Brown Bag Breakfast Briefing: Responsible Persons with/using Suitable Means of Verification for Effort Certification

DGCA Background OMB Circular A-21: Section J10b(2)(b) - …..Direct cost activities and F&A activities may be confirmed by responsible persons with suitable means of verification that the work was performed. Definition (Wiktionary): Responsible – answerable for an act performed, able to answer reasonably for one's conduct and obligations, held accountable

DGCA Responsible Persons/Officials Direct knowledge could encompass the Principal Investigator, the individual performing the actual work or a direct supervisor who have sufficient and verifiable knowledge of the work being performed, including an understanding of the individual’s regular duties and responsibilities RU : Principal Investigator (Preferred), the individual themselves or direct supervisor may certify effort reports Other department officials (i.e. Chairs, Deans, Directors), by proxy may certify provided they have suitable means of verification that the work was performed.

DGCA Responsible Persons/Officials Continued Reminder: In any audit situation, it would be the responsibility of the person certifying the effort to support all certification requirements were met and provide the suitable means of verification used

DGCA 5 Suitable Means of Verification Definitions: (Wiktionary): Suitable – Having sufficient or required properties for a certain purpose or task Verification - to denote confirmation by evidence that something that was believed is correct, serving to support or corroborate Oral verification from a faculty member to an administrator will NOT pass the test of “suitable means of verification Verification, at a minimum should be accompanied by some form of written documentation All documentation used as suitable means must be retained for audit purposes to support certification, consistent with the award’s record retention requirements

DGCA Suitable Means of Verification Continued The means of verification must take into consideration and be consistent with other University documentation in existence Must be sufficient to support a reasonable estimate of effort expended The responsible person/official certifying the report shall maintain a written description of what was used as the suitable means of verification for future audit purposes It is suggested that the source of written verification be noted internally for what was used to support effort for future audit purposes

DGCA 7 Examples of Suitable Means of Verification Calendar - Detailed Meetings - Agenda, Notes, Minutes, Attendees List Lab books/notes Time and Attendance Sheets/Sign-in Sheets Travel reports Award work products – Presentations, reports or analyses completed, surveys/interviews conducted, events held, log of services performed Other written documentation – Memos, s

DGCA Graduate Students If a graduate student is receiving tuition remission in addition to the salary on the grant, OMB A-21 indicates that the tuition remission is subject to the “reporting requirements” in Section J10. Since tuition remission charged to a grant should be in the same proportion as the salary charged to the award (i.e. 50% of student’s total tuition remission - 50% of GA’s salary to award), certification of a graduate student effectively supports the tuition remission charged to the award.

DGCA Red Flags Lack of Written Means of Verification to substantiate effort certified Contradictions to Other University Records –Appointment Letter/Contract –Teaching schedules –“Other Support” –Other active sponsored programs –Committee meetings – Department, University and Other –Travel records –Outside Activity Forms –Leaves Late Effort Reports Time sheets without supervisor’s OK and/or certification statement

DGCA Red Flags Continued Non-Compliance with Procedures for Accelerated Payroll Cutoffs Time Sheets. For further details, refer to: Late (>90 days) salary and tuition remission cost transfers Multiple re-certifications Agency Salary Cap Violations (i.e. NIH, NSF, etc) PI with 0% effort on funded award Non-Research Appointments – PIs with 90%+ on funded awards

DGCA Discussion What is your unit doing to ensure that suitable means of verification is being used and maintained by certifiers to support all time and effort certified? RIAS Phase III and New Web-based Effort Reporting System and Updated Policies and Procedures

DGCA Take Away - Recommendations Develop and implement standards within your unit on what written means of verification will be used to document actual work effort that will be maintained by PIs for audit purposes. Institute procedures within your unit to note internally what means of verification was used to support all time and effort certified. Provide training to all personnel in your unit involved in reviewing and certifying time and effort on effort reporting policies and procedures In cases where an individual is charged to multiple PI awards, ensure each PI confirms effort prior to certification