Personnel Effort Reporting System (PERS) & Electronic Effort Reporting (ERS) Amy R. Lederberg Assoc VP for Research

PERS for Sponsored Projects  Effort reports are the documentation that salaries charged to a project are for work performed  Like a “receipt” for personnel costs  Proof we are not defrauding sponsor  OMB Circular A-21 provides guidance on what is acceptable documentation

PERS: Board of Regents  Wants to know how much of our state funds (instructional $$) is expended on research activities  We use the effort reporting system to generate this figure

Why are we changing?  Personnel Effort Reporting source of major finds by Universities: Florida International paid $11.5 million in fines Florida International paid $11.5 million in fines UAB paid $3.39 million UAB paid $3.39 million Northwestern $5.5 million Northwestern $5.5 million  Our old system did not comply with federal guidelines  Recent audits pointed out inadequacies of GSU system

What is different?  Implementing a new web-based Effort Reporting System designed by Maximus (ERS) developed to comply with federal guidelines  Adopted new policies and procedures Who certifies effort reports Who certifies effort reports Timeliness of effort reporting Timeliness of effort reporting Clarified what is effort Clarified what is effort

Basic Concepts  Only Effort for GSU (exclude activities that are not compensated for by GSU)  Document all sponsored-compensated effort Including committed cost share (via a companion account) Including committed cost share (via a companion account)  Uncommitted Cost Share Effort that is funded by GSU but not committed in proposal is accounted for by “non-sponsored activities” Effort that is funded by GSU but not committed in proposal is accounted for by “non-sponsored activities”

100% Effort may be Divided into Five Types of Activities How do I spend my time?  Sponsor Project Activities Sponsored (paid for by sponsor) Sponsored (paid for by sponsor) Cost Share (paid for by University) Cost Share (paid for by University)  Non-Sponsored Activities: Research (Department & University) Research (Department & University) University Instruction University Instruction Other Other

What is 100% of effort?  All the activities an individual engages in to earn GSU salary (IBS) Because it includes all activities they MUST equal 100%  100% of an Exempt employee’s effort is not defined by a set number of hours or days. For some, it may be 70 hours a week, others 40.  Part time employee may be 20 hours.  Summer faculty may be less than Full Time if earning less than 33.33% of Academic Year salary

What is not included in effort?  Activities that are being compensated for by another entity besides GSU Consultant activities to other institutions Consultant activities to other institutions Reviewing for federal agencies Reviewing for federal agencies Activities that earn an honorarium Activities that earn an honorarium Volunteer activities Volunteer activities

Students  Special case  IRS rules can only work up to 20 hours a week for compensation  100% effort < 20 hours worth of activities  Student can be doing additional educational activities which require them to work many more hours than 20 BUT can only be required to work up to 20 hours for salary

But I’m not a lawyer! OMB Circular A-21, Section J.10.b.1.c Reasonable estimates are based on the understanding: “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.”

ERS  After-the-fact certification  Three times a year (summer, fall, and spring)  Generates one Personal Effort Report (PER) per employee  Based on payroll allocation of Institutional Base Salary (excludes any special supplements) (i.e., corresponds to distribution of salary on PAF)

ERS: Workflow  Department Coordinators review effort reports Assign certifiers (default is employee) Assign certifiers (default is employee) Prereviews: Checks and makes sure payroll allocation is consistent with record Prereviews: Checks and makes sure payroll allocation is consistent with record  ERS automatically sends to certifiers after prereview (at 6 PM daily)  Certifiers review and certify effort  Department coordinators do cost transfers for any effort reports changed by certifiers

Who gets a PER?  All employees engaged in activities for a sponsored project (either charged directly to the sponsored account or to a companion account if cost sharing) (either charged directly to the sponsored account or to a companion account if cost sharing)AND  Faculty and staff funded solely from fund code 10 who are engaged in research funded by the university (does not include graduate students who are not on sponsored projects) (does not include graduate students who are not on sponsored projects)

Who can certify effort reports? Federal guidelines PERs are required to be certified in a timely manner by individuals “with suitable means of verification that work was performed” (OMB A-21 J.10.c.2.c)

Who can certify PER with sponsored effort?  Faculty do their own  PI certifies staff/student on sponsored projects OR  PI can designate someone who has suitable means of verification (i.e. Project Manager, Lab Coordinator – NOT department Business Manager) Must document via to department coordinator Must document via to department coordinatorOR  Staff can do their own (typically only when working on multiple projects with more than one PI and are long term employees)

Who can certify for faculty with only non-sponsored activity?  Only when faculty do not expect to have sponsored activity in the future (for next 5 years)  Department coordinators (business managers) can certify because only for BOR reporting purposes  BUT NEED TO BE CAREFUL  Can not change semester by semester

Step by Step Guide

ERS: Timing  Central administrator (Nicole Andrews) generates Effort Reports  Based on ACTUAL payroll from HR/Financials (Which should correspond to PAF (s) averaged over semester)  Summer and Fall: 30 days after close out of semester; Spring earlier  Prereview and Certification required to be finished 30 days later

Special Issues  Course releases I get one course release in the spring. Should I charge my grant 33.3% of my salary during that semester or 16.66% for the academic year? I get one course release in the spring. Should I charge my grant 33.3% of my salary during that semester or 16.66% for the academic year?  Summer I work on my grant all year but only want to charge it during the summer I work on my grant all year but only want to charge it during the summer

Effort Commitment: Proposed PIs estimate the amount of effort they will spend on a sponsored project in a proposal (and to build a budget) Federal agencies regard estimates as a commitment So do sponsors using federal funds (federal flow through, e.g., other institutions like state governments, other Universities) Some sponsors may not require fulfill effort commitments. Need to read terms and conditions of award. Call OSP if unsure.

Over commitment  PIs need to ensure they can fulfill effort commitment by examining all other sponsored and non-sponsored activities  Total Effort can not equal more than 100%  Because not all proposals are funded, PIs may get an award and can not fulfill commitment  Must get prior approval from sponsoring agency to reduce effort commitment. (Procedures specific to agency. Can get help from OSP)

Effort Commitments  OMB Circular A-110 Section 25.3.c: “recipients shall request prior approvals from Federal awarding agencies for….The absence for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator.”  Commitment may be binding on all “Key Personnel” as defined in the award document

Effort Commitments: Committed Effort %Actual Effort % Committed Effort % % Change in Effort If more than 25% than have to ask permission from sponsor for reduction of committed effort

Effort Commitments are for the Budget Year  Proposed effort committed for the academic year can be moved to the summer (or vice versa) IF actual effort for a budget year is not significantly reduced from the committed effort for that budget year AND actual effort for a budget year is not significantly reduced from the committed effort for that budget year AND the faculty member can certify they expended the effort during the period the sponsored project is charged. the faculty member can certify they expended the effort during the period the sponsored project is charged.

Commitment = payroll = effort Committed Effort = Salary Charged = (within 25% of effort committed) Actual Effort Certified (% charged = certified effort + 5% Total Effort)

What are auditors looking at? Effort Reporting  Commitments  Was the Proposed Effort Met?  Are Faculty Over Committed?  Certification  Was the Certifier Appropriate?  Account for All Activities?  Timeliness  Why are there Delays in Certifying Effort?  Do Delays Indicate Bigger Issues?

Cost Transfers  Was How & Why Occurred documented?  Are Charges Reasonable, Allowable, Allocable & Consistently Treated?  Did the PI Certify the Correctness of the new Charges to their Sponsored Project?  Are Processes Changed to Prevent Future Cost Transfers? What are auditors looking at?

Resources Available  Personnel Effort Reporting Policies & Procedures (lots of examples)  Salary, effort, and person conversion chart (available under proposal dev page) (available under proposal dev page) opment.html opment.html  Department Coordinator  Amy Lederberg and Nicole Andrews, RFS and OSP staff