FECs, Sal Cap, & Impact of RSTs

1. FECs, Sal Cap, & Impact of RSTs Presented by Susan Graham 10/2009

2. Introduction • Faculty Effort Reporting • BNHS FEC Coordinator • Staff Role

3. Objectives • Understand what the FEC is • Understand relationship between FEC, Cost Sharing, Salary Cap, and RSTs or SETs • Understand staff responsibilities in FEC process

4. FEC • FEC – Faculty Effort Certification • FEC is required reporting • Faculty effort reporting is required of all agencies receiving federal grant funds • BNHS has a lot of faculty receiving grant funds • No one really understands it – including faculty • We must do it and it’s an audit flag when it’s late or has lots of revisions

5. FEC (cont.) • Automatically generated for all faculty paid on grant funds • Comes out quarterly • Reporting is for previous quarter and shows salary amounts and effort averaged over a 3-month period • May differ by quarter • Faculty are responsible for their own FEC

6. FEC • Sample FEC – typical • Section 1 shows pay on grants and contracts • Section 4 show cost sharing effort (if any)

7. Cost Sharing • What IS Cost Sharing? “Cost Sharing” on a grant is the portion of project or program cost not borne by the sponsor. It is the University's share of the cost of research. We have very few faculty who do cost sharing.

8. Cost Sharing (cont.) • Types of Cost Sharing • Mandatory (M): Cost sharing that the sponsor (typically a federal sponsor) requires as a condition of the award. • Committed (R): Cost sharing that the PI promises in the project proposal budget or the budget justification that is not required by the sponsor. • If cost sharing is NOT required by the funding agency, UW really discourages voluntary (committed) cost sharing

9. Cost Sharing (cont.) • Salary Cap (C): Cost sharing required of faculty who exceed specific limits established by the NIH salary cap. Salary Cap cost sharing is required by: • National Institute of Health (NIH) • Substance Abuse and Mental Health Services Administration (SAMHSA) • Agency for Healthcare Research and Quality (AHRQ)

10. Cost Sharing (cont.) With Salary Cap cost sharing: • The restriction on salary limits the amount that can be awarded and charged to some grants and contracts. • Faculty’s actual institutional base salary may exceed the salary cap, BUT individuals with salaries over the cap must provide cost sharing from non-federal funds for that portion of their salary over the salary cap.

11. Cost Sharing (cont.) • If there is ANY faculty effort cost sharing commitment on a grant, the way that commitment is documented is through the FEC

12. Cost Sharing (cont.) • If the grant you monitor has faculty effort cost sharing and faculty do not report this cost sharing on their FEC, YOU will be unable to close a grant or get carry forward funds, until cost sharing issues are resolved • This will be a nightmare

13. FEC • Sample FEC - Big Problem • Note changes in salary • Note changes in cost sharing • Note the comment “See Expense Transfer Attached”

14. Salary Transfers • FEC is affected by Salary Transfers (RSTs or SETs) • Every time an RST is processed, a modification of previously signed FECs is required • Revised FECs are an audit flag • Staff responsibilities • Notify Susan Graham when any Salary Expense Transfer is processed retroactively for any faculty funded on any grant • Remind faculty member they will need to submit a REVISED FEC when retroactive salary is transferred onto or off of ANY grant budget

15. Salary Transfers (Cont.) • Considerations when processing Salary Expense Transfers: • Provide and save appropriate documentation • Audits will look for adequacy of justification • Audits will look for the reason why the expenditure was charged to the original budget • Are the expenses appropriate? • Depts. need to provide evidence to justify costs

16. Salary Transfers (Cont.) • Notify FEC Coordinator (me) and faculty member ASAP because • FEC Coordinator is not always aware of retroactive salary events that will affect the FEC, and faculty members don’t always remember salary transfers have been processed when they’re reviewing the FEC from 3 months ago • FEC’s should be processed within 90 days of original transaction • Auditors will look for reasons why processing FEC’s are greater than 120 days • Provide copies of SETs to Susan Graham

17. Staff Responsibilities • When a New Grant is Funded • Check to see if there is Cost Sharing in proposal • Make sure that cost sharing is entered into budget driver • Use IBS calculator tools to determine correct OPUS entry for all faculty on grant • Check to see if anyone on the grant is affected by Salary Cap restrictions

18. Staff Responsibilities (cont.) • On-going during grant period • Notify Susan Graham when any Salary Expense Transfer is processed retroactively for any faculty funded on any grant • Remind faculty member they will need to submit a REVISED FEC when retroactive salary is transferred onto or off of ANY grant budget • If your grant has COST SHARING, help PI to periodically review Faculty Effort Certification System (eFECs) to check that all cost share contributions are captured correctly & ensure that cost sharing obligations are met in a timely manner

19. Staff Responsibilities (cont.) https://ucs.admin.washington.edu/efecs/UWNetID/CostShare/Default.aspx

20. Wrap-up • FEC is Faculty responsibility BUT • Routine salary transfers affect the FEC and may require revision of PAST FECs • Too many salary transfers and/or revised FECs are an audit flag • Please let Susan Graham know when you process salary transfers onto or off of grant funds

21. Wrap-up • Nobody really understands FECs anyway, but don’t you like a real challenge now and then? • Questions?

22. Resources • Contacts in BNHS • Determining IBS: Matt Eng • Cost Sharing: Susan Graham • FEC: Susan Graham • Other UW Contacts • Cost Sharing: GCA Team 4 • FEC: Suzette Ashby-Larrabee; 206 685-7395 suzette@u.washington.edu

23. Resources (cont.) • Cost Sharing • GIM 21 http://www.washington.edu/research/osp/gim/gim21.html • Federal Salary Cap Limits http://grants.nih.gov/grants/policy/salcap_summary.htm

24. Resources (cont.) • FEC • http://f2.washington.edu/fm/maa/fec • GIM 35 – Effort Reporting Policy • http://www.washington.edu/research/osp/gim/gim35.html • Salary Calculator Tools for IBS, Salary Cap, and Cost-Sharing http://f2.washington.edu/fm/maa/fec/fectools

25. Resources (cont.) • Faculty Grants Management Workshop“Effort Certification Education” https://courses.washington.edu/fecnon/lesson3/index.html • Institutional Base Salary (IBS) http://f2.washington.edu/fm/maa/fec/faculty-effort

26. FECs, Sal Cap, & Impact of RSTs THE END

27. IBS • Institutional Base Salary (IBS) is: All regular salary paid by the UW including: • A/B • summer salary • paid professional leave • salary for retired faculty • administrative supplements (ADS) • endowed supplements (ENS)

28. IBS (cont.) • IBS does NOT include: • Salary from external appointments • VA • CHRMC • FHCRC • Outside Professional Work • Consulting • Excess Compensation (E/C) • Temporary Supplement (TPS) • Other sources we don’t see often

29. IBS (cont.) • Why do I care? • Developing grant proposal • If a grant is funded – determining payroll/OPUS amounts • If helping faculty prepare FECs