1. Effort Reporting – A Faculty Perspective Jeremy Forsberg, University of Texas at Arlington David Ngo, University of Wisconsin - Madison

3. Communication takes two - Perspective and Understanding Faculty perspective on effort reporting Understanding the intent of the requirements for effort reporting and what should be communicated to faculty Convergence of reality, intent, and regulatory compliance

4. Faculty Perspective on Effort Reporting

5. Faculty/Institutional Responsibilities Their Job Description: Research, Teaching, and Service Commonly split: 40% Research 40% Teaching 20% Service Faculty annual reviews are based on these expectations 5

6. Research Activities: Sponsored Projects Unfunded Projects Scholarly activities Human subject Research Animal subject Research Publications Discoveries Grant Writing (sometimes considered “research”) 6

7. Instructional Activities: Courses taught Includes preparation time and meetings outside of class Service Activities: Advising activities Board Service / serving on committees Administrative appointments (Chair/Dean etc.) Paid consulting 7

8. Faculty Survey for Time Allocation Barry Bozeman, Georgia Tech, Albert Link, UNC Greensboro, and Christopher Swann, UNC Greensboro’s paper “A Time Allocation Study of University Faculty” consisted of a survey of 150 Research Intensive Universities with 1,403 faculty respondents. The results of the percent of time faculty spent on institutional responsibilities were: Teaching 32% Research 36% Grant Writing 8% Service 24% 8

9. Faculty – Outside Activities or Activities not recorded for Effort Reporting Purposes Allotted 1 day a week for outside consulting activities Supplemental Pay Travel Reimbursements Fringe Payments for Outside Board Service 9

10. Faculty – Adding it up Faculty activities are often intermingled (research, teaching, service) Research activities are much broader than the time spent on projects that are funded or committed to Much of their time on sponsored projects may be (in their minds) voluntary uncommitted cost sharing (compare this to committed effort – just didn’t receive “pay” for the time contributed) The number of hours worked towards faculty activities still comprise of 100% effort. 10

11. Effort is based on percentages of time towards a sponsored project relative to a faculty member’s total activities (of their IBS) For example, faculty member X works 80 hours a week and faculty member Y works 40 hours a week. They both are committed to the same project and have the same IBS - $100k). The amount the sponsor pays faculty member Y can be higher than faculty member X for less hours worked towards the project! Faculty member X expends 15% effort/$15k for 12 hrpw Faculty member Y expends 20% effort /$20k for 8 hrpw 11

12. 12 The Haywire of Effort Reporting It’s busy work Lots of unfunded work on projects and voluntary uncommitted cost sharing Questions integrity to a very subjective compliance requirement Faculty with research funding often work more hours than their colleagues Do not get paid extra

13. Example Calculations of Effort Sponsors may require or faculty may propose salary in three common ways: # of months, % effort, and $. – If Professor Ty Webb has a 9 month academic year salary of $90,000, what is his 12 month salary? – If Professor Webb commits 1.3 months of salary, what is the total salary requested? – What is the % effort? 13

14. Considerations of new activities: The addition of a grant may affect effort on other grants. Example: If Professor Bridgett Jones currently has a NSF grant paying 15% of her time and a NIH grant for 25%, what affect could a new private grant have where on her total effort on sponsored projects if she is paid another 20% time? If Bridgett continues to work a total 40 hours per week on average after receiving the new grant, what adjustments need to be made? 14

15. Ineffective Communication

16. Understanding the Intent of Effort Reporting

17. The basic idea In a grant proposal, we offer effort At award time, we make a commitment of effort Throughout the project, we charge salary to the sponsor Periodically, sponsors want to know: – Have we devoted enough effort to justify the salary charges? – Even in cases where we are not charging salary to the sponsor, have we fulfilled our commitments?

18. Commitments Paid Effort Cost-Shared Effort Non-Payroll Cost Sharing Effort Not Paid By Sponsor Non-Effort Paid by Sponsor

19. What is Effort Certification? Effort certification (or effort reporting) is the means of assuring sponsors that: – Salary charges are justified (or “they got what they paid for”) – Researchers devoted the effort that was promised in the proposal and agreed upon at the time of the award (or “they paid for that they got”) This is not “timekeeping” or “activity tracking” – Researchers are not required to report how they spent their time

20. Who says we have to do this and who has to do this? Certification is required for individuals who have paid or committed effort on sponsored projects Effort must be certified by a person who has “suitable means of verifying” that the work was performed – Faculty, academic staff, and all PIs certify their own effort – PIs certify for graduate students, postdocs, and non-PI classified staff who work on their projects 20

21. It’s Not an Exact Science Precision is not required Sponsors recognize that research, teaching, service, and administration are often inextricably intermingled Reasonable estimates are expected – But there are some rules to follow! 21

22. The Rules Require us to: Be careful about what we offer in a proposal Be careful when making commitments at award time Change commitments when needed, and document the changes Fulfill commitments Charge salary in a way that’s congruent with actual effort Certify effort in a way that’s congruent with what actually happened 22

23. The Rules Also Require us to: Not charge a grant for time that doesn’t pertain to the grant Not charge a grant for time spent writing a proposal for a new project or a competing continuation – Time spent on these activities must be covered by institutional or gift funds Transfer salary charges off of a grant if the level of effort does not justify the salary charges 23

24. 24 PROPOSAL: Commitments are Offered AWARD: Commitments Become Obligations Commitment Setup Documentation & Reporting of Fulfillment Commitments are Fulfilled Tracking and Management Lifecycle of a Grant

25. We Do Want to Get this Right The consequences of not getting this right can be dire for the university Effort reporting is the #1 target for federal auditors Many universities have paid millions of dollars in fines Audits are underway at many research institutions Problematic areas: SCT’s and Recerts 25

26. Recent Effort Reporting Audits & Settlements Effort Reporting Non-Compliance: Significant Audits & Settlements University of Michigan Effort Certification Arizona State University Effort Reporting System St. Louis University Overstatement of Effort $1 million University of Notre Dame Subrecipient monitoring and Effort Reporting University of Nevada-Reno Effort Reporting System Weill Cornell Medical College Committed Effort $2.6 million University of Wisconsin – Madison Effort Reporting System Georgia Institute of Technology Effort Reporting System Yale University Effort Reporting and Cost Transfers $7.6 million 26 University of Alaska-Anchorage Effort Reporting and Grants Management University of Delaware Effort Reporting Louisiana Board of Regents Effort Reporting, Cost Sharing $1.9 million questioned costs Ohio State University Commitments and Cost Sharing $1.7 million in questioned costs California State University - Fresno Effort Reporting Commitments and Cost Sharing Fort Valley State Lack of an Effort Reporting System $500,000 settlement Florida State University Salary/Non-salary disallowances $3.0 million in requested refund

27. 27 Institution/DateSUNY Stony Brook Aug-12 Florida State July -12 Univ Notre Dame Mar-12 Univ Alaska- Anchorage Aug-11 CSU – Fresno Mar- 11 Univ Delawar e Mar-10 Wash U Feb- 10 Fort Valley State Jan-10 U Nevada- Reno Jan-10 UW Madison Nov-09 Univ Michiga n Aug-09 ASU Aug-09 Suitable means of verification XXX Inappropriate charges, cost transfers XXXX Lack of salary documentation XXXXX Internal control weaknesses XXXXXXX Effort reporting training, policies XXXXXXXX Certification doesn’t include all activities XXXX Salary above NSF cap XXX No independent internal evaluation of system XXXXXXX Late certifications XXX Effort reporting system weaknesses XXXX

28. Effective Means of Communication – Policy considerations – Mechanisms for compliance – Education and Training programs Perspective and Understanding – One on One with Faculty – Department Chair Meetings – The broader university systems

29. Questions? Contact Info – Jeremy Forsberg j.forsberg@uta.eduj.forsberg@uta.edu – David Ngo dvngo@rsp.wisc.edudvngo@rsp.wisc.edu