Transcript Personnel Effort Reporting Policies and Procedures

Personnel Effort Reporting
System (PERS) &
Electronic Effort Reporting
(ERS)
Amy R. Lederberg
Assoc VP for Research
PERS for Sponsored Projects
 Effort
reports are the documentation that
salaries charged to a project are for work
performed
 Like a “receipt” for personnel costs
 Proof we are not defrauding sponsor
 OMB Circular A-21 provides guidance on
what is acceptable documentation
PERS: Board of Regents
 Wants
to know how much of our state
funds (instructional $$) is expended on
research activities
 We
use the effort reporting system to
generate this figure
Why are we changing?
 Personnel
Effort Reporting source of major
finds by Universities:



Florida International paid $11.5 million in fines
UAB paid $3.39 million
Northwestern $5.5 million
 Our
old system did not comply with federal
guidelines
 Recent audits pointed out inadequacies of
GSU system
What is different?
 Implementing
a new web-based Effort
Reporting System designed by Maximus
(ERS) developed to comply with federal
guidelines
 Adopted new policies and procedures

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Who certifies effort reports
Timeliness of effort reporting
Clarified what is effort
http://www.gsu.edu/25271.html
Basic Concepts

Only Effort for GSU (exclude activities that are
not compensated for by GSU)

Document all sponsored-compensated effort


Including committed cost share (via a companion
account)
Uncommitted Cost Share

Effort that is funded by GSU but not committed in
proposal is accounted for by “non-sponsored
activities”
100% Effort may be Divided into
Five Types of Activities
How do I spend my time?

Sponsor Project Activities



Sponsored (paid for by sponsor)
Cost Share (paid for by University)
Non-Sponsored Activities:



Research (Department & University)
University Instruction
Other
What is 100% of effort?

All the activities an individual engages in to earn
GSU salary (IBS)
Because it includes all activities they MUST equal 100%
100% of an Exempt employee’s effort is not
defined by a set number of hours or days. For
some, it may be 70 hours a week, others 40.
 Part time employee may be 20 hours.
 Summer faculty may be less than Full Time if
earning less than 33.33% of Academic Year
salary

What is not included in effort?
 Activities
that are being compensated for
by another entity besides GSU




Consultant activities to other institutions
Reviewing for federal agencies
Activities that earn an honorarium
Volunteer activities
Students
 Special
case
 IRS rules can only work up to 20 hours a
week for compensation
 100% effort < 20 hours worth of activities
 Student can be doing additional
educational activities which require them
to work many more hours than 20 BUT
can only be required to work up to 20
hours for salary
But I’m not a lawyer!
OMB Circular A-21, Section J.10.b.1.c
Reasonable estimates are based on the
understanding: “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.”
ERS
 After-the-fact
certification
 Three times a year (summer, fall, and
spring)
 Generates one Personal Effort Report
(PER) per employee
 Based on payroll allocation of Institutional
Base Salary (excludes any special
supplements) (i.e., corresponds to
distribution of salary on PAF)
ERS: Workflow

Department Coordinators review effort reports


Assign certifiers (default is employee)
Prereviews: Checks and makes sure payroll
allocation is consistent with record

ERS automatically sends email to certifiers after
prereview (at 6 PM daily)

Certifiers review and certify effort

Department coordinators do cost transfers for
any effort reports changed by certifiers
Who gets a PER?
 All employees engaged in activities for a
sponsored project

(either charged directly to the sponsored account or
to a companion account if cost sharing)
AND
 Faculty and staff funded solely from fund code
10 who are engaged in research funded by the
university

(does not include graduate students who are not on
sponsored projects)
Who can certify effort reports?
Federal guidelines
PERs are required to be certified in a timely
manner by individuals “with suitable
means of verification that work was
performed” (OMB A-21 J.10.c.2.c)
Who can certify PER with
sponsored effort?

Faculty do their own

PI certifies staff/student on sponsored projects
OR

PI can designate someone who has suitable means of
verification (i.e. Project Manager, Lab Coordinator – NOT
department Business Manager)

Must document via email to department coordinator
OR

Staff can do their own (typically only when working on
multiple projects with more than one PI and are long
term employees)
Who can certify for faculty with only
non-sponsored activity?
 Only
when faculty do not expect to have
sponsored activity in the future (for next 5
years)
 Department
coordinators (business
managers) can certify because only for
BOR reporting purposes
 BUT
NEED TO BE CAREFUL
 Can
not change semester by semester
Step by Step Guide
ERS: Timing

Central administrator (Nicole Andrews)
generates Effort Reports

Based on ACTUAL payroll from HR/Financials
(Which should correspond to PAF (s) averaged
over semester)

Summer and Fall: 30 days after close out of
semester; Spring earlier

Prereview and Certification required to be
finished 30 days later
Special Issues
 Course

releases
I get one course release in the spring. Should
I charge my grant 33.3% of my salary during
that semester or 16.66% for the academic
year?
 Summer

I work on my grant all year but only want to
charge it during the summer
Effort Commitment: Proposed
PIs estimate the amount of effort they will spend
on a sponsored project in a proposal (and to
build a budget)
Federal agencies regard estimates as a
commitment
So do sponsors using federal funds (federal flow
through, e.g., other institutions like state
governments, other Universities)
Some sponsors may not require fulfill effort
commitments. Need to read terms and
conditions of award. Call OSP if unsure.
Over commitment

PIs need to ensure they can fulfill effort
commitment by examining all other sponsored
and non-sponsored activities
 Total Effort can not equal more than 100%
 Because not all proposals are funded, PIs may
get an award and can not fulfill commitment
 Must get prior approval from sponsoring agency
to reduce effort commitment. (Procedures
specific to agency. Can get help from OSP)
Effort Commitments

OMB Circular A-110 Section 25.3.c: “recipients
shall request prior approvals from Federal
awarding agencies for….The absence for more
than three months, or a 25 percent reduction in
time devoted to the project, by the approved
project director or principal investigator.”

Commitment may be binding on all “Key
Personnel” as defined in the award document
Effort Commitments:
Committed Effort %
Actual Effort %
Committed Effort %
If more than 25% than have to ask permission from sponsor for
reduction of committed effort
%
Change
in Effort
Effort Commitments are for the
Budget Year
 Proposed
effort committed for the
academic year can be moved to the
summer (or vice versa) IF


actual effort for a budget year is not
significantly reduced from the committed effort
for that budget year AND
the faculty member can certify they expended
the effort during the period the sponsored
project is charged.
Commitment = payroll = effort
Committed Effort =
Salary Charged =
(within 25% of effort committed)
Actual Effort Certified
(% charged = certified effort + 5% Total
Effort)
What are auditors looking at?
Effort Reporting
 Commitments
 Was the Proposed Effort Met?
 Are Faculty Over Committed?
 Certification
 Was the Certifier Appropriate?
 Account for All Activities?
 Timeliness
 Why are there Delays in Certifying Effort?
 Do Delays Indicate Bigger Issues?
What are auditors looking at?
Cost Transfers

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Was How & Why Occurred documented?
Are Charges Reasonable, Allowable, Allocable
& Consistently Treated?
Did the PI Certify the Correctness of the new
Charges to their Sponsored Project?
Are Processes Changed to Prevent Future
Cost Transfers?
Resources Available
 Personnel
Effort Reporting Policies &
Procedures (lots of examples)
 Salary, effort, and person conversion chart
(available under proposal dev page)
http://www.gsu.edu/research/proposal_devel
opment.html
 Department Coordinator
 Amy Lederberg and Nicole Andrews, RFS
and OSP staff