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Effort Reporting: Total Professional Activity vs. Institutional Activity

Effort Reporting: Total Professional Activity vs. Institutional Activity

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Effort Reporting: Total Professional Activity vs. Institutional Activity

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  1. Effort Reporting:Total Professional Activity vs.Institutional Activity

  2. Salary and Wage CostsWhat NIH Expects • Charges for salaries and wages will reflect actual effort expended--not necessarily the proposed or budgeted effort • Charges for salaries and wages, whether treated as direct costs or indirect costs, will be based on documented payrolls/effort reports approved by a responsible official of the organization • Significant changes in actual effort vs. budgeted effort will be adjusted

  3. What is a Significant Change? • No precise definition • Determination should be made by the employee or the individual who certifies the effort report • Any changes made by the individual or certifying official should be considered significant

  4. Significant Change • General Rule: A change applicable to a given project or activity of 5% or more of an employee’s TOTAL effort would require an adjustment to the effort report

  5. Salary and Wage Costs- Cost Transfers • Used to correct errors or changes in effort certified vs. budgeted effort • Must be well documented • Must be made in a timely manner

  6. Personnel - Prior Approval • Required for change in a key person specified on Notice of Grant Award (NGA) Always Principal Investigator (PI) • Key Person: an individual identified in the application who contributes to the scientific development or execution of the project in a substantive way, whether or not salary is requested

  7. Personnel - Prior Approval • Required if PI or other key personnel named on the NGA will: • Withdraw from the project completely • Be absent 3 months or more • Reduce time devoted to project by 25% or more

  8. Prior Approval • Required for: Change in scope or objective of a project Change in Scope is a change in direction or other area that constitutes a significant change from the aims, objective, or purpose of the originally approved project (significant change in effort by key personnel could indicate potential change in scope)

  9. Institutional Base Salary (IBS) • The annual compensation that the applicant organization pays for an employee’s appointment whether that individual’s time is spent on research, teaching, patient care or other activities. • Excludes any income that an individual may be permitted to earn outside of duties to the applicant organization. • May NOT be increased as a result of replacing institutional salary funds with grant funds

  10. Revised NIH Grants Policy Statement

  11. NIH Grants Policy Statement – A Closer Look • Closely related work: • NIH eliminated the option for grantees to pursue prior approval to account for multiple projects under a single cost objective • NIH applies the relatedness provision of A-21 to all NIH recipients, which is consistent with the FDP Terms and Conditions

  12. NIH Grants Policy Statement – A Closer Look Key Personnel: • Expanded definition to: describe contribution of key personnel as “measurable” whether or not salaries are requested. Clinical Practice Plan (IBS): • Clinical practice plan appointments compensation may be considered in the base salary as long as criteria are met.

  13. Revised Grants Policy Statement Clinical Practice Compensation (IBS): Clinical Practice Compensation (CPC) appointments compensation may be considered in the IBS, provided: • CPC must be guaranteed by the university/Institution • Clinical practice effort must be shown on the appointment form and must be paid through the university/institution • Clinical practice effort must be included and accounted for on the university/institution effort report

  14. Total Professional Activities – Other Support • NIH requires complete and up-to-date other support information before an award can be made • Complete means all sources of research support (including outside the applicant organization – Total Professional Activities) • Grantees must report changes in other support as part of the annual progress report NIH Guide, February 13, 2003 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-03-029.html

  15. Total Professional Activities -Career Awards • Most Career Awards require a minimum commitment of total professional effort to research. • Previously defined total professional effort as all sources of research support (including appointments outside the applicant organization, exclusive of consulting activity within institution's limits.) • Effective for all applications submitted after 10/1/04 investigators will meet the required commitment of total professional effort as long as: 1) the individual has a full-time appointment with the applicant organization; and 2) the minimum percentage of the candidate’s commitment required for the proposed Career award experience is covered by that appointment. NIH Guide, August 3, 2004 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-04-056.html

  16. Support/Commitment Overlap • Overlap of support (scientific or budgetary) is unallowable • Over commitment of an individual’s effort is unallowable

  17. Salary Cap • Restricts the amount of direct salary under a grant or contract to Executive Level I of the Federal Executive Pay Scale • Executive Level I increase effective January 1, 2005 $180,100 $175,700 January 7, 2005 NIH Guide Notice http://grants.nih.gov/grants/guide/notice-files/NOT-OD-05-024.html

  18. Top 10 Issues on Salary Costs to NIH Grants? • Certifying official does not have first-hand knowledge of effort performed • Effort reports not certified and returned in a timely manner • Certifying the budgeted effort vs. actual effort • Salary cap not treated correctly with respect to effort and charging NIH grants/contracts • Corrections for significant changes in budgeted vs. actual effort are not made OR not made in a timely manner

  19. Top 10 Issues on Salary Costs to NIH Grants? • Transferring costs from one project to another to avoid a cost overrun • Failure to get prior approval for change in key personnel, i.e., withdraw from project completely, be absent for 3 months or more or reduces time by 25% or more • Overlap of support (scientific or budgetary) • Overlap of commitment • Use of incorrect IBS, especially when CPC is involved

  20. What’s at Risk? • Audit Findings/Cost Disallowances • Designation as High Risk Organization • Special Terms and Conditions on NGAs • Requirement for Corrective Action Plan • Special Monitoring by NIH • Temporary Withholding of Payments • Withholding of Future Awards

  21. Questions?Joe EllisActing Director, Office of Policy for Extramural Research Administration301-435-0938Ellisj1@mail.nih.gov