Attachment B Training Materials about Effort Page 1 of 13 This is a topic of intense federal scrutiny. Auditors sometimes visit with individual faculty members to discuss effort reporting and we do not want you to be in the uncomfortable position of not knowing the most essential facts about how to do it right. We are obligated by federal regulations to certify effort. We are in this together – auditors fault institutional Sponsor audits are becoming increasingly common. systems and individual certifications. Penalties can be substantial. Erroneously certifying effort (accidentally or with Even the most reputable institution is at risk. intent) ◦ Can be viewed as fraud ◦ May lead to an institutional audit by a Federal sponsor ◦ May lead to an institutional audit by a Federal sponsor ◦ Often results in significant penalties North Northweste tern Un Univer ersi sity ty NOT based on a 40-hour work week ◦ $5.5 million (2003) The 40-hour work week as the basis of % Johns H Johns Hopkins ins Un Universit sity calculations is the most serious and most common ◦ $2.6 million (2004) misconception. East Ca st Carolin rolina a Un Universi sity ty Based on 100% of activities for which you are ◦ $2 4 million (2004) $2.4 million (2004) compensated by Agnes Scott College including: Harv Harvard / / Bet Beth Is Israe rael Deaco Deaconess ss Medi Medical Cent Center Spon Sponsore red project act project activities ◦ $3.25 million (2000 & 2004) Non-spo Non-sponso sored a d activ tiviti ties Unive Universit sity of of Conne Connect ctic icut Administration (including duties as chair, dean, etc.) ◦ $2.5 million (2006) Dartm Dartmouth Instruction (teaching, advising) ◦ $37,780 (2005) Research (excluding externally funded research) Expressed in percentages 1
Attachment B Training Materials about Effort Page 2 of 13 Academic Year Pizza Crust ◦ “worth” your IBS 100% is 100% ◦ “weighs” your job description There are no nights and weekends Exempt employees (faculty and staff) are not paid by the hour — they are paid to accomplish their job Spo Sponsor sored project activities include: Non-sp n-sponso onsored red activities include: Effort on federal grants or contracts* Teaching (e.g. , NIH, NSF, NASA – including federal funds that have flowed to ASC Advising from other institutions) Research funded by ASC Effort on non-federal research projects* ◦ (i.e., research you do as part of your regular workload for ASC) (e g (e.g. , a foundation grant) a foundation grant) Department Chair duties Administrative effort related to a sponsored project* Attending general departmental faculty meetings ◦ Writing progress reports ◦ Holding a meeting with staff Serving on College committees ◦ Presenting research results at a scientific conference Proposal preparation ◦ Reading scientific journals to keep up to date with the latest advances in the project topic area. * Even if your effort is not completely paid by the sponsor (i.e., salary cost sharing) External professional activities paid through an agreement outside your Agnes Scott college OMB Circular A21 J 10 b(1)(c) workload (e.g., consulting engagements, incidental ◦ “In the use of any methods for apportioning salaries, it is work for ASC that is over and above your workload) recognized that, in an academic setting, teaching, research, service and administration are often inextricably intermingled. intermingled ” Serving on an NIH Study Section or NSF Peer Review ◦ “A precise assessment of factors that contribute to costs is Panel not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is If you have any questions about whether an activity is or appropriate.” is not part of the effort considered in the 100% i % institu stitutiona nal b l base s salary lary, The degree of tolerance at Agnes Scott College is +/- 5% check with the Office of Sponsored Programs. 2
Attachment B Training Materials about Effort Page 3 of 13 Each employee reviews and signs her/his own effort certification form. Salary and wages charged to sponsored projects should reasonably reflect the proportionate share Exceptions are sometimes necessary (e.g., the of time spent on the project researcher is out of the country or is on temporary leave of absence) leave of absence). Contact Sponsored Programs to Contact Sponsored Programs to Cost share commitments must be included in the determine if an exception is necessary. effort distribution Federal requirements stipulate that anyone certifying effort for another individual must credibly Salary payments cannot be made for effort not have first hand knowledge of that individual’s applied to the project actual effort. It depends on your classification: Individual inserts percentages of actual effort and verifies the report as a re reasonab onable e le esti timate o mate of For 9-month faculty employees, effort report is actual effort actua effort worked by signing the report preprinted with promised effort distribution ◦ Each academic term and each half of summer A variety of resources may be relied upon to jog For 12-month exempt employees (even those who one s memory and document effort allocations: one’s memory and document effort allocations: hold faculty rank), effort report is preprinted with ◦ Calendars promised effort distribution Journals, logs, and blogs ◦ ◦ Every six months Teaching schedules ◦ Non-exempt employees (those paid by the hour) ◦ Leave reports certify their effort when they submit their time Correspondence ◦ sheets (they certify their time) Outside activity forms ◦ ◦ Each pay period Late effort reports Difference between ◦ potential effort Effort certified by someone lacking first-hand ◦ actual effort knowledge of the individual’s actual effort Limits on amount allowed Percentage outside of sponsored project is insufficient to credibly cover teaching insufficient to credibly cover teaching, administrative, or other College work Multiple post-certification revisions Significant data inconsistency between effort report and other documentation such as: Calendar Leave reports Other support forms Outside activity forms 3
Attachment B Training Materials about Effort Page 4 of 13 Effort reporting is under scrutiny by the Office of ◦ Pamela Napier ◦ Emily Kandetzki Inspector General at NIH, NSF, and other agencies. ◦ Buttrick 207 ◦ Buttrick 109 Each individual is responsible for certifying his or her own effort. ◦ 404-471-6951 ◦ 404-471-6952 The effort % is NOT based on a 40-hour work week. It is based on the individual’s actual amount. ◦ osp@agnesscott.edu @ d Effort reporting tracks the re reas asonable able appro pproximation imation of actual activ actual activity on projects. *It should not *It should not simply simply mimic mimic budgete budgeted amoun amounts. Effort reporting is our means of providing assurance to sponsors that faculty and staff have met their commitments, paid or unpaid, to extramural projects. For our effort reporting system to have integrity and pass audit, • The College’s procedure needs to be based on the federal accounting principles for effort and d • Individual effort certification needs to follow the basic guidelines published by the Office of Sponsored Programs We want to assist you in any way we can 4
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