Effort Reporting & Cost Sharing Systems

1. Effort Reporting & Cost Sharing Systems Campus Council For Information Technology November 8, 2004

2. Overview of Presentation • Supporting the Research Enterprise • Effort Reporting • What is Effort Reporting? • How is Effort Defined? • Who cares? • UC Effort Reporting Initiative • Cost Sharing • What is it? • Cost Shared Effort • UCD’s Cost Sharing Tracking System

3. Providing an Effective Environment for Research Administration • Enhance the infrastructure that supports the research enterprise • Training • Certificate Series in Grants Administration • Web based courses • Systems • Electronic Research Administration (InfoEd) • Effort Reporting • Cost Sharing Tracking

4. What is Effort Reporting? • Effort reporting is the Federally mandated process for certifying to granting agencies that the effort charged or committed to each award has actually been met • Required when an individual is compensated by or has agreed to contribute time to a federally sponsored project • OMB Circular A-21, section J.10 • Investigators on sponsored agreements are personally responsible for certifying their effort • Condition of acceptance http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

5. What is Effort Reporting? • Effort Reports are generated by UC Personnel Activity Reports (PAR) System • Effort Reports or PAR Forms are generated and distributed after each quarter (~ 4,000 per quarter) • After the fact activity reporting • Align salary with effort • Required to document effort commitments • Certified PAR forms support salary charges, EBs and F&A recovery charged to sponsored projects • Certified PAR forms are also required to document that specific voluntary commitments of time have been met

6. How is Effort Defined? • Institutional Base Salary (IBS) = 100% Effort • Regardless of % FTE appointment • Effort is defined as the amount of time spent on a particular activity • Expressed as a percentage of time spent on work related activities for which an individual is compensated by the University • Includes the time spent working on a sponsored project in which salary is directly charged or voluntarily contributed (cost shared) to a sponsored project • Instruction • Includes Departmental Research (per A-21) • Organized Research • Department Administration • Patient Care

7. Why Should PIs Care? • Federal auditors are focusing on Effort Reporting & Cost Sharing compliance • Northwestern audit disallowance of $5.5 mm • USF paid back $4.1 mm • UC paid back $2.1 mm to NIH • Failure to comply with Federal rules can result in: • Loss of funding and flexibility • Damage to UCD’s reputation • Fines and penalties

8. Effort Reporting – Current Status • Paper based system • Based on 1980’s technology • Not integrated with cost sharing data • No history • Gaps in PPS • Does not support our compliance requirements

9. Evaluating Options • UC RFP Issued in 2002 • Only one viable vendor • UC Effort Reporting Initiative • Collaborative project • UCB, UCD, UCLA, UCSD, UCSF, UCOP • Consulted with key stakeholders including: • Council of Vice Chancellors Administration, COVC, VC’s Research, Budget & Planning Officers, Controllers, IT Leadership Council • Project Team members from Campuses • Management, Functional, Technical • Project funding in place - $2.1 mm • Requirements definition completed January 2004

10. Effort Reporting – The Future • Web-based system • Fully distributed • Online edits • Retain history • Fit to Campus standards • Authentication, style & format • Integrate with cost sharing data • Available February 2006

11. What is Cost Sharing? • Cost sharing is defined in OMB Circular A-110 • “All contributions, including cash and in-kind, shall be accepted as part of the recipient's cost sharing or matching” that a recipient makes to an award • Cash contributions • In-kind contributions • That portion of a project or program cost that is not reimbursed by the sponsor http://www.whitehouse.gov/omb/circulars/a110/a110.html

12. Types of Cost Sharing • Mandatory: Required by the sponsor as a condition of the award. • Voluntary: Offered by the PI when no mandatory cost sharing requirements exist • Amounts in excess of mandatory cost sharing requirements Remember:Whether required by the sponsor or offered by the PI voluntarily in the proposal, once an award is made, all cost sharing proposed becomes a commitment under the terms of the award, and as such, represents a binding obligation of the University.

13. Cost Shared Effort • Committed Cost Sharing • Specifically identified or pledged in the proposal, proposal budget or award • Mandatory • Voluntary • Whether mandated by the sponsor or volunteered by the PI, commitments are a condition of the award and must be: • Properly documented • Captured in the accounting system • Project Overruns (intentional committed, unplanned not committed) • Captured in the payroll distribution and/or effort reporting system

14. Committed Effort • Committed effort is effort explicitly offered in the proposal narrative, budget or budget justification • Commitments made to the sponsor must be honored • Sponsor expects that effort commitments will be met • Even if PI or Key Personnel salaries are not charged, effort commitment is expected to be met • Must be documented and certified to on the effort report • Proposed effort commitments can exceed 100% • Must be reduced if more proposals awarded than expected

15. Cost Shared Effort • Uncommitted Cost Sharing • Faculty effort above and beyond that which is committed and budgeted for in the sponsored agreement • Voluntary (donated) • Neither committed in the proposal nor required in the award • Faculty do not have to document uncommitted voluntary effort • Not included in the organized research base for F&A purposes • Cannot be used to meet the University’s cost sharing commitments • Amounts in excess of NIH Salary Cap • Unallowable by Congress • UC Position: Not included in organized research base (OIA) http://www.whitehouse.gov/omb/memoranda/m01-06.html

16. UCD’s Cost Sharing Tracking System • A&FS has developed a web-based system to track cost sharing • Must be implemented in order to support committed cost sharing in time for the University’s next F&A rate submission • Base year 2005-06 • DaFIS transactions are identified by fund • Accounted for over the life of the award • Deployment begins December 2004

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