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PARs and Effort Reporting

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  • PARs and Effort Reporting

  • 2

    Workshop Objectives

    By the end of this workshop, you will be able to:

    • Understand UNL’s Personnel Activity Report

    (PAR) form

    • Identify all parts of the PAR

    • Name the reasons for completing the PAR

    consistently and accurately

  • 3

    Workshop Objectives

    • Accurately certify expended effort

    – on federally and some non-federally funded

    projects

    – under a cost share agreement

    • Develop a system for efficiently completing

    and certifying a PAR

    • Coach others (faculty, students and staff) about

    how to complete the PAR

  • 4

    Content • What is effort reporting?

    • Why and how often is a PAR generated?

    • Certification steps?

    • What does cost share mean?

    • Practical examples/odd scenarios: – Items to ignore

    – PAFs/retros

    – 9/12 Employees

    – More than one department involved

    • Questions

  • 5

    • What is effort reporting? – The mechanism used to confirm salaries charged

    to each sponsored agreement are reasonable in relation to the actual work performed.

    – UNL has chosen the “after-the-fact” activity records methodology.

    – At UNL, known as PARs (Personnel Activity Reports).

    What is Effort Reporting?

  • 6

    Why certify effort?

    Federal regulations (Uniform Guidance §200.430, formerly OMB Circular A-21) require institutions that receive federal funds to maintain systems and procedures documenting the distribution of activity and associated payroll charges to each individual sponsored agreement.

    Reporting is required for:

    – Professorial and professional staff

    • Each academic term, but no less frequently than every six

    months.

    – Other employees

    • Unless alternate arrangements are agreed to

    • No less frequently than monthly

  • 7

    When is a PAR created?

    When salary is from a federal or federal pass-through source (salary certification) – 24-XXXX-XXXX-XXX

    – 25-XXXX-XXXX-XXX

    – Some 26-XXXX-XXXX-XXX

    When cost share is required - quantifiable

    For IANR Hatch/Smith-Lever cost objects – 21-62DD-0762 federal funds

    – 21-62DD-0862 state match

    – 21-63DD-0763 federal funds

    – 21-63DD-0863 state match

  • 8

    How often are PARs generated?

    • Three times a year:

    – Spring: 01/01/20xx to 05/31/20xx

    – Summer: 06/01/20xx to 08/31/20xx

    – Fall: 09/01/20xx to 12/31/20xx

  • 9

    Who certifies the PAR?

    • A person with first-hand knowledge of the effort: – Employee

    – Supervisor

    – Principal Investigator

    • Employees should report their own effort, or…

    • A responsible person with/using suitable means of verification that the work was performed may report for the individual.

  • 10

    Why accurate and on-time PARs matter

    • UNL must comply with Uniform Guidance

    §200.430 to avoid:

    – Loss of federal funds

    – Debarment list

    – Inability to receive future federal funds

    – Disallowance of items of expense upon audit

  • 11

    Don’t let this happen to you!

    • Charging more salary to a federal award than

    a reasonable estimate of the effort spent on

    the award can be viewed as fraud!

    • Fraud violations may subject institutions and

    individuals to both civil actions and criminal

    prosecution.

    • For example . . .

  • 12

    Don’t let this happen to you!

    • Federal audits have resulted in significant findings, disallowances and fines in the last 10 years:

    – Columbia University - $9,020,073

    – Yale University - $7.6 million

    – University of California-Santa Barbara - $6.3 million

    – Northwestern University - $5.5 million

    – Johns Hopkins University – $2.6 million

    – University of Connecticut - $2.5 million

    – East Carolina University - $2.4 million

    – Harvard University/Beth Israel Deaconess Medical Center - $3.25 million

    Sources: National Conference on College Cost Accounting, www.costaccounting.org; Manhattan U.S. Attorney (http://www.justice.gov/usao/nys/pressreleases/October14/)

    http://www.costaccounting.org/http://www.justice.gov/usao/nys/pressreleases/October14/

  • 13

    Don’t let this happen to you!

    • Past audit findings related to effort

    certification affecting salary costs charged to

    NSF awards resulted in changes to effort

    reporting systems at: – University of California-San Diego

    – University of Utah

    – University of Illinois, Urbana-Champaign

    – Vanderbilt University

    – University of Wisconsin - Madison

  • 14

    Use the Basic PAR exercise

    handout to follow along

  • 15

    Jane Jones

  • 16

    Categories of effort

    1. Instruction

    – Teaching, training and direct administration

    activities, including departmental research.

    • All research and development activities that are NOT

    separately budgeted and accounted for as organized

    research.

    2. Research

    – Includes organized research, except Ag

    Experiment Station

    • All research and development activities that ARE

    separately budgeted and accounted for

  • 17

    3. Public Service:

    – Public Service related programs and projects

    – Financed by federal and non-federal agencies

    – Not instruction or organized research

    (excludes cooperative extension)

    4. Other Sponsored Activities:

    – Public Service activities, except cooperative

    extension

    – Funded by federal and non-federal agencies.

    Categories of effort

  • 18

    5. Agricultural Experiment Station:

    – All research activities separately budgeted and

    accounted for

    – Administered by the Agricultural Experiment

    Station

    – All Agricultural Experiment Station research

    activities included, whether funded from

    university, Hatch, or any other federal or non-

    federal funds.

    Categories of effort

  • 19

    6. Cooperative Extension Service:

    – All extension service activities administered by the

    Cooperative Extension Service Division of the Institute

    for Agriculture & Natural Resources (IANR).

    7. Patient Care Services

    – Excludes private practice

    – Effort expended in:

    • Treating patients as an attending physician

    • Providing personal identifiable medical services to patients, or

    • Teaching or supervising hospital staff where such duties are not reported as instruction.

    Categories of effort

  • 20

    Categories of effort

    8. Administration (all administrative effort)

    – Student administration • Advising and counseling; student affairs and service activities

    – Departmental administration • Administrative and supporting activities

    • Benefit an academic department’s common or joint departmental objectives

    – Sponsored project administration • Effort to develop and administer sponsored projects

    – College/School Administration • Supervisory, managerial, or administrative duties related to dean’s office

    – General Administration • University-wide general executive and administrative activities or

    committee efforts

  • 21

    Categories of effort

    9. Other Institutional Activities

    – Public/community service activities and

    extension services

    – Funded by institutional funds: e.g., State

    Museum, University Television, Conservation

    and Survey

    – Plus UNL’s auxiliary operations

    • Resident halls, unions, libraries, or athletics.

  • 22

    Print Your Name Sign Your Name Date

    Jane Jones

  • 23

    Steps for the certification

    1. Ignore cost objects and other items if no effort is associated with the payment (such as fellowships, professorships, workstudy, stipends, cell phone charges, federal retirement, WBS #s from other campuses, negative amounts).

    2. Identify cost objects under your department’s scope.

    3. Calculate the % for each cost object and handwrite it on the left hand side of the form under the correct category.

  • 24

    Steps for the certification

    4. Use “remarks” if needed: – Explain why some cost objects were ignored

    – Indicate that just a portion of the 100% was certified

    – Indicate that the cost share was modified

    – Indicate 9/12 appointment

    – Alert Sponsored Programs that other action is required.

    5. Print name and date. Sign the form.

    6. Return to Sponsored Programs before due date.

  • 25

    Try it!

    • Using the handout, work alone or in pairs to

    complete a basic PAR form.

  • 26

    Jane Jones

    2505060081001: $4,000/$20,000 = 20%

    2601160145001: $8,000/$20,000 = 40%

    2162220001: $6,000/$20,000 = 30%

    2161220001: $2,000/$20,000 = 10%

    10

    30 20 40

    Jane Jones Jane Jones 1/15/2014

  • 27

    Common odd scenarios

    Cost share

    Items to ignore: professorships, fellowships, workstudy, stipends, cell phone charges, federal retirement, WBS’s from other campuses

    PAFs / Retros: Affecting same period & previous periods

    9/12 employees

    More than one department involved

  • 28

    Cost Share

    Cost share is the portion of a project that is borne

    by the University

    If required as part of the project, UNL must document it was provided

    Items must be in conformance with same rules/ regulations as direct charges the award falls under

    Must support the work of the project

    Can include salary and non-salary items as well as third party

  • 29

    Cost share or matching funds must come from a valid

    source other than the sponsored project and are identified

    in the proposal/agreement/contract.

    Cost share funds cannot come from another grant or

    sponsored project.

    Cost share percentage cannot be greater than the portion

    of salary paid from non-grant funds.

    If cost share ends in the middle of a reporting period,

    leave the pre-printed percentage as it is. In the Remarks

    box, indicate the time period for which you are certifying

    the cost share and include the date the cost share ended.

    Some notes on cost share

  • 30

    Companions 10 digit cost center assigned via Accounting with OSP approval

    – Will be set up if costs other than effort will be used (i.e. equipment, travel, supplies)

    – Will be set up if a combination of salary and other costs will be used

    – If salary/benefits only, the information will be added to the OSP cost share table

    – When cost share obligations are met, the companion must not be used for any other purposes; will be locked

    – Workflow notice signals a department should remove salary from companion and/or project by project end date

    – Companions not being used correctly will be locked

  • 31

    Cheat sheet: Totals by cost object 2562220338001 - $4,000

    2563220333001 - $8,000

    2162220001 - $6,000

    2161220001 - $2,000

    Grand total: $20,000

    Cost share exercise

  • 32

    Cheat sheet: Totals by cost object 2562220338001 - $4,000

    2563220333001 - $8,000

    2162220001 - $6,000

    2161220001 - $2,000

    Grand total: $20,000

    10

    25 20 40

    Cost share exercise solution

    Jane Jones Jane Jones 1/15/2014

  • 33

    Fellowship

    Professorship

    Work study

    ACTIVITY % OF EFFORT WORK PERIOD ACCOUNT SALARY BENEFITS

    1. Instruction 1. 09/01/2007 to 09/30/2007 2405060018001 NIH Kaposis sarcoma Human Herpesvirus515210 61.50 0.00

    Larson Fellow Fund 515200 72.03 0.00

    10/01/2007 to 10/31/2007 2405060018001 NIH Kaposis sarcoma Human Herpesvirus515210 322.08 0.00

    Larson Fellow Fund 515200 72.03 0.00

    2. Research 2. 11/01/2007 to 11/30/2007 NIH Kaposis sarcoma Human Herpesvirus515210 322.08 0.00

    2405060018001 100.0 91.9 Larson Fellow Fund 515200 72.03 0.00

    12/01/2007 to 12/31/2007 NIH Kaposis sarcoma Human Herpesvirus515210 322.08 0.00

    Larson Fellow Fund 515200 72.03 0.00

    COST OBJECT DESCRIPTION

    2723088007001

    2723088007001

    2405060018001

    2723088007001

    2405060018001

    2723088007001

    GRANTS AND CONTRACTS OFFICE USE ONLY

    ACTIVITY % OF EFFORT WORK PERIOD ACCOUNT SALARY BENEFITS

    1. Instruction 1. 09/01/2007 to 09/30/2007 2111080001 Genetics 511100 370.22 251.42

    80 John Smith Professorship Distinguished Scholar511100 128.59 16.67

    10/01/2007 to 10/31/2007 2711080003002 John Smith Professorship Distinguished Scholar511100 128.59 16.67

    11/01/2007 to 11/30/2007 Genetics 511100 1,938.82 251.42

    2. Research 2. John Smith Professorship Distinguished Scholar511100 128.59 16.67

    2662350665009(2111080001) 20.0 * 12/01/2007 to 12/31/2007 Genetics 511100 1,938.82 251.42

    John Smith Professorship Distinguished Scholar511100 128.59 16.67

    COST OBJECT DESCRIPTION

    2711080003002

    2111080001

    2711080003002

    2111080001

    2711080003002

    2111080001

    GRANTS AND CONTRACTS OFFICE USE ONLY

  • 34

    PAFs / Retros: Same period

    $487 was incorrectly charged to the cost object 25-0506-0063-001

    313

    18

  • 35

    Retros: Different periods Summer 2012

    100

    Remarks: Retro made on Summer PAR:

    $1740.19 was incorrectly charged to

    25-0511-0044-001 during May 2012

    75

    25

    Revised

    Re: retros, it’s very important to go back and review all of the PARs that are affected. If a PAR was

    already certified and a retro is made after the certification, then the PAR needs to be REVISED.

    Spring 2012

    78.7

    21.3

  • 36

    UNL Retroactive Payroll Justification Form

    Use this form for all

    retro adjustments

    older than 60 days. – Go to the Sapphire

    website: http://sapphire.nebraska.edu

    – Follow this path: Business Forms > UNL Business Forms > Human Resources > Forms (blank) > Retro PAF Instructions and Forms

    http://sapphire.nebraska.edu/

  • 37

    9/12 summer period - monthly employees

    • The employee gives no effort during the

    summer; the PAR form was generated only

    because the salary is split over 12 months. – Mark all percentages as 0.

    – Remarks box: • Indicate that the employee is paid 9/12 and

    • That all effort was expended during the academic year (September-May).

  • 38

    9/12 summer period - monthly employees

    • The employee gives effort during the summer by

    teaching a class and working on a sponsored

    project. – Indicate effort percentages accordingly.

    • The employee gives effort during summer only to a

    sponsored project. – Indicate all effort toward the project even though

    payment is most likely coming from sources other than the sponsored project.

    – Remarks box: • Indicate that the employee is paid 9/12 and

    • All effort for the summer months was expended on the sponsored project(s).

  • 39

    Example, no instruction

    74

    0.0 2105220001

    2605220001001 26 REMARKS:

    9/12 employee, no instruction given during

    summer

  • 40

    2550.10 145.00

    2156.30 54.40

    More than one department involved Department 1 Department 2

    Dr. Espy

    Department 2

    Department 1

    Department 1 notes: “Just

    Athletics effort”

    2377011411 4.1

    Department 2 Department 1 Department 2 Department 1

    Dr. Jones

    JULIE JONES

  • 41

    PARs Guidebook

    • Please access our Guidebook for Completing the Personnel Activity Reports. It can be found at: – http://research.unl.edu/sp1/docs/PARguidelines.pdf

    http://research.unl.edu/sp1/docs/PARguidelines.pdf

  • 42

    Questions

    Contact the Office of Sponsored Programs

    Samantha Swanson 402-472-3608

    [email protected]

  • 43