Transcript Effort Reporting Training Module

EFFORT REPORTING
Research Administration & Finance
October 2009
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What is Effort Reporting?
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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?
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Employees paid in whole or part from
extramurally-funded sources required to
certify to effort/$$ expended on these projects
as a condition of accepting the funding.
UCHC obligated to provide the administrative
support and system to facilitate effort
reporting.
Required…obligated…
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By whom?
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As a condition of accepting federal funds, we
(institutionally and individually) agree to meet
federal guidelines for determining costs
applicable to Grants (OMB Circular A-21).
Other sponsors, including the State of
Connecticut.
University policy – it’s just good business.
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What’s the standard?
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The Federal government is the established standard. More
than 75% of UCHC’s research $$ are from federal agencies,
predominantly the National Institutes of Health (NIH).
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Federal government accepts ambiguity in research:
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“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)
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But institutional policies and procedures are required.
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What Criteria is Expected by the Federal
Government to Meet the Standard?
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OMB Circular A-21, Section J.10.b(2)
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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…
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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
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Recent civil settlements between other
research institutions and the Federal
Government:
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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
UCHC’s policies and procedures exist to guide and protect researchers and the
institution. Recent effort reporting audits have sited UCHC for the following:
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UCHC A-133 audit findings:
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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?
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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) – what’s 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)
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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:
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Time allocated to non-research activities
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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.
2.
3.
4.
5.
6.
7.
Who must file effort reports?
What is effort and how is it determined?
What is Cost Share?
What is Salary Cap Cost Share?
What about changes to effort?
What do I do when a grant goes into a “No
Cost Extension?”
What is our process for reporting effort?
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1. Who must file Effort Reports?
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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?
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Time devoted to all institutional activities expressed as a % of
total institutional activities.
Total institutional activities includes time spent on:
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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?
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Cost share is that portion of an employee’s 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
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UCHC only recognizes “committed effort” cost
sharing.
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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
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Certain sponsors, including the National Institutes of Health,
limit the amount of salary that can be direct charged to a
grant.
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2009 salary cap = $196,700
Proportional amounts over this cap must be reported as Salary Cap
Cost Share.
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An employee making $200,000 and committed 50% to a grant would
have a salary cap cost share amount of $1,650.
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(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?
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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:
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Use the Assignment Authorization process to change future
allocation of effort.
Retrospective changes:
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Use Labor Distribution Change Authorization (LDCA) process to
change posted payroll charges. Allowable retrospective changes
include:
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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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6. What happens to effort during a
“No-Cost-Extension”
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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 UCHC’s effort reporting process?
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UCHC’s 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 webbrowser, 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
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Training will be conducted in the “Test”
Environment at :
https://uat-home.uchc.edu/TimeAndEffort/Security/LocalLogin.aspx
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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
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
December 14, 2009
March 16, 2010
June 14, 2009
September 13, 2009
PI certifications and close of quarter
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
December 14, 2010
March 16, 2011
June 14, 2011
September 13, 2011
PI certifications and close of quarter
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ERS Tutorials (to be added)
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Logging into ERS
Department Administrator role
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Principal Investigator role
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Certifying effort
Rejecting effort
Research Employee role
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Delegating effort approvals to other administrators
Approving effort as reported
Approving effort with changes
Creating an LDCA outside of Effort Reporting
Viewing effort report
Other roles
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Dean
Department Chair
Budget and Finance
Research Finance
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