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The Office of Management and Budget (OMB) Circular A-21 requires that institutions document the time and effort that each employee expends on various University activities during a specified time period. Effort includes the time spent working on a sponsored project in which salary is directly charged or contributed, as well as time spent on instruction, administration, and public service. Effort reporting is the method of certifying to the granting agencies that the effort charged or cost shared to each award has actually been completed.
The University of Houston Time and Effort Report
At the University of Houston the Time and Effort Report is combined with the timesheet. It constitutes the primary basis for reimbursement to the University by the Federal government of salaries applied directly to sponsored research projects. It also provides documentation that an employee is in the employment of the University during the pay period. Principal Investigators are urged to check Time and Effort Reports for all their employees closely each month to certify that all persons paid on a sponsored project did, in fact, work on that project for the amount of time indicated on the Time and Effort Report. The employee and the employee’s supervisor must sign the timesheet.
When properly filled out, the Time and Effort Report also provides a record of 100% of employee effort. The information reported for a pay period should reflect the actual activity of each employee as well as it can be measured, not the budgeted activity. The budgeted effort percentages reflect only the budget sources from which an employee is paid and are not meant to reflect the distribution of actual time and effort. It is important to note that one hundred percent of an employee’s effort is the sum of an employee’s total hours actually spent on work within the scope of his or her employment, regardless of how many or how few hours an employee works and regardless of the percent FTE listed on the appointment. Effort certification must reflect actual work performed. Additionally, just as an employee’s total effort is not defined by regular business hours of the employer or by the percent FTE of the appointment, research effort does not necessarily take place only in the research facility or on university premises. Research effort can occur at home, at a conference, or in off-site research-related meetings. The employee, the PI, or a responsible official using suitable means of verification that the work was performed must sign the report. See MAPP 02.05.02 for the University policy on and a detailed discussion about time and effort reporting.
Time and effort reports are subject to audit by both the federal government and by Internal Audit. Institutional disallowances can result if the effort report was certified by an individual other than the employee, the PI, or a responsible official using suitable means of verification that the work was performed. A disallowance may also result if the effort report does not encompass all of the activities performed by the employee under the terms of his or her employment, or if the levels of effort reported do not appear reasonable, given the responsibilities of the individual. Individual disallowances can result if the effort report certified by the individual is found to be falsified or if the levels of effort reported do not appear reasonable.
External Consulting
A faculty member’s external consulting is not considered to be part of his or her total effort. OMB Circular A-21 provides that professional services “provided outside the institution for non-institutional compensation” is not part of total effort for purposes of the requirement to document the time and effort that each employee expends on University activities.
Change in Level of Effort
OMB Circular A-110 requires grantees to obtain the sponsoring agency’s approval in writing if the PI or other key personnel specifically named in the Notice of Grant Award will withdraw from the project entirely, be absent from the project during any continuous period of three months or more, or reduce time devoted to the project by twenty-five percent or more, from the level approved at the time of the award. It is important that the PI notify the Office of Contracts and Grants if he or she anticipates a significant change in the level of effort to be devoted to a sponsored project.
What is required of Faculty in the time and effort system?
For faculty, the Time and Effort Reports show the salary charged to each cost center and the percent of effort for the current month’s activity. The following is required of Faculty in the Time and Effort system:
- A distribution of 100% of the effort for which an employee is compensated, regardless of his or her budgeted effort.
- Reasonable approximations of effort recorded
- Signature and date of certification
- If cost-sharing or effort in other categories is appropriate, recording into these categories.
- Submission in a timely fashion.
Faculty members are typically paid and budgeted as instruction during the academic year. Therefore, for all effort other than instructional effort, effort must be indicated by showing the percent of effort devoted to other activities. If a faculty member is contributing effort to a sponsored project while drawing pay from an instructional cost center, he or she will fill in the cost center number with the appropriate percentage of effort devoted to that project.
What is required of Deans and Department Chairs in the Time and Effort system?
The following is required of Deans and Department Chairs in the Time and Effort system:
- A distribution of 100% of the effort for which an employee is compensated, regardless of his or her budgeted effort;
- Reasonable approximations of effort recorded;
- Signature and date of certification
- If cost-sharing or effort in other categories is appropriate, recording into these categories
- Submission in a timely fashion.
The time spent on administrative duties by a college dean is initially budgeted as departmental administration. Therefore, the only percentages a dean will report for the administrative budget are the time spent cost sharing on sponsored project.
If one hundred percent of a Department Chair’s salary comes from the department instructional budget, his or her time is initially budgeted as instruction. In this case the chair must correct the time and effort report to show the time spent in direct instructional activities, the time spent on sponsored activities, and the time spent on departmental administration.
If a department chair’s budgeted time is split between the faculty salary budget and an administrative budget, the budgeted percentages for each activity are shown on the time and effort report. They should be adjusted as discussed above. The chair must consider all of his or her current institutional activities when reviewing the report and must complete the percentage of effort for the current pay period. A chair who contributes effort to a sponsored project while drawing pay from an instructional cost center must indicate the cost center numbers of the sponsored project on the form with the appropriate percentage of effort. The report must be signed and dated either by the Dean or department Chair or by a responsible official having a suitable means of verification that the work was performed as indicated.
What is required of Professional/administrative staff in the time and effort system?
The following is required of professional/administrative staff in the time and effort system:
- A distribution of 100% of the effort for which an employee is compensated, regardless of his or her budgeted effort;
- Reasonable approximations of effort recorded
- Signature and date of certification;
- If cost-sharing or effort in other categories is appropriate, recording into these categories;
- Submission in a timely fashion.
The time and effort of a professional/administrative staff member who is paid from a non-state cost center is recorded as one hundred percent effort to that budget. A staff member who devotes effort to a category other than that from which he or she is paid must indicate that distribution on the report. A professional/administrative staff member paid from a state cost center must record time and effort as departmental administration. If he or she contributes effort to a category other than that from which salary is paid, he or she must indicate that distribution on the report form. It is important to consider all current institutional activities in order to complete the percentage of effort for the current pay period accurately. If the staff member is contributing effort to a sponsored project while drawing pay from a state cost center, he or she must fill in the cost center number and percentage of effort on the report. The report must be signed and dated either by the employee or by a responsible official having a suitable means of verification that the work was performed.
What is required of Bi-weekly staff in the time and effort reporting system?
The Time and Effort Reports of bi-weekly employees reflect all current budgets and budgeted FTE per cost center for the employee and require employees to report hours worked chargeable to each budget. If the employee is cost-sharing on a project, he or she must fill in the cost center number in the effort distribution block of the report, along with the number of hours devoted to that project. The time and effort report must be signed and dated either by the employee or by a responsible having a suitable means of verification that the work was performed.
The Time and Effort Report is sent to departments each pay period for verification of the distribution of activity, to report absences and/or hours for pay; and for certifications.
Requesting Retroactive Changes
Retroactive salary reallocations for all employees may be requested by use of a Payroll Account Reallocation Form. There must be a written explanation of how the error occurred and why a correction is necessary. If the change is to a period in excess of 90 days past, a detailed explanation of why the charge was not corrected earlier must be provided. Also, there must be a certification of the correctness of the new charge. The request should normally be signed by the same person who signed the original Time and Effort Report and by the department head. The department must submit to the Office of Contracts and Grants the request along with the Time and Effort Report (timesheet) as well as either a screen print of gross income distribution earnings or the labor distribution report so that the original charge may be verified. For more detailed information concerning retroactive changes, refer to MAPP 05.02.03. It is important to be aware that a pattern of retroactive cost transfers may suggest to an auditor that an effort certification has been formulated by factors other than actual effort on the project.
Retroactive adjustments to time and effort distribution may be requested by use of the Time and Effort Adjustment Request form. The originator must include the Employee ID of the employee, the name, the pay period ending date, the original distribution as reported on the TAE report submitted to Payroll, and the revised distribution. One form must be submitted for each pay period and the appropriate time and effort report must be attached to each request. The form must be completed by including a justification for the adjustment. Both the employee and the employee’s supervisor must sign the form certifying to the correctness of the new distribution. The completed form must be kept on file in the department for audit purposes and for documentation of cost sharing, if appropriate. It is important to be aware that a pattern of retroactive adjustments to effort certifications may suggest to an auditor that an effort certification has been informed by factors other than actual effort on the project.
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