COM Business Office Compliance

University of South Florida

HSC 160

Compliance Defined

• Effectiveness and efficiency of operations

• Reliability of financial reporting• Compliance with applicable laws and

regulations.

Overview of Compliance

Fundamental concepts:• Internal control is a process• It’s a means to an end, not an end

in itself• Geared toward the achievement of objectives

• Internal control is affected by people at every level

• Not merely policy manuals and forms

• Provides reasonable, not absolute assurance

Key Components

5 Key Components of Internal Control System:

1. Control environment

2. Risk assessment

3. Control activities

4. Information and communication

5. Monitoring

Financial Compliance

As USF employees, we have the Fiduciary Responsibility to:

1. Confirm valid, authorized purchases are made from the appropriate funding sources,

2. Validate accurate posting of all expenditures

3. Validate all revenues are received and deposited timely

4. Confirm staff have the appropriate training to fulfill their job responsibilities

Financial Compliance (cont.)

5. Safeguard University equipment

6. Identify and take action on fraudulent activity

7. Review and approve system security actions

Overview of Internal Controls

Definition of Internal Controls:

Systematic measures instituted by an organization to:

1. conduct its business in an orderly and efficient manner,

2. safeguard its assets and resources,

3. deter and detect errors, fraud, and theft,

4. ensure accuracy and completeness of its accounting data,

5. produce reliable and timely financial and management information, and

6. ensure adherence to its policies and plans.

Internal Controls

Remember:

Internal controls do not necessarily ensure success!

Poor internal controls can result in:

1. Bad Decisions

2. Poor managers

3. Unethical behavior

4. Collusion

5. Override of controls

Examples of Internal Controls

1. Segregation of Duties: Separate the duties among different individuals to reduce the risk of error or inappropriate actions. a) Example: The person who charges expenses to a USF P-Card

should not be the same person to approve those charges in the FAST System.

Examples of Internal Controls (cont.)

2. Physical Controls: Assets, inventories, securities and cash are secured physically and periodically counted and compared to amounts on control records.Example: Review list of equipment annually to ensure that all equipment is documented and accounted for.

3. Reconciliations: Comparisons are made between source documents maintained by the document’s custodian and the official ledgers.Example: Reconcile your source documents monthly with the ledgers available on Finance Mart.

Examples of Internal Controls (cont.)

4. Policies and Procedures: Established policies, procedures and job descriptions provide guidance and promote consistency.

Example: Provide job descriptions for each of your employees so that they know what their duties are.

5. Transaction and Activity Reviews: Managers compare information about current performance to budgets, forecasts, prior periods to measure if goals and objectives are being achieved.

Example: Compare all source budget with monthly reconciliations to make sure the department is still operating within their means.

Procedures for Purchasing

• Requisitions/Purchase Orders must be in place prior to the ordering of goods or services.

• If you are buying office supplies using State funds, they must be purchased through Office Depot.

• Any technology/computer item must be purchased through the USF Computer Store

• Independent Contractor agreements are reviewed and signed off my General Counsel and Purchasing before engaging in service.

Procedures for Purchasing (cont.)

Helpful Links:

Computer Storehttp://www.computerstore.usf.edu/

Purchasing and Property Serviceshttp://usfweb2.usf.edu/purchasing/

UTSBhttp://www.it.usf.edu/purchasing/information/utsb

Procedures for Purchasing (cont.)

Remember Quote Requirements

• Less than $5,000 – you must have one verbal quote documented.

• Between $5,000 & $25,000 – you must have two verbal or written quotes documented.

• Between $25,000 & $75,000 – you must have three written quotes documented.

• Greater than $75,000 – Must be sent out for competitive bids. Purchasing must certify the bids.

Procedures for Purchasing (cont.)

Single Source: If an item or service is determined to be

non competitive in nature and is only available from one

particular vendor, you can purchase via

single source.

Memberships: Can be purchased via purchase

order if the membership is essential to the duties and

responsibilities of the University.

Contractual Services: Can be purchased via purchase

order, but the contract must be executed prior to the

rendering of the service. The Purchasing Department must

approve prior to initiating PO.

Procedures for P-Cards

Before you Purchase:

• Check for any University policies or processes that you must follow

• Check for any preferred vendors (i.e. Avis, Office Depot)

• Purchase all technology items from the USF Computer Store

• Make sure the total cost of the purchase does not exceed your single transaction limit

• Have the USF tax exempt number available

• Reference Website: http://usfweb2.usf.edu/pcard/index.html

Procedures for P-Cards (cont.)

• P-Cards can be used for purchases with a single transaction value of $2,000 or less.

• P-Cards have a monthly limit of $5,000 or less.

• You can NOT purchase equipment (more than $5,000) with a P-card.

• You can NOT purchase food on the P-card.

• You can NOT pay for contractual Services

• You can NOT pay for Independent Contractors

Procedures for P-Cards (cont.)

Things you CAN purchase:

• Office Supplies• Computers less than $5000• Computer supplies• Employment Advertising• Lab Supplies• Printing• Rental Fees• Software under $1000• Subscriptions• Travel charges

Things you CAN’T purchase:

• Alcohol• Attorneys• Cash Advances• Contractual Services• Flowers• Computers over $5,000• Parking Permits• Personal convenience Items• Plaques/Awards• Shredders

For a complete list of allowable and unallowable purchases, please see the P-Card website: P-Card Purchases

Procedures for P-Cards (cont.)

Misuse of Card includes:

• Falsification of records

• Fraud

• Theft

• Using the card for personal gain

• Allowing another individual to use your card

• Repeated non-compliance with processes and procedures

• Divulging confidential information

P-Card Audit

What happens once you submit your receipts?

1. Reconciler will match the receipt to the incoming charge in FAST and approve within 7 business days.

2. Reconciler matches receipts to the monthly bank statement.

3. Reconciler gets cardholder and accountable officer signature.

4. Reconciler submits copy of bank statement and receipts to P-Card department

Once your P-Card receipts have been submitted, the P-Card department reviews all the charges and may contact you for any

questions.

Travel Compliance

Travel Authorization (TA)

• The completed Travel Authorization is the Traveler’s permission to incur expenses and to travel and is an estimate of what a specific trip will cost. The Authorization should list all anticipated Travel Expenses that are known, or can be projected, before the trip. The TAR should be submitted prior to any charges are incurred.

• A Travel Authorization in advance of any travel to a conference or convention is explicitly required per Florida Statute.

• Should authorized Emergency Travel be required of an employee that prohibits prior entry of a Travel Authorization into FAST, a memo is required indicating the details of the travel and the circumstances that prohibited adherence to the normal Authorization process, including evidence that the situation was out of the Traveler’s control.

Travel Compliance (cont.)

Expense Report (ER)

• After travel occurs, an Expense Report is submitted in FAST to report expenses and/or request Traveler reimbursement.

• The Expense Report will list all expenses associated with the Travel, whether paid directly by the University or reimbursable to Traveler.

• Expense Reports must be submitted within thirty (30) days of last date of travel.

Travel Compliance (cont.)

• USF Travelers will be reimbursed for coach/non-refundable airfare only

• USF Travelers will be reimbursed for up to a maximum

of two (2) bags.

• Travelers utilizing their personal vehicles are

authorized to be reimbursed at the Florida Statutory

Rate of .445 cents per mile.

• Avis Rent a Car System, LLC, (AVIS) is the Preferred Vendor for USF Travelers in need of rental vehicles.

Travel Compliance (cont.)

• Taxis, trains, buses, and other mass transit may be used when these modes of transportation result in a cost savings to the University. Receipts are required for all ground transportation regardless of the amount.

• Parking, storage or toll fees under $25 may be reimbursed without receipts.

• Domestic Travelers will be paid meal allowances pursuant to FS112.061 (6) (a-c) as follows: 

Breakfast $6Lunch $11Dinner $19Total for day $36

Travel Compliance

• For domestic lodging, justification is required at the time of reimbursement request if the nightly hotel rate (before taxes) exceeds $200.

• Meals for all days of Foreign Travel will be reimbursed at the published Department of State rate for the destination area.

• Foreign lodging should be obtained at or below the published

Department of State rate for the destination area whenever possible.

Reconciliation• Reconciling gives you the opportunity to find errors and make

corrections

• Reconcile your ledgers on a monthly basis

• Compare departmental source documentation to the official ledgers

• Notate and follow up on any discrepancies you may find

• Share reconciliation with key people (Supervisor, PI, senior management)

• Make sure signature authorization and workflow forms are updated upon hire or termination of an employee

• GBR is filled out after an award has been granted to distribute budget to the appropriate budget account codes based on the sponsor’s approved budget

• Pay Distribution is updated in a timely manner to align personnel with the grant proposal/award

• NIH salary caps are taken into consideration and if anyone exceeds the cap, cost share accounts are set up in a timely manner

**** RETS should consider impact to NIH salary cap before submitting

Sponsored Research

• All Sick and Annual leave is properly reported in the ALT system in a timely manner

• Internal documentation is kept within the department as justification to the ALT leave record

• Leave audits are performed annually

Leave Tracking

• Definition: an employee has influence or decision making authority over the employment of a relative.

• “relative” is defined as the husband; wife; parent; step-parent; child; step-child; brother; sister; half-brother; half-sister; spouse of child, brother, sister or parent; child, brother or sister of spouse; grandparent; grandchild; aunt; uncle; first cousin; niece; or nephew of the employee. “Relative” or “related” person also includes a person who is engaged to be married to an employee.

• If relatives work in the same area, a nepotism memo must be signed and approved by the Vice President before work my commence.

Nepotism

Record Retention

Before disposing of any records, you must review the retentionschedule provided by the state: http://dlis.dos.state.fl.us/recordsmgmt/gen_records_schedules.cfm

After reviewing the retention schedule, you must submit the RecordDisposition Request Form to Lazara Stinnette, Purchasing and PropertyServices at AOC 200.

If your records contain only copies, you do not need to submit a recorddisposition request form. These records can be destroyed as soon asthey have served their purpose.

Accounting Best Practices

1. Review all funding sources monthlya. Look for errors

b. Look for fraudulent activity

2. Compare outstanding transactions to

previous transactionsa. Look for budget errors

b. Look for chartfield value errors

c. Look for chartfield combination errors

3. Become familiar with standard transactionsa. Payroll transactions

b. P-card transactions

c. Revenue transactions

d. Budget transfers

e. Corrected transactions

Accounting Best Practices

4. Be organizeda. Create electronic files for easy reference

5. Trust and verifya. Check transactions for accuracy and

allowability

b. Review payroll for unknown individuals

c. Review reimbursements

6. Locate equipmenta. Keep a list of all property and include serial numbers and USF tag numbers

Accounting Best Practices

7. Network

a. Join any available list serve• FAST• GEMS• Foundation• DSR/RFM• Travel• Accounts Payable• Accounts Receivable

b. Check COMPASS

c. Enroll in Talent Management, TRAIN, or Business Office Training

EthicsPoint Hotline

• USF has engaged EthicsPoint—a third party hosted hotline—to enable the safe, secure, and anonymous reporting of activities which may involve misconduct, fraud, abuse, and other violations of USF policies. You may file a report by clicking on the To Make a Report link on the chart or by calling toll-free 1-866-974-U411.

• USF is committed to providing a safe, secure, and ethical place to work. As a member of the USF community, you have a responsibility to voice compliance and ethics concerns, so that we can work together to promptly resolve the issues while helping to cultivate a positive environment.

• Website

Additional Resources

Audit and Compliance

http://usfweb2.usf.edu/uac/risks.htm

TRAIN

http://www.research.usf.edu/TRAIN/

Controller’s Office Training

http://usfweb2.usf.edu/UCOTraining/

Purchasing Policies

http://usfweb2.usf.edu/purchasing/reg_policy_proc.htm

Records Retention

http://dlis.dos.state.fl.us/recordsmgmt/gen_records_schedules.cfm

Faculty Activity ReportingTraining

USF Health Business Office

Objectives

• What, Who, When, Where, and Why?

• Category Names and Definitions

• Navigation for Faculty

• Questions and Answers

Who and What ?

• Who has to report?– Faculty, graduate assistants, residents, and faculty

administrators

• What is Faculty Activity Reporting? – Faculty Activity Reporting (FAR) is a legislatively State

mandated process to report faculty effort within educational, research, service and other categories.

When and Where ?

• When does FAR have to be done?– Faculty Activity Reporting is required each

semester - three times per year. Summer (05), Fall (08), and Spring (01).

• Where do I report my effort?– Faculty Academic Information Reporting

(FAIR)

Why?

• Why do I have to do this?– Comply with F.S.S. 1012.945 (12 hour law)– Comply with Chancellor Memo 87-17.1– Expenditure Analysis - determines funding– LCME reporting– Management reporting– Historically has been used in Asset

Investment Management System (AIMS)

Categories

And

Definitions

• Course numbers are in the following format

BCC 7114 001

Course Number Anatomy

Prefix (GMS, BMS, BCC, MEL, etc)

Number(7114, 7980, 7814, etc.)

Section number(001, 002, 003, etc.)

In addition, each course/section has a unique course reference number:

• Medical courses start with a 7• Main campus course in summer start with 5• Main campus course in fall start with 8• Main campus course in spring start with 1

17 – Clinical Instruction

• Time spent instructing, supervising, and evaluating House staff (Residents, Fellows, or Interns (including Clinical Research Fellows) in a clinical environment.

Note: This would also include advising the above groups.

40 - Academic Advising *

• Formal counseling with students on academic course or program selection, scheduling, and career counseling.

• Academic advising assignments shall include such indicators as number of students formally advised by the faculty member, hours specifically designated for advising purposes and other appropriate indicators of advising activity.

• This category is NOT for House staff advisement, which should be included in Clinical Instruction.

* Backup Documentation Required

25 - Other Instructional Effort *

Instruction-related activities which includes• development of new approaches• improvement/revisions of materials for credit courses• participation in planning• development or evaluation of total curricula, program services, • preparing, planning programs, • participation in non-credit generating instructional activities such as

Learning Community, or • mentoring, etc.

* Backup Documentation Required

25 - Other Instructional Effort Examples

• Ex: Administrative assignments as Course Director, Clerkship Director or Residency Training Director are related to instruction

• Ex: Supervision of student ARNP’s in clinical setting • Ex: Participation on the College Curriculum Committee or the Medical

Student Selection Committee

22 - Departmental Research(Research/ Scholarly Activity w/o external grants) *

•Research activities that are supported by department sources of funding (NOT Sponsored),

Duties may include:– the preparation, planning and conduct or research, – data analysis, –manuscript preparation, –presentation of results, and –supervision of postdoctoral trainees (not externally funded).

****Department Research may also include the preparation and publication of scholarly reviews, chapters, monographs and books, as well as the development of new educational approaches or

techniques and other types of medically-related creative activity.

* Backup Documentation Required

32 - Public Service *

• Activities that extend the professional and/or discipline related services of individuals to the community, the state, or the nation.– This includes service in professional organizations

and academic or professional student organizations.– The primary intent is to provide professional and/or

discipline-related services, other than instruction, that are beneficial to groups and individuals.

– Such public service shall NOT generate payment from third party.

* Backup Documentation Required

47 - University Governance *

• Activities that provide advisory support to the general governance of the unit or the institution.– Includes participation on department, college or

university committees and councils.– Includes special assignment such as consultation

services to university offices and units.• Ex: Participation on the Practice Plan Physician Advisory

Board

* Backup Documentation Required

36 - Paid Patient Care

• Reimbursable activities in a clinical environment that do NOT involve Medical Students or House staff.

34 - Clinical Service (Non-Reimbursable)*

• NON-REIMBURSABLE patient care activities in a clinical environment that do NOT involve House staff or Medical Students.

Ex: Bridge Clinic: patients are not paying for

your service.

Ex: Judeo Christian Clinic- patients are not paying for your service.

Although there may be students with you, there may be instances

where the clinic is backed up and faculty see the patients alone.

* Backup Documentation Required

46 – Academic Administration *

• Restricted to individuals with formal administrative appointments.– Does NOT include direct administrative effort related to a

specific course which should be reflected in the appropriate instruction category.

– Direct administrative effort related to a specific project, & funded by the sponsored research, should be reflected in Research category.

• Ex: Formal administrative appointments such as Dean, Vice Dean, Associate Dean, Chair, Vice Chair, Director, President, etc…

* Backup Documentation Required

89 - Leave of Absence with Pay

• An authorized compensated leave of absence granted to the employee by the university. Examples:– Disability leave– Sabbaticals– FMLA leave

* Backup Documentation Required

Professional Development

• Professional development activities should be reported according to the category in which they fall in and should be reported as follows:

– President of a professional association: Public Service– Attendance at a professional conference, meeting or seminar to improve

teaching skill: Appropriate instructional category– Attendance at a professional conference, meeting or seminar to improve

research or scholarship skills: Departmental Research or Sponsored Research

– Attendance at a professional conference, meeting or seminar to present research findings or scholarship: Departmental Research or Sponsored Research

– Attendance at a professional conference, meeting or seminar for general knowledge and professional networking: Public Service

23 - Sponsored Research (External Grants & University Internal Research Awards) *

• Separately budgeted and accounted for research; all research activities that ARE SPONSORED by federal, state, local government and private organizations.

• Includes all approved grant, contract and industry supported research activities both basic and clinical in nature.

• Grant related duties include the preparation, planning, and conduct of research, as well as related data analysis, manuscript preparation, presentation of results, and supervision of postdoctoral trainees (externally grant funded).

NOTE: The FTE % must be consistent with those reflected on Federal Grants & PERT forms.

* Backup Documentation Required

AFD-FAR NAVIGATION FOR

FACULTY MEMBERS

Login

Enter through the USF Administrative Portal

https://my.usf.edu

Login screen

Enter your NET ID and Password

If you do not have a NETID, click “Activate your NETID” to create an ID.

Note: you can use your health email as your NETID. Ex: hclark@health.usf.eduYou will then use the same password you use to sign into the computer with.

Access to FAIR

• Click “Business Systems” and then scroll down to “Fair”

Main menu

Once in FAIR, you will click on the Workload tab to view the FAR Reports

Semester Selection

Click on the applicable term

YYYY05 = Summer

YYYY08 = Fall

YYYY01 = Spring

Simplified Medicine Form

Medical Courses

Masters / PhD Courses

Grants

Non Instructional Activities

Reporting in Percent of FTE

• Why do some faculty member’s FAR not add up to 100%?– The Board of Governors require the SUS

system to report effort in FTE %.– If you are a 100% FTE, your form will add to

100.– If you are a partial FTE, the form will compute

on the partial FTE– The next slide is to assist those faculty

members in converting 100% to their FTE %.

Calculation of FTE percentage

Activity Effort FTE FTE %

Academic Advising 25% * .50 12.50

Clinical Instruction 25% * .50 12.50

Department Res 25% * .50 12.50

Public Service 25% * .50 12.50

Total 100% 50.00

To convert percentage of effort to FTE %, multiply each line by the decimal form of your FTE. In the sample above, the individual is a 50% FTE; therefore, you use .50 as the multiplier.

Medical Courses

Click Edit to enter % of FTE

Click Delete to remove the course

Assigning Effort to Medical Courses

1. Click Edit to enter the % of FTE

2. Enter the % for the course. Please take into consideration the course begin and end dates and the term begin and end dates.

Masters / Ph.D. Courses

Click Edit to enter %

Assign % of FTE to Undergraduate, Masters, and Ph.D. Courses

Click Edit to add or change % of FTE and click update

Non-Instructional Activities

1. Enter the % of FTE

4. Backup Documentation

3. Must be equal to each other once the form is complete.

2. When you finish, click the update button

Supporting Documentation

• Supporting Documentation is required for certain categories.– There is a link labeled “Supp Doc” for all

categories requiring explanation. They are all identified earlier in this presentation.

– State in a paragraph or two what you did for the category chosen.

Sample of Supp Doc Screen

1. Enter the supporting documentation here

2. Click “Save this document” when finished entering.

Certifying the FAR Report

Upon completion and confirmation by faculty that the total of all activities and assigned FTE match, the “SIGN” button will appear,

The faculty need to select the sign button, Notify the effort representative in the College of Medicine Business Office (Danny

Woolbright) that all steps have been completed, Courses will be rolled to Administrative form, COM will be notify when roll is complete, You will assign paying and benefitting funding sources, THE END

AFD-FAR NAVIGATION FOR

Administrators

Login

Enter through the USF Administrative Portal

https://my.usf.edu

Login screen

Enter your NET ID and Password

If you do not have a NETID, click “Activate your NETID” to create an ID.

Note: you can use your health email as your NETID. Ex: dshockl1@health.usf.eduYou will then use the same password you use to sign into the computer with.

Access to FAIR

• Click “Business Systems” and then scroll down to “Fair”

Main menu

Once in FAIR, you will click on the Workload tab to view the FAR Reports

Browse by Camp/Coll/Dept

• Enter search parameters and click the “submit” button

Search Results

Departmental Listing

Pay Plans:

22 – Faculty

06 – Adjunct Faculty

05 – Grad Assist

01 – Supplemental Comp

98 – Non-compensated SUS

99 – Non-compensated non SUS

Click on the blue hyper link to access the form

Administrative Form

• There four main sections– Course Related Activity– Instruction Related Activity– Non Instruction Activity– Sponsored Research Activity

Course Related Activity

Instruction Related

Non Instruction-Related

Sponsored Activity

FAR Admin FormAdministrators will use this form to assign the paying and benefitting accounts. Click “View Pay Summary” for Salary Information.

View Pay Summary

• Provides the following information– Pay Summary by Funding Source

• Provides the percentage by budget entity

– Pay Detail by pay period and funding source• Detail pay by pay period and funding source

– Faculty Info Summary• Crosswalk from chart field to State Reporting

Number (SRN)

Pay Summary

Budget Entities

Budget Entity FAST Fund Code Fund Type SRN Suffix

E & G 10000 & 10009 Health Sciences / EG 20, 00, 50

Contract and Grant

18300 Rebate R0

20000 Grant: Federal L0, K0, P0

21000 Grant: State/Local L0, K0, P0

22000 Grant: Private L0, K0, P0

24000 Endowment L0

9#### Convenience P0 or L0

State Reporting Numbers (SRN) are used in reporting to the State e.g. 610100020. The chart below helps you to identify funding type to SRN.

Activities and Funding

Activity Funding PriorityUndergraduate, Graduate, MED Courses E&G, Convenience, Rebate

Clinical Instruction (Residents) E&G, Convenience, Rebate

Supervision of Co-op Interns E&G, Convenience, Rebate

Academic Advising E&G, Convenience, Rebate

Other Instructional Effort E&G, Convenience, Rebate

Departmental Research Convenience, Rebate, E&G

Public Service Convenience, Rebate, E&G

University Governance Convenience, Rebate, E&G

Paid Patient Care Convenience, Rebate, E&G

Clinical Service Convenience, Rebate, E&G

Administration Convenience, E&G, Rebate

Leave of Absence Convenience, Rebate, E&G

Organized / Sponsored Research Research Grants (cost share)

Paying & Benefitting Accounts Assigned Report Reconciled

Functions

• Inserting a row• Deleting a row• Editing a row• Add an account to drop lists

Inserting a Row

1. Click on the blue “+” mark

Inserting a row…………………..2

1. Use the drop down menu to choose category

2. Enter % FTE

3. Apply paying and benefiting accounts

4. Click on green check mark

Please be sure to complete the row before moving to another row.

Deleting a row

1. Click on box with scissors above

2. Click on Update

Editing a row

1. You may edit the category, % FTE, paying account, or benefiting account by changing the field.

2. Click on UPDATE.

Adding Account to Drop Down.1

Click “Faculty Information”

Adding Account to Drop Down.2

Click on hyperlink

Adding Account to Drop Down.3

Adding Account to Drop Down.4

Enter chart field and Click Search

Choose the grant and scroll down and click Submit

Cost Share

• There are four categories of cost share– Mandatory (Committed) - required by the program as a condition of the

award and therefore is obligatory and reportable. (example: NSF 1% mandatory cost share)

– Salary Cap Cost Sharing (Committed) - occurs when the salary for an individual exceeds the sponsor imposed limit. This is classified as Voluntary Committed cost share and must be documented within USF’s PERT system.

– Voluntary (Committed) – offered/proposed by the grantee when not specifically required by the sponsor. The offer is included in the award directly or by reference. Voluntary Committed cost sharing expenses must be properly identified for cost accounting purposes. Voluntary cost sharing is highly discouraged and requires approval Division of Sponsored Research (DSR) approval.

– Voluntary (Uncommitted) - unplanned cost share that does not need to be documented within the University’s system or reported to the sponsors.

Questions and Answers

• What happens if a faculty member does not complete their faculty activity report?

– Non compliance with state law (Auditor General annual audit)

– Impacts the University, College and Department funding

What is PERT?

• PERT (Personnel Effort Reporting)• PERT is USFs federal effort reporting process as mandated by the

United States Government Office of Management and Budget (OMB) published regulations OMB Circular A-21 which requires educational institutions to maintain an accurate system for reporting the percentage of time that employees devote to federally funded projects. In accepting Federal funding, the University and Principal Investigator agree to comply with this regulation. PERT effort reports are designed to meet A-21 requirements and are the only authorized approach for federal effort reporting at USF. In the absence of an appropriate effort reporting system, salaries and wages will not be reimbursed or funded with federal dollars

Can a certified effort report be changed?

• Certified effort reports assert that the information represented is to the best of the certifier’s knowledge, is accurate, and complete

• Changes to previously certified effort erode the credibility of the certifier as well as the entire effort certification process

• In the GEMS system, Retro Expense Transfers (RETS) will trigger the need to re-certify the affected effort report

Questions and Answers

• Do FAR and PERT (Personnel Effort Reporting Tool) need to Match?– YES!!!

• Possible consequences if they are inconsistent: Cost Disallowances Designation as High Risk Organization Special Terms and Conditions in Awards Special Monitoring by Federal Agencies Temporary Withholding of Payments Withholding of Future Awards