Fiscal Compliance Requirements for Sponsored Programs Effort Reporting. Published 2010
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1 Fiscal Compliance Requirements for Sponsored Programs Effort Reporting Published 2010
2 Learning Objectives To understand: Effort reporting compliance requirements University s process for Effort Verification Reporting (EVR Form) Responsibility of Principal Investigator (PI), Research Administrator, and Subject Common issues and impact of noncompliance 2
3 Definitions Effort Reporting The process for employees to verify effort spent on a sponsored award. Effort Verification Report (EVR) Form used by the University to certify effort. Modified Effort An adjusted estimate of how an employee s time was actually spent during the reporting period. 3
4 Definitions Personnel Action Form (PAF) University form that establishes planned payroll distribution Payroll Correcting Entry (PCE) A correcting journal entry to redistribute payroll to a different funding source Subject Anyone who has time charged to an award 4
5 Effort Reporting Requirements What resources outline procedures for effort reporting? OMB Circular A 21 Cost Principles for Educational Institutions UM System APM Effort Verification Reports UM System BPM 213 Adjustment of Income and Expense Items 5
6 Effort Reporting Requirements Effort is verified to ensure all direct payroll costs reflect actual efforts. Total effort must reflect 100% of all University compensated activity. Total effort is not based on a 40 hour workweek or Full time equivalent. 6
7 Effort Reporting Requirements EVRs should be: Completed every 6 months Signed by the subject of the effort or a person with suitable means of verification that work was performed Submitted to the Sponsored Programs Office (SPO) within 30 days 7
8 EVR What to check Are these the right grants or other funding sources? 8
9 EVR What to check From the PAF at the beginning of the reporting period 9
10 EVR What to check Actual pay, presented in dollars and percentage 10
11 EVR What to check ) Estimate your effort. 2) Compare to Payroll Data %. 3) If different, complete Modified Effort 11
12 EVR Signature Completion Compensation not related to Base Pay awards, incentive, allowance, etc. Signing and dating are critical since this is a certification 12
13 EVR Unallowable Costs Payroll related costs can be unallowable if: EVR is not signed EVR is not signed by person with suitable means of verification EVR is not signed and dated by the due date Information is incomplete or inaccurate Certified effort does not match the General Ledger 133
14 Payroll Correcting Entries PCEs From the PI monthly review, PCEs must be: Entered if the difference between Payroll Data % and the Modified Effort exceeds 5%. Entered within 2 accounting periods after the month of the transaction. Supported by proper documentation See BPM 213 Adjustment of Income and Expense Items 14
15 Roles and Responsibilities UM System Controller s Office Produces EVRs and provides compliance oversight Sponsored Programs Office (SPO) Reviews EVRs for compliance; follows up on late or incomplete EVRs Departments Distributes and collects EVRs. Initiates PAFs and PCEs at the direction of the PI 14
16 Roles and Responsibilities The subject: Ensures the EVR is accurate and consistent with the proposed effort Completes the Modified Effort if actual effort is different from Payroll Data % Reviews his/her EVR and signs timely If leaving University: reviews actual effort with supervisor/pi multiple units may need to sign 16
17 Roles and Responsibilities Activity PI 17 Research Admin Overall Compliance Responsibility X Attend Training X X Ensure proposed effort was delivered X Work with SPO to contact sponsor with X significant effort changes Distribute and follow-up on late EVRs X Reviews EVRs for completeness X Initiates/processes PCEs and PAFs X X Ensure all EVRs are reviewed, signed, and submitted by due date X X
18 Common Issues Incomplete or inaccurate EVRs Not signed by subject or person with suitable means Late EVRs and PCEs PCEs not completed to reflect changes in effort > 5% PAF s not timely updated PI effort charged 100% to sponsored activities 18
19 Impact of Noncompliance Questioned or unallowable costs Repayments to the sponsor Fines and/or sanctions Subject to additional external audits Jeopardize future funding opportunities Damage to reputation 19
20 Concluding Points Payroll costs should reflect actual effort worked Signature indicates the effort is reasonable Do not wait until EVR cycle to review effort! 20
21 Additional Information University Accounting Policy APM Section 60 APM EVR Policy University Business Policy BPM 213 Correction of Income & Expense Items Other related training available: Financial Compliance Training Website Contact your Sponsored Programs Office for departmental training sessions or further discussion Please Click Here to Complete the Training Survey 25
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