Effort Reporting – A Faculty Perspective

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

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

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

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%

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

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.

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

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?

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?

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 Effort Non-Effort PaidEffort Cost-Shared Effort Non-Payroll Cost Sharing Paid by Sponsor Not 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

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!

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

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

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

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

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

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.edu • David Ngo dvngo@rsp.wisc.edu