Hartford Hospital Research Institute
Time and Effort Reporting
Prepared By:
HHC Office of Compliance, Audit and Privacy
Angelo Quaresima, Research Compliance Specialist
May 2013
What is Effort?
Effort is defined as the amount of time spent on a particular
activity, expressed as a percentage of all time you spend on
your institutional responsibilities. It includes the time spent
working on a sponsored project in which salary is directly
charged (paid effort) or contributed (cost share effort).
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Why Do We Need to Report and Certify Effort?
Federal Requirement
45 CFR 74 APPENDIX E - Principles For Determining Costs Applicable To
Research And Development Under Grants And Contracts With Hospitals
requires salary and wage charges to be supported by either actual time
records or current and reasonable estimates of the percentage distribution
of Total Effort.
Hartford Hospital Requirement
Research Institute - Time and Effort Reporting Policy provides guidance
and outlines procedures to comply with federal requirements.
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Who is Required to Report and Certify Effort?
Non-Exempt Employees:
Effort for non-exempt employees is certified through the completion
and approval of weekly HH KRONOS timecards.
Exempt Employees:
A monthly Time and Effort (T&E) Report must be completed and
certified for any exempt employee with Committed or Actual Effort
(paid effort or cost share) on federal or federal sub-recipient sponsored
projects administered by HH.
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Federal Effort Reporting Requirements
• Reasonable estimates of the percentage distribution of Total Effort may
be used as support in the absence of actual time records.
• Estimates of effort should be prepared by the individual who performed
the services or someone, such as a supervisor or department head, with
first-hand knowledge of the services performed.
• Percentage estimates must show the allocation of effort between
organized research and all other hospital responsibilities.
• Estimates must be made no later than one month after the month in
which the services were performed.
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HH T&E Reporting Key Points
• Institutional Base Salary (IBS) should be used when preparing budgets and charging
salary to sponsored projects. (Note: Federal grants have an IBS cap)
• Committed Effort is your budgeted effort (paid effort or cost share) on the project
which is accepted by the sponsor.
• Actual Effort is calculated based on a reasonable estimate of the percentage of Total
Effort expended during the monthly reporting period.
• Total Effort must always equal 100% of your institutional responsibilities, regardless of
hours worked during the week.
• Activities outside of your institutional responsibilities, such as consulting, are not
included as part of your Total Effort.
• Time & Effort (T&E) Reports are used to document after-the-fact certification of Actual
Effort on sponsored projects.
• T&E Reports must be completed and certified within 14 calendar days of distribution.
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Role of Principal Investigators
HH 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 and in compliance with
Federal regulations, sponsor requirements, and institutional policy. This includes
oversight of effort certification and related charges for all personnel on the project.
• Sponsor notification 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. However, accountability for compliance with federal
regulations, sponsor requirements, and institutional policy, ultimately rests with the PI.
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T&E Reports
T&E Reports document that salary charged to a project is consistent
with the Actual Effort provided during a specific time period.
(Replaces a timesheet)
T&E Report certification is the method of verifying that:
• Actual Effort supported and charged to the project has been
performed as committed, and
• Actual Effort expended in support of a project but not paid by
the project (cost sharing) has been performed as committed.
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T&E Reports
HH monthly T&E Reports are pre-populated with Actual Effort percentages based
on payroll distributions allocated within the accounting system.
Employees need to review and certify Actual Effort percentages. If needed, T&E
report percentages should be revised to reflect Actual Effort expended.
For example:
Investigator Z’s May 2013 T&E Report reflects 25% effort for project Y based on
payroll distributions allocated within the accounting system. However,
Investigator Z spent 40% Actual Effort on the project during the month.
Investigator Z would need to adjust the T&E Report to reflect Actual Effort of
40% prior to certification and, if needed, request a cost transfer to adjust payroll
charges.
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T&E Report Sample
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Actual Effort Calculation Formula
Estimate of weekly hours spent on sponsored project
_________________________________________
Total hours in an average work week
(Total Effort)
=
Actual Effort %
on
Sponsored Project
Actual Effort percentages should not be calculated on the basis of a
40-hour work week or any other "standard" work week. Actual Effort
must always be calculated and expressed as a percentage of Total
Effort.
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Effort Calculation Examples
Doctor A
• Doctor A works 30 hours a week on Grant A and spends 20 hours a week on
patient care and administrative responsibilities.
Effort Calculation:
• 100% Total Effort for HH is 50 hours
• Actual Effort for Grant A is 60%, or 30/50 hours
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Effort Calculation Examples
Doctor B
• Works 40 hours per week on patient care, research grant and administrative
duties.
• Also is paid for serving on an outside scientific advisory board, averaging 5 hours a
week.
• Works on two research grants, spending total of 10 hours a week on Grant A and 5
hours a week on Grant B.
Effort Calculation:
• 100% Total Effort for HH is 40 hours, work on the outside advisory board is not
included in total effort
• Actual Effort for Grant A is 25%, or 10/40 hours
• Actual Effort for Grant B is 12.5%, or 5/40 hours
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Effort Calculation Examples
Doctor B Continued
Doctor B obtains another research grant, expecting to spend 10
hours per week on Grant C and does not drop/decrease any other
HH responsibilities.
Effort Calculation:
•
•
•
•
100% Total Effort for HH is now 50
Actual Effort for Grant A is 20%, or
Actual Effort for Grant B is 10%, or
Actual Effort for Grant C is 20%, or
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hours
10/50 hours
5/50 hours
10/50 hours
Cost Share Example
Doctor C
Mandatory Cost Share:
• A federal grant requires HH to match 50% of Doctor C’s salary on a project
• Actual Effort committed on the project for the month is 50%
• Institutional Base Salary (IBS) = $100,000
Calculation:
• $100,000 x 50% = $50,000 in salary expended to the project
• $50,000 x 50% = $25,000 should be charged to the project account
• $50,000 x 50% = $25,000 should be charged to a non-federal or
departmental account and cost shared to the project
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Change in Committed Effort on NIH Grants
Per NIH Grants Policy Statement, Part II, Subpart A, General—Administrative
Requirements (October 1, 2010).
HH is required to submit a prior approval request to NIH if the PD/PI or other
Senior/Key Personnel specifically named in the Notice of Award will:
• Withdraw from the project entirely
• Be absent from the project during any continuous period of 3 months or
more
• Reduce time devoted to the project by 25 percent or more from the level
that was approved at the time of initial competing year award
Once approval has been given for a significant change in the level of effort, then
all subsequent reductions are measured against the approved, adjusted level.
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NIH 25% Reduction in Effort Example
• A PI proposes a change in Committed Effort from 40% to 30%. A 25%
reduction will occur, requiring pre-approval from NIH.
Calculation:
40% - 30% = 10%
10/40 = 25% Reduction in Committed Effort
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Red Flags
• Late or missing T&E Reports
• Certification by someone without first-hand knowledge
• Effort reported for non-research projects is not reasonable to cover patient care,
administrative or other HH responsibilities.
• Significant number of revisions to T&E Reports (retro-active management of effort)
• Projects with Committed Effort but none delivered
• Significant data inconsistency between T&E Report and other documentation such as:
• Payroll records
• Progress reports
• Time allocated to non-research projects
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Non-Compliance Fines and Penalties
Johns Hopkins University (2004) - $2.6 million settlement
• Overstated PI effort on federal projects
YALE (2008) - $7.6M settlement ($3.8M in actual damages and $3.8M
in penalties)
• Cost transfers for unallowable costs
• Unsigned effort reports (costs disallowed)
• No procedures in place to monitor effort expended versus
committed
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Contact Information
Any questions or concerns regarding the completion or certification of T&E
Reports should be directed to Grants and Contracts.
Grants and Contracts Main Line: 860.545.4592
Tammy Weirs, Manager: 860.545.4412
Linda Adams, Administrator: 860.545.5611
Marc Ginnett, Administrator: 860.545.2093
Compliance concerns should be directed to the HHC Office of Compliance,
Audit and Privacy (OCAP).
Angelo Quaresima, Research Compliance Specialist: 860.972.7065
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Questions?
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