Effort Reporting November 9, 2005

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Effort ReportingNovember 9, 2005

• Eric Cottington
• Associate Vice President for Research

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Agenda

• Background
• Regulations
• Challenge
• Action Plan
• Results to Date
• Next Steps

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Background

• Effort is the proportion of time spent on
  professional activities such as research,
  teaching, administration, service.
• Effort Reporting is the method of
  documenting the proportion of time devoted to
  these professional activities as a percentage of
  total professional activity.
• Effort not necessarily calculated on a
  40-hour workweek.
• Payroll and effort distributions are not the
  same thing.

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Effort Reporting per OMB Circular A-21 (Section
J Part 8)

• Most universities use after-the-fact
  activity record systems
• Distribution of salaries and wages are
  supported by activity reports that
• show the percentage distribution of activity of
  employee
• are signed by the employee, principal
  investigator, or responsible official(s) using
  suitable means of verification that the work was
  performed
• reflect activity applicable to each sponsored
  project
• are prepared each academic term, but no less
  frequently than every six months.

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Challenge

• Reporting is complicated and time-consuming.
• Federal policy interpretations lack flexibility
  to accommodate diverse university activities and
  compensation arrangements.
• Blurred lines among researchers activities
• Research versus patient care
• Multiple funding sources for research with
  overlapping purposes
• Policies that discourage or prohibit accurate
  calculation of institutional base salaries when
  compensation comes from outside of the
  institution
• Recent governmental enforcement
• Northwestern University 5.5 Million settlement
• Johns Hopkins University 2.6 Million settlement
• Harvard University 3.3 Million settlement
• University of Alabama-Birmingham 3.9 Million
  settlement
• NIH has specific requirements for including
  clinical practice compensation as part of base
  salary for effort reporting purposes

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NIH requirements regarding clinical practice
compensation

• Clinical practice compensation must be set
  by the university
• Clinical practice activity must be shown on
  the universitys payroll or salary appointment
  forms and records approved by the institution
• Clinical practice compensation must be paid
  through or at the direction of the university
• Clinical practice activity must be included
  and accounted for in the institutions effort
  reporting and/or payroll distribution system
• University must assure that all financial
  reports and supporting documents associated with
  the combined institutional base salary and
  resulting charges to NIH grants are retained and
  made available to federal officials

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Action Plan

• Create Effort Report Taskforce
• Review all NIH K awards, which require
  substantial effort commitments (gt 50)
• Revise SOM faculty appointment form to formally
  acknowledge effort in teaching, research,
  clinical care, and service
• Develop Effort Reporting policy
• Revise Effort Reporting Procedures
• Create Effort Reporting Website
• Pilot test of revised effort reporting
  procedures
• Implement revised effort reporting procedures for
  entire university

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Effort Reporting Website
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FAQs

• Who is subject to Effort Reporting?
• Every individual who devotes effort to sponsored
  activities, whether this effort is paid or
  unpaid, is subject to effort reporting

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FAQs

• What is 100 effort?
• The total amount of effort expended to
  accomplish the professional activities of Case
  faculty, staff, and students regardless of the
  actual number of hours expended on those
  activities.
• This normally includes all effort expended
  on Case-compensated sponsored research,
  administration, teaching, unsponsored scholarly
  activity, and other activity and, in the case of
  clinical faculty, clinical activity compensated
  by clinical practice plans.
• 100 per cent effort is not defined as a
  single, standard number of hours or days per
  week, since it will likely be different for each
  person and may vary during the year.
• The number of hours implicit in an
  individuals 100 effort must be reasonable and
  supportable to department, school, university and
  external reviewers, if requested.
• In most circumstances, a minimum of 40
  hours (assuming a full-time schedule) and a
  maximum of 80 hours would be considered a
  reasonable average work week.

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FAQs

• Can the total effort listed on the Effort
  Certification Form be less than or greater than
  100?
• No. The effort percentages on the Effort
  Certification Form must total 100 - neither more
  or less.
• All Case compensated effort (and for
  clinical faculty, Case compensated effort and
  hospital or practice plan compensated effort)
  must be accounted for and obviously the sum of
  the individual effort categories cannot be
  greater than 100.
• Again, just because an individual may work
  more than a normal 35- or 40-hour week does not
  alter this rule.
• For example, an individual who spends 40
  hours a week on sponsored research and 40 hours a
  week on clinical activity would report an effort
  percentage of 50 percent for each category,
  totaling 100 percent for the report period.

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FAQs

• Are there some sponsored projects where I can
  report 0 effort?
• Individuals are expected to commit some level of
  effort (gt0) on sponsored projects on which they
  are listed as a principal investigator or key
  personnel.
• Exceptions to this guideline are equipment and
  instrumentation grants, doctoral dissertation
  grants, student supplement grants, and
  institutional/individual training grants (for
  faculty mentors).

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FAQs

• Who should sign the Effort Certification Form?
• The person completing and signing the Effort
  Certification Form must be someone with
  first-hand knowledge of the effort expended.
• This is required to ensure that the effort
  reporting system reasonably reflects actual
  effort expended in the various categories during
  the report period.
• In general, this is the individual whose
  effort is being reported. At Case, faculty on
  sponsored projects will certify their own effort.
  
• Non-faculty key and other personnel
  (including graduate students, post-doctoral
  fellows, research assistants) will have their
  effort certified by the department administrator
  via the PeopleSoft time reporting system.

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FAQs

• How often are Effort Certification Forms
  completed?
• For schools or colleges within the university
  that provide faculty with 12-month appointments,
  Effort Certification Forms are completed
  semi-annually, based on the fiscal year. The Form
  for the period from July 1 to December 31 is
  completed in January of every year. The Form for
  the period of January 1 through June 30 is
  completed in July of every year.
• For schools or colleges that provide faculty with
  academic year (or 9-month appointments), Effort
  Certification Forms are completed three times a
  year, i.e., in the month following the end of
  fall semester, in the month following the end of
  spring semester, and in the month following the
  end of summer semester.

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On-Line Effort Certification

• PROCESS

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On-Line Effort Certification E-mail to Dept.
Admin.

• From Eric Cottington Sent Tuesday, February
  28, 2006 551 PMTo Eric CottingtonSubject
  Effort Reporting - 7/1/05 - 12/31/05
• Effort Reporting 7/01/05 12/31/05
• In order for Case to remain in compliance with
  federal regulations governing sponsored project
  activities, faculty must certify their effort on
  these activities at least every six months. To
  this end, the attached spreadsheet provides the
  salary allocation detail in PeopleSoft for
  faculty in your department who have charged
  salary to sponsored projects from 7/1/05 through
  12/31/05.  The effort certification forms for
  these faculty have been pre-populated with
  percentages derived from this salary
  distribution.  At your earliest convenience,
  please use this information and other information
  you may have (e.g., practice plan compensation or
  other sources of compensation) to prepare the
  effort certification forms in Spiderweb and route
  them to the affected faculty for their
  certification.    
• To prepare the forms, go to the following website
  and enter your Case network ID and password. 
  Select Effort Reporting from the menu.  You will
  then see the names of the faculty who need to
  certify their effort.   Click on their name to
  prepare their form.
• https//addison.ra.cwru.edu/spiderweb/
• These forms need to be reviewed and completed by
  the faculty in your department no later than
  April 1, 2006.  Your assistance in this effort is
  greatly appreciated

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On-Line Effort Certification Website
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On-Line Effort Certification Website
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On-Line Effort Certification Website
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Definitions
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification Form
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On-Line Effort Certification E-mail to Faculty

• -----Original Message-----
• From Research Administration
• Sent Friday, March 10, 2006 212 PM
• To pxc5_at_cwru.edu' Resadm Send
• Subject Effort Certification Form for the period
  07/01/05 - 12/31/2005
• On-Line Effort Certification Form
• Case has recently changed its procedures for
  effort certification. Each faculty member
  involved with sponsored projects must now certify
  his or her own effort for specific reporting
  periods. The purpose of this e-mail is to notify
  you that an On-Line Effort Certification Form has
  been prepared by your Department Administrator
  for you to review and certify. Please go to the
  following URL to access your effort certification
  form
• http//showcase.case.edu/spiderweb/
• Enter your Case ID and password. Under the
  Compliance section, select Effort Reporting.
  This will bring up the latest Effort
  Certification Form for you to review and certify.
  If you have any questions about the data
  reported on the form, please contact your
  Department Administrator. Please do not make
  any changes without first consulting your
  Department Administrator. Please complete your
  review and certification no later than April 1,
  2006. More information about Effort Reporting
  including those to contact with questions can be
  found at the following URL
• http//addison.ra.cwru.edu/research/effort/index.c
  fm
• If you believe you have received this e-mail in
  error, please contact your Department
  Administrator.
• Thank you.

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Example 1

• Faculty member with total compensation below NIH
  salary cap
• Case salary distribution by activity for
  six-month reporting period

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On-Line Effort Certification
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Example

• If one or more of the sponsored projects started
  after the beginning of the reporting period, the
  percent effort based on salary distribution will
  be different than the percent effort proposed.
• This can be explained in the comment box on the
  form. This effort also may not differ
  significantly, i.e., by 5 or more, from what was
  proposed anyway.
• If the percent effort on the Steris grant was not
  directly charged, the percent effort should be
  listed in the cost share cell.

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On-Line Effort Certification
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Example 2

• Faculty member with total compensation above NIH
  salary cap
• Case and practice plan salary distribution by
  activity for six-month reporting period

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On-Line Effort Certification
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Example 2

• Faculty member with total compensation above NIH
  salary cap
• Case and practice plan salary distribution by
  activity for six-month reporting period

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Example 2

• Since the six-month NIH salary cap would be
  90,050, the percent effort directly charged to
  NIH grant 1 and NIH grant 2 needs to be revised
  as follows
• NIH Grant 1 (.10 x 90,050)/100,000 9
• NIH Grant 2 (.20 x 90,050)/100,000 18
• The difference between the percent effort listed
  in the previous table and the percent effort
  based on the NIH salary cap is cost share.

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On-Line Effort Certification
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Next Steps

• Revise on-line form and process based on pilot
  test results
• Assess staffing requirements to administer effort
  reporting process including training, data
  integration, analysis and reconciliation and
  acquire additional resources
• Implement revised effort reporting system
  university-wide by the end of February 2006
• Integrate Case payroll and clinical/VA
  compensation so that pre-populated effort
  certification form is more accurate