Wayne State University PAD Session – Effort Reporting Introduction 2009 March, 2011 1 We listen. We partner. We focus. We deliver. © Huron Consulting Services LLC. All rights reserved. Agenda • What is Effort Reporting? Why do we need to do it? • Project background • Summary of changes in how we do Effort Reporting • Fundamental concepts and requirements • Support and additional information • System “Demo” and Training 2 We listen. We partner. We focus. We deliver. What is Effort Reporting? Why do we need to do it? • Effort reporting is required by the federal government (OMB Circular A-21, Section J-10), since Wayne State University receives federal funds to be used for sponsored research. • It applies only those faculty and staff who are involved in sponsored/ externally funded research ( i.e. those who charge or cost share part of their salary to sponsors, and/or who have effort commitments to sponsored programs). • It serves as an after-the-fact confirmation that the assignment of time and associated salary and fringe benefit costs to individual sponsored projects is fair, consistent, and timely. • Effort reporting is not new to WSU. We have been doing it for several years via paper-based “Payroll Certification” forms. We are now moving to an online system (a module contained within Banner) that will provide greater efficiency and better position WSU to meet its compliance requirements. • The sole purpose and capability of the new system is effort reporting compliance. 3 We listen. We partner. We focus. We deliver. WSU Project Background • WSU is focused on enhancing its compliance with federal requirements related to effort reporting • This has, and will continue to include cultural as well as operational and technical changes • Over the past year, WSU evaluated automated solutions and is now in the process of kicking off a project to implement the Effort Reporting module offered by Banner • Huron is providing subject matter and project management assistance for the project 4 We listen. We partner. We focus. We deliver. Project Update H i g h -L e v el T i m el in e J uly August Septem ber O ctober N ovem ber D ec embe r Januar y P lan and Man ag e th e P roject Kic koff/Mobilization O ngoing M anagem ent A n alyz e C u rren t Stat e Policies and Proc edures Educ ational Materials and D eliver y O ptions C om mon Pr actic ie s and Lev els of U nderstanding U se of T echno logy D esig n an d D evelo p F ut u re St ate v v Policies and Proc edures Educ ational Materials and D eliver y O ptions C om mon Pr actic ie s and Lev els of U nderstanding D esign and C onfigure Ban ner E ffort M odule S ystem In stallat io n , C o n fig u ratio n an d T estin g In itial A pplic ation Installation and S etup D etailed Application C onfiguraiton Validate D ata and T est Banner Effort M odule F unctionality D ep loy D eliver C om munication & E ducation on Policy & P rocedur es D eliver C om munication & E ducation on Ban ner E ffort M odule D eploy Banner E ffort M odule and R elated Pr actic es Milestones & Progress to Date 5 Project Kickoff July 1 Completed Current State Assessment System configuration and testing complete Conducted “Effort 101” sessions We listen. We partner. We focus. We deliver. Produced draft “Effort Reporting Procedures and Guidelines” Continuing Effort Education Finalizing plans for rollout/go-live F ebrua ry Summary of Key System & Process Changes • All electronic – no paper! – “Effort” displayed as percentages (based on Banner payroll/labor distribution) • Pre-Review – Quality control function performed by departmental administrative staff – Purpose is to identify effort reports that do not reasonably reflect the EFFORT during the period of performance – Pre-review is mandatory. Certification can’t take place until pre review is complete • Grad Student Certification – Will be performed by PI’s, not by grad students – Grad students will not receive email notifications, nor have the ability to certify in the system • Research Assistant Certification – It is intended that research assistants perform their own certification – PI’s will be assigned as “Alternate Certifiers” for research assistants, and will have the ability to certify for research assistants if needed • Summer Certification – For 9-month faculty, there will be a separate certification cycle for the summer period 6 We listen. We partner. We focus. We deliver. The Context of Effort Reporting Effort Reporting encompasses more than just certifying effort 7 Appointing Faculty & Staff Preparing the Proposal Budget • Employment terms are established. • Effort is proposed, a commitment is made to the sponsor. We listen. We partner. We focus. We deliver. Charging Salary • Salary is charged (or cost shared), consistent with activity. Adjustments may be made, shortly after-the-fact. Certifying Effort • Effort is attested to, after activity has occurred (adjustments to salary distribution may be made if effort < salary%). Who Needs to Certify? • All individuals paid from or with effort committed to a sponsored project are required to complete an effort report , per federal regulations • Effort reports should be certified by: – An employee, principal investigator or other responsible official with first-hand knowledge of all of an employee’s effort, or – An individual who used suitable means of verifying that the work was performed. 8 We listen. We partner. We focus. We deliver. Role of the Principal Investigator (PI) • Sponsored awards are made to Wayne State University, with the Principal Investigator serving as the “steward” of the research project and accompanying funds received from the sponsor • The University is legally responsible to the sponsor, but the PI is held accountable for the proper fiscal management and conduct of the project. PI responsibilities include: – Scientific performance of the work related to the project – Management of the project within funding limitations – Assurance that the sponsor will be notified when significant conditions related to the project change – Responsibility for the day-to-day management of project finances may be delegated to administrative or other staff, but accountability for compliance with WSU policy and sponsor requirements ultimately rests with the PI. 9 We listen. We partner. We focus. We deliver. What is Effort? • Effort is the portion of time spent on a given professional activity and expressed as a percentage of the total professional activity for which an individual is employed by WSU. • Important points: – The government recognizes that it is a “reasonable estimate” – Total effort must equal 100% – Effort is not based on a standard (e.g., 40-hour) work week, instead based on whatever was worked – “100% Effort” considers all professional activities related to the individual’s WSU appointment (teaching, research, service) – Effort does not include outside activities: • External consulting • Special activities resulting in a one-time payment • Temporary activities over and above normal responsibilities • For clinical faculty, VA and UPG activities 10 We listen. We partner. We focus. We deliver. A Perspective on “Effort” “Effort” from Wayne State’s perspective: • Overall, the Banner payroll/labor distribution does not reflect the hours I spend, nor does it capture the different types of effort I put forth for WSU. • All my effort, regardless of who is paying for it or when it’s done is important and should be recognized. “Effort” from the government’s perspective: • The federal government wants to know how individuals working on federally-sponsored programs are expending all of their effort • In proposals, key personnel indicated their estimated effort and requested the associated salary, or made a cost-sharing commitment that the institution would fund the salary • While not perfect, payroll/labor distributions serve as a reasonable starting point for effort certification (it may be off in terms of both timing and source) • Effort certification serves as an after-the-fact confirmation that the individual/key personnel expended the promised effort, and that they worked at least as much as the percent of their salary charged/cost-shared to the project 11 We listen. We partner. We focus. We deliver. Certifying Effort or Payroll? • Effort reports may pre-populate total percentages of payroll distributions to be used as a starting point, since it is often assumed that payroll distribution is monitored and revised based on effort expended • However, these percentages may need to be revised during certification based on actual expended effort • This after-the-fact confirmation is necessary for compliant effort reporting 12 We listen. We partner. We focus. We deliver. Reasonable Estimate & Suitable Means • Sponsors recognize that the activities that constitute effort are often difficult to separate. Effort certification must often rely on a reasonable estimate of effort, and when estimating, a degree of tolerance (up to 5%) is appropriate. Examples: – It would be reasonable for a faculty member who was awarded and expended 40% effort on a grant to sign an effort report stating 39% payroll support for that grant. – It would not be reasonable for a faculty member who teaches two classes to certify that she worked 95% on sponsored research. • What are suitable means of verification? ⁻ The individual should have some documentation of how the time was spent that is certified. ⁻ Documentation could be in the form of an email, calendar, project reports, etc. 13 We listen. We partner. We focus. We deliver. Committed Effort • Committed effort is the amount of effort promised by the institution in the proposal or the amended effort included in the award documentation. • The total distribution of effort dedicated to all institutional activities for an individual must not be greater than 100%, including cost sharing commitments. • 100%, or nearly 100% research effort, is not realistically possible for individuals with significant non-research obligations to the institution (e.g., teaching and service). • If key personnel intend to reduce their effort on sponsored programs by more than 25%, the institution needs to notify the sponsor and receive approval. • If the receipt of an award increases an investigator’s committed effort to greater than 100%, the investigator must revise the level of effort requested by communication with the sponsor, reduce effort on other activities, or refuse the award. 14 We listen. We partner. We focus. We deliver. Plans for System Rollout Date 1/10 1 Prepare Production Environment 2 Training 3 Conduct Pre-Review/Admin. Training Wk of 2/7 4 Distribute Certifier Training Materials Wk of 2/21 5 Pre-Review Period 2/14 6 Initial Pre-review notification 2/28 7 First pre-review reminder 3/7 8 Second pre-review reminder 3/10 9 Third/final pre-review reminder 3/14 10 SPA Direct Follow Up 11 Certification Period 3/7 12 Initial Certification Notification 3/21 13 Certification reminder 4/4 14 Certifications Complete! 4/4 15 First certification late reminder 4/8 16 Second certification late reminder January 1/17 1/24 1/31 2/7 February 2/14 2/21 2/28 March/April 3/14 3/21 3/28 3/7 • By the time you certify, you’re departmental administrative staff willl have already reviewed your effort report(s). This is a required step in the work flow. • Research faculty and staff who have effort reports eligible for certification will be notified via a system-generated email on or about March 7. • Certification due date is April 4. System generated reminders and notices will be sent as outlined in the above timeline. 15 We listen. We partner. We focus. We deliver. 4/4 Support and Additional Information What if I have questions or problems? • Your departmental business manager and other resources have been trained to help you. They can answer questions about using the system and about the information and percentages that appear on the effort reports. • You can also contact Sponsored Programs Administration. Patrick Maher Marlene Erno merno@wayne.edu 313.577.6594 patrick.maher@wayne.edu 313.577.6597 • For additional information on effort reporting (educational materials, operational guidelines, etc.) please see the SPA web site: http://www.spa.wayne.edu/post/effort_reporting.php • Education and Guidance on Effort Reporting – Draft Effort Guidelines – Provides guidance on how manage effort reporting at WSU – “Effort 101” – Covers key effort reporting definitions and concepts – Effort Reporting FAQ document • Navigation and use of the new effort reporting system. Guides have been developed specifically for: – Research faculty and staff – Departmental administrative support staff 16 Questions? Comments?? 17 We listen. We partner. We focus. We deliver.