EFFORT REPORTING Mary Moskofides Effort Reporting Analyst Post

EFFORT REPORTING Mary Moskofides Effort Reporting Analyst Post Award Financial Operations

Agenda • What is Effort? • Maximum/Minimum • Why do we certify? • What is Effort Reporting? • How often do we report? • Effort Report Overview • Control Logs & PARs • Certifying Effort • Salary vs. Effort • Issues to consider o Cost Share/ DHHS Cap o Salary Adjustments o Manual PAR • PAR Completion Process

What is Effort? • Effort is the time spent on any University activity by an individual, expressed as a percentage of the individual’s Total University Effort o A reasonable estimate o Total effort must equal 100% o Not based on a standard 40 hour work week o Does not include outside activities § External consulting § Veterans Administration (VA) compensated activities

Maximum and Minimum Effort • Maximum Effort o Most faculty are unable to devote 100% of their time to sponsored activities due to other responsibilities that include: § Teaching § Administrative work § Patient care § Competitive proposal writing • Minimum Effort o Principal Investigators (PIs) cannot certify 0% effort on sponsored project o PIs must certify at least 1% to reflect leadership on the project o Sponsor exemptions: equipment, training, conference support grants

Why Do We Certify Effort? • Office of Management and Budget (OMB) Uniform Guidance o Compensation for Personal Services (§ 200. 430) § Eliminated from Uniform Guidance Ø “Certification” Ø Specific examples for acceptable validation § Many of same principles over what is acceptable do not appear to have explicitly changed § Charges must still be based on percentage distribution of total institutional base salary activities

Why Do We Certify Effort? The federal audit community has not bought into the full “elimination” of effort reporting. We are monitoring closely. • BU will continue to follow “After-the-Fact” reporting method • Effort reports are almost always requested and reviewed by federal auditors when sponsored programs are under review o Labor costs typically represent 2/3 of the direct costs charged to federal awards

What is Effort Reporting? • A method for documenting the proportion of total work time devoted to sponsored agreements, expressed as a percentage of total work time • A means of verifying o Appropriate salary & wage expenses were charged to sponsored projects and that they were reasonable o Cost sharing was performed as promised o Total effort commitments were met o Labor costs supporting sponsored activity are appropriately classified in the facilities and administrative (F&A) cost rate • Boston University uses Personnel Activity Reports (PARs) to certify effort o Primary auditable documents to support salary costs to an award

Effort Certification Periods • Faculty, Managerial and Professional Employees: Semi-annually for the periods January to June and July to December • Non-Professional, Clerical and Technical Employees: Quarterly for the periods from January to March, April to June, July to September, and October to December • Students: Annually for the Fiscal Year period from July to June

Effort Certification Periods GOOD NEWS!!! Effective Fiscal Year 2016 July 2015 to December 2015 PAR Period • All University employees will be on the same schedule of certifying effort reports twice a year: o July to December o January to June • This includes Exempt, Non-Exempt, and Student Employees

Review Control Log • In keeping with the sort order of PARs, the control log that accompanies the reports is sorted alphabetically by last name within each Mail Code. • If you are missing a PAR or a PAR was sent to your department in error o Please email effort@bu. edu and either request or return PAR immediately to PAFO

Personnel Activity Report • PARs contain pre-printed information indicating the percentages of the employee’s University salary that were allocated to sponsored agreements and other non-sponsored University activities o Category I: BU NON-SPONSORED ACTIVITY § “Unrestricted Breakdown” of percentages for informational purposes Please provide only one percentage in “% of Effort Expended” column o Category II: BU SPONSORED ACTIVITY § Section A reflects Sponsored Agreements § Section B reflects Cost Sharing Activity Please provide sponsored program number(s) and percentage of effort expended on each agreement o Category III: SERVICES PROVIDED TO BOSTON MEDICAL CENTER (as vendor) § This category reflects the percentage(s) related to BMC sponsored activity

PAR Guidance

Certifying Effort not Salary • Two columns are listed on the PAR o One with pre-printed salary percentages (provided for reference) o One to complete actual effort percentages • Considerations: o Payroll percentages may be incorrect o Only PAR eligible wage types are considered for effort o Funding sources may not align with how effort was expended o Cost sharing o Salary Adjustments

Issues to consider when reconciling PARs • Salary of less than. 5% to a cost object will not display on PAR • Key Wage Types and Impact on Effort Reporting

Cost Sharing • Cost Sharing is the portion of project or program cost that is not reimbursed by the sponsor. Cost Sharing Type Definition Required on PAR? Mandatory Required by the sponsor as a condition of an award Yes Voluntary Committed Cost associated with a sponsored project, identified in the proposal, but was not (VCCS) Yes required or funded by the sponsor Voluntary Uncommitted (VUCS) Cost that is neither committed in the proposal nor required as a condition of the award No • Salary cost sharing occurs when effort exceeds the payroll charged to a particular project • Example is DHHS Salary Cap (Mandatory Cost Sharing) • These costs may not be charged to the sponsored project and must be supported by University funds.

Mandatory Cost Sharing DHHS Salary Cap • Federal Guidelines limit the annual amount of salary that can be charged to DHHS awards to $183, 300 effective January 2015 • Employees whose 100% full-time equivalent salary is greater than $183, 300 must ensure that no more than $15, 275 is charged to DHHS awards on a monthly basis • Employees over the threshold must charge an unrestricted account for any amount greater than $183, 300 IMPORTANT NOTE o Faculty doing any work outside of research, such as proposal writing, teaching, clinic or committee work MUST allow a minimum of 5% to be charged to a non-sponsored account after cost share is accounted for What does this mean? ? ? In this case, only $174, 135/annually or $14, 511/monthly can be charged to DHHS awards with the remaining 5% charged to a non-sponsored account

PAR Review if “% of Salary Charged” is a reasonable reflection of how employee spent their time Within a PAR period, effort percentages: • May fluctuate among sponsored programs, if within the same grant • Must equal total salary charged among those sponsored programs • May be greater than salary charged, but the difference must come from non-sponsored funding sources If errors are found, corrections should be made on the PAR • Salary must support effort percentages • Effort percentages cannot be less than salary charged • Retroactive salary adjustment may be needed Complete PAR in its entirety o Percentages (whole numbers only - no decimals) o Effort certification statement o Return to PAFO by deadline (Auditors review for timely submission)

Salary Adjustments • If effort expended percentage is less than salary charged, a salary adjustment must be processed • When processing a Personnel Action or an Additional Payment which encompasses a period for which PARs have been issued, the employee PAR must be attached • If the PAR has been accepted, the PAR will need to be re- certified. This is a rare occurrence and only approved under special circumstances.

Manual PAR • A manually produced PAR may be requested from the research accounting administrator if: • Employee not previously paid from a sponsored agreement • Cost share documentation is required

Who can certify? Certification Eligibility: PAR Certifiers must comply with the following statement: “I certify that I am either the covered individual, Principal Investigator (PI) or other responsible official using suitable means of verification to confirm that the percentages shown in the Percent of Effort Expended column reasonably reflect the actual effort devoted to the sponsored agreement(s) during the period of the effort report. ” Faculty: All faculty must certify their own PARs Non-Faculty: • Non-faculty Principal Investigators (PIs) must certify their own PARs • All other non-faculty PARs may be certified by the individual, the PI or other responsible official using suitable means of verification Students: PARs may be certified by the student employee, the student’s supervisor or the PI NOTE: The certification statement must include the employee’s signature, printed name, title and date

Who cannot certify? Department research administrators are not eligible to certify the effort of faculty or research staff, unless they have such written after-the-fact confirmation from an individual having suitable means of verification.

PAR Process Information • Federal Guidelines require certification to be on completed on timely basis • Certification Timing: Time for completion and return to our office is sixty (60) days to allow adequate and reasonable time for certification. o You should not wait until the deadline to submit • Any PAR certifications received after 60 days, run the risk of disallowance. If this occurs, your department will be charged back for the associated salary, fringe, and indirect charges incurred • Federal regulation requires each PAR be accurately certified and received in PAFO office by the deadline listed on the PAR

Certified PARs A PAR is considered certified when the following criteria are met: Ø“% of Effort Expended” column is completed ØColumn adds up to 100% ØCertifier has signed, dated, printed his/her name and title on the form for verification An incomplete or incorrectly signed PAR will be returned to the department for corrections, often resulting in significant delays in report submission and compliance.

Consequences of Non-Compliance • The risks of non-compliance with effort reporting are significant • The sponsor may: o Disallow related salary, fringe and F&A costs o Reduce or eliminate future funding o Press criminal charges

Effort Reporting Information The Sponsored Program Effort Certification Policy provides clear guidance to faculty and administrators on PAR process (link below): http: //www. bu. edu/cfo/post-award-financial-operations/resources/university-policies/

Questions & Answers Thank you for your attention! Contact Effort Reporting with additional questions: effort@bu. edu