effort commitments on sponsored projects office of sponsored programs
DESCRIPTION
What should I know?TRANSCRIPT
Effort Commitments on Sponsored ProjectsOffice of Sponsored Programs
Why are we talking about this?
• The federal government has made effort reporting a top target for audits.
• NSF’s Office of the Inspector General (OIG) is making the rounds of research universities.
• The Department of Justice is involved, filing charges under the False Claims Act.
• Many universities have had to pay millions of dollars in fines.
What should I know?
10
Effort is your work or your time on an activity, sponsored or non-sponsored.
9
Your total effort is capped at 100%.(Sorry, over-achievers.)
8A commitment of effort on a sponsored project must be based on a good faith estimate of the amount of time planned to carry out the project.
7Effort on a sponsored project
can take two forms:
Committed Effort =Paid (Direct) Effort +
Contributed (Cost-Shared) Effort
6Proposed effort becomes an obligation of effort if/when the project is awarded that
must be met.*
5
If you’re working on your bee grant, don’t charge your ant grant.
4If you say that you’re working 100% on a sponsored project, you better be working
100% on that project.
3
Effort should be charged when it is expended, and reasonably align with salary.*
2Effort must be certified by someone with the best firsthand knowledge and suitable means of verifying that the work was performed.
1Effort reporting and certification is not an
exact science. Reliance is placed on justifiable estimates.
Tracking Effort
Certifying EffortTRAC
KING
EFF
ORT
Polic
ies &
Pro
cedu
res
Syst
ems a
nd F
ram
ewor
k
Expending/Charging Effort
Acknowledging Effort
Proposing Effort
Proposing a Commitment of Effort
IBS, time, etc. Principal Investigators Good faith estimate
IBS, time, etc. DRAs/Dept. Support Staff Help PIs put together proposals/budgets
IBS, time/buyout Academic Administration Plan workloads/release times, approvals
Policies/Procedures OSP/VPR Provide assistance, oversight
ROLES
CONCEPTS
Effort is proposed and budget is prepared (based on IBS, % Time, Duration)
Acknowledging Effort Commitment
INOA Principal Investigators Acknowledge award, conditions
INOA, Comm. Report DRAs/Dept. Support Staff Assist PIs with adjustments
if necessart
INOA, Comm. Report Academic Administration Track PI time
INOA, Comm. Report OSP/VPR Record and disseminate info
ROLES
CONCEPTS
Commitment is reported and published in INOA.
Expending and Charging Effort
Time, Appt, $ Principal Investigators Comm w/staff
Appt/Position DRAs/Dept. Support Staff Make appointments
Appt/Position Academic Administration Approve appointments
OSP/VPR Assist with adjustments, provide oversight
ROLES
CONCEPTS
Appointments are made commensurate with work.
Certifying Effort
ECRT Principal Investigators Certify effort (self and support staff)
ECRT/Comm Report. DRAs/Dept. Support Staff Assist PIs with certification
Comm Report Academic Administration Track certifications
ECRT OSP/VPR process certifications, assist PIs with ECRT
ROLES
CONCEPTS
Effort is attested to after the fact.
Assessment of risk at the institutional and system level led to this revamping of how
we talk about effort at UTSA.
SO, Why are we talking about this?
• It’s federal policy.
• It’s not new; it may just sound unfamiliar because of the recent changes.
SO, Why are we talking about this?
“The most important obstacles in effort reporting compliance are misunderstanding and denial, and sometimes one obstacle feeds on the other.”
Robert J. Kenney, Jr.Director, Grants and Contracts Practice
Hogan and Hartson LLP, Washington, DC“Time and Effort Reporting: Overview and Risk Assessment”
Report on Research Compliance, January 2006
Auditors look for indication that certification was based on factors other than actual,
justifiable effort.
SO, Why are we talking about this?
Audits & Investigations:
Who Does What?Office of Sponsored Programs
Who Audits?• Sponsored research projects are subject to
audit by a variety of offices and agencies:
• Internal Audit (UTSA Auditing and Consulting Services)
• State of Texas• UT System• Department of Health and Human Services• Individual Sponsors
Federal OIG
Purpose of Audits• Verification of Good Fiscal Stewardship
• Recommendations for Areas of Improvement
• Due Diligence Regarding Whistleblower Allegations
• Investigation and Establishment of Consequences if Findings Uncover Wrongdoing
Role of the Auditor• Auditors are not “The Bad Guys.” • Auditors provide the important function of keeping
the system in balance and protecting the public. • Especially when referring to federally sponsored
projects, auditors and their work provide assurances that we are good fiscal stewards of the people’s money.
• Occasionally, the auditor provides valuable feedback and advice to management for making improvements to the process.
Role of Central Research Administration
• Central research administrators from OSP play the role of host.
• OSP is the main point of contact between the auditors and institutional staff, coordinating interviews, monitoring the flow of information, and ensuring that the auditors have appropriate space and equipment.
• OSP monitors the audit to ensure that the audit is conducted within the rules of accepted audit practice and to ensure that the audit is conducted within the originally-defined scope.
• The Vice President for Research has the final say in responding to the audit on behalf of the University.
Role of the PIs and Support Staff (yes,
you)
• Provide information/documentation as necessary• Agree to answer questions/meet with auditors
within established parameters• Assist OSP with any and all information requests
The Audit Process
The Audit Letter
• Serves as initial notification to the University
• Should clearly define scope of the audit and dates.
• Should provide sufficient time to pull appropriate documents and schedule office space for auditors.
Entrance Conference
• Also called entrance interview, the auditor will conduct an initial meeting with the principal investigator, business managers, compliance officials and representatives from OSP.
• The purpose of the Entrance Conference is to define the scope of the audit and lay the ground rules for the audit.
Audit Fieldwork• Assess the competence and attitude of the
University central administrators as well as the principal investigator and departmental business personnel.
• Looks at our internal control system, i.e., policies and procedures, and monitoring mechanisms.
• If the University makes a good impression, the auditor will develop an audit plan, selecting transactions on a sample basis to verify that the system is working.
• If the University makes a bad impression, the auditor will have no choice but to “look at everything.”
Exit Conference
• At the end, auditors will discuss their “findings” with central administrators during an “Exit Conference/Interview.”
• It is the job of central administration to know the regulations and defend the University if we are operating within the rules (and to concede if we are not).
Findings and Impacts
• Following the visit, and depending on the type of audit, the University will receive a written report with audit findings
• The University may or may not have the opportunity to respond to the findings
• In certain cases, audit findings prompt changes to university processes and procedures
• In particular cases, audit findings may require involvement of other agencies of the Federal Government (e.g. DOJ)
Audit Tips• Do not make the auditors do your work; pull
the records for the auditors.
• Do tell the truth and answer questions honestly and directly.
• Do not do the auditors’ work for them; limit your response to the question being asked.
• Call a central administrator if you ever feel uncomfortable about the way an audit is being conducted.
Audit Tips• Do not tamper with or manufacture records. If
you have no records, say so. This is not the time to make records!
• Be alert. Auditors may not know the regulations applicable to your project as well as you do.
• Auditors are people too. Kindness and respect go a long way.
Remember...• All audits of sponsored grants and contracts
must be coordinated through OSP. If an auditor contacts you directly, please refer them to OSP.
• Do not allow an external auditor or investigator to look at documents or interview personnel without the involvement of these central offices.
• Do not allow the FBI, attorneys, or any other investigators of law enforcement officials to proceed with an investigation without involving OSP.