time and effort reporting - texas a&m...
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Time and Effort Reporting
Texas A&M University
Research Services
Karan Watkins, CRA
Effort Reporting Administrator
(979) 862-1765
http://tamurs.tamu.edu/
AGENDA
• Effort Reporting Audits
• Lessons Learned
• Mitigating Risks
• Time and Effort Update
• Frequently Asked Questions
EFFORT REPORTING AUDITS
• Harvard University
The settlement $3.3 Million: The university and an affiliated teaching hospital
agreed to pay a total of $3.3-million to resolve accusations that a researcher
worked fewer hours than promised on a project to study aging. The accusations
included other accounting and management issues, including salaries paid to
scientists who did not meet one of the grant's citizenship requirements.
• Johns Hopkins University
The settlement $2.6 Million: The university agreed to pay $2.6-million to settle
claims that scientists had knowingly overstated how much time they had spent
on research. The researcher had billed the granting agency more than 100
percent of his available work time and the grant supported other employees for
work that was never performed.
EFFORT REPORTING AUDITS
• Northwestern University
The settlement $5.5 Million: The university agreed to a settlement of $5.5-million over
charges that medical researchers at the university had reported spending more time on
federally sponsored projects from 1995 to 2001 than they actually did.
• Cornell Weill Medical College
The settlement $2.6 Million: Weill Cornell Medical College has agreed to pay over $2.6
million to settle charges that Cornell defrauded the National Institutes of Health and the
Department of Defense as it sought more than $14 million ($13 million from NIH and $1
DOD) in federal research grants. The principal investigator failed to disclose to the
Government the full extent of her various active research projects. These omissions
deprived the Government of its ability to assess the researchers’ ability to perform the
projects in the grant applications. The government alleged that the PI’s failure to disclose
other grants she received allowed her to over-commit her professional time, which is
prohibited by NIH guidelines. Federal funding guidelines and regulations require
researchers to disclose their active projects and the amount of research time they plan to
devote to each project to ensure that researchers have adequate time to complete a project
and that the project is funded appropriately.
YALE AUDIT HHS audit of Yale subcontract from UMass Medical School
(February 2006)
• $194K of a $572K NIH award was disallowed by HHS
• Disallowed $151,252 for unallowable payroll cost transfers
– Did not adequately explain and document the cost transfers (e-mail stated salary cost transfers
made to spend down funds) altered documentation given to auditors.
• Disallowed $42,527 for unsupported direct charges
– The PI moved expenses to the subaward from other projects that were over budget.
– Direct charges questioned: laboratory stockroom supplies (no evidence supplies used on
subaward), charges for DNA Sequencing services requested by researchers not documented as
working on subaward, charges for maintenance of equipment purchased under another sponsored
grant.
– Method used for splitting invoices was unallowable because it is not a recognized method,
consistently applied. (3 active projects in lab at same time) Memo did not provide any supporting
evidence that the various projects would consume the same level of supplies and materials, nor did
it adequately account for smaller projects.
• PI failed to provide the 25% level of effort proposed in subaward application, PI did not
submit effort reports for lab technician, two effort reports were not certified.
YALE AUDIT NIH, DoD and NSF serve Yale with subpoenas (June 2006)
• $7.6 MILLION Settlement
• FBI agents went at night to faculty and staff homes (and to one vacation destination) to question them
• 47 grants totaling $45 million from 14 departments
• The investigation focused on allegations involving two types of mischarges to federal
grants. Both types of mischarges arose as violations of the basic principle that recipients
of federal grants are allowed to charge to each grant account only “allocable” costs,
which are costs that relate to the specific objectives of that grant project.
• The first allegation involved cost transfers and the requirement that costs transferred to a
federal grant account must be allocable to that particular grant account. The settlement
resolves allegations that some YALE UNIVERSITY researchers at times improperly
transferred charges to a federal grant account to which those charges were not
allocable. Researchers allegedly were motivated to carry out these wrongful transfers
when the federal grant was near its expiration date and they needed to spend down the
remaining grant funds. Federal regulations require that unspent grant funds be returned
to the Government.
YALE AUDIT
The second allegation involved salary charges and the requirement that
charges to federal grant accounts for researcher time and effort must
reflect actual time and effort spent on a particular grant. The Government
alleges that some researchers at YALE UNIVERSITY at times submitted
time and effort reports, for summer salary paid from federal grants, that
wrongfully charged 100 percent of their summer effort to federal grants
when, in fact, the researchers expended significant effort on unrelated
work. Researchers allegedly were motivated to carry out these wrongful
salary charges by the fact that they are not paid their academic-year salary
by YALE UNIVERSITY during the summer. The only salary received by
these researchers during the summer was the result of the effort they
charged to federal grants. Absent the alleged grant mischarges, the
researchers would not have been paid.
YALE
YALE AUDIT
Y: The audit said Yale found an e-mail that had been altered and reported
it. The original e-mail had asked for costs to be transferred from other
grants to the sub-grant, which was about to expire with funds still
remaining. A reference to "spending down" the sub-grant was deleted in
the altered e-mail.
L: That e-mail was a matter of great concern to us. When we discovered
the altered email, we immediately reported it to the federal auditors. It is
intolerable, no matter what the intention, for a Yale employee to alter a
document in the course of a government audit. And it's wrong to charge a
research grant that is about to expire for expenses unrelated to the grant.
There is simply no doubt about it.
Effort Reporting Audits
Links Yale Audit Information
HHS Audit: http://oig.hhs.gov/oas/reports/region1/10501501.pdf
US Attorney (DHHS, NSF, DOE, NASA Audit:
http://www.justice.gov/usao/ct/Press2008/20081223-1.html
Yale Alumni Magazine: http://www.yalealumnimagazine.com/issues/2006_09/q_a.html
Yale Office of Public Affairs & Communications: http://opac.yale.edu/news/article.aspx?id=6302
LESSONS LEARNED
• Key Personnel – PI’s with multiple grants
• Effort percentage in proposal vs. available time when award is accepted
• Reduction of more than 25% requires prior sponsor approval
• Cost Share
• Cost Transfers
• Timeliness of Effort Certification
• Suitable Means of Verification
• Appointment Letters reflect Institutional Base Salary
• Expenses Must Meet the Following Criteria • Allowable (conform to sponsor regulations i.e. OMB A-21, reasonable, and
are given consistent treatment)
• Reasonable (withstand public scrutiny)
• Allocable (support or advance the work of a specific sponsored project)
MITIGATING RISKS
• Effort reports are certified within the 45 day certification period
• Communication with Project Administrator
• Monthly review of account expenditures
• Avoid Re-certifications to Effort Reports
– Place effort reports on HOLD if:
• PAYROLL CORRECTIONS ARE PENDING
• MISSING DATA (Research Foundation)
• Reports - (Documents with negative percent effort)
• Request Interim Funding
• Is it problematic to charge 100% effort to research grants?
TIME AND EFFORT UPDATE AND INFO
THEN
CSBA WINTER 2010 WORKSHOP
• TAMU % Certified:
SPRING 2009 – 96%
FALL 2009 – 97%
SPRING 2010 – 97%
• TAMUG % Certified:
SPRING 2009 – 96%
FALL 2009 – 100%
SPRING 2010 - 97%
NOW
CSBA SPRING 2011 WORKSHOP
• TAMU % Certified:
SPRING 2009 – 99%
FALL 2009 – 99%
SPRING 2010 – 99%
FALL 2010 – 95%
• TAMUG % Certified:
SPRING 2009 – 100%
FALL 2009 – 100% SPRING 2010 - 100% FALL 2010 – 98%
TIME AND EFFORT UPDATE AND INFO
DEPARTMENT ADMINISTRATOR CHECKLIST
Effort documents for previous certification periods are complete
(T&E – Reports)
Employees have Doc PIN managers (T&E - Reports)
Payroll corrections (must be in FAMIS by June 30)
Cost share accounts have been reviewed and are in
compliance with SAP 15.01.01.M1.03
http://rules-saps.tamu.edu/PDFs/15.01.01.M1.03.pdf Separate SA for each sponsored project
Coded CSOR, CSIN, CSOS (Famis 008, 051)
Account title (must include sponsored project
account number)
Identify effort reports that should be placed on hold (pending
payroll corrections, projects in negotiations)
TIME AND EFFORT UPDATE AND INFO
TIME and EFFORT 1.3
NEW TAB: FUTURE DOCUMENTS - Monthly View - “Collecting Status” will be
moved out of the Employee’s Document Inbox
TIME AND EFFORT - FAQ
Q What is the difference between Self Certify and PI Eligible?
(T&E - Employee Details)
A Both Self Certify and PI Eligible status allow the employee to
certify their own effort. The PI Eligible mechanism is automated
through BPP based on the employees title code. The Self-Certify
mechanism is manual and can only be changed by making a request
to the Central Administrator.
Q The payroll correction has posted in FAMIS, why is it not
reflected in the effort document?
A The Time and Effort system is updated the 11th of each month to
include the previous months payroll transactions. If a payroll
correction is posted to FAMIS in the month of May, the effort report
will not reflect the correction until June 11.
TIME AND EFFORT - FAQ
Description EFFORT REPORTING SYSTEM PAYROLL CERTIFICATION SYSTEM
SYSTEM FOCUS INDIVIDUALS PROJECT (GRANT or CONTRACT)
CERTIFICATION
FREQUENCYBI-ANNUAL MONTHLY
CERTIFIER
PRINCIPAL INVESTIGATOR or SUPERVISOR
The certfier must have first hand knowledge
of the employees work/tasks/responsiblities.
OPTIONAL, can be the Principal Investigator ,
delegate or Department Head.
SYSTEM RATIONALE
Percent Effort in relation to "all" or 100% of
the employees institutional responsibitlities is
reasonable.
Percent of payroll charged to the project for the
month is reasonable based on the work performed
by the employee.
Q I approve my monthly payroll project reports each month,
isn’t certification of effort a duplication of what I have already
done?
QUESTIONS?