Transcript Testing this template - Western Illinois University

Fundamentals of
Time & Effort
Certification Reporting
Western Illinois University
Office of Sponsored Projects
1
What is Effort Certification?


Effort certification provides assurance to sponsors that
faculty and staff have met their commitments, paid or
unpaid, to externally-funded projects
It’s required by federal regulation and University policy
for all individuals working on sponsored projects
Why is Time & Effort
Reporting Important?




Signed effort reports are considered legal documents in
which an individual attests to the accuracy of the effort
spent on sponsored projects
Erroneously certifying effort reports can be viewed as
fraud
Sanctions can apply to both the institution and the
individual
We are obliged by federal regulations to exercise good
stewardship of those funds
1.) Effort is a part of that stewardship
2.) Personnel costs are the majority of research costs
Effort Certification Actually Begins
at the Proposal Stage:
Preparing
the
Proposal
Budget
Effort is
proposed
and a
commitment
is made to
the sponsor
Award is Received
Appropriate
personnel
forms are
processed
and monthly
match entries
are recorded
in the WIU
system (if
applicable)
Effort is Devoted
Project Director
or designee
monitors time and
effort to ensure
accuracy of
contracts and
match entries
Effort is
certified by
Effort Reports PD or
Distributed
designee
Quarterly
What Exactly is “Effort”?
Definition:
“Effort is the percentage of time spent towards
particular Work-Related Activities, such as
sponsored projects, instruction, proposal
preparation, or other administrative duties. “
What “Effort” isn’t…
Don’t confuse effort reporting with Payroll
distributions as they are not the same thing!
Payroll distributions are the distribution of an
individual's salary, while effort reports describe the
allocation of an individual's actual time and effort
spent for specific projects, whether or not
reimbursed by the sponsor.
Effort reporting is separate from, and
can be independent of, salary charges.
Time & Effort Reporting is…

is a way for an employee to certify that:
1.) Effort supported (paid) by a federally sponsored
project has been performed as promised.
2.) Effort expended in support of a federally sponsored
project but not paid by the project has been performed
as promised

is required by federal regulation for all individuals
working on federally funded sponsored projects

makes salary sources for the period congruent with
effort spent for the period
How is Effort Determined?
Effort is NOT based on your regular work week.
It is calculated as a percentage based on the
total hours spent on work-related duties.
For example, if a person averages 60 hours per
week during a reporting period and spends an
average of 15 hours on a Sponsored Project,
that person has spent 25% effort on the
sponsored project and 75% effort on other
activities.
How is Effort Determined?
Effort is based on 100% of the activities for
which you are compensated by the WIU

These activities are divided into:
◦ Sponsored project activities
◦ Non-sponsored activities
Sponsored Activities:



This is your effort on:
◦ Federal grants or contracts (e.g. NIH, NSF, USDE, DOE)
◦ Non-federal projects (e.g. a state grant or industrysponsored project)
Activities you can allocate to a sponsored project include:
◦ Writing progress reports; holding a meeting with
individuals working on the sponsored project; presenting
results at a conference; reading journals to keep up to
date with the latest advances in the project topic area
... even if your salary is not completely paid by the sponsor
(i.e. salary cost sharing)
Non-Sponsored Activities:
Teaching
 Serving as a department chair, and other administrative
duties
 Serving on university committees
 Attending general departmental faculty meetings
 Public service and outreach

100% Effort =
Teaching…
100% Effort =
+
Teaching…
Reading journals to keep
up-to-date on research
topic…
100% Effort =
+
Teaching…
Reading journals to keep
up-to-date on research
topic…
Meeting with people working on your grant…
100% Effort =
+
Teaching…
+
Reading journals to keep
up-to-date on research
topic…
Conducting
research for
your grant…
Meeting with people working on your grant…
Remember…Effort Always
Equals 100%
Grant #1, 20%
Instruction,
70%
Grant #2, 10%
Who Certifies the Time & Effort
Certification Report?

An individual’s effort is usually certified by the Project
Director.

There are some exceptions that are made for practical
reasons. For example, the Project Director may
designate another employee to review and certify the
forms if they have a better knowledge of the actual dayto-day work that was performed by the individuals on
the project.
How to Certify
The Project Director (or the designated certifier) must
verify that the time & effort certification report shows a
reasonable estimate of the actual effort expended on each
project/source.
Documentation that may be helpful in verifying effort could
include:
◦
◦
◦
◦
◦
◦
teaching schedules
outside activity forms
time sheets
leave reports
calendars
correspondence
How to Certify (continued)

If the percentages for the specified account accurately
reflect the actual work performed during the specified
time period by the individuals listed:
◦ Sign and date the certification report before returning to OSP

If the percentages for the specified account do not
accurately reflect the actual work performed during the
specified time period by the individuals listed:
◦ Do not sign the form and notify OSP immediately
Pay Sources Should Reasonably
Reflect Activity
OMB Circular A-21 J10b(1)(c) says:
“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.”
In other words…
The distribution of effort should represent a reasonable
estimation of the actual effort expended during the
term being certified.
The deviation that is considered acceptable at WIU is
+ or – 10%.
Let’s take a look at a sample of the
time and effort certification report…
JAMES SMITH
Psychology Department
Waggoner Hall 100
5/10/10
WESTERN ILLINOIS UNIVERSITY
TIME AND EFFORT CERTIFICATION REPORT FOR 522220 TV VIEWING SURVEY
TIME PERIOD 01/01/10 – 04/30/10
EMPL
NAME
CHARGE
DEPT
CHARGE
NAME
WORK
DEPT
PCT
EFFORT
SMITH, JAMES
144440
522220
PSYCHOLOGY
TV VIEWING SURVEY
TOTAL EFFORT
144440
144440
83.33
16.67
100.00
DOE, JANE
144440
141630
522220
PSYCHOLOGY
PUBLIC SERVICE MATCH
TV VIEWING SURVEY
TOTAL EFFORT
144440
533330
144440
75.00
10.00
15.00
100.00
I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED
ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED
BY THESE INDIVIDUALS.
SIGNED: ________________________________________
DATE: _________________________
JAMES SMITH
Psychology Department
Waggoner Hall 100
5/10/10
WESTERN ILLINOIS UNIVERSITY
TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY
TIME PERIOD 01/01/10 – 04/30/10
EMPL
NAME
CHARGE
DEPT
CHARGE
NAME
WORK
DEPT
PCT
EFFORT
SMITH, JAMES
144440
522220
PSYCHOLOGY
TV VIEWING SURVEY
TOTAL EFFORT
144440
144440
83.33
16.67
100.00
DOE, JANE
144440
141630
522220
PSYCHOLOGY
PUBLIC SERVICE MATCH
TV VIEWING SURVEY
TOTAL EFFORT
144440
533330
144440
75.00
10.00
15.00
100.00
I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED
ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED
BY THESE INDIVIDUALS.
SIGNED: ________________________________________
DATE: _________________________
JAMES SMITH
Psychology Department
Waggoner Hall 100
5/10/10
WESTERN ILLINOIS UNIVERSITY
TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY
TIME PERIOD 01/01/10 – 04/30/10
EMPL
NAME
SMITH, JAMES
CHARGE
DEPT
144440
522220
CHARGE
NAME
WORK
DEPT
PSYCHOLOGY
TV VIEWING SURVEY
TOTAL EFFORT
144440
144440
PCT
EFFORT
83.33
16.67
100.00
This could be
supplemental
pay from the
DOE, JANE
144440
PSYCHOLOGY
144440
75.00
grant or it
141630
PUBLIC SERVICE MATCH
533330
10.00
could be a
522220
TV VIEWING SURVEY
144440
15.00
TOTAL EFFORT
100.00
portion of his
regular salary
that is being
I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED
paid from
the
ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED
grant funds.
BY THESE INDIVIDUALS.
SIGNED: ________________________________________
DATE: _________________________
JAMES SMITH
Psychology Department
Waggoner Hall 100
5/10/10
WESTERN ILLINOIS UNIVERSITY
TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY
TIME PERIOD 01/01/10 – 04/30/10
EMPL
NAME
CHARGE
DEPT
CHARGE
NAME
WORK
DEPT
PCT
EFFORT
SMITH, JAMES
144440
522220
PSYCHOLOGY
TV VIEWING SURVEY
TOTAL EFFORT
144440
144440
83.33
16.67
100.00
DOE, JANE
144440
141630
522220
PSYCHOLOGY
PUBLIC SERVICE MATCH
TV VIEWING SURVEY
TOTAL EFFORT
144440
533330
144440
75.00
10.00
15.00
100.00
I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED
ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED
BY THESE INDIVIDUALS.
SIGNED: ________________________________________
DATE: _________________________
JAMES SMITH
Psychology Department
Waggoner Hall 100
5/10/10
WESTERN ILLINOIS UNIVERSITY
TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY
TIME PERIOD 01/01/10 – 04/30/10
EMPLof her regular
CHARGE
A portion
NAME
DEPT
salary is being used as
match for a second
SMITH,
JAMES
144440
grant
(5-33330)
that
522220
she is working on in
addition to 5-22220.
DOE, JANE
144440
141630
522220
CHARGE
NAME
WORK
DEPT
PCT
EFFORT
PSYCHOLOGY
TV VIEWING SURVEY
TOTAL EFFORT
144440
144440
83.33
16.67
100.00
PSYCHOLOGY
PUBLIC SERVICE MATCH
TV VIEWING SURVEY
TOTAL EFFORT
144440
533330
144440
75.00
10.00
15.00
100.00
I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED
ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED
BY THESE INDIVIDUALS.
SIGNED: ________________________________________
DATE: _________________________
Issues that raise red flags with auditors…
Late effort certification
Effort certified by someone without
suitable means of verification
A distribution of effort that leaves too
little non-sponsored time to credibly
cover teaching, administrative, or other
university duties
Post-certification revisions
Examples of Audits and Fines
Assessed on Institutions






Northwestern University – $5.5 million (2003)
Johns Hopkins University (for one investigator)
– $2.6 million (2004)
East Carolina University – $2.4 million (2004)
Harvard University/Beth Israel Deaconess
Medical Center – $3.25 million (2000 & 2004)
Dartmouth – $37,780 (2005)
University of Connecticut - $2.5 million (2006)
Important Points to Remember
Effort reporting is under scrutiny by the
Office of Investigators General from NSF,
NIH, and other Federal agencies
 100% effort is NOT Based on a regular
40-hour work week. It is based on each
individual’s own average work week.
 Effort reporting tracks the reasonable
approximation of actual activity on
projects and should not simply mimic
budgeted amounts.

Call us if…
you need to make changes to contracts of
WIU employees being paid from your grant
 the effort you or one of the employees
working on your grant changes substantially
 changes need to be made to the percentage
of effort of an employee being used as
match on your grant
 an employee that was working on your
grant leaves WIU
 you have any questions

For more information
or questions, contact
the Office of
Sponsored Projects at
298-1191