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Effort Commitments on Sponsored Projects Office of Sponsored Programs

Effort Commitments on Sponsored Projects Office of Sponsored Programs

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Page 1: Effort Commitments on Sponsored Projects Office of Sponsored Programs

Effort Commitments on Sponsored ProjectsOffice of Sponsored Programs

Page 2: Effort Commitments on Sponsored Projects Office 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.

Page 3: Effort Commitments on Sponsored Projects Office of Sponsored Programs

What should I know?

Page 4: Effort Commitments on Sponsored Projects Office of Sponsored Programs

10

Effort is your work or your time on an activity, sponsored or non-sponsored.

Page 5: Effort Commitments on Sponsored Projects Office of Sponsored Programs

9

Your total effort is capped at 100%.(Sorry, over-achievers.)

Page 6: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 7: Effort Commitments on Sponsored Projects Office of Sponsored Programs

7Effort on a sponsored project

can take two forms:

Committed Effort =Paid (Direct) Effort +

Contributed (Cost-Shared) Effort

Page 8: Effort Commitments on Sponsored Projects Office of Sponsored Programs

6Proposed effort becomes an obligation of effort if/when the project is awarded that

must be met.*

Page 9: Effort Commitments on Sponsored Projects Office of Sponsored Programs

5

If you’re working on your bee grant, don’t charge your ant grant.

Page 10: Effort Commitments on Sponsored Projects Office of Sponsored Programs

4If you say that you’re working 100% on a sponsored project, you better be working

100% on that project.

Page 11: Effort Commitments on Sponsored Projects Office of Sponsored Programs

3

Effort should be charged when it is expended, and reasonably align with salary.*

Page 12: Effort Commitments on Sponsored Projects Office of Sponsored Programs

2Effort must be certified by someone with the best firsthand knowledge and suitable means of verifying that the work was performed.

Page 13: Effort Commitments on Sponsored Projects Office of Sponsored Programs

1Effort reporting and certification is not an

exact science. Reliance is placed on justifiable estimates.

Page 14: Effort Commitments on Sponsored Projects Office of Sponsored Programs

Tracking Effort

Page 15: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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

Page 16: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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)

Page 17: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 18: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 19: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 20: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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?

Page 21: Effort Commitments on Sponsored Projects Office of Sponsored Programs

• 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?

Page 22: Effort Commitments on Sponsored Projects Office of Sponsored Programs

“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

Page 23: Effort Commitments on Sponsored Projects Office of Sponsored Programs

Auditors look for indication that certification was based on factors other than actual,

justifiable effort.

SO, Why are we talking about this?

Page 24: Effort Commitments on Sponsored Projects Office of Sponsored Programs

Audits & Investigations:

Who Does What?Office of Sponsored Programs

Page 25: Effort Commitments on Sponsored Projects 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

Page 26: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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

Page 27: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 28: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 29: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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

Page 30: Effort Commitments on Sponsored Projects Office of Sponsored Programs

The Audit Process

Page 31: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 32: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 33: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.”

Page 34: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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).

Page 35: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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)

Page 36: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 37: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.

Page 38: Effort Commitments on Sponsored Projects Office of Sponsored Programs

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.