1. Effort Reporting Audit
Harvard Medical School
Research Administrators Open Forum
Friday, October 13, 2017
Lauren Kopec, Senior Auditor
Goda Sekmokaite, Senior Auditor
Risk Management & Audit Services

2. UNIVERSITY CONFIDENTIAL
Agenda
Provide overview of key audit elements
Background
Audit Objectives
Risks
Data analysis
Scope/Approach
Share outcomes
Strengths
Opportunities
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Background
University-wide audit
Included in the RMAS internal audit plan
Key audit drivers include:
Regulatory, financial and reputational risks
Recent OIG audit results
Relatively new HU Effort Reporting Policy and system
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4. FY16 Annual Faculty Effort Certifications by Tub
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5. FY16 Quarterly Project Effort Certifications by Tub
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Key Audit Objectives
To evaluate the system of internal control over effort reporting with specific focus on:
Effort certifications
Complete
Timely
Certified by appropriate individuals
Faculty proposed and committed effort vs. certified effort
Sponsors appropriately notified of significant changes and approval obtained, as needed
Administrative salaries
Justified
Reviewed and approved
Appropriately reflected in effort certifications
Policies & Procedures, Training, and Monitoring
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Risks
Non-compliance with federal regulations and award terms and conditions
Invalid effort reports – not certified by individuals with suitable means of verification that work was performed
Insufficient effort to meet commitments to sponsors
Over-commitment of effort with no time allocated for non- research responsibilities
Inaccurate reporting of effort – not reflective of salary transactions in GL
Unallowable and/or unallocable administrative salaries charged to federal awards
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Data Analysis
Risk Indicator
Annual
Certifications
Quarterly
Minimal reported effort: <4% 
>95% total effort on sponsored funds
>10 sponsored accounts
Status:
re-opened
certified after deadline
manually certified
Certified by proxy
Certified by designee
Certifier’s job title/function
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9. Testing Scope/Approach
Reviewed a sample of 50 effort certifications
15 - FY15 annual certifications
25 - FY16 Q1-Q3 quarterly project certifications
10 - FY16 Q1-Q3 administrative salaries
Reviewed training registration documentation
Interviews
OSP
Tub Effort Coordinators in FAS, HMS & SPH
HUIT ATS
Reviewed Compliance Controls Review Questionnaires completed for the FY16 Uniform Guidance audit
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10. Sample Testing Approach
Description
Effort Certifications
Accuracy
Reconciliation to Detail Listing
Recalculation of effort %
Completeness
Timeliness
Certified before deadline?
Validity
Certifier title – appropriate certifier?
Approval of proxy/designee
Committed Effort
Commitments met?
Administrative Salaries
Justified
Role in budget justification/proposal
Review & Approval
Harvard & sponsor approval
Effort Certified
Actual effort in certification vs. proposed
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Strengths
Electronic certification
Timely certifications
Ability to monitor/track
Policies and procedures are established
Roles and responsibilities are clearly defined
21-day review period
Reconciliations of financial feeds are performed regularly
Institutional job aids and resources
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Opportunities
Central Monitoring
Committed Effort - no University-wide tracking
Enhance administrative salary review to include targeted testing (i.e. low effort %, charged to multiple federal awards, etc.)
Institutional Training
Specialized training to address unique circumstances that may result in inaccurate effort %
Additional appointments, i.e. TA
Federal Work Study
Journals and re-opening certifications
Manual certifications
Period of Work Performed
Cost sharing
Criticality of Grants Manager role - consider mandatory training
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13. Thank you! Questions? Comments?
Contact Us
Lauren Kopec, Senior Auditor
Goda Sekmokaite, Senior Auditor
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