Effort Reporting Department of Medicine Grand Rounds March 21, 2017 Anne DiNoto, Compliance Analyst Craig Gerome, Compliance Manager Gretchen Hartigan, AVP, PAFO

Background Federal Guidance: Charges to Federal awards must be based on records that accurately reflect work performed Be supported by a system of internal control... Charges are accurate, allowable, and properly allocated Incorporated into the official records of the non-Federal entity (BU) Reasonably reflect the total activity for which the employee is compensated Encompass both federally assisted and all other activities compensated by the non-federal entity Comply with established accounting policies Support the distribution of the employee’s salary or wages among specific activities or cost objectives Effort Reporting is simply the mechanism BU currently uses to comply with this Federal Guidance

High Level BU Policy Who is affected? Time Period? Salary or Effort? Professional / Exempt (Monthly Paid) Non Exempt (Weekly Paid) Students (Salaried, Weekly Paid) Time Period? Two PAR Periods: January – June July – December Salary or Effort? PARs are printed based on salary charged to sponsored / non sponsored awards BU Employees are certifying Effort, not Salary

What to look out for! Percentages must tie to 100% No decimal points... SAP works in whole numbers only We may be off 1% due to rounding... That’s ok. Faculty having 100% effort on Sponsored Awards only is a red flag and usually an audit issue... Faculty typically have other duties such as: teaching, clinic, administrative, and writing proposals Charging 100% of Faculty effort to NIH while writing an NSF Proposal is fraud. Faculty should always leave 3-5% wiggle room to account for the other administrative type duties Anyone over the DHHS Cap must include cost share (CY2016 = $185,100); (CY2017 = $187,000) Only individuals with “suitable means of verification that the work was performed” should be signing the PARs. Ideally each individual will sign their own.

What to look out for cont’d... Overbase / Incidental Wage Types For incidental type work (3 months or less), Incidental Wage Types can be used. These Wage Types will not be picked up on the PAR so will not be reflected within the overall effort of an individual. The three options to choose from are: 2109 Overbase-Research-Inciden 2110 Overbase-Teaching-Inciden 2111 Overbase-Service-Incident

PAR Example

Discussion Topics Cost Share Manual PARs UROP 100% Effort? Who can sign? Mail Codes / Mail Code changes? What do you use to confirm salary per grant is correct? Success stories... What do you find that works? ?

Post Award Financial Operations Reference Post Award Financial Operations Website: http://www.bu.edu/researchsupport/