1. The Basics of Effort Reporting
FS 126
Jorge Rafael Manzano Time and Effort Coordinator Office of Sponsored Programs
Tuesday, September 18, 2018

2. Purpose
The purpose of this course is to familiarize faculty and their administrative support staff with Federal regulations and UTSA policies and procedures that govern effort commitments, reporting and certification.

3. Goals
Explain the key principles of effort and related concepts on sponsored projects
Communicate the requirements that apply in proposing, managing, and certifying effort on sponsored projects
Provide guidance on effort reporting and certification

4. Audience
Completion of this course is recommended for:
Principal Investigators with active sponsored projects (manage “26” accounts)
Department administrative and support staff who provide support to PIs on their 26 accounts (e.g., make grant appointments)
Administrators and other members of the campus research community may also find it useful.

5. Outline Topics Purpose 1. Basics of Effort and Sponsored Projects
Outline the fundamental principles of effort and commitments, so you understand what’s required of you when you certify effort
2. Total Institutional Activities
3. Commitments
4. Effort Certification Requirements
Outline the reasons behind effort reporting and who does what
5. Guidelines and Policies
6. Review Exercise
Test what you covered in this course
7. How to Certify (FS 127…)
A Look at the ECRT system

6. So what is effort?
Effort is the amount of time spent on any activity expressed as a percentage of Total Institutional Activities for which an Individual is compensated by UTSA.
Your UTSA job duties may include:
Instruction
Administration
Research
Service as a member of a committee or governance body
Service and outreach to the community

7. And what is a sponsored project?
A sponsored project is activity that is funded by a grant, contract, or cooperative agreement under which there is a scope of work, a specific budget, and specified terms and conditions. It requires detailed financial accountability and compliance with the sponsor’s terms and conditions.
In this course we'll focus on effort associated with sponsored projects and the relationship of that effort to your non-sponsored activities.

8. What is effort certification?
If you work on a sponsored project, you're required to assure the sponsor that:
You did, in fact, devote effort to the project at a level that corresponds with how you were paid from the project
You’ve met your commitments of effort to the project, regardless of whether the sponsor provided salary support

9. What is effort certification?
Effort certification is the university's means of providing this assurance to sponsors. To certify your effort, you'll review a statement that shows:
The sources from which you were paid, including (if applicable)…
Your cost-shared effort on sponsored projects

10. What is effort certification?
Your task is to make sure that the statement shows a correct distribution of your effort. This requires a good understanding of many things, including:
Cost-shared effort
Commitments to sponsored projects
How to classify the things that you do, so you can sort them into buckets for the purpose of determining your effort distribution
In this course, the terms effort certification and effort reporting are used interchangeably.

11. Keep in mind…
Effort certification is not an exact science!
Don’t worry - you don’t need to come up with a precise accounting of your time. Sponsors recognize that research, teaching, service, and administration are often inextricably intermingled.
Reasonable, good faith estimates are expected. But there are some rules you must observe…

12. Keep in mind…
Total effort must equal 100%
Effort is NOT calculated on a 40-hour workweek or any other standard workweek
Not limited by time (daytime, evening, weekends) or place (on campus, at home, while traveling)

13. Putting it all together
Total Effort = ∑ (UTSA Activities)

14. What counts as Total Institutional Activities?
Because you must certify 100% of your Total Effort, it’s important to know what counts as effort and what doesn’t. The basic rule is: Your Total Effort includes all the professional activities for which you are compensated by the university.
Effort includes:
Sponsored Programs (e.g. grants and contracts)
Non-Sponsored (Departmental) Research
Teaching
Service
Administrative Duties
Other Institutional Activities
Outside consulting, or other income earned outside of duties to UTSA
Supplemental compensation for non-permanent, incidental work
Outside consulting, or other income earned outside of duties to UTSA
Supplemental compensation for non-permanent, incidental work

15. UTSA Activities on Sponsored Projects
Your sponsored effort is part of your Total Effort. When you certify sponsored effort, it’s important to know what activities can be allocated to a sponsored project.
The basic rule is: A sponsored project can only be charged for activities that directly relate to the work of the project.

16. UTSA Activities that can be allocated to a sponsored projected
Actual conduct of research in furtherance of a grant’s objectives
Administrative effort directly associated with the research
Special lectures, writing reports and articles, participating in seminars, consulting with colleagues and graduate students, attending meetings and conferences
Preparing progress reports
“On the job” training of grant personnel

17. UTSA Activities that cannot be allocated to a sponsored projected
Effort expended on research not in furtherance of the objectives of the grant to which it is charged, i.e., effort related to another grant or to an area of general scientific interest
New proposal writing
General instruction
General administrative activity
Unrelated departmental research
Unrelated clinical activity

18. When should I think about effort?
PRE-AWARD
POST-AWARD
Preparing
Proposal
Budget
Effort Commitment is Entered
Charging
Salary
Certifying
Effort
Effort is proposed and budget is prepared (based on IBS, % time, and duration), and proposal package is submitted to the sponsor
Effort commitment is established based on award negotiation and/or acceptance of award
Effort is charged, reflected in grant appointment (or department account as cost sharing)
Effort is attested to, after activity has occurred
LEADERSHIP, POLICIES, TRAINING, SYSTEMS

19. Making a Commitment of Effort
A commitment is the amount of effort you propose in a grant proposal or other project application, and that the sponsor accepts – regardless of whether you request salary support for the effort.
A commitment is an obligation that the university must fulfill.
Commitments are specific and quantified, and they generally are expressed in terms of a percentage of your work time over a given project period.
Commitments may be adjusted with the approval of the sponsoring agency.

20. Effort Commitments on Sponsored Projects
Often, the sponsor pays all of the costs associated with a sponsored project. But sometimes UTSA bears a portion of the costs.
Paid effort is work for which the sponsor provides salary support.
Contributed (or cost-shared) effort is any work on a sponsored project for which the university, rather than the sponsor, provides salary support.
Both types of effort are important in the effort certification process.

21. Tracking Effort Commitments
Commitments are recognized and must be tracked for:
the principal investigator/project director
all co-investigators
all persons identified as senior/key personnel in the grant proposal.
When the proposal does not explicitly list key persons, the university defines key personnel for the purpose of effort reporting as the principal investigator/project director and all co-investigators.

22. Must I include effort on a grant?
PIs have to commit at least a minimum level of effort to a sponsored project, whether it is directly or indirectly charged to the grant.
Exceptions:
Equipment and instrumentation grants
Dissertation support, training grants or other awards intended as “student augmentation”
Limited-purpose awards, such as travel grants, conference support, etc.
Proposals without any effort listed will have to be signed off on by department chair through routing form process.

23. Is there a maximum commitment level?
Primary Individuals must consider academic and non- sponsored duties when committing effort.
“40/40/20”
Department/College approval
For those individuals who have administrative appointments, the maximum level of effort may not exceed eighty percent (80%) percent of their total effort annually.

24. Is there a maximum commitment level?
100% effort is allowable over the summer provided that the individual cannot perform other activities during that period (e.g. serving on institutional committees, writing proposals, etc.) whose costs are not allowable under OMB Circular A-21.
Individuals tasked as Supporting Individuals or Key Personnel or those with research appointments (e.g. research technicians, research postdoctoral positions or research associates) may be allowed a one hundred percent (100%) appointment on a sponsored program with a similar level of effort.

25. Any questions?

26. Certification: Why are we here?
Why did I
get that grant?

27. Why are we here?
Extramural funding for sponsored programs oftentimes comes with strings attached
Accepting federal funds means compliance with applicable cost principles (A-21, A-110)
Universities receiving sponsored research dollars should have appropriate systems, policies and procedures in place to properly document all commitments, including effort

28. Why are we here?
Effort Reporting has come under increasing scrutiny
Focus of Federal review and enforcement activity
Several multi-million dollar False Claims Act settlements
NSF/OIG audits (recent and ongoing)

29. Why is there so much emphasis on effort reporting?
Northwestern University – $5.5 million (2003)
“…knowingly or recklessly overstated salary rates for faculty…”
Johns Hopkins University - $2.6 million (2004)
East Carolina University - $2.4 million (2004)
Harvard University/Beth Israel Deaconess - $3.25 million (2000 & 2004)
University of Alabama-Birmingham - $3.0 million (2005)
University of Connecticut - $2.5 million (2006)
Florida International University - $11.5 million (2006)
Caltech - $11K (2007)

30. Why is there so much emphasis on effort reporting?
Areas of government focus in audits/investigations related to effort reporting:
Salary charges
Over-commitments
Salary cost transfers and cost sharing
Integration with systems that report time or effort
Roles and responsibilities
Who ensures appropriate salary is charged?
Who ensures level of commitment is reasonable?
Who signs the reports?
Who independently monitors to evaluate system’s effectiveness?

31. Okay, but we’re at UTSA.
For FY07-08, the university expended over $50 million provided by the public and private sectors to conduct research, public service, and training projects.
Approximately two-thirds of extramural funding supports salaries of faculty and staff engaged in these sponsored program activities.
Through effort reporting, the university assures sponsoring agencies that the salaries charged are reasonable

32. Am I alone in effort reporting?
No.

33. Am I alone in effort reporting?
Effort Reporting at UTSA is a SHARED responsibility.
Faculty Principal Investigators (PIs/PDs)
Departmental Administrative and Support Staff
Department Chairs & College Deans
Office of Sponsored Programs
Vice President for Research

34. Principles for determining whether effort is chargeable to a grant
There is some room for interpretation (check T&C, agency contacts, guidelines, etc.)
Sponsors fund projects based on proposed goals, objectives and methodologies
Auditors and IGs do not view their agency’s support as discretionary funds for PIs
Discretion to modify the approach that got you an award in the first place exists but is not unfettered

35. Principles for determining whether effort is chargeable to a grant
As the PI, you are responsible for the charges to your grants – this includes your effort and the effort of those devoting effort on your grant.
If you were interviewed by an auditor, consider how would you defend your decision to charge a particular researcher to a specific grant. 42

36. Principles for determining whether effort is chargeable to a grant
When in doubt, contact OSP.

37. What are we on the lookout for?
Minimum and maximum levels of effort commitments
Over-commitments
Administrative duties
Summer appointments
Contributed Effort (aka cost shared effort)

38. What is Cost Sharing?
Mandatory Cost Sharing: Required by the sponsor as a condition of obtaining the award. Mandatory cost sharing must be specified in the proposal; otherwise, the proposal will not receive consideration from the sponsoring agency.
Voluntary Committed Cost Sharing: Cost sharing that is not required by a sponsor, but is nevertheless pledged in the proposal or subsequent communication with the sponsor. This type of cost sharing is often used to reflect accurately the total resources necessary to complete a project.

39. What is Cost Sharing?
Voluntary Uncommitted Cost Sharing: Faculty- donated additional time above that agreed to as part of a sponsored agreement.
In-Kind Contributions: Non-cash contributions provided by the university or third parties.

40. What is Cost Sharing?
When an award is received in which mandatory or voluntary committed cost sharing was proposed, the cost sharing becomes a binding commitment which the university must identify, monitor, track and report as part of the performance of the sponsored project.

41. We certify effort and salaries?
No, effort certification is not a verification of the accuracy of the payroll system.
Should changes be made to the amount of committed effort associated with an activity during the effort certification process, a corresponding change to the payroll system will also need to be made.

42. How is effort related to salaries?
The salaries paid by UTSA to its employees working on Federal grants are generally charged or allocated to those grants on the basis of effort expended
For example, if 33.3% of an employee’s total effort is expended on a Federal grant, then up to 33.3% of the employee’s salary is chargeable to that grant
A certified effort report confirms that charges are reasonable in relation to the work performed

43. Why do we report effort?
OMB Circular A-21, Section J.10 (Compensation for Personal Services)
Effort reporting requirements
After-the-fact confirmation of personnel costs charged to sponsored agreements
The system must be incorporated into the official records of the institution
Certification which encompasses all employee activities on an integrated basis (i.e. 100% effort)
Certification by an individual with suitable means of verification that the work was performed
Independent internal evaluations to ensure the system’s effectiveness and compliance

44. How often do we report effort?
OMB Circular A-21, Section J.10 (Compensation for Personal Services)
Timing requirements
Annually (plan-confirmation system)
Each academic term (after-the-fact activity records - PIs and professional staff), or
Monthly (after-the-fact activity records - all other employees)

45. How do we report effort?
OMB Circular A-21, Section J.10 (Compensation for Personal Services)
Reliability and Reasonableness
“…it is recognized that research, service and administration are 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.”

46. Who certifies effort?
It is the responsibility of every Principal Investigator/Project Director to certify their own effort and the effort of all persons working on their sponsored programs, as they have the best firsthand knowledge of their sponsored programs.

47. Really. Who said so?
“Specifically, PIs have primary responsibility for all aspects of the sponsored projects including approval of all charges and ensuring that the research is conducted in accordance with the award terms and conditions.” (NSF Audit of Payroll Distribution System, Cal Tech, OIG )

48. Are there exceptions?
There are some exceptions made for practical reasons (e.g. perhaps the researcher is out of the country or is on temporary leave of absence).
Federal requirements are that anyone certifying effort for another individual must credibly have first hand knowledge of the individual’s actual effort.

49. Effort Non-compliance: The Dark Side
30/45/60
Escalating communications to ensure compliance and awareness of concern
Suspension of accounts
Jail

50. Current Effort Reporting: The PER
TERMINATED

51. Future Effort Reporting: ECRT
PER
ECRT
Method of distribution
Paper-based
Web-based
Frequency of distribution
Monthly
Semi-annually
Certifiers
PIs
Review period
n/a
Six months
Certification window
30 days

52. Education and information dissemination Framework Development
Challenges
Culture change
Time and effort – Policies and procedures
Effort Certification Practices
Education and information dissemination
Framework Development
Risk Assessments

53. Where can I get more information?

54. Questions?

55. Review