Fundamentals of Time & Effort Certification Reporting

1. Fundamentals of Time & Effort Certification Reporting Western Illinois University Office of Sponsored Projects

2. What is Effort Certification? • Effort certification provides assurance to sponsors that faculty and staff have met their commitments, paid or unpaid, to externally-funded projects • It’s required by federal regulation and University policy for all individuals working on sponsored projects

3. Why is Time & Effort Reporting Important? • Signed effort reports are considered legal documents in which an individual attests to the accuracy of the effort spent on sponsored projects • Erroneously certifying effort reports can be viewed as fraud • Sanctions can apply to both the institution and the individual • We are obliged by federal regulations to exercise good stewardship of those funds 1.) Effort is a part of that stewardship 2.) Personnel costs are the majority of research costs

4. Effort Certification Actually Begins at the Proposal Stage:

5. What Exactly is “Effort”? Definition: “Effort is the percentage of time spent towards particular Work-Related Activities, such as sponsored projects, instruction, proposal preparation, or other administrative duties. “

6. What “Effort” isn’t… Don’t confuse effort reporting with Payroll distributions as they are not the same thing! Payroll distributions are the distribution of an individual's salary, while effort reports describe the allocation of an individual's actual time and effort spent for specific projects, whether or not reimbursed by the sponsor. Effort reporting is separate from, and can be independent of, salary charges.

7. Time & Effort Reporting is… • is a way for an employee to certify that: 1.) Effort supported (paid) by a federally sponsored project has been performed as promised. 2.) Effort expended in support of a federally sponsored project but not paid by the project has been performed as promised • is required by federal regulation for all individuals working on federally funded sponsored projects • makes salary sources for the period congruent with effort spent for the period

8. How is Effort Determined? Effort is NOT based on your regular work week. It is calculated as a percentage based on the total hours spent on work-related duties. For example, if a person averages 60 hours per week during a reporting period and spends an average of 15 hours on a Sponsored Project, that person has spent 25% effort on the sponsored project and 75% effort on other activities.

9. How is Effort Determined? Effort is based on 100% of the activities for which you are compensated by the WIU • These activities are divided into: • Sponsored project activities • Non-sponsored activities

10. Sponsored Activities: • This is your effort on: • Federal grants or contracts (e.g. NIH, NSF, USDE, DOE) • Non-federal projects (e.g. a state grant or industry-sponsored project) • Activities you can allocate to a sponsored project include: • Writing progress reports; holding a meeting with individuals working on the sponsored project; presenting results at a conference; reading journals to keep up to date with the latest advances in the project topic area • ... even if your salary is not completely paid by the sponsor (i.e. salary cost sharing)

11. Non-Sponsored Activities: • Teaching • Serving as a department chair, and other administrative duties • Serving on university committees • Attending general departmental faculty meetings • Public service and outreach

12. 100% Effort = Teaching…

13. 100% Effort = + Teaching… Reading journals to keep up-to-date on research topic…

14. 100% Effort = + Teaching… Reading journals to keep up-to-date on research topic… Meeting with people working on your grant…

15. 100% Effort = + Teaching… Reading journals to keep up-to-date on research topic… + Conducting research for your grant… Meeting with people working on your grant…

16. Remember…Effort Always Equals 100%

17. Who Certifies the Time & Effort Certification Report? • An individual’s effort is usually certified by the Project Director. • There are some exceptions that are made for practical reasons. For example, the Project Director may designate another employee to review and certify the forms if they have a better knowledge of the actual day-to-day work that was performed by the individuals on the project.

18. How to Certify The Project Director (or the designated certifier) must verify that the time & effort certification report shows a reasonable estimate of the actual effort expended on each project/source. Documentation that may be helpful in verifying effort could include: • teaching schedules • outside activity forms • time sheets • leave reports • calendars • correspondence

19. How to Certify (continued) • If the percentages for the specified account accurately reflect the actual work performed during the specified time period by the individuals listed: • Sign and date the certification report before returning to OSP • If the percentages for the specified account do not accurately reflect the actual work performed during the specified time period by the individuals listed: • Do not sign the form and notify OSP immediately

20. Pay Sources Should Reasonably Reflect Activity • OMB Circular A-21 J10b(1)(c)says: • “In the use of any methods for apportioning salaries, it is recognized 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.”

21. In other words… The distribution of effort should represent a reasonable estimation of the actual effort expended during the term being certified. The deviation that is considered acceptable at WIU is + or – 10%.

22. Let’s take a look at a sample of the time and effort certification report…

23. JAMES SMITH Psychology Department Waggoner Hall 100 5/10/10 WESTERN ILLINOIS UNIVERSITY TIME AND EFFORT CERTIFICATION REPORT FOR 522220 TV VIEWING SURVEY TIME PERIOD 01/01/10 – 04/30/10 I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED BY THESE INDIVIDUALS. SIGNED: ________________________________________ DATE: _________________________

24. JAMES SMITH Psychology Department Waggoner Hall 100 5/10/10 WESTERN ILLINOIS UNIVERSITY TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY TIME PERIOD 01/01/10 – 04/30/10 I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED BY THESE INDIVIDUALS. SIGNED: ________________________________________ DATE: _________________________

25. JAMES SMITH Psychology Department Waggoner Hall 100 5/10/10 WESTERN ILLINOIS UNIVERSITY TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY TIME PERIOD 01/01/10 – 04/30/10 This could be supplemental pay from the grant or it could be a portion of his regular salary that is being paid from the grant funds. I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED BY THESE INDIVIDUALS. SIGNED: ________________________________________ DATE: _________________________

26. JAMES SMITH Psychology Department Waggoner Hall 100 5/10/10 WESTERN ILLINOIS UNIVERSITY TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY TIME PERIOD 01/01/10 – 04/30/10 I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED BY THESE INDIVIDUALS. SIGNED: ________________________________________ DATE: _________________________

27. JAMES SMITH Psychology Department Waggoner Hall 100 5/10/10 WESTERN ILLINOIS UNIVERSITY TIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY TIME PERIOD 01/01/10 – 04/30/10 A portion of her regular salary is being used as match for a second grant (5-33330) that she is working on in addition to 5-22220. I CERTIFY THAT THE TIME AND EFFORT PERCENTAGES FOR THE INDIVIDUALS LISTED ABOVE FOR ACCOUNT 522220 ACCURATELY REFLECT THE ACTUAL WORK PERFORMED BY THESE INDIVIDUALS. SIGNED: ________________________________________ DATE: _________________________

28. Issues that raise red flags with auditors… Late effort certification Effort certified by someone without suitable means of verification A distribution of effort that leaves too little non-sponsored time to credibly cover teaching, administrative, or other university duties Post-certification revisions

29. Examples of Audits and Fines Assessed on Institutions • Northwestern University – $5.5 million (2003) • Johns Hopkins University (for one investigator) – $2.6 million (2004) • East Carolina University – $2.4 million (2004) • Harvard University/Beth Israel Deaconess Medical Center – $3.25 million (2000 & 2004) • Dartmouth – $37,780 (2005) • University of Connecticut - $2.5 million (2006)

30. Important Points to Remember • Effort reporting is under scrutiny by the Office of Investigators General from NSF, NIH, and other Federal agencies • 100% effort is NOT Based on a regular 40-hour work week. It is based on each individual’s own average work week. • Effort reporting tracks the reasonable approximation of actual activity on projects and should not simply mimic budgeted amounts.

31. Call us if… • you need to make changes to contracts of WIU employees being paid from your grant • the effort you or one of the employees working on your grant changes substantially • changes need to be made to the percentage of effort of an employee being used as match on your grant • an employee that was working on your grant leaves WIU • you have any questions

32. For more information or questions, contact the Office of Sponsored Projects at 298-1191