1. KEYS TO SUCCESS NCURA Region IV Spring Meeting April 27 – 30, 2014 © 2014 National Council of University Research Administrators National Council of University Research Administrators Keys to Success! NCURA Region IV Indianapolis, Indiana April 27 – 30, 2014 NCURA Region IV Spring Meeting April 27 – 30, 2014 KEYS TO SUCCESS © 2014 National Council of University Research Administrators Effort Reporting: A Primer Matt Richter Effort Administrator University of Wisconsin – Madison

2. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Agenda Background: What is Effort Reporting? An Institution’s Effort Policy Commitments Effort Cost Share Questions Slide 2 © 2014 National Council of University Research Administrators

3. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Background: What is Effort Reporting What is Effort Reporting? – Assuring an individual met his or her commitments The sponsor got what it paid for – Assuring sufficient effort was devoted to justify salary charges The sponsor paid for what it got Basically, an Effort Report is… a receipt. Slide 3 © 2014 National Council of University Research Administrators

4. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Background: What is Effort Reporting The basic idea In a grant proposal, we offer effort At award time, we make a commitment of effort Throughout the project, we charge salary to the sponsor Periodically, sponsors want to know: – Have we devoted enough effort to justify the salary charges? – Even in cases where we are not charging salary to the sponsor, have we fulfilled our commitments? Precision is not required: Reasonable estimates are expected Slide 4 © 2014 National Council of University Research Administrators

5. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Background: What is Effort Reporting Authority As recipients of federal funding, educational institutions must abide by OMB Circular A-21 (Cost Principles for Educational Institutions) A-21, Section J.10 outlines acceptable methods for supporting charges related to “compensation for personal services” on federal grants and contracts – OMB A-21, J.10: “the reports will be signed by the employee, PI or responsible official(s) using suitable means of verification that the work was performed” – Direct knowledge not needed – First hand supervision not needed Slide 5 © 2014 National Council of University Research Administrators

6. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Background: What is Effort Reporting Government Use: Verify that labor charges are appropriate based on the amount of work performed Verify that effort commitments and cost sharing is performed as promised Verify that sponsored research is appropriately classified (i.e., included in Organized Research F&A base) Institution Use: Management reporting tools Are faculty and others working in areas as expected or promised? Is payroll distribution appropriate? Where is labor cost sharing occurring? May be used for other reporting purposes (state teaching requirements, Medicare time reporting) Slide 6 Background: What is Effort Reporting © 2014 National Council of University Research Administrators

7. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Background: What is Effort Reporting What the regulations require us to do… Be careful about what we offer in a proposal Be careful when making commitments at award time Change commitments when needed, and document the changes Fulfill commitments Charge salary in a way that’s congruent with actual effort Certify effort in a way that’s congruent with what actually happened Slide 7 © 2014 National Council of University Research Administrators

8. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Background: What is Effort Reporting What the regulations require us to do… Not charge a grant for time that doesn’t pertain to the grant Not charge a grant for time spent writing a proposal for a new project or a competing continuation – Time spent on these activities must be covered by institutional or gift funds Transfer salary charges off of a grant if the level of effort does not justify the salary charges Slide 8 © 2014 National Council of University Research Administrators

9. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Background: What is Effort Reporting …And why we do it right. The consequences of not getting this right can be dire for the university Effort reporting remains a target for federal auditors Many universities have paid millions of dollars in fines Audits are underway at peer research institutions Slide 9 © 2014 National Council of University Research Administrators

10. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Slide 10 PROPOSAL: Commitments are Offered AWARD: Commitments Become Obligations Commitment Setup Commitments are Fulfilled Tracking and Management Lifecycle of a Grant Documentation & Reporting of Fulfillment © 2014 National Council of University Research Administrators

11. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring An Institution’s Effort Policy: Who, What, When, Where Who: Whose Effort must be certified? Effort must be certified for all faculty, staff, students, and postdoctoral researchers who either: – Charge part or all of their salary directly to a sponsored project, or – Expend committed effort on a sponsored project, even though no part of their salary is charged to the project Slide 11 © 2014 National Council of University Research Administrators

12. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring An Institution’s Effort Policy: Who, What, When, Where Who certifies? Effort must be certified by a responsible person with suitable means of verifying that the work was performed At the UW: – All PIs, faculty, and academic staff members certify for themselves – PIs certify for the graduate students, postdocs, and non-PI classified staff who work on their projects When the PI doesn't have suitable means of verifying that the work was performed: – A designee can certify the effort for project staff Slide 12 © 2014 National Council of University Research Administrators

13. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring An Institution’s Effort Policy: Who, What, When, Where What is required? Effort certification is mandatory – Effort training is looked at fondly by the feds, but is not required under J.10. At the UW: Penalties for non-compliance – The UW will not provide support for extramural activities Precision is not required in certifying effort – Reasonable estimates are expected Slide 13 © 2014 National Council of University Research Administrators

14. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring An Institution’s Effort Policy: Who, What, When, Where What is required? At the UW: Recertification—up to the certification deadline, an individual may request to recertify At the UW: After the certification deadline: – The PI or department administrator must submit a written request to RSP requesting to recertify – The written request will be reviewed by the Associate Vice Chancellor for Research Administration – Only in the most compelling of circumstances will it be granted Slide 14 © 2014 National Council of University Research Administrators

15. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring An Institution’s Effort Policy: Who, What, When, Where When to certify and take training: Depends on the method for confirming payroll distribution: – J.10 provides 3 examples of acceptable methods – A commonly used method: After-the-fact reporting At least every 6 months for professional and professorial staff Hourly workers = monthly (time sheet will suffice) At the UW: For classified staff: 4 times / year – Periods of performance (PPs) correspond to calendar quarters At the UW: faculty, academic staff, grad students, postdocs: twice yearly – PPs are January - June and July - December At the UW: Certification starts a month or more after the PP At the UW: The certification window is 90 days Slide 15 © 2014 National Council of University Research Administrators

16. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring An Institution’s Effort Policy: Who, What, When, Where Where to certify: Effort Reporting Systems Many electronic systems on the market At the UW: Assembled a PI task force to help choose the appropriate software Slide 16 © 2014 National Council of University Research Administrators

17. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Slide 17 PROPOSAL: Commitments are Offered AWARD: Commitments Become Obligations Commitment Setup Commitments are Fulfilled Tracking and Management Lifecycle of a Grant Documentation & Reporting of Fulfillment © 2014 National Council of University Research Administrators

18. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Commitments A statement in the proposal or project application – Specific and quantified – Effort for a PI, co-investigator, or key person, regardless of whether salary is charged An obligation that the university must fulfill Example – Professor Jones proposes 30% of her effort for 12 months and requests 10% salary support: – Professor Jones has committed 30% of her effort for that 12-month period Slide 18 © 2014 National Council of University Research Administrators

19. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Commitments Slide 19 Paid Effort Cost-Shared Effort Non-Payroll Cost Sharing Effort Not Paid By Sponsor Commitments Non-Effort © 2014 National Council of University Research Administrators

20. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Commitments Minimum commitment required; Changing commitments Minimum commitment: PI/PD is required to commit a certain minimum of effort to each project – At the UW: Minimum commitment for PI/PD = 1% Commitments can be changed – Some changes require prior written approval from the sponsor – All other changes must be documented Slide 20 © 2014 National Council of University Research Administrators

21. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Commitments For whom are commitments required? The principal investigator/project director All co-investigators All individuals identified as senior/key personnel in the grant proposal – At the UW: When the proposal does not explicitly list key persons, the university defines key personnel for the purpose of effort reporting as the principal investigator/project director and all co-investigators Slide 21 © 2014 National Council of University Research Administrators

22. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Commitments Where are commitments indicated? Some statements in the proposal become commitments when the university and the sponsor finalize the award agreement: – Requests for salary support and statements about cost-shared effort in the budget or budget justification – Effort proposed in the research plan or project description – but only when specific and quantified: Example: "Professor Jones will devote 10% of his time during the academic year to this project." Slide 22 © 2014 National Council of University Research Administrators

23. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Commitments Limits on total commitments Commitments can never total more than 100% Commitments can add up to a full 100% only if ALL of your job duties to your institution can be allocated to sponsored projects – This is generally not the case for faculty members, for any consecutive 12- month period Can academic staff, postdocs, classified staff be paid 100% from sponsored projects? – This is not against the rules, and it’s entirely appropriate in many – but not all – circumstances Slide 23 © 2014 National Council of University Research Administrators

24. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Commitments When the awarded budget is less than proposed You cannot assume that the effort commitments are automatically reduced in proportion to the budget reduction You have several options: – Keep salaries and effort the same, and reduce other budget categories – Keep effort the same, reduce salaries, and document the increase in cost sharing – Reduce effort commitments – requesting prior approval for a key person's reduction of 25% or more Slide 24 © 2014 National Council of University Research Administrators

25. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Effort What is Effort? Effort is not based on a 40-hour work week 100% equals all the activities for which you are compensated by your institution, regardless of appointment or number of hours worked Examples: – If you work a half-time job, your 100% = what you do for that 0.5 FTE appointment – If you work 80 hours a week, your 100% = what you do during those 80 hours Slide 25 © 2014 National Council of University Research Administrators

26. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Effort What counts as Effort? The activities for which you are compensated by your institution This includes: – Externally sponsored research – Internally-funded or unfunded research – Instruction, administration, and service on committees – Public service and outreach activities directly related to your professional duties at your institution Slide 26 © 2014 National Council of University Research Administrators

27. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Effort What does not count as Effort? Activities for which someone else compensates you, and some activities for which you are not paid Examples: – Consulting – Leadership in professional societies – Peer review of manuscripts – Advisory activities for a sponsor (NIH study section, or NSF peer review panel) Slide 27 © 2014 National Council of University Research Administrators

28. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Effort What counts as sponsored activity? Activities contributing to and intimately related to work under the agreement As long as it's about the specific project, it counts as sponsored activity: – Lab meetings, conferences, seminars, writing a progress report – Reading journals to keep up-to-date on subject area Writing a proposal for a new project or competing continuation does NOT count Lab meetings not specific to a project do NOT count Research patient care – The care that is described in the protocol is sponsored activity – Routine patient care is NOT, even if provided to a research subject

29. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Effort Effort that is too small to count: Activities that you do on an infrequent, irregular basis can be ignored in your effort calculations if the total amount of time would not affect your effort distribution – Possible examples: department meetings, serving on a search committee – depending on your individual situation Regular, well-defined activities generally should not be treated as de minimis Proposal writing cannot be de minimis Slide 29 © 2014 National Council of University Research Administrators

30. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Effort Unfunded or “weekend” work: Activities that are closely associated with your professional duties must be counted as part of your 100% effort Examples: – Proposal writing – Instruction, administration, service on committees You cannot characterize them as "unfunded" or "volunteer" activities, or "weekend work," for which no institutional salary is paid Slide 30 © 2014 National Council of University Research Administrators

31. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Effort Effort can vary over time: To meet a commitment, the actual effort need not be a constant It must add up, over time, to fulfill the commitment Example: If 30% effort is committed for a calendar year, one way to fulfill this commitment is by spending: – 40% effort on the project during the first six months of the year, and – 20% effort on the project during the last six months Slide 31 © 2014 National Council of University Research Administrators

32. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Cost Share What is Cost Share? Cost sharing is the portion of the total costs of a sponsored project that is borne by your institution Cost-shared effort is any work on a sponsored project for which the university, rather than the sponsor, provides salary support Paid effort is work for which the sponsor provides salary support Example – With a 30% effort commitment and salary support for 10% of the effort: – 10% is paid effort – 20% is cost-shared effort Slide 32 © 2014 National Council of University Research Administrators

33. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Cost Share Mandatory Cost Share vs. Voluntary Committed Cost Share: Mandatory cost sharing is cost sharing that’s required by the sponsor as a condition for proposal submission and award acceptance Voluntary committed cost sharing is cost sharing that is not required as a condition for proposal submission – But, once offered and accepted, it becomes a commitment Slide 33 © 2014 National Council of University Research Administrators

34. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Key Concepts: Cost Share Voluntary Uncommitted Cost Share: When you certify, you must include cost-shared effort up to and including the amount of your cost-sharing commitments If you’ve put in more time than you were paid to spend, over and above your cost-sharing commitments: – This is voluntary uncommitted cost sharing – This extra effort is not required to be documented or tracked – You should not include it in the effort you certify for a sponsored project Slide 34 © 2014 National Council of University Research Administrators

35. NCURA Region IV Spring Meeting April 27 – 30, 2014 NCRUA Region IV Spring Thank you For questions, please contact me anytime: Matt Richter Effort Administrator / ECRT Manager (608) 890-0289 msrichter@rsp.wisc.edu Slide 35 © 2014 National Council of University Research Administrators