Effort Certification Amber Roberts Institutional Effort Coordinator Sponsored Projects Administration The Basics What? – What is effort certification? Why? –Why do we certify effort? When? –When.
Download ReportTranscript Effort Certification Amber Roberts Institutional Effort Coordinator Sponsored Projects Administration The Basics What? – What is effort certification? Why? –Why do we certify effort? When? –When.
Effort Certification Amber Roberts Institutional Effort Coordinator Sponsored Projects Administration The Basics What? – What is effort certification? Why? –Why do we certify effort? When? –When do we certify? Who? –Who should be certifying? How? –How is effort certified? What? The Effort Certification system: Documents effort (the amount of personnel activity) expended on federally sponsored projects Labor Distribution (payroll) information is pulled from Oracle for each employee for creation of the effort statements. Fringe Benefits/OPE and Travel Reimbursements are not included in the calculation. Certifying is the agreement that an employees payroll distribution and cost share (if applicable) is how they ACTUALLY spent their time on each federal project. More What? Certification is the assertion, by an employee or responsible official with suitable means of verification, that labor charges accurately reflect effort (activities) expended over the certification period The “Statement” When a person signs they are certifying to this statement: “I certify that I have reasonable means of verifying the activities performed by the above mentioned employee and that the distribution for effort represents a reasonable estimate of the actual work performed by the employee during the period covered by this report.” What is considered reasonable? Within 5% per line Why? OHSU’s Effort Certification system was developed in direct response to the Federal Office of Management and Budget (OMB) Circular A-21 A-21 addresses “principles for determining costs applicable to grants, contracts, and other agreements with educational institutions” More Why? A-21 aims to ensure that the Federal Government bears its fair share of total costs A 21 states : Institutions must be able to document the distribution of payroll charges using an acceptable method. OHSU uses after the fact Activity Records (J.10.c(2) in A21) Failure to comply with A-21 can have very serious consequences Even More WhyCommitted Effort What is the Committed Effort? It’s the effort commitment made at the time of award for the Principal Investigator and Key Personnel. Why is this important? We must honor our effort commitments. Most federal sponsors consider a 25% or greater reduction an issue. Auditors will compare committed effort in a grant application to actual effort on the certified Effort Certification Statements. Even More WhyCommitted Effort OHSU follows NIH guidelines http://grants.nih.gov/grants/policy/nihgps_2001/part _iia_5.htm Grantee must notify sponsor if PI or other Key personnel reduce their committed effort by 25% or more A letter must be generated by Principal Investigator detailing the new effort commitment requested. This is co-signed by the SPA Director. Grantee can always increase effort above proposed Faculty Committed Effort Faculty cannot have 100% Effort on Sponsored Funding with the exception: If PI is receiving 100% salary support on sponsored projects they need a signed statement on file from their departments Dean or Director specifying that they are 100% committed to research. This means the PI is does not have administrative, teaching, or clinical responsibilities and is solely working on their research projects. When? OHSU certifies effort semi-annually Effort periods end Jun 30 & Dec 31 Effort periods close in February and August Effort Process Timeline http://www.ohsu.edu/research/rda/spa/docs/effc erttl0110_0610.pdf IEC Reminders Institutional Effort Coordinator sends email reminders: That the effort period has ended (December 31st and June 30th) Upcoming close and LD Lockout (In February and August) of the effort period Statements are ‘in the mail’ and to check for packets Upcoming deadline for turning in statements (April and October) Who? An employee is required to complete an Effort Certification Statement (ECS) if… Their activities are partially or totally devoted to a sponsored agreement (federal grant, contract or cooperative agreement, or federal money from a pass-through entity) AND, pay is partially or totally paid from such an agreement, OR represents cost sharing Who else? Graduate Research Assistants receiving GRA support payments (object code 5198) need to certify their effort. HR has determined GRA’s to be “quasi” employees. Research Training Fellows receiving stipend payments do not certify effort. They are not considered employees and are here strictly for a training experience. Cost Sharing Cost sharing is defined as the portion of the project or program costs not borne by the sponsor. The majority of Cost Sharing commitments are met through effort/payroll expense Cost Shared Effort must be included on Effort Certification Statements and certified. Cost Sharing must be from a non-federal account— most likely a General Ledger Account. How? Oracle identifies individuals who are receiving effort related salary from federally sponsored and cost sharing accounts in the Payroll Module. Note: If you have someone who is receiving all of their salary off of the GL, but have activities benefiting a project as cost sharing please be sure to contact the IEC at the close of the effort period. Statements are generated showing the effort related percentages of payroll distribution the individual received on each account. Effort Certification Statements Example Print Date: For the Effort Period: Jan08-Jun08 01/01/2008-06/01/2008 Oregon Health and Science University Effort Certification Statement Employee#/ Name: 12345 Schultz, Charles Employe e Cove rage : 1-JAN-2008 To 30-JUN-2008 Mail Code: Primary Organization: Project # Award # Project Name Run: Database: FISPRD Award Name % Payroll Distribution % C/S Committed % C/S Uncommitted T otal C/S T otal Effort 0% 0% 0% 100% GL-Related Activities 0151-69999-11-5111-000-0000-000 UNIVERSIT Y GENERAL FUND 24.75% OGA Related Activities 35.00% GRANT A AWARD A NIH Grant BBB interaction study GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28% GRANT C AWARD C NIH Grant Stroke study 7.46% GRANT D AWARD D AHA Grant Stroke study GRANT E AWARD E Univ of WA Stroke studies 8.29% 20.22% 100.00% I c e rt if y t h a t I h a v e re a s o n a b le m e a n s o f v e rif yin g t h e a c t iv it ie s p e rf o rm e d b y t h e a b o v e m e n t io n e d e m p lo ye e a n d t h a t t h e d is t rib u t io n o f e f f o rt re p re s e n t s a re a s o n a b le e s t im a t e o f t h e a c t u a l wo rk p e rf o rm e d b y t h e e m p lo ye e d u rin g t h e p e rio d c o v e re d b y t h is re p o rt . [_] Principal Investigator Relationship to covered Individual (please check one) Covered Individual Or Date Responsible Official Date [_] Supervisor Responsible Official (Please print name) Note on Suspense Activity Suspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation. Note on Cost Sharing Please enter the amount of cost sharing in each of the C/S fields. %C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing. Note on Federal Salary Cap It is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then %Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the %C/S Committed column. How? More How? What if cost sharing or corrections are needed? Examples can also be found online at http://www.ohsu.edu/research/rda/spa/effortworkshop.shtml Cost Sharing If applicable, cost shared effort needs to be shown on a ECS. If a cost share companion account has been set up, the account should be shown already on the statement. If a companion account is not being used, cost sharing must be shown using a hand correction showing support from a non-federal sponsored account to the sponsored account. Cost Sharing Hand Corrections Print Date: For the Effort Period: Jan08-Jun08 01/01/2008-06/01/2008 Oregon Health and Science University Effort Certification Statement Employee#/ Name: 12345 Schultz, Charles Employe e Cove rage : 1-JAN-2008 To 30-JUN-2008 Mail Code: Primary Organization: Project # Award # Project Name Run: Database: FISPRD Award Name % Payroll Distribution % C/S Committed 24.75% 35.00% % C/S Uncommitted T otal C/S T otal Effort -10.00% -10.00% 14.75% 10.00% 10.00% 45.00% 4.28% 7.46% 8.29% 20.22% 0% 100% GL-Related Activities 0151-69999-11-5111-000-0000-000 UNIVERSIT Y GENERAL FUND OGA Related Activities GRANT A AWARD A NIH Grant BBB interaction study GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28% GRANT C AWARD C NIH Grant Stroke study 7.46% GRANT D AWARD D AHA Grant Stroke study GRANT E AWARD E Univ of WA Stroke studies 8.29% 20.22% 100.00% 0% 0% I c e rt if y t h a t I h a v e re a s o n a b le m e a n s o f v e rif yin g t h e a c t iv it ie s p e rf o rm e d b y t h e a b o v e m e n t io n e d e m p lo ye e a n d t h a t t h e d is t rib u t io n o f e f f o rt re p re s e n t s a re a s o n a b le e s t im a t e o f t h e a c t u a l wo rk p e rf o rm e d b y t h e e m p lo ye e d u rin g t h e p e rio d c o v e re d b y t h is re p o rt . [_] Principal Investigator Relationship to covered Individual (please check one) Covered Individual Or Date Responsible Official Date [_] Supervisor Responsible Official (Please print name) Note on Suspense Activity Suspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation. Note on Cost Sharing Please enter the amount of cost sharing in each of the C/S fields. %C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing. Note on Federal Salary Cap It is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then %Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the %C/S Committed column. Salary Cap? NIH prohibits employees from receiving a salary greater than the established cap ($199,700 for calendar year 2010) http://grants.nih.gov/grants/policy/salcap_summary.ht m Any amount above this cap must be considered Cost Sharing and charged to the appropriate non-federal account For more information about the salary cap, please register for the Advanced Effort- Salary Cap PEP class Change to the % of Payroll Distribution The ECS is generated but the % of payroll needs to be changed. 1) Enter a change in Labor Distribution in Oracle to reflect the correct % of payroll 2) Do a hand correction to amend the ECS to mirror the Labor Distribution Change. Changes should be made to the left of the % payroll column 3) Complete a Labor Cost Transfer Form (LCTA Form) http://www.ohsu.edu/research/rda/spa/docs/lcta.pdf 4)Submit all paperwork together to SPA % of Payroll Distribution Hand Correction Print Date: For the Effort Period: Jan08-Jun08 01/01/2008-06/01/2008 Employee#/ Name: 12345 Oregon Health and Science University Effort Certification Statement Schultz, Charles Employe e Cove rage : 1-JAN-2008 To 30-JUN-2008 Mail Code: Primary Organization: Project # Award # Project Name Run: Database: FISPRD Award Name % Payroll Distribution % C/S Committed % C/S Uncommitted T otal C/S T otal Effort GL-Related Activities 0151-69999-11-5111-000-0000-000 34.97% 24.75% BBB interaction study 35.00% 35.00% 4.28% 7.46% 8.29% 20.22% UNIVERSIT Y GENERAL FUND 24.75% OGA Related Activities GRANT A AWARD A NIH Grant GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28% GRANT C AWARD C NIH Grant Stroke study 7.46% GRANT D AWARD D AHA Grant Stroke study GRANT E AWARD E Univ of WA Stroke studies 8.29% 20.22% 10.00% 100.00% I c e rt if y t h a t I h a v e re a s o n a b le m e a n s o f v e rif yin g t h e a c t iv it ie s p e rf o rm e d b y t h e a b o v e m e n t io n e d e m p lo ye e a n d t h a t t h e d is t rib u t io n o f e f f o rt re p re s e n t s a re a s o n a b le e s t im a t e o f t h e a c t u a l wo rk p e rf o rm e d b y t h e e m p lo ye e d u rin g t h e p e rio d c o v e re d b y t h is re p o rt . [_] Principal Investigator Relationship to covered Individual (please check one) Charles Schultz 0% 0% 0% 9/13 /2010 Covered Individual Or Date Responsible Official Date [_] Supervisor Responsible Official (Please print name) Note on Suspense Activity Suspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation. Note on Cost Sharing Please enter the amount of cost sharing in each of the C/S fields. %C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing. Note on Federal Salary Cap It is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then %Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the %C/S Committed column. 100% Suspense Activity Clearing Suspense is where Labor Distributions go when there is not an account to place it in! It starts with a 0051 Fund Number All Suspense must be cleared on ECS and in LD before a statement can be accepted. Suspense Corrections The same protocol exists for the % of payroll change 1) Enter a change in Labor Distribution in Oracle to reflect the correct % of payroll 2) Do a hand correction to amend the ECS to mirror the Labor Distribution Change. Changes should be made to the left of the % payroll column 3) Complete a Labor Cost Transfer Form (LCTA Form) http://www.ohsu.edu/research/rda/spa/docs/lcta.pdf 4)Submit all paperwork together to SPA Suspense Hand Corrections Print Date: For the Effort Period: Jan08-Jun08 01/01/2008-06/01/2008 Oregon Health and Science University Effort Certification Statement Employee#/ Name: 12345 Schultz, Charles Employe e Cove rage : 1-JAN-2008 To 30-JUN-2008 Mail Code: Primary Organization: Project # Award # Project Name Run: Database: FISPRD Award Name % Payroll Distribution % C/S Committed % C/S Uncommitted T otal C/S T otal Effort GL-Related Activities 0151-69999-11-5111-000-0000-000 UNIVERSIT Y GENERAL FUND 0051-69999-11-5111-000-0000-000 SUSPENSE CLEARING ACT IVIT Y 24.75% 0.00% 24.75% 0.00% 10.22% OGA Related Activities GRANT A AWARD A NIH Grant BBB interaction study 35.00% GRANT B AWARD B NSF Grant Alzheimer's Disease study 4.28% GRANT C AWARD C NIH Grant Stroke study 7.46% GRANT D AWARD D AHA Grant Stroke study GRANT E AWARD E Univ of WA Stroke studies 8.29% 20.22% 10.00% 100.00% I c e rt if y t h a t I h a v e re a s o n a b le m e a n s o f v e rif yin g t h e a c t iv it ie s p e rf o rm e d b y t h e a b o v e m e n t io n e d e m p lo ye e a n d t h a t t h e d is t rib u t io n o f e f f o rt re p re s e n t s a re a s o n a b le e s t im a t e o f t h e a c t u a l wo rk p e rf o rm e d b y t h e e m p lo ye e d u rin g t h e p e rio d c o v e re d b y t h is re p o rt . [_] Principal Investigator Relationship to covered Individual (please check one) 35.00% 4.28% 7.46% 8.29% 20.22% Charles Schultz 0% 0% 0% 9/13 /2010 Covered Individual Or Date Responsible Official Date [_] Supervisor Responsible Official (Please print name) Note on Suspense Activity Suspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation. Note on Cost Sharing Please enter the amount of cost sharing in each of the C/S fields. %C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing. Note on Federal Salary Cap It is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then %Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the %C/S Committed column. 100% TBD Correction The ECS is generated but an award is missing because an account is not yet set up in OGA. 1) Write in TBA for Grant Account Number 2)Show Effort in the Cost Sharing Column 3) Once OGA account is set up, LD can be changed and a LCTA form will be needed but you will not need to do an amended ECS. TBD Hand Correction Print Date: For the Effort Period: JAN10-JUN10 1/1/10 T o 6/30/2010 Employee#/ Name: 12345 Schultz, Charles Award # Project Name Run: Database: FISPRD Employe e C ove rage : 1-JAN-2010 To 30-JUN-2010 Mail Code: Primary Organization: Project # Oregon Health and Science University Effort Certification Statement Award Name % Payroll Distribution % C/S Committed 25.00% -10% % C/S Uncommitted T otal C/S T otal Effort GL-Related Activities 0151-69999-11-5111-000-0000-000 UNIVERSIT Y GENERAL FUND 15% OGA Related Activities GRANT 1000A AWARD1000 NIH Grant BBB interaction study 25.00% GRANT 2000A AWARD2000 NSF Grant Alzheimer's Disease study 25.00% AWARD3000 AHA Grant Stroke study 25.00% GRANT 3000A TBD PI: Schultz, C NIH Grant Cardiac Study 10% 100.00% I c e rt if y t h a t I h a v e re a s o n a b le m e a n s o f v e rif yin g t h e a c t iv it ie s p e rf o rm e d b y t h e a b o v e m e n t io n e d e m p lo ye e a n d t h a t t h e d is t rib u t io n o f e f f o rt re p re s e n t s a re a s o n a b le e s t im a t e o f t h e a c t u a l wo rk p e rf o rm e d b y t h e e m p lo ye e d u rin g t h e p e rio d c o v e re d b y t h is re p o rt . [_] Principal Investigator Relationship to covered Individual (please check one) 25% 25% 25% 10% 0% 0% Charles Schultz 8 /3 0/2010 Covered Individual Or Date Responsible Official Date [_] Supervisor Responsible Official (Please print name) Note on Suspense Activity Suspense activity must be cleared before certifying the statement. When returning the statement please write, in ink, what the funding should have been and attach a copy of all appropriate back-up documentation. Note on Cost Sharing Please enter the amount of cost sharing in each of the C/S fields. %C/S Committed includes Mandatory and Voluntary Committed cost sharing. C/S Uncommitted refers to only Voluntary Uncommitted cost sharing. Note on Federal Salary Cap It is the department's responsibility to ensure salary charges to NIH, SAMHSA, and AHRQ awards are not distributed at a rate in excess of the salary cap for those sponsors. If the covered individual's total salary is in excess of the cap then %Payroll Distribution should not be certified equal to Total Effort. The difference between allowable salary distribution and actual effort should be refelcted in the %C/S Committed column. 0% 100% Additional Info & Things to Remember Please document effort for each line in the far right column—this helps to explicitly show what the person’s effort is for each account Effort must add up to 100% The date the statement was signed must be included If a responsible official signs (this must be someone who has substantial knowledge of the individual’s effort), they must also include their printed name and check one of the relationship box options Additional Info & Things to Remember Use pen (not pencil) to make corrections DO NOT use White out Total effort column needs to sum to 100%. Cost sharing columns need to sum to zero SPA cannot amend these forms on your behalf. Additional Info & Things to Remember A great tools to use before and after you get statements: Effort Certification Process Timeline (http://www.ohsu.edu/research/rda/spa/docs/effcerttl011 0_0610.pdf) Effort Procedure (http://www.ohsu.edu/research/rda/spa/docs/effortcertpr oc.pdf) OGADW Employee Effort Report Distribution by Period in Discoverer If you aren’t sure about something, call the Institutional Effort Coordinator! Additional Info & Things to Remember There is approximately 30 days between the end and the close of the effort period. This time allows you to review and make any needed LD Changes. This helps reduce the need for payroll related hand corrections on the ECS. DECs have approximately 35 business days between the time statements are distributed to the return deadline. Outstanding statements are subject to the Notification Process If DECs have a statement that will be late, please send in what has been certified before the deadline. Signature Reminder It is generally inappropriate for a Departmental Effort Coordinator or a Department Chair to sign all of the Effort Certification Statements in the unit or department. Let’s Review! Let’s Review! Let’s Review! Let’s Review! What Tools Are Available to with Effort Certification? Effort Timeline Effort Procedure OGADW Employee Effort Report Distribution by Period Institutional Effort Coordinator (IEC) Let’s Review! Who needs an Effort Certification Statement? Anyone who’s effort/activity is partially or totally devoted to a sponsored agreement (federal grant, contract or cooperative agreement, or federal money from a pass-through entity) AND, pay is partially or totally paid from such an agreement, OR represents cost sharing Let’s Review! When does OHSU Certify Effort? Twice Each Year (Jan1-June 30 & July 1-Dec 31) How much time is provided to change Labor Distribution after the Effort Certification Period Ends (either June 30 or Dec 31)? 30 business days o Note: Keep an eye on the Effort Certification Process Timeline for deadline dates and when LCTA forms must be in for adjustments that do not auto approve. Let’s Review! How many days after SPA distribution date are the ECS form due back to SPA? 35 business days The deadline date is listed on the Effort Certification Process Timeline How many notifications are sent for late Effort Certification Statements? 5, the last to the Dean or Director of the Department Let’s Review! What is a reasonable estimate? +/- 5% per line True or False? DECs must wait to submit all their ECS to SPA until they have all been signed! False!!! Please submit all certified statements before the effort deadline Let’s Review! True or False? As a the Department Effort Coordinator, I truly do know what folks are up to in my department, and thus I can sign the ECS form. Most likely FALSE!!! Remember what the “statement” says and what certifying means. Let’s Review! True or False? I can edit the Effort Statements with Pencil FALSE. Pen please! True or False? I can white out on Effort Statements. FALSE. The use of white out voids the effort statement and a new one will be needed. Let’s Review! If you receive an ECS that needs a correction, what steps do you need to take? If payroll related, correct LD to match actual effort performed (if cost sharing-no LD may be needed) Hand Correct Statement (using PEN) to reflect Effort change and obtain appropriate signatures Complete LCTA Form if LD change was made Submit all to SPA One last thing! What if you need to correct an already certified statement? AMENDING A STATEMENT ERODES THE CREDIBILITY OF THE CERTIFIER AND THE STATEMENT SO PLEASE TRY TO ALWAYS AVOID THIS! BUT IF YOU MUST….There is a process for amending and recertifying effort statements. Submit an LD adjustment, LCTA form and an amended ECS with hand corrections Complete a Effort Recertification Form located on SPA’s website under Effort http://www.ohsu.edu/research/rda/forms.shtml#fm Don’t forget the Effort Procedure is available online The full text of OHSU’s Effort Certification Procedure is available on the SPA website: http://www.ohsu.edu/research/rda/spa/docs/effo rtcertproc.pdf Questions? If you think of something later you can contact the IEC at [email protected] or at ext. 4-6984.