fundamentals of time & effort certification reporting 1 western illinois university office of...

Fundamentals of Fundamentals of Time & Effort Time & Effort

Certification ReportingCertification Reporting

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Western Illinois University Office of Sponsored Projects

What is Effort What is Effort Certification?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

Why is Time & Effort Why is Time & Effort Reporting Important?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

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Effort Certification Actually Effort Certification Actually Begins at the Proposal Stage:Begins at the Proposal Stage:

Award is Received Effort is Devoted Effort Reports

Distributed Quarterly

Preparing the Proposal Budget

Effort is proposed and a commitment is made to the sponsor

Appropriate personnel forms are processed and monthly match entries are recorded in the WIU system (if applicable)

Project Director or designee monitors time and effort to ensure accuracy of contracts and match entries

Effort is certified by PD or designee

What Exactly is “Effort”?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. “

What “Effort” isn’t…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.

Time & Effort Reporting Time & Effort Reporting is…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

How is Effort Determined?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.

How is Effort Determined?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

Sponsored Activities: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)

TeachingServing as a department chair, and other

administrative dutiesServing on university committeesAttending general departmental faculty

meetingsPublic service and outreach

Non-Sponsored Activities:Non-Sponsored Activities:

100% 100% Effort =Effort =

Teaching…


Teaching… Reading journals to keep up-to-date on research topic…

+


Teaching…

Meeting with people working on your grant…

+Reading journals to keep up-to-date on research topic…


Teaching…

Conducting research for your grant…

Meeting with people working on your grant…

+

+Reading journals to keep up-to-date on research topic…

Remember…Effort Always Remember…Effort Always Equals 100%Equals 100%

Who Certifies the Time & Who Certifies the Time & Effort Certification Report?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.

How to CertifyHow to CertifyThe Project Director (or the designated certifier) must verify that the time & effort certification report shows

areasonable estimate of the actual effort expended on

eachproject/source.

Documentation that may be helpful in verifying effort could

include:

◦ teaching schedules◦ outside activity forms◦ time sheets◦ leave reports◦ calendars◦ correspondence

How to Certify (continued)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

Pay Sources Should Pay Sources Should Reasonably Reflect Reasonably Reflect Activity 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.”

In other words…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%.

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

JAMES SMITHPsychology DepartmentWaggoner Hall 100

5/10/10 WESTERN ILLINOIS UNIVERSITYTIME AND EFFORT CERTIFICATION REPORT FOR 522220 TV VIEWING SURVEY

TIME PERIOD 01/01/10 – 04/30/10

EMPLNAME

CHARGEDEPT

CHARGENAME

WORKDEPT

PCT EFFORT

SMITH, JAMES 144440522220

PSYCHOLOGYTV VIEWING SURVEY

TOTAL EFFORT

144440144440

83.3316.67

100.00

DOE, JANE 144440141630522220

PSYCHOLOGYPUBLIC SERVICE MATCHTV VIEWING SURVEY

TOTAL EFFORT

144440533330144440

75.0010.0015.00

100.00

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: _________________________


5/10/10 WESTERN ILLINOIS UNIVERSITYTIME AND EFFORT CERTIFICATION REPORT FOR 5-22220 TV VIEWING SURVEY

TIME PERIOD 01/01/10 – 04/30/10

EMPLNAME

CHARGEDEPT

CHARGENAME

WORKDEPT

PCT EFFORT



TOTAL EFFORT

144440144440

83.3316.67

100.00

DOE, JANE 144440141630522220


TOTAL EFFORT

144440533330144440

75.0010.0015.00

100.00


SIGNED: ________________________________________ DATE: _________________________



TIME PERIOD 01/01/10 – 04/30/10

EMPLNAME

CHARGEDEPT

CHARGENAME

WORKDEPT

PCT EFFORT



TOTAL EFFORT

144440144440

83.3316.67

100.00

DOE, JANE 144440141630522220


TOTAL EFFORT

144440533330144440

75.0010.0015.00

100.00


SIGNED: ________________________________________ DATE: _________________________

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.



TIME PERIOD 01/01/10 – 04/30/10

EMPLNAME

CHARGEDEPT

CHARGENAME

WORKDEPT

PCT EFFORT



TOTAL EFFORT

144440144440

83.3316.67

100.00

DOE, JANE 144440141630522220


TOTAL EFFORT

144440533330144440

75.0010.0015.00

100.00


SIGNED: ________________________________________ DATE: _________________________



TIME PERIOD 01/01/10 – 04/30/10

EMPLNAME

CHARGEDEPT

CHARGENAME

WORKDEPT

PCT EFFORT



TOTAL EFFORT

144440144440

83.3316.67

100.00

DOE, JANE 144440141630522220


TOTAL EFFORT

144440533330144440

75.0010.0015.00

100.00


SIGNED: ________________________________________ DATE: _________________________

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.

Issues that raise red flags with Issues that raise red flags with auditors…auditors…

Late effort certification

Effort certified by someone withoutsuitable means of verification

A distribution of effort that leaves too little non-sponsored time to crediblycover teaching, administrative, or

other university duties

Post-certification revisions

Examples of Audits and Fines Examples of Audits and Fines Assessed on InstitutionsAssessed 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)

Important Points to Important Points to RememberRememberEffort 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.

Call us if…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

For more For more information or information or

questions, contact questions, contact the Office of the Office of Sponsored Sponsored

Projects at 298-Projects at 298-11911191

fundamentals of time & effort certification reporting 1 western illinois university office of...

Documents

effort isntdont

signed effort reports

time effort reporting

sponsored projectserroneously

percentage of time

reporting period

individuals actual time

individuals salary