Effort Certification Cynthia Moore SPA Compliance Analyst 503

Effort Certification Cynthia Moore SPA Compliance Analyst (503) 494 -1885 Mail code: AD 220 moorecyn@ohsu. edu Sponsored Projects Administration

Why are we Here ? l Compliance is a challenge l “Always do right. This will gratify some people and astonish the rest. ” -Mark Twain Sponsored Projects Administration

Lifting the Burden… Raising the Standard • Semi-annual reporting for all employees paid on sponsored accounts. • Responsibility to adhere to the 90 -day fund change standard. • Our opportunity to prove that EC can be captured through other systems. Sponsored Projects Administration

Effort Certification - PURPOSE OMB Circular A-21 Section J 8 a, Compensation for Personal Services Requires It! Sponsoring agencies require accurate and reasonable documentation to support that labor charged to sponsored accounts is consistent with effort expended. Sponsored Projects Administration

OMB Circular A-21 Section J 8 a Compensation for Personal Services • Charges are supported and documented • Conformity to the policies of OHSU. • Consistently applied Sponsored Projects Administration

Risk of Non-compliance Severe penalties and funding disallowances could result from inaccurate (False Claims), incomplete, or untimely effort reporting. · University of Minnesota · Canadian Food Grains Bank/PHP Sponsored Projects Administration

Risk of Non-Compliance We become a target! Danger of losing our Expanded Authority! Sponsored Projects Administration

Who is Subject to EC? If Employee Activity is: And Pay is: • Partially or totally devoted to a sponsored agreement, i. e. grants & contracts between the institution and the federal Government or a Pass-Through entity. • Partially or totally paid from a sponsored project account, excluding clinical trials. • Partially or totally committed to Mandatory or Voluntary Committed cost-sharing for sponsored agreements. • From a departmental fund account or other non-federally funded account. Sponsored Projects Administration

Who is Subject to EC? – Continued • Providing direct patient care for which a professional fee is billed. • Selecting, supervising and training of house staff (interns, residents, and fellows). Includes recruitment, teaching and teaching preparation time, and post session activities. See “Education Time” under Part III Definitions. • From any OHSU Fund. Sponsored Projects Administration

Who is Subject to EC? – Continued • Providing Medical Director and administrative services for OHSU Hospitals & Clinics, (e. g. , medical directions, serving on a hospital committee, supervising hospital employees, or participating in quality control and utilization review. ) • From any OHSU Fund. Sponsored Projects Administration

Who is Subject to EC? – Continued • Supervising and training of students in allied health programs (such as nursing, dietetics, pharmacy, radiation oncology, or medical technology) concurrently with providing patient care related activities in OHSU Hospitals & Clinics. • From any OHSU Fund. Sponsored Projects Administration

Who is Subject to EC? – Continued • Other activities such as teaching university medical students, conducting research, or providing direct patient care without the involvement of an intern, resident, or fellow. • From any OHSU Fund. Sponsored Projects Administration

Effort Certification - DEFINITION Effort is the work or proportion of time spent on a particular activity and is expressed as a percentage of total time spent conducting University business. For unclassified employees, 100% effort is defined as the total time spent on University/Hospital business, which includes work performed outside of the normal work schedule, work performed on vacation, and work performed off-campus. Furthermore, an individual’s appointment serves as the basis for that individual’s total effort. Thus, if an employee has a 50% appointment, 100% effort consists of the entire 50% appointment. Sponsored Projects Administration

Effort Certification - DEFINITION For classified employees, 100% effort consists of the total hours worked, including overtime. Thus, if a classified employee works 10 hours of overtime on top of a 40 -hour week, 20 hours devoted to an individual project represents 40% effort, not 50%. Sponsored Projects Administration

What is Payroll? Net Effort Payroll consists of: ü Salary & Wages ü Other payroll expenses such as Medical Insurance, all payroll related taxes Non-effort Payroll consists of: ü Bonuses, health plan rebates, and other one-time payments not directly associated with labor. Sponsored Projects Administration

Certify Definition: Assert in writing the correctness of something. This is a legal and binding document! Sponsored Projects Administration

Who Can Certify? Confirmed by responsible persons with suitable means of verification that the work was performed: + Who has DIRECT knowledge of the individual’s effort + Quarterly, for HEC employees, and semi-annually, for employees paid on grant funds, a statement will be signed by the employee, PI or responsible official(s) that the work was performed, stating that salaries and wages charged to sponsored agreements as direct charges are reasonable in relation to work performed. Sponsored Projects Administration

Signature Authority Whenever possible, the Effort Certification Statement should be signed directly by the employee. In lieu of the employee’s certification, the Effort Certification Statement may be signed by a person with suitable means of verification that the labor distribution is representative of the total work performed. This implies that the certifier must have direct and complete knowledge of all of the employee’s time spent on University activities. This person is usually a Principal investigator or direct supervisor of the employee. Sponsored Projects Administration

IMPORTANT IT IS NEVER PROPER FOR A DEPARTMENTAL EFFORT COORDINATOR OR DEPARTMENT HEAD TO SIGN ALL OF THE EFFORT CERTIFICATION STATEMENTS IN HIS OR HER UNIT/DEPARTMENT! Sponsored Projects Administration

A Closer Look • Effort Certification Packet: Ø Memorandum ØControl log (For DEC use) Ø Effort Certification Statements Sponsored Projects Administration

ECS Control Log HEC Sponsored Projects Administration

Effort Certification Statement Control Log • Gross Payroll – Gross payroll is the total amount paid to the employee over a fixed period of time. • Non-Effort Payroll – Non-effort payroll is money paid to the employee that does not relate to services or work performed. This includes bonuses, health plan rebates, and other one-time payments not directly associated with labor, and which are therefore excluded from the effort base. • Net Effort Payroll – Net effort payroll is the difference between gross payroll and non-effort payroll. It represents the total amount paid to the employee for actual services or work performed. Net effort payroll represents total (100%) effort over a fixed period of time. Sponsored Projects Administration

ECS Control Log - continued • % Payroll - % payroll is computed by dividing the Net Effort payroll by fund, by the Total Net Effort Payroll. • % Cost Sharing – Costs that are incurred for the sponsored projects that are not funded by the project. Mandatory cost sharing refers to the cost sharing that is required by a federally funded grant or contract in writing. Voluntary cost sharing is not explicitly required by the awarding agency, but once included in the budget narrative or award agreement is committed and therefore binding. • Total Effort % = % Payroll + % Cost Sharing Sponsored Projects Administration

Effort Certification Statement

Keeping Things in Order Sponsored Projects Administration

Effort Certification Statement with Cost Sharing

Cost Sharing • Cost sharing represents that portion of the total project costs of a sponsored agreement borne by the University, rather than by the sponsor. Cost sharing of direct expenditures represents a redirection of departmental or school resources from teaching or other departmental and school activities to support sponsored agreements. • Considered effort and must be accounted for. Sponsored Projects Administration

Cost Sharing • Can be expressed as a whole percentage, however, must be identified and accounted for on the effort certification statements. Sponsored Projects Administration

Mandatory Cost Sharing • Required by the agency for award • Must be accounted for on the Effort Certification Statement as committed. Sponsored Projects Administration

Voluntary Cost Sharing • Committed: Ø Where the University has determined that such a contribution is necessary to ensure the success of a competitive award or proposal. Ø Becomes binding, once included in the award. Ø Must be accounted for in the Effort Certification Process as Committed. Sponsored Projects Administration

Voluntary Cost Sharing • Uncommitted: ØNot part of the award document. ØInternal agreement with the PI and the University. ØMust be captured in the Effort Certification Process as Uncommittted. Sponsored Projects Administration

Cost Sharing • Institutions must capture this cost + NYU Medical settlement of $15 million • NIH $161, 200 Salary Cap Sponsored Projects Administration

Effort Certification Statement With Negative Effort

OHSU HOSPITALS & CLINICS Francine Harman Hospital Fiscal Services Phone: (503) 494 -6099 Sponsored Projects Administration

Filling the “Buckets” • How am I designated as an HEC employee? • What do I do if I am? • What if I am not designated but should be? • What if I am designated and shouldn’t be? Sponsored Projects Administration

PA Form Sponsored Projects Administration

General-Changes COA Form Sponsored Projects Administration

Hospital Effort Certification Statement (HEC)

Hospital Effort Certification CODES • A: Providing direct patient care for which OHSU Hospitals & Clinics bills the professional fees. • B: Supervising and training of house staff (interns, residents, and fellows) while performing patient care related activities where a bill for professional fees is NOT rendered. • C: Providing management and administrative services for OHSU Hospitals & Clinics (i. e. , serving on a hospital committee, supervising hospital employees, or participating in quality control and utilization review). Sponsored Projects Administration

Hospital Effort Certification continued • • D: Supervising and training of students in allied health programs (such as nursing, dietetics, pharmacy, radiation oncology, medical technology) concurrently with providing patient care related activities where a bill for professional fees is NOT rendered. E: Providing service not related to OHSU Hospitals & Clinics. (Such activities include teaching medical students, conducting research, or providing direct patient care which is not billed by OHSU Hospitals & Clinics. Sponsored Projects Administration

Challenges with Federal Regulations • Reporting Based on 100% Effort + Workload not based on number of hours + Full workload can vary from week to week + Instructional effort is constant, predictable + Research effort varies Sponsored Projects Administration

Issues & Considerations • PIs Effort • Compliance, Oversight, and Stewardship • Timely submission Sponsored Projects Administration

Compliance, Oversight and Stewardship • Written policies and procedures Define roles & responsibilities + Provide clarity regarding who can certify + • • Compliant with federal and institutional policies Programs that measure compliance Sponsored Projects Administration

Where the Rubber Meets the Road… • Does effort report agree with proposal budget/narrative, progress reports, current and pending support, etc. ? Sponsored Projects Administration

Truth in Advertising “A little inaccuracy sometimes saves tons of explanation. ” Saki (1870 - 1916) Sponsored Projects Administration

Effort Worksheet Sponsored Projects Administration

Policies, Procedures, Timeline • Policy: In EC Info Packet • Procedure: In EC Info Packet • EC timeline Sponsored Projects Administration

YOUR ATTENTION PLEASE: • Timely submission - Cited by A-133 Auditors • Consequences Sponsored Projects Administration

Effort Certification Process

Effort Certification Timeline Sponsored Projects Administration

What’s my line? § Verify system/process for compliance Ø Independent internal evaluation to ensure the system’s integrity and compliance Ø Establish programs to monitor compliance üAudit effort statements to ensure labor depicts effort üInterview employees, Department Effort Coordinators. Sponsored Projects Administration

Thank you for coming and participating in this Workshop The success of this program lies, in a big part with the Department Effort Coordinator and Department Chair. Without you, it would be impossible for us to reach all of the individuals who must certify their effort and complete the process in a timely manner. Sponsored Projects Administration

ANY OTHER QUESTIONS? ? ? Sponsored Projects Administration