1 EFFORT REPORTING Research Administration & Finance October 2009.

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EFFORT REPORTINGResearch Administration & Finance

October 2009

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What is Effort Reporting? A retrospective assurance that the time committed

and/or budgeted corresponds to the time spent and effort invested on a given sponsored project for a specific period.

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Why do we certify effort? Employees paid in whole or part from

extramurally-funded sources required to certify to effort/$$ expended on these projects as a condition of accepting the funding.

UCHC obligated to provide the administrative support and system to facilitate effort reporting.

Required…obligated…

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By whom? As a condition of accepting federal funds, we

(institutionally and individually) agree to meet federal guidelines for determining costs applicable to Grants (OMB Circular A-21).

Other sponsors, including the State of Connecticut.

University policy – it’s just good business.

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What’s the standard? The Federal government is the established standard. More

than 75% of UCHC’s research $$ are from federal agencies, predominantly the National Institutes of Health (NIH).

Federal government accepts ambiguity in research: “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.”

OMB Cir A-21, Section J10b(1)(c)

But institutional policies and procedures are required.

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What Criteria is Expected by the Federal Government to Meet the Standard? OMB Circular A-21, Section J.10.b(2)

A system of allocating salaries based on effort that is incorporated into the official records of the institution.

Must reasonably reflect the activity of the employee. May be made initially on the basis of estimates, but

significant changes must be identified and entered into the payroll distribution system.

An after-the-fact confirmation by a “responsible person with suitable means of verification that the work was performed.”

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Mistake or Fraud?

Cost disallowances and fines if effort reported does not appear reasonable.

Special monitoring. Name in the news. Fraud violations may subject both institution

and individual to civil and criminal prosecution.

The Federal Government has the power to impose sanctions on you and the institution for actions “deemed” to be fraudulent. These sanctions, and other actions, include…

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The Bottom Line Recent civil settlements between other

research institutions and the Federal Government:

Yale - $7.60 million Northwestern - $5.50 million Johns Hopkins - $2.60 million (for 1 PI) East Carolina University - $2.60 million Harvard/Beth Israel Deaconess MC - $3.25 million

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The Bottom Line continued

UCHC A-133 audit findings: 2008 Effort reports not certified on a timely basis

become questioned costs and therefore material findings. 2008 Particularly successful PI had 99% effort approved

to research. 2007 PI shares password. 2007 Labor distribution change authorization (LDCA) are

requested after effort has been certified – what is the basis for the certification in the first place?

UCHC aggressively enforces our policies and procedures because it is the right thing to do.

UCHC’s policies and procedures exist to guide and protect researchers and the institution. Recent effort reporting audits have sited UCHC for the following:

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Red Flags

Significant number of re-certifications – Pro-actively manage effort.

More than 95% effort on sponsored accounts – review effort commitments with Chair and AVP Research Administration & Finance on semi-annual basis.

Non-organized research sponsored accounts with 0% effort (clinical trials) – what’s the justification, does it make sense?

NIH salary cap violations – track salary cap investigators and review direct charges to grants.

1st hand knowledge test – did the investigator have 1st hand knowledge? If not, who did?

Accounts where effort is promised but none delivered. Federal standard applies to all sponsored accounts.

What types of activities cause concern for UCHC and how do we mitigate them?

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Red Flags (continued) Late or missing effort reports – will result in

suspension of spending privileges. Data inconsistency between financial and effort

reporting data and other sources of effort data: Time allocated to non-research activities

Teaching/Clinic Committees/NIH Study Sections Chair responsibilities

Payroll records Tenure material NIH Biographical Sketches and JIT Other Support pages Progress Reports

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The Details1. Who must file effort reports?2. What is effort and how is it determined?3. What is Cost Share?4. What is Salary Cap Cost Share?5. What about changes to effort?6. What do I do when a grant goes into a “No

Cost Extension?”7. What is our process for reporting effort?

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1. Who must file Effort Reports? Faculty who receive salary support from a

sponsored account and/or have committed effort on a sponsored account.

Staff who receive salary support from a sponsored account or who devoted effort to a grant as cost sharing (limited by UCHC policy #2002-14). Staff effort reports are filed by the PI.

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2. What is effort and how is it determined? Time devoted to all institutional activities expressed as a %

of total institutional activities. Total institutional activities includes time spent on:

Patient care Research Chair and committee responsibilities NIH study sections Education

Institutional activities do not include external professional activities for which you receive remuneration.

Effort is NOT a 40-hour work week. It is how you allocate your time across ALL your faculty activities.

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3. What is Cost Share? Cost share is that portion of an employee’s effort or

salary that is paid by the institution, rather than the sponsor.

Cost sharing of effort can be mandatory (required by the sponsor) or voluntary.

Cost sharing of salary as a result of the sponsor limiting the salary chargeable to a grant is salary cap cost share.

See policy #2002-14.

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3a. Effort Cost Sharing UCHC only recognizes “committed effort” cost

sharing. Committed effort cost share is a binding commitment

between UCHC, the employee, and sponsor. UCHC requires prior approval for cost share before

proposal submitted. Cost sharing is limited to PI and key personnel. Committed cost share can be mandatory (required by the

sponsor) or voluntary. Voluntary committed cost share becomes mandatory

when approved/awarded by the sponsor. See policy #2002-14.

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4. Salary Cap Cost Sharing Certain sponsors, including the National Institutes of Health,

limit the amount of salary that can be direct charged to a grant. 2009 salary cap = $196,700 Proportional amounts over this cap must be reported as Salary Cap

Cost Share. An employee making $200,000 and committed 50% to a grant would

have a salary cap cost share amount of $1,650. (200,000 * .5)-(196,700 * .5) = $1,650

Salary Cap Cost Share does not impact effort. It is a transfer of salary $$ only from the sponsored account to the cost share account.

With version 2.0 of ERS, Research Finance will track salary cap cost share and transfers dollars, leaving the effort report intact for certifying effort.

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5. What do I do when my effort changes?

Effort on a sponsored account should match the commitment approved in the grant proposal.

Changes to effort should be made according to the terms of the award. Federal requirements require prior notification for reductions of effort amounting to 25% or greater.

Prospective changes: Use the Assignment Authorization process to change future

allocation of effort. Retrospective changes:

Use Labor Distribution Change Authorization (LDCA) process to change posted payroll charges. Allowable retrospective changes include:

Changes to the current effort reporting period or older periods when effort has not yet been certified.

Changes to certified effort only permitted with Research Finance approval.

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6. What happens to effort during a “No-Cost-Extension”

A no-cost-extension is considered an extension of the project as approved.

PI effort must continue to be direct charged to the grant or cost-shared as previously approved.

Effort can be reduced by following the process defined previously.

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7. What is UCHC’s effort reporting process? UCHC’s Effort Reporting System (ERS), was

designed and developed by UCHC to meet the reporting needs of our research community.

ERS is available on-line from any computer (Mac or PC) with internet access and a commonly used web-browser, such as Internet Explorer or Firefox.

The next series of slides are click-by-click demonstrations of the ERS system. Some material is generic to the ERS system, others are specific to roles within the system, such as investigator, and department administrators.

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ERS Access Training will be conducted in the “Test”

Environment at :https://uat-home.uchc.edu/TimeAndEffort/Security/LocalLogin.aspx

ERS (in production) will available on October 16th at:

https://home.uchc.edu/Portal/Security/Login.aspx

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ERS Key DatesFiscal Year 2010 Key Dates

Data loaded for quarter September 30, 2009 December 31, 2009 March 31, 2009 June 30, 2009

Application available for Department Administrator approvals/changes (22 days) October 15, 2009 January 15, 2010 April 15, 2009 July 15, 2009

Effort reports on approved "system" approved and pushed to PIs for certification November 6, 2009 February 6, 2010 May 7, 2009 August 6, 2009

PI certifications and close of quarter December 14, 2009 March 16, 2010 June 14, 2009 September 13, 2009

Fiscal Year 2011 Key Dates

Data loaded for quarter September 30, 2010 December 31, 2010 March 31, 2011 June 30, 2011

Application available for Department Administrator approvals/changes (22 days) October 15, 2010 January 15, 2011 April 15, 2011 July 15, 2011

Effort reports on approved "system" approved and pushed to PIs for certification November 6, 2010 February 6, 2011 May 7, 2011 August 6, 2011

PI certifications and close of quarter December 14, 2010 March 16, 2011 June 14, 2011 September 13, 2011

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ERS Tutorials (to be added) Logging into ERS Department Administrator role

Delegating effort approvals to other administrators Approving effort as reported Approving effort with changes Creating an LDCA outside of Effort Reporting

Principal Investigator role Certifying effort Rejecting effort

Research Employee role Viewing effort report

Other roles Dean Department Chair Budget and Finance Research Finance