Yale University Principles of Effort Reporting Presented by

Yale University Principles of Effort Reporting Presented by: Office of Sponsored Projects Revised 06/06/2017 PRN: 10/31/2020 10: 29 AM

Course Learning Objectives • Upon completion of this course, you will: – Understand requirements and concepts related to effort reporting • Key terms, policies, procedures and regulations • Award management activities: proposal – closeout • Roles and responsibilities – Be introduced to the Effort Reporting System (ERS) 2

Agenda • • Overview Regulations and Policies Key Terms and Concepts The Effort Reporting Lifecycle – – Appointing faculty and staff Proposing effort Charging salaries and wages Certifying effort • Case study exercises • Other training and reading • References and contact information 3

Overview • What is effort? – Effort is the time spent on any activity by an individual expressed as a percentage of total University effort. • What is effort reporting? – Effort reporting is a method for documenting activities paid by the institution for services rendered during the period of performance under sponsored agreements. 4

Overview • Why is effort reporting required? – As a condition of receiving sponsored awards, Yale must assure sponsors that the effort expended on their sponsored projects is commensurate with the salary charged to those projects and that commitments of effort made to the sponsor at the time of proposal are fulfilled. Note: Training grants and fellowships are excluded from the effort reporting requirement as stated in the Code of Federal Regulations, 2 CFR Part 220 [Office of Management and Budget (OMB) Circular A-21] and 2 CFR Part 200 [Office of Management and Budget (OMB) Circular A-81]. 5

Effort Report Certification Regulation & Policy 6

Effort Report Certification 2 CFR Part 220 (OMB Circular A-21) 2 CFR Part 200 (OMB Circular A-81) • For federal awards/subawards issued to Yale with a start date prior to December 26, 2014, 2 CFR Part 220 (OMB Circular A-21) applies. For all new funds (new awards and new monies, such as continuation awards, supplements, etc. received for existing awards) with a start date on or after December 26, 2014, these new funds are subject to 2 CFR Part 200 (OMB Circular A-81, commonly referred to as Uniform Guidance but hereinafter referred to as “ 2 CFR Part 200”). 7

Regulations and Policies • 2 CFR Part 220 (Cost Principles for Educational Institutions) and 2 CFR Part 200 (Subpart E- Cost Principles) – Appendix A to Part 220 – Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions, Section J. 10 – Compensation for Personal Services – 2 CFR Part 200. 430 Compensation- Personal Services • Provides guidance for documenting activities in support of sponsored projects • Directs the policies and procedures adopted internally at Yale and other peer institutions • Requires certain criteria for the method of documentation 8

Regulations and Policies • Section J. 10 and 200. 430 state that the method for documenting: – Reasonably reflect the activities for which an individual is paid by the University – Reflect all of the activities performed by the individual – Be made initially on reasonable estimate made before the services are performed • Specific to Section J. 10 – Include after-the-fact confirmation to ensure that initial salary charges reasonably approximate actual effort – Be certified by the employee, the Principal Investigator or responsible official using a suitable means of verification that the work was performed 9

Regulations and Policies • Yale’s Policies and Procedure: – – – Policy 1316 - Effort Commitment: Managing Effort Associated with Sponsored Projects Policy 1315 – Effort Reporting: Certifying Effort on Sponsored Projects Procedure 1315 PR. 04 – Effort Reporting 10

Key Terms and Concepts 11

Key Terms and Concepts • Minimum Proposed Effort – Faculty are expected to propose some level of sponsor supported activity or the minimum required by the program on proposals on which they are listed as Principal Investigator or key personnel unless specifically exempted by the sponsor. (Examples of exceptions to the minimum effort requirement would possibly include equipment and instrumentation grants, doctoral dissertation, travel grants, and conference awards. ) Policy 1316: Effort Commitment: Managing Effort Associated with Sponsored Projects 12

Key Terms and Concepts • Maximum Allowed Sponsored Project Effort – Most faculty generally have responsibilities for teaching, administration, or patient care that would preclude them from devoting 100% of their time to sponsored activities. – Certain research faculty, postdoctoral appointees and staff may be charged at 100% effort to a sponsored project(s) but only in cases where no such activities (Yale administration, service, clinical activity, new or competing proposal preparation and institutional governance) exist, and therefore full effort can be committed to the award(s). Policy 1316: Effort Commitment: Managing Effort Associated with Sponsored Projects 13

Key Terms and Concepts • Estimating Reasonable Effort – In preparing applications for sponsored projects funding, PIs are expected to provide reasonable estimates of the percent of effort necessary to carry out the proposed project – If awarded, the University must assure the sponsor that the effort proposed will be effectively managed within the parameters of the sponsor’s requirements and University policy. • Mixed Effort – A reasonable allocation of effort between sponsored projects activity and clinical care. Example: Research and Clinical Care • Seeing patients, some of whom are also research participants Policy 1316: Effort Commitment: Managing Effort Associated with Sponsored Projects 14

Key Terms and Concepts • Cost Sharing – The portion of total sponsored project costs not funded by the sponsor. – Cost sharing is defined as the University’s financial contribution toward a sponsored project. • Types of Cost Sharing – Mandatory Cost Sharing (requires Yale prior approval) – Voluntary Committed Cost Sharing (requires Yale prior approval) – Voluntary Uncommitted Cost Sharing Policy 1306: Cost Sharing on Sponsored Projects 15

Key Terms and Concepts • Mandatory Cost Sharing – Funding, either required by the terms and conditions of the award or by federal statute, that requires Yale to contribute toward the project as a condition of receiving the award. – Must be in the approved budget • Voluntary Uncommitted Cost Sharing – A cost associated with a sponsored project which was not committed to in the proposal or in any other communication to the sponsor. This includes effort of faculty or senior researchers that is over and above that which is committed and budgeted for in a sponsored agreement. 16

Key Terms and Concepts • Voluntary Committed Cost Sharing – A cost associated with a sponsored project, which was identified in the proposal and was not required or funded by the sponsor. – Yale University does not typically cost share effort on a voluntary basis, consistent with its objectives of receiving fair compensation from sponsors for research and scholarly activity conducted at the University. – A voluntary commitment of uncompensated effort should be made only where the competitive circumstances or perceived institutional benefit of receiving the award are deemed to be sufficiently strong to warrant the commitment. • According to 2 CFR 200. 306 (OMB Circular A-81), voluntary cost sharing on federal research proposals is not expected and cannot be used as a factor during merit review of applications or proposals. Voluntary committed cost sharing should not be included in the proposal unless explicitly described in the notice of funding opportunity. 17

Key Terms and Concepts • Voluntary Committed Cost Sharing (continued) – Approval for voluntary committed cost sharing must be obtained from the Dean for self-support units or the Provost for FAS units prior to the preparation of the budget and budget justification. Note: Both department chair and department business office approval is required prior to making a request to the Dean for selfsupport units or the Provost for FAS units. 18

Key Terms and Concepts • Voluntary Committed Cost Sharing of Effort – Effort committed in a proposal but not compensated by the sponsored project must be documented and accounted for through the effort certification process – Cost sharing accounts are established to capture this effort and associated University salary. – Cost sharing must be indicated and approved prior to the submission of the proposal. 19

Key Terms and Concepts • Calendar (Person) Months – Most sponsors require that proposals submitted include the number of person months for each individual listed in the budget devoting effort and their associated salaries – Guide 1306 GD. 01 Effort Percent/Calendar Month Conversion Tables ( http: //your. yale. edu/policies-procedures/guides/1316 -gd 01 -effortpercentcalendar-month-conversion-tables ) – This guide assists with the conversion of percentages to calendar months and vice versa for both 9 -month and 12 -month appointments. • This guide does not address the summer period. • The NIH also has a conversion tool available via this URL: http: //grants. nih. gov/grants/policy/person_months_conversion_chart. xls. 20

Key Terms and Concepts • Compensated Activities – As defined in 2 CFR Part 200. 430: “Compensation for personal services includes all remuneration, paid currently or accrued, for services of employees rendered during the period of performance under the Federal award, including but not necessarily limited to wages and salaries…” • May include fringe benefits [200. 431 Compensation- fringe benefits] • Costs of compensation are allowable when: – Satisfy the requirements of Part 200 – Reasonable and conform to Yale Policy for both Federal and non. Federal – Stem from an appointment made in accordance with Yale’s policies and meet Federal statute – Apply to all faculty members and follow the Standards for Documentation of Personnel Expenses 21

Key Terms and Concepts • Total University Effort – The total professional activity for which an individual is compensated by the University. – For faculty and other professionals, effort is NOT based on a standard work week of 37. 5 or 40 hours but rather the total time an individual devotes to activities for which Yale compensates them. – Estimate of hours representing Total University Effort are the denominator when calculating effort percentages. • Activities NOT included in Total University Effort – Consulting and other outside compensated work – Bonuses and one-time or supplemental compensation for incidental work (Policy 1001: Compensation Above Salary http: //your. yale. edu/policiesprocedures/policies/1001 -compensation-above-salary ) – Clinical effort conducted at VA Hospital NOT compensated by Yale 22

The Effort Reporting Life Cycle Effort Commitments Appointing Faculty & Staff Labor Distribution Proposing Effort Charging Salaries Effort Certification Certifying Effort Salary is charged Employment terms Effort is proposed as contemporaneous are established Verify and certify a reasonable with activity, including effort devoted to estimate; a expenditures are appointment type sponsored projects commitment is made monitored, and institutional after-the-fact to the sponsor corrections made in base salary a timely manner 23

Appointing Faculty and Staff 24

The Effort Reporting Life Cycle Effort Commitments Appointing Faculty & Staff Employment terms are established including appointment type and institutional base salary 25

Appointing Faculty and Staff • Appointment letter – Helps set and define: • Full workload • Faculty effort • Institutional base salary • Appointment types – 9 -Month – 12 -Month – Joint (specifically, VA and Yale) • Faculty Handbook – Provides information on University policies and practices as they pertain to faculty – Can be found here: http: //provost. yale. edu/faculty-handbook 26

Appointing Faculty and Staff Appointment Types • 9 -Month and 12 -Month Appointments – 9 Month Appointment • 9 -month period (September – May) constitutes the full workload. • Faculty on 9 -month appointments paid over 12 months are paid in advance during July and August of each year of appointment and must complete the academic year to have earned that salary. • Faculty devoting effort to sponsored research have an option to elect payment of salary over 9 months. • Summer compensation (in addition to regular salary) is possible. – 12 -Month Appointment • Faculty appointments to the research ranks are normally made on a 12 -month basis and depending on the school may begin and end at any time of the year. 27

Appointing Faculty and Staff Appointment Types • Joint Appointments The reference to Joint Appointments in the context of discussing effort reporting is limited to faculty that hold an appointment at both the Veteran’s Affairs Connecticut Healthcare System (VACHS) and Yale University. – A Memorandum of Understanding (MOU) between Yale University and the VACHS for those individuals participating in sponsored research that hold joint appointments with Yale University and the VACHS is required by the National Institutes of Health (NIH). • A MOU is an agreement that outlines the terms and details of an agreement between parties, including each party’s expected activities and goals. – The MOU must be updated not less than annually and with each significant change as related to responsibilities and distribution of effort. Guide 1411 GD. 01: VA Memorandum of Understanding Requirements: faculty with both a Veteran’s Administration Medical Center and Yale University joint appointment. 28

Appointing Faculty and Staff Institutional Base Salary • Establishment of Institutional Base Salary – Institutional Base Salary (IBS) • IBS is the annual compensation paid by the University for an employee’s appointment, whether that individual’s time is spent on research, teaching, patient care or other activities. – The IBS does not include: • Bonuses, one-time payments or incentive pay. • Salary paid directly by another organization including but not limited to the West Haven Veterans Administration Hospital (VA) or Howard Hughes Medical Institute (HHMI) or; • Income that an individual is permitted to earn outside of their University responsibilities such as consulting. Policy 1311: Institutional Base Salary for Sponsored Projects 29

Appointing Faculty and Staff Summer Salary • Summer Salary – Faculty compensated for 9 -month academic appointments are permitted to expend up to an additional 2. 5 months of summer effort on one or more sponsored projects in the period beyond the academic year (i. e. , during the summer research period) and earn up to 2. 5 months of additional salary for that effort, subject to sponsor and University policies and the approval of the department chair and dean/provost. – A request to the Provost’s Office for summer salary indicates a commitment to put forth the comparable effort on the particular project during the summer, not the academic year. Effort expended during the academic year does not satisfy a commitment related to the receipt of summer salary. 30

Appointing Faculty and Staff Summer Salary • Summer Salary (continued) – Faculty are not permitted to indicate unpaid summer effort in a proposal to a sponsor. Because the University is not obligated to pay faculty salary during the summer, unpaid committed summer effort has no monetary value and therefore may not be included in applications as a commitment of the PI or the University. – If a faculty member has academic, administrative or other nonresearch responsibilities during the summer period, they may be precluded from devoting 100% effort to sponsored projects and thus from requesting 2. 5 months of salary from those sponsored projects. 31

Appointing Faculty and Staff Summer Salary • Summer Salary – 2 CFR Part 200. 430 stipulates that charges for work performed in periods outside of the academic year may be charged at a rate that does not exceed IBS Note: The National Science Foundation (NSF) normally limits salary compensation for senior project personnel on awards made by the Foundation, to no more than two months of their regular salary in any one year (Yale defines “any one year” as within a fiscal year, July to June). This limit includes salary received from all NSF funded grants. • Payment of salary from NSF funds must be commensurate with the effort devoted to the award. Effort can be devoted in the summer or during the academic year for 12 month faculty and 9 -month faculty participating in the 9 -over-9 program. 32

Appointing Faculty and Staff FAS and FES 9 -over-9 Salary Allocation Program • FAS and FES 9 -over-9 Program – The 9 -over-9 salary program allows participating faculty to charge up to 4. 5 months of their salary to sponsored awards during the academic year, coincident with when the effort was devoted to the project. – Academic year effort and corresponding salary charged to sponsored projects during the academic year is separate and apart from the effort and associated salary charged during the summer months (i. e. , summer salary). http: //provost. yale. edu/faculty/policy/9 -over-9 33

Appointing Faculty and Staff Summer Salary • Faculty with 9 -Month Appointments Who are NOT Participating in the 9 -over-9 Program • • • Effort devoted to a sponsored project usually occurs throughout the calendar year. For faculty on 9 -month appointments this effort is generally paid for by the University during the academic year, while the sponsor pays their effort in the summer. Faculty with nine-month appointments who devote such effort to a sponsored project during the course of the academic year may continue to do so but only without formally committing a specific amount of academic-year effort in the proposal unless they elect to participate in the 9 -over-9 program. In general, faculty on 9 -month appointments who are not enrolled in the 9 -over-9 program must meet all explicit sponsor requirements for commitment of effort via summer salary. 34

Appointing Faculty and Staff Compensated Activities • Activities that do not benefit a sponsored award – Mentoring a junior faculty member who is writing a grant proposal – Writing a new grant application – Serving on the Human Investigation Committee (HIC) or a committee in the Office of Animal Research Support. – Serving on an National Institute of Health (NIH) study section – Serving on an National Science Foundation (NSF ) Peer Review Panel – Effort expended on departmental/University research – Instruction/University supported academic effort 35

Appointing Faculty and Staff Compensated Activities • Activities that benefit a sponsored award and translate to effort – – Effort devoted to the conduct of the research Writing a progress report for an existing grant Holding a research meeting with staff Attending a scientific conference related to your research held by an outside professional society – Reading scientific journals to keep up to date with the latest advances in the specific field of research – Serving on committees or advisory councils that are part of and specific to an individual award 36

Proposing Effort 37

The Effort Reporting Life Cycle Effort Commitments Appointing Faculty & Staff Proposing Effort Employment terms Effort is proposed as are established a reasonable including estimate; a appointment type commitment is made and institutional to the sponsor base salary 38

Proposing Effort Requesting Salary Support • Requesting Salary Support – Levels of effort proposed in any sponsored project application should be consistent with the actual effort that each individual is expected to expend on the project during the relevant project period(s). – Proposed level of effort must be expressed in accordance with sponsor requirements, usually in person months. 39

Proposing Effort Graduate Student Stipends and Tuition Remission • Requesting Salary Support – If a proposal requests support for a graduate student in the form of a stipend, the appropriate amount of tuition remission should also be requested from the sponsor. – For example, a principal investigator budgets for a FTE graduate student at a stipend of $17, 000 per year. The tuition remission in the budget would be at a rate of 50% of $34, 500 (total cost of tuition for the year) or $17, 250. 40

Proposing Effort Career Awards • Career Development Awards – Often referred to as a K award because of the NIH sponsor reference number assigned to it, a career development award provides a Principal Investigator with ‘protected time’ and/or emphasizes a period of intense research intended to enhance his/her research career. – K awards generally require a minimum amount of committed effort. – The NIH K Kiosk is an important source of information when managing a K award. The URL is: http: //grants. nih. gov/training/careerdevelopmentawards. htm – Certain K awards have salary limitations. Because effort commitments must be met, salary paid above the limitation is recorded as mandatory cost sharing. 41

Proposing Effort • Salary Rate Cap – As part of the Consolidated Appropriations Action, 2012 (Public Law 112 -74) DHHS agencies with the exception of the FDA and the Indian Health Service are required to: • Impose a salary rate cap applicable to grants, cooperative agreements and contracts (with the exception of those that are clearly defined to be exempt from the cap). • Set the salary rate cap at the Executive Level II of the Federal Pay schedule. • Sponsors (federal and non-federal) other than the sponsors identified above may have a salary reimbursement limitation as a matter of policy; and • Sponsors (federal or non-federal, including subawards or pass-thru awards made to Yale) may have a salary rate cap that may be program specific, limiting the recovery of salary. 42

Proposing Effort • Salary Rate Cap – It is important to note that the sponsor’s funding announcement as well as the terms and conditions of an award must be carefully read in order to determine if a salary limitation exists. – Salaries charged to awards that are subject to a sponsor imposed rate cap e. g. , NIH, AHRQ may not exceed the federal Executive Level II rate. • The Executive Level II rate is usually announced every January. – Total capped salary may be charged only if the individual is working 100% on that sponsored project. – In general, faculty with 9 -month appointments are not paid summer salary over the cap, however the % effort committed must still be expended. – YSM faculty on 12 -month appointments generally are paid salary over the cap. – Salary over the cap CANNOT be charged to another sponsored project. 43

Proposing Effort • Salary Rate Cap example – Individual with a 12 -Month Appointment devotes 40% effort to an NIH award • Monthly salary – $240, 000/12 = $20, 000 • Amount of the salary associated with effort on this award: – $20, 000 x. 40 = $8, 000 • Monthly salary rate cap: – $187, 000/12 = $15, 583 • Amount of the salary rate cap that can be charged to the award: – $15, 583 x. 40 = $6, 233 • Subtract capped salary from uncapped salary: – $8, 000 - $6, 233=$1, 767 • In this example, $6, 233 can be charged to the sponsored award; the remaining amount is captured in a linkage account. 44

Proposing Effort Responsibilities • Business Office Responsibilities – Advise faculty regarding preparation of budgets and effort commitments in sponsored project proposals – Monitor current and pending effort commitments – Inform faculty regarding availability of effort to meet commitments. – Advise faculty regarding consequences of effort commitments and cost sharing and assist in obtaining required approvals – Identify the accounts from which cost sharing will be funded – Ensure consistency throughout proposal regarding effort commitments. 45

Reducing Effort after Proposal/Award • Reduction of Effort – PIs and/or key personnel named in the application and/or award must obtain University and sponsor prior approval for reductions in effort when such approval is required by the sponsor • This requirement usually applies to the individual(s) named in the award document for federal granting agencies. • PI is responsible for obtaining prior approval from the sponsor for reductions of effort of ≥ 25% (federal awards) or absence from the project of 3 months or more. • Notifying the sponsor of such a change via a Progress/Technical/Continuation Application/Report is inappropriate. – Prospectively, it is acceptable to notify the sponsor in a progress report but not for what already occurred. Contact your OSP Award Manager for assistance with post-approval. 46

Charging Salaries & Wages 47

The Effort Reporting Life Cycle Effort Commitments Appointing Faculty & Staff Labor Distribution Proposing Effort Charging Salaries Salary is charged Employment terms contemporaneous are established Effort is proposed as with activity, including reasonable estimate; expenditures are appointment type a commitment is monitored, and institutional made to the sponsor corrections made in base salary a timely manner 48

Charging Salaries Setup • Creating a New Sponsored Project Award When a proposal is awarded, a new account is created in order to appropriately allocate allowable costs in the Oracle financial system. – The new account will include a seven-digit sponsored project number and a 6 character alpha-numeric award. – If there is any associated cost sharing, an additional nonsponsored award will be “linked” with the new sponsored project. – Direct costs are charged to the sponsored project and sponsored award. – Cost sharing is charged to the same seven-digit project and the linked non-sponsored award. 49

Charging Salaries • Salary Distribution – Salary distribution consistent with the committed effort should begin on sponsored projects (or cost sharing) accounts concurrently with actual project effort. – Yale University’s effort reporting process relies on payroll data to provide information on the projects to which an individual’s salary was charged during the certification period. 50

Charging Salaries • Salary Distribution and Effort Distribution – Salary Distribution reflects the salary charged to an activity via the payroll system. – Effort distribution reflects an individual’s time spent on an activity. NOTE: – Effort reporting periods may not coincide with the annual budget periods for which effort commitments are normally made. – The effort reporting process offers an opportunity to consider whether the actual effort expended during the reporting period is consistent with the effort commitment and charging of salary. 51

Charging Salaries • Earning Elements – Earnings that are considered non-recurring are generally entered into the Labor Distribution Module as an element-level labor schedule and charged to the appropriate project, task, award and organization (PTAO) combination. – When an element-level labor schedule is not present for earnings above an individual’s normal recurring pay, payroll may be incorrectly allocated. • As an example, an individual earns supplemental compensation from the School of Music but normally works for the School of Law. If the elementlevel labor schedule is not defined, the School of Law will be inappropriately charged for the work performed for the School of Music. – Because certain earnings are excluded from the effort reporting requirement, departments should take special care to distinguish earnings for both staff and graduate students. 52

Effort Report Certification 53

The Effort Reporting Life Cycle Effort Commitments Appointing Faculty & Staff Labor Distribution Proposing Effort Charging Salaries Effort Certification Certifying Effort Salary is charged Employment terms contemporaneous are established Effort is proposed as Verify and certify with activity, including reasonable estimate; effort devoted to expenditures are appointment type a commitment is sponsored projects monitored, and institutional made to the sponsor after-the-fact corrections made in base salary a timely manner 54

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Effort Report Certification Procedure 1315 PR. 04 Completing the Certification Process Central Administrator Pre Review (Business Office) Certification Effort Not Changed Effort Changed Post Review (Business Office) Complete! 56

Central Administrator (CA) • Initializes new Effort Reporting cycle • Sends notification to Pre Reviewers Pre Review • Business Office Pre Reviews effort forms; makes cost transfers and/or sets up cost sharing accounts if necessary • When complete, automatic e-mail notification is sent to Certifier Certify • Certifies actual effort by award in terms of percentages of total effort expended • If percentages were updated and form is certified an automatic email is sent to the Post Reviewer Post Review • Business Office Post Reviews the effort forms if Certifiers have made changes to the effort percentages reflected in Pre Review 57

Effort Report Certification Procedure 1315 PR. 04 • System Access – Training is required. • • • Introduction to Sponsored Projects Administration Effort Reporting Principles with Quiz (i. e. , this course) Effort Reporting System Cost Transfer Principles Labor Distribution Module Data Warehouse Portal – Access is periodically monitored. Procedure 1315 PR. 04 Effort Reporting 58

Effort Report Certification The Effort Report Form 59

Effort Report Certification The Effort Report Form Pre Review 60

Effort Report Certification The Effort Report Form Certification Shows sponsored and nonsponsored activities Shows payroll and actual effort %. 61

Effort Report Certification The Effort Report Form • Payroll Percentage Column – Definition: The percent of the total University salary charged to each funding source during the effort reporting period. • The percentages in the payroll column are for informational purposes only. • Percentages represent the distribution (averaged over the reporting period) of the covered individual's compensation among the listed sponsored projects and other activities. • That distribution may or may not be consistent with the distribution of Actual Effort on the projects and activities. 62

Effort Report Certification The Effort Report Form • Actual Effort Percentage Column – Definition: The amount of time (expressed as a percent of all University compensated activities) that was spent on an activity during the reporting period. • Effort devoted and paid to the account • Actual effort promised to the sponsor in the proposal but paid with non-sponsored project funds • Time spent on a project above and beyond what was indicated in a proposal and not charged to the project (commonly referred to as voluntary uncommitted cost sharing) during the reporting period. Because no account would be charged for this effort, it should be reflected in the NOTES box. 63

Effort Report Certification The Effort Report Form • Sponsored activities – Includes effort devoted to grants, contracts and other cooperative agreements sponsored by non-University entities • Non-sponsored activities – Includes effort devoted to departmental business activities, instruction, administration and clinical activities • Effort report must always total 100%. 64

Effort Report Certification Yale Policy 1315 65

Effort Report Certification Yale Policy 1315 • Yale Policy 1315: Effort Reporting: Certifying Effort on Sponsored Projects – – – Purpose of the Policy Proposing Effort and Requesting Salary Support Establishment of Salaries on Sponsored Project Accounts Completion and Certification of Effort Reports Summer Effort/Salary for Faculty with 9 -Month Academic Appointments – Salary Reallocations and Recertification – Sanctions for Non-compliance 66

Effort Report Certification Yale Policy 1315 • Purpose of the Policy – The University must assure sponsors that the commitment indicated (included mandatory and voluntary committed cost sharing) in the proposal and subsequent award is met in accordance with sponsor’s terms and conditions. – Periodic effort reports are required for each individual whose salary is charged to one or more sponsored projects and/or cost sharing accounts during the effort reporting period 67

Effort Report Certification Yale Policy 1315 • Completion and Certification of Effort Reports – On a regular basis an effort report form will be generated from the University’s effort reporting system [in most cases]. – The effort report forms will contain data indicating the percentages of the individual’s University salary that were allocated to sponsored project accounts and other University activities. – If salary percentages reflect the actual effort, the person completing the form (certifier) should certify the effort report form in accordance with University procedures. 68

Effort Report Certification Yale Policy 1315 • Completion and Certification of Effort Reports (cont. ) – Faculty members are required to certify their own effort reports. – A PI should certify the effort reports of the research staff working on his or her sponsored projects. – A Laboratory or Project Manager/Director, using a suitable means of verification that the work was performed, may certify effort reports for research staff. • A suitable means of verification is defined as having direct knowledge of the work performed. This would be documented by determining work assignments and determining the awards to which the work assigned applies. 69

Effort Report Certification Yale Policy 1315 • Completion and Certification of Effort Reports (cont. ) – Any covered individual may sign his/her own effort report. The individual is expected to fully understand his/her funding and level of effort committed to each sponsored project. – A department research administrator or business manager does not have the knowledge of an employee’s Total Work Effort and should not certify the effort of research staff. This is a PI or qualified lab manager/director responsibility. 70

Effort Report Certification Yale Policy 1315 • Completion and Certification of Effort Reports (cont. ) – When certifying graduate student effort represented in the form of a Stipend charged to an award, the PI/responsible individual is also certifying the tuition remission is proportional to the student’s level of effort and Stipend directly charged to the award. 71

Effort Report Certification Yale Policy 1315 • Salary Reallocations and Recertification – If it is necessary to adjust the salary charges for a previously certified effort period, documentation must provide a detailed explanation of the need for the salary adjustment and subsequent recertification. – Once certification of effort has been completed, only in certain rare circumstances will subsequent salary adjustments be permitted. 72

Effort Report Certification Yale Policy 1315 • Sanctions for Non-compliance – Failure to follow the provisions of this effort reporting policy may subject the individuals and departments responsible for the violation(s) to administrative and/or disciplinary actions in accordance with University disciplinary procedures and the judgment of management. – See Policy 1315 for specific information. 73

Effort Report Certification Process, Roles & Responsibilities 74

Effort Report Certification Procedure 1315 PR. 04 • Procedure 1315 PR. 04: Effort Reporting – – – Roles and Responsibilities Access to ERS Completing the Certification Process Monitoring Notifications and Escalation Frequently Asked Questions 75

Effort Report Certification Procedure 1315 PR. 04 • Overview – The Office of Sponsored Projects department’s Effort Reporting Central Administrator (CA) initiates effort reports and monitors completion rates for all departments via the Effort Reporting System (ERS). 76

Effort Report Certification Procedure 1315 PR. 04 • Timing – Effort reports are initiated in the months shown below – Effort reports should be certified within 60 calendar days from the date of availability notification Effort Period Covered Individuals Spring and Fall Academic Term (January & June) Graduate students Summer (September) Graduate students and 9 -month Faculty summer compensation Semiannual (January & July) Professionals, Faculty and Staff 77

Effort Report Certification Procedure 1315 PR. 04 • Timing – Certification for certain personnel that are paid weekly, such as casuals and undergraduate students is accomplished through signature verification by the appropriate individual within the certification block on the Temporary Employee Payment Request form 3501 FR. 05. – For departments using the e. Timesheet system for students, the supervisor of the student certifies electronically to the hours worked. 78

Effort Report Certification Procedure 1315 PR. 04 • Completing a Manual Effort Report – The following are examples of when an effort report may not automatically generate in ERS: • Covered individual is on the Executive (Confidential) Payroll • Covered individual is on sabbatical leave for the entire effort period and is continuing his/her commitment to the sponsored project • Individuals paid 100% by a non-Yale source [i. e. , Howard Hughes Medical Institute or the Veteran’s Affairs Connecticut Healthcare System (VACHS)] – If a situation occurs where an effort report is not generated, it is the responsibility of the business administrator to complete the Effort Report template and have the form appropriately certified. 79

Effort Report Certification Procedure 1315 PR. 04 Manual Form 80

Effort Report Certification Procedure 1315 PR. 04 • General Overview – Exiting PI/Faculty Member – Prior to a Principal Investigator’s (PI) or faculty member’s permanent departure from Yale, s/he is required to complete the requisite Effort Reports for him/herself and those for which they are directly responsible. 81

Effort Report Certification Procedure 1315 PR. 04 • Roles and Responsibilities – Central Administrator (CA) • The Effort Reporting Central Administrator determines which reporting periods need to be generated. The CA generates effort reports for all departments and notifies Department Coordinators, Sub Department Coordinators and Pre Reviewers via e-mail when effort reports are ready for the certification process. The Central Administrator monitors overall completion by department for the University, performs routine maintenance to ensure data integrity, and supports the certification process. – Division Head (DH) • The Division Head provides support to both the CA and the Department Coordinator to ensure timely completion of certification. The Division Head is responsible for escalating effort reporting issues to OSP, BOLT and/or Department Chairs as appropriate. 82

Effort Report Certification Procedure 1315 PR. 04 • Roles and Responsibilities – Department Coordinator (DC) • • • Typically, the department business manager/administrator Determines and assigns review responsibility Ensures compliance with policy Understands sponsored projects administration Provides assistance to staff and faculty who participate in the effort process • Guides certifiers in the use of the Effort Reporting System • Identifies reasons for outstanding certifications and assists Division Head with escalation – Sub. Department Coordinator (Sub. DC) • Has the same responsibilities as the DC 83

Effort Report Certification Procedure 1315 PR. 04 • Roles and Responsibilities – Pre/Post Reviewers • Assists the DC and/or Sub. DC in facilitating a timely and efficient process for those required to certify effort • Reviews effort reports and makes appropriate adjustments both prior to and after review by the certifier • Has knowledge of proposal budgets and effort commitments applicable to the grant accounts under his/her review • Provides assistance to faculty who participate in the effort process • Ensures cost transfers are in accordance with University policies and sponsor terms and conditions 84

Effort Report Certification Procedure 1315 PR. 04 • Roles and Responsibilities – Certifiers • Must be aware of the level of effort committed to sponsored projects • Review the effort form to make sure the percentages correctly represent the covered individual’s effort • Note voluntary uncommitted effort or career development award concurrent effort in the Notes box • Communicate any significant changes in level of sponsored projects effort to his/her Department Coordinator 85

Case Study Exercises 86

Case Study Exercises Case Study One • Dr. Smith, a new clinical faculty member, would like to pursue a career in research. His application to the NIH for a Career Development award requires 75% effort. – Dr. Smith currently spends 30% of his time attending departmental rounds, 40% seeing patients and 30% working the ICU in the evenings. – He plans to stop seeing patients during the workday to accommodate his schedule for the K award. • Q: By making this change, will Dr. Smith meet his obligation to the NIH? 87

Case Study Exercises Case Study One • No – In order to meet the requirements of the sponsor, Dr. Smith would have to devote even less effort to other activities. If not, the award may be in jeopardy and the sponsor must be contacted. Practically, Dr. Smith should reduce the amount of time devoted to his non-sponsored activities to assure that sufficient % effort can be devoted to meet the sponsor’s requirements. • Note that the ≥ 25% rule would not apply since the 75% effort commitment is a condition of the award. ANY reduction in effort for this type of award MUST be discussed with the sponsor. 88

Case Study Exercises Case Study Two • Dr. Spruce has a 12 -month faculty appointment. She spends 50% of her time on research and 50% on teaching and administrative duties. Her 50% research is split evenly between two awards. Dr. Spruce has made an important discovery on one award and in order to confirm her results, she spends less time on her administrative effort. • Q: Does her effort report need to change? • Q: If so, how? • Q: If not, why? 89

Case Study Exercises Case Study Two • Yes, Dr. Spruce’s effort report does need to change. – The increase in effort on the award is considered to be voluntary, uncommitted effort supported by administrative dollars. – Dr. Spruce either needs to indicate the increased percentage of effort on the Effort Report in the Notes box or she could charge the additional salary to the award and reduce the administrative portion of her salary. – Voluntary uncommitted effort does not need to be captured in a cost sharing account. 90

Case Study Exercises Case Study Three • Dr. Jones devotes 10% of his time to an NIH award. His institutional base salary is above the NIH salary cap amount by 2%. • Q: How should his labor schedule be set up? • Q: What will his effort report look like? 91

Case Study Exercises Case Study Three • 8% of Dr. Jones’ salary can be charged to the NIH award. • 2% of Dr. Jones’ salary is captured in a linkage account. • The effort report will reflect 10% to sponsored activities and 90% to non-sponsored activities. 92

Other Training & Reading 93

Other Training & Reading • Council on Government Relations (COGR) – Compensation, Effort Commitments and Certification – http: //www. rsp. wisc. edu/effort/COGR_Effort. Paper. pdf • The Office of Management and Budget, 2 CFR Part 220, Section J. 10 (OMB Circular A-21) – https: //obamawhitehouse. archives. gov/sites/default/files/omb/assets/omb/fedreg/2005/083105 _a 21. pdf – 2 CFR Part 200, Subpart E Cost Principles 200. 430 Compensation- personal services (OMB Circular A-81) – http: //www. ecfr. gov/cgi-bin/textidx? SID=60623 b 20 e 6213558 b 4 aa 6 ab 7 eb 76 b 619&node=2: 1. 1. 2. 2. 1. 5&rgn=div 6#se 2. 1. 200_1 430 • OMB Memorandum – Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing (abbrev. ) – https: //obamawhitehouse. archives. gov/omb/memoranda_m 01 -06/ • Yale Office of Research Administration – Effort Reporting Pocket Guide – Found here: http: //your. yale. edu/sites/default/files/risfinalpcktguide. pdf 94

References & Contact Information 95

References & Contact Information • Policies, Procedures and Forms available on Yale’s Policies and Procedures website: http: //your. yale. edu/policies-procedures • https: //your. yale. edu/sponsored-projects-administration – Policy 1315: Effort Reporting: Certifying Effort on Sponsored Projects – Policy 1316: Effort Commitment: Managing Effort Associated with Sponsored Projects – Policy 1306: Cost Sharing on Sponsored Projects – Policy 1311: Institutional Base Salary for Sponsored Projects – Procedure 1315 PR. 04: Effort Reporting – Procedure 1315 PR. 03: Salaries Above a Sponsor Imposed Rate Cap – Procedure 1306 PR. 01 Cost Sharing – Form 1315 FR. 01 Effort Report and Instructions • Office of Sponsored Projects website for effort reporting related items – http: //your. yale. edu/research-support/office-sponsored-projects/financialmanagement/effort-reporting 96

References & Contact Information • Jessica Gray Effort Reporting Central Administrator Office of Sponsored Projects effort. reports@yale. edu 203 -785 -3517 • Nancy Kendrick Director Office of Sponsored Projects 203 -785 -3076 97

Questions? Contact: effort. reports@yale. edu 98