2013 06 03 HCCA Effort Rptg Presentation€¦ · 3. Other Salary 2. Summer Salary: Salary paid...
Transcript of 2013 06 03 HCCA Effort Rptg Presentation€¦ · 3. Other Salary 2. Summer Salary: Salary paid...
Road Map to Effort Reporting
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Road Map to Effort Reporting
Monday, June 3, 2013
Presenter: Kerry BorawskiCPA, CHRC, MBA
Research Compliance Auditor
Session 103:
• Today’s Objectives:• OIG Attention to Effort Reporting• Proposed OMB Uniform Guidance• Requirements of Time & Effort Reporting• St. Louis University’s Process
• Planned Confirmation • Roles & Responsibilities
• Fact or Fiction
Collaborate – To work, one with another; To cooperate.-Dictionary.com
• Effort Reporting • Is a process for employees• To VERIFY the time they spent on sponsored projects
• To CERTIFY that we charged the correct salary to those projects
Applies to ANYONE who has charged time to an award.Ex = Principal Investigator, Graduate Assistant, Administrator, Lab
Tech, Co-Investigator, etc.
Road Map to Effort Reporting
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• Current Regulations• OMB Circular A‐21 – Cost Principles for Educational Institutions
• OMB Circular A‐133 –Compliance Supplement
In order for the University to accept any federal funds, including federal financial aid, then we must obey the Effort Reporting requirements
• Proposed Regulations• OMB Uniform Guidance: Cost Principles, Audit, & Administrative Requirements for Federal Awards
• “Super Circular”• Name Change to “Documentation of Personnel Expenses”
Many argue that the Super Circular has successfully merged the various circulars in most areas, with the EXCEPTION of Time & Effort
• A‐21, Three Methods:• Plan Confirmation• After‐the‐Fact• Multiple Confirmation Records
After-the-Fact records requirement aligns most closely with the othercirculars’ time distribution rules.
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• Proposed Regulations:• General reqm’t stays the same• Type depends on # of Cost Objectives worked on by each employee
• Certified Reports should be:• Integrated with payroll system• Certified• Kept using % or Hours
For employees working on MULTIPLE Cost Objectives, some requirements are laid out but there remains flexibility with each awarding agency.
Effort Reporting Process
Referred to as a “Plan Confirmation Process”
EPAFLabor
Reallocation (LR)
Effort Report (EVR)
ActualPlanPlan
• EPAF – Electronic Personnel Action Form
The form used to create the payroll record for a University employee.
EPAF
Allocates the percent of time the employee intends to spend on each segment of their job. For ex –Teaching responsibilities are paid from a separate
fund than Research responsibilities.
Plan
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• LR – Labor Reallocation
Labor Reallocation
When changes are identified, this prompts the new Allocation for the percent of time the employee intends to spend on each segment of their job.
A correcting journal entry to redistribute payroll to a different funding source.
Plan
EVR‐Effort Verification Report
Form used to certify an individual’s effort for a reporting period
Effort Report (EVR)
1. Effort Reportable Salary
2. Summer Salary
3. Other Salary
Actual
EVR‐Effort Verification Report
Effort Reportable Salary = Institutional Base Salary (IBS)
Effort Report (EVR)
1. Effort Reportable Salary
2. Summer Salary
3. Other Salary
1. Institutional Base Salary (IBS):
Total compensation paid to an employee for all
professional activities they provide to the University within their appointment.
Effort Reportable Salary = Institutional Base Salary (IBS)(1) Instruction, (2) Research, (3) Clinical, (4) Administration
Actual
Road Map to Effort Reporting
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EVR‐Effort Verification Report
Full Time Staff and Faculty with 12 month appointments would NOT be eligible b/c they work all 12 months.
Effort Report (EVR)
1. Effort Reportable Salary
2. Summer Salary
3. Other Salary
2. Summer Salary:Salary paid during the
summer months for work done outside of the normal
contract period.
Actual
EVR‐Effort Verification Report
Effort Report (EVR)
1. Effort Reportable Salary
2. Summer Salary
3. Other Salary
3. Other Salary:Incentive, Bonus, On-Call
Pay, Overload, Supplemental
Used to capture “Total Professional Effort”,
includes all activities that comprise employee’s total
W-2 wages
Institutional Base Pay (Research, Instruction, Clinical, Admin)+ Other Salary (Incentive, Bonus, Overload, Supplement)
Total W-2 Wages
Actual
•QUESTION:•Which activities, specifically, are categorized within each of the 3 sections on the Effort Report?
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The Effort Report separates the salary figures into three distinct sections:1) Effort Reportable
Salary2) Summer Salary3) Other Salary
1. Teaching Research Methods course, Sept-Dec
2. Teaching Research Methods course, Jul-Aug
3. Co-Investigator on Example Grant, Sept-Dec
4. Co-Investigator on Example Grant, Jul-Aug
5. Outstanding Performance Bonus, Dec6. Mentoring Students, Dec7. Proposal Writing, Dec8. Chair of St Louis Foundation, Dec9. Investigator-Initiated Non-Funded
Research, Dec10.Clinical Trial Nurse, Dec
Assume a 9‐month faculty appointment …
Effort Reporting Process
Referred to as a “Plan Confirmation Process”
EPAFLabor
Reallocation (LR)
Effort Report (EVR)
ActualPlanPlan
•QUESTION:•What happens with my Zero Credit Hour Graduate Reading Course? I don’t get paid for that class.
Instruction means Teaching & Training Activities whether credit is granted or not
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•QUESTION:•What happens with my unfunded research?
Research means a systematic investigation, including research development, testing and evaluation, designed to develop or contribute to generalizable knowledge.
• Sponsored Research•University Research•Other Institutional Activities
The PI has ultimate responsibility for
ensuring compliance requirements are met on their sponsored
awards.
FACT
Effort reporting is optional. Even if I am paid on a sponsored
program, if my Business Manager says “I’m
exempt”, then I don’t have to do it.
FICTION – If paid on a federal award, you must complete an Effort Report. Only Exception is for employees paid on weekly Time Sheets.
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Effort reporting reflects a “Reasonable
Estimate” of how my time was spent.
FACT
The Effort Report is someone else’s attempt at showing how I spent
my time.
FICTION – Only you know how you spent your time.
EVR‐Effort Verification Report
When investigators leave the University, the formal HR Exit Process prompts them to complete their Effort Report.
Effort Report (EVR)
1. Effort Reportable Salary
2. Summer Salary
3. Other Salary
1. Every 6 months1. January-June2. July-December
2. Investigator must sign it1. Or someone with
“…suitable means of verification”
3. Finalized w/in 30 days of distribution
Actual
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Total Professional Effort
Total Professional Effort is NOT based on a 40-hour work week NOR is it based on a Full Time Equivalent (FTE).
Scenario – New Employee:
100% Appointment
Time
Appointment
Total Professional Effort
Total Professional Effort is NOT based on a 40-hour work week NOR is it based on a Full Time Equivalent (FTE).
Scenario ‐ Add Research:80% Appointment20% Grant
Time
Appointment
Grant
Yahoo!
Total Professional Effort
Total Professional Effort is NOT based on a 40-hour work week NOR is it based on a Full Time Equivalent (FTE).
Scenario ‐ Add Admin:75% Appointment20% Grant5% Admin
Time
Appointment
Grant
Admin
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Total Professional Effort
Total Professional Effort is NOT based on a 40-hour work week NOR is it based on a Full Time Equivalent (FTE).
Scenario ‐ Add Overload Teaching:
75% Appointment20% Grant5% Admin
Total Institutional Base Salary (IBS)
$5,000 Overload ______TeachingTotal Other Salary
Time
Appointment
Grant
Admin
Ovrld Teach
• Incidental Pay• Payment made to University employee for activities done Outside the Scope of their Total Professional Effort & Institutional Base Pay
It is Minimal, Infrequent in Nature, and Outside the Scope of their Normal University Role.
Effort Reporting ProcessCollaborative System that expects Continuous Communication
EPAFLabor
Reallocation (LR)
Effort Report (EVR)
ActualPlanPlan
Employee, Dept Admin, Bus Mgr & Payroll
Employee, Dept Admin, Bus Mgr & Payroll
Employee, Dept
Chair, PI & Spon Pro
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• System Improvements:• Pending Funds• Timeliness• Electronic Memo of Agreement
• EPAF improvements
University’s System is a Work in Process
Total Professional Effort always equals 100%.
FACT
Personnel who work > 40 hours/week should report 100% effort on their EVR, regardless of how many hours they
work.
FACT
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Part time personnel should report 100% effort on their EVR,
regardless of what FTE the appointment
represents.
FACT
If I identify an “itty‐bitty little change” on my Effort Report, I don’t
need to bother to adjust it with a Labor Reallocation.
FACT for changes less than 6% of Institutional Base Pay
Late or Unsigned Effort Reports have no impact on the allowability of the salary expense.
FICTION – late & unsigned reports reflect Unallowable Expenses
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Employees should NOT be 100% funded on Sponsored Activity.
FACT - The 100% question applies to Category #1 Effort Reportable Salary AND to Category #2 Summer Salary
The Research Division is responsible for
repayment of any unallowable costs.
FICTION – The Principal Investigator’s Department is responsible for unallowable costs.
The Time & Effort System asks me to record how I spend
every minute of my day with “Time Clock” detail
FICTION – Time and Effort records should support your “Reasonable Estimate”
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• Take Away Message:• You should feel CONFIDENT about signing your Effort Report.
SLU Ethics Hotline is 1-877-525-KNOW (5669)
What’s Next?•Pending Changes due to OMB Proposed Guidance•Open Floor Up for Questions & More Discussion
Thank You.
Presenter: Kerry BorawskiCPA, CHRC, MBA
Research Compliance Auditor
(314) 977‐7720