Managing Effort Through the Eyes of Your Collaborators

Joe Gindhart – Washington University&

Lillie Ryans-Culclager – SRI International

Why is effort reporting a big deal?

• Grantees agree to comply with Federal Principles, OMB Circulars A-122 & A-110.

• A-122 requires payroll costs to be documented to ensure that external sponsors reimburse the grantee only for the time and effort actually expended on their behalf.

• Salary costs are the majority of costs incurred on a grant.

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What is effort reporting?

• An individual certifies that salaries charged to sponsored projects are reasonable in relation to the work performed.

• Actual salary dollars are presented as percentage figures (of total salary) on a report or time-sheet.

A-122 Requirements• Salary distribution to awards

supported by “activity/effort” report.–Must reflect after-the-fact determination

of actual activity of employee.– Account for total activity of employee– Signed by employee or responsible

official– Prepared at least monthly

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Staff Effort: Exempt Type• Total activity for which a staff

member is compensated by the entity via a salary.– Regardless of the number of hours

actually worked (100% Institutional Effort).

– Effort varies from individual to individual– Includes all entity activity• Not just Monday through Friday• Not just X days a week

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Staff Effort: Non -Exempt Type

• Total activity for which a staff member compensated by the entity via a wage(s).– Based upon actual hours worked/paid– Includes regular hours and overtime

hours

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Preparingthe Proposal

BudgetCharging

SalaryCertifying

Effort

Post-awardPre-award

AppointingStaff

• Employment terms are established, including # months (contract period), % full time, salary base

Effort Reporting Cycle

• Effort is proposed, a commitment is made to the sponsor

• Effort is charged, contemporaneously with activity

• Effort is attested to, after activity has occurred

The Effort Reporting Process

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• Proper “Effort Reporting” encompasses much more than certification, and includes:– Definitions, policies, procedures, forms, data and systems

• Effort reporting includes management of:– Faculty and staff appointments– Pledging and tracking of institutional effort commitments– Payroll distribution– Effort certification– Communication and training on all aspects of system– Enforcement of policy

Key Policy Issues

• Who certifies for whom?• What is 100% effort?• What constitutes timely certification?• Level of tolerance• De minimis effort

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Key Policy Issues, cont.• Cost sharing• How will you handle training on effort

reporting? Is it voluntary or mandatory?• Setting consequences for failure to

comply with effort reporting policies and practices

Facilitating Compliance• Realistic due date (30, 45, 60

days)• Provide %s and $s• Proxy certifications• Comment box and attachments• Department and central contacts

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Areas of Concern• No effort reports• Salaries not distributed to specific

awards/accounts, within payroll system

• Employees paid from grant but not working on project

• Salary transfers and/or adjustments

Areas of Concern, cont.• Employees not aware that they are

working on grant funded projects• Inconsistent rates of pay• Cost sharing not documented• Cash flow constraints• Expenditure reporting vs. project

progress

Timesheets - Example• Payroll time sheets signed by the employee

and a responsible supervisor, manager or director having first-hand knowledge of the work performed. These time sheets contain:– Hours the employee works– Distribution of employee’s salary over the

different funding sources (in percent effort)– Name and signature of employee’s supervisor– Employee’s signature

Contact Info• Lillie Ryans-Culclager – SRI Int’l– (650) 859-2651– lillie.ryans-culclager@sri.com

• Joe Gindhart – Washington University– 314-935-7089– jgindhart@wustl.edu