Effort Reporting: Who, What, When, Where, Why And How

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Effort Reporting Who, What, When, Where, Why
And How
OFFICE OF SPONSORED RESEARCH ADMINISTRATIONApril
28, 2009
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The Agenda

• Definition of Effort
• Definition of Effort Reporting
• Definition OMB Circular A-21
• The Cycle of Effort Reporting
• Difference between Effort Reporting and Payroll
  Distribution
• Overview of Reporting Requirements
• Who, What, When, Where, Why (but not in that
  order)
• Important Things to Consider
• Current Issues
• Direct Charged vs. Cost Shared
• Effort vs. Pay
• The Effort Reporting Process
• Managing Effort Commitments
• Summer Effort on Sponsored Projects

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Definition of Effort

• effort (n.) - the proportion of time spent on
  any activity and expressed as a percentage of the
  total professional activity for which an
  individual is employed by the institution

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In other words
Employee must account for all activities in
his/her assignment

• For Faculty, this usually means
• Teaching
• Research
• Service
• Advising

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What kind of effort must be reported?

• The Effort Report must account for all effort the
  University compensates the individual
• Sponsored Activities
• All effort expended on sponsored projects and
  cost shared
• Institutional Activities
• Department Administration
• Instruction and unsponsored scholarly activity
• Academic setting for faculty (Teaching, research,
  service, advising)
• Clinical activity

What is excluded from the effort
calculations?

• Effort Report must exclude from the effort
  calculations the following
• Extra State Compensation/Overload
• Outside consulting work
• Educational Incentives (stipend)
• Recognition Awards
• Bonus
• Lump Sum
• Additional Compensation

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WHAT is Effort Reporting?

• Effort Reporting is the means
• that Federal agencies have
• to verify that salary dollars
• were charged properly,
• either direct-charged or cost-shared

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What is the OMB Circular A-21 (Office of
Management and Budget)

• The OMB Circular A-21, Cost Principles for
  Educational Institutions, is the primary federal
  guidance on cost principals and requirements
  applicable to grants, contracts, and other
  agreements
• Effort reporting regulations are defined
  primarily in OMB Circular A-21

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Why is Effort Reporting Required?

• Effort reporting is a Federal requirement. It is
  mandated by the Office of Management and Budget
  (OMB) in the regulation referred as OMB Circular
  A-21
• Requires a confirmation of effort of all
  individuals performing services on a sponsored
  project when all or a portion of their salary is
  charged to the sponsored project
• After-the-fact is the method FIU uses to
  demonstrate that individuals who are paid on
  federal funds have contributed the required
  effort

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THE CYCLE FOR EFFORT REPORTING

• Grant is awarded with specified level of effort
  to perform the Research
• Investigator/ Department Administrator
  establishes payroll distribution based on
  estimated effort
• If estimated effort changes
• Process payroll adjustments for prior pay period
• Change salary distributions for future pay
  periods
• End of the semester effort reports are produced
  based on the salary distributions

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WHAT is the difference between Effort Reporting
and Payroll Distribution?

• Payroll distributions and effort reports are not
  the same thing
• Payroll distributions are the distribution of an
  individuals salary
• Effort reports describe the allocation of an
  individual's actual effort spent for specific
  projects, whether or not reimbursed by the
  sponsor
• Thus, effort reporting is separate from and can
  be independent of salary charges
• Effort is not just a verification of the salary
  or payroll distribution. Cost-shared or
  contributed effort must be included in effort
  reports

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WHO has to certify Effort?

• FIU employee
• (Faculty, Administrative, Staff, Temporary)
• who works any portion of his/her time
• on sponsored projects or activities
• whether compensated or uncompensated
• by that project

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WHEN should one certify?

• THREE TIMES PER YEAR
• at the end of each semester
• FALL
• SPRING
• SUMMER C
• ( A B as an average)

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WHERE?

• It depends on who you are
• FACULTY, Administrative, Staff (Exempt) and
  Graduate Assistants
• Via the Time Effort Certification System
  (TECS)
• a web-based system that tracks effort
  commitments and allows employee to certify effort
  online
• Staff (Non-exempt) and Temporary (non contract)
• Timesaver Time entry system for hourly and
  salaried employee

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Important Things to Consider
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• Effort Reporting
• is a reasonable estimate,
• not an exact science

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• Degree of Tolerance Certification must rely on a
  reasonable estimate of effort during a specified
  time period, and when estimating, a degree of
  tolerance is acceptable and appropriate. FIU
  recognizes this degree of tolerance to be no more
  than /- 5
• Payroll Adjustment Anytime that payroll does not
  accurately reflect how the employee spent his/her
  time on the certified effort report by a margin
  of /- 5, a payroll transfer request is
  necessary
• Exact Assessment Activities that comprise an
  individuals total effort (teaching, research,
  service, administration, etc) are often difficult
  to separate and that an exact assessment of
  factors that contribute to costs is not always
  feasible, nor is it expected

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• Effort is
• not based on a
• 40-hour work week

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• Normal Work Week Effort is not calculated on a
  40-hour workweek or other University approved
  standard workweek. Effort is expressed as a
  percentage based on the total number of hours
  worked by the individual
• Example If the employee worked 40 hours in one
  week on a sponsored project and 20 hours in the
  same week on an unrelated University project,
  then the employees effort report should show
• 67 effort devoted to the sponsored project
• 40 hours / 60 total-effort hours 67
• and 33 on the unrelated University project
• 20 hours / 60 total-effort hours 33
• Extra State Compensation (aka Overload) Effort
  Certification does not include effort for which
  the employee receives compensation directly from
  another entity (e.g., outside consulting work) or
  incidental work for which supplemental
  compensation (i.e., extra state/overload
  compensation) is paid

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• Total Effort
• must equal 100.
• The total effort expended cannot be more than or
  less than 100 regardless of the FTE

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• Effort Certification must be performed by
  someone with first-hand knowledge of an
  employees effort

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• First-Hand Knowledge Either the individual or
  someone having firsthand knowledge of the
  activities performed by the employee must certify
  effort reports
• Suitable Means of Verification The person
  signing the effort report must have "suitable
  means of verification that the work was
  performed." In most cases, this will be the
  employee performing the work
• Employees Absence In the employees absence,
  the Principal Investigator for a specific project
  may certify the effort of the employees working
  on the PIs project. The PI must be able to
  provide verification that persons paid on their
  sponsored projects actually performed the work
• Departmental Staff Certification of effort by a
  departmental secretary or other staff is not
  permitted

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Is It Direct-ChargedorIs It Cost-Shared?
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Direct-Charged

• Any time Effort is charged directly to a Funding
  Agency through the ADP Payroll System (timesaver,
  employment contract, etc.), then the salary is
  said to be direct-charged

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Cost-sharing

• Any time that Effort is expended towards a
  project, and the salary is not recovered from the
  project, the Effort is cost-shared

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3 Types of Cost-Sharing

• Mandatory/Committed cost sharing that is
  required by the sponsor, documented in the
  proposal and agreed to in the sponsors awarding
  documents
• Voluntary/Committed cost sharing that the
  sponsor did not require, but the proposal
  nonetheless included, and subsequently became a
  condition of the award
• Voluntary/Uncommitted cost sharing that the
  University expended on the project, but was not
  required by the sponsor nor was it included in
  the proposal document. This type of cost sharing
  occurs when effort exceeds pay
• Mandatory-Committed and Voluntary-Committed must
  be tracked and reported to the agency

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EFFORTvs.PAYWhats the Difference?
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• All work performed on sponsored projects (whether
  employee was compensated from the Funding Agency
  or not) must be certified
• The effort certification report should list all
  the projects that the employee is working on and
  the effort towards each, whether or not the
  project paid for the employees salary. Specific
  non-related effort not paid by the grant must be
  listed as cost share on the effort report
• If payroll does not reflect (within the /- 5
  margin) the correct effort, then a payroll
  transfer is necessary

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Managing Effort Commitments

• Faculty charging 100 effort to Sponsored
  Programs
• Faculty must be able to justify charges to
  satisfy potential audits
• Bids proposals cannot be charged to a project
• A PI or Co-PI with 100 effort on projects can
  not have teaching or service commitments nor work
  on proposals

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Managing Effort Commitments

• Key personnel may reduce their effort on
  sponsored programs by less than 25
• Effort changes may require sponsor prior
  approval in accordance with sponsor guidelines or
  the award document
• Reduction of effort necessitates a review of
  payroll within the /- 5 margin (effort cannot
  be less than charged )

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SUMMER EFFORT ON SPONSORED PROJECTS

• Summer salary is allowable subject to regulations
  of the funding agency and the Universitys
  policies
• Faculty who receive summer salary must expend
  effort during the summer period
• A faculty member may receive no more than three
  months of summer salary, or three-ninths of the
  regular academic year

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Effort Certification Process- Data

• OSRA requests direct- charge payroll data from
  FIUs ADP Payroll System.
• Current award data is requested from the InfoEd
  system.
• Both data are uploaded into the TECS system.
• Personalized Effort Reports are built for all
  individuals who are required
• to certify effort.

TECS system distributes these pre-printed report
to all faculty and staff who have any portion of
their time dedicated to sponsored research
3 times per year (Fall, Spring, and Summer C)
Employees must respond within 30 days after the
effort report e-mail distribution
Effort Reports must be completed in a timely
manner
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SAMPLE OF TIME EFFORT CERTIFICATION REPORT
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 At the end of each academic semester (Fall,
Spring, Summer), a personalized Time Effort
(TE) report is emailed to all employees who had
effort allocated to sponsored project(s) either
as a direct charge to a grant project or as cost
sharing.  The information contained in your TE
report is based on the Universitys payroll
system and your research file(s) in the Office of
Sponsored Research Administration.    TO
COMPLETE THE ELECTRONIC CERTIFICATION
PROCESS 1.        Review the information
contained in Sections A B of your effort
report.  If you need to change an item that you
disagree with, select Edit at the end of the
row.  Make the appropriate change(s) and select
Update.  Selecting Cancel will return you to the
main screen without saving your change(s).Note
Changes to direct charge in excess of /- 5 will
require a redistribution of your salary (payroll
transfer) over the reporting period.2.       If
you devoted effort to a project/department ID
that does not appear in Sections A or B, enter
that information in the project ID box provided
and click on the yellow box beneath.Note Effort
associated with a new project that exceeds 5
will require a payroll transfer to be completed
unless the effort is approved cost
sharing.3.       If the project ID is not on
file, you will receive an error message. Do not
click on the Green Certify Button. Instead,
send an email to tecert_at_fiu.edu with the name,
project ID and the effort you have committed
to the project. Once this information has been
added to the TEC system, a revised effort report
will be emailed to you. 4.       After you have
reviewed your effort report, click on the green
certify button to certify your effort for the
semester.Your total effort must equal 100
during any one semester, regardless of your FTE. 
You will not be able to certify your effort if
the total is more or less than 100.  IMPORTANT
Individuals who make changes to direct charge
in excess of 5 will receive an email requesting
a payroll transfer to reconcile the changes.
This transfer must be submitted within 1-business
day of certification. Certification will not be
accepted as complete until the transfer has been
approved. QUESTIONS/ADDITIONAL INFORMATION
Please direct any questions to http//us.f545.mail
.yahoo.com/ym/Compose?Totecert_at_fiu.edu or visit
the OSRA Time and Effort page  (http//www.fiu.edu
/dsrt/time.htm).
INSTRUCTIONS FOR CERTIFYING YOUR TIME EFFORT
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Effort Certification Process Agree
Employee reviews the report for accuracy
Reports are generated and sent out
End of Semester rolls around
Salary Costs charged based on work performed
Employee agrees and certifies report
OSRA reviews Certified Report
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Effort Certification Process - Disagree

• I

Employee makes amendments and certify the report
Employee disagrees with the report
OSRA reviews Certified Report
Employee sends additional request to
tecert_at_fiu.edu a revised report will be sent for
certification
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Effort Certification Process - Adjustments

• All payroll adjustments need to be submitted
  within 24-hours of effort certification
• An email will be sent to the PI/ individual
  certifying requesting the payroll transfer
• Certified report will not be accepted as
  completed without the transfer
• No re-certifications without proper justification
  and payroll transfer

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SAMPLE- REVISED PAYROLL TRANSFER FORM
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Appropriate Effort Report Practices

• Submit payroll adjustments on a bi-weekly basis,
  do not wait until the end of the semester
• Submit effort certification in a timely manner.
  Effort Reporting should be collected within 30
  days following the distribution
• Do not designate certification role to
  departmental staff
• The first three items are necessary for FIU to
  complete effort reporting in a manner that
  maintains compliance

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ROLES RESPONSABILITIES INVOLVING EFFORT
REPORTING

• GRANTS ADMINISTRATORS
• Process any personnel cost transfers resulting
  from discrepancies between certified effort and
  payroll distribution
• ACADEMIC DEPARTMENT
• Principal Investigator
• Certifies that the Effort is accurate on the
  Effort Report
• Certifies that the effort for all professional
  staff that work on his or her projects during the
  applicable time period is accurate.
• Certifies all labor-related cost-sharing
• A PI should not certify for another faculty
  member, even if the faculty member worked on one
  or more of the PIs projects
• Department Chair and College Dean
• Reviews and certifies Effort Reports for faculty
  who are unavailable for signature

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Effort Reporting Must be Timely

• Employee certifications must be submitted to OSRA
  within 30 days of the initial email of the effort
  report from OSRA to the employee each reporting
  period
• PI is responsible for ensuring that all persons
  working on his/her sponsored project timely
  certifies their effort
• OSRA will keep PI apprised of any delinquent
  effort reports for any person on the PIs
  sponsored project so that the PI may follow up
  with that person to ensure that he/she promptly
  certifies his/her effort
• The OSRA Effort Reporting and Certification
  Policy contains a Certification Timeline, which
  includes penalties for late certification, which
  may include putting the project on hold and
  prohibiting new grant submissions by the PI

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Related References

• Office of Management and Budget, Circular A-21
  found online http//www.whitehouse.gov/omb/circul
  ars/a021/a21_2004.html
• (1) Council on Government Relations March 1, 2007
  Recent COGR News http//www.cogr.edu/
• Office of Management and Budget, Memorandum
  M-01-06, Clarification of OMB A-21 Treatment of
  Voluntary Uncommitted Cost Sharing and Tuition
  Remission Costs (January 5, 2001) found online
  http//www.whitehouse.gov/omb/memoranda/m01-06.htm
  l
• (1) Council on Government Relations March 1, 2007
  Recent COGR News http//www.cogr.edu/
• Research Administration Web Site
  http//www.OSRA.fiu.edu/

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University Related Policies

• Cost Sharing in Sponsored Projects
• http//policies.fiu.edu/record_profile.php?id244
  scost20share
• Effort Reporting and Certification
• http//policies.fiu.edu/record_profile.php?id350
  seffort20reporting
• No-Cost Extension of Sponsored Projects
• http//policies.fiu.edu/record_profile.php?id259
  sno20cost20extension
• Personnel Effort Pledged on Proposal for
  Sponsored Project
• http//policies.fiu.edu/record_profile.php?id264
  seffort20reporting
• Cost and Payroll Transfers on Sponsored Project
• http//policies.fiu.edu/record_profile.php?id266
  seffort20reporting
• Only Allowable Direct Charge may be Charged on
  Federally Sponsored Project Proposals
• http//policies.fiu.edu/record_profile.php?id260
  ssponsored20research
• Tracking Cost Share on Sponsored Project Award
• http//policies.fiu.edu/record_profile.php?id370
  ssponsored20research

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When In Doubt?

• Email tecert_at_fiu.edu
• Call Yolanda Ruggiero Cardoch (7-1795)
• Visit MARC 410