2013 06 03 hcca effort rptg presentation€¦ · 3. other salary 2. summer salary: salary paid...

Road Map to Effort Reporting

1


Monday, June 3, 2013

Presenter: Kerry BorawskiCPA, CHRC, MBA

Research Compliance Auditor

Session 103:

• Today’s Objectives:• OIG Attention to Effort Reporting• Proposed OMB Uniform Guidance• Requirements of Time & Effort Reporting• St. Louis University’s Process

• Planned Confirmation • Roles & Responsibilities

• Fact or Fiction

Collaborate – To work, one with another; To cooperate.-Dictionary.com

• Effort Reporting • Is a process for employees• To VERIFY the time they spent on sponsored projects

• To CERTIFY that we charged the correct salary to those projects

Applies to ANYONE who has charged time to an award.Ex = Principal Investigator, Graduate Assistant, Administrator, Lab

Tech, Co-Investigator, etc.


2

• Current Regulations• OMB Circular A‐21 – Cost Principles for Educational Institutions

• OMB Circular A‐133 –Compliance Supplement

In order for the University to accept any federal funds, including federal financial aid, then we must obey the Effort Reporting requirements

• Proposed Regulations• OMB Uniform Guidance: Cost Principles, Audit, & Administrative Requirements for Federal Awards

• “Super Circular”• Name Change to “Documentation of Personnel Expenses”

Many argue that the Super Circular has successfully merged the various circulars in most areas, with the EXCEPTION of Time & Effort

• A‐21, Three Methods:• Plan Confirmation• After‐the‐Fact• Multiple Confirmation Records

After-the-Fact records requirement aligns most closely with the othercirculars’ time distribution rules.


3

• Proposed Regulations:• General reqm’t stays the same• Type depends on # of Cost Objectives worked on by each employee

• Certified Reports should be:• Integrated with payroll system• Certified• Kept using % or Hours

For employees working on MULTIPLE Cost Objectives, some requirements are laid out but there remains flexibility with each awarding agency.

Effort Reporting Process

Referred to as a “Plan Confirmation Process”

EPAFLabor

Reallocation (LR)

Effort Report (EVR)

ActualPlanPlan

• EPAF – Electronic Personnel Action Form

The form used to create the payroll record for a University employee.

EPAF

Allocates the percent of time the employee intends to spend on each segment of their job. For ex –Teaching responsibilities are paid from a separate

fund than Research responsibilities.

Plan


4

• LR – Labor Reallocation

Labor Reallocation

When changes are identified, this prompts the new Allocation for the percent of time the employee intends to spend on each segment of their job.

A correcting journal entry to redistribute payroll to a different funding source.

Plan

EVR‐Effort Verification Report

Form used to certify an individual’s effort for a reporting period

Effort Report (EVR)

1. Effort Reportable Salary

2. Summer Salary

3. Other Salary

Actual


Effort Reportable Salary = Institutional Base Salary (IBS)

Effort Report (EVR)


2. Summer Salary

3. Other Salary

1. Institutional Base Salary (IBS):

Total compensation paid to an employee for all

professional activities they provide to the University within their appointment.

Effort Reportable Salary = Institutional Base Salary (IBS)(1) Instruction, (2) Research, (3) Clinical, (4) Administration

Actual


5


Full Time Staff and Faculty with 12 month appointments would NOT be eligible b/c they work all 12 months.

Effort Report (EVR)


2. Summer Salary

3. Other Salary

2. Summer Salary:Salary paid during the

summer months for work done outside of the normal

contract period.

Actual


Effort Report (EVR)


2. Summer Salary

3. Other Salary

3. Other Salary:Incentive, Bonus, On-Call

Pay, Overload, Supplemental

Used to capture “Total Professional Effort”,

includes all activities that comprise employee’s total

W-2 wages

Institutional Base Pay (Research, Instruction, Clinical, Admin)+ Other Salary (Incentive, Bonus, Overload, Supplement)

Total W-2 Wages

Actual

•QUESTION:•Which activities, specifically, are categorized within each of the 3 sections on the Effort Report?


6

The Effort Report separates the salary figures into three distinct sections:1) Effort Reportable

Salary2) Summer Salary3) Other Salary

1. Teaching Research Methods course, Sept-Dec

2. Teaching Research Methods course, Jul-Aug

3. Co-Investigator on Example Grant, Sept-Dec

4. Co-Investigator on Example Grant, Jul-Aug

5. Outstanding Performance Bonus, Dec6. Mentoring Students, Dec7. Proposal Writing, Dec8. Chair of St Louis Foundation, Dec9. Investigator-Initiated Non-Funded

Research, Dec10.Clinical Trial Nurse, Dec

Assume a 9‐month faculty appointment …

Effort Reporting Process

Referred to as a “Plan Confirmation Process”

EPAFLabor

Reallocation (LR)

Effort Report (EVR)

ActualPlanPlan

•QUESTION:•What happens with my Zero Credit Hour Graduate Reading Course? I don’t get paid for that class.

Instruction means Teaching & Training Activities whether credit is granted or not


7

•QUESTION:•What happens with my unfunded research?

Research means a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge.

• Sponsored Research•University Research•Other Institutional Activities

The PI has ultimate responsibility for

ensuring compliance requirements are met on their sponsored

awards.

FACT

Effort reporting is optional. Even if I am paid on a sponsored

program, if my Business Manager says “I’m

exempt”, then I don’t have to do it.

FICTION – If paid on a federal award, you must complete an Effort Report. Only Exception is for employees paid on weekly Time Sheets.


8

Effort reporting reflects a “Reasonable

Estimate” of how my time was spent.

FACT

The Effort Report is someone else’s attempt at showing how I spent

my time.

FICTION – Only you know how you spent your time.


When investigators leave the University, the formal HR Exit Process prompts them to complete their Effort Report.

Effort Report (EVR)


2. Summer Salary

3. Other Salary

1. Every 6 months1. January-June2. July-December

2. Investigator must sign it1. Or someone with

“…suitable means of verification”

3. Finalized w/in 30 days of distribution

Actual


9

Total Professional Effort

Total Professional Effort is NOT based on a 40-hour work week NOR is it based on a Full Time Equivalent (FTE).

Scenario – New Employee:

100% Appointment

Time

Appointment



Scenario ‐ Add Research:80% Appointment20% Grant

Time

Appointment

Grant

Yahoo!



Scenario ‐ Add Admin:75% Appointment20% Grant5% Admin

Time

Appointment

Grant

Admin


10



Scenario ‐ Add Overload Teaching:

75% Appointment20% Grant5% Admin

Total Institutional Base Salary (IBS)

$5,000 Overload ______TeachingTotal Other Salary

Time

Appointment

Grant

Admin

Ovrld Teach

• Incidental Pay• Payment made to University employee for activities done Outside the Scope of their Total Professional Effort & Institutional Base Pay

It is Minimal, Infrequent in Nature, and Outside the Scope of their Normal University Role.

Effort Reporting ProcessCollaborative System that expects Continuous Communication

EPAFLabor

Reallocation (LR)

Effort Report (EVR)

ActualPlanPlan

Employee, Dept Admin, Bus Mgr & Payroll

Employee, Dept Admin, Bus Mgr & Payroll

Employee, Dept

Chair, PI & Spon Pro


11

• System Improvements:• Pending Funds• Timeliness• Electronic Memo of Agreement

• EPAF improvements

University’s System is a Work in Process

Total Professional Effort always equals 100%.

FACT

Personnel who work > 40 hours/week should report 100% effort on their EVR, regardless of how many hours they

work.

FACT


12

Part time personnel should report 100% effort on their EVR,

regardless of what FTE the appointment

represents.

FACT

If I identify an “itty‐bitty little change” on my Effort Report, I don’t

need to bother to adjust it with a Labor Reallocation.

FACT for changes less than 6% of Institutional Base Pay

Late or Unsigned Effort Reports have no impact on the allowability of the salary expense.

FICTION – late & unsigned reports reflect Unallowable Expenses


13

Employees should NOT be 100% funded on Sponsored Activity.

FACT - The 100% question applies to Category #1 Effort Reportable Salary AND to Category #2 Summer Salary

The Research Division is responsible for

repayment of any unallowable costs.

FICTION – The Principal Investigator’s Department is responsible for unallowable costs.

The Time & Effort System asks me to record how I spend

every minute of my day with “Time Clock” detail

FICTION – Time and Effort records should support your “Reasonable Estimate”


14

• Take Away Message:• You should feel CONFIDENT about signing your Effort Report.

SLU Ethics Hotline is 1-877-525-KNOW (5669)

What’s Next?•Pending Changes due to OMB Proposed Guidance•Open Floor Up for Questions & More Discussion

Thank You.

Presenter: Kerry BorawskiCPA, CHRC, MBA

Research Compliance Auditor

[email protected]

(314) 977‐7720

2013 06 03 hcca effort rptg presentation€¦ · 3. other salary 2. summer salary: salary paid...

Documents