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UCSF INTRO TO EFFORT REPORTING
Table of Contents
Introduction FAQs Definitions Related Information Contacts
Introduction
Effort reporting is a process mandated by the federal government to verify that salary and wages charged to federally sponsored projects are reasonable estimates in relation to the actual work performed. An effort report is an “after the fact” certification of activities for which the employee was compensated by the institution. Cost sharing commitments must also be confirmed. All faculty who serve as investigators on federally sponsored agreements are personally responsible for certifying the amount of effort that they and their employees spent on sponsored activities. This guide provides an overview of effort reporting. Please refer to this link http://acctg.ucsf.edu/ers/index.htm for additional information.
What is effort?
An individual’s effort is expressed as a percentage of the total amount of time spent on work-related activities (instruction, research, patient care, administration, etc.) for which the University compensates an individual. For example, if an individual works 1,000 hours in a six month reporting period, the individual’s effort per activity is expressed as a percentage of those 1,000 hours. Effort always equals 100% of the total number of hours worked.Why must effort be certified?
The federal Office of Management and Budget’s OMB Circular A-21 "Cost Principles for Educational Institutions" defines what costs are allowable and allocable to federal grants and other agreements. It sets forth criteria for acceptable methods of charging salaries and wages to federally sponsored projects, and requires that institutions follow acceptable methods for documenting the distribution of activity for all project personnel. Certification must be done by individuals who have first-hand knowledge of 100 percent of the employee's compensated activities. It is mandatory for us to comply with OMB Circular A-21.What are the risks of not complying with OMB Circular A-21?
Non-compliance has real costs for individuals and the organization. Effort reporting audits are a high priority for federal auditors; several recent audits have resulted in multi million dollar fines to major universities. Such fines can erode confidence in the institution, leading to a significant decrease in other sponsored funding/donor giving. Worst case scenario is debarment from receiving federal funds for up to five years.How can we prevent institutional or individual disallowances?
- Sound effort reporting policies, procedures, and systems which promote compliance with OMB Circular A-21 have been put in place by the University
- Individuals follow the university’s policies and procedures in addition to OMB A-21
- The effort reports are certified by the employee or someone who has first-hand knowledge of 100 percent of the employee's time
- The effort report encompasses all of the activities performed by the employee under the terms of their employment
- The levels of effort reported appear reasonable, given the responsibilities of the individual
- The individual’s certified report is not re-certified several times after the initial certification
FAQs
How must effort be reported?
The government does not prescribe a standard method for providing the assurances required under Circular A-21, but it does identify specific criteria for an acceptable method and provides examples. UCOP and the five major research campuses, including UCSF, followed these criteria when developing the UC-wide Effort Reporting System.
What information appears on the Effort Report?
The Effort Report is an after-the-fact report that reflects how an individual spent his/her time on various activities during the reporting period (faculty every six months; staff every three months).
The Effort Report shows the percent of effort spent on a project (and whether that effort was funded solely by the sponsor or also by other sources) and the percent of salary charged to that project. The percent of effort should be consistent with what was agreed to by the investigator and the sponsor. Also, t he percent of effort spent on a federally-sponsored project should not be less than the percent of salary charged to the project. All other effort (the “base effort”), including instruction, organized research, departmental research, clinical activity, and public service funded from non-sponsored project funds, is reported as “non-sponsored activity.”
What is included in my base effort?
Base effort represents time required to fulfill the employee’s obligation to UCSF for which the university compensates an individual. Base effort must total 100% even if the appointment is less than full time. Compensation for incidental work such as intra-university consulting, honoraria, and lump-sum payments, work unrelated to base effort (e.g. UCSF extension courses), by agreement payments and premium overtime is not included .
What is cost-shared effort?
Cost sharing represents that portion of the total project costs of a sponsored agreement that are not borne by the sponsor of the project. Cost sharing can be either committed or uncommitted.
Commited Mandatory Not Quantified in Award or Proposal Budget or Narrative Incidental Reference Documentation without specific % time/hrs committed in narrative is ok.
If Sponsor required Cost Sharing as terms of award: Mandatory
If Department included extra 10% effort without associated pay in proposal budget/ narrative and sponsor did not require: Voluntary Committed
If no commitment to effort over 20% is noted in proposal budget or narrative:Voluntary Uncommitted
- Mandatory/Voluntary Committed cost sharing is always included in an Effort Report.
- Voluntary Uncommitted Cost Sharing should not be included in an Effort Report.
How precise does my stated effort have to be?
UCOP policy states that “Effort Reports at UC may be completed with a preciseness tolerance of +/-5%” per activity. In the example below, 32% of the salary was charged to the grant. This report can be certified at 32% as long as her actual effort was anywhere between 27-37%. In fact, it is preferable to do so because certifying this effort report at anything other than 32% will require a payroll expense transfer (PET) be submitted to force the salary to match the effort.
How is the salary distribution calculated on an effort report?
Two Payroll DOS code attributes--Pay Category and Type Pay--are used to determine which payments are included in the salary distribution of an Effort Report. Pay Category N ( Normal) and Type Pay 1 (Regular), 2 (Overtime Straight), or 5 (On Call) are included. All other Pay Categories and Type Pays are not included.
Payments made on certain commonly-used DOS codes do not meet the above criteria and will always be excluded from the Effort Report calculations; e.g.,
BYA - By Agreement IAP - Incentive Award Payment STP - Stipend TRM - Terminal Vacation Pay VLT - Vacation Leave Transfer WOS - Work Without Salary VAC - Vacation SKL - Sick Leave HON - Honorarium How does the Effort Reporting System handle over-the-cap salaries?
Federal awards from the NIH, AHRQ and the SAMHSA typically restrict the amount of direct salary paid on their grants, commonly known as the “salary cap.” This is a legislative mandate imposed by congress. In these situations, the Effort Reporting System recognizes that the dollars under-represent the effort and adjusts the Effort Report accordingly.
How does the Effort Reporting System handle effort for K-awards?
K awards are unique in that they often require a certain level of effort but cap the salary that can be charged to the award. Please visit http://ucsflink.ucsf.edu/ERS/JobAid-EffortReportswithK-Awards.pdffor the job aid to see how K-awards are handled for Effort Reporting Purposes.
Is there a minimum effort that must be committed by a PI on a grant?
Yes. UCSF administrative policy 400-10 states that PIs who propose to head an extramurally-funded research, training or public service project must personally participate in the project to a significant degree. The minimum effort must be sufficient to assume oversight of financial, scientific and compliance aspects of a project, and must be in proportion to the size and scope of a project. For UCSF proposals, PIs must commit a minimum effort level of at least 1%.
Is there a maximum salary we can charge to sponsored research?
“At UCSF, for ladder rank faculty, the practice has been to require that, as a minimum, 33% (and preferably 50%) of the fiscal year base salary, be charged to state funds. For in-residence faculty where the majority of salary support comes from non-State funds, and frequently from contracts and grants, a maximum of 95% of salary may be charged to extramurally sponsored projects.” Excerpted from 10/31/96 UCSF memo from D. Bainton to Academic Deans.
The 95% rule does not apply to faculty in the clinical or adjunct series. In-residence faculty (including Clinical Professor of X) can’t be 100% sponsor-funded since these appointments require them to do teaching, research, University and public service. Regardless of appointment type, a proportionate salary should always be charged to institutional funds for activities such as grant proposal writing for competitive awards and well-defined, regular administrative duties.
What is the relationship between my Other Support and my Effort Report?
ERS will take the average over an effort reporting period. Other support data takes into consideration effort for a particular point in time, so the two may not match at a given time.
What other documents could we look at before certifying?
For a faculty member, there may be a variety of sources that report on activity or document the expectations of his or her appointment and may include the following:
- Faculty appointment letters
- Faculty workload reports (often targeted at teaching effort); Productivity Reports
- Teaching schedules (course catalog)
- Clinic, On Call, and/or Surgery Schedules
- Appointment Calendars
- Medicare cost reports
- In the grant proposal: OSR page for cost sharing, PI/faculty agreements, budget/ justification pages, other support page, etc.
- Upon award: Notice of grant award, cost sharing budget forms, salary plan/salary calculator, PAF, etc.
- Progress report documentation (any internal budgets, changes in effort and justification, personnel & OSR form)
- Payroll expense transfer (PET) forms, if any
Departments Effort Report Reviewers, usually RSAs, can assist investigators with tracking, filing, and organizing supporting documentation
Who is responsible for certifying the effort reports?
Both UCOP and federal policies state that Individuals in Professorial, Professional Research, and Management titles should certify their own effort. Staff, postdocs and students do not need to certify Effort Reports; they must be certified by a responsible official who has first hand knowledge of the effort using a suitable means of verification that the work was performed. Typically, administrators such as administrative directors, managers, analysts, assistants, etc, will not be allowed to certify for other individuals if they do not directly supervise the individual performing the work and would not have sufficient and verifiable knowledge of the work being performed, including an understanding of another individual’s regular duties and responsibilitiesHow often do we have to certify effort reports?
Academics and professional employees (MSPs and above) must certify Effort Reports bi-annually
- July-December = Fall
- January-June = Spring
PIs certify staff employees’ Effort Reports quarterly.
- July-September = Summer
- January-March = Winter
- October-December = Fall
- April-June = Spring
What is the timeline for receiving and certifying Effort Reports?
Effort Reports must be distributed within 45 days of the end of the reporting period. Certification of effort reports must be completed within 30 days of distribution.What are the EMF procedures for ensuring compliance?
UCSF now has a system that supports the campus in maintaining and improving a high compliance rate.
- Day 1: E-mail notifications sent to ERCs by ERS – reports available for viewing, reviewing, and certification
- Day 15: Automated e-mail notification to ERCs only
- Day 20: Automated e-mail notification to PIs only, and only if reports are still OPEN
- Day 30: Deadline for effort reports to be certified
- Day 31 – 37: EMF to review delinquent effort reports and send 1 st reminder to ERCs, and Viewers (ERC back-up) requesting they certify reports within 1 week.
- Day 44 – 50: EMF to review delinquent effort reports and send 2nd reminder, Dean’s Office Control Points
In cases of non-compliance, the EMF Compliance Manager will work intensively with MSOs, chairs and/or deans offices to resolve delinquent effort reports. Non-compliance may ultimately result in the transfer of payroll expenses from federal sponsored projects to discretionary funds.
Definitions
Cost Sharing: The terms "cost sharing," "matching," and "in-kind" refer to that portion of the total project costs not borne by the sponsor.
Mandatory Cost Sharing: Sponsor-driven, i.e., cost sharing that is required by the sponsor as a condition for proposal submission.
Voluntary Committed Cost Sharing : Cost sharing funds are not required by the sponsor as a condition for proposal submission, but are nevertheless committed by the investigator in the proposal or ORU sponsor document, with no corresponding funding requested or awarded. This type of cost sharing must be reported in effort reports.
Voluntary Uncommitted Cost Sharing: Voluntary cost sharing funds not pledged in the proposal and subsequently not stated on award documents. This type of cost sharing is above that which was committed and/or budgeted to as part of the award. This is commonly referred to as voluntary uncommitted cost sharing and should not be documented or reported.
Effort: Work or the proportion of time spent on any professional activity and expressed as a percentage of total time. Total effort for an employee must equal 100% (+ or - 1 due to rounding). The appointment serves as the basis for an individual's total effort. In other words, for a 50% appointment, 100% effort is the 50% appointment. Likewise, for a 75% appointment, 100% effort is the 75% appointment.
Effort Report Coordinator (ERC): Effort reporting administrators at the department level who facilitate the distribution and submission of Effort Reports and help others in the department understand the effort reporting system and effort reporting requirements.
Notice of Grant Award (NGA): A document that provides information regarding the award's important terms and conditions. It should provide guidance to the PIs and departments for managing the project.
Sponsored Projects: An externally funded activity that is governed by specific terms and conditions. Sponsored projects must be separately budgeted and accounted for subject to terms of the sponsoring organization. Sponsored projects may include grants, contracts, and cooperative agreements for research, training, and other public service activities.Related Information
Federal Office of Management & Budget - http://www.whitehouse.gov/OMB/circulars/a021/a021.html- Cost Principles for Educational Institutions
Federal Office of Management & Budget - http://www.whitehouse.gov/omb/circulars/a110/a110.html - Uniform Administrative Requirements...
Cost Sharing:
Policies
Federal Office of Management & Budget - http://www.whitehouse.gov/omb/memoranda/m01-06.html - Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs (January 5, 2001) http://policies.ucsf.edu/400/40017.htm http://acctg.ucsf.edu/extramural_funds/policies/Cost_Sharing_One_Page.pdfProcedures: http://acctg.ucsf.edu/extramural_funds/policies/Cost_Sharing_Proc.pdf
FAQs: http://acctg.ucsf.edu/extramural_funds/policies/Cost_Sharing_FAQ.pdf
Council on Governmental Relations (COGR) report March 1, 2007, “Policies and Practices, Compensation, Effort Commitments and Certification” - http://www.cogr.edu/
EMF website - http://acctg.ucsf.edu/extramural_funds/index.htm
Contacts
Anyone with questions or concerns about this policy should immediately contact Wendy Hom, EMF Compliance Manager, Controller’s Office. She can be reached at 476-8688 or wendy.hom@ucsf.edu.
This page last updated on: Thursday June 07 2007
