Effort Reporting atVanderbilt Presentation to Faculty Dennis Hall, Associate Provost, Research & Graduate Education Tim McNamara, Associate Provost, Faculty
Chronology: A Few Dates • Feb. 2003 Northwestern audit • $5.5M Dept. of Justice settlement (effort reporting) • Spring 2005 UAB settlement • $3.4M (effort reporting) • Jan. 13, 2006 Science article • “U.S. Rules on Accounting for Grants Amount to More than a Hill of Beans” • June 30, 2006 DGH Memo: NSF Labor Audit at VU
Chronology: A Few Dates • July 24, 2007 Provost’s memo to Deans • “Effort Declaration and Certification” • Oct. 19, 2007 Major Effort Meeting • Deans of A&S, Engineering, Peabody; Associate Provosts; representatives from GC, OCGA, Provost’s Office of F&A • Many issues surfaced • Nov. 19, 2007 Interim Chancellor’s memo to Deans • “Our Continuing Work on Accounting for Effort” • Dec. 6, 2007 Interim Chancellor & VC-Health Affairs memo to Deans • “Transinstitutional Effort of Faculty”
Effort: Basic Principles • Effort is more fundamental than compensation. • Declare and certify all institutional (!) effort, specify each element as a percentage of the total institutional effort (T.I.E.) • Elements must sum to 100%. Charge federal sources for the appropriate shares of the T.I.E. • Consulting, grant-review panels, etc. are not included in T.I.E.
Effort: Basic Principles • Corollary: When compensation for a particular period of time is charged to a federal source, the feds’ expectation is that the corresponding effort (i.e., via the base salary) has been expended entirely on the work funded by that source. • Incidental activities: 2.5% (1 hour per 40-hour week; 1.5 hours per 60-hour week) • Effort spent writing proposals cannot be charged to grants (rare exceptions) • Reasonableness standard (very important) • T.I.E = everything we do as part of our jobs as college professors, no matter when or where the activity is performed. • Effort certification cannot be based on the number of hours worked; percentages are required.
Limit Summer Grant Support Carnegie Mellon Cornell Dartmouth Duke Harvard Michigan State MIT Penn State U. Michigan U. Rochester Aware, and ~ Working on it Emory Northwestern Stanford Washington U. USC Resources Field Manual: “Policies and Practices: Compensation, EffortCommitments and Certification” (COGR, March 1, 2007) VU Websites: http://www.vanderbilt.edu/ocga/vupolicies/effortreporting/efforttableofcontent.htm http://www.vanderbilt.edu/ocga/vupolicies/vupolicies.htm Not Yet Aware • NYU • Rutgers • U. Kansas • U. Nebraska • U. Pittsburgh
Remaining Challenges,Works in Progress • Aligning the administrative and academic calendars • Personnel paid 100% from federal grants/contracts • The lack of an institutional policy on “vacations” for faculty • Others