KEYS TO SUCCESS NCURA Region IV Spring Meeting April 27 – 30, 2014 © 2014 National Council of University Research Administrators Effort Certification and Policy Development National Council of University Research Administrators

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Christin Nelson Grants & Contracts Officer University of North Dakota

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Agenda - Definition of Effort Reporting -Definition of Effort -Federal Effort Certification Requirements -A-21 -Super Circular -Developing an Effort policy -Managing a paper based effort certification system

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Proper “Effort Reporting” includes definitions, policies, procedures, forms, data, and systems. Effort reporting includes management of: - faculty and staff appointments -pledging and tracking of institutional effort commitments -payroll distribution -effort certification -communication and training -enforcement of policy

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators What is Effort ? - Effort is defined as the amount of time spent on a particular activity. It includes the time spent working on a sponsored project in which salary is directly charged or contributed (cost share) -Individual effort is expressed as a percentage of the total amount of time spent on work-related activities (instruction, research, and service) for which the university compensates an individual. IBS- Institutional Based Salary -Effort certification is the institution’s means of providing assurance to sponsors that the effort charged or cost shared to each award has actually been completed.

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Federal Requirements Requirements actually relate to effort certification (there is no mention of “effort reporting” in federal regulations -As recipients of federal funding, educational institutions must abide by OMB Circular A-21 (Cost Principals for Educational Institutions) Section J.10.b.(2) Criteria for Acceptable Methods

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Section J.10.b.(2) Criteria for Acceptable Methods J.10.b.(2) (a) The payroll distribution system will J.10.b.(2).(a).(i). be incorporated into the official record of the institution J.10.b.(2).(a).(ii) reasonably reflect the activity for which the employee is compensated by the institution J.10.b.(2).(a).(iii) encompass both sponsored and all other activities on an integrated basis…

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators J.10.b.(2).(b) The method must recognize the principle of after the fact confirmation or determination so that costs distributed represent actual costs….Direct cost activities and F&A costs activities may be confirmed by responsible persons with suitable means of verification that the work was preformed. J.10.b.(2).(d) Practices vary among institutions and within institutions as to the activity constituting a full workload. Therefore, the payroll distribution system may reflect categories of activities expressed as a percentage distribution of total activities

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Super Circular 2 CFR Chapter I, Chapter II, Part 200-Super Circular Section (i)- Standards for Documentation of Personnel Expenses (1)Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work preformed. These records must: (i) Be supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. (ii) Be incorporated into the official records of the non- Federal entity

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators (iii) Reasonably reflect the total activity for which the employee is compensated by the non-federal entity, not exceeding 100% of compensated activities. (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis…

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators (c) The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made the to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. (ix) Because practices vary as the to the activity constituting a full workload, records may reflect categories of activities expressed as a percentage distribution of total activities.

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Importance of effort policy - comply with federal requirements - gives faculty, staff, and administrators a point of reference -lists the expectations of effort certification -gives consequences of not complying

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Developing an effort policy -Evaluate institution’s current processes -What processes does your institution current have in place for effort reporting? -Are these processes complying with the federal requirements? -Are changes needed? -Research other institution’s effort policies -Review other institution’s effort policies online -Ask administrators at other institutions about their policies -Develop a committee of faculty, staff, department administrators, and research administrators who work directly with sponsor funded projects

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Effort Policies and Procedures - Effort Reporting polices should address, at a minimum -Effort Commitments -Cost Sharing -Effort Certification -Content of the Policy -The “what” and the “why” -Content of the Procedures -The “how”, “who”, and “when”

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators What is “Negotiable”? -Frequency of effort certification (monthly, quarterly, yearly, or by semester) -Medium of certifying (paper or electronic) -Consequences -Reasonable period of time for completion (30, 45, 60 days) BE REALISTIC -Certification for individuals with time cards -Minimum level for effort on a project -Training (voluntary or mandatory)

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators “Non-negotiable” items: - All employees that expend effort on sponsored projects are required to certify 100% effort -Must be certified by responsible person with suitable means of verification that the work was preformed -Results must be incorporated into institution’s official record

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Drafting and Revising Policy - committee meetings -campus wide comment periods -redrafting

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Approving policy -Cabinet approval -President signature

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Policy implementation - publish policy -hard copy -campus newsletter -campus website -provide education -online -person to person training

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Tips for managing a paper based effort system - Central Effort Coordinator -coordinates effort runs -serves as a campus contact for effort -answers questions on effort reporting -provides training -sends out notifications -monitors returned forms -reviews system for errors

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators - Department effort coordinators - serves as a point of contact for listserv and training -routes and tracks effort forms - Colored paper

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Top 10 Things a PI Should Know 1. Effort is your work on a project, whether the sponsor pays your salary or not. 2. When you write yourself into a gran proposal, you are committing your effort to the sponsor. 3. If you reduce your effort, paid or unpaid, on a federal grant by 25%, you must have agency approval. If you reduce your paid effort, you may choose to document cost-sharing so that the total effort does not decrease. 4. Many activities cannot be charged to a federally sponsored project. For example, the time you spend on these activities cannot be charged: -writing proposal -serving on an IRB or other research committee -serving on a department or university service committee

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Top 10 Things a PI Should Know cont. 5. If you work on a sponsored project, you must certify to effort. 6. Certifying effort is not the same as certifying payroll. 7. Certification must reasonably reflect all the effort for all the activities that are covered by your University compensation. 8. Effort is not based on a 40 hour work week. It’s not based on hours at all. 9. Effort must be certified by someone with suitable means of verifying that the work was preformed. 10. In identifying audit findings, auditors look for indications that certification was based on factors other than actual, justifiable effort.

NCURA Region IV Spring Meeting April 27 – 30, 2014 National Council of University Research Administrators Questions?