New York University School of Medicine Time and Effort Certification Training 2007
Effort reporting…Why? • The Federal Government requires it! • Office of Management and Budget Circular A-21- “Cost Principles for Educational Institutions” • Specifics given in Section J.10 of A-21 • Effort reporting is NOT optional!
Key Requirements • Salary apportionment needs to produce equitable distribution of charges, and must reasonably reflect the activity for which the employee is being compensated. • The payroll distribution needs to be incorporated into official records.
Key Requirements (cont’d) • Effort reporting system must allow for confirmation of activity to each sponsored agreement. (How was my time spent) • Confirmation of the charge to the project • Confirmation of the effort to the project
How to certify T&E Reports Certification is accomplished by accessing the NYUSOM time and effort web based report http://tools.med.nyu.edu/Timeandeffort Consider: Effort reporting is not based upon a 40 hour week. It is based upon 100% of faculty activities for which compensation is received from NYUSOM. • Sponsored Projects • Non-sponsored Projects • Administration, Institutional, Clinical Activities(FGP) • Does not include activities for which you are compensated outside NYUSOM.
Institutional Base Salary (IBS) Defined • Annual compensation paid by New York University School of Medicine • For all activities; research, teaching, patient care, other • IBS is guaranteed and fixed in advance • Excludes compensation not guaranteed or not fixed in advance (i.e. Incentive compensation) • Compensation paid through non-New York University School of Medicine payroll system is excluded
Pay sources should reasonably reflect activity. Consider: OMB Circular A-21, J.10 “In the use of any methods for apportioning salaries, it is recognized that, in an academic setting, teaching, research, service and administration are often inextricably intermingled.” “A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate.”
Activities Included In Effort Sponsored Projects Activity • Effort on all grants and contracts, federal and non-federal (e.g. foundation or industry sponsored grants) • Even if the project work is not completely paid for by the sponsor (e.g. cost sharing) • Actual Effort should relate to what was committed in the grant proposal. • If material variance, >25%, agency needs to be advised. Non-Sponsored Activities • Attending general departmental faculty meetings. • Serving on the SOM committees. • Serving on an NIH Study Section or Peer Review Panel.
Activities NOT Included in Effort External Professional activities approved by the School of Medicine, and referenced in the faculty handbook, “Restrictions on Outside Employment”. • For example, consulting for pay through a Non-School of Medicine consulting agreement. • Compensation from an affiliate through their paymaster, such as the VA and Bellevue.
Red Flag Issues • Late filing of Efforts Reports – beyond 75 days of period close • Effort reports certified by someone without first-hand knowledge. • 100 % funding on grants. • Too many post certification payroll cost transfers. • Significant data inconsistency between effort report and other documentation such as: • Clinical time reports • Outside activity forms • Leave reports
Points to Remember • Effort reporting is under scrutiny by the Office of Investigator General, NIH, and other Federal Agencies. • PIs are responsible for certifying their own effort report. • PI must certify for non-professional staff on their grants. • May coordinate with administrator or knowledgeable designee • The % is NOT Based on a 40 hour work week. It is based on the individual’s own work week. • Effort reporting tracks the reasonable approximation of actual activity on projects and should not simply mimic budgeted amounts. • Certifying to non-professional reports is an attestation that you are cognizant of the day-to-day activities of that employee.
Certification Process • The following slide is of a sample report as it would be viewed by a faculty member to be certified. • If the salary is correct as displayed, and the corresponding “Payroll Allocation %” shown represents the actual effort applied to the grants, then the “Certify” box should be checked, and the form submitted. • If, however, the effort applied differs from what is presented, then “Actual Effort %” needs to be modified to your actual effort applied. This is illustrated in the second slide. • Comment fields are available on each line, and below, to allow for explanations as needed. • Always consider: The NIH salary cap, cost sharing, committed effort, pending adjustments, etc.