Effort Commitments on Sponsored Projects by mikesanye

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									Effort Commitments on
 Sponsored Projects
 Office of Sponsored Programs
       Why are we talking about
                this?
•   The federal government has made effort reporting a top
    target for audits.

•   NSF’s Office of the Inspector General (OIG) is making the
    rounds of research universities.

•   The Department of Justice is involved, filing charges under
    the False Claims Act.

•   Many universities have had to pay millions of dollars in
    fines.
What should I know?
Effort is your work or your time on an
activity, sponsored or non-sponsored.
Your total effort is capped at 100%.
      (Sorry, over-achievers.)
A commitment of effort on a sponsored
project must be based on a good faith
estimate of the amount of time planned to
carry out the project.
 Effort on a sponsored project
      can take two forms:

      Committed Effort =
      Paid (Direct) Effort +
Contributed (Cost-Shared) Effort
Proposed effort becomes an obligation of
effort if/when the project is awarded that
              must be met.*
If you’re working on your bee grant,
     don’t charge your ant grant.
If you say that you’re working 100% on a
sponsored project, you better be working
          100% on that project.
Effort should be charged when it is
expended, and reasonably align with salary.*
Effort must be certified by someone with
the best firsthand knowledge and suitable
means of verifying that the work was
performed.
Effort reporting and certification is not an
   exact science. Reliance is placed on
           justifiable estimates.
Tracking Effort
                                                                 Systems and Framework
                  Policies & Procedures
TRACKING EFFORT

                                          Proposing Effort

                                          Acknowledging Effort

                                          Expending/Charging
                                          Effort

                                          Certifying Effort
                   Proposing a Commitment of Effort
                   Effort is proposed and budget is prepared
                   (based on IBS, % Time, Duration)




IBS, time, etc.       Principal Investigators    Good faith estimate


                                                 Help PIs put together
IBS, time, etc.       DRAs/Dept. Support Staff
                                                 proposals/budgets

                                                 Plan workloads/release times,
IBS, time/buyout      Academic Administration
                                                 approvals


Policies/Procedures   OSP/VPR                    Provide assistance, oversight
                Acknowledging Effort
                Commitment
               Commitment is reported and published in INOA.




INOA                 Principal Investigators    Acknowledge award, conditions


INOA, Comm. Report                              Assist PIs with adjustments if
                     DRAs/Dept. Support Staff
                                                necessart

INOA,
Comm. Report         Academic Administration    Track PI time

INOA, Comm. Report
                     OSP/VPR                    Record and disseminate info
                 Expending and Charging Effort
                Appointments are made commensurate with work.




Time, Appt, $       Principal Investigators    Comm w/staff


Appt/Position       DRAs/Dept. Support Staff   Make appointments


Appt/Position       Academic Administration    Approve appointments


                                               Assist with adjustments, provide
                    OSP/VPR
                                               oversight
               Certifying Effort

               Effort is attested to after the fact.




ECRT                Principal Investigators    Certify effort (self and support staff)



ECRT/Comm Report.   DRAs/Dept. Support Staff   Assist PIs with certification



Comm Report         Academic Administration    Track certifications


                                               process certifications, assist PIs
ECRT                OSP/VPR
                                               with ECRT
SO, Why are we talking about
           this?

Assessment of risk at the institutional and
system level led to this revamping of how
      we talk about effort at UTSA.
    SO, Why are we talking about
               this?

•   It’s federal policy.

•   It’s not new; it may just sound unfamiliar
    because of the recent changes.
“The most important obstacles in
effort reporting compliance are
misunderstanding and denial, and
sometimes one obstacle feeds on the
other.”
                                                    Robert J. Kenney, Jr.
                                 Director, Grants and Contracts Practice
                                Hogan and Hartson LLP, Washington, DC
             “Time and Effort Reporting: Overview and Risk Assessment”
                          Report on Research Compliance, January 2006
SO, Why are we talking about
           this?

Auditors look for indication that certification
  was based on factors other than actual,
              justifiable effort.
    Audits &
 Investigations:
Who Does What?
  Office of Sponsored Programs
           Who Audits?
•   Sponsored research projects are subject to audit
    by a variety of offices and agencies:

• Internal Audit (UTSA Auditing and Consulting
    Services)
•   State of Texas
•   UT System
•   Department of Health and Human Services
•   Individual Sponsors
     Federal OIG
       Purpose of Audits
• Verification of Good Fiscal Stewardship

• Recommendations for Areas of Improvement

• Due Diligence Regarding Whistleblower Allegations

• Investigation and Establishment of Consequences if
   Findings Uncover Wrongdoing
        Role of the Auditor
•   Auditors are not “The Bad Guys.”
•   Auditors provide the important function of keeping the
    system in balance and protecting the public.
•   Especially when referring to federally sponsored projects,
    auditors and their work provide assurances that we are
    good fiscal stewards of the people’s money.
•   Occasionally, the auditor provides valuable feedback and
    advice to management for making improvements to the
    process.
         Role of Central Research
              Administration
•   Central research administrators from OSP play the role of
    host.
•   OSP is the main point of contact between the auditors and
    institutional staff, coordinating interviews, monitoring the
    flow of information, and ensuring that the auditors have
    appropriate space and equipment.
•   OSP monitors the audit to ensure that the audit is
    conducted within the rules of accepted audit practice and
    to ensure that the audit is conducted within the originally-
    defined scope.
•   The Vice President for Research has the final say in
    responding to the audit on behalf of the University.
            Role of the PIs
      and Support Staff (yes, you)


•   Provide information/documentation as necessary
•   Agree to answer questions/meet with auditors within
    established parameters
•   Assist OSP with any and all information requests
The Audit Process
       The Audit Letter

•   Serves as initial notification to the University
•   Should clearly define scope of the audit and dates.
•   Should provide sufficient time to pull appropriate
    documents and schedule office space for auditors.
Entrance Conference

•   Also called entrance interview, the auditor will
    conduct an initial meeting with the principal
    investigator, business managers, compliance
    officials and representatives from OSP.
•   The purpose of the Entrance Conference is to define
    the scope of the audit and lay the ground rules for
    the audit.
       Audit Fieldwork
•   Assess the competence and attitude of the
    University central administrators as well as the
    principal investigator and departmental business
    personnel.
•   Looks at our internal control system, i.e., policies
    and procedures, and monitoring mechanisms.
•   If the University makes a good impression, the
    auditor will develop an audit plan, selecting
    transactions on a sample basis to verify that the
    system is working.
•   If the University makes a bad impression, the auditor
    will have no choice but to “look at everything.”
      Exit Conference

•   At the end, auditors will discuss their “findings” with
    central administrators during an “Exit
    Conference/Interview.”
•   It is the job of central administration to know the
    regulations and defend the University if we are
    operating within the rules (and to concede if we are
    not).
Findings and Impacts
•   Following the visit, and depending on the type of
    audit, the University will receive a written report with
    audit findings
•   The University may or may not have the opportunity
    to respond to the findings
•   In certain cases, audit findings prompt changes to
    university processes and procedures
•   In particular cases, audit findings may require
    involvement of other agencies of the Federal
    Government (e.g. DOJ)
               Audit Tips
•   Do not make the auditors do your work; pull the
    records for the auditors.
•   Do tell the truth and answer questions honestly and
    directly.
•   Do not do the auditors’ work for them; limit your
    response to the question being asked.
•   Call a central administrator if you ever feel
    uncomfortable about the way an audit is being
    conducted.
              Audit Tips

•   Do not tamper with or manufacture records. If you
    have no records, say so. This is not the time to
    make records!
•   Be alert. Auditors may not know the regulations
    applicable to your project as well as you do.
•   Auditors are people too. Kindness and respect go a
    long way.
          Remember...
•   All audits of sponsored grants and contracts must be
    coordinated through OSP. If an auditor contacts you
    directly, please refer them to OSP.
•   Do not allow an external auditor or investigator to
    look at documents or interview personnel without the
    involvement of these central offices.
•   Do not allow the FBI, attorneys, or any other
    investigators of law enforcement officials to proceed
    with an investigation without involving OSP.

								
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