Current Issues in Effort Reporting: Problems and Potential Solutions

1. Current Issues in Effort Reporting:Problems and Potential Solutions David Kennedy Director of Costing Policies and Studies Council on Governmental Relations (COGR) NCURA 49th Annual Meeting Washington Hilton, Washington DC Monday, November 5, 2007

2. 2 COGR Council on Governmental Relations 1948 Staff of 5 Costing, Compliance, Intellectual Property Active Board and Committees 170+ member institutions www.cogr.edu

3. 3 COGR in Action Close, working relationship with Federal representatives from OMB, NIH, NSF, DCA, ONR, and other applicable agencies to facilitate federal rules and regulations, and to advocate for and represent the research and university community with a single voice. v Federal Register, Comment Letters v Publications, Surveys v Newsletters, Updates, Position Papers v Membership Meetings, 3 per year v Other, as needed

4. 4 COGR Partners Association of American Universities (AAU) Association of American Medical Colleges (AAMC) National Assoc. of State Universities and Land-Grant Colleges (NASULGC) SECA, MECA, WECA, NECA NCURA, FDP, NACUBO, etc.

5. 5 Staying Informed HHS and NSF IG web sites http://www.oig.hhs.gov/ http://www.nsf.gov/oig/ HHS FY2008 Workplan (October 2007) NSF Semi-annual Report to Congress (soon) COGR Updates / Meetings Other Association Meetings (NCURA) COGR Effort Paper (March 2007)

6. 6 COGR Effort Paper Official title: �Compensation, Commitments, Certification� 19 Chapters describing federal policies and institutional practices; �Policy and Practice Suggestions� at end of chapters. Engage federal officials? � restore balance between accounting oversight and regulatory flexibility necessary for good science.

7. 7 COGR Effort Paper Regulatory Background and Historical Context Effort Reporting Basics, with Roles and Responsibilities Appendices: Circular A-21, J10 and January 5, 2001 OMB Clarification Memo

8. 8 The �meat� 1. Compensation What�s �in�, What�s �out� v Consulting, VA, Clinical Practice Plan, etc. v Standard work week? v Supplemental Compensation, case-by-case? v Base rate of pay v Volunteer activity? v Propose, Charge, Effort report = consistency Define and Apply Institutional Policies that treat Sponsored and Non-sponsored activity in a Consistent manner.

9. 9 The �meat� 2. Commitments The Grant Proposal = The Commitment v Voluntary Committed, Mandatory Cost Sharing v Zero Commitment (January 5, 2001 Memo) v Voluntary Uncommitted Cost Sharing (out!) v Other Support Pages v Significant Changes, how to monitor? v Effort reporting time period (e.g., semester) v Overcommitment; pending proposals, number of awards v No Cost Extensions; commitment continuation v K Award nuances

10. 10 The �meat� 2. Certification Confirmation of Salary Charges (based on an initial estimate) should be simple, but � v Individuals paid 100% on sponsored funds v Individuals paid on NSF summer salary v Precision (e.g., �is this reasonable within 5%�?) v Post-certification changes/transfers; not good v Education; is it do-able??? � (Spirit of A-21) Certification (confirmation of salary) has been married to Commitments (cost sharing), though not defined in A-21, A-110, etc.

11. 11 The �meat� 3. Technical Fundamental Requirements, for the most part, which are defined in A-21: v J10b(2), Criteria (e.g., after-the fact) v The three examples v Responsible persons, suitable means of verif. v Frequency (6 mos., semester, etc) -- Timing? v Independent Internal Evaluation One �after-the-fact� lesson � if you define �gold standard� policies, make sure you can implement them!

12. 12 Contact Info David Kennedy dkennedy@cogr.edu 202-289-6655, ext. 12