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									                                 NEMOURS
                       POLICY AND PROCEDURE MANUAL
SUBJECT: Effort Reporting                                                      No. 5.9.5

EFFECTIVE DATE: December 1, 2008                  SUPERSEDES: 10148099.002, 11/01/06
SECTION: Corporate Ethics &
                                                  DEPARTMENT: Research Integrity
         Responsibility
NAME/TITLE: David J. Bailey, MD, MBA, President and Chief Executive Officer

SIGNATURE:                                        DATE APPROVED: December 1, 2008


1. PURPOSE
   To establish the policy and procedure for Associates to utilize when documenting their
   effort and actual hours worked on projects funded through state or federal grants
   (“sponsored projects”) to ensure compliance with applicable federal and/or state laws
   and regulations.

2. POLICY
   2.1 Nemours Associates involved in sponsored projects will accurately document their
       effort and actual hours worked in compliance with Federal Circulars OMB A -122
       (2CFR230), A – 133, and any other applicable regulations from a state or federal
       agency or other granting agency.
   2.2 All Nemours Associates are required to follow the procedures established by
       Nemours for accurately documenting their effort and actual hours worked in
       Nemours electronic effort reporting system, as set forth in Exhibit “A”.
   2.3 All Nemours Associates involved in sponsored projects must receive appropriate
       training on Nemours’ electronic effort reporting system prior to charging their time
       to a sponsored project.
   2.4 The Nemours Associates and the corresponding Principal Investigator or
       Administrator responsible for managing the sponsored project are both responsible
       for compliance with this and may be subject to discipline for violations.

3. DEFINITIONS
   3.1 Effort - the time spent on any sponsored project by an Associate, expressed as a
       percentage of the Associate’s total employment time for Nemours, includes the
       time spent working on a sponsored project in which salary is directly charged or
       contributed (cost-shared effort). Individual effort is expressed as a percentage of
       the total amount of time spent on work-related activities (instruction, research,
       administration, etc.) for which Nemours compensates an individual.
   3.2 Effort Reporting - the mandated method of certifying to the granting agencies that
       the effort charged or cost shared to each award has actually been completed.
   3.3 Principal Investigator (“PI”) - the individual named on the research application form
       and approved by the appropriate research oversight committee as the person
       responsible for the administrative, financial, procedural and scientific aspects of a
       research study or protocol. The PI is responsible and accountable for the proper
       conduct of the proposed protocol, including all related activities undertaken and


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POLICY AND PROCEDURE:            Effort Reporting                                No. 5.9.5

          performed by any member of the Research Team (“RT”); ensuring the RT has
          fulfilled all training requirements for the protocol; obtaining all required IRB, CRRC,
          IBC, or IACUC determinations and approvals; and complying with applicable
          Nemours policies. In addition, the PI is responsible for oversight of and
          compliance with all federal and state regulations that apply to the financial
          management of the protocol; budget management; personnel management; effort
          reporting and cost sharing.

4. PROCEDURES
   4.1 Principal Investigators or the Administrator responsible for managing a sponsored
       project must ensure that all Associates who will be charging time to the sponsored
       project receive appropriate training, including but not limited to training on
       Nemours’ electronic effort reporting processes set forth in Exhibit “A”, prior to
       charging any time to a sponsored project.
   4.2 All Nemours Associates are required to follow the procedures established by
       Nemours for accurately documenting their effort and actual hours worked in
       Nemours electronic effort reporting system, as set forth in Exhibit “A”.
   4.3 All Nemours Associates documenting time spent working on sponsored projects
       will be required to certify to Nemours and to the granting agency that the time they
       document for a specific sponsored project is true and accurate to the best of their
       knowledge.



Review/Revision Dates:
Policy 8785-03, 11/21/05
10148099.002, 11/01/06




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                                      EXHIBIT “A”


1. All non-exempt employees are required to use the electronic time clock system (Kronos)
   to accurately record hours worked. All exempt Research employees and those other
   Nemours employees and faculty who charge any portion of their time to federally-
   sponsored or state-sponsored projects are required to input their total actual hours
   worked into the Research Timekeeper System. Budgeted estimates do not meet the
   requirements. Timesheet reports must coincide with pay periods and be prepared at
   least monthly, depending on the payroll cycle to which an individual Associate is
   assigned. Each individual, exempt or non-exempt, submitting his/her timesheet via the
   Research Timekeeper System for supervisory approval is certifying that this is his/her
   true and actual time worked in accordance with pertinent regulations.

2. If a biweekly-paid Associate, exempt or non-exempt, becomes aware of any adjustments
   that are needed, he/she is responsible for notifying Research Administration as soon as
   possible to facilitate the input of corrections. All such Associates will be required to
   recertify their time.

3. All monthly-paid Associates involved in Research activities are required to input their
   research time allocations into the Research Timekeeper System by close of business on
   the designated day to coincide with the close of the current pay period. All monthly
   employees will receive an electronic reminder as to the close of the pay period. Due to
   the timing of the payroll close for monthly employees, all such Associates will be
   required to recertify their time at the end of the calendar month in the Research
   Timekeeper System, inputting a request for any adjustments or corrections as needed.

4. All Associates who utilize the Research Timekeeper System are required to complete
   the currently approved computer-based learning module on the topic of Effort Reporting,
   available through Learning Services.




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