Time and Effort Reporting for Federal Grants

1. Time and Effort Reporting for Federal Grants Presentation for Private Investigators By: The Grant Accounting Office PI’s are required to verify that they have reviewed the tutorial by sending an email to Tanja F. Blackstone, tfblackstone@una.edu, stating that ‘Time and Effort training has been completed’.

2. What is Effort Certification? • Effort Certification is the formal reporting of employee activities. • It is required by federal regulations in order to test the reasonableness of award salaries.

3. Importance of Reporting • Labor reports are used to certify that the amount of labor expended on a federal grant corresponds to the salary allocated to the project. • The expectation is for the salary charged to the grant to not be greater than the percentage of effort expended. • Federal agencies are accountable to Congress for appropriate usage of their funds. • Therefore, recipients of federal awards must be transparent in the activities associated with their grant.

4. Governmental Regulation • OMB Circular A-21 (Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions) states… • “that, in an academic setting, teaching, research, service, and administration are often 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…”

5. General Assumptions • Documentation must... • Appropriately reflect compensation that an individual receives from UNA’s payroll system • Ensure that salary charges reasonably match actual effort • Verification must… • Be performed by the individual who is paid by the grant • UNA has the PI verify the report, as well. • Include proof of performance • UNA requests that a Progress Report justifying the level of effort is attached to the report.

6. Risks of Noncompliance • UNA is expected to meet federal guidelines for Effort Certification. • In recent years, the federal government and its auditors have become active in reviewing effort reports. A number of universities have received large fines for noncompliance.

7. Fines for Noncompliance • University of Alabama – Birmingham • $3.4 Million • Northwestern University • $5.5 Million • John Hopkins University • $2.6 Million • Florida International University • $11.5 Million • Cornell University • $4.4 Million • Harvard University • $2.4 Million

8. Definition of Effort • Effort = the percentage of time spent on any activity expressed as a percentage of total time fulfilling the assigned university responsibilities • 100% Effort = total time estimated for UNA activities (activities compensated through the UNA payroll system)

9. Definition of Effort • Includes… • Teaching • Administration • Research • Other university activities • Doesn’t Include… • Private consulting to outside parties • Incidental, one-time payments in excess of base salary

10. Effort Example Percentage of Effort Calculation: % of Effort for a Federally Sponsored Project = Amount Paid by Project during Period Divided by Total Amount Paid from All Sources During the Period Total Effort Must Equal 100%!

11. Federally Sponsored Activities • Includes effort devoted to grants, contracts, and cooperative agreements sponsored by the federal government for the purposes of training, public service, or research • OMB Circular A-21 states, “…Charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences, but not writing new funding applications…”

12. Non-Federally Sponsored Activities • Includes… • Classroom Instruction • Curriculum Development • Departmental Administration • Other Non-Federally Sponsored Effort • State or Local Grants • Proposal preparation time is included in this category of effort.

13. Timeline

14. Certificate

15. Progress Report

16. Due Dates for Private Investigators • On the 15th day of the month following the quarter, PI will receive the reports. • During the next two weeks, the PI will have time to get the employees to certify the reports and to prepare Progress Reports. The PI will also need to review and to co-sign the report. • The reports are due in two weeks in the Grant Accounting Office. • Example: • Quarter Period = January to March • April 15th = Receive Effort Certification Report • Due with in two weeks

17. Labor Redistributions • If any changes need to occur, these will be handled by the Grant Accounting Office and the Payroll Department. • Redistributions will be determined on a case-by-case basis. • A new report will be created for certification purposes.

18. Contact Information • Grant Accounting Office: Anita Holcombe Accountant II, Grants 126 Bibb Graves Hall Florence, AL 35632 256-765-4273 agholcombe@una.edu • Sponsored Research Department: Dr. Tanja Blackstone Director, Spon. Research 208 Bibb Graves Hall Florence, AL 35632 256-765-4523 tfblackstone@una.edu