Effort Reporting & the Effort Certification System

The Office Of Grants Management

Frequently Asked Questions

• What is effort reporting?

• Who can certify an effort certificate?

• How should faculty calculate their effort?

• How often do I have to certify?

• My effort certificate is incorrect, should I certify?

• My effort is incorrect again what should I do?

What is Time and Effort Reporting

• Time and effort reporting is required by federal regulations (OMB Circular A-21: Principles for Determining Costs Applicable to Grants, Contracts, And Other Agreements with Educational Institutions) and Howard University’s policy for anyone that receives federal funding

• Time and effort reporting is also required for individuals’ salary that are included in cost share

What is Time and Effort Reporting• Time and effort reporting reflects an after-the-fact,

retrospective, verification of employees’ distribution of activity

• According to the OMB Circular, professors and professional staff must certify “timely”.

• Howard University’s policy requires that all professors and professional staff certify quarterly.Wage employees certify bi-weekly with the submission of their

signed and approved timesheet.

Why is Time and Effort Important

• Federal agencies must report to Congress and to the public how the federal funds are being spent

• Salaries are typically the majority of federal funds

• Time and effort reporting help track the allocation of funds

• Time and effort reporting is required based on our contractual agreement with the sponsor

Who can approve time and effort• Confirmation of salaries is performed by a person with first-

hand knowledge of the effort (OMB Circular A-122, Attachment B.8) or the principal investigator or responsible official(s) using suitable means of verification that the work was performed (Circular A-21, J.10)

• An exact percentage of time is not expected or feasible, but should appropriately reflect a true estimate of time and effort provided (deviation of no more than 5%)

How to Calculate Faculty Effort• The calculation should be based on 100% of the time not 40 hours• The effort should include sponsored and non-sponsored activities

Example:

• The PI worked 50 hours this week• 10 hours teaching• 20 hours completing research• 20 hours completing chair duties

• Teaching 20% (10/50)• Research 40% (20/50)• Chair 40% (20/50)• Total 100%

Sponsored and Non-Sponsored Activities

Sponsored

• Writing progress reports for a current award

• Staff meetings with research assistants on an existing project

• Attending conferences to present research results

Non Sponsored

• Attending departmental staff meetings

• Mentoring junior faculty members

• Writing a new grant

• Serving on a peer review panel

Time and Effort Process

• PeopleSoft generates effort certificates based on payroll records

• Effort Certificates are sent approximately 30 days after the end of the quarter

• The certificates should be completed within two weeks of distribution

• Open houses are available to assist individuals with PeopleSoft issues or to answer questions

My Effort is Incorrect Should I certify?

• Effort Certificates are created based on payroll records

• You can make corrections to the allocation of time using the ECS.

• If a PR was entered late or not at all, the effort certificate maybe incorrect

• The NOA was received after the start of the project

• You should still certify your time with corrections, but follow up to ensure your PR is approved

Consequences of Falsely Reporting Time and Effort

• Fines can be levied

• False reporting can open the University and Principal investigators to civil and criminal prosecution under the False Claims Act

• Reduction in federal funding

• Negative A-133 audit

Consequences of Falsely

Reporting Time and Effort• University of Connecticut - $2.5 million-2006

• Harvard University- $3.25 million-2004

• John Hopkins- $2.6 million- 2004

Consequences of Falsely Reporting Time and Effort

Cornell Medical College

Having been found to have violated three of five charges under the False Claims Act, Cornell was ordered by Federal District to pay $887,714 in total damages. In a formal complaint to the court, whistleblower Dr. Daniel Feldman, a former Cornell fellow, alleged that not only did the fellows spend “less than half” of their research time devoted to studying HIV/AIDS, but that they spent “vast majority” of their clinical work “on patients who were not HIV-infected and who were also paid by private insurance.”

www.costaccounting.org

Consequences of Falsely Reporting Time and Effort

Weill Cornell Medical College

• Agreed to pay over $2.6 million to settle civil charges that Cornell defrauded the National Institutes of Health and the Department of Defense as it sought more than $14 million in federal research grants

• The PI failed to disclose to the Government the full extent of her various active research projects. These omissions deprived the Government of its ability to assess the researcher’s ability to perform the projects in the grant applications. The government alleged that the PI failure to disclose other grants she received allowed her to “over-commit” her professional time, which is prohibited by NIH guidelines.

www.costaccounting.org

Questions