Transcript Document

Wayne State University
School of Medicine
Research Development Committee
March 4, 2011
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Agenda
• What is Effort Reporting? Why do we need to do it?
• Consequences of not doing effort reporting correctly
• Effort Reporting Project background and accomplishments
• Summary of changes in how we do Effort Reporting
• Brief system demo
• Next steps/plans for system rollout
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What is Effort Reporting? Why do we
need to do it?
• Effort reporting is required by the federal government (OMB Circular A-21,
Section J-10), since Wayne State University receives federal funds to be
used for sponsored research.
• It applies only to those faculty and staff who are involved in sponsored/
externally funded research ( i.e. those who charge or cost share part of their
salary to sponsors, and/or who have effort commitments to sponsored
programs).
• It serves as an after-the-fact confirmation that the assignment of time and
associated salary and fringe benefit costs to individual sponsored projects is
fair, consistent, and timely.
• Effort reporting is not new to WSU. We have been doing it for several years
via paper-based “Payroll Certification” forms. We are now moving to an
online system (a module contained within Banner) that will provide greater
efficiency and better position WSU to meet its compliance requirements.
• The sole purpose and capability of the new system is effort reporting
compliance.
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A Perspective on “Effort”
“Effort” from Wayne State’s
perspective:
• Overall, the Banner payroll/labor
distribution does not reflect the hours
I spend, nor does it capture the
different types of effort I put forth for
WSU.
• All my effort, regardless of who is
paying for it or when it’s done is
important and should be recognized.
“Effort” from the government’s perspective:
• The federal government wants to know how
individuals working on federally-sponsored
programs are expending all of their effort
• In proposals, key personnel indicated their
estimated effort and requested the associated
salary, or made a cost-sharing commitment that the
institution would fund the salary
• While not perfect, payroll/labor distributions serve
as a reasonable starting point for effort certification
(it may be off in terms of both timing and source)
• Effort certification serves as an after-the-fact
confirmation that the individual/key personnel
expended the promised effort, and that they
worked at least as much as the percent of their
salary charged/cost-shared to the project
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Consequences of Not Doing Effort
Reporting Correctly
•
Effort reporting is a condition of accepting Federal funds
•
The risks of non-compliance with effort reporting are significant
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Sponsors (and/or the Department of Justice) may:
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Numerous investigations have been conducted by the federal government that have
focused on effort reporting - settlements have been in the tens of millions of dollars
Disallow related salary, fringe and F&A costs
If considered a “false claim”, triple damages apply
Reduce or eliminate future funding
Press criminal charges against the individual
NSF in particular has conducted nearly 20 reviews of institutions’ effort
reporting practices. Common findings have included:
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Effort reports certified late and/or by individuals without suitable means of verification
100% effort and Institutional Base Salary (IBS) not defined appropriately
Problems with summer salary/effort calculations and reports
Effort commitments not considered in certification
Failure to report committed cost sharing accurately in “Current & Pending” support pages of
proposal
– Inadequate education programs for faculty and administrators
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Consequences of Not Doing Effort Reporting Correctly
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Institution
Summary of Issue
University of
Michigan
Auditors for the NSF determined that costs claimed by the University of Michigan
(UM) questioned $1.6 million in costs and $136,200 of "at risk cost-sharing." The
audit encompassed nearly $58 million in direct NSF-funded costs and $17 million of
cost sharing claimed by UM. However, UM rejected the findings and the
recommendations. Discussions are still ongoing.
Yale University
Government auditors alleged that Yale mischarged federal grants through improper cost
transfers, and through inaccurate and overstated effort reports that resulted in salary
overcharges to federal awards.
Specifically, as it relates to effort reporting, the government alleged (1) that Yale researchers
submitted effort reports for summer salary that wrongfully charged 100 percent of their
summer effort to federal grants, when researchers expended significant effort on other work;
(2) that the PI failed to provide the level of effort proposed; and (3) the University did not
have procedures for monitoring the budgeted or minimum level of effort for key personnel.
$7.6 million paid to the government.
Cornell
University
Weill Medical
College
Whistleblower alleged that over an eight year period, the full salaries of nurses, laboratory
technicians, and other workers had been paid with NIH grant dollars, even though some of
the employees were not involved in the research at all and others did not work full time on
the project. The Department of Justice (DOJ) said Weill Medical College, ‘defrauded the
government and made false statements' when a PI 'failed to disclose to the government the
full extent of her various active research projects’. $4.38 million paid to the government
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Consequences of Not Doing Effort Reporting Correctly
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Institution
Summary of Issue
Florida
International
University
An audit found that the university had not properly documented whether faculty members
had spent the percentage of time they had promised to spend on research projects financed
by the grants. Government alleged that FIU improperly billed the government for scientists'
time, travel, and administration expenses over a 10-year period on a single award dating
back to 1995. $11.5 million paid to the government
Harvard
University
Harvard disclosed to government that it had, along with an affiliated hospital, overcharged
NIH research and training grants by seeking reimbursement for the salaries of researchers
who did not work on the grant. Faculty time was also found to be overstated, the
government was billed for salaries and expenses unrelated to federal grants, and a
researcher spent fewer hours than promised on a research study.
Harvard and affiliated institutions paid $3.3 million to government.
Northwestern
University
Whistleblower suit alleged that NU overcharged federal grants .
Government alleged that NU overstated faculty members’ institutional base salaries in grant
applications and when drawing down funds and failed to maintain adequate procedures to
reconcile proposed and actual effort. Recipients of awards had not dedicated required
percentage of effort to award). $5.5 million paid to government
Johns Hopkins
University
Whistleblower suit alleged that JHU had knowingly overcharged the government by
overstating the amount of time researchers worked on federal research projects and in at
least one case charging for more than 100% of an individual’s salary. NIH found that JHU
failed to maintain adequate compliance procedures to reconcile proposed and actual effort.
$2.6 million paid to government
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WSU Project Background
• WSU is focused on enhancing its compliance with federal
requirements related to effort reporting
• This has, and will continue to include cultural as well as operational
and technical changes
• Over the past year, WSU evaluated automated solutions and is now in
the process of kicking off a project to implement the Effort Reporting
module offered by Banner
• Huron is providing subject matter and project management assistance
for the project
• WSU project sponsors are
– Ron Brown, Provost & VP Academic Affairs
– Rick Nork, VP Finance & Facilities Management
– Hilary Ratner, VP Research
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Key Communication and Education
Activities
 Presentation to Presidents’ Cabinet
 Presentation to Council of Deans
 Presentation to Academic Senate (Research Subcommittee)
 Interviewed 15 research faculty from a variety of schools/disciplines
 Faculty participation in our Project “Working Group”
 Multiple presentations at Research Administrators Meetings
 Presentation to Faculty Research Administrators Council
 Presentation to Business Affairs Officers
 Scheduled to present to SOM Research Development Committee
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Additional Project Accomplishments
 Conducted current state assessment, identified areas of compliance
risk and opportunities for improvement
 Developed educational materials and conducted several sessions
 Developed “Draft Effort Guidelines” which provides guidance on key
effort compliance requirements and practices
 Configured and tested the new system
 Provided effort fundamentals and system training to departmental
administrative staff
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Summary of Key System & Process
Changes
• All electronic – no paper!
– “Effort” displayed as percentages (based on Banner payroll/labor distribution)
• Pre-Review
– Quality control function performed by departmental administrative staff
– Purpose is to identify effort reports that do not reasonably reflect the EFFORT during
the period of performance
– Pre-review is mandatory. Certification can’t take place until pre review is complete
• Grad Student Certification
– Will be performed by PI’s, not by grad students
– Grad students will not receive email notifications, nor have the ability to certify in the
system
• Research Assistant Certification
– It is intended that research assistants perform their own certification
– PI’s will be assigned as “Alternate Certifiers” for research assistants, and will have
the ability to certify for research assistants if needed
• Summer Certification
– For 9-month faculty, there will be a separate certification cycle for the summer period
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System Demo
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Plans for System Rollout
Date
1/10
1 Prepare Production Environment
2 Training
3 Conduct Pre-Review/Admin. Training Wk of 2/7
4 Distribute Certifier Training Materials Wk of 2/21
5 Pre-Review Period
2/14
6 Initial Pre-review notification
2/28
7 First pre-review reminder
3/7
8 Second pre-review reminder
3/10
9 Third/final pre-review reminder
3/14
10 SPA Direct Follow Up
11 Certification Period
3/7
12 Initial Certification Notification
3/21
13 Certification reminder
4/4
14 Certifications Complete!
4/4
15 First certification late reminder
4/8
16 Second certification late reminder
January
1/17 1/24
1/31
2/7
February
2/14 2/21
2/28
March/April
3/14 3/21 3/28
3/7
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• Research faculty and staff who have effort reports eligible for certification will be
notified via a system-generated email on or about March 7.
• Certification due date is April 4. System generated reminders and notices will
be sent as outlined in the above timeline.
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4/4
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Support and Additional Information
• For additional information on effort reporting (educational materials, operational
guidelines, etc.) please see the SPA web site:
http://www.spa.wayne.edu/post/effort_reporting.php
• Education and Guidance on Effort Reporting
– Draft Effort Guidelines – Provides guidance on how manage effort reporting
at WSU
– “Effort 101” – Covers key effort reporting definitions and concepts
– Effort Reporting FAQ document
• Navigation and use of the new effort reporting system. Guides have been
developed specifically for:
– Research faculty and staff
– Departmental administrative support staff
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Questions? Comments??
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