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Faculty Effort ReportingWashington University School ofMedicineClick the play button () below toadvance the slides.If you experience technical difficulties with this training program,please contact Research Education at 314-747-5574Version 4.0FY 20111
Institutional Risk National attention focused onEffort Reporting– Large University financialsettlements– DHHS Office of Inspector GeneralWork plan Local attention– NSF and DHHS On-campus audits– Compliance Office Reviews2
Why is effort reporting a big deal? Grantees agree to comply with FederalGuidelines and Uniformed Guidance 2CFR 200 (UG). UG requires payroll costs to bedocumented to ensure that externalsponsors reimburse the grantee onlyfor the time and effort actuallyexpended on their behalf. Salary costs are the majority of costsincurred on a grant.3
February 2003 5.5 millionsettlement Qui Tam /Whistleblower Insufficient PIeffort on NIH KAwardsFebruary 2004 2.6 millionsettlement Qui Tam /Whistleblower Effort reportingissues4
Effort ReportingAudit (9/08) Administrative &Clerical Costs (1/09) 7.6 million settlementwith DHHS, NSF, NASA,Army, DOE, DCAA &FBI (12/08) Effort ReportingAudit (6/09)5
Effort Reporting at WU Documentation– Electronic Personnel Activity Report(ePAR)– New ePARS system (certify & monitor)– Research Compliance reviews Education program– Faculty meetings– On-line course6
What is effort reporting? An individual certifies thatsalaries charged tosponsored projects arereasonable in relation to thework performed during thereport period. Actual salary dollars arepresented as percentagefigures (of total salary) on anePAR.7
Faculty/Staff Effort Total activity for which a faculty/staffmember is compensated by WU.– Regardless of the number of hours actuallyworked (100% Institutional Effort).– No standard hours or work week– Effort varies from individual to individual– Includes all WU activity Not just Monday through Friday Not just X days a week8
Institutional Base Salary (IBS) Annual compensation paid by WU for afaculty member’s appointment foractivities such as:– Organized Research– Department Research– Instruction– Patient Care (Clinical Care/Trials)– Graduate Medical Education– Department Administration– Management of Hospital Services9
Excluded from IBS (and ePARS) VA Salary Incentive pay (Z) Consulting perWU policy(paid/unpaid)– NIH peer review– Guest lecturer Patient Advocacy CommunityService Paid EditorPositions Additional pay(on-call)10
Key DefinitionsThe following slides provide key definitionsof effort reporting categories that shouldbe used in allocating effort.11
Organized Research Research and developmentactivities that aresponsored by federalagencies, non-federalorganizations and industry. Includes training ofindividuals in researchtechniques (e.g.,NIH T-32& F-32 projects).12
Organized Research, cont Work on federalgrants (NIH, NSF ) Work on non-federalgrants (JDRF, AHA,Boeing ). Writing progressreports for existingprojects. Holding a meetingwith lab staff todiscuss specificprojects. Attending a scientificconference held byan outsideprofessional societyto present researchresults13
Department Research General research support, includingstart-up funding and bridge fundingthat is not project oriented. Typically, department researchsupport is paid from a pool and is notidentified by project.14
Instruction All teaching and training activities– Offered for credit towards a degree/certificate or on a non-credit basis– Offered through regular academicdepartments or separate divisions Excludes - supervision of residentsenrolled in an ACGME accreditedprogram (see separate GMEcategory).15
Instruction, cont. TeachingLecturing /tutoringSupervisingindependentstudy, laboratorycourse workPreparing forscheduledteachingGrading papersCourse Development Preparing forfuture courses Devising newinstructionaltechniques Revising manuals,tapes, slides, etc.16
Patient Care Clinical services - rendered toindividual patients that are normallyeligible to be billed to patients or thirdparties (Part B).– Professional– Technical– Support staff services Clinical trial activities - testing of drugsand medical devices using humansubjects (industry-sponsored).17
Graduate Medical Education (GME) Supervision of residents - activitiesrelated to the supervision of personsenrolled in ACGME accredited internand residency programs.– Teaching of clinical procedures.Normally, the ex tra tim e required for anyprocedure or other patient interactiondue to the supervision of the resident(s).– Grand rounds– Teaching conferences18
Department Administration Administrative and supportingservices which benefit two or moredepartmental activities or objectives. Activity cannot be directly identifiedwith an organized research project,instruction, patient care, hospitaladministration 19
Dept. Administration, cont. Preparation of competitive grantproposals. Participation in school/deptcommittees Review of dept accounts andfinancial statements. Selection/training of general staff Selection/recruitment of faculty Planning for building projects orrenovations20
Management of Hospital Services Relates to the affiliationagreements and contracts with aspecifically named hospital The University is providing facultyto:– Supervise hospital services– Serve on hospital committees– Provide other administrative andgeneral patient services (Part A).21
Prior ApprovalPI must seek and receive prior approvalfrom the Federal agency before makingthe following project changes (OMB A110):– PI time devoted to project is reduced by25% or more from the level in theapproved application (e.g., new grant oradditional clinical responsibilities)– He/she relinquishes active direction of theproject for more than three months (e.g.,extended maternity/paternity leave)22
Implications of K Awards Minimum level of effort, typically 75% Great for basic sciences, but in clinicaldepartments, clinical effort MUST bereduced. Reduction of clinical effort Reductionof clinical revenue. Some other faculty member must pickup slack.23
Effort Reporting CyclePre-awardAppointingFaculty &Staff Employmentterms areestablished,including #months (contractperiod), % fulltime, salary basePreparingthe ProposalBudget Effort isproposed, acommitment ismade to thesponsorPost-awardChargingSalary Effort ischarged,contemporaneouslywith activityCertifyingEffort Effort isattested to,after activityhas occurred24
AppointmentsPre-awardAppointingFaculty &StaffPreparingthe fort Faculty appointment, as documented inthe payroll (HRMS) system, denotes theindividual’s FTE and salary.25
Proposing EffortPre-awardAppointingFaculty &StaffPreparingthe fort PI must have some level of proposed effort for eachproject. Proposed effort is a com m itm ent to the sponsor thatmust be honored and tracked if awarded. Sum of effort for all WU activities, includingawarded sponsored projects, must equal 100%.26
Charging EffortPre-awardAppointingFaculty &StaffPreparingthe fort Salary charges should be posted toappropriate accounts as actual activityoccurs Salary charges must be com m ensurate w ithactual effort ex pended Salary charged cannot be actual w ork27
Certifying EffortPre-awardAppointingFaculty &StaffPreparingthe fort Certification of activity should reflectactual effort, which should be basedon effort commitments28
How do I certify effort? Effort certification is completed viathe ePARS system.– Electronic web-based effort reportingsystem (implemented in January 2009)– Available 24/7 via the ePARS Portalhttps://eparsprod.wustl.edu/ecrt/– Detailed system information andtraining materials available at ePARSwebsite: http://epars.wustl.edu29
ePAR Example30
ePAR Certification “I certify that the percentagesnoted on this page for the periodshown indicate a reasonableapproximation of the effort actuallyspent on the projects/activitieslisted.” Legal document. Certification is required by Federalregulations and is subject toindependent audit and review.31
Changes to ePAR’s If the actual effort performed on asponsored project differs from thepercentage noted on the ePAR by:– 0 to 5% , no adjustment to the figure isnecessary.– 5% , the ePAR should be adjusted toreflect the correct effort percentage.32
ePAR Support Each department/division has adesignated Effort Coordinator. Sponsored Projects Accounting (SPA)coordinates the timing, distributionand completion of effort reports. SPAprovides institutional oversight foreffort reports and maintains andmonitors all aspects of the effortreporting system.– Contacts: Christal Zhu (5-8202)Carla Reed (5-7939)33
Roles and Responsibilitieshttps:/ / financialservices.w ustl.edu/ w pcontent/ uploads/ 2016/ 03/ W P SPA EFFOR T R R .pdf Faculty: Reviews, adjusts (asnecessary) and legally certifies theaccuracy of employee ePARs. Department Administrator: Assistsfaculty in reviewing, adjusting andcertifying (if the employee is notavailable) ePARs for appropriateproject personnel.34
Who Can Certify An ePAR? Strongly recommend that eachindividual faculty or staff membercertify their own ePAR. A supervisor or administrator (proxy)may certify the ePAR in the absence ofthe employee,– IF he/she has suitable means of verification.– Requires documented review by an individual,such as a PI, project manager, supervisor or anemployee who has first hand knowledge that thework was performed.35
Reporting Periods Medical School Campus– Academic (all faculty), report semi-annually January through June July through December– Non-Academic (staff that work on sponsoredprojects), report quarterly January through March April through June July through September October through December36
ePAR Timeline Per the agreement with ourfederal cognizant agency(DHHS):– The ePAR must be certified by thefaculty/staff member or their proxywithin 30 days of the start of thecertification period.37
Helpful HintsThe situations below require specialattention: 100% on sponsored research projects Large clinical (RVU) activity and largeresearch effort percentages Should include effort associated withadministrative duties– Preparation of competitive grant proposals– School/department committees– Selection of general staff, faculty and students38
Effort Reporting Links Effort Reporting Policy and Procedures– porting/ ePARS Training– https://epars.wustl.edu/ ePARS Portal– https://eparsprod.wustl.edu/ecrt/39
Real World Effort Example- WUSM -40
The Dilemma Full-timeWUSM Faculty ActiveClinician ConsultantDr. Jane Doe41
Dr. Jane Doe – WUSM Effort Teaches One Class 6Serves on IRB 5Grant Proposals 5NIH RO1 Grant 15NIH RO3 Grant 10Patient Care/Clinical 30Total hrs/wk 7142
Dr. Jane Doe – Consultant Effort Head of R&D for aUniversity-FundedStart-Up Company 14 Hrs/Wk43
Consulting Considerations WUSM allows faculty to consult oneday/wk. WUSM does not include consulting inthe faculty appointment letter anddoes not pay consulting salary. WUSM does not include consultingeffort in the ePAR.44
Dr. Jane Doe – Total EffortWUSMInstruction:Dept. Admin:Research:Patient Care:Subtotal WUSM:6 hrs10 hrs25 hrs30 hrs7%12%29%35%71 hrs83%Consulting14 hrs17%Total Effort85 hrs100%45
Dr. Jane Doe – Reportable Effort(excludes Consulting )WUSMInstruction:Dept. Admin:Research:Patient Care:Subtotal WUSM:6 hrs10 hrs25 hrs30 hrs9%14%35%42%71 hrs100% (17%)Consulting(14) hrs0%ReportableEffort:71 Hours100%( 7%)(12%)(29%)(35%)46
Report a Concern or Violation Institutional Officials for Research andFinancial Compliance– Jennifer K. Lodge, Ph.D. – Vice Chancellorfor Research, (314) 747-0515– Amy B. Kweskin – Vice Chancellor forFinance and CFO, (314) 935-9018 University’s Compliance Hotline– (314) 362-4998– Reports can be made anonymously– No caller ID or number recognition47
Contacts Joseph M. Gindhart – Associate ViceChancellor for Finance and SponsoredProjects – jgindhart@wustl.edu– 314-935-7089 Denise A. McCartney, Associate ViceChancellor for Research Administration– mccartnd@wustl.edu– 314-747-625348
the payroll (HRMS) system, denotes the individual's FTE and salary. 26 . WUSM does not include consulting effort in the ePAR. Dr. Jane Doe - Total Effort. WUSM. Instruction: 6 hrs. Dept. Admin: 10 hrs. Research: 25 hrs. Patient Care: 30 hrs Subtotal -
