Transcript Introduction to Effort Reporting, the Basics

Faculty Effort Certification, the
Basics
OCTOBER 2011
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

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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 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 FY2010
$1,419,850,098
Non-federal
Sponsors, 30%
Federal
Sponsors, 70%
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 faculty salaries charged to grants and contracts.

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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 A-21.
OMB A-21
The Code of Federal Regulations (CFR) Title 2, Volume I, Part 220
 Charges fairly represent the work performed.
 Was the time faculty spent working on the grant reasonable,
accurate?
 Verification that the compensation charged is
appropriate to the activity performed.

Was faculty’s time actually spent on the grant as opposed to
other work?
 Verification that the 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 continue 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 cannot be paid from federal funds
and only from other non-federal sponsored project
funds when approved by 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/facultyc
ostshare/detaileddefinition
The FEC
 Faculty Effort Certification Reports (FECs) are forms
faculty use to document

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 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
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Department

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Office of Sponsored Programs (OSP)

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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 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 or Endowed
Supplements? ADS or 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 the faculty have performed the work they
committed in the proposal
 Available for audit
 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 documentation is available to verify that effort
commitments as stated in the proposal have been
met.
Step 7: Records Retention
 Departments will keep FECS and supporting
documentation one year after the end of the fiscal year for
all FEC cycles prior the launch of eFECS, Phase III, Online
Certification.
 With the launch of eFECS, Phase III, 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 with launch of Phase III. (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:
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Must be set up in ASTRA for Effort Reporting as User with FEC
Coordinator/View and Print Effort Report role.
ASTRA set up instructions
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https://f2.washington.edu/fm/efecs/access-and-roles
Log in to eFECS

https://f2.washington.edu/fm/efecs/
 Cost Share
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Must be set up in ASTRA for eFECS Cost Share as User with Campus
Inquiry/View role.
ASTRA set up instruction (in eFECS Training)

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http://www.washington.edu/uwit/im/Finance/efecs/
Log in to eFECS Cost Share Module
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http://www.washington.edu/uwit/im/Finance/efecs/
Unmet Cost Share Report
 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

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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?
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Sponsor assumes what is committed in the proposal will be
accomplished.
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Commitments include both effort paid directly from the grant and
cost shared effort.
Significant reduction in effort 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).
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 code?
 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?
Rabbit, P.
35
What do I put into OPUS?
 Simple Example:

% in OPUS should reflect % committed in proposal
 Administrative (ADS) or Endowed (ENS) Supplements
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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
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 to put in the Comment Box- or Not
38
.
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
 Manual Changes (Recertification Only)
 Make changes on the FEC
System Changes
 System Changes
 Salary transfers (OSETs) are made in MyFD
 Changes to cost share pledges are made in eFECS Cost Share
Module
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Contact [email protected]
Retro pay and overpayments made through Payroll
Before FEC is certified, wait overnight, Confirm
changes appear as you expect.
Print a new, updated FEC from eFECS.
Manual Changes
 Manual Changes
 Use column D, “% Adjustment”
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

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Using a non-federal grant, with sponsor approval, as a source
for cost sharing.
Manual Changes - Recertification
 For FECs created prior to Phase III:
Use the department copy of the previously certified report
 For FECs created after Phase III, online certification
 Print a paper copy of the certified FEC from eFECS

Write “Revised” at the top
Make the required changes
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.
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 Do not print a corrected copy from eFECS for recertification
purposes.
Who should sign or certify the FEC?
 The faculty member whose name is on the FEC
should sign the form (Phase II) or certify (Phase III).
 Phase II Process when Faculty is not on campus or
unavailable to sign


Mail, scan or FAX 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
What happens if I am late?
 Four Step Follow up Process

Step One: 45 Days after Release Date
Email reminder– FEC is due in two weeks.
 To: FEC Coordinator and Administrator


Step Two: 60 days after Release Date
Letter indicating FEC is overdue
 To: FEC Coordinator, Department Administrator; copy to Chair,
College/School Administrator, Faculty


Step Three: 60 days plus two weeks after Release Date
Letter indicating FEC is overdue
 To Chair; copy to Dean, Faculty, School/College and Department
Administrator, FEC Coordinator

The Final Step

Step Four: 60 days plus four weeks
Letter to Dean requesting all charges be removed from grant
 Copy to Chair, Faculty School/College and Department
Administrator and FEC Coordinator.

• PHASE III WILL PILOT REDUCTION IN FOLLOW UP BY MAA.
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:
•
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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
 http://f2.washington.edu/fm/maa/contact
 Compliance
Congratulations
Change or Delete?
Column D and Total
Column to reflect
increase in Cost Share.
.3
--------44.1
.3
----9.0
-.3
----55.9
Change or delete SHORT
TERM SHIFT IN
FUNDING SOURCE
5.6%
5.6%.
-5.6%
Budget 61-6850 - Short term shift in funding source
----49.4%
----10.0%
----50.6%