KEYS TO SUCCESS NCURA Region IV Spring Meeting April 27 – 30, 2014 © 2014 National Council of...

KEYS TO SUCCESSNCURA Region IV

Spring MeetingApril 27 – 30, 2014

© 2014 National Council of University Research Administrators

National Council of University Research Administrators

Keys to Success!

NCURA Region IVIndianapolis, IndianaApril 27 – 30, 2014

NCURA Region IV Spring Meeting

April 27 – 30, 2014

KEYS TO SUCCESS


Effort Reporting: A Primer

Matt RichterEffort AdministratorUniversity of Wisconsin – Madison

NCURA Region IV Spring MeetingApril 27 – 30, 2014

NCRUA Region IV Spring

Agenda

• Background: What is Effort Reporting?• An Institution’s Effort Policy• Commitments• Effort• Cost Share• Questions

Slide 2 © 2014 National Council of University Research Administrators



Background: What is Effort Reporting

What is Effort Reporting?– Assuring an individual met his or her commitments

• The sponsor got what it paid for– Assuring sufficient effort was devoted to justify salary charges

• The sponsor paid for what it got

Basically, an Effort Report is… a receipt.





The basic idea• In a grant proposal, we offer effort• At award time, we make a commitment of effort• Throughout the project, we charge salary to the sponsor• Periodically, sponsors want to know:

– Have we devoted enough effort to justify the salary charges?– Even in cases where we are not charging salary to the sponsor, have we fulfilled our commitments?

• Precision is not required: Reasonable estimates are expected





Authority

• As recipients of federal funding, educational institutions must abide by OMB Circular A-21 (Cost Principles for Educational Institutions)

• A-21, Section J.10 outlines acceptable methods for supporting charges related to “compensation for personal services” on federal grants and contracts– OMB A-21, J.10: “the reports will be signed by the employee, PI or responsible

official(s) using suitable means of verification that the work was performed”– Direct knowledge not needed– First hand supervision not needed




Background: What is Effort ReportingGovernment Use:

•Verify that labor charges are appropriate based on the amount of work performed

•Verify that effort commitments and cost sharing is performed as promised

•Verify that sponsored research is appropriately classified (i.e., included in Organized Research F&A base)

Institution Use:

• Management reporting tools• Are faculty and others working in

areas as expected or promised?

• Is payroll distribution appropriate?

• Where is labor cost sharing occurring?

• May be used for other reporting purposes (state teaching requirements, Medicare time reporting)

Slide 6






What the regulations require us to do…

• Be careful about what we offer in a proposal• Be careful when making commitments at award time• Change commitments when needed, and document the changes• Fulfill commitments• Charge salary in a way that’s congruent with actual effort• Certify effort in a way that’s congruent with what actually happened





What the regulations require us to do…

• Not charge a grant for time that doesn’t pertain to the grant• Not charge a grant for time spent writing a proposal for a new project or a

competing continuation– Time spent on these activities must be covered by institutional or gift funds

• Transfer salary charges off of a grant if the level of effort does not justify the salary charges





…And why we do it right.

• The consequences of not getting this right can be dire for the university• Effort reporting remains a target for federal auditors• Many universities have paid millions of dollars in fines• Audits are underway at peer research institutions




Slide 10

PROPOSAL: Commitments are Offered

AWARD: Commitments Become Obligations

Commitment Setup

Commitments are Fulfilled

Tracking and Management

Life

cycl

e o

f a G

rant

Documentation & Reporting of

Fulfillment




An Institution’s Effort Policy: Who, What, When, Where

Who: Whose Effort must be certified?• Effort must be certified for all faculty, staff, students, and postdoctoral

researchers who either:– Charge part or all of their salary directly to a sponsored project, or– Expend committed effort on a sponsored project, even though no part of their

salary is charged to the project





Who certifies?• Effort must be certified by a responsible person with suitable means of

verifying that the work was performed• At the UW:

– All PIs, faculty, and academic staff members certify for themselves– PIs certify for the graduate students, postdocs, and non-PI classified staff who work

on their projects• When the PI doesn't have suitable means of verifying that the work was

performed:– A designee can certify the effort for project staff





What is required?• Effort certification is mandatory

– Effort training is looked at fondly by the feds, but is not required under J.10.

• At the UW: Penalties for non-compliance – The UW will not provide support for extramural activities

• Precision is not required in certifying effort– Reasonable estimates are expected





What is required?• At the UW: Recertification—up to the certification deadline, an individual

may request to recertify• At the UW: After the certification deadline:

– The PI or department administrator must submit a written request to RSP requesting to recertify

– The written request will be reviewed by the Associate Vice Chancellor for Research Administration

– Only in the most compelling of circumstances will it be granted





When to certify and take training:• Depends on the method for confirming payroll distribution:

– J.10 provides 3 examples of acceptable methods– A commonly used method: After-the-fact reporting

• At least every 6 months for professional and professorial staff• Hourly workers = monthly (time sheet will suffice)

• At the UW: For classified staff: 4 times / year– Periods of performance (PPs) correspond to calendar quarters

• At the UW: faculty, academic staff, grad students, postdocs: twice yearly– PPs are January - June and July - December

• At the UW: Certification starts a month or more after the PP• At the UW: The certification window is 90 days





Where to certify: Effort Reporting Systems• Many electronic systems on the market• At the UW: Assembled a PI task force to help choose the appropriate

software




Slide 17

PROPOSAL: Commitments are Offered

AWARD: Commitments Become Obligations

Commitment Setup

Commitments are Fulfilled

Tracking and Management

Life

cycl

e o

f a G

rant

Documentation & Reporting of

Fulfillment




Key Concepts: Commitments• A statement in the proposal or project application

– Specific and quantified– Effort for a PI, co-investigator, or key person, regardless of whether salary is

charged• An obligation that the university must fulfill• Example – Professor Jones proposes 30% of her effort for 12 months and

requests 10% salary support:– Professor Jones has committed 30% of her effort for that 12-month period




Key Concepts: Commitments

Slide 19

PaidEffort

Cost-Shared Effort

Non-Payroll Cost Sharing

Effort

Not Paid By Sponsor

Commitments

Non-Effort




Key Concepts: CommitmentsMinimum commitment required; Changing commitments• Minimum commitment: PI/PD is required to commit a certain minimum of

effort to each project– At the UW: Minimum commitment for PI/PD = 1%

• Commitments can be changed– Some changes require prior written approval from the sponsor– All other changes must be documented




Key Concepts: CommitmentsFor whom are commitments required?• The principal investigator/project director• All co-investigators• All individuals identified as senior/key personnel in the grant proposal

– At the UW: When the proposal does not explicitly list key persons, the university defines key personnel for the purpose of effort reporting as the principal investigator/project director and all co-investigators




Key Concepts: CommitmentsWhere are commitments indicated?• Some statements in the proposal become commitments when the

university and the sponsor finalize the award agreement:– Requests for salary support and statements about cost-shared effort in the

budget or budget justification– Effort proposed in the research plan or project description – but only when

specific and quantified:• Example: "Professor Jones will devote 10% of his time during the academic year

to this project."




Key Concepts: CommitmentsLimits on total commitments• Commitments can never total more than 100%• Commitments can add up to a full 100% only if ALL of your job duties to

your institution can be allocated to sponsored projects– This is generally not the case for faculty members, for any consecutive 12-

month period• Can academic staff, postdocs, classified staff be paid 100% from sponsored

projects?– This is not against the rules, and it’s entirely appropriate in many – but not all

– circumstances




Key Concepts: CommitmentsWhen the awarded budget is less than proposed• You cannot assume that the effort commitments are automatically

reduced in proportion to the budget reduction• You have several options:

– Keep salaries and effort the same, and reduce other budget categories– Keep effort the same, reduce salaries, and document the increase in cost

sharing– Reduce effort commitments – requesting prior approval for a key person's

reduction of 25% or more




Key Concepts: EffortWhat is Effort?• Effort is not based on a 40-hour work week• 100% equals all the activities for which you are compensated by your

institution, regardless of appointment or number of hours worked• Examples:

– If you work a half-time job, your 100% = what you do for that 0.5 FTE appointment

– If you work 80 hours a week, your 100% = what you do during those 80 hours




Key Concepts: EffortWhat counts as Effort?• The activities for which you are compensated by your institution• This includes:

– Externally sponsored research– Internally-funded or unfunded research– Instruction, administration, and service on committees– Public service and outreach activities directly related to your professional

duties at your institution




Key Concepts: EffortWhat does not count as Effort?• Activities for which someone else compensates you, and some activities

for which you are not paid• Examples:

– Consulting– Leadership in professional societies– Peer review of manuscripts– Advisory activities for a sponsor (NIH study section, or NSF peer review

panel)




Key Concepts: EffortWhat counts as sponsored activity?• Activities contributing to and intimately related to work under the

agreement • As long as it's about the specific project, it counts as sponsored activity:

– Lab meetings, conferences, seminars, writing a progress report– Reading journals to keep up-to-date on subject area

• Writing a proposal for a new project or competing continuation does NOT count

• Lab meetings not specific to a project do NOT count• Research patient care

– The care that is described in the protocol is sponsored activity– Routine patient care is NOT, even if provided to a research subject



Key Concepts: EffortEffort that is too small to count:• Activities that you do on an infrequent, irregular basis can be ignored in

your effort calculations if the total amount of time would not affect your effort distribution– Possible examples: department meetings, serving on a search committee –

depending on your individual situation• Regular, well-defined activities generally should not be treated as de

minimis• Proposal writing cannot be de minimis




Key Concepts: EffortUnfunded or “weekend” work:• Activities that are closely associated with your professional duties must

be counted as part of your 100% effort• Examples:

– Proposal writing– Instruction, administration, service on committees

• You cannot characterize them as "unfunded" or "volunteer" activities, or "weekend work," for which no institutional salary is paid




Key Concepts: EffortEffort can vary over time:• To meet a commitment, the actual effort need not be a constant• It must add up, over time, to fulfill the commitment• Example: If 30% effort is committed for a calendar year, one way to fulfill

this commitment is by spending:– 40% effort on the project during the first six months of the year, and– 20% effort on the project during the last six months




Key Concepts: Cost ShareWhat is Cost Share?• Cost sharing is the portion of the total costs of a sponsored project that is

borne by your institution• Cost-shared effort is any work on a sponsored project for which the

university, rather than the sponsor, provides salary support• Paid effort is work for which the sponsor provides salary support• Example – With a 30% effort commitment and salary support for 10% of

the effort:– 10% is paid effort– 20% is cost-shared effort




Key Concepts: Cost ShareMandatory Cost Share vs. Voluntary Committed Cost Share:• Mandatory cost sharing is cost sharing that’s required by the sponsor as a

condition for proposal submission and award acceptance• Voluntary committed cost sharing is cost sharing that is not required as a

condition for proposal submission– But, once offered and accepted, it becomes a commitment




Key Concepts: Cost ShareVoluntary Uncommitted Cost Share:• When you certify, you must include cost-shared effort up to and including

the amount of your cost-sharing commitments• If you’ve put in more time than you were paid to spend, over and above

your cost-sharing commitments:– This is voluntary uncommitted cost sharing– This extra effort is not required to be documented or tracked– You should not include it in the effort you certify for a sponsored project




Thank you

For questions, please contact me anytime:

Matt RichterEffort Administrator / ECRT Manager(608) [email protected]


KEYS TO SUCCESS NCURA Region IV Spring Meeting April 27 – 30, 2014 © 2014 National Council of...

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