Faculty Effort Certification, the Basics April2012 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 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 $1.5 Billion in sponsored project funding Equals almost 1/3 of UW operating budget Supports over 7500 University employees 2600+ Faculty performing research each year UW is ranked 23rd best university in the world and fourth among American public universities. Around 2,500 FECs are processed annually by departments and MAA every year to document faculty effort on grants and contracts.

Sponsored Activity at UW 107 grants over $1m 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 salaries charged to grants and contracts. For UW faculty this is accomplished via the FEC. Salary charged to sponsored agreements 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 OMB A-21.

OMB A-21 The Code of Federal Regulations (CFR) Title 2, Volume I, Part 220, J 10 Charges fairly represent the work performed. Was the time faculty spent working on the grant reasonable, accurate? Verification that compensation charged is appropriate to the activity performed. Was faculty’s time actually spent on the grant as opposed to other work? Verification that 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 continues to be, an audit focus. 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 Penalties have ranged between $285,000 to $16.5 Million

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 for a federally funded project cannot be paid from other federal funds and only from non-federal sponsored project funds when approved by both 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/facultycostshare/detaileddefinition

The FEC Faculty members use Effort Certification Reports (FECs) to certify 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 Pre-Award Post-Award Appointment of Faculty & Staff Preparing the Proposal Project Set-up Charging Expenses Reporting & Certifying Effort Fiscal Reporting Records Retention Consider this a process, not an event, beginning when you first hire a faculty member and ending when the grant or contract closes and is archived.

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 the Office of Sponsored Programs (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 Department Revises/prepares GC1 Addendum if needed for cost sharing and submits to OSP Office of Sponsored Programs (OSP) Creates electronic Funding Action (eFA) and forwards to GCA along with a copy of the GC1 Addendum. GCA Receives eFA and GC1 Addendum from OSP and sets up budget in FIN and the eFECS Cost Share Module if there is cost sharing. Checks EVERYTHING Budget set up in FAS/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 (ADS) or Endowed Supplements (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 faculty have performed the work they committed in the proposal Available for audit to support salary charges 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 effort commitments as stated in the proposal have been met. Compare what was proposed to what was documented as actual effort, both cost share or paid on the grant. Ensure the total of the two combined are within tolerances of what was committed. Ensure there was not a shift in funding source that was not documented. Keep records of shifts. Keep any records that support changes (Perms, GC1 Addenda, etc.)

Step 7: Records Retention Departments will keep FECS and supporting documentation for one year after the end of the fiscal year for all FEC cycles prior the launch of eFECS, Phase III, Online Certification. January 2012: calendar reporters March 2012: academic reporters 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. (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 Effort Report Must be set up in ASTRA for Effort Reporting as User Roles: https://f2.washington.edu/fm/efecs/roles-access View Online Effort Report View and Update Effort Report View and Print Effort Report ASTRA set up instructions https://f2.washington.edu/fm/efecs/access-and-roles/get-access Log in to eFECS https://f2.washington.edu/fm/efecs/

Getting Access – eFECS Cost Share Module Must be set up in ASTRA for eFECS Cost Share as User with Campus Inquiry/View role. ASTRA set up instruction (in eFECS Training) http://www.washington.edu/uwit/im/Finance/efecs/ Log in to eFECS Cost Share Module

Getting Access - 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 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? Sponsor assumes what is committed in the proposal will be accomplished. Commitments include both effort paid directly from the grant and cost shared effort. Significant reduction in effort (25% or more) 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). Excludes Earn types that are not part of the IBS (e.g. TPS, E/C) Salary from VAMC, CHRMA, FHCRC, Outside professional work

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 source? 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?

Cost Share is prorated based on start and end dates of grant Rabbit, P.

What do I put into OPUS? Simple Example: % in OPUS should reflect % committed in proposal

What do I put into OPUS? 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 do I put into OPUS? ADS/ENS Administrative (ADS) or Endowed (ENS) Supplements 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 FEC to OPUS - % FEC to OPUS - $ OPUS to FEC - $

c r u Comments and predefined comments Show where to access comments Discuss using any predefined comments as applicable to the FEC and what might go in the additional comment section this would be a good lead into the next slide. u

What to put in the Comment Box- or Not . 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. Departments should reconcile the percent FTE on the FEC to HEPPS/OPUS records. True False 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/MyFD NO manual changes can be made to the online FEC. Manual Changes are for Recertifications Only Make changes on the certified copy of the FEC

System Changes System Changes Salary transfers (sometimes referred to as OSETs or RSTs) are made in MyFD Changes to cost share pledges are made in eFECS Cost Share Module Contact GCAHelp@u.washington.edu or use Grant Tracker Retro pay and overpayments made through Payroll Wait overnight, Confirm changes appear as you expect. View a new, updated FEC in eFECS.

Manual Changes – for Recertification Only For FECs created after online certification Calendar: 7/1/11 -12/31/11 FECs Academic: 9/16/11-12/15/12 FECs Make appropriate changes in UW systems (e.g. MyFD, Cost Share Module) and on printed copy of certified FEC 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. Make a copy for department files and return original to MAA More detail in exercise

Manual Changes – Prior to Online Certification Use the department copy of the previously certified report and write “Revised” at the top For salary transfers and retro pay adjustments adjust % in the “Compensation/% Distribution” column A For Cost Share 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 Make adjustments in subtotals and totals.

Who should sign or certify the FEC? The faculty member whose name is on the FEC should sign the form (prior to online certification) or certify online (2012). Prior to When Certification is Online: Process when Faculty is not on campus or unavailable to sign Mail, scan or FAX the 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: Academic 1/1/xx – 6/30/xx 7/1/xx – 12/31/xx

Consequences, What’s the Risk? Significant audit findings are possible if reports are late or inaccurate Audit findings may result in 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 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: 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 efecs@u.washington.edu GCAHelp@u.washington.edu eFECS Effort and Cost Share Modules GCAHelp@u.washington.edu Cost share pledges

Congratulations

Recertifications Process Prior to 7/1/11 and 3/16/11 Make appropriate changes in UW systems (e.g. OPUS, Cost Share Module). Write “Revised at the departmental copy of the previously certified FEC. Make the required changes to the budget(s) by drawing a line through the incorrect information and writing the adjusted amounts in ink. Adjust all totals and sub totals. Attach documentation to support the revision. Provide a reason why the effort was previously considered correct and now is not. Have the faculty review and sign and date the form in ink. Make a copy for the department files and return the original to MAA.

Professor Researcher put 9% cost share effort on budget 67-3119, Walking Health. Revise FEC to show appropriate adjustments.

Recertification Process for 7/11/11 and 3/16/11 FECs and forward Make appropriate changes in UW systems (e.g. MyFD, Cost Share Module) Log in to eFECS and navigate to the FEC needing to be recertified Select the change status button and choose “Pending Recertification.” Print a paper copy of the certified FEC from eFECS Make the required changes to the budgets 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. Make a copy for department files and return original to MAA

An OSET transfers 3.3% effort from a budget in Other Salary Sources to budget 61-0825. Adjust the FEC