effort certification why and how david knight and trish haugaard

EFFORT CERTIFICATION

Why and How

David Knight and Trish Haugaard

WHY DO WE HAVE EFFORT CERTIFICATION?

Effort reporting is a requirement of the Federal Government.

In order to receive Federal funding the institution must maintain an effort reporting system.

DEFINITION OF EFFORT CERTIFICATION

EFFORT Work or the proportion of time spent on any

activity and expressed as a percentage of University time. It does not equate to a 40 hour week or fixed number of hours.

CERTIFY

Assert in writing the correctness of something.

WHAT IS THE PURPOSE The Effort Reporting System provides the

ONLY means for certifying that the salaries charged to sponsored research projects are consistent with the effort devoted to the project.

It is the only documentation for the majority of direct charges on sponsored accounts.

How Often do we need to Certify? Emory uses a six month certification period We certify for Sept. thru Feb. and for March

thru August. To successfully manage effort you will need

to track it throughout each 6 month period and proactively adjust for changes

PROACTIVE EFFORT MANAGEMENT Being proactive eliminates the headaches

that can occur when effort certification deadline is near.

If not managed properly, some problems are not fixable at the time of certification.

Being proactive means reviewing a PI’s effort on a regular basis and knowing what has been committed as well as proposed commitments.

PROACTIVE – CONT. Always check the NOA to confirm the effort

commitment. If the investigator becomes over committed

due to a new grant now is the time to take corrective action.

Always keep the investigator up to date on their time commitments.

WHAT CAN YOU DO TO MANAGE EFFORT? Keep a spreadsheet or data base to track

committed and proposed effort. You can use the OSP data base (see

instructions at end of presentation) or use the effort system developed by Pathology by contacting Andrew West ([email protected])

Other ways are in development including GSIMS.

mailto:[email protected]

EFFORT CERTIFICATION GUIDELINES An investigator can never be paid 100% from

sponsored accounts and have other responsibilities such as teaching, administrative/committee work, departmental chair, etc.

The Emory policy will allow an investigator to be committed up to 95%, it MUST be less if they have other commitments.

PIs of grants, clinical trials, pharmaceutical grants, etc. MUST show effort

EFFORT CERTIFICATION GUIEDLINES

If you have a very well funded investigator check each proposal to make sure that they have the time available if it were to be funded. Have a plan in place if they become too committed (which grant can they reduce effort on/when would they contact the agency to reduce committed effort).

EFFORT CERTIFICATION GUIDELINES

The Effort Certification Form is considered a legal document.

Signing a faculty members Effort Certification Form would be like signing their tax return (not a good idea).

EFFORT CERTIFICATION GUIDELINES Salary can only be paid on a grant in

proportion to the effort devoted. Since the effort certification period at Emory

is 6 months, investigators must reflect effort on their federal projects on each effort report.

Investigators must notify the sponsor if their committed effort on a federal project decreases by 25% or more.

WHY OMB Circular A-110:C.25©

When a PI is absent in excess of 90 days from his/her project, and or effort is less that 25% or more from budgeted effort, approval must be obtained from the sponsoring agency.

http://www.whitehouse.gov/omb/circulars/a110/a110.html


Effort Certification reports must be submitted by the established due date.

Late reports are almost always suspect to federal auditors.

Auditors have been increasingly known to reconcile “Current Support” on proposals with the effort certification system.


WHO SHOULD CERTIFY?

anyone paid from or cost shares to a sponsored account (5 ledger and 6 ledger greater than 6-37xxx).


Signer must understand what they are signing and “KNOW” the effort.

The investigator must sign the document, only they can attest to how their time was allocated.

A PI could sign for a person in his/her lab IF they are able to testify to the effort expended on their grant.


Individual Supervisor Principal Investigator Blue Ink

AUTHORIZED SIGNERS

The signer must understand what they are signing and "know" the effort. Business managers should not sign for entire departments. Administrative and accounting personnel should not sign for faculty. The signer should be as close as possible to the work performed. The academic unit may require a second signature. A space has been provided for this optional signature.

COST SHARING

Cost sharing is the difference between the effort expended on a project and the effort that is paid for by a project

Federal Salary Caps

COST SHARING

Only salaried effort on the ECR form can be used for reporting cost-share to sponsors.

No salary can be used for match purposes unless shown on the ECR.

Federal (HHS) Funding?

YES

*is faculty member paidover the salary cap?

(lowest cap is $125,900)

NO

no recalculations necessary

YES NO


check NOA to seewhat cap the grant was funded under

COST SHARING

the following reflects the time frames (from when the grant was awarded) associated with the existing salary caps:

Federal Salary Caps

See website for prior year awardsFY 2002 AwardsOctober 1, 2001 through December 31, 2001 $161,200January 1, 2002 through December 31, 2002 $166,700 FY 2003 AwardsOctober 1, 2002 through December 31, 2002 $166,700January 1, 2003 through December 31, 2003 $171,900FY 2004 AwardsOctober 1, 2003 through December 31, 2003 $171,900January 1, 2004 through December 31, 2004 $175,700 FY 2005 AwardsOctober 1, 2004 through December 31, 2004 $175,700January 1, 2005 through December 31, 2005 $180,100 FY 2006 AwardsOctober 1, 2005 through December 31, 2005 $180,100January 1, 2006 through December 31, 2006 $183,500

http://grants.nih.gov/grants/policy/salcap_summary.htm


YES



NO


YES NO



Funds available

Limited fundsIf there are no extra funds available within the existing budget, must use salary cap under which it was awarded

You can use NEW caps (up to $183,500) to calculate cost share

check w/ PI

COST SHARING

Awards issued will not be adjusted by NIH. If adequate funds are available within the existing budget, and if the salary cap increase is consistent with the institutional base salary, grantees may rebudget to accommodate the new salary cap levels.


YES



NO


YES NO



Funds available

Limited funds

check w/ PI

COST SHARING

K AWARDS NIH K awards have special effort requirements

Effort percentage listed is minimum requirement Cannot be reduced (25% rule does not apply) All effort does not need to be shown on K award,

can include other federal research K awards can be used for cost sharing

Person Months

Transitioning to the SF424 Research and Related (R&R) has introduced a new business practice for measuring effort devoted to a grant - person months. Personnel working on projects now indicate effort by indicating the number of calendar, academic, and/or summer months. The PHS398 has also been revised to reflect this new effort measure

Person months - Is the metric for expressing the effort (amount of time) personnel devote to a specific project. The effort is based on the type of appointment of the individual with the organization; e.g., calendar year (CY), academic year (AY), and/or summer term (SM); and the organization's definition of such. For instance, some institutions define the academic year as a 9-month appointment while others define it as a 10-month appointment.

http://grants1.nih.gov/grants/policy/person_months_faqs.htm

Person Months

Conversion of percentage of effort to person months is straight-forward. To calculate person months, multiply the percentage of your effort associated with the project times the number of months of your appointment. For example:

25% of a 9 month academic year appointment equals 2.25 (AY) person months (9 x .25= 2.25)

10% of a 12 month calendar appointment equals 1.2 (CY) person months (12 x .10 = 1.2)

35% of a 3 month summer term appointment equals 1.05 (SM) person months (3 x .35= 1.05)

http://grants1.nih.gov/grants/policy/person_months_faqs.htm

Person Months vs. Percent Effort The addition of Person Months does not

change how we track effort. We still need to tie percent of time to

monthly salary paid.

THE RISK OF NON-COMPLIANCE

Severe penalties and funding disallowances could result from inaccurate (False Claims), incomplete, or untimely effort reporting.

Effort Certification is currently on the Federal government’s list of major audit areas.

THE GOVERNMENT TAKES THESE VERY SERIOUSLY

The Federal Government considers falsifying an effort report to be FRAUD.

Principal investigators found to have falsified effort reports have been suspended from receiving federal funding.

CRIMINAL AND CIVIL LIABILITY

Individuals may be fined up to $250,000 and face 5 years imprisonment. Civil penalties for each false claims is between $5,000 and $10,000 plus THREE times the amount of damages which the Government sustains because of the act of the defendant.

GENERAL COMPLIANCE ENVIRONMENT

Since 1966, financial penalties resulting from audits of sponsored research have increased from $237 million to $1.9 billion.

Since 1966, the number of convictions of individuals or entities that engaged in improper compliance activities has nearly quadrupled. 533 in 2004 alone.

UNIVERSITITES IN THE NEWS Northwestern University: $5.5 million plus

attorneys’ fees and disallowances. Thomas Jefferson University: $2.6 million Johns Hopkins University: $2.6 million Harvard University: $3.3 million THIS IS A LIST WE DON’T WANT TO BE

ON!

effort certification why and how david knight and trish haugaard

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