Effort Reporting at UNR

M I C H E L E D O N D A N V I L L E

R E S E A R C H C O M P L I A N C E P R O G R A M M A N A G E R

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M D O N D A N V I L L E @ U N R . E D U

The Goals of Effort Reporting

1) Are we charging sponsors the correct amount of personnel expenses?

2) Have we met our effort commitments?

What is effort?Effort is time spent on any activity that benefits the institution and for which a person is compensated.

It is expressed as a percentage of an employee’s total institutional activities during a specific period of time, such as a semester, month, or an overload period.

◦ Examples of Institutional Activities

◦ Conducting research

◦ Writing proposals

◦ Instruction

◦ Advising students

◦ Supervising employees

◦ Serving on internal committees

◦ Attending required training

◦ Clinical activity

◦ Administrative Assistance

Why Do We Do Effort Reporting?As recipients of federal funding, educational institutions must abide by 2 CFR, Part 200, which are the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

Section 200.430: Compensation for Personal Services◦ “Budgets estimates alone do not qualify as support for charges to Federal awards, but they may be used for

interim accounting purposes.”

◦ “The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges….All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable and properly allocated.”

The federal government requires that salary charges are consistent with actual effort in order to ensure that a sponsor is only charged for the amount of effort that directly benefited the project.

How do we certify effort?

The after-the-fact verification is accomplished at UNR through the web-based Effort Reporting System (ERS).

In ERS, each individual certifies how he or she actually spent the time for which they were compensated.

What effort gets counted?

Non-Exempt (classified) employees’ effort period = contractual work week.

Exempt employees (salaried) are paid to use whatever time is necessary to complete their assigned Institutional Activities. Effort period = standard weekdays, evenings, weekends…..

Who must report effort?

All faculty, staff, and students working on sponsored projects must certify that:

1. the proportion of their salary expensed to the project reflects a reasonable estimate of their actual effort on the project, and

2. they met their effort commitment.

When do we report effort?

Classified employees report monthly in ERS◦ ERS reports are based on pay periods, not payroll dates

◦ Classified monthly reports show the two pay periods of the month

When do we report effort?

“A” Contract Faculty report effort twice annually◦ January – June effort is reported in July

◦ July – December effort is reported in JanuaryJan - JuneReport in

July

July - DecReport in

Jan.

"A" CONTRACT REPORTING PERIODS

When do we report effort?“B” contract faculty have two additional effort reporting periods in ERS

◦ Sponsored projects overload effort in December, January and Spring Break is reported in May

◦ Sponsored projects overload effort in May, June, July and August is reported in October

◦ Jan & July reports only capture contract period effort

Fall contractAug - DecReport in January

Spring contractJan - May

Report in July

Summer overloadReport in October

W/SB overloadReport in

May

"B"CONTRACT REPORTING PERIODS

Effort report for Summer OVL 2012 – reporting period 05/01/12 - 09/30/12

Only Earning Code OVL is captured on this effort report

B-contract faculty effort report for July – December 2012 academic period

Overlapping reporting period, but only contract effort is captured. OVL effort is excluded from report.

Overload PAF Deadlines

Summer OVL – submitted by 1st business day in September

Winter/Spring Break OVL – submitted by 1st business day in April

“It is not acceptable to store effort from a semester and pay overload during a non-contract day. Semester effort must be reported on a semester effort report. Overload effort must be earned during non-contract days.” University Administrative Manual, section 2695

Effort is “captured” through payroll

Example:

“A” contract faculty

Reporting period = January – June

Total Institutional Salary = $40,000

If % of effort paid for an activity does not reflect actual effort, we need to adjust payroll.

How accurate does an effort report need to be?

“It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to Federal awards for IHEs, a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.”

UNR’s degree of tolerance: up to 5%

What if payroll expenses need to be corrected? Payroll cost transfers involving sponsored project accounts must be:

◦ Timely:

◦ Within 90 days of the posting of the expense

◦ Before the last 45 days of the project

◦ Prior to effort certification

◦ Use a PR-45 if within 2 weeks of an effort reporting period

◦ Through the Effort Reporting System (ERS) otherwise

◦ Cost transfers are audit RED FLAGS – be proactive with PAFs

Cost Transfer vs. Cost ShareEffort committed on a sponsored project can be:

1. Directly paid by sponsor by charging a sponsored project account

2. Initially paid by non-sponsored account, then transferred to project account = Cost Transfer

3. Paid by non-sponsored account = Cost Share

Types of cost share that must be reported in the Effort Reporting System:

Mandatory Committed Cost Share: required by sponsor

Salary-cap Cost Share: when Institutional Base Salary exceeds a sponsor’s salary cap

Voluntary Committed Cost Share: not required by sponsor, but committed in proposal

Payroll does not capture cost share, so it must be reported in the Effort Reporting SystemPlease notify the CA if you need an effort report created for cost share.

The effort cycle

Typical sponsored project cycle:

1. Proposal budget – we offer effort (an estimate)

2. Awarded project set up – we commit effort (PAF is based on an estimate)

3. Work (effort) is started

4. Personnel expenses charged to sponsored project (based on estimate in PAF)

5. Departmental review to check for accuracy and errors

6. PR-45 for payroll cost transfers and/or revised PAF

7. Effort reporting – confirmation of actual effort

Effort Reporting System (ERS) process1. Effort reports are generated by OSP from payroll records

2. Pre-Reviewer reviews for accuracy and makes necessary adjustments (cost transfers and/or cost sharing).

3. Certifier reviews effort report for accuracy. If accurate, s/he certifies report and process is complete.

4. If Certifier makes changes, Post-Reviewer reviews for accuracy then completes process.

Who’s Responsible for What?Principle Investigators (PIs) are responsible for being certain that every individual working on their sponsored project has completed an effort report.

Administrative units are expected to facilitate sponsored project management in order to enable the timely and accurate submission of effort reports.

The Office of Sponsored Projects (OSP) ◦ Is responsible for providing oversight of the University’s effort reporting

system and designing and implementing the effort reporting policies and procedures.

◦ Conducts training on the effort reporting system and the related policies and procedures.

Roles in ERS1) Central Administrator (CA)◦ Manages the Effort Reporting System◦ Generates Effort Reports◦ Provides support for all users

2) College Administrator◦ Reviews progress of effort reporting in division

3) Departmental Coordinator (DC)◦ Determines routing in their department◦ Can do Pre and Post Reviews, or can delegate◦ Monitors for completion of effort reports in their department(s)

Roles in ERS4) Pre-Reviewer/Post-Reviewer:◦ Ensures that payroll distributions are correct

◦ Works with other departments to verify effort distribution, if necessary

◦ Initiates any adjustments, such as cost transfers or cost share

◦ Communicates with the Central Administrator about any problems or concerns

◦ Assists certifiers

◦ Keeps tabs on who has and hasn’t certified, and nudge delinquents in the right direction

5) Certifier:

◦ Reviews each effort report

◦ Works with Pre-Reviewer to make any adjustments

◦ Certifies that the effort report is a reasonably accurate representation of the work performed

Who can certify an effort report?“I certify that the proportion of my salary expensed or cost shared to each of the accounts on this effort report represents a reasonable estimate of my actual effort on each activity during this reporting period. Or, in the event that I am certifying effort for someone other than myself, I have first-hand knowledge of the employee’s effort during this reporting period.

I understand that falsification of effort statements may result in potential disallowed costs, penalties and/or actions under the Federal False Claims Act.”

The Certifier must be one of the following:

◦ Employee

◦ PI with first-hand knowledge of the employee’s effort

◦ Supervisor with first-hand knowledge of an employee’s effort

Certified effort reports are finalOnce an effort report is certified, it is considered final.

No revisions may be made to effort report except under very rare circumstances.

Effort Reporting DeadlinesProposed policy:

All effort reports must be certified within 28 days from the date the pre-reviewers receive initial notification that the effort report has been generated.

Failure to certify within 28 days will result in the following:◦ Late Notice

◦ Delinquent Notice: 14 days after the late notice

◦ PI’s account will be put on Administrative Hold until reports are certified

◦ Exception for clinical trials

Where does the information in ERS come from?

Uploaded from HR only once per reporting period.

Includes:◦ Employee name and ID

◦ Department

◦ Accounts: sponsored projects accounts and non-sponsored projects accounts

◦ Details on each paycheck received during reporting period

Each employee is assigned to:

1. Division

2. Department/Subdepartment

3. Pre-Reviewer

4. Certifier

5. Post-Reviewer

Please (pretty please) notify CA if any of the above needs changing

Welcome to the Effort Reporting System

https://effortreporting.unr.edu/GenericERS/custom/index.jsp

Log into ERS with your UNR NetID and password

Questions?THANK YOU FOR YOUR TIME!