Time and Effort Reporting Dr. Chellu S. Chetty Associate VP for Research and Sponsored Programs February 23, 2010
Accountability and Compliance Requirement Ga. Board of Regents to pay for false claims Associated Press – January 11, 2010 2:44 PM ET ATLANTA (AP) • Federal officials say the Board of Regents of the University System of Georgia will pay $500,000 to settle allegations that administrators at a historically black college lied to meet the terms of a grant. • The U.S. attorney for the Middle District of Georgia said Fort Valley State University administrators falsely certified compliance with requirements of the National Science Foundation's $2.5 million cooperative agreement from 2001 to 2007. • The grant was intended to help increase the number of minorities graduating with degrees in science, math, engineering and technology. • The U.S. attorney's office did not provide additional details. A call to the Board of Regents seeking comment was not immediately returned Monday.
What is “Time and Effort” Reporting? Federal regulation requires that any salaries and benefits charged to a federal award(s) must be based on documentation that meets the following criteria in order to be allowable charges to the awards(s): • The employee’s time must be documented in writing. • The documentation should reflect the actual time spent by the employee on activities of the federal program(s) being charged. • The documentation should account for all of the employee's time for the period covered (including state/local activities). • The documentation should be signed by the employee and the employee’s supervisor. This requirement applies to all federal awards and sub-awards, including those received directly from the federal government, unless specifically exempted by the Office of Management and Budget (OMB).
Effort always equals 100%(except during Summer) Effort always equals 100%
Certification of reports • The employee listed on the report who can confirm the time and effort of Forms must complete the time and effort form. • The reports must bear the ORIGINAL signature of the employee or a responsible official with first hand knowledge of the activity of the individuals on the report • These reports should be completed within 30 days of the end of the term (faculty and professional staff). • Return completed, signed and dated forms to the OSRA. • These will be kept on file for at least three years after the grant or contract officially ends • Effort reports are subject to an audit and frequently are specifically targeted. Therefore, it is imperative that all reports are accurate and on file in the Controller’s Office
Time and Effort Reporting Policy • POLICY: Savannah State University (SSU) requires that all salaries and wages charged to sponsored projects are certified consistent with federal requirements. As a requirement to receiving federal funding, it is required to maintain and certify the percentage of time that employees devote to externally (federal/state/private) funded sponsored programs. The time and effort certification process provides verification of salaries, wages, as well as the time and effort charged to these projects. This procedure is necessary to prevent cost disallowances and penalties by the federal government and other sponsoring agencies. • SCOPE: OMB Circular A-21, Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions outlines the regulations governing time and effort reporting and the verification of salary distributions. Specifically, OMB Circular A-21, Section (J)(10)(c)(2)(b) requires Time and Effort Reports to be completed to provide after the fact verification of the salary charged to sponsored projects: “[effort] report[s] will reflect after the fact reporting of the percentage distribution of activity of employees.” OMB Circular A-21 requires that this verification be completed for all faculty and professional staff following each semester (fall, spring and summer).
Time and Effort Reporting Policy (continued) Each Time and Effort report should: • indicate the distribution of the employee’s total period compensation across all SSU functions, including work on instruction, administration and sponsored projects. • account for 100% time and effort (except during summer) • be completed within 30 days of the end of each semester. • be certified by the supervisor Time and Effort Certification • Reflects the salary charged to a sponsored project must never exceed the amount of actual time and effort devoted to that project. • If a change in time and effort indicated on the Time and Effort Report requires approval by the sponsor based on the terms and conditions of the agreement, OSRA will contact the employee. If there are no changes or when any additional actions are complete, the Time and Effort Report is filed. • When a Time and Effort Report form has been signed and certified, no further changes will be allowed. • Employee should return Time and Effort Report forms to ORSP by the posted deadline. OSRA processes Time and Effort Report forms and follows up as necessary with the employee’s and department administrators to ensure 100% completion. • The signature on the Time and Effort Report is an endorsement by the employee that, to the best of their knowledge, the salary charges accurately reflect the effort distribution across all activities. If an individual is no longer employed at SSU, the employee’s supervisor will certify the employee’s Time and Effort Reports. At the end of each semester, if necessary, OSRA provides assistance in the preparation of Time and Effort. • SSU may impose corrective action such as suspension of sponsored project accounts in the event of consistent failure to complete Time and Effort Reports. • Deadlines for the submission of Completed Forms to OSRA • Fall Semester: January 15; Spring Semester: June 15; Summer: September 15
Time and Effort Policy (continued) • ROLES AND RESPONSIBILITIES • Office of Sponsored Research Administration (OSRA) • Grants Coordinator (Post-Awards): • Assists the faculty and professional staff in the preparation of Time and Effort Report forms. • Contacts faculty and professional staff to follow-up with Time and Effort Report forms that are not returned in a timely manner. • Reviews Time and Effort Report forms when they are returned to OSRA for signature and identifies any necessary follow-up. • Tracks the receipt of Time and Effort Report forms to ensure 100% completion. • Files the completed Time and Effort Report in the OSRA files. • Principal Investigator/Program Director- • Certifies that the time and effort is accurately documented on the Time and Effort Report. • Department Chair • Reviews and certifies Time and Effort Reports all the faculty (including for faculty who are on sabbatical, or who are otherwise unavailable for signature) and professional staff. RELATED DOCUMENTS • OMB Circular A-21, “Cost Principles for Educational Institutions” • OMB Circular A-110, “Uniform Administrative Requirements for Grants and Agreements with • Higher Education, Hospitals and Other Non-Profit Organizations” • OMB Circular A-133, “Audits of States, Local Governments, and Non-Profit Organizations”
Tips for the preparation of Time and Effort Form • Open a folder and store the hard copies of all the correspondence including Academic Year or annual contract and summer pay checks. • Obtain the Account # and the title of the project from the PI/PD. • Obtain an email authorization regarding the % effort (release time during fall and spring semesters) and $ amount towards compensation during the summer and forward the same to the OSRA with a copy to the Chair and the Dean.
Model Calculation • Faculty Effort during a calendar year is: 1.0 • Academic Year: 9 months (0.75) • Summer: 3 months (0.25) • Total 12 months (1.0) Please note that Academic Year is 9 not 10 months • 1 month during AY = 1/9 x 100 = 11.11% • Summer: 3 months • 1 month effort: 11.11%; 2 months effort: 22.22%; 3 months effort: 33.33% • If your Academic Year (AY) salary is: $63,000 • Monthly salary is: 63,000/9 months = $7,000/month • Summer: 3 months: $7,000 x 3 months: $21,000 (100% effort) • The summer compensation from teaching, administration and grants cannot exceed $21,000
Model Calculation (continued) Calculation of Percent (%) Effort 11.11% = 1 month • Teaching: $5,100 5,100 ------- x 100 = 8.1% 8.1/11.11 x 100 = 0.73 months 63,000 • Grant 1: $6,000 6,000 ------- x 100 = 9.52% 9.52/11.11 x 100 = 0.86 months 63,000 • Grant 2: $9,000 9,000 ------- x 100 =14.29% 14.29/11.11 x 100 = 1.29 months 63,000 Total =31.91% equivalent to 2.88 months • During AY your total effort for teaching, administration and grants should equal to 100%. • During summer your effort need not be equivalent to 33.33% (100%).