Effort Reporting - University of Pittsburgh Office of... · · 2012-12-07Effort Reporting Schedule 1 1/27/2012 Slide 8 • Effort Statements will be certified every academic term

Financial Compliance for Research

Effort Reporting November 2012



Agenda

1. Effort Reporting Basics

2. Key Points to the University’s Effort Reporting Policy

3. Introduction to ecrt

4. Effort FAQ’s

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The 5 W’s of Effort Reporting and Certification

• Who: Effort certification is required for all salaried individuals having effort paid or cost shared on a federal sponsored project. All PI’s will self certify. Effort statements for all other employees with effort on federal sponsored projects will be routed to the PI of the project for certification.

• What: Effort certification is the primary means of verifying that effort supported (paid) by the project and effort expended in support of a project but not paid by the project (cost sharing) has been performed as promised.

• Where: Effort is recorded in the SPAR application which serves as the basis for salary distribution. Effort certification is performed in the ecrt application.

• When: Effort certification for the University of Pittsburgh will be performed three times a year coinciding with the academic terms for all employees expending effort on a federal sponsored project.

• Why: Effort certification is a requirement of federal regulations and the University of Pittsburgh Effort Reporting Policy.

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Research Compliance Overview

• Sponsored awards are made to the University of Pittsburgh, with the Principal Investigator serving as the “steward” of the research project and accompanying funds received from the sponsor

• The University is legally responsible to the sponsor, but the PI is held accountable for the proper fiscal management and conduct of the project. PI responsibilities include:

– Scientific performance of the work related to the project

– Management of the project within funding limitations and in compliance with all reporting requirements

– Sponsor notification when significant conditions related to the project change

– Responsibility for the day-to-day management of project finances may be delegated to administrative or other staff, but accountability for compliance with University of Pittsburgh policy and sponsor requirements ultimately rests with the PI.

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Why Certify Effort?

• Effort Certification is a Federal requirement

– Federal Office of Management and Budget (OMB) Circular A-21 (Cost Principles for Educational Institutions) requires some form of after-the-fact confirmation that labor expenses represent actual cost of work performed.

• Certification is a requirement of the University’s Effort Reporting Policy (http://www.cfo.pitt.edu/fcr/documents/EffortReportingPolicy.pdf)

– The policy establishes responsibility for effective effort reporting and certification in compliance with OMB Circular A-21.

• Effort certification is the primary means of verifying that:

– Effort supported (paid) by the project has been performed as promised, and

– Effort expended in support of a project but not paid by the project (cost sharing) has been performed as promised.

• Labor expenses typically represent the majority of direct costs of research

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What is Effort?

• Effort is the portion of time spent on a given professional activity and expressed as a percentage of the total 100% professional activity for which an individual is employed by the University of Pittsburgh.

• Important points:

– The government recognizes that it is a “reasonable estimate”

– Total effort must equal 100% for each employee, regardless of the number of hours

worked per week or the percentage FTE of their appointment

– Effort is not based on a standard (e.g., 40-hour) work week, instead based on each

employee’s typical level of work performed (e.g., 25, 48, 60 hours per week)

– “100% Effort” considers all professional activities related to the individual’s University

appointment (teaching, research, service, administration)

– Effort does not include outside activities (e.g., external consulting, UPP activities, etc.)

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Effort Reporting at the University of Pittsburgh

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• All employees paid from or with cost sharing to a federal sponsored project are required to have after-the-fact confirmation of direct labor, per federal regulations

• The PI of the Project is responsible for certifying effort statements of all employees on the project EXCEPT other PIs. PIs will ALWAYS certify their own effort statements.


Effort Reporting Schedule

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• Effort Statements will be certified every academic term (The Periods of Performance will be September – December, January – April, and May – August)

• PIs will have 45 days to complete their certifications in ecrt.

• Because of the conversion to the new effort reporting policy, the first certification period will require two separate sets of effort statements to be certified. These Periods of Performance will be July – August 2012 and September – December 2012. All subsequent certification periods will involve only one set of effort statements corresponding to a 4-month Period of Performance.

• The first Certification Period will begin on January 22, 2013 and End on March 7, 2013.

• Subsequent Certification Period schedules will be posted to the Financial Compliance for Research website, http://www.cfo.pitt.edu/fcr/ecrt.php.


2. Key Points to University’s Effort Reporting Policy

• Faculty/PI responsibilities:

– To be aware of his/her effort on sponsored projects and all other University obligations. Communicate this effort and any significant subsequent change to the Department Administrator.

– PI’s must ensure reasonableness of effort distributions for all employees on his/her sponsored projects, including effort certification.

– All PI’s must contribute some level of effort on his/her sponsored projects, regardless of the availability of sponsor funding. Amount of effort reported should reflect time necessary to oversee all aspects of work.

– Faculty will be asked to justify 100% research effort. Activities including proposal writing, departmental meetings, advising students, etc. cannot be charged to sponsored projects.

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Key Points to University’s Effort Reporting Policy

• Two-term faculty must recognize a portion of institutional effort during the summer for activities not related to sponsored projects.

• Salary Reallocations greater than 90-days must be fully documented and approved by Research Compliance Committee.

• Chairs and Deans are responsible to ensure that PI’s comply with all aspects of effort reporting policy.

• Labor costs associated with uncertified effort may be removed from the sponsored project and charged to the unit responsible for the sponsored project.

• All faculty and staff with sponsored research responsibilities are required to participate in mandatory systems and compliance training as needed.

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3. Introduction to ecrt

• ecrt is a web-based Effort Certification System to facilitate compliance and increase productivity.

• Effort statements are required to be certified for all employees having effort paid or cost shared to a federal sponsored project.

• Effort Statements include one line for each unique account number on the SPAR form. The percentages of Actual, Distributed and Cost Share effort represent the average percentage for the 4-month period.

– For example, if an employee begins work on a new sponsored project on November 1 st to which he devotes 10% effort, his actual effort on the Sept-Dec effort statement would be 5%. (2 months @ 0% + 2 months @ 10% = 5% average for the 4 month period).

• Descriptions of activity on the effort statements include the Project Title for PI ease of identification.

• All PI’s will self-certify. Effort statements for all other research staff are automatically routed to associated PI(s) for certification.

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Introduction to ecrt (Con’t)

• Automatic Notifications (emails)

– Notification is sent automatically to Effort Coordinators when effort statements are available for pre-review.

– Notification is sent automatically to PI when effort statements are ready for certification.

– There are links present throughout the system that allow the PI to email the associated Effort Coordinator (fiscal administrator) for assistance.

– Reminder emails will be sent throughout the 45-day certification period to notify PI of outstanding certification responsibilities. Reminders will cease upon completion of all required certifications.

– Reminders of outstanding certifications will be escalated to the Chair/Dean as appropriate.

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Certifier Proxy and Designee

• Designee – authorized delegation of certification responsibilities on a specific sponsored project to another individual (other than the PI) with first-hand knowledge of the work performed. Examples include:

– Project supervision by a lead lab tech

– Supervisor/Manager of work performed in a remote location

• Proxy – authorized delegation of certification responsibilities for the PI’s personal effort statement. Examples of situations include:

– Serious illness

– Months spent in a remote location with no internet access

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Certifier Proxy and Designee (Con’t)

• Fiscal Administrators are not suitable Proxy or Designee Certifiers.

• Justification is required for either certification reassignment.

• Request Forms are available on the FCR website.

• All requests are subject to approval by the CFO or his designee.

• Proxy/Designee must have suitable means of verification to certify effort.

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4. Effort FAQ’s

• What causes an effort statement to require certification?

– Any individual who is paid (or cost shared) on a Federal Sponsored Project during a period of performance will have an effort statement that needs to be certified.

• Who certifies for an employee that works on federal sponsored projects for more than one PI?

– Each PI will have access to the effort statement of the employee. However, each will only have access to certify his/her project(s).

• Who is responsible for certifying the Sponsored Non-Federal and Non-Sponsored lines of an effort statement?

– As federal guidelines require us to account for 100% of an individual’s time, the effort statement may contain accounts for Non-Federal sponsored projects or Non-Sponsored activity. The PI who hired the individual is responsible for certifying ALL Sponsored Non-Federal and Non-Sponsored lines of the effort statement.

• How and when will July-August activity be certified?

– July-August activity will be certified electronically using the ecrt system in January 2013.

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Effort FAQ’s Continued • What is the process for getting approval for SPAR modification over

90 days?

– Complete the Request for SPAR Reallocation Greater Than 90 Days form available on the FCR website prior to making the modification.

– Provide a complete explanation as to how the error occurred, why the adjustment was not made timely and a plan to ensure that this situation will not be repeated. Attach all supporting documentation.

– Attach a marked -up copy of the SPAR with changes indicated.

– Modifications must meet one of the approved exceptions on the request form.

• What can I do to limit the number of requests for 90-Day exceptions in my department?

– Complete an Early Account Request through the Office of Research.

– Review level reports every month to identify incorrect charges and make modifications timely.

– Be proactive in discussing faculty effort on projects to identify activity changes as they occur.

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Effort FAQ’s Continued • How is the 90-day window calculated?

– The 90-day window expires at the end of the third month following the month end of the original charge. For example, if the initial charge occurred in June, any modification would need to be made by September 30.

• Is there an easy way to print a SPAR form, or all SPAR forms in our Department?

– Yes, the development team will be releasing instructions very soon for generating a SPAR report , available for download or printing, for an individual SPAR or for an entire RC or Department.

• Sometimes when I log in to the SPAR application the ‘Query Only’ box is checked and I am unable to make any modifications. Why does this happen?

– The SPAR application is unavailable for update nightly after 9:30 to accommodate daily systems processing. During the month-end closing processes, the SPAR application is not available for update from 5:00 p.m. on the 2nd working day of the month through 6:00 a.m. on the 5th working day of the month. Please log out ending your session before these posted times. Any modification attempted may jeopardize the integrity of the University’s payroll distribution data. You may log in during the update restriction as the application is available in query mode.

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Ask the OR Summary Please continue to:

• Become familiar with the Effort Reporting policy available on the FCR website.

• Identify all employees to be Effort Coordinators in your area and have them register for an EC Training session

• Submit effort, SPAR, or ecrt questions to the [email protected]

• Refer employees with new SPAR or ecrt responsibilities to the FCR website for training materials. Beginning in the spring, we will offer effort reporting, SPAR and ecrt classes through the Human Resources Faculty and Staff Development Program.

• Thank you for attending today!

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Documents

Effort Reporting - University of Pittsburgh Office of... · · 2012-12-07Effort Reporting Schedule 1 1/27/2012 Slide 8 • Effort Statements will be certified every academic term