effort certification cynthia moore spa compliance analyst (503) 494-1885 mail code: ad220...

Effort Certification

Cynthia MooreSPA Compliance Analyst

(503) 494-1885Mail code: AD220

[email protected] Sponsored Projects Administration

Why are we Here ?

Compliance is a challenge

“Always do right. This will gratify some people and astonish the rest.” -Mark Twain

Sponsored Projects Administration

Lifting the Burden…Raising the Standard

• Semi-annual reporting for all employees paid on sponsored accounts.

• Responsibility to adhere to the 90-day fund change standard.

• Our opportunity to prove that EC can be captured through other systems.


Effort Certification - PURPOSE

OMB Circular A-21Section J8a, Compensation for Personal ServicesRequires It!

Sponsoring agencies require accurate and reasonable documentation to support that labor charged to sponsored accounts is consistent with effort expended.


OMB Circular A-21 Section J8a Compensation for Personal Services

• Charges are supported and documented

• Conformity to the policies of OHSU.

• Consistently applied


Risk of Non-compliance

Severe penalties and funding disallowances could result from inaccurate (False Claims), incomplete, or untimely effort reporting. University of Minnesota Canadian Food Grains Bank/PHP


Risk of Non-Compliance

We become a target!Danger of losing our Expanded

Authority!


Who is Subject to EC?If Employee Activity is:

• Partially or totally devoted to a sponsored agreement, i.e. grants & contracts between the institution and the federal Government or a Pass-Through entity.

• Partially or totally committed to Mandatory or Voluntary Committed cost-sharing for sponsored agreements.

And Pay is:

• Partially or totally paid from a sponsored project account, excluding clinical trials.

• From a departmental fund account or other non-federally funded account.


Who is Subject to EC? – Continued

• Providing direct patient care for which a professional fee is billed.

• Selecting, supervising and training of house staff (interns, residents, and fellows). Includes recruitment, teaching and teaching preparation time, and post session activities. See “Education Time” under Part III Definitions.

• From any OHSU Fund.



• Providing Medical Director and administrative services for OHSU Hospitals & Clinics, (e.g., medical directions, serving on a hospital committee, supervising hospital employees, or participating in quality control and utilization review.)




• Supervising and training of students in allied health programs (such as nursing, dietetics, pharmacy, radiation oncology, or medical technology) concurrently with providing patient care related activities in OHSU Hospitals & Clinics.




• Other activities such as teaching university medical students, conducting research, or providing direct patient care without the involvement of an intern, resident, or fellow.




Effort Certification - DEFINITION

Effort is the work or proportion of time spent on a particular activity and is expressed as a percentage of total time spent conducting University business. For unclassified employees, 100% effort is defined as the total time spent on University/Hospital business, which includes work performed outside of the normal work schedule, work performed on vacation, and work performed off-campus. Furthermore, an individual’s appointment serves as the basis for that individual’s total effort. Thus, if an employee has a 50% appointment, 100% effort consists of the entire 50% appointment.


For classified employees, 100% effort consists of the total hours worked, including overtime. Thus, if a classified employee works 10 hours of overtime on top of a 40-hour week, 20 hours devoted to an individual project represents 40% effort, not 50%.

Effort Certification - DEFINITION


What is Payroll?

Net Effort Payroll consists of: Salary & Wages Other payroll expenses such as Medical Insurance, all payroll related taxes

Non-effort Payroll consists of: Bonuses, health plan rebates, and other one-time payments not directly associated with labor.


Certify

Definition:

Assert in writing

the correctness

of something.

This is a legal andThis is a legal and

binding document!binding document!


Who Can Certify?

Confirmed by responsible persons with suitable means of verification that the work was performed:

+ Who has DIRECT knowledge of the individual’s effort

+ Quarterly, for HEC employees, and semi-annually, for employees paid on grant funds, a statement will be signed by the employee, PI or responsible official(s) that the work was performed, stating that salaries and wages charged to sponsored agreements as direct charges are reasonable in relation to work performed.


Signature Authority

Whenever possible, the Effort Certification Statement should be signed directly by the employee. In lieu of the employee’s certification, the Effort Certification Statement may be signed by a person with suitable means of verification that the labor distribution is representative of the total work performed. This implies that the certifier must have direct and complete knowledge of all of the employee’s time spent on University activities. This person is usually a Principal investigator or direct supervisor of the employee.


IMPORTANT

IT IS NEVER PROPER FOR A DEPARTMENTAL EFFORT COORDINATOR OR DEPARTMENT HEAD TO SIGN ALL OF

THE EFFORT CERTIFICATION STATEMENTS IN HIS OR HER

UNIT/DEPARTMENT!


A Closer Look

• Effort Certification Packet:

Memorandum

Control log (For DEC use)

Effort Certification Statements


ECS Control Log

SOM 63000 DEPARTMENT OF MEDICINE

Name SSN Salary Grade

Account Title Fund-Org-Provider

Gross Payroll

Non-Effort Payroll

Net Effort Payroll % Payroll

63000-2000-2-11-1-00001

DANDY, JIIM ACADEMIC NIH SPECIAL RESEARCH FOR CAMPBELL SOUPG141-63000-21-0000 5,000.00 5,000.00 61

465-25-8879 UNIVERSITY GENERAL FUND0151-63000-11-0000 3,500.00 330.00 3,170.00 39

8,500.00 330.00 8,170.00 100

63000-2001-3-11-1-00002

DOE, JOHN ACADEMIC ANIMAL X-RAY LABH383-63000-21-0000 2,500.00 2,500.00 36

555-44-3232 UNIVERSITY GENERAL FUND0151-63000-11-0000 4,730.00 330.00 4,400.00 64

7,230.00 330.00 6,900.00 100

Department Total: # of Statements 2 15,730.00 660.00 15,070.00

Distributed to: JONES, MARY

63000 Department of Medicine

L456

Non-effort dollars consists of monies paid out during the quarter for adjustments not realted to hours w orked. These include but are not limited

to bonus payments and retroactive pay for unclassif ied employees; shift or holiday differential for hourly employees; and insurance rebates.

Payroll

OREGON HEALTH & SCIENCE UNIVERSITY

EFFORT CERTIFICATION STATEMENT CONTROL LOG

REPORTING QUARTER ENDING SEPTEMBER 2001

PAY PERIODS 14 THROUGH 20

HEC


Effort CertificationStatement Control Log

• Gross Payroll – Gross payroll is the total amount paid to the employee over a fixed period of time.

• Non-Effort Payroll – Non-effort payroll is money paid to the employee that does not relate to services or work performed. This includes bonuses, health plan rebates, and other one-time payments not directly associated with labor, and which are therefore excluded from the effort base.

• Net Effort Payroll – Net effort payroll is the difference between gross payroll and non-effort payroll. It represents the total amount paid to the employee for actual services or work performed. Net effort payroll represents total (100%) effort over a fixed period of time.


ECS Control Log - continued

• % Payroll - % payroll is computed by dividing the Net Effort payroll by fund, by the Total Net Effort Payroll.

• % Cost Sharing – Costs that are incurred for the sponsored projects that are not funded by the project. Mandatory cost sharing refers to the cost sharing that is required by a federally funded grant or contract in writing. Voluntary cost sharing is not explicitly required by the awarding agency, but once included in the budget narrative or award agreement is committed and therefore binding.

• Total Effort % = % Payroll + % Cost Sharing


Effort Certification Statement

School: SOM

NAME: ID # 32451

Fund Org Mission Provider%

Payroll% C/S

Committed% C/S

Uncommitted% C/S Total

0151 63958 11 0000 50 ____ ____ ____ ____ 50 ____

D146 63958 21 0000 20 ____ ____ ____ ____ 20 ____

J333 63959 21 0000 30 ____ ____ ____ ____ 30 ____

Totals 100 0 100

Signature: Print Name & Title (if different than above) Date: Phone:

POLICY NOTES: Only individuals having direct know ledge of all of an employee's effort may certify effort. Where feasible, employees should certify their ow n effort.

In accordance with OMB Circular A-110, prior approval from the Federal sponsoring agency is required if principal investigatiors or projectdirectors will be absent for more than three consecutive months, or a 25 percent reduction in his or her effort devoted to a sponsored project in comparison to the approved budget plan. Contact your SPA accountant.

Salary for this individual may exceed $161,200 ($6,200 bi-weekly). If funded from an NIH award, an adjustment for cost sharing must be made in excess of the capped amount.

I certify that I have direct knowledge of all of the effort reflected in the TOTAL EFFORT column above for this employee. I certify further that to the best of my knowledge the effort reasonably reflects actual effort expended. I understand no changes are allowed once this statement is signed and submitted.

Grant A

Grant B

…………………………………………………………………………………………………

If there are any changes to payroll, please attach a COPY of your PA or Payroll Distribution Funding Change Forms.

Univ. Gen. Fund

First Quarter Fiscal Year 01/02 (July-September):Pay Periods 14 through 20

DANDY, JIM

Department:

TITLE: Assistant Professor

Oregon Health & Science University - Effort Certif ication Statement Control #: 6300-2002-1-11-1-00001

Account Title Total Effort

63958 HEMATOLOGY

Keeping Things in Order

A B

Oregon Health Sciences University - Effort Certifitaion Statement Control #: 63000-2002-1-11-1-00001First Quarter Fiscal Year 2002 (July-September) Pay Periods included are 14 through 20

Unit: School of Medicine Department: 63000 DEPARTMENT OF MEDICINENAME: ATRICKS, JERRY TITLE: Assistant Professor ID#: 38721

Acct. Name Fund Org Mission Provider% C/S

Committed% C/S

Uncommitted % C/S Total

UNIVERSITY GENERAL FUND 0151 63000 11 0000 43 54 0 _-11_ _____ _-11_ 43

RESEARCH SUPPORT G324 63000 21 0000 2 0 _____ _____ _____ 2

FDN SWANK NERV SYSTM RES H475 63202 21 0000 3 0 _____ _____ _____ 3

Heathly Aging and Senile Deme J108 63000 21 0000 26 20 0 _____ __6__ __6__ 26

Alzheimer's Diesease Center Cor H709 63000 21 0000 26 21 0 __5__ _____ __5__ 26

TOTALS 100 0 100

% of Payroll Total Effort


Effort Certification Statementwith Cost Sharing

School: SOM

NAME: ID # 32451


Payroll% C/S

Committed% C/S


0151 63958 11 0000 50 ____ _(10)_ _(20)_ _(30)_ 50 _20_

D146 63958 21 0000 20 ____ _10_ ____ _10_ 20 _30_

J333 63959 21 0000 30 ____ ____ _20_ _20_ 30 _50_

Totals 100 0 100





Grant A

Grant B

…………………………………………………………………………………………………


Univ. Gen. Fund


DANDY, JIM

Department:




63958 HEMATOLOGY

Cost Sharing

• Cost sharing represents that portion of the total project costs of a sponsored agreement borne by the University, rather than by the sponsor. Cost sharing of direct expenditures represents a redirection of departmental or school resources from teaching or other departmental and school activities to support sponsored agreements.

• Considered effort and must be accounted for.


•Can be expressed as a whole percentage, however, must be identified and accounted for on the effort certification statements.

Cost Sharing


Mandatory Cost Sharing

• Required by the agency for award

• Must be accounted for on the Effort Certification Statement as committed.


Voluntary Cost Sharing

• Committed: Where the University has

determined that such a contribution is necessary to ensure the success of a competitive award or proposal.

Becomes binding, once included in the award.

Must be accounted for in the Effort Certification Process as Committed.


•Uncommitted:Not part of the

award document.Internal agreement

with the PI and the University.

Must be captured in the Effort Certification Process as Uncommittted .

Voluntary Cost Sharing


Cost Sharing

• Institutions must capture this cost+NYU Medical settlement of $15

million

• NIH $161,200 Salary Cap


Effort Certification Statement With Negative Effort

School: SOM

NAME: ID # 32451


Payroll% C/S

Committed% C/S


0151 63958 11 0000 50 ____ ____ ____ ____ 50 ____

D146 63958 21 0000 20 ____ ____ ____ ____ 20 ____

J333 63959 21 0000 30 ____ ____ ____ ____ 30 ____

Totals 100 0 100


POLICY NOTES: Only individuals having direct know ledge of all of an employee's effort may certify effort. Where feasible, employees should certify their ow n effort.




Grant A

Grant B

…………………………………………………………………………………………………


Univ. Gen. Fund


DANDY, JIM

Department:




63958 HEMATOLOGY

OHSU HOSPITALS & CLINICS

Francine HarmanHospital Fiscal ServicesPhone: (503) 494-6099


Filling the “Buckets”

• How am I designated as an HEC employee?

• What do I do if I am?

• What if I am not designated but should be?

• What if I am designated and shouldn’t be?


PA Form


General-Changes COA Form


Hospital Effort Certification Statement(HEC)

School: SOM

NAME: ID # 32451


Payroll% C/S

Committed% C/S


0151 63958 11 0000 50 ____ ____ ____ ____ 50 ____

D146 63958 21 0000 20 ____ ____ ____ ____ 20 ____

J333 63959 21 0000 30 ____ ____ ____ ____ 30 ____

Totals 100 0 100

Enter % Effort in the spaces provided by the letter as applicable to the definitions below .

A: Providing direct patient care for which OHSU Hospitals & Clinics bills the professional fees.B: Supervising the training fo housestaff (interns, residents, and fellows) while performing patient care related activities in OHSU Hospitals & Clinics where a bill for professional fees is NOT rendered.C: Providing management and administrative services for OHSU Hospitals & Clinics (e.g., serving on a hospital committee, supervising hospital employees, or participating in quality control and utilization review).

A:_5__ B:_10_ C:___ D:___ E:_85_ = 100%

In accordance with OMB Circular A-110, prior approval from the Federal sponsoring agency is required if principal investigatiors or projectdirectors w ill be absent for more than three consecutive months, or a 25 percent reduction in his or her effort devoted to a sponsored project in comparison to the approved budget plan. Contact your SPA accountant.


Grant A

Grant B

…………………………………………………………………………………………………


D: Supervising and training of students in allied health programs (such as nursing, dietetics, pharmacy, radiation oncology, medical technology) concurrently with providing patient care related activities in OHSU Hospitals & Clinics where a bill for professional fees in NOT rendered.E: Providing services not related to OHSU Hospitals & Clinics. (Such activities include teaching medical students, conducting research, or providing direct patient care which is NOT billed by OHSU Hospitals & Clinics.)

Univ. Gen. Fund


DANDY, JIM

Department:




63958 HEMATOLOGY

Hospital Effort Certification

CODES• A: Providing direct patient care for which OHSU

Hospitals & Clinics bills the professional fees.• B: Supervising and training of house staff (interns,

residents, and fellows) while performing patient care related activities where a bill for professional fees is NOT rendered.

• C: Providing management and administrative services for OHSU Hospitals & Clinics (i.e., serving on a hospital committee, supervising hospital employees, or participating in quality control and utilization review).


Hospital Effort Certificationcontinued

• D: Supervising and training of students in allied health programs (such as nursing, dietetics, pharmacy, radiation oncology, medical technology) concurrently with providing patient care related activities where a bill for professional fees is NOT rendered.

• E: Providing service not related to OHSU Hospitals & Clinics. (Such activities include teaching medical students, conducting research, or providing direct patient care which is not billed by OHSU Hospitals & Clinics.


Challenges with Federal Regulations

• Reporting Based on 100% Effort+Workload not based on number of hours+Full workload can vary from week to week+Instructional effort is constant, predictable+Research effort varies


Issues & Considerations

• PIs Effort

• Compliance, Oversight, and Stewardship

• Timely submission


Compliance, Oversight and Stewardship

• Written policies and procedures

+Define roles & responsibilities+Provide clarity regarding who can certify

• Compliant with federal and institutional policies

• Programs that measure compliance


Where the Rubber Meets the Road…

• Does effort report agree with proposal budget/narrative, progress reports, current and pending support, etc.?


Truth in Advertising

“A little inaccuracy sometimes saves tons of explanation.”Saki (1870 - 1916)


Effort Worksheet

Professor X

Here is the effort you proposed on the grant(s) that you currently have:

Grant A XX%Grant B XX%

How much of your total work time did you actually spend on each of these projects?

Grant AGrant B

OFFICE USE ONLY:

Grant Actual Cost TotalGrant Budget Time PA Sharing Effort


Policies, Procedures, Timeline

• Policy: In EC Info Packet

• Procedure: In EC Info Packet

• EC timeline


• Timely submission - Cited by A-133 Auditors

• Consequences

YOUR ATTENTION PLEASE:


IEC requests managementreport, control log, and Effort

Certification Statementprintouts from ITG on firstbusiness day after fiscal

quarter end.

IEC prepares cover letter,instructions, and FAQ sheet toaccompany packets. IEC also

keeps a copy of themanagement report and control

log for each department andfiles into a binder

Effort Certification Packetsare printed within 5 business

days of fiscal quarter end,and returned to IEC.

IEC packages managementreport, control log, effort

certification statements andcover sheet information and

sends to DEC's within 10business days of fiscal

quarter end.

DEC reviews forms to verifythat they are inline with PA

forms and that all employeeswho are required to certifyreceive a statement. They

then distribute the EffortCertification Statements tothe appropriate employees.

Employee makes necessarychanges to effort certification

statement, and signs toverify that effort is correct.

IEC sends out an e-mail 5business days prior to

deadline to remind DEC's toturn in effort packets.

DEC collects and reviewsstatements and returns to

IEC within 35 business daysof fiscal quarter end.

IEC inputs certificationverification (C) into bannerand verifies that all effort

reported equals 100%, andthat each ECS is signed in

ink.

If effort information ischanged on ECS, IEC

changes data in banner toreflect appropriate effort and

cost sharing.

Mass Effort template inBanner totals the number of

completed ECS for eachdepartment, and IEC inputs

this total to delinquencyreport spreadsheet.

IEC files ECS'salphabetically by person inFY file. Most recent 2 FYdata is kept in active file

cabinet while past FY data isstored in boxes.

IEC will begin follow-upprocess for delinquent EffortCertification Statements until

all ECS are turned in.

Page 1

OHSU Effort Certification Process

IEC- Institutional Effort Coordinator

DEC- Departmental Effort Coordinator

Effort Certification Process

Effort Certification Timeline

Task/Quarter First–HEC Employees

Second–ALL Employees

Third--HEC Employees

Fourth--ALL Employees

Quarter Begins. 10/ 01/ 01 1/ 02/ 02 4/ 01/ 02 7/ 01/ 02

ORPRC submits suborg file and SPA submits Effort Coordinator file to ITG.

10/ 01/ 01 1/ 02/ 02 4/ 01/ 02 7/ 01/ 02

IEC requests Effort Certification Packets to be printed from ITG. 10/ 01/ 01 1/ 02/ 02 4/ 01/ 02 7/ 01/ 02

ITG prints Effort Certification Packets and sends to SPA. 10/ 08/ 01 1/ 08/ 02 4/ 08/ 02 7/ 15/ 02

IEC Distributes Effort Certification Packets to DEC's. 10/ 15/ 01 1/ 15/ 02 4/ 15/ 02 7/ 15/ 02

DEC's must have all Effort Certification Statements completed and returned to IEC.

11/ 19/ 01 2/ 21/ 02 5/ 20/ 02 8/ 19/ 02

IEC sends e-mail to DEC's with delinquent ECS, as reminder of deadline.

11/ 28/ 01 2/ 28/ 02 5/ 28/ 02 8/ 28/ 02

Call and follow-up e-mail to DEC's from IEC to stress importance of Effort Certification Process.

12/ 05/ 01 3/ 04/ 02 6/ 04/ 02 9/ 04/ 02

Letter sent to Department Chair or Unit Director from SPA Director notifying them of DEC/ PI non-compliance with Effort Policy.

12/ 19/ 01 3/ 18/ 02 6/ 18/ 02 9/ 18/ 02

All Payroll Adjustment forms which accompanied ECS must be reviewed and authorized by the SFA's, and sent to Payroll for processing.

12/ 19/ 01 3/ 18/ 02 6/ 18/ 02 9/ 18/ 02

Letter sent to Dean from SPA Director notifying them of DEC/ PI non-compliance with Effort Policy.

12/ 28/ 01 3/ 25/ 02 6/ 25/ 02 9/ 25/ 02

All adjustments must be entered into Banner database. 12/ 31/ 02 3/ 29/ 02 6/ 28/ 02 9/ 30/ 02

Quarter Ends. 12/ 31/ 01 3/ 29/ 02 6/ 28/ 02 9/ 30/ 02


What’s my line?

Verify system/process for compliance

Independent internal evaluation to ensure the system’s integrity and compliance

Establish programs to monitor compliance

Audit effort statements to ensure labor depicts effort

Interview employees, Department Effort Coordinators.


Thank you for coming and participating in this Workshop

The success of this program lies, in a big part with the Department Effort Coordinator and Department

Chair.

Without you, it would be impossible for us to reach all of the individuals who must certify their effort and

complete the process in a timely manner.


ANY OTHER QUESTIONS???


effort certification cynthia moore spa compliance analyst (503) 494-1885 mail code: ad220...

Documents

sponsored accounts

ohsu fund

sponsored agreements

sponsored project account

mark twainsponsored

policies of ohsu

ohsu hospitals clinics

day fund