effort certification & commitment fsm workshop€¦ · effort certification & commitment...
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Effort Certification & Commitment FSM Workshop
Mike [email protected]
Jennifer [email protected]
2011
Effort Reporting
Agenda
Risk of non-complianceSchedule and timelinesEffort principleKey topicsReady to review some effort forms?Ready to review some effort forms?Q&AsWhere to find assistance?
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Effort Reporting
Compliance Reinforced by Office of Inspector General (OIG):
CertificationTimely reporting?Account for all activities and correct base salary?Salary charged consistent with effort devoted per sponsored project?Was the certifier appropriate?
CommitmentsWas the proposed effort, including Mandatory and Voluntary Committed Cost Share, met?Are faculty over-committed?
Cost TransferLate cost transfers and/or Not Supported by Effort certifiedExcessive and inappropriate labor cost transfers
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Effort Reporting
Risk of Non-compliance…Institution Period Alleged Issues Settlement
Y l U i 2007 C t t f l $7 6 illiYale Univ 2007 Cost transfers; summer salary $7.6 million
Univ of Massachusetts Medical School
2006 Cost transfers; unsupported labor charges
$24K; triggered Yale & Roger Williams Hospital audits
California Institute of Technology
2006 Timeliness; NSF grants N/A
Howard Univ 2006 Cost sharing on NSF grants N/A
Univ of Pennsylvania 2006/ NSF Timeliness; cost transfers $3.3 million
Univ of Alabama, Birmingham
2005 Research work overstated; Medicare billed for research
$3.4 million
H d U i 2004 Bill d f l & l t d t $2 4 illiHarvard Univ 2004 Billed for sal & expenses unrelated to federal grants
$2.4 million
Johns Hopkins Univ 2004/ NIH Faculty time & effort overstated $2.6 million
Florida International 2004 Cost transfers and direct costs $11 5 millionFlorida International 2004 Cost transfers and direct costs $11.5 million
Northwestern 2003 Institutional base salary (NMFF-NU); K awards; Assigned certifier
$5.5 million
Effort Reporting
Schedule of Effort Reporting
Effort reports are generated 4 times a year (on a quarterly basis)
Calendar:Calendar:
Qtr Period Effort Forms AvailableQ 1 Sept to Nov DecemberQ Sept to o ece be
Q 2 Dec to Feb MarchQ 3 Mar to May JulyQ 4 J t A O t bQ 4 June to Aug October
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Effort Reporting
Follow-up Process of Effort Certification
Timeframe ActionDay 0 Effort Reports availableWeek 4 1. Effort Report Initial due (~30 days from Day 0)Week 7 2. Delinquency sent to Chairq yWeek 10 3. Delinquency sent to Dean’s OfficeWeek 14 4. Final Due Date;
Delinquency sent to Provost / VPRDelinquency sent to Provost / VPR
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Effort Reporting
Key Principle of Effort Reporting
Principle In Practice
In a given quarter, the certified % f ff t t b l t
If salary charges are greater than effort expended, salary must be adjusted per Quarterof effort must be equal to or more
than the % of salary charged and cost-shared to the grant
adjusted per Quarter
Effort commitments (paid and t h d ff t) h ld b tcost shared effort) should be met
within the Budget Period
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Effort Reporting
Effort Confirmation on a Quarterly Basis
Confirming Effort is the process of verifying that salaryConfirming Effort is the process of verifying that salary (payroll) charged to the project does not exceed actual effort expended.
Payroll % Effort %
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Per Quarter
Effort Reporting
Payroll exceeds Effort after the Certifier attested his/her Effort expended on the project for the reporting period
The sponsored account should be credited (refunded) so the sponsor is not overcharged
Special terms and conditions should be reviewed on a case by case basis (i.e. NIH career awards)
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Per Quarter
Effort Reporting
Effort exceeds Payroll after the Certifier attested his/her Effort expended on the project for the reporting period
Provided there is available budget and approved by the PI, the additional effort may be charged to the project.
If the project budget cannot cover the extra effort expended, the excess effort must be charged to a non-sponsored source such as a departmental account This is called Cost Sharinga departmental account. This is called Cost Sharing.
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Per Quarter
Effort Reporting
Payroll Charges vs. Certified Effort
Charges to the sponsored accounts (payroll %) should Not be higher than the Certified Effort %
Example: % Under the Certified Effort % generally should not be lower theExample: % Under the Certified Effort % generally should not be lower the Payroll %
Effort Reporting
Key Topics
Who should certify effort?yFaculty must certify their own effort certifications and their research staff’s. BAs and RAs cannot certify effort for the department
Safeguard NetID and Password:Never give NetID and password to others
Reporting effort must be consistent among all reports: Effort reportsProgress reportsProgress reportsCurrent pending & support pages (JIT submission)Financial status reports
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Effort Reporting
Key Topics
What Effort Related Issues do we check during Account gClose-out?
Effort certified?Payroll charges against effort certifiedNIH salary cap / cost shareCertified effort on Career awardsAnything else we are aware
If you receive a notice from the Effort team, please address the issue(s) as soon as possible so If you never receive a notice from the Effort team:If you never receive a notice from the Effort team:THANK YOU!!!
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Effort Reporting
Question #1
When is it too late in the effort reporting quarter to have a certified effort formquarter to have a certified effort form dropped for corrections/changes?
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Effort Reporting
Question #1When is it too late in the effort reporting quarter to have a certified effort form dropped for corrections/changes?corrections/changes?
Response:The current effort form can be accessed again by g ythe Certifier as long as it has not been post reviewedERS L > Cli k C t M ti > Cli kERS Logon -> Click on Cert Menu option -> Click on the current reporting period
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Effort Reporting
Question #2
If waiting on a late SDA or payroll change, is it better to go ahead and have the PI certify an effort form by putting in cost shared effort in place of the SDA/payroll and then correct at post-review or have the form dropped and re-certified correctly OR tell thethe form dropped and re certified correctly OR tell the PI to wait (past the effort certification deadline) in order to certify effort that appropriately reflects the SDA or payroll? Where is the bigger audit risk?SDA or payroll? Where is the bigger audit risk?
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Effort Reporting
Response to Question 2:
Late effort certification or missing effort certification is a risk…certification is a risk…
Last cost transfer (over 90 days) is also anLast cost transfer (over 90 days) is also an audit risk…
Effort should be driving the Payroll distribution
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Effort Reporting
Question #3
Several of our faculty members are listed on industry clinical trials but no other sponsoredindustry clinical trials but no other sponsored projects. As there is 0% effort, they only end up certifying for their non-sponsored portion and have asked me frequently why they are certifying. Would you recommend that they b d f th ERS t ?be removed from the ERS system?
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Effort Reporting
Question #3Several of our faculty members are listed on industry clinical trials but no other sponsored projects. As there is 0% effort, they only end up certifying for their non-sponsored portion and have asked me frequently why they are
tif i W ld d th t th b dcertifying. Would you recommend that they be removed from the ERS system?
ResponseKey personnel are listed per sponsored project, which will trigger ERS to generate an effort reportEffort forms are still needed to jog the memory when effort j g ywas expendedIf the clinical trials are not listed under the Sponsored Account Session, the effort can be entered on the second screen (see the next slide)
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Effort Reporting
If the clinical trials are not listed on the effort form, enter the effort in the Last university effort category
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Effort Reporting
Question #4
For the odd start dates, how can we correctly determine the first quarter of effort for thatdetermine the first quarter of effort for that grant? For example, one of my PIs has his start date listed as 05-21-11 on his NOGA and he’s at 30% effort. He’s been at 30% effort, but not for the full 31 days of May, so h t l l t ?how to calculate?
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Effort Reporting
Question #4For the odd start dates, how can we correctly determine the first quarter of effort for that grant? For example, one of my PIs has his start date listed as 05-21-11 on his NOGA and he’s at 30% effort. He’s been at 30% effort, but not for the full 31 days of M h t l l t ?May, so how to calculate?
Response pChicago Q3 is from 3/1 to 5/31, below is an estimate:Estimate: his effort is 3 to 4% on this project for Q3
• March: 0% Effort• March: 0% Effort• April: 0% Effort• May: 7 days out of 21 days *30% = ~10% (not exact)
Next Quarter, effort commitment is 30% as it will be 30% for each month
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Effort Reporting
Effort Reporting Training SessionsEffort 101 (4 times a year)
Eff t 101 i i d t i t th Eff t R tiEffort 101 is required to gain access to the Effort Reporting System (ERS) Federal regulations, NU policies & Procedures, Audit updates key compliance issues etcupdates, key compliance issues, etc.Hands-on training (lab)
• Pre Review / Certification / Post Review• Assignment & ReportingAssignment & Reporting
Faculty Effort Reporting Session per Dept Audience: FacultyOn demand as requested by the department (let us know!)On demand as requested by the department (let us know!)
Brown Bag SessionsERS system update, Reports overview, Others as requested
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requestedOne-on-one assistance
Contact your Effort coordinator
Effort Reporting
H d d h l ?Have you attended these classes? Trainings Classes Available for Effort Administrators:1 Attend the Research Administration Training Seminar offered by1. Attend the Research Administration Training Seminar offered by
Office of Research Integrity (ORI) prior to attending Effort 101
2. Attend Effort 101 (contact your Effort Coordinator)
3. In addition to Effort 101, the following classes are strongly recommended b f ft Eff t 101before or soon after Effort 101:
FASIS• HRS101: FASIS Lookup Training• HRS102: FASIS Deployed Funding• HRS102: FASIS Deployed Funding• HRS103: FASIS Temp Administration• http://www.northwestern.edu/hr/hris/training/index.htmlProject Café NUFinancials/InfoEd class
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j• FMS505: Managing Sponsored Projects• http://cafe.northwestern.edu/cafe/calendar/course.jsp?uid=FMS505-0001-
Effort Reporting
Effort Reporting System Support & Project Contact
NetID and password support1-4357 (NUIT)NetID and Password Security:NetID and Password Security:http://www.it.northwestern.edu/netid/security.html
Effort Reporting Operational SupportJennifer Wei (7-2473)
• Tina Mete (Chicago/Evanston 1 6755)• Tina Mete (Chicago/Evanston, 1-6755)• Erin Farlow (Chicago, 3-0323)
Effort Reporting
Any Any Any Any Questions?Questions?