Effort Reporting November 9, 2005

1. Effort ReportingNovember 9, 2005 Eric Cottington Associate Vice President for Research

2. Agenda Background Regulations Challenge Action Plan Results to Date Next Steps

3. Background Effort is the proportion of time spent on professional activities such as research, teaching, administration, service. Effort Reporting is the method of documenting the proportion of time devoted to these professional activities as a percentage of total professional activity. Effort not necessarily calculated on a 40-hour workweek. Payroll and effort distributions are not the same thing.

4. Effort Reporting per OMB Circular A-21 (Section J; Part 8) Most universities use after-the-fact activity record systems Distribution of salaries and wages are supported by activity reports that: show the percentage distribution of activity of employee are signed by the employee, principal investigator, or responsible official(s) using suitable means of verification that the work was performed reflect activity applicable to each sponsored project are prepared each academic term, but no less frequently than every six months.

5. Challenge Reporting is complicated and time-consuming. Federal policy interpretations lack flexibility to accommodate diverse university activities and compensation arrangements. Blurred lines among researchers� activities Research versus patient care Multiple funding sources for research with overlapping purposes Policies that discourage or prohibit accurate calculation of institutional base salaries when compensation comes from outside of the institution Recent governmental enforcement Northwestern University: $5.5 Million settlement Johns Hopkins University: $2.6 Million settlement Harvard University: $3.3 Million settlement University of Alabama-Birmingham: $3.9 Million settlement NIH has specific requirements for including clinical practice compensation as part of base salary for effort reporting purposes

6. NIH requirements regarding clinical practice compensation Clinical practice compensation must be set by the university Clinical practice activity must be shown on the university�s payroll or salary appointment forms and records approved by the institution Clinical practice compensation must be paid through or at the direction of the university Clinical practice activity must be included and accounted for in the institution�s effort reporting and/or payroll distribution system University must assure that all financial reports and supporting documents associated with the combined institutional base salary and resulting charges to NIH grants are retained and made available to federal officials

7. Action Plan Create Effort Report Taskforce Review all NIH K awards, which require substantial effort commitments (> 50%) Revise SOM faculty appointment form to formally acknowledge effort in teaching, research, clinical care, and service Develop Effort Reporting policy Revise Effort Reporting Procedures Create Effort Reporting Website Pilot test of revised effort reporting procedures Implement revised effort reporting procedures for entire university

8. Effort Reporting Website

9. FAQs Who is subject to Effort Reporting? Every individual who devotes effort to sponsored activities, whether this effort is paid or unpaid, is subject to effort reporting

10. FAQs What is 100% effort? The total amount of effort expended to accomplish the professional activities of Case faculty, staff, and students regardless of the actual number of hours expended on those activities. This normally includes all effort expended on Case-compensated sponsored research, administration, teaching, unsponsored scholarly activity, and other activity and, in the case of clinical faculty, clinical activity compensated by clinical practice plans. 100 per cent effort is not defined as a single, standard number of hours or days per week, since it will likely be different for each person and may vary during the year. The number of hours implicit in an individual�s 100% effort must be reasonable and supportable to department, school, university and external reviewers, if requested. In most circumstances, a minimum of 40 hours (assuming a full-time schedule) and a maximum of 80 hours would be considered a reasonable average work week.

11. FAQs Can the total effort listed on the Effort Certification Form be less than or greater than 100%? No. The effort percentages on the Effort Certification Form must total 100% - neither more or less. All Case compensated effort (and for clinical faculty, Case compensated effort and hospital or practice plan compensated effort) must be accounted for; and obviously the sum of the individual effort categories cannot be greater than 100%. Again, just because an individual may work more than a normal 35- or 40-hour week does not alter this rule. For example, an individual who spends 40 hours a week on sponsored research and 40 hours a week on clinical activity would report an effort percentage of 50 percent for each category, totaling 100 percent for the report period.

12. FAQs Are there some sponsored projects where I can report 0% effort? Individuals are expected to commit some level of effort (>0%) on sponsored projects on which they are listed as a principal investigator or key personnel. Exceptions to this guideline are equipment and instrumentation grants, doctoral dissertation grants, student supplement grants, and institutional/individual training grants (for faculty mentors).

13. FAQs Who should sign the Effort Certification Form? The person completing and signing the Effort Certification Form must be someone with first-hand knowledge of the effort expended. This is required to ensure that the effort reporting system reasonably reflects actual effort expended in the various categories during the report period. In general, this is the individual whose effort is being reported. At Case, faculty on sponsored projects will certify their own effort. Non-faculty key and other personnel (including graduate students, post-doctoral fellows, research assistants) will have their effort certified by the department administrator via the PeopleSoft time reporting system.

14. FAQs How often are Effort Certification Forms completed? For schools or colleges within the university that provide faculty with 12-month appointments, Effort Certification Forms are completed semi-annually, based on the fiscal year. The Form for the period from July 1 to December 31 is completed in January of every year. The Form for the period of January 1 through June 30 is completed in July of every year. For schools or colleges that provide faculty with academic year (or 9-month appointments), Effort Certification Forms are completed three times a year, i.e., in the month following the end of fall semester, in the month following the end of spring semester, and in the month following the end of summer semester.

15. On-Line Effort Certification PROCESS

16. On-Line Effort Certification: E-mail to Dept. Admin. From: Eric Cottington Sent: Tuesday, February 28, 2006 5:51 PMTo: Eric CottingtonSubject: Effort Reporting - 7/1/05 - 12/31/05 Effort Reporting: 7/01/05 � 12/31/05 In order for Case to remain in compliance with federal regulations governing sponsored project activities, faculty must certify their effort on these activities at least every six months. To this end, the attached spreadsheet provides the salary allocation detail in PeopleSoft for faculty in your department who have charged salary to sponsored projects from 7/1/05 through 12/31/05.� The effort certification forms for these faculty have been pre-populated with percentages derived from this salary distribution.� At your earliest convenience, please use this information and other information you may have (e.g., practice plan compensation or other sources of compensation) to prepare the effort certification forms in Spiderweb and route them to the affected faculty for their certification.� �� To prepare the forms, go to the following website and enter your Case network ID and password.� Select Effort Reporting from the menu.� You will then see the names of the faculty who need to certify their effort.�� Click on their name to prepare their form. https://addison.ra.cwru.edu/spiderweb/ These forms need to be reviewed and completed by the faculty in your department no later than April 1, 2006.� Your assistance in this effort is greatly appreciated

17. On-Line Effort Certification Website

18. On-Line Effort Certification Website

19. On-Line Effort Certification Website

20. On-Line Effort Certification Form

21. On-Line Effort Certification Form

22. On-Line Effort Certification Definitions

23. On-Line Effort Certification Form

24. On-Line Effort Certification Form

25. On-Line Effort Certification Form

26. On-Line Effort Certification Form

27. On-Line Effort Certification Form

28. On-Line Effort Certification Form

29. On-Line Effort Certification Form

30. On-Line Effort Certification Form

31. On-Line Effort Certification Form

32. On-Line Effort Certification Form

33. On-Line Effort Certification: E-mail to Faculty -----Original Message----- From: Research Administration Sent: Friday, March 10, 2006 2:12 PM To: �pxc5@cwru.edu'; Resadm Send Subject: Effort Certification Form for the period 07/01/05 - 12/31/2005 On-Line Effort Certification Form Case has recently changed its procedures for effort certification. Each faculty member involved with sponsored projects must now certify his or her own effort for specific reporting periods. The purpose of this e-mail is to notify you that an On-Line Effort Certification Form has been prepared by your Department Administrator for you to review and certify. Please go to the following URL to access your effort certification form: http://showcase.case.edu/spiderweb/ Enter your Case ID and password. Under the Compliance section, select Effort Reporting. This will bring up the latest Effort Certification Form for you to review and certify. If you have any questions about the data reported on the form, please contact your Department Administrator. Please do not make any changes without first consulting your Department Administrator. Please complete your review and certification no later than April 1, 2006. More information about Effort Reporting including those to contact with questions can be found at the following URL: http://addison.ra.cwru.edu/research/effort/index.cfm If you believe you have received this e-mail in error, please contact your Department Administrator. Thank you. Eric M. Cottington, Ph.D. Associate Vice President for Research Case Western Reserve University 10900 Euclid Avenue Cleveland, OH 44106-7015 216-368-4515 (phone) 216-368-4679 (fax)

34. Example 1 Faculty member with total compensation below NIH salary cap Case salary distribution by activity for six-month reporting period:

35. On-Line Effort Certification

36. Example If one or more of the sponsored projects started after the beginning of the reporting period, the percent effort based on salary distribution will be different than the percent effort proposed. This can be explained in the comment box on the form. This effort also may not differ significantly, i.e., by 5% or more, from what was proposed anyway. If the percent effort on the Steris grant was not directly charged, the percent effort should be listed in the cost share cell.

37. On-Line Effort Certification

38. Example 2 Faculty member with total compensation above NIH salary cap Case and practice plan salary distribution by activity for six-month reporting period

39. On-Line Effort Certification

40. Example 2 Faculty member with total compensation above NIH salary cap Case and practice plan salary distribution by activity for six-month reporting period

41. Example 2 Since the six-month NIH salary cap would be $90,050, the percent effort directly charged to NIH grant 1 and NIH grant 2 needs to be revised as follows: NIH Grant 1: (.10 x $90,050)/$100,000 = 9% NIH Grant 2: (.20 x $90,050)/$100,000 = 18% The difference between the percent effort listed in the previous table and the percent effort based on the NIH salary cap is cost share.

42. On-Line Effort Certification

43. Next Steps Revise on-line form and process based on pilot test results Assess staffing requirements to administer effort reporting process including training, data integration, analysis and reconciliation and acquire additional resources Implement revised effort reporting system university-wide by the end of February 2006 Integrate Case payroll and clinical/VA compensation so that pre-populated effort certification form is more accurate