HSC160 Compliance

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COM Business Office
Compliance
University of South Florida
HSC 160
Compliance Defined
• Effectiveness and efficiency of
operations
• Reliability of financial reporting
• Compliance with applicable laws and
regulations.
Overview of Compliance
Fundamental concepts:
• Internal control is a process
• It’s a means to an end, not an end
in itself
•
Geared toward the achievement of objectives
• Internal control is affected by people
at every level
• Not merely policy manuals and forms
• Provides reasonable, not absolute
assurance
Key Components
5 Key Components of Internal Control
System:
1. Control environment
2. Risk assessment
3. Control activities
4. Information and communication
5. Monitoring
Financial Compliance
As USF employees, we have the Fiduciary
Responsibility to:
1. Confirm valid, authorized purchases are made
from the appropriate funding sources,
2. Validate accurate posting of all expenditures
3. Validate all revenues are received and
deposited timely
4. Confirm staff have the appropriate training to
fulfill their job responsibilities
Financial Compliance (cont.)
5. Safeguard University equipment
6. Identify and take action on fraudulent
activity
7. Review and approve system security
actions
Overview of Internal Controls
Definition of Internal Controls:
Systematic measures instituted by an organization to:
1. conduct its business in an orderly and efficient manner,
2. safeguard its assets and resources,
3. deter and detect errors, fraud, and theft,
4. ensure accuracy and completeness of its accounting
data,
5. produce reliable and timely financial and management
information, and
6. ensure adherence to its policies and plans.
Internal Controls
Remember:
Internal controls do not necessarily ensure success!
Poor internal controls can result in:
1.
2.
3.
4.
5.
Bad Decisions
Poor managers
Unethical behavior
Collusion
Override of controls
Examples of Internal Controls
1. Segregation of Duties: Separate the duties among different individuals
to reduce the risk of error or inappropriate actions.
a) Example: The person who charges expenses to a USF P-Card
should not be the same person to approve those charges in the
FAST System.
Examples of Internal Controls
(cont.)
2. Physical Controls: Assets, inventories, securities and cash are
secured physically and periodically counted and compared to amounts
on control records.
Example: Review list of equipment annually to ensure that all
equipment is documented and accounted for.
3. Reconciliations: Comparisons are made between source documents
maintained by the document’s custodian and the official ledgers.
Example: Reconcile your source documents monthly with the ledgers
available on Finance Mart.
Examples of Internal Controls
(cont.)
4. Policies and Procedures: Established policies, procedures
and job descriptions provide guidance and promote
consistency.
Example: Provide job descriptions for each of your
employees so that they know what their duties are.
5. Transaction and Activity Reviews: Managers compare
information about current performance to budgets, forecasts,
prior periods to measure if goals and objectives are being
achieved.
Example: Compare all source budget with monthly
reconciliations to make sure the department is still operating
within their means.
Procedures for Purchasing
• Requisitions/Purchase Orders must be in place prior to
the ordering of goods or services.
• If you are buying office supplies using State funds, they
must be purchased through Office Depot.
• Any technology/computer item must be purchased
through the USF Computer Store
• Independent Contractor agreements are reviewed and
signed off my General Counsel and Purchasing before
engaging in service.
Procedures for Purchasing (cont.)
Helpful Links:
Computer Store
http://www.computerstore.usf.edu/
Purchasing and Property Services
http://usfweb2.usf.edu/purchasing/
UTSB
http://www.it.usf.edu/purchasing/information/utsb
Procedures for Purchasing (cont.)
Remember Quote Requirements
• Less than $5,000 – you must have one verbal quote
documented.
• Between $5,000 & $25,000 – you must have two verbal
or written quotes documented.
• Between $25,000 & $75,000 – you must have three
written quotes documented.
• Greater than $75,000 – Must be sent out for competitive
bids. Purchasing must certify the bids.
Procedures for Purchasing (cont.)
Single Source: If an item or service is determined to be
non competitive in nature and is only available from one
particular vendor, you can purchase via
single source.
Memberships: Can be purchased via purchase
order if the membership is essential to the duties and
responsibilities of the University.
Contractual Services: Can be purchased via purchase
order, but the contract must be executed prior to the
rendering of the service. The Purchasing Department must
approve prior to initiating PO.
Procedures for P-Cards
Before you Purchase:
• Check for any University policies or processes that you must follow
• Check for any preferred vendors (i.e. Avis, Office Depot)
• Purchase all technology items from the USF Computer Store
• Make sure the total cost of the purchase does not exceed your
single transaction limit
• Have the USF tax exempt number available
• Reference Website: http://usfweb2.usf.edu/pcard/index.html
Procedures for P-Cards (cont.)
• P-Cards can be used for purchases with a single transaction value
of $2,000 or less.
• P-Cards have a monthly limit of $5,000 or less.
• You can NOT purchase equipment (more than $5,000) with a Pcard.
• You can NOT purchase food on the P-card.
• You can NOT pay for contractual Services
• You can NOT pay for Independent Contractors
Procedures for P-Cards (cont.)
Things you CAN purchase:
Things you CAN’T purchase:
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
Office Supplies
Computers less than $5000
Computer supplies
Employment Advertising
Lab Supplies
Printing
Rental Fees
Software under $1000
Subscriptions
Travel charges
Alcohol
Attorneys
Cash Advances
Contractual Services
Flowers
Computers over $5,000
Parking Permits
Personal convenience Items
Plaques/Awards
Shredders
For a complete list of allowable and unallowable purchases,
please see the P-Card website: P-Card Purchases
Procedures for P-Cards (cont.)
Misuse of Card includes:
• Falsification of records
• Fraud
• Theft
• Using the card for personal gain
• Allowing another individual to use your card
• Repeated non-compliance with processes and procedures
• Divulging confidential information
P-Card Audit
What happens once you submit your receipts?
1. Reconciler will match the receipt to the incoming charge in FAST
and approve within 7 business days.
2. Reconciler matches receipts to the monthly bank statement.
3. Reconciler gets cardholder and accountable officer signature.
4. Reconciler submits copy of bank statement and receipts to PCard department
Once your P-Card receipts have been submitted, the P-Card
department reviews all the charges and may contact you for any
questions.
Travel Compliance
Travel Authorization (TA)
•
The completed Travel Authorization is the Traveler’s permission to
incur expenses and to travel and is an estimate of what a specific trip
will cost. The Authorization should list all anticipated Travel Expenses
that are known, or can be projected, before the trip. The TAR should
be submitted prior to any charges are incurred.
•
A Travel Authorization in advance of any travel to a conference or
convention is explicitly required per Florida Statute.
•
Should authorized Emergency Travel be required of an employee that
prohibits prior entry of a Travel Authorization into FAST, a memo is
required indicating the details of the travel and the circumstances that
prohibited adherence to the normal Authorization process, including
evidence that the situation was out of the Traveler’s control.
Travel Compliance (cont.)
Expense Report (ER)
• After travel occurs, an Expense Report is submitted in FAST to
report expenses and/or request Traveler reimbursement.
• The Expense Report will list all expenses associated with the
Travel, whether paid directly by the University or reimbursable
to Traveler.
• Expense Reports must be submitted within thirty (30) days of
last date of travel.
Travel Compliance (cont.)
• USF Travelers will be reimbursed for coach/non-refundable airfare
only
• USF Travelers will be reimbursed for up to a maximum
of two (2) bags.
• Travelers utilizing their personal vehicles are
authorized to be reimbursed at the Florida Statutory
Rate of .445 cents per mile.
• Avis Rent a Car System, LLC, (AVIS) is the Preferred Vendor for
USF Travelers in need of rental vehicles.
Travel Compliance (cont.)
• Taxis, trains, buses, and other mass transit may be used when
these modes of transportation result in a cost savings to the
University. Receipts are required for all ground transportation
regardless of the amount.
• Parking, storage or toll fees under $25 may be reimbursed without
receipts.
• Domestic Travelers will be paid meal allowances pursuant to
FS112.061 (6) (a-c) as follows:
Breakfast
Lunch
Dinner
Total for day
$6
$11
$19
$36
Travel Compliance
• For domestic lodging, justification is required at the time of
reimbursement request if the nightly hotel rate (before taxes)
exceeds $200.
• Meals for all days of Foreign Travel will be reimbursed at the
published Department of State rate for the destination area.
• Foreign lodging should be obtained at or below the published
Department of State rate for the destination area whenever
possible.
Reconciliation
• Reconciling gives you the opportunity to find errors and make
corrections
• Reconcile your ledgers on a monthly basis
• Compare departmental source documentation to the official ledgers
• Notate and follow up on any discrepancies you may find
• Share reconciliation with key people (Supervisor, PI, senior
management)
• Make sure signature authorization and workflow forms are updated
upon hire or termination of an employee
Sponsored Research
• GBR is filled out after an award has been granted to distribute
budget to the appropriate budget account codes based on the
sponsor’s approved budget
• Pay Distribution is updated in a timely manner to align personnel
with the grant proposal/award
• NIH salary caps are taken into consideration and if anyone exceeds
the cap, cost share accounts are set up in a timely manner
**** RETS should consider impact to NIH salary cap before
submitting
Leave Tracking
• All Sick and Annual leave is properly reported in the ALT system in
a timely manner
• Internal documentation is kept within the department as justification
to the ALT leave record
• Leave audits are performed annually
Nepotism
• Definition: an employee has influence or decision making authority
over the employment of a relative.
• “relative” is defined as the husband; wife; parent; step-parent; child;
step-child; brother; sister; half-brother; half-sister; spouse of child,
brother, sister or parent; child, brother or sister of spouse;
grandparent; grandchild; aunt; uncle; first cousin; niece; or nephew
of the employee. “Relative” or “related” person also includes a
person who is engaged to be married to an employee.
• If relatives work in the same area, a nepotism memo must be
signed and approved by the Vice President before work my
commence.
Record Retention
Before disposing of any records, you must review the retention
schedule provided by the state:
http://dlis.dos.state.fl.us/recordsmgmt/gen_records_schedules.cfm
After reviewing the retention schedule, you must submit the Record
Disposition Request Form to Lazara Stinnette, Purchasing and Property
Services at AOC 200.
If your records contain only copies, you do not need to submit a record
disposition request form. These records can be destroyed as soon as
they have served their purpose.
Accounting Best Practices
1. Review all funding sources monthly
a.
b.
Look for errors
Look for fraudulent activity
2. Compare outstanding transactions to
previous transactions
a.
b.
c.
Look for budget errors
Look for chartfield value errors
Look for chartfield combination errors
3. Become familiar with standard transactions
a.
b.
c.
d.
e.
Payroll transactions
P-card transactions
Revenue transactions
Budget transfers
Corrected transactions
Accounting Best Practices
4. Be organized
a.
Create electronic files for easy reference
5. Trust and verify
a.
b.
c.
Check transactions for accuracy and
allowability
Review payroll for unknown individuals
Review reimbursements
6. Locate equipment
a.
Keep a list of all property and include serial numbers and USF tag numbers
Accounting Best Practices
7. Network
a. Join any available list serve
•
FAST
•
GEMS
•
Foundation
•
DSR/RFM
•
Travel
•
Accounts Payable
•
Accounts Receivable
b. Check COMPASS
c. Enroll in Talent Management, TRAIN, or
Business Office Training
EthicsPoint Hotline
• USF has engaged EthicsPoint—a third party hosted hotline—to
enable the safe, secure, and anonymous reporting of activities which
may involve misconduct, fraud, abuse, and other violations of USF
policies. You may file a report by clicking on the To Make a Report
link on the chart or by calling toll-free 1-866-974-U411.
• USF is committed to providing a safe, secure, and ethical place to
work. As a member of the USF community, you have a responsibility
to voice compliance and ethics concerns, so that we can work
together to promptly resolve the issues while helping to cultivate a
positive environment.
• Website
Additional Resources
Audit and Compliance
http://usfweb2.usf.edu/uac/risks.htm
TRAIN
http://www.research.usf.edu/TRAIN/
Controller’s Office Training
http://usfweb2.usf.edu/UCOTraining/
Purchasing Policies
http://usfweb2.usf.edu/purchasing/reg_policy_proc.htm
Records Retention
http://dlis.dos.state.fl.us/recordsmgmt/gen_records_schedules.cfm
Faculty Activity Reporting
Training
USF Health Business Office
Objectives
• What, Who, When, Where, and Why?
• Category Names and Definitions
• Navigation for Faculty
• Questions and Answers
Who and What ?
• Who has to report?
– Faculty, graduate assistants, residents, and faculty
administrators
• What is Faculty Activity Reporting?
– Faculty Activity Reporting (FAR) is a legislatively
State mandated process to report faculty effort within
educational, research, service and other categories.
When and Where ?
• When does FAR have to be done?
– Faculty Activity Reporting is required each
semester - three times per year. Summer
(05), Fall (08), and Spring (01).
• Where do I report my effort?
– Faculty Academic Information Reporting
(FAIR)
Why?
• Why do I have to do this?
– Comply with F.S.S. 1012.945 (12 hour law)
– Comply with Chancellor Memo 87-17.1
– Expenditure Analysis - determines funding
– LCME reporting
– Management reporting
– Historically has been used in Asset
Investment Management System (AIMS)
Categories
And
Definitions
Course Number Anatomy
• Course numbers are in the following
format
BCC 7114 001
Prefix
Section number
(GMS, BMS, BCC, MEL, etc)
(001, 002, 003, etc.)
Number
(7114, 7980, 7814, etc.)
In addition, each course/section has a unique course
reference number:
•Medical courses start with a 7
•Main campus course in summer start with 5
•Main campus course in fall start with 8
•Main campus course in spring start with 1
17 – Clinical Instruction
• Time spent instructing, supervising, and
evaluating House staff (Residents, Fellows, or
Interns (including Clinical Research Fellows) in a
clinical environment.
Note: This would also include advising the above groups.
40 - Academic Advising *
• Formal counseling with students on academic course or
program selection, scheduling, and career counseling.
• Academic advising assignments shall include such
indicators as number of students formally advised by the
faculty member, hours specifically designated for
advising purposes and other appropriate indicators of
advising activity.
• This category is NOT for House staff advisement, which
should be included in Clinical Instruction.
* Backup Documentation Required
25 - Other Instructional Effort *
Instruction-related activities which includes
•
•
•
•
•
•
•
development of new approaches
improvement/revisions of materials for credit courses
participation in planning
development or evaluation of total curricula, program services,
preparing, planning programs,
participation in non-credit generating instructional activities such as
Learning Community, or
mentoring, etc.
* Backup Documentation Required
25 - Other Instructional Effort
Examples
•
•
•
Ex: Administrative assignments as Course Director, Clerkship Director or
Residency Training Director are related to instruction
Ex: Supervision of student ARNP’s in clinical setting
Ex: Participation on the College Curriculum Committee or the Medical
Student Selection Committee
22 - Departmental Research
(Research/ Scholarly Activity w/o external grants) *
•Research activities that are supported by department sources of
funding (NOT Sponsored),
 Duties may include:
– the preparation, planning and conduct or research,
– data analysis,
–manuscript preparation,
–presentation of results, and
–supervision of postdoctoral trainees (not externally funded).
****Department Research may also include the preparation and publication of scholarly reviews,
chapters, monographs and books, as well as the development of new educational approaches or
techniques and other types of medically-related creative activity.
* Backup Documentation Required
32 - Public Service *
• Activities that extend the professional and/or
discipline related services of individuals to the
community, the state, or the nation.
– This includes service in professional organizations
and academic or professional student organizations.
– The primary intent is to provide professional and/or
discipline-related services, other than instruction, that
are beneficial to groups and individuals.
– Such public service shall NOT generate payment
from third party.
* Backup Documentation Required
47 - University Governance *
• Activities that provide advisory support to the general
governance of the unit or the institution.
– Includes participation on department, college or
university committees and councils.
– Includes special assignment such as consultation
services to university offices and units.
• Ex: Participation on the Practice Plan Physician Advisory
Board
* Backup Documentation Required
36 - Paid Patient Care
• Reimbursable activities in a clinical
environment that do NOT involve Medical
Students or House staff.
34 - Clinical Service (Non-Reimbursable)*
• NON-REIMBURSABLE patient care
activities in a clinical environment that do
NOT involve House staff or Medical
Students.
Ex: Bridge Clinic: patients are not paying for
your service.
Ex: Judeo Christian Clinic- patients are not paying for your service.
Although there may be students with you, there may be instances
where the clinic is backed up and faculty see the patients alone.
* Backup Documentation Required
46 – Academic Administration *
• Restricted to individuals with formal administrative appointments.
– Does NOT include direct administrative effort related to a
specific course which should be reflected in the appropriate
instruction category.
– Direct administrative effort related to a specific project, & funded
by the sponsored research, should be reflected in Research
category.
• Ex: Formal administrative appointments such as Dean, Vice Dean,
Associate Dean, Chair, Vice Chair, Director, President, etc…
* Backup Documentation Required
89 - Leave of Absence with Pay
• An authorized compensated leave of
absence granted to the employee by the
university. Examples:
– Disability leave
– Sabbaticals
– FMLA leave
* Backup Documentation Required
Professional Development
• Professional development activities should be reported according to
the category in which they fall in and should be reported as follows:
– President of a professional association: Public Service
– Attendance at a professional conference, meeting or seminar to improve
teaching skill: Appropriate instructional category
– Attendance at a professional conference, meeting or seminar to improve
research or scholarship skills: Departmental Research or Sponsored
Research
– Attendance at a professional conference, meeting or seminar to present research
findings or scholarship: Departmental Research or Sponsored Research
– Attendance at a professional conference, meeting or seminar for general
knowledge and professional networking: Public Service
23 - Sponsored Research (External Grants &
University Internal Research Awards) *
• Separately budgeted and accounted for research; all research
activities that ARE SPONSORED by federal, state, local government
and private organizations.
• Includes all approved grant, contract and industry supported
research activities both basic and clinical in nature.
• Grant related duties include the preparation, planning, and conduct
of research, as well as related data analysis, manuscript
preparation, presentation of results, and supervision of postdoctoral
trainees (externally grant funded).
NOTE: The FTE % must be consistent with those
reflected on Federal Grants & PERT forms.
* Backup Documentation Required
AFD-FAR NAVIGATION FOR
FACULTY MEMBERS
Login
Enter through the USF Administrative Portal
https://my.usf.edu
Login screen
If you do not have a NET
ID, click “Activate your
NETID” to create an ID.
Enter your NET ID
and Password
Note: you can use your health email as your NETID. Ex: hclark@health.usf.edu
You will then use the same password you use to sign into the computer with.
Access to FAIR
• Click “Business Systems” and then scroll
down to “Fair”
Main menu
Once in FAIR, you will click on the
Workload tab to view the FAR
Reports
Semester Selection
Click on the
applicable term
YYYY05 = Summer
YYYY08 = Fall
YYYY01 = Spring
Simplified Medicine Form
Medical
Courses
Masters / PhD
Courses
Grants
Non
Instructional
Activities
Reporting in Percent of FTE
• Why do some faculty member’s FAR not
add up to 100%?
– The Board of Governors require the SUS
system to report effort in FTE %.
– If you are a 100% FTE, your form will add to
100.
– If you are a partial FTE, the form will compute
on the partial FTE
– The next slide is to assist those faculty
members in converting 100% to their FTE %.
Calculation of FTE percentage
Activity
Effort
FTE
FTE %
Academic Advising
25%
*
.50
12.50
Clinical Instruction
Department Res
25%
25%
*
*
.50
.50
12.50
12.50
Public Service
25%
*
.50
12.50
Total
100%
50.00
To convert percentage of effort to FTE %, multiply each line by the
decimal form of your FTE. In the sample above, the individual is a
50% FTE; therefore, you use .50 as the multiplier.
Medical Courses
Click Edit to enter % of FTE
Click Delete to remove the course
Assigning Effort to Medical Courses
1. Click Edit to enter the % of FTE
2. Enter the % for the course. Please take into
consideration the course begin and end dates and the
term begin and end dates.
Masters / Ph.D. Courses
Click Edit to enter %
Assign % of FTE to Undergraduate,
Masters, and Ph.D. Courses
Click Edit to add or change % of FTE and click update
Non-Instructional Activities
4. Backup
Documentation
1. Enter the % of
FTE
3. Must be equal to
each other once the
form is complete.
2. When you finish, click the update button
Supporting Documentation
• Supporting Documentation is required for
certain categories.
– There is a link labeled “Supp Doc” for all
categories requiring explanation. They are all
identified earlier in this presentation.
– State in a paragraph or two what you did for
the category chosen.
Sample of Supp Doc Screen
1. Enter the
supporting
documentation
here
2. Click “Save this
document” when
finished entering.
Certifying the FAR Report

Upon completion and confirmation by faculty that the total of all activities and
assigned FTE match, the “SIGN” button will appear,

The faculty need to select the sign button,

Notify the effort representative in the College of Medicine Business Office (Danny
Woolbright) that all steps have been completed,

Courses will be rolled to Administrative form,

COM will be notify when roll is complete,

You will assign paying and benefitting funding sources,

THE END
AFD-FAR NAVIGATION FOR
Administrators
Login
Enter through the USF Administrative Portal
https://my.usf.edu
Login screen
If you do not have a NET
ID, click “Activate your
NETID” to create an ID.
Enter your NET ID
and Password
Note: you can use your health email as your NETID. Ex:
dshockl1@health.usf.edu
You will then use the same password you use to sign into the computer with.
Access to FAIR
• Click “Business Systems” and then scroll
down to “Fair”
Main menu
Once in FAIR, you will click on the
Workload tab to view the FAR
Reports
Browse by Camp/Coll/Dept
• Enter search parameters and click the
“submit” button
Search Results
Departmental Listing
Pay Plans:
22 – Faculty
06 – Adjunct Faculty
05 – Grad Assist
Click on the blue
hyper link to
access the form
01 – Supplemental Comp
98 – Non-compensated SUS
99 – Non-compensated non SUS
Administrative Form
• There four main sections
– Course Related Activity
– Instruction Related Activity
– Non Instruction Activity
– Sponsored Research Activity
Course Related Activity
Instruction Related
Non Instruction-Related
Sponsored Activity
FAR Admin Form
Administrators will use this form to assign the paying and
benefitting accounts.
Click “View Pay Summary” for Salary Information.
View Pay Summary
• Provides the following information
– Pay Summary by Funding Source
• Provides the percentage by budget entity
– Pay Detail by pay period and funding source
• Detail pay by pay period and funding source
– Faculty Info Summary
• Crosswalk from chart field to State Reporting
Number (SRN)
Pay Summary
Budget Entities
State Reporting Numbers (SRN) are used in reporting to the State e.g.
610100020. The chart below helps you to identify funding type to SRN.
Budget Entity
FAST Fund Code
Fund Type
SRN Suffix
E&G
10000 & 10009
Health Sciences / EG
20, 00, 50
Contract and
Grant
18300
Rebate
R0
20000
Grant: Federal
L0, K0, P0
21000
Grant: State/Local
L0, K0, P0
22000
Grant: Private
L0, K0, P0
24000
Endowment
L0
9####
Convenience
P0 or L0
Activities and Funding
Activity
Funding Priority
Undergraduate, Graduate, MED Courses
E&G, Convenience, Rebate
Clinical Instruction (Residents)
E&G, Convenience, Rebate
Supervision of Co-op Interns
E&G, Convenience, Rebate
Academic Advising
E&G, Convenience, Rebate
Other Instructional Effort
E&G, Convenience, Rebate
Departmental Research
Convenience, Rebate, E&G
Public Service
Convenience, Rebate, E&G
University Governance
Convenience, Rebate, E&G
Paid Patient Care
Convenience, Rebate, E&G
Clinical Service
Convenience, Rebate, E&G
Administration
Convenience, E&G, Rebate
Leave of Absence
Convenience, Rebate, E&G
Organized / Sponsored Research
Research Grants (cost share)
Paying & Benefitting Accounts Assigned
Report Reconciled
Functions
•
•
•
•
Inserting a row
Deleting a row
Editing a row
Add an account to drop lists
Inserting a Row
1. Click on the blue “+” mark
Inserting a row…………………..2
1. Use the drop down menu to
choose category
2. Enter % FTE
3. Apply paying and
benefiting accounts
Please be sure to complete the row before moving to
another row.
4. Click on
green
check
mark
Deleting a row
2. Click on Update
1. Click on box with
scissors above
Editing a row
1. You may edit the category, % FTE, paying account, or
benefiting account by changing the field.
2. Click on UPDATE.
Adding Account to Drop Down.1
Click “Faculty Information”
Adding Account to Drop Down.2
Click on hyperlink
Adding Account to Drop Down.3
Adding Account to Drop Down.4
Enter chart
field and
Click Search
Choose the grant and scroll down and click Submit
Cost Share
• There are four categories of cost share
– Mandatory (Committed) - required by the program as a condition of the
award and therefore is obligatory and reportable. (example: NSF 1%
mandatory cost share)
– Salary Cap Cost Sharing (Committed) - occurs when the salary for an
individual exceeds the sponsor imposed limit. This is classified as
Voluntary Committed cost share and must be documented within USF’s
PERT system.
– Voluntary (Committed) – offered/proposed by the grantee when not
specifically required by the sponsor. The offer is included in the award
directly or by reference. Voluntary Committed cost sharing expenses
must be properly identified for cost accounting purposes. Voluntary
cost sharing is highly discouraged and requires approval Division
of Sponsored Research (DSR) approval.
– Voluntary (Uncommitted) - unplanned cost share that does not need to
be documented within the University’s system or reported to the
sponsors.
Questions and Answers
• What happens if a faculty member does
not complete their faculty activity report?
– Non compliance with state law (Auditor
General annual audit)
– Impacts the University, College and
Department funding
What is PERT?
• PERT (Personnel Effort Reporting)
• PERT is USFs federal effort reporting process as mandated by the
United States Government Office of Management and Budget
(OMB) published regulations OMB Circular A-21 which requires
educational institutions to maintain an accurate system for reporting
the percentage of time that employees devote to federally funded
projects. In accepting Federal funding, the University and Principal
Investigator agree to comply with this regulation. PERT effort reports
are designed to meet A-21 requirements and are the only authorized
approach for federal effort reporting at USF. In the absence of an
appropriate effort reporting system, salaries and wages will not be
reimbursed or funded with federal dollars
Can a certified effort report be
changed?
• Certified effort reports assert that the information
represented is to the best of the certifier’s
knowledge, is accurate, and complete
• Changes to previously certified effort erode the
credibility of the certifier as well as the entire
effort certification process
• In the GEMS system, Retro Expense Transfers
(RETS) will trigger the need to re-certify the
affected effort report
Questions and Answers
• Do FAR and PERT (Personnel Effort Reporting Tool) need to
Match?
– YES!!!
• Possible consequences if they are inconsistent:






Cost Disallowances
Designation as High Risk Organization
Special Terms and Conditions in Awards
Special Monitoring by Federal Agencies
Temporary Withholding of Payments
Withholding of Future Awards
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