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,*,Click to edit Master title style,Click to edit Master text styles,Second level,Third level,Fourth level,Fifth level,Click to edit Master title style,Click to edit Master text styles,Second level,Third level,Fourth level,Fifth level,*,1,Managing Effort:Truth or Consequences,NCURA PRA Conference,July 19-21,2021,Providence,RI,2,Todays Presenters:,Patrice Carroll,Associate Director,Office of Sponsored Projects,Brown University,Patrick Fitzgerald,Associate Dean for Research Administration,Faculty of Arts and Sciences,Harvard University,Brenda Kavanaugh,Assistant Director,Office of Research&Project Administration,University of Rochester,3,Regulations Governing“Effort Reporting,OMB Circular A-21,Cost Principles for Educational Institutions,Section J.10:“Compensation for personal services,OASC-3,HHS Cost Principles for Hospitals,“Compensation for personal services,OMB Circular A-122,Cost Principles for Non-Profit Organizations,“Compensation for personal services,4,A-21 Section J.10,“Compensation for personal services,Covers amounts paid by the institution for services rendered during the period of performance under sponsored agreements,including salaries,wages&fringe benefits,Costs are allowable to the extent they conform to the established policies of the institution,are consistently applied and are determined and supported per J.10.,Reliance is placed on estimates in which a“degree of tolerance is appropriate,5,A-21 Requirements,After-the-fact confirmation of personnel costs charged to sponsored agreements,Signed by the employee,principal investigator or responsible official(s)using,suitable means of verification,that the work was performed,Must be incorporated into institutions official records,Reports will reasonably reflect the activities for which employees are compensated by the institution,6,A-21 Requirements,The institutions effort reporting system must provide for modification of an individuals salary distribution commensurate with a significant change in the employees work activity,A-21 doesnt define“significant change,Time is expressed in terms of percent of total activity(“effort)not hours,Frequency of reporting varies depending upon method of certification,7,A-21 Requirements,Effort reporting system should be part of institutions official records,System will provide for independent internal evaluations to ensure compliance,Government rationale,:,Labor charges are majority of direct costs of research and other(non-university)recipients of federal funds have much more stringent requirements,8,A-21 Requirements,Examples,of Acceptable Methods for Payroll Distribution:,Plan-Confirmation,After-the-fact Activity Records,Multiple Confirmation Records,Since these are examples,we should be able to choose other methods which satisfy the General Principles in J.10.b.(1),9,A-122:Compensation for personal services,Allowable when compensation(salary and benefits)is reasonable for the services rendered and conforms to the established policy of the organization consistently applied to both federal and non-federal activities,Compensation must be,reasonable,:,Compensation for federally-sponsored work is reasonable if its consistent with that paid for:,work in the organizations other activities,Similar work in the labor markets in which the organization competes for the kind of employees,10,A-122:Compensation for personal services,Support of salaries and wages:,The distribution of salaries to awards must be supported by personnel activity reports,Reports reflecting the distribution of each activity of each employee must be maintained for all staff members whose compensation is charged directly to awards.,In addition,to support the allocation of indirect costs,such reports must also be maintained for employees whose work involves two or more functions if a distribution of compensation between functions is needed in the determination of the indirect cost rate,11,OMB A-122:Compensation for Personal Services,Reports must meet the following standards:,Reflect an,after-the-fact,determination of the actual activity of each employee.Budget estimates do not qualify as support.,Report must account for the total activity for which employees are compensated,Must be signed by the employee,or by a responsible supervisory official having first hand knowledge of the work performed and represent a reasonable estimate of the actual work performed,Must be prepared monthly,Charges for nonprofessional employees must be supported by records indicating#of hours worked,Salaries used as cost sharing must be supported in the same manner as wages direct-charged,12,OASC-3:Compensation for Personal Services,Supplemental data on time or effort required for individuals whose compensation is chargeable to two or more research agreements,or two or more(direct)categories,Salaries and wages of individuals other than professional staff will be supported by daily time and attendance and payroll dist.Records,Professional staffcurrent and reasonable estima
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