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Managing Effort Through the Eyes of Your Collaborators. Joe Gindhart – Washington University & Lillie Ryans-Culclager – SRI International. Why is effort reporting a big deal?. Grantees agree to comply with Federal Principles, OMB Circulars A-122 & A-110.
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Managing Effort Through the Eyes of Your Collaborators Joe Gindhart – Washington University & Lillie Ryans-Culclager – SRI International
Why is effort reporting a big deal? Grantees agree to comply with Federal Principles, OMB Circulars A-122 & A-110. A-122 requires payroll costs to be documented to ensure that external sponsors reimburse the grantee only for the time and effort actually expended on their behalf. Salary costs are the majority of costs incurred on a grant.
What is effort reporting? • An individual certifies that salaries charged to sponsored projects are reasonable in relation to the work performed. • Actual salary dollars are presented as percentage figures (of total salary) on a report or time-sheet.
A-122 Requirements • Salary distribution to awards supported by “activity/effort” report. • Must reflect after-the-fact determination of actual activity of employee. • Account for total activity of employee • Signed by employee or responsible official • Prepared at least monthly
Staff Effort: Exempt Type • Total activity for which a staff member is compensated by the entity via a salary. • Regardless of the number of hours actually worked (100% Institutional Effort). • Effort varies from individual to individual • Includes all entity activity • Not just Monday through Friday • Not just X days a week
Staff Effort: Non -Exempt Type • Total activity for which a staff member compensated by the entity via a wage(s). • Based upon actual hours worked/paid • Includes regular hours and overtime hours
Effort Reporting Cycle Pre-award Post-award Preparing the Proposal Budget Appointing Staff Charging Salary Certifying Effort • Effort is charged, contemporaneously with activity • Effort is proposed, a commitment is made to the sponsor • Effort is attested to, after activity has occurred • Employment terms are established,including # months (contract period), % full time, salary base
The Effort Reporting Process • Proper “Effort Reporting” encompasses much more than certification, and includes: • Definitions, policies, procedures, forms, data and systems • Effort reporting includes management of: • Faculty and staff appointments • Pledging and tracking of institutional effort commitments • Payroll distribution • Effort certification • Communication and training on all aspects of system • Enforcement of policy
Key Policy Issues • Who certifies for whom? • What is 100% effort? • What constitutes timely certification? • Level of tolerance • De minimiseffort
Key Policy Issues, cont. • Cost sharing • How will you handle training on effort reporting? Is it voluntary or mandatory? • Setting consequences for failure to comply with effort reporting policies and practices
Facilitating Compliance • Realistic due date (30, 45, 60 days) • Provide %s and $s • Proxy certifications • Comment box and attachments • Department and central contacts
Areas of Concern • No effort reports • Salaries not distributed to specific awards/accounts, within payroll system • Employees paid from grant but not working on project • Salary transfers and/or adjustments
Areas of Concern, cont. • Employees not aware that they are working on grant funded projects • Inconsistent rates of pay • Cost sharing not documented • Cash flow constraints • Expenditure reporting vs. project progress
Timesheets - Example • Payroll time sheets signed by the employee and a responsible supervisor, manager or director having first-hand knowledge of the work performed. These time sheets contain: • Hours the employee works • Distribution of employee’s salary over the different funding sources (in percent effort) • Name and signature of employee’s supervisor • Employee’s signature
Contact Info • Lillie Ryans-Culclager – SRI Int’l • (650) 859-2651 • lillie.ryans-culclager@sri.com • Joe Gindhart – Washington University • 314-935-7089 • jgindhart@wustl.edu