Time and Effort Reporting for Federal Grants Presentation for Private Investigators By: The Grant Accounting Office PI’s are required to verify that they have reviewed the tutorial by sending an to Tanja F. Blackstone, stating that ‘Time and Effort training has been

What is Effort Certification? Effort Certification is the formal reporting of employee activities. It is required by federal regulations in order to test the reasonableness of award salaries. 2

Importance of Reporting Labor reports are used to certify that the amount of labor expended on a federal grant corresponds to the salary allocated to the project. - The expectation is for the salary charged to the grant to not be greater than the percentage of effort expended. Federal agencies are accountable to Congress for appropriate usage of their funds. - Therefore, recipients of federal awards must be transparent in the activities associated with their grant. 3

Governmental Regulation OMB Circular A-21 (Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions) states… - “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…” 4

General Assumptions Documentation must... - Appropriately reflect compensation that an individual receives from UNA’s payroll system - Ensure that salary charges reasonably match actual effort Verification must… - Be performed by the individual who is paid by the grant » UNA has the PI verify the report, as well. - Include proof of performance » UNA requests that a Progress Report justifying the level of effort is attached to the report. 5

Risks of Noncompliance UNA is expected to meet federal guidelines for Effort Certification. In recent years, the federal government and its auditors have become active in reviewing effort reports. A number of universities have received large fines for noncompliance. 6

Fines for Noncompliance University of Alabama – Birmingham - $3.4 Million Northwestern University - $5.5 Million John Hopkins University - $2.6 Million Florida International University - $11.5 Million Cornell University - $4.4 Million Harvard University - $2.4 Million 7

Definition of Effort Effort = the percentage of time spent on any activity expressed as a percentage of total time fulfilling the assigned university responsibilities 100% Effort = total time estimated for UNA activities (activities compensated through the UNA payroll system) 8

Definition of Effort Includes… - Teaching - Administration - Research - Other university activities Doesn’t Include… - Private consulting to outside parties - Incidental, one-time payments in excess of base salary 9

Effort Example Percentage of Effort Calculation: % of Effort for a Federally Sponsored Project = Amount Paid by Project during Period Divided by Total Amount Paid from All Sources During the Period Federal Grant 25% State Grant 25% Instruction 25% Administration 25% 10 Total Effort Must Equal 100%!

Federally Sponsored Activities Includes effort devoted to grants, contracts, and cooperative agreements sponsored by the federal government for the purposes of training, public service, or research OMB Circular A-21 states, “…Charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences, but not writing new funding applications…” 11

Non-Federally Sponsored Activities Includes… - Classroom Instruction - Curriculum Development - Departmental Administration - Other Non-Federally Sponsored Effort » State or Local Grants Proposal preparation time is included in this category of effort. 12

Timeline Post review will be completed by Dr. Tanja Blackstone, Director of Sponsored Research. PI’s will mail the reports back to the Grant Accounting Office. These are due in 2 weeks. Effort Reports are Certified. The employees will certify the reports, and the PIs will later review and co-sign them. A Progress Report should also be attached to the report. Reporting period of the quarter ends. The Grant Accounting Office creates Certification Reports. These will be delivered to the PIs by the 15th of the month after the quarter. Actual salary is charged during the quarter based on HR assignments. 13

Certificate 14

Progress Report 15

Due Dates for Private Investigators On the 15 th day of the month following the quarter, PI will receive the reports. During the next two weeks, the PI will have time to get the employees to certify the reports and to prepare Progress Reports. The PI will also need to review and to co-sign the report. The reports are due in two weeks in the Grant Accounting Office. Example: - Quarter Period = January to March - April 15 th = Receive Effort Certification Report - Due with in two weeks 16

Labor Redistributions If any changes need to occur, these will be handled by the Grant Accounting Office and the Payroll Department. Redistributions will be determined on a case-by-case basis. A new report will be created for certification purposes. 17

Contact Information Grant Accounting Office: Anita Holcombe Accountant II, Grants 126 Bibb Graves Hall Florence, AL Sponsored Research Department: Dr. Tanja Blackstone Director, Spon. Research 208 Bibb Graves Hall Florence, AL