Personnel Effort Reporting Personnel Effort Reporting System (PERS) &System (PERS) &

Electronic Effort Reporting Electronic Effort Reporting (ERS)(ERS)

Amy R. LederbergAmy R. Lederberg

Assoc VP for ResearchAssoc VP for Research

PERS for Sponsored ProjectsPERS for Sponsored Projects

Effort reports are Effort reports are the the documentation that documentation that salaries charged to a project are for work salaries charged to a project are for work performedperformed

Like a “receipt” for personnel costsLike a “receipt” for personnel costs Proof we are not defrauding sponsorProof we are not defrauding sponsor OMB Circular A-21 provides guidance on OMB Circular A-21 provides guidance on

what is acceptable documentationwhat is acceptable documentation

PERS: Board of RegentsPERS: Board of Regents

Wants to know how much of our state Wants to know how much of our state funds (instructional $$) is expended on funds (instructional $$) is expended on research activitiesresearch activities

We use the effort reporting system to We use the effort reporting system to generate this figure generate this figure

Why are we changing?Why are we changing?

Personnel Effort Reporting source of major Personnel Effort Reporting source of major finds by Universities:finds by Universities: Florida International paid $11.5 million in finesFlorida International paid $11.5 million in fines UAB paid $3.39 millionUAB paid $3.39 million Northwestern $5.5 millionNorthwestern $5.5 million

Our old system did not comply with federal Our old system did not comply with federal guidelinesguidelines

Recent audits pointed out inadequacies of Recent audits pointed out inadequacies of GSU systemGSU system

What is different?What is different?

Implementing a new web-based Effort Implementing a new web-based Effort Reporting System designed by Maximus Reporting System designed by Maximus (ERS) developed to comply with federal (ERS) developed to comply with federal guidelinesguidelines

Adopted new policies and proceduresAdopted new policies and procedures Who certifies effort reportsWho certifies effort reports Timeliness of effort reportingTimeliness of effort reporting Clarified what is effortClarified what is effort http://www.gsu.edu/25271.htmlhttp://www.gsu.edu/25271.html

Basic ConceptsBasic Concepts

Only Effort for GSU (exclude activities that are Only Effort for GSU (exclude activities that are not compensated for by GSU)not compensated for by GSU)

Document all sponsored-compensated effortDocument all sponsored-compensated effort Including committed cost share (via a companion Including committed cost share (via a companion

account)account)

Uncommitted Cost ShareUncommitted Cost Share Effort that is funded by GSU but not committed in Effort that is funded by GSU but not committed in

proposal is accounted for by “non-sponsored proposal is accounted for by “non-sponsored activities”activities”

100% Effort may be Divided into 100% Effort may be Divided into Five Types of ActivitiesFive Types of Activities

How do I spend my time?How do I spend my time?

Sponsor Project ActivitiesSponsor Project Activities Sponsored (paid for by sponsor)Sponsored (paid for by sponsor) Cost Share (paid for by University)Cost Share (paid for by University)

Non-Sponsored Activities:Non-Sponsored Activities: Research (Department & University) Research (Department & University) University Instruction University Instruction Other Other

What is 100% of effort?What is 100% of effort?

All the activities an individual engages in to earn All the activities an individual engages in to earn GSU salary (IBS)GSU salary (IBS)Because it includes all activities they MUST equal 100%Because it includes all activities they MUST equal 100%

100% of an Exempt employee’s effort is not 100% of an Exempt employee’s effort is not defined by a set number of hours or days. For defined by a set number of hours or days. For some, it may be 70 hours a week, others 40. some, it may be 70 hours a week, others 40.

Part time employee may be 20 hours.Part time employee may be 20 hours. Summer faculty may be less than Full Time if Summer faculty may be less than Full Time if

earning less than 33.33% of Academic Year earning less than 33.33% of Academic Year salarysalary

What is not included in effort?What is not included in effort?

Activities that are being compensated for Activities that are being compensated for by another entity besides GSUby another entity besides GSU

Consultant activities to other institutionsConsultant activities to other institutions Reviewing for federal agenciesReviewing for federal agencies Activities that earn an honorariumActivities that earn an honorarium Volunteer activitiesVolunteer activities

StudentsStudents

Special caseSpecial case IRS rules can IRS rules can onlyonly work up to 20 hours a work up to 20 hours a

week for compensation week for compensation 100% effort 100% effort < < 20 hours worth of activities20 hours worth of activities Student can be doing additional Student can be doing additional

educational activities which require them educational activities which require them to work many more hours than 20 BUT to work many more hours than 20 BUT can only be required to work up to 20 can only be required to work up to 20 hours for salaryhours for salary

But I’m not a lawyer!But I’m not a lawyer!

OMB Circular A-21, Section J.10.b.1.cOMB Circular A-21, Section J.10.b.1.c

Reasonable estimates are based on the Reasonable estimates are based on the understanding: “in an academic setting, understanding: “in an academic setting, teaching, research, service, and administration teaching, research, service, and administration are often inextricably intermingled. A precise are often inextricably intermingled. A precise assessment of factors that contribute to costs is assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a therefore, is placed on estimates in which a degree of tolerance is appropriate.”degree of tolerance is appropriate.”

ERS ERS

After-the-fact certificationAfter-the-fact certification Three times a year (summer, fall, and Three times a year (summer, fall, and

spring)spring) Generates one Personal Effort Report Generates one Personal Effort Report

(PER) per employee (PER) per employee Based on payroll allocation of Institutional Based on payroll allocation of Institutional

Base Salary (excludes any special Base Salary (excludes any special supplements) (i.e., corresponds to supplements) (i.e., corresponds to distribution of salary on PAF)distribution of salary on PAF)

ERS: WorkflowERS: Workflow

Department Coordinators review effort reportsDepartment Coordinators review effort reports Assign certifiers (default is employee)Assign certifiers (default is employee) Prereviews: Checks and makes sure payroll Prereviews: Checks and makes sure payroll

allocation is consistent with recordallocation is consistent with record

ERS automatically sends email to certifiers after ERS automatically sends email to certifiers after prereview (at 6 PM daily)prereview (at 6 PM daily)

Certifiers review and certify effort Certifiers review and certify effort Department coordinators do cost transfers for Department coordinators do cost transfers for

any effort reports changed by certifiersany effort reports changed by certifiers

Who gets a PER?Who gets a PER?

AllAll employees engaged in activities for a employees engaged in activities for a sponsored project sponsored project (either charged directly to the sponsored account or to (either charged directly to the sponsored account or to

a companion account if cost sharing)a companion account if cost sharing)

ANDAND Faculty and staff funded solely from fund code Faculty and staff funded solely from fund code

10 who are engaged in research funded by the 10 who are engaged in research funded by the university university (does not include graduate students who are not on (does not include graduate students who are not on

sponsored projects) sponsored projects)

Who can certify effort reports?Who can certify effort reports?

Federal guidelinesFederal guidelines

PERs are required to be certified in a PERs are required to be certified in a timelytimely manner by individuals “with suitable manner by individuals “with suitable means of verification that work was means of verification that work was performed” (OMB A-21 J.10.c.2.c) performed” (OMB A-21 J.10.c.2.c)

Who can certify PER with Who can certify PER with sponsored effort?sponsored effort?

Faculty do their ownFaculty do their own PI certifies staff/student on sponsored projects PI certifies staff/student on sponsored projects

OROR PI can designate someone who has suitable means of PI can designate someone who has suitable means of

verification verification (i.e. Project Manager, Lab Coordinator – (i.e. Project Manager, Lab Coordinator – NOT department Business Manager)NOT department Business Manager)

Must document via email to department coordinator Must document via email to department coordinator

OROR Staff can do their own (typically only when working on Staff can do their own (typically only when working on

multiple projects with more than one PI and are long multiple projects with more than one PI and are long term employees)term employees)

Who can certify for faculty with only Who can certify for faculty with only non-sponsored activity? non-sponsored activity?

Only when faculty do not expect to have Only when faculty do not expect to have sponsored activity in the future (for next 5 sponsored activity in the future (for next 5 years)years)

Department coordinators (business Department coordinators (business managers) can certify because only for managers) can certify because only for BOR reporting purposesBOR reporting purposes

BUT NEED TO BE CAREFULBUT NEED TO BE CAREFUL Can not change semester by semesterCan not change semester by semester

Step by Step GuideStep by Step Guide

ERS: TimingERS: Timing

Central administrator (Nicole Andrews) Central administrator (Nicole Andrews) generates Effort Reports generates Effort Reports

Based on ACTUAL payroll from Based on ACTUAL payroll from HR/Financials (Which should correspond to HR/Financials (Which should correspond to PAF (s) averaged over semester)PAF (s) averaged over semester)

Summer and Fall: 30 days after close out Summer and Fall: 30 days after close out of semester; Spring earlierof semester; Spring earlier

Prereview and Certification required to be Prereview and Certification required to be finished 30 days laterfinished 30 days later

Special IssuesSpecial Issues

Course releasesCourse releases I get one course release in the spring. Should I get one course release in the spring. Should

I charge my grant 33.3% of my salary during I charge my grant 33.3% of my salary during that semester or 16.66% for the academic that semester or 16.66% for the academic year?year?

SummerSummer I work on my grant all year but only want to I work on my grant all year but only want to

charge it during the summercharge it during the summer

Effort Commitment: ProposedEffort Commitment: Proposed

PIs estimate the amount of effort they will spend PIs estimate the amount of effort they will spend on a sponsored project in a proposal (and to on a sponsored project in a proposal (and to build a budget)build a budget)

Federal agencies regard estimates as a Federal agencies regard estimates as a commitmentcommitment

So do sponsors using So do sponsors using federal fundsfederal funds (federal flow (federal flow through, e.g., other institutions like state through, e.g., other institutions like state governments, other Universities)governments, other Universities)

Some sponsors may not require fulfill effort Some sponsors may not require fulfill effort commitments. Need to read terms and commitments. Need to read terms and conditions of award. Call OSP if unsure.conditions of award. Call OSP if unsure.

Over commitmentOver commitment

PIs need to ensure they can fulfill effort PIs need to ensure they can fulfill effort commitment by examining all other sponsored commitment by examining all other sponsored and non-sponsored activitiesand non-sponsored activities

Total Effort can not equal more than 100%Total Effort can not equal more than 100% Because not all proposals are funded, PIs may Because not all proposals are funded, PIs may

get an award and can not fulfill commitmentget an award and can not fulfill commitment Must get prior approval from sponsoring agency Must get prior approval from sponsoring agency

to reduce effort commitment. to reduce effort commitment. (Procedures (Procedures specific to agency. Can get help from OSP)specific to agency. Can get help from OSP)

Effort CommitmentsEffort Commitments

OMB Circular A-110 Section 25.3.c: “recipients OMB Circular A-110 Section 25.3.c: “recipients shall request prior approvals from Federal shall request prior approvals from Federal awarding agencies for….The absence for more awarding agencies for….The absence for more than three months, or a 25 percent reduction in than three months, or a 25 percent reduction in time devoted to the project, by the approved time devoted to the project, by the approved project director or principal investigator.”project director or principal investigator.”

Commitment may be binding on all “Key Commitment may be binding on all “Key Personnel” as defined in the award document Personnel” as defined in the award document

Effort Commitments:Effort Commitments:

Committed Effort % Actual Effort %

Committed Effort %

% Change in Effort

If more than 25% than have to ask permission from sponsor for reduction of committed effort

Effort Commitments are for the Effort Commitments are for the Budget YearBudget Year

Proposed effort committed for the Proposed effort committed for the academic year can be moved to the academic year can be moved to the summer (or vice versa) IFsummer (or vice versa) IF

actual effort for a budget year is not actual effort for a budget year is not significantly reduced from the committed effort significantly reduced from the committed effort for that budget year AND for that budget year AND

the faculty member can certify they expended the faculty member can certify they expended the effort during the period the sponsored the effort during the period the sponsored project is charged. project is charged.

Commitment = payroll = effortCommitment = payroll = effort

Committed Effort =Committed Effort =

Salary Charged =Salary Charged =(within 25% of effort committed)(within 25% of effort committed)

Actual Effort Certified Actual Effort Certified (% charged = certified effort (% charged = certified effort + + 5% Total 5% Total

Effort)Effort)

What are auditors looking at?What are auditors looking at?

Effort ReportingEffort Reporting CommitmentsCommitments

Was the Proposed Effort Met?Was the Proposed Effort Met? Are Faculty Over Committed? Are Faculty Over Committed?

CertificationCertification Was the Certifier Appropriate?Was the Certifier Appropriate? Account for All Activities?Account for All Activities?

Timeliness Timeliness Why are there Delays in Certifying Effort?Why are there Delays in Certifying Effort? Do Delays Indicate Bigger Issues?Do Delays Indicate Bigger Issues?

Cost TransfersCost Transfers

Was Was How & Why OccurredHow & Why Occurred documented? documented? Are Charges Reasonable, Allowable, Are Charges Reasonable, Allowable,

Allocable & Consistently Treated?Allocable & Consistently Treated? Did the PI Certify the Correctness of the Did the PI Certify the Correctness of the

new Charges to their Sponsored Project?new Charges to their Sponsored Project? Are Processes Changed to Prevent Are Processes Changed to Prevent

Future Cost Transfers?Future Cost Transfers?

What are auditors looking at?What are auditors looking at?

Resources AvailableResources Available

Personnel Effort Reporting Policies & Personnel Effort Reporting Policies & Procedures (lots of examples)Procedures (lots of examples)

Salary, effort, and person conversion chartSalary, effort, and person conversion chart (available under proposal dev page)(available under proposal dev page)http://www.gsu.edu/research/proposal_develhttp://www.gsu.edu/research/proposal_development.htmlopment.html Department CoordinatorDepartment Coordinator Amy Lederberg and Nicole Andrews, RFS Amy Lederberg and Nicole Andrews, RFS

and OSP staffand OSP staff