Effort Reporting: Compliance Training Overview

1. Faculty Compliance Training2008-2009 Office of Audit, Compliance & Ethics

2. Overview • Effort Reporting • Faculty/AAUP Consulting and Conflicts of Interest in Research– Updates • Code of Conduct and Code of Ethics - Updates Office of Audit, Compliance & Ethics

3. Basics • Handouts • Distractions • Cell Phones/Blackberries • Laptops • Questions • Late Entry/Early Exit Office of Audit, Compliance & Ethics

4. Compliance Training: Effort Reporting and Certification Office for Sponsored Programs Spring 2009 Office for Sponsored Programs

5. What is Effort Reporting? 5 Effort reporting is the mechanism used to confirm that salaries charged to each sponsored project are reasonable in relation to the work actually performed. Cost sharing commitments are also confirmed through the use of effort reports. OMB Circular A-21requires that the University document the distribution of activity to each individual sponsored project. Office for Sponsored Programs

6. Effort Reporting Encompasses More Than Just Certifying Effort … Post-Award Pre-Award Appointing Faculty & Staff Preparing the Proposal Budget Committing Effort Award Management/ Charging Salary Certifying Effort Employment Terms are Established including # months, % full-time, salary base Effort is Proposed a commitment is made to the sponsor Salary is Charged or Cost Shared contemporaneously with effort Effort is Certifiedafter activity has occurred 6 Office for Sponsored Programs

7. Why? 7 Effort Certification is a Federal Requirement • Universities must comply with OMB Circular A-21 (Cost Principles for Educational Institutions) • Labor expenses typically represent the majority of direct costs on sponsored projects • Effort certification is the only means of verifying that the salaries charged to grant and contract accounts were appropriate Office for Sponsored Programs

8. Who? 8 Effort Certification is a Federal Requirement • Effort reports are required for all individuals who work on sponsored projects. • Principal Investigators are responsible for ensuring that all charges (including salary) to an award are appropriate. • Commitments must be met, regardless of whether the sponsor provided salary support. Office for Sponsored Programs

9. When? 9 • For Faculty/Professional Staff : • Fall Semester • Spring Semester • Summer Semester • Summer Effort Does Not Overlap with the Spring and Fall Semesters • Classified Staff Certify Effort Quarterly Office for Sponsored Programs

10. How is Effort Measured? As a percentageof total time dedicated to University activities for a given period. Since percentage is the basis for measurement, total effort for any given period must equal 100%. This is not equivalent to a 35, 40 or even a 60 hour work week, or any fixed number of hours. 10 Office for Sponsored Programs

11. Summer Salary • It is not possible to work “extra” during the academic year, then take a summer salary without actually working during the summer. • “Protecting” your budget by delaying taking summer salary can be problematic. 11 Office for Sponsored Programs

12. What are University Activities? • Preparing Proposals • Pursuing Intellectual Property • Public Service • Outreach • Paid Absences 12 Research Departmental and University Research Instruction University Supported Academic Effort Administration Service on Institutional Committees Office for Sponsored Programs

13. Sponsored Research Activities 13 • A sponsored project can only be charged for activities that directly relate to the project. This may include: • Directing or Participating in the Research • Writing a Progress Report • Holding a Meeting with Lab Staff • Consulting with Colleagues • Delivering Special Lectures • Mentoring Graduate Students Office for Sponsored Programs

14. Activities Not Applicable to Sponsored Research 14 • Activities that cannot be allocated to sponsored projects include: • Writing, Editing and Submitting Proposals • Administration • Instruction, Office Hours, Counseling for Students • Mentoring Graduate Students (on something other than a specific research project) • Service on an IRB, IACUC, Selection Committee • Service as the Primary Editor of a Journal • Advisory Activities for Sponsors Office for Sponsored Programs

15. Cost Sharing 15 • Cost shared effort reflects work on a sponsored project that is not paid by the sponsor • Mandatorycost sharing is required by the sponsor and must be shown on the effort form. • Voluntary Committedcost sharing is promised by the university in the proposal, is required by the award and must be shown on the effort form. • Voluntary Uncommittedcost sharing is work performed after the award is received that was not included as part of the proposal or required by the terms and conditions of an award. Office for Sponsored Programs

16. Documentation Requirements 16 • Documentation Must… • Reasonably reflect the activity for which an individual is paid by the University (or has committed effort…). • Reflect all of the activities performed by the individual. Office for Sponsored Programs

17. Documenting Effort How can someone “prove” his/her effort for a period of time? Maintain documentation that supports the research contribution, both research content and time/percentage of effort. Use a calendar, correspondence, work products, etc… 17 Office for Sponsored Programs

18. Documentation Requirements 18 • Documentation Must… • Include after-the-fact confirmation to ensure that initial salary charges reasonably approximate actual effort. • Be performed by the individual or a responsible individual who has a “suitable means of verification that the work was performed”. Office for Sponsored Programs

19. Who Can Sign? 19 Reports must be signed by the Principal Investigator, employee or a responsible person using suitable means of verification. Office for Sponsored Programs

20. Differences? 20 Generally speaking… If actual effort on a grant < % salary charged to the grant, a cost transfer should be requested. If actual effort > % salary charged, it becomes cost share if effort is committed in proposal. Office for Sponsored Programs

21. Changes to Signed Effort Reports • Should not be made unless an unusual or extraordinary situation exists. • Changes to previously certified effort reports are a red flag for auditors. • Requests for changes are usually tied to attempts to use up remaining grant funds. 21 Office for Sponsored Programs

22. Example #1 In addition to her teaching and other University responsibilities, Dr. Smith is the PI for three research projects. She has voluntary cost shared effort of 10% for Project A, and no committed effort for Projects B and C. How should Dr. Smith’s salary and effort be recorded on her effort report?

23. 10% Cost Shared Effort

24. Example #2 This scenario is the same as Example #1, except in this case, Dr. Smith is being paid 10% of her salary from Project A. She has no committed effort for the other two projects. How should Dr. Smith’s salary and effort be recorded in this situation?

25. 10% Paid Effort

26. Example #3 In this example, Dr. Smith has 10% paid effort on Project A, and 5% cost shared effort on Project B. How should Dr. Smith’s salary and effort be recorded on her effort report in this situation?

27. 10% Paid and 5% Cost Shared Effort

28. Example #4 Common Mistakes

29. Example #5 This example is designed to illustrate what happens when a PI delays taking a summer salary in order to”protect” his/her budget. Currently, we do not have a method to isolate and exclude such a payment from the fall/spring effort reports.

30. Summer Pay During Academic Year * 67 $41,540 33 20,460 $62,000 * $6,000 was summer salary from 525XXX

31. Auditors Look for… • Patterns suggesting actual effort was less than the level certified. • Patterns of retroactive adjustments that appear to be for the purpose of using of unspent grant funds. 31 Office for Sponsored Programs

32. Audit / Compliance Headlines 32 Office for Sponsored Programs

33. Effort Certification—Key Points 33 Effort should reasonably reflect activity. Effort certified must represent 100% of University effort. Effort is not based on a 40-hour work week. Faculty should certify their own individual effort report form. Effort reports for other employees must be completed and signed either by the employee, the principal investigator, or a responsible official. Office for Sponsored Programs

34. Contacts 34 • Antje Harnisch 486-3994 antje.harnisch@uconn.edu • Neal Breen 486-3798 neal.breen@uconn.edu Office for Sponsored Programs

35. Office of Research Compliance (ORC) Annual Compliance Training2008-2009 Office of Research Compliance

36. Training – Why? It is required Opportunity for review Experience identifies new issues Amendments to policy and procedure Related topics Office of Research Compliance

37. Training – Worth It? Opportunity for dialogue Allays confusion and rumor Ensures smooth operation of program Protects program Office of Research Compliance

38. REVIEW Office of Research Compliance

39. Consulting ……. is defined “as providing services, advice and similar activities for compensation, based on faculty member’s professional expertise or prominence in his or her field, while not acting as a State employee”. http://consulting.uconn.edu/ Office of Research Compliance

40. Activities that are NOT consulting…. • There is no compensation, other than necessary expenses • The compensation is paid through the State • The work is done with another State agency • The work does not enhance professional development Office of Research Compliance

41. Time due the University..…. http://consulting.uconn.edu/ is defined “as anytime necessary for successfully carrying out the duties assigned to and for which a faculty member was hired. This includes both sufficient time to perform assigned duties as well as sufficient opportunity to meet with other faculty, staff and students”. Office of Research Compliance

42. Approval to Consult given only if faculty member……. • is currently fully performing his/her state duties • is not exceeding an average of one day per week Office of Research Compliance

43. Learn From Experience Office of Research Compliance

44. Prior Approval…. • Not on the day of activity • Before start of activity • Late submissions to any of the required signatories cannot be approved and triggers sanctions Office of Research Compliance

45. How do I count the days? Any time away from “time due the University” Must include travel time Time not “due the University” -counts as 0 (zero) days Office of Research Compliance

46. Amendments And Changes Office of Research Compliance

47. As of January 1, 2009, the Faculty Consulting Office (FCO) will……. • Process only those forms that are submitted at least one day prior to the start of the activity • Impose sanctions for requests submitted late - on or after the start date of the activity. Office of Research Compliance

48. Departments and Schools will be reminded to……. Monitor the total number of consulting days requested (39 during the academic year – September through May) Consider whether proposed consulting activity could be done by the University Office of Research Compliance

49. The Request to Consult Form is modifiedto require……. • The total estimated time committed for the consulting activity to include associated travel time, broken out by days expected to be at work AND days not expected to be at work; Office of Research Compliance

50. Form updates Office of Research Compliance • The number of already approved requests for the current academic year; • The project titles of requestor’s current University grants/contracts from the contracting entity; • The name of the end-client if the contracting entity is owned by the requestor.