EFFORT REPORTING

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EFFORT REPORTING

• Research Administration Finance
• October 2009

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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.

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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

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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.

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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.

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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.

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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.

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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

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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.

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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.

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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

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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?

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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.

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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

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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
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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