2/28/2017 J:/DACP/Research_Administration/Time & Effort 1.24.17 FUNDAMENTALS OF SPONSORED PROGRAMS Time & Effort 1 2/28/2017 Agenda What it is How it is determined How to manage Now you do it What is Time & Effort Time & Effort Certification is the documentation of the effort (not salary) that each employee expends on various activities during a specified time period regardless of sponsor and pay. Time & Effort certification is mandated by 2 CFR 200 Uniform Guidance Total amount of effort = 100% and is not based on a 40-hour work week. It’s not based on hours at all. All HPHCI employees must certify 2 2/28/2017 How is Time & Effort Determined? T&E is based on institutional commitments (research, clinical work, teaching and administrative responsibilities). Established in the hire letter which indicates the Institutional Base Salary (IBS). Labor Management Tips Know the active and pending projects Is there a budget manager? Establish process to keep each other informed Confirm percentages on projects Check labor every month Pay attention to deadlines Pay attention to the letters at the end of the project number 3 2/28/2017 END DATES are important! Labor schedules remain active until a change is requested The Oracle GMS LD module is designed to encumber/commit funds. PI must take into account the clinical, administrative, teaching and other research responsibilities when applying for grants. ALL effort must be accounted for. 4 2/28/2017 Pit Falls and things to look out for PI promises small amount of “in kind” effort to another investigator PI wants to be a consultant for another investigator PI wants to “bank” clinical $$ 5 2/28/2017 Case Study Mary Smith’s hire letter Annual salary will be $100,000. Expected to spend time 75% research (includes 5% administration) 20% clinical work 5% director of teaching program 6 2/28/2017 Mary’s Current LD Project # FTE Role Source Dates PF000001 5% PI DPM Administrative Account PF000002 5% Director HPHCI Teaching Program PF000003 20% Clinician Hospital PH000010 25% PI AHRQ Jan 1, 17 – July 31, 17 PH000011 15% PI NIDDK Sep 1, 16 – Aug 31, 17 PH000012 15% Co I Pfizer Oct 1, 16 – Sept 30, 17 PH000013 15% Co I PCORI June 1, 16 – May 31,17 Mary’s Pending Projects Project Name FTE Role Source Dates Testing Garden Soil 20% PI NCI 3/1/17-2/28/18 Growing Vegetables 15% Co I PCORI 7/1/17-2/28/18 Puttering in the Garden 25% PI NIMH 5/1/17-4/30/18 Planting Flowers Naturally 25% PI NCCM 6/1/17-5/31/18 7 2/28/2017 Take Home Mary’s salary is $250,000 Same projects and effort Formula for Determining Effort Charged to Grant when Salary is Over the Cap Cap on grant = $185,100 PI salary = $250,000 PI Effort on project =20% Conversion factor = $185,100/$250,000=0.74 LD% charged to project = (20%)*(0.74) = 15% LD% charged to cost share account = 20% - 15% = 5% Total effort on sponsored project should be a whole number Modify T&E report to show that T&E% listed on cost share account reflects effort on sponsored project 8 2/28/2017 Top Ten Points You and PI Need to Know Certification must reasonably reflect all the effort for all the activities (research, teaching, clinical and administrative) activities that are covered by institutional compensation. Effort is not based on a 40-hour work week. It’s not based on hours at all. Effort is the work on a project, whether a sponsor pays salary or not and that effort must be certified. Effort included on a grant application is committed effort. If effort is reduce, paid or unpaid, on a federal grant by 25%, must agency approval must be obtained. If paid effort is reduced, cost-sharing could be documented so that the total effort does not decrease. Certifying effort is not the same as certifying payroll. Effort must be certified by someone with suitable means of verifying that the work was performed. Many activities cannot be charged to a federally sponsored project. For example, the time you spend on these activities cannot be charged: Writing a proposal Serving on an IRB, IACUC or other research committee Serving on a departmental or university service committee In identifying audit findings, auditors look for indications that certification was based on factors other than actual, justifiable effort. 9 2/28/2017 Where Can I Find the policy https://www.harvardpilgrim.org/osp 10
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