02/15/11
Heather Kraus
Associate Controller
[email protected]
1
ecrt is a web-based application that UA
will use to certify and report time and effort.
2
ecrt will provide UA with:
• Reasonable assurance that salaries charged
to a sponsored project are appropriate
• Reasonable estimation of the actual time
spent towards a project (relative to the
individual’s total time spent on activities on
behalf of UA)
3
What is effort?
Effort is the amount of time an individual spends
on a particular activity.
4
What is effort certification?
Effort Certification is UA’s means of providing
assurance to sponsors that:
• Salaries charged to sponsored projects are
reasonable in relation to the work performed.
• Faculty and staff have met their commitments
to sponsored projects.
5
Why certify effort?
• Effort certification is required by federal
regulation and University policy for all
individuals working on sponsored projects.
• Failure to certify effort correctly, and in a
timely manner, could jeopardize UA’s federal
research funding or result in large fines levied
against UA.
• Effort certification ensures proper use of
federal research funds.
6
Why certify effort? cont’d
• President Proenza has set the goal for The
University of Akron to move from $48 million
in research annually to $200 million.
• With more research dollars, there is more
scrutiny on how those dollars are managed.
• The University of Akron is devoting
considerable time and money to build a grant
management infrastructure which supports
this goal, including PeopleSoft Grants and
ecrt.
7
Risks of Non-Compliance
• Impact on UA
– Susceptible to False Claims Act allegations
– May owe direct cost refunds
– Sponsor may reduce future funding
– Adverse publicity
• Impact on Individual
– Susceptible to False Claims Act allegations
– Possible criminal charges
– May lose access to current funding
8
Risks of Non-Compliance
Multi-million dollar fines for erroneously
certifying effort have been levied
against many universities including
Johns Hopkins University, Northwestern
University and Harvard University.
9
Who needs to certify effort?
• An individual’s effort must be certified if his/her salary is
charged to a sponsored project, in whole or in part.
• An individual’s effort must be certified if there is mandatory
cost sharing of his/her time on a sponsored project, in whole
or in part.
• All faculty certify their own effort. Also, all Principal
Investigators (PIs), regardless of their classification, certify
their own effort.
• All graduate students, postdoctoral trainees and non-PI
classified staff have their sponsored effort certified by their
PI. Their non-sponsored effort is certified by their Department
Head.
10
Effort Terminology
11
Effort:
The amount of time spent on any activity,
expressed as a percentage of total
institutional activities for which an individual
is compensated by UA
12
Effort:
• Effort is NOT calculated on a standard 40
hour work week.
• Total effort (sponsored programs and nonsponsored activities) equals 100%,
regardless of part-time or full-time status.
• Effort is based on a reasonable estimate.
13
Total Institutional Activities:
• Those activities for which an individual is paid
by UA
• Effort expended on Total Institutional
Activities is grouped into one of the following:
– Sponsored Programs
– Non-Sponsored Activities
14
Sponsored Programs:
• Formal written agreement entered into by UA
and a sponsor
• Research, training or public service scope
• Funds are budgeted separately and
accounted for by UA
15
Non-Sponsored Activities - Faculty:
• FAC-Administration
Activities for university administrative functions such as serving as college
dean or department chair
• FAC-Instructional Support
Activities not covered under “Teaching,” including counseling and academic
advising of students and developing/preparing new academic programs
• FAC-Research-ABIA only (Austen Bioinnovation)
• FAC-Research/Creative Activity
Activities directed towards scientific inquiry or creative endeavors that are
not funded by an external sponsor
• FAC-Service
Activities directed towards service to university committees or professional
organizations
• FAC-Teaching
Activities that generate load credit, including classroom instruction,
independent or individual study, thesis or dissertation research/creative
activity, or reading courses
16
Non-Sponsored Activities–Graduate Assistants:
• GA-Discussion or Recitation
Activities include preparation of lessons and meeting students in the
classroom as assistance in a course taught by a regular faculty member
• GA-Direct Instructional Support
Activities include grading, test preparation, test monitoring and holding
office hours for students in a course taught by a regular faculty member
• GA-Other (Non-research/Non-instructional)
Activities include administrative support, advising, special projects
• GA-Research
Activities directed towards scientific inquiry or creative endeavors that
are not funded by an external sponsor
• GA-Teaching Lab
Activities include preparation of lessons, design of laboratory
assignments, grading and monitoring of laboratory activity.
• GA-Teaching
GA is instructor of record for class.
17
Institutional Base Salary (IBS):
The total guaranteed annual compensation
an individual receives from UA
18
Cost Transfer:
The reassignment of an expense to/from a
sponsored project after the expense initially was
charged to another sponsored project or nonsponsored project.
Cost transfers include reassignments of salary
and other direct costs.
19
Cost Sharing:
A portion of total sponsored project costs that
are not funded by the sponsor
20
Users of ecrt
21
Certifiers:
• All faculty members and any non-faculty
member who is a Principal Investigator,
Project Lead or Department Head.
• They will certify their own effort.
• They also will certify the effort of Support
Staff (supporting individuals).
22
Support Staff:
• These are individuals with effort on
sponsored and non-sponsored projects,
who are not faculty, and who are not
otherwise in a leadership role.
• The responsibility for certifying their effort
on sponsored projects rests with the
Principal Investigator of each project.
• The responsibility for certifying their effort
on non-sponsored activities rests with their
Department Head.
23
Effort Coordinators:
Each Department or College has one or more
individuals who work with departmental
faculty and staff and with central offices to
facilitate the effort certification process.
• To interface with payroll/financial systems
• Manage the certification process from the
department’s perspective
24
Central Administrators:
Individuals who oversee the effort certification
and reporting process, which includes
working with effort coordinators, those who
process payroll and those who set up new
grants
25
Effort Certification Process
26
UA Process Timeline
Certifier
Department
Administrator
Effort
Reporting
Period (Term)
Collect Payroll
Data and
Adjustments
30 Day
Certification
Period
Pre-Review
Period
Pre-Review
Period
Activity
Prepare and Agree
Certify
Personal
Effort
Post
Certification
Period
Process
Run
Postaudit
reports
Certification
Activity
Certify
Effort of
Supporting
Individuals
27
Red Flag Issues
• Late effort certification
• Effort certified by someone without
suitable means of verification
• A distribution of effort that leaves too little
non-sponsored time to credibly cover
teaching, administrative, or other
University duties
Red Flag Issues (continued)
• Post-certification revisions
• Significant data inconsistency between the
Effort Statement and other documentation
such as:
– Outside activity forms
– Other support forms
– Leave reports
Points to Remember
• Effort reporting is under scrutiny by the
Office of Inspector General from NSF, NIH,
and other Federal agencies.
• 100% effort is NOT Based on a 40-hour
work week. It is based on an individual’s
own average work week.
• Effort reporting tracks the reasonable
approximation of actual activity on
projects and should not simply mimic
budgeted amounts.
For Assistance with ecrt
• Contact your effort coordinator.
• e-mail [email protected] for questions about certifying
Graduate Assistant’s
non-sponsored efforts
• e-mail [email protected] for help with all other ecrt questions
• Visit the Controller’s Office ecrt page at
http://www.uakron.edu/busfin/controller/ecrt.php
• Review the online training tutorials and documentation at
https://editor2.uakron.edu/pages/its/learning/training/ecrt.php
31