University of Kentucky Review of Effort Reporting Processes and Systems Subset of Final Report edited by Jennifer Miles March 2015 Table of Contents • • • • Executive Summary Background and Scope Current Process Overview Observations and Recommendations – Distribution of Effort (DOE) – Effort Certification – Related Compliance Topics • Appendices © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. Executive Summary – UK Effort Reporting UK engaged Huron to assess its current effort reporting process, policy, systems and procedures and how they meet the requirements of OMB’s new Uniform Guidance Areas reviewed encompassed: • Distribution of Effort process and form (for faculty) • Staff payroll distribution process • Faculty and Staff Effort Certification forms In general, UK’s current process is consistent with federal requirements; however, the following recommendations will help UK enhance compliance and improve efficiencies: Distribution of Effort form/process 1. Separate the current DOE process into general effort planning and salary distribution. 2. Consider utilizing an electronic, web-based system and process for the effort planning and salary charging process(es). Effort Certification form/ process 1. Consider an electronic salary distribution confirmation system for faculty and staff with salary charged to sponsored programs. 2. Modify timing of staff certifications so that they are only performed annually. 3. Investigate possibility of certifying non-salaried individuals via the existing time-keeping process. © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 3 Background The University of Kentucky (UK) engaged Huron Consulting Group (Huron) to assess its current effort reporting process, policy, systems and procedures as it relates to UK’s ability to efficiently meet the requirements of the Office of Management and Budget’s new Uniform Guidance, CFR 200.430 – Compensation for Personal Services, which went into effect December 26, 2014 At UK, the following processes are used to meet these requirements: • Distribution of Effort (DOE) – at least annually, used to plan effort for full-time faculty, and identify accounts to which salary is distributed • Staff pay allocation – accomplished directly in UK’s SAP Payroll system; changed as necessary (a change in funding or an account closes) – Includes both salaried and hourly employees • Effort Certification – performed twice/year for staff and once/year for any faculty with charges or commitments to sponsored programs © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. Background Huron performed the following tasks in order to complete this assessment 1. Reviewed relevant existing policies, procedures, processes • See Appendix A for documents reviewed 2. Met with central and departmental administrators to review actual practices • See Appendix B for interview listing 3. Analyzed the supporting technology • The focus of the assessment was on compliance with OMB Uniform Guidance (see next slide for requirements), but also on enhancing efficiency and effectiveness in order to better utilize valuable UK resources © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. Faculty and Staff Salary Distribution and Effort Certification Processes at UK The process maps on the following two slides provide details on UK’s processes for faculty salary distribution (DOE), staff pay distribution, and effort certification for faculty and staff Descriptions of the processes, along with the benefits and potential issues, are outlined on subsequent slides In general, UK’s processes meet compliance requirements, but enhancements could be relatively easily incorporated in order to reduce current administrative burden associated with these processes © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 6 Faculty DOE and Effort Certification Process University of Kentucky Effort Certification Lifecycle Process Flow Distribution of Effort and Effort Certification Schools/Colleges receive notice of new fiscal year DOE for faculty members. Determination is made to either carry percentages forward or start from scratch DOE percentages are entered into FES and payroll distribution is created DOE is updated. Percentages are assigned to each ‘mission’ and account the faculty member expects to charge or will be charging for the upcoming fiscal year Y Carry Forward? N Faculty members are paid according to their DOE and this continues until the end of the fiscal year DOE is created with an original distribution. Percentages are assigned to each ‘mission’ and account the faculty member expects to charge or will be charging for the upcoming fiscal year Change in Plan? New grant? Cost Transfer? When the DOE is submitted and percentages are entered a labor debit/credit is submitted for every account listed on the DOE for the entire fiscal year FER contains percentage of effort charges to each account for the previous fiscal year A new DOE is created with the new account line items. Up to 12 DOE’s may be created each fiscal year DOE is signed by the faculty member, chair, dean, and department administrator Hard copy DOE is returned to sponsored program accounting Faculty Effort Report is produced by SPA Fiscal Year Ends When the DOE is submitted and percentages are entered a labor debit/credit is submitted for every account listed on the DOE for the entire fiscal year SPA distributes the faculty effort certifications to the departments with instructions on how to complete the certification Effort report is delivered to faculty by department representative Faculty reviews and signs effort report with percentage of effort worked for themselves and their staff (in most cases) Distribution of Effort (DOE) Effort Certification Changes to effort report? N Faculty Effort Report is complete Y Cost transfer is created – Effort Report is recertified © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 7 Staff Salary Distribution & Effort Certification Process University of Kentucky Effort Certification Workflow - Staff Phase Staff Salary Allocation and Effort Certification Process Salaried Payroll distribution for salaried staff employee is received by a department administrator Non-salaried Hourly staff clock in/out using Kronos or SAP Department administrator enters payroll distribution into SAP Payroll Distribution carries on into perpetuity Payroll distribution for hourly staff employee is received by a department administrator Department administrator enters payroll distribution into SAP Semi-Annually – an effort certification report is created containing all payroll charges on all accounts incurred up to that point Effort Certification is reviewed by the employee or an individual with suitable means of verification and signed Account reaches end date. New distribution is needed Changes to effort report? N Payroll distribution is updated Payroll Distribution carries on in perpetuity Staff Effort Certification is complete Y Cost transfer is created – Effort Report is recertified © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 8 Current Process: Distribution of Effort (DOE) (See Appendix C for sample DOE form) Since 1993, UK has used the DOE form, generated from the Faculty Effort System (FES), to record faculty*’s professional activities; the Effort Summary section of the form indicates planned effort in the following categories: • Instruction • Research • Service • Administration • Professional Development Accounts to which the faculty member’s salary is to be charged are identified in a the Payroll Distribution Block of the DOE; the form is used for data input to UK’s SAP Payroll system A DOE is generated for all faculty members at the beginning of the fiscal year, and only tracks academic appointment effort (not summer) DOE forms must be signed by the faculty member, the department chair and the dean each year * Only full-time faculty (>50% FTE) are included in the DOE process © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. Current Process: DOE (cont’d) The DOE results in two key subsets of data, used UK-wide: a) Planned workloads, by general category of effort • b) Reports to UK executives have been generated from this data Salary distribution between pay/funding sources (accounts) • Used as the official payroll record for faculty salary distribution Data from the DOE may be used by departments and schools to summarize faculty activity for various purposes: • Tenure/promotion review • Annual or bi-annual performance reviews • Bonuses/incentives DOE expectations are often set by the department or college • Faculty generally allocate effort on the DOE to Research, Instruction, or Service • As an example, some colleges recommend splitting the percentage 45 Research (funded and/or unfunded), 45 Instruction, 10 Service – Commonly this split is only adjusted after the 1 or 2 year performance review – May be adjusted sooner if there is a significant increase in funded research © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. DOE – Benefits • Enables UK to meet several OMB requirements associated with documenting personnel expenses • • • • Supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated Reflect the total activity for which the employee is compensated by the institution, not exceeding 100% of compensated activities Encompass both federally assisted and all other activities compensated by the institution on an integrated basis Support the distribution of the employee's salary or wages among specific activities if the employee works on multiple activities Requires at least an annual review and planning of individual faculty members’ activities Identifies all sponsored projects, including cost share, that an individual is committed to or has planned to expend effort on for the upcoming Provides key performance metrics to UK colleges, departments, and executives • However, if DOEs are only completed based on department expectations and not actual plan/activity, the metrics may be inaccurate © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. DOE – Potential Issues Administratively cumbersome – paper-based, requires multiple signatures • Initial form requires at least three signatures • Updates during the year typically require at least two signatures, and occur frequently for faculty with sponsored programs starting and ending – DOE updated when a grant account number changes (e.g., continuation) – Potential for 12 different DOEs over the course of a fiscal year No oversight or ownership of the form or the process • Sponsored Projects Accounting (SPA) is viewed by campus as having responsibility for administering the DOE process, although the data relevant for SPA is only that associated with sponsored program effort (pay distribution, accounts, timing). Forms are often returned late Initial DOE form due in September and is used for SACS reporting – late initial forms could result in inaccurate information reported to SACS Forms reflecting changes to effort distribution during the year are also often late, resulting in late charging and/or cost transfers to accounts © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. DOE – Potential Issues (cont’d) Percentages indicated on form for pay distribution can be confusing to faculty • Percentages are annualized for the UK fiscal year, which is often inconsistent with how grant effort is proposed • Ex.: if a sponsored project starts January 1st and the awarded effort is 10%, the percentage on the form is only 5% because the DOE covers July through June Metrics are not used consistently across the colleges and departments, and the data may not be accurate • Each “interested party” (Provost, Deans, Chairs) uses the data differently • If DOEs are only completed based on college/department expectations and not actual plan/activity, the metrics may be inaccurate Reporting is limited • Reports not readily available to the university community © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 13 Current Process: Staff Payroll Distribution Payroll distribution for salaried staff and non-salaried staff/students (“Cost Distribution” in the UK system) is entered into UK’s SAP Payroll system by department administrators Payroll distribution continues unless: • An account ends • A new account is added to the distribution • A change in distribution is initiated by the department • For non-salaried staff/students, hours worked per period interface from Kronos (hospitalbased employees) or are entered directly via Time Management in SAP Payroll Benefits Payroll distribution is entered on the front end, electronically, reducing the risk of lost paperwork of incorrect account codes being used There is no need to update/create a new distribution annually Department administrators indicated that this more streamlined process (compared to the faculty process) resulted in fewer retroactive cost transfers Distribution entered at the department level reduces additional administrative steps No significant issues were identified with staff payroll distribution © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. Current Process: Effort Certification Reports (See Appendix D for sample form) Generated for all individuals with pay charged or cost shared to a sponsored program; must be certified and returned to a departmental administrator. a) Faculty Base Salary Certification Report (IBS/academic year pay) – b) Faculty Non-Base Salary Certification Report (usually summer salary) – c) once/year for the July-June period, displays accounts funding salary with a percentage assigned to each account funding base salary, based on the pay distribution – – – once/year for the July-June period, displays only the pay associated with each sponsored account Staff Certification Report initial report for the July-December period displays accounts funding salary with a percentage assigned to each account funding base salary, based on the pay distribution second report is generated for the July-June period with the pay distribution for the entire fiscal year, including retroactive cost transfers not on initial report Requires one signature, however, many units require a second signature by the PI © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 15 Effort Certification Reports – Benefits Enables UK to meet several OMB requirements associated with documenting personnel expenses • • • • • • Supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated Reflect the total activity for which the employee is compensated by the institution, not exceeding 100% of compensated activities Encompass both federally assisted and all other activities compensated by the institution on an integrated basis Support the distribution of the employee's salary or wages among specific activities if the employee works on multiple activities Include salaries/wages for those employees used to meet cost sharing requirements on Federal awards All necessary adjustment made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated Training and detailed instructions are provided and the effort statements are generally understood by the individuals that are signing them Statements are generally certified in a timely manner • Few late or outstanding statements © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 16 Effort Certification Reports – Issues Administratively cumbersome • Electronic certifications are not allowed, reports must be printed and signed • For units requiring it, staff reports for those working on several PIs’ projects require signatures from each PI Differences between actual effort and payroll distribution may not be adequately reflected • Effort percentages are pre-printed – there is no field for actual effort to be indicated • Payroll cost transfers occurring after the certification has been printed and prior to certification will not automatically be reflected on the effort certification (although a new report can be requested and generated if the fiscal year has not yet closed) Changes as a result of effort certification will not be reflected at a detailed level in the Payroll system • Changes after the fiscal year end or the “Earliest Retro Date” require a journal entry in the General Ledger; there is no detail in the Payroll system Staff mid-point effort certification is effectively superseded by the end-of-year report © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 17 DOE - Recommendations 1. Separate the current DOE process into two separate, but coordinated processes Effort Planning • Change “ownership” of this process from SPA; consider assigning responsibility to an office with a more vested interest in the overall allocation of faculty effort • Establish a unified metrics procedure for effort allocation Salary Charging • Segregating this process from effort planning and the FES should enable a more intuitive approach to salary distribution data – Eliminating the current requirement to annualize the percentages (which is needed because of system limitations) should address many faculty concerns © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 18 DOE - Recommendations 2. Consider utilizing an electronic, web-based system and process for the DOE (effort planning and salary charging) process – Online approvals, workflow and electronic signatures; enhanced reporting capabilities would be available – Effort commitment information could also be more easily incorporated into the process o Commitments to research sponsors could be uploaded from a sponsored program proposal/award database – Data from the separated processes could be easily reconciled, especially if a common system is used for the two processes © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 19 DOE - Recommendations If the process remains paper-based, UK should consider: • Creating a worksheet or a form that can allow for simplistic data entry and upload into FES; would result in more timely and efficient faculty payroll distributions – College of Medicine and Behavior Sciences templates could serve as initial models • Exploring the option of developing edit checking functionality in the SAP payroll module, so that faculty and staff cost distribution adjustments can be processed efficiently and effectively utilizing one consistent method • Allowing specific dates to be associated with payroll distribution instead of an annualized average, or provide a view that shows a monthly delineation of effort © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 20 Effort Certification - Recommendations 1. Consider an electronic salary distribution confirmation system for faculty and staff with salary charged to sponsored programs. • • • • Would significantly expedite the process and ease administrative burden Ideally, the system would allow individuals to review salary distribution pro-actively in order to determine if the allocation of salary is consistent with effort (UK could still only require an annual certification, but could strongly encourage periodic reviews) Could enable better reporting of information such as salary cap cost sharing, sponsored and non-sponsored research effort, mandatory and voluntary cost sharing by department, and (assuming effort commitments are captured) comparisons of certified to committed effort Would enable automatic identification of salary journal entries (currently, the JV is noted on the paper form) Data from the distribution of effort, salary charging, and salary confirmation processes could be easily reconciled, especially if a common system is used for all processes UK could also consider certification by project in addition to or in place of current certification,, which is by individual Could further reduce administrative burden by coordinating certification with end-ofbudget period reviews currently performed by PIs © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 21 Effort Certification - Recommendations 2. Modify timing of staff certifications so that they are performed annually • Will reduce administrative burden and be aligned with faculty certification cycle • Consistent with federal regulations - new Uniform Guidance removes previous requirement on timing of certification • UK should ensure that individuals review their payroll distribution more often than once a year • UK should revisit the “Earliest Retro Date” for staff 3. Investigate whether certification of non-salaried staff can be done via the existing time-keeping mechanisms (Kronos and SAP) • Determine if the supervisor approves the hours worked • Determine if the labor distribution account(s) can be provided and confirmed with the same process as the supervisor’s approval of hours © 2015 Huron Consulting Group. All Rights Reserved. Proprietary & Confidential. 22 Contact Information Jim Carter Managing Director (312) 799-9171 [email protected] Jennifer Hubert Director (312) 731-5185 [email protected] Marty Bergerson Manager (312) 731-5714 [email protected]
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