort Reporting?
  • A retrospective assurance that the time committed
    and/or budgeted corresponds to the time spent and
    effort invested on a given sponsored project for
    a specific period.

3
Why do we certify effort?
  • Employees paid in whole or part from
    extramurally-funded sources required to certify
    to effort/ expended on these projects as a
    condition of accepting the funding.
  • UCHC obligated to provide the administrative
    support and system to facilitate effort
    reporting.
  • Requiredobligated

4
By whom?
  • As a condition of accepting federal funds, we
    (institutionally and individually) agree to meet
    federal guidelines for determining costs
    applicable to Grants (OMB Circular A-21).
  • Other sponsors, including the State of
    Connecticut.
  • University policy its just good business.

5
Whats the standard?
  • The Federal government is the established
    standard. More than 75 of UCHCs research
    are from federal agencies, predominantly the
    National Institutes of Health (NIH).
  • Federal government accepts ambiguity in research
  • In the use of any methods for apportioning
    salaries, it is recognized that, in an academic
    setting, teaching, research, service, and
    administration are often inextricably
    intermingled. A precise assessment of factors
    that contribute to costs is not always feasible,
    nor is it expected. Reliance, therefore, is
    placed on estimates in which a degree of
    tolerance is appropriate.
  • OMB Cir A-21, Section J10b(1)(c)
  • But institutional policies and procedures are
    required.

6
What Criteria is Expected by the Federal
Government to Meet the Standard?
  • OMB Circular A-21, Section J.10.b(2)
  • A system of allocating salaries based on effort
    that is incorporated into the official records of
    the institution.
  • Must reasonably reflect the activity of the
    employee.
  • May be made initially on the basis of estimates,
    but significant changes must be identified and
    entered into the payroll distribution system.
  • An after-the-fact confirmation by a responsible
    person with suitable means of verification that
    the work was performed.

7
Mistake or Fraud?
The Federal Government has the power to impose
sanctions on you and the institution for actions
deemed to be fraudulent. These sanctions, and
other actions, include
  • Cost disallowances and fines if effort reported
    does not appear reasonable.
  • Special monitoring.
  • Name in the news.
  • Fraud violations may subject both institution and
    individual to civil and criminal prosecution.

8
The Bottom Line
  • Recent civil settlements between other research
    institutions and the Federal Government
  • Yale - 7.60 million
  • Northwestern - 5.50 million
  • Johns Hopkins - 2.60 million (for 1 PI)
  • East Carolina University - 2.60 million
  • Harvard/Beth Israel Deaconess MC - 3.25 million

9
The Bottom Line continued
UCHCs policies and procedures exist to guide and
protect researchers and the institution. Recent
effort reporting audits have sited UCHC for the
following
  • UCHC A-133 audit findings
  • 2008 Effort reports not certified on a timely
    basis become questioned costs and therefore
    material findings.
  • 2008 Particularly successful PI had 99 effort
    approved to research.
  • 2007 PI shares password.
  • 2007 Labor distribution change authorization
    (LDCA) are requested after effort has been
    certified what is the basis for the
    certification in the first place?
  • UCHC aggressively enforces our policies and
    procedures because it is the right thing to do.

10
Red Flags
What types of activities cause concern for UCHC
and how do we mitigate them?
  • Significant number of re-certifications
    Pro-actively manage effort.
  • More than 95 effort on sponsored accounts
    review effort commitments with Chair and AVP
    Research Administration Finance on semi-annual
    basis.
  • Non-organized research sponsored accounts with 0
    effort (clinical trials) whats the
    justification, does it make sense?
  • NIH salary cap violations track salary cap
    investigators and review direct charges to
    grants.
  • 1st hand knowledge test did the investigator
    have 1st hand knowledge? If not, who did?
  • Accounts where effort is promised but none
    delivered.
  • Federal standard applies to all sponsored
    accounts.

11
Red Flags (continued)
  • Late or missing effort reports will result in
    suspension of spending privileges.
  • Data inconsistency between financial and effort
    reporting data and other sources of effort data
  • Time allocated to non-research activities
  • Teaching/Clinic
  • Committees/NIH Study Sections
  • Chair responsibilities
  • Payroll records
  • Tenure material
  • NIH Biographical Sketches and JIT Other Support
    pages
  • Progress Reports

12
The Details
  1. Who must file effort reports?
  2. What is effort and how is it determined?
  3. What is Cost Share?
  4. What is Salary Cap Cost Share?
  5. What about changes to effort?
  6. What do I do when a grant goes into a No Cost
    Extension?
  7. What is our process for reporting effort?

13
1. Who must file Effort Reports?
  • Faculty who receive salary support from a
    sponsored account and/or have committed effort on
    a sponsored account.
  • Staff who receive salary support from a sponsored
    account or who devoted effort to a grant as cost
    sharing (limited by UCHC policy 2002-14). Staff
    effort reports are filed by the PI.

14
2. What is effort and how is it determined?
  • Time devoted to all institutional activities
    expressed as a of total institutional
    activities.
  • Total institutional activities includes time
    spent on
  • Patient care
  • Research
  • Chair and committee responsibilities
  • NIH study sections
  • Education
  • Institutional activities do not include external
    professional activities for which you receive
    remuneration.
  • Effort is NOT a 40-hour work week. It is how you
    allocate your time across ALL your faculty
    activities.

15
3. What is Cost Share?
  • Cost share is that portion of an employees
    effort or salary that is paid by the institution,
    rather than the sponsor.
  • Cost sharing of effort can be mandatory (required
    by the sponsor) or voluntary.
  • Cost sharing of salary as a result of the sponsor
    limiting the salary chargeable to a grant is
    salary cap cost share.
  • See policy 2002-14.

16
3a. Effort Cost Sharing
  • UCHC only recognizes committed effort cost
    sharing.
  • Committed effort cost share is a binding
    commitment between UCHC, the employee, and
    sponsor.
  • UCHC requires prior approval for cost share
    before proposal submitted.
  • Cost sharing is limited to PI and key personnel.
  • Committed cost share can be mandatory (required
    by the sponsor) or voluntary.
  • Voluntary committed cost share becomes mandatory
    when approved/awarded by the sponsor.
  • See policy 2002-14.

17
4. Salary Cap Cost Sharing
  • Certain sponsors, including the National
    Institutes of Health, limit the amount of salary
    that can be direct charged to a grant.
  • 2009 salary cap 196,700
  • Proportional amounts over this cap must be
    reported as Salary Cap Cost Share.
  • An employee making 200,000 and committed 50 to
    a grant would have a salary cap cost share amount
    of 1,650.
  • (200,000 .5)-(196,700 .5) 1,650
  • Salary Cap Cost Share does not impact effort. It
    is a transfer of salary only from the
    sponsored account to the cost share account.
  • With version 2.0 of ERS, Research Finance will
    track salary cap cost share and transfers
    dollars, leaving the effort report intact for
    certifying effort.

18
5. What do I do when my effort changes?
  • Effort on a sponsored account should match the
    commitment approved in the grant proposal.
  • Changes to effort should be made according to the
    terms of the award. Federal requirements require
    prior notification for reductions of effort
    amounting to 25 or greater.
  • Prospective changes
  • Use the Assignment Authorization process to
    change future allocation of effort.
  • Retrospective changes
  • Use Labor Distribution Change Authorization
    (LDCA) process to change posted payroll charges.
    Allowable retrospective changes include
  • Changes to the current effort reporting period or
    older periods when effort has not yet been
    certified.
  • Changes to certified effort only permitted with
    Research Finance approval.

19
What happens to effort during a
No-Cost-Extension
  • A no-cost-extension is considered an extension of
    the project as approved.
  • PI effort must continue to be direct charged to
    the grant or cost-shared as previously approved.
  • Effort can be reduced by following the process
    defined previously.

20
7. What is UCHCs effort reporting process?
  • UCHCs Effort Reporting System (ERS), was
    designed and developed by UCHC to meet the
    reporting needs of our research community.
  • ERS is available on-line from any computer (Mac
    or PC) with internet access and a commonly used
    web-browser, such as Internet Explorer or
    Firefox.
  • The next series of slides are click-by-click
    demonstrations of the ERS system. Some material
    is generic to the ERS system, others are specific
    to roles within the system, such as investigator,
    and department administrators.

21
ERS Access
  • Training will be conducted in the Test
    Environment at
  • https//uat-home.uchc.edu/TimeAndEffort/Security/L
    ocalLogin.aspx
  • ERS (in production) will available on October
    16th at
  • https//home.uchc.edu/Portal/Security/Login.aspx

22
ERS Key Dates
Fiscal Year 2010 Key Dates Fiscal Year 2010 Key Dates Fiscal Year 2010 Key Dates Fiscal Year 2010 Key Dates
Data loaded for quarter September 30, 2009 December 31, 2009 March 31, 2009 June 30, 2009
Application available for Department Administrator approvals/changes (22 days) October 15, 2009 January 15, 2010 April 15, 2009 July 15, 2009
Effort reports on approved "system" approved and pushed to PIs for certification November 6, 2009 February 6, 2010 May 7, 2009 August 6, 2009
PI certifications and close of quarter December 14, 2009 March 16, 2010 June 14, 2009 September 13, 2009

Fiscal Year 2011 Key Dates Fiscal Year 2011 Key Dates Fiscal Year 2011 Key Dates Fiscal Year 2011 Key Dates
Data loaded for quarter September 30, 2010 December 31, 2010 March 31, 2011 June 30, 2011
Application available for Department Administrator approvals/changes (22 days) October 15, 2010 January 15, 2011 April 15, 2011 July 15, 2011
Effort reports on approved "system" approved and pushed to PIs for certification November 6, 2010 February 6, 2011 May 7, 2011 August 6, 2011
PI certifications and close of quarter December 14, 2010 March 16, 2011 June 14, 2011 September 13, 2011
23
ERS Tutorials (to be added)
  • Logging into ERS
  • Department Administrator role
  • Delegating effort approvals to other
    administrators
  • Approving effort as reported
  • Approving effort with changes
  • Creating an LDCA outside of Effort Reporting
  • Principal Investigator role
  • Certifying effort
  • Rejecting effort
  • Research Employee role
  • Viewing effort report
  • Other roles
  • Dean
  • Department Chair
  • Budget and Finance
  • Research Finance
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