Transcript Introduction to Effort Reporting, the Basics

Faculty Effort Certification, the
Basics
APRIL2012
SUZETTE ASHBY
MANAGEMENT ACCOUNTING AND ANALYSIS
Introduction
Agenda
 Introduction
 Why are we here?
 What is Faculty Effort?
 What are the steps in the Process?
 What do I need to know to successfully review FECs?
 What are the consequences?
Training Objectives
 Understand the federal requirements and why we do




effort reporting
Understand UW policy
Understand relationships among effort, cost sharing,
salary transfers
Understand key terms and definitions
Be able to properly review effort reports.
Sponsored Funding at UW is Huge!
 Over $1.5 Billion in sponsored project funding
 Equals almost 1/3 of UW operating budget
 Supports over 7500 University employees
 2600+ Faculty performing research each year
Sponsored Activity at UW
UW Sponsored Activity FY 2011
$1,512,610,221
Non-federal
Sponsors, 27%
Federal
Sponsors, 73%
With Federal sponsored research support comes compliance requirements.
One of these is Effort Reporting
What is Effort Reporting?
 Effort reporting represents the periodic certification
of salaries charged to grants and contracts. For UW
faculty this is accomplished via the FEC.



Salary charged to sponsored agreements represents a
reasonable reflection of effort devoted to those agreements
Each sponsored agreement must be certified separately, i.e.
cannot be lumped together
This is also required for effort that is cost shared.
 This is a Federal requirement per OMB A-21.
OMB A-21
The Code of Federal Regulations (CFR) Title 2, Volume I, Part 220, J 10
 Charges fairly represent the work performed.
 Was the time faculty spent working on the grant reasonable,
accurate?
 Verification that compensation charged is
appropriate to the activity performed.

Was faculty’s time actually spent on the grant as opposed to
other work?
 Verification that actual effort performed equates to
the effort committed.

Did the faculty do the work they committed to in the proposal?
Why is accurate, timely reporting important?
 Effort reporting, cost sharing, salary transfers, late
FECs have been, and continues to be, an audit focus.
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2010 University of Delaware
2009 Arizona State
2008 Yale
2007 Georgia State
2006 University of Arizona
2005 Florida International University
2004 Johns Hopkins
2003 Northwestern
What is Faculty Effort?
 Time faculty spend on instruction, research, patient
care, administration, etc. which is compensated by the
University of Washington
 Compensation supporting the grant effort may be from
 Grant funds
 Non-grant funds (cost shared)
Cost Sharing
 Cost sharing is effort that is
 committed in the proposal
 performed on the grant
 but not paid by the grant
 Cost shared effort for a federally funded project
cannot be paid from other federal funds and only
from non-federal sponsored project funds when
approved by both sponsors.
Types of Cost Sharing
 Mandatory
 Voluntary Committed
 Salary Cap
 Shift in Funding Source (long term and short term)
 K Award Cost Sharing
 More Information:
http://f2.washington.edu/fm/maa/fm/maa/facultycostshare/detaileddefinition
The FEC
 Faculty members use Effort Certification Reports (FECs)
to certify

Salary effort paid on sponsored projects

Cost shared effort performed on sponsored projects

And all other effort (non-sponsored)
The purpose of the FEC is to certify that pay was a reasonable
reflection of effort using a suitable means of verification.
Note: Effort for Non-Faculty
 Regulations that apply to faculty also apply to other
employees who work on sponsored projects.
 Non-faculty employees such as professional staff,
senior fellows, lab technicians, graduate students
must also certify their effort
 Certification for non-faculty is done on the Grant
and Contract Certification Report (GCCR).
Quiz
True or False
 Effort on each grant must be exactly what was
committed in the proposal.
 Faculty can use some time paid by the grant to work
on related research.
Process: the Seven Steps to Success
15
Pre-Award
Appointment Preparing
of Faculty &
the
Staff
Proposal
Project
Set-up
Post-Award
Charging
Expenses
Reporting &
Certifying
Effort
Fiscal
Reporting
Records
Retention
I just want to get to the FEC part!
 Why talk about pre-award?
What do I need to know to analyze the data on the FEC?
 Where does the data come from?
 How do I confirm the information is right? Wrong?
 Where do I go to have errors fixed?

Building a Solid Foundation
Step One: Appointment
 Terms of employment
 Scope of work
 Institutional base salary
 Appropriate funding sources
Step Two: The Proposal
 Effort commitments
 Once effort commitments are made to the sponsor, they are
required if the grant or contract is awarded.

If requested funding is reduced by sponsor
The department should consider if effort needs to be reduced
and, if so, work with the Office of Sponsored Programs (OSP) to
reduce effort commitment.
OR
 If the department chooses not to contact the sponsor to reduce
effort, the faculty member is obligated for the effort committed
in the proposal.

Step Three: Project Set Up
 Roles and Responsibilities

Department


Office of Sponsored Programs (OSP)


Creates electronic Funding Action (eFA) and forwards to GCA along
with a copy of the GC1 Addendum.
GCA


Revises/prepares GC1 Addendum if needed for cost sharing and
submits to OSP
Receives eFA and GC1 Addendum from OSP and sets up budget in
FIN and the eFECS Cost Share Module if there is cost sharing.
Department

Checks EVERYTHING
 Budget set up in FAS/MyFD and eFECS Cost Share Module if
applicable.
Step Four: Charging Expenses
 What should I put into OPUS?
 What are the effort commitments?
 Does the grant have a salary limitation?
 Does the faculty have Administrative (ADS) or Endowed
Supplements (ENS)?
 Does the faculty have clinical salary?
 Is there a shift in funding source?
Step Five: Reporting and Certifying Effort
 How is the FEC used?
 To certify that faculty have performed the work they
committed in the proposal
 Available for audit to support salary charges
 Documents a cost share source
 Forms part of the F&A calculation
 Final report to sponsor
Step Six: Fiscal Reporting
 GCA closes the budget
 Cost share
 Cost share must be met before the budget can close
 Cost share data included in final report to sponsor
 At the end of the grant the department should ensure that
effort commitments as stated in the proposal have been met.

Compare what was proposed to what was documented as actual
effort, both cost share or paid on the grant. Ensure the total of the
two combined are within tolerances of what was committed.
 Ensure there was not a shift in funding source that was not
documented. Keep records of shifts.
 Keep any records that support changes (Perms, GC1 Addenda,
etc.)
Step 7: Records Retention
 Departments will keep FECS and supporting
documentation for one year after the end of the fiscal year
for all FEC cycles prior the launch of eFECS, Phase III,
Online Certification.
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
January 2012: calendar reporters
March 2012: academic reporters
 Departments will not be required to keep paper files for
future cycles.
 eFECS will keep electronic copies for one year after the end
of the sixth fiscal year. (3 biennia plus the current fiscal
year. )
Quiz
 Name 3 reasons why it is important to know
something about the pre-award process.
What do you need to know to review an FEC?
 Where can I find the new FECs? Get access?
 What was the sponsor promised?
 What is institutional base salary?
 What is considered a faculty work week?
 What should I be checking?
 What do I put into OPUS?
 How do I handle changes?
 Who can certify the FEC and what is “suitable means
of verification?
Getting Access – eFECS Effort Report
 Must be set up in ASTRA for Effort Reporting as User
 Roles: https://f2.washington.edu/fm/efecs/roles-access



View Online Effort Report
View and Update Effort Report
View and Print Effort Report
 ASTRA set up instructions
https://f2.washington.edu/fm/efecs/access-and-roles/getaccess
 Log in to eFECS

https://f2.washington.edu/fm/efecs/
Getting Access – eFECS Cost Share Module
 Must be set up in ASTRA for eFECS Cost Share as
User with Campus Inquiry/View role.
 ASTRA set up instruction (in eFECS Training)

http://www.washington.edu/uwit/im/Finance/efecs/
 Log in to eFECS Cost Share Module

http://www.washington.edu/uwit/im/Finance/efecs/
Getting Access - Unmet Cost Share Report
 Provides departments with real time status of cost
share for their budgets and allows them to print
individual reports for PIs.
 Request access using the Contact form on the FEC
website

http://f2.washington.edu/fm/maa/contact
 Log in

http://f2.washington.edu/fm/maa/home
Commitments
 What was the sponsor promised and why is it
important?

Sponsor assumes what is committed in the proposal will be
accomplished.
 Commitments
include both effort paid directly from the grant and
cost shared effort.

Significant reduction in effort (25% or more) requires PRIOR
sponsor approval.
Institutional Base Salary (IBS)
 IBS represents compensation paid by UW for an
employee’s appointment.


Includes

Time spent on research, instruction, administration, service or
clinical activity.

Earn types REG, SUM, PLP, TFA, ADS, ENS.

Salary from State, Grants and Contracts, Gifts and Endowments,
Other UW funds and Clinical Practice Plan (UWP and CUMG).
Excludes

Earn types that are not part of the IBS (e.g. TPS, E/C)

Salary from VAMC, CHRMA, FHCRC, Outside professional work
Quiz
 What is the difference between Institutional Base
Salary and full time rate?
Faculty Work Week
 Faculty work week is the average number of hours a
faculty member normally works – averaged over the
FEC cycle.
 Effort is NOT defined in hours, it IS defined in %

If a faculty member works on average
40 hours a week, 10% of his/her time is 4 hours.
 50 hours a week, 10% of his/her time is 5 hours.
 60 hours a week, 10% of his/her time is 6 hours.

Checking “Everything”
 Check FIN/MyFD
 Is the budget type and class correct?
 Does the budget have the correct revenue source?
 Is the cost share flag set?
 Check eFECS Cost Share Module (CSM)
 Is the cost share set up?
 Is the cost share set up for the right periods, faculty, percents?
 Is summer cost share required; has the workaround been put into the CSM?
 Does the budget have the correct begin and end dates?
 Check HEPPS/OPUS
 Is the appointment information correct?
 Does the % reflect the committed effort?
 Has the % been adjusted for earn types without FTE?
 Is the salary paid up to, but not over cap?
r
u
Cost Share is prorated
based on start and end
dates of grant
Rabbit, P.
37
What do I put into OPUS?
 Simple Example:

% in OPUS should reflect % committed in proposal
What do I put into OPUS?
Clinical Salary
 Clinical Salary dollars are not displayed in HEPPS/OPUS
 Example:

Grant requires 10% effort
X = $150,000 (UW Salary)
 Y = $25,000 (Practice Plan)

$175,000

10% * $175,000 = $17,500
 $17,500/$150,000 = 11.67

Put 11.67 into OPUS
 FEC includes both X and Y so % = 10%

What do I put into OPUS?
ADS/ENS
 Administrative (ADS) or Endowed (ENS) Supplements
 ADS and ENS have no FTE attached to them in HEPPS/OPUS
 % effort must be adjusted so that the percent on the FEC reflects the
effort committed in the proposal.
 % effort in OPUS will be greater than the committed effort.
 ADS/ENS calculator tool:
http://f2.washington.edu/fm/maa/fec/fectools

Note: there are three tabs
 FEC to OPUS - %
 FEC to OPUS - $
 OPUS to FEC - $
r
u
What to put in the Comment Box- or Not
43
.
GOOD
• Variations from normal reporting
• Short term shift in funding.
• Non-federal grant has approval to be used as a cost share source.
• Reason FEC is being recertified.
BAD
• This was not my plan.
• The % effort is not consistent with what I understood it to be or as
listed in my support from the sponsor.
• Have initialed corrections on [the FEC] when it went through my hands.
• I do not understand the calculations.
• This grant ended. There should be no charges on it after summer quarter.
Quiz
Your new chair has an ADS component to her salary.
True
False
Departments should reconcile the percent FTE on the FEC to
HEPPS/OPUS records.
True
False
ADS is not included in the institutional base salary used on
the FEC.
True
False
The department should set up the OPUS record to reflect the
percentage of effort committed in the proposal
True
False
The department should ensure that the percentage on the FEC
matches the percentage in the award.
How do I handle changes?
 System Changes
 Make changes to OPUS, eFECS Cost Share Module,
FIN/MyFD
 NO manual changes can be made to the online FEC.
 Manual Changes are for Recertifications Only
 Make changes on the certified copy of the FEC
System Changes
 System Changes
 Salary transfers (sometimes referred to as OSETs or RSTs) are
made in MyFD
 Changes to cost share pledges are made in eFECS Cost Share
Module


Contact [email protected] or use Grant Tracker
Retro pay and overpayments made through Payroll
 Wait overnight, Confirm changes appear as you expect.
 View a new, updated FEC in eFECS.
Manual Changes – for Recertification Only
 For FECs created after online certification

Calendar: 7/1/11 -12/31/11 FECs

Academic: 9/16/11-12/15/12 FECs
 Make appropriate changes in UW systems (e.g. MyFD, Cost Share Module) and on
printed copy of certified FEC
 Attach documentation to support the revision
 Provide reason why effort previously was determined to be correct and now is not.
 Faculty signs and DATES the form in ink.
 Make a copy for department files and return original to MAA
Manual Changes – Prior to Online Certification
 Use the department copy of the previously certified
report and write “Revised” at the top
 For salary transfers and retro pay adjustments adjust %
in the “Compensation/% Distribution” column A
 For Cost Share changes use column D, “% Adjustment”


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Actual cost share is different than the pledge
Faculty chooses not to budget up to new cap
Documenting K Award cost share
Documenting short term shift in funding source
 Make adjustments in subtotals and totals.
Who should sign or certify the FEC?
 The faculty member whose name is on the FEC should
sign the form (prior to online certification) or certify
online (2012).
 Prior to When Certification is Online: Process when
Faculty is not on campus or unavailable to sign


Mail, scan or FAX the FEC to faculty for review and signature
Faculty can
Review and sign the form and return by campus mail.
 Review and sign the form and email back to chair or dean indicating
that the effort information is correct on the form.
 Chair or Dean can provide signature in ink using email as suitable
means of verification.

Suitable Means of Verification
 Suitable means of verification that the work was
performed is required by federal regulations.
 What is suitable means?


Participation in or close supervision of work performed
Written confirmation from the faculty member that the work
was performed and effort displayed accurately on the FEC.
Cycle Dates
 Calendar:
 1/1/xx – 6/30/xx
 7/1/xx – 12/31/xx
 Academic
 9/16/xx – 3/15/xx
 3/16/xx – 9/15/xx
Consequences, What’s the Risk?
 Significant audit findings are possible if reports are
late or inaccurate
 Audit findings may result in
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Payback of funds to sponsor
Withholding future awards
Temporary withholding of payments
Loss of expanded authorities
Special monitoring by sponsor
Requirements for corrective action
Designation as a “high risk” organization
What are the Issues
 Faculty spent less time on grants than
 proposed
 reported
 charged
 Audit Concerns
 Timeliness
 Sponsor approval of changes
 Salary transfers
 Cost share
 Proposed salaries = effort commitments = actual effort
Resources


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
FEC website:
 http://www.washington.edu/research/maa/fec/
eFECS website:
 https://f2.washington.edu/fm/efecs/
Cost share website:
 http://www.washington.edu/research/gca/costshare
GIM 15: Transfer of Expenditures between Budgets
 http://www.washington.edu/research/osp/gim/gim15.html
GIM 35: Effort Reporting Policy for Sponsored Agreements:
•



http://www.washington.edu/research/osp/gim/gim35.html
Faculty Effort Certification, online training
 Non-Clinical Version:
http://depts.washington.edu/fecnon
 Clinical Version:
http://depts.washington.edu/fecclin
The Code of Federal Regulations (CFR) Title 2, Volume I, Part 220 (OMB Circular A-21)
 Defines allowable costs and effort reporting requirements
The Code of Federal Regulations (CFR) Title 2, Volume I, Part 215 (OMB Circular A-110)
 Sets administrative standards
Help
 [email protected]
 eFECS Effort and Cost Share Modules
 [email protected]
 Cost share pledges
Congratulations
Recertifications Process
Prior to 7/1/11 and 3/16/11
 Make appropriate changes in UW systems (e.g. OPUS, Cost Share Module).
 Write “Revised at the departmental copy of the previously certified FEC.
 Make the required changes to the budget(s) by drawing a line through the
incorrect information and writing the adjusted amounts in ink.
 Adjust all totals and sub totals.
 Attach documentation to support the revision.
 Provide a reason why the effort was previously considered correct and now is
not.
 Have the faculty review and sign and date the form in ink.
 Make a copy for the department files and return the original to MAA.
Professor Researcher put
9% cost share effort on
budget 67-3119, Walking
Health. Revise FEC to
show appropriate
adjustments.
Recertification Process
for 7/11/11 and 3/16/11 FECs and forward

Make appropriate changes in UW systems (e.g. MyFD, Cost Share Module)

Log in to eFECS and navigate to the FEC needing to be recertified

Select the change status button and choose “Pending Recertification.”
o Print a paper copy of the certified FEC from eFECS

Make the required changes to the budgets

Adjust all totals and subtotals

Attach documentation to support the revision

Provide reason why effort previously was determined to be correct and now is not.

Faculty signs and DATES the form in ink.

Make a copy for department files and return original to MAA
An OSET
transfers
3.3%
effort
from a
budget in
Other
Salary
Sources
to budget
61-0825.
Adjust
the FEC