Effort Reporting Presented by Contract and Grant Administration Meghan Cartwright and Stacy Salisbury on your effort report
What COULD happen…. Columbia U. Agrees to $9.02 Million False Claims Settlement http://www.justice.gov/usao/nys/pressreleases/October14/ColumbiaICAPsettlementPR.php Columbia University…received millions of dollars in federal grants and…was required… to use a suitable means of verifying that the employees had actually performed the work charged to a particular grant. Instead of taking the appropriate steps to determine whether the reports were accurate, the principal investigators would certify large batches of the reports, without making any inquiry into whether the allocation of work among the grants was accurate. …charged federal grants for time spent on activities that are not chargeable to any federal grants, such as competitive grant proposal writing.
Who needs an Effort Report? • An effort report (ER) is a receipt auditors use to document the amount of effort performed on a restricted grant. • ERs are required for individuals with salary charged or committed cost share on Federal or State of MI accounts. • Students & On call/Temps do not require ERs. • If an agency requires salary/cost share documentation an effort report may be used.
Committed Effort vs. Committed Cost Share • Committed Effort: • Based off the budget or justification that was provided to the agency. Key Personnel only. • Can be salary on a federal account. • Agencies require prior approval for a reduction in effort of 25% or greater. • Committed Cost Share: • Portion of the project costs that are paid from sources other than the sponsor agreed upon in award. • Can be salary but not from federal funds. Anyone listed in the budget can be set up. • Do not need prior approval but there may be consequences if not met.
I just use my pay percent….right!?! The story behind the percent • Populated based off budget or justification • CGA Awards enters at beginning of award, PI and admin are notified in the award set-up email • Can also be viewed during the life of the project in Account Explorer under the effort tab. • Percent entered on ER • should be an accurate representation of the amount of time spent working on the project. Does not need to match pay. • Report must total 100% • If 100% on Sponsored – no writing proposals, committees, teaching, etc. for professors. • Activities covered under your MSU Institutional Base Salary (AY, AN, or Summer pay) are included.
And….. Why? Uniform Guidance 2 CFR Part 200 (applies to all federal grants and cooperative agreement) §200.308 Revision of budget and program plans (c)(1)…recipients must request prior approvals from Federal awarding agencies for …. (ii) Change in a key person specified in the application or the Federal award. (iii) The disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or PI.
Effort Reporting Keys • Effort %s are based on your total professional effort to MSU - NOT a standard 40 hr work week • The person certifying the ER MUST be comfortable that percentages listed in the “% Effort Worked” column are accurate for each 6-month reporting period • If a federal project is not listed on the ER – click on “add Effort on a Sponsored Project not listed above” button to add the Account number and % of effort worked. If the account number is not assigned yet, add a note at the bottom of the ER indicating the IP number and % effort worked. • ERs must be completed in a timely manner – maximum of 180 days • The % Effort Worked column should total 100% regardless of percent employment or percent of the period worked. If a person only worked two weeks of a semester, % effort worked should still total 100% (based on the distribution of those two weeks). Rounding is your friend here! • Because MSU doesn’t keep time records for faculty, only the employee, or PI, can defend or contradict the percentages reported in % Effort Worked column of the ER
Who can certify? • Principal Investigators (PI's): certify their own • Other Senior Personnel: certify their own • Graduate Students: Should be certified by the PI, Co-PI, or Faculty Advisor. • If a grad student is on multiple accounts the PI’s need to communicate regarding the effort met on their accounts and have one PI certify on behalf of the grad student. • In those rare circumstances when the above guidelines cannot be met, a dean or chair may certify the ER, if they have suitable means of verification that the work was performed as indicated by the percentages reported. • Assign a delegate instructions • Person to Person Delegates
I need to recertify my effort • Reports can be recertified within 14 calendar days • If the 14 day period has passed or the period has closed and you need to recertify follow these steps: • Email email@example.com to request to have the effort report opened for recertification. • In this email include: • A detailed description of the activities performed on the sponsored project & how they benefited the project. • How the error occurred • Confirmation that individual who certified effort has reviewed the Effort Report Instructions & FAQs • We will review and consider opening the effort report based on the information provided.
Other useful notes • Salary is, by far, the largest project expense and effort reports are the receipt • Bi-weekly pay can cross effort periods • Effort includes pay AND mandatory or voluntary uncommitted cost share • If AY Employee receives 3 months of summer pay on sponsored projects, no vacation may be taken during that time period. • Effort Reporting Overview & FAQ’s
Useful links • CGA’s Website: https://www.cga.msu.edu/Default.aspx • Effort Reporting FAQ’s: https://www.cga.msu.edu/PL/Portal/DocumentViewer.aspx?cga=aQBkAD0AMQA0ADcA • Effort Reporting Instructions for Admins: https://www.cga.msu.edu/PL/Portal/DocumentViewer.aspx?cga=aQBkAD0AMgAzADEA • Summer Pay link: https://www.hr.msu.edu/ua/hiring/faculty-academic-staff/ay-dates-factors.html