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EFFORT REPORTING
UCONN Health Center
Farmington, CT
Research Administration & Finance
February 2014
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What is Effort Reporting?
• A retrospective assurance that the time
committed and/or budgeted corresponds to the
time spent and effort invested on a given
sponsored project for a specific period.
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Why do we certify effort?
• Employees paid in whole or part from
extramurally-funded sources required to certify
to effort/$$ expended on these projects as a
condition of accepting the funding.
• UCHC obligated to provide the administrative
support and system to facilitate effort reporting.
• Required…obligated…
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By whom?
• As a condition of accepting federal funds, we
(institutionally and individually) agree to meet
federal guidelines for determining costs
applicable to Grants (OMB Circular A-21).
• Other sponsors, including the State of
Connecticut.
• The University.
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What is the standard?
• The Federal government is the established standard.
More than 75% of UCHC’s research $$ are from federal
agencies, predominantly the National Institutes of
Health (NIH).
• Federal government accepts ambiguity in research:
▫ “In the use of any methods for apportioning salaries, it is
recognized that, in an academic setting, teaching, research,
service, and administration are often inextricably intermingled.
A precise assessment of factors that contribute to costs is not
always feasible, nor is it expected. Reliance, therefore, is placed
on estimates in which a degree of tolerance is appropriate.”
OMB Cir A-21, Section J10b(1)(c)
• But institutional policies and procedures are required.
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What Criteria is Expected by the Federal
Government to Meet the Standard?
• OMB Circular A-21, Section J.10.b(2)
▫ A system of allocating salaries based on effort that is
incorporated into the official records of the
institution.
▫ Must reasonably reflect the activity of the employee.
▫ May be made initially on the basis of estimates, but
significant changes must be identified and entered
into the payroll distribution system.
▫ An after-the-fact confirmation by a “responsible
person with suitable means of verification that the
work was performed.”
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Mistake or Fraud?
The Federal Government has the power to impose sanctions on you and the institution
for actions “deemed” to be fraudulent. These sanctions, and other actions, include…
• Cost disallowances and fines if effort reported
does not appear reasonable.
• Special monitoring.
• Name in the news.
• Fraud violations may subject both institution
and individual to civil and criminal prosecution.
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The Bottom Line
• Recent civil settlements between other research
institutions and the Federal Government:
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Yale - $7.60 million
Northwestern - $5.50 million
Johns Hopkins - $2.60 million (for 1 PI)
East Carolina University - $2.60 million
Harvard/Beth Israel Deaconess MC - $3.25 million
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The Bottom Line continued
UCHC’s policies and procedures exist to guide and protect researchers and the
institution. Recent effort reporting audits have sited UCHC for the following:
• UCHC A-133 audit findings:
▫ 2008 Effort reports not certified on a timely basis
become questioned costs and therefore material
findings.
▫ 2008 Particularly successful PI had 99% effort
approved to research.
▫ 2007 PI shares password.
▫ 2007 Labor distribution change authorization (LDCA)
are requested after effort has been certified – what is
the basis for the certification in the first place?
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Red Flags
What types of activities cause concern for UCHC and how do we mitigate them?
• Significant number of re-certifications – Pro-actively
manage effort.
• More than 95% effort on sponsored accounts – review
effort commitments with Chair and AVP Research
Administration & Finance on semi-annual basis.
• Non-organized research sponsored accounts with 0%
effort (clinical trials) – what’s the justification, does it
make sense?
• NIH salary cap violations – track salary cap investigators
and review direct charges to grants.
• 1st hand knowledge test – did the investigator have 1st
hand knowledge? If not, who did?
• Accounts where effort is promised but none delivered.
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Red Flags (continued)
• Late or missing effort reports – will result in
suspension of spending privileges.
• Data inconsistency between financial and effort
reporting data and other sources of effort data:
▫ Time allocated to non-research activities
 Teaching/Clinic
 Committees/NIH Study Sections
 Chair responsibilities
▫ Payroll records
▫ Tenure material
▫ NIH Biographical Sketches and JIT Other Support
pages
▫ Progress Reports
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The Details
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Who must file effort reports?
What is effort and how is it determined?
What is Cost Share?
What is Salary Cap Cost Share?
What about changes to effort?
What do I do when a grant goes into a “No Cost
Extension?”
7. What is our process for reporting effort?
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1. Who must file Effort Reports?
• Faculty who receive salary support from a
sponsored project and/or have committed effort
on a sponsored project.
• Staff who receive salary support from a
sponsored project or who devoted effort to a
grant as cost sharing (limited by UCHC policy
#2002-14). Staff effort reports are filed by the
PI.
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2. What is effort and how is it determined?
• Time devoted to all institutional activities expressed as a
% of total institutional activities.
• Total institutional activities includes time spent on:
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Patient care
Research
Chair and committee responsibilities
NIH study sections
Education
• Institutional activities do not include external
professional activities for which you receive
remuneration.
• Effort is NOT a 40-hour work week. It is how you
allocate your time across ALL your faculty activities.
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3. What is Cost Share?
• Cost share is that portion of an employee’s effort
or salary that is paid by the institution, rather
than the sponsor.
• Cost sharing of effort can be mandatory
(required by the sponsor) or voluntary.
• Cost sharing of salary as a result of the sponsor
limiting the salary chargeable to a grant is salary
cap cost share.
• See policy #2002-14.
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3a. Effort Cost Sharing
• UCHC only recognizes “committed effort” cost
sharing.
▫ Committed effort cost share is a binding commitment
between UCHC, the employee, and sponsor.
▫ UCHC requires prior approval for cost share before
proposal submitted.
▫ Cost sharing is limited to PI and key personnel.
▫ Committed cost share can be mandatory (required by
the sponsor) or voluntary.
▫ Voluntary committed cost share becomes mandatory
when approved/awarded by the sponsor.
• See policy #2002-14.
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4. Salary Cap Cost Sharing
• Certain sponsors, including the National Institutes of
Health, limit the amount of salary that can be direct
charged to a grant.
▫ 2014 salary cap at Executive Level II = $181,500
▫ Proportional amounts over this cap must be reported as Salary
Cap Cost Share.
 An employee making $200,000 and committed 50% to a grant would
have a salary cap cost share amount of $9,250.
 (200,000 * .5)-(181,500 * .5) = $9,250
▫ Salary Cap Cost Share does not impact effort. It is a transfer of
salary $$ only from the sponsored account to the cost share
account.
▫ With the current version effort reporting, Research Finance
tracks salary cap cost share and transfers dollars, leaving the
effort report intact for certifying effort.
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5. What do I do when my effort changes?
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Effort on a sponsored account should match the
commitment as proposed in the grant proposal or
amended with the sponsor.
Changes to effort should be made according to the
terms of the award. Federal requirements require
prior notification for reductions of effort amounting to
25% or greater.
Prospective changes:
Use the EPAF process to change future allocation of effort.
Retrospective changes:
Use Labor Distribution Change Authorization (LDCA) process
to change posted payroll charges. Allowable retrospective
changes include:
 Changes to the current effort reporting period or older periods when effort
has not yet been certified.
 Changes to certified effort only permitted with Research Finance approval.
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6. What happens to effort during a
“No-Cost-Extension”
• A no-cost-extension is considered an extension
of the project as approved.
• PI effort must continue to be direct charged to
the grant or cost-shared as previously approved.
• Effort can be reduced by following the process
defined previously.
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7. What is UCHC’s effort reporting process?
• UCHC’s Effort Reporting System (ERS), was
designed and developed by UCHC to meet the
reporting needs of our research community.
• ERS is available on-line from any computer
(Mac or PC) with internet access and a
commonly used web-browser, such as Internet
Explorer or Firefox.
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ERS Access
• ERS link:
http://efforttracker.cam.uchc.edu/
• Step-by-step instructions on completing the review and
approval or certification of effort can be found under the
Help menu or by following this link:
http://efforttracker.cam.uchc.edu/documents/ETS_Effort_Reporting.pdf