Salary Planning & Effort Reporting

Northwestern University Feinberg School of Medicine

Salary Planning & Effort

Reporting

January 24, 2012

What you will expect today

Part I – Salary Planning and Distribution

• Introduction and principles

• Planning for 12-month appointments

• Planning for 9-month appointments

Part II – Effort Reporting

• Introduction and principles

• Effort Certification and commitment

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Part I Presentation Overview

• Introduction and Principles Eric Boberg

• Putting Principles to Practice in 12-month appointments Michelle Grana

• Planning for 9-month appointments and Impact of Practice Marsha McClellan

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Principals of Salary PlanningEric Boberg, PhD

Executive Director for Research

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Get it right the first time‘Cause that's the main thingCan't afford to let it passGet it right the next timeThat's not the same thingIt’s much, MUCH Harder!

With apologies to Billy Joel

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Measure Twice, Cut Once…

• Planning begins with pre-award budget

• Adjust/finalize plan with awarded budget

• When planning well, effort reporting is simple and seamless

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Principles & PoliciesFrom NIH Grants Policy Statement (10/10):

Salary and wage amounts charged to grant-supported projects for personal services must be based on an adequate payroll distribution system that documents such distribution in accordance with applicable Federal Cost Principles and consistently applied institutional policy and practices.

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Key Principles

• Salary tracks with effort, but is not always equivalent

• Institutional base salary (and effort) includes both NU and NMFF

• Cost sharing (including over the cap salary) must come from non-sponsored source

• Identify cost-sharing sources early

Key Principles

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• A PI’s career is NOT all one big project; effort must be allocated to specific projects/activities

• Not all faculty activities can come from extramural funding:

• Instruction

• Administration

• Grant writing (usually…)

• No PI should ever be 100% funded

Key Principles

• When things go wrong…

• You can’t just use up the money

• Salary changes need scientific justification

• Review systems may be frustrating, but they are there to ensure compliance

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Putting Principles to PracticeMichelle Grana

Buehler Center on Aging, Health and Society

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Putting Principles to Practice

• Pre-award planning

• Post-award planning

• Dual appointments

• Cost sharing

• Practical solutions

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Putting Principles to Practice

Pre-award Planning: Consider proposed commitment

• Other support

• Other commitmentso clinical, teaching, administrative, external

commitments (VA)

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Putting Principles to PracticePost-award Planning:

• Consider proposed commitment (again)

• Consider any changes from pre-award budget

• Reduced award?• Change in personnel?• Change in start date?• Change in salary?

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A PI is funded for a new award from the NIH. Through routine budget cutbacks, the NIH has reduced the award by 30%. The PI has insisted he can still meet the all of the study aims within the reduced award budget.

Do you need to do anything?

What is the research administrator’s role in advising PI’s of appropriate steps?

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Further complications…

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• Dual (NU+NMFF) appointments

• Cost Sharing

NU & NMFF Appointments

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• NU + NMFF = Base Salary

• Institutional base salary represents the combined salary from both NU and NMFF

• Paid by NU under common paymaster

• Number of person months represents NU effort in relation to professional effort encompassed by the dual NU and NMFF appointments


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• % NMFF appointment is based on clinical commitment

Faculty appointment letter; other documentation of clinical commitment (clinic notes, clinical billing)

• 2 half-days clinic = 20% NMFF appointment

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• NU appointment represents total % effort available for research, teaching, administrative duties

• NMFF salary represents compensation for clinical activities and may NOT be used in payroll distribution to support cost sharing on grants

Cost Sharing

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• Cost sharing occurs when a cost specifically benefits a sponsored project but is not charged to that project.

• Can be mandatory (matching funds) or voluntary (NIH cap gap)

• Most common type of cost sharing on the Chicago campus is the NIH statutory cap and the salary limitation on NIH career (K) awards

Voluntary Committed Cost Sharing: Cap Gap

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• NIH statutory cap - tied to Executive Level II of the Federal Executive Pay scale

• K-award salary cap - typically limited to only $75K allowable salary recovery (for min. 75% effort)

• Commitments must be met and tracked for sponsor verification in the University's records. (Use your 192’s!)

Practical SolutionsWorksheets for 12-month and 9-month appointments available at ASRSP website

• Plan faculty salary distribution among grant and non-grant chart strings

• Track cost sharing commitments

• Track effort commitments on sponsored projects

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12-Month Tool

• Includes instruction sheet

• Unprotected Excel worksheet – edit to fit needs

• Summarizes effort @ end of each quarter

• Provides guidance on NU % salary based on % NMFF appointment

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Instructions - Use

• Complete specific instructions available in excel file

• Organized by three chart string categories:

Sponsored projects

Non-sponsored chart strings

Associated cost sharing chart strings

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Features of the Tool• Worksheet auto-calculates monthly NMFF

salary

• Worksheet auto-calculates monthly % NU salary based on % committed effort

• Worksheet auto-calculates and tracks effort reporting and cost sharing

• Math checks built in (“TRUE”) track monthly totals and also to confirm % base salary + % cost share = % committed effort

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12-Month Tool

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12-Month Tool

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12-Month Tool

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12-Month Tool

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12-Month Tool

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Summary Pages• Provides for both quarterly and annual

summaries

• Tracks annualized effort based on number of award months in fiscal year

• Use for department budget projections

• Use for projecting future sponsored awards

• Auto-calculates difference between annualized effort and committed effort

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Year-end summary

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Sample Questions

PI’s often add effort/salary for employees if they see there is money left. Is this just a matter of continually informing them that they are not to escalate expenses near the end of a grant or is there something else we can use to encourage them not to follow this practice? Also, this is often retroactive which involves 90-day letters.

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Locating the answers…• COME TO THE EXPENSE MONITORING SESSION ON

TUESDAY, FEBRUARY 7TH FROM 1PM-4PM

• Meet with PI’s regularly regarding budget balance and projections

• Monitor funds so that there is not a large balance or deficit at the end of the project

• Know what the non-salary funds are planned to be used for

• If the budget changes from what was planned pre-award, alert your PI that you need to revise the planned projections for the account (ie. S/he decides not to hire a support staff or it doesn’t happen until 6 months into the project. Is this rebudgeting allowable? How will it be accomplished?

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12-Month Planning Summary…When?

• Pre-award

• Post-award

Special considerations?

• Dual appointments

• Cost sharing

How?

• Practical solutions

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Planning for 9-month appointments

and Impact of Planning

Marsha McClellan

Director of Financial Management

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9-month Faculty

• Appointment –Ph.Ds

• Investigator track/Tenure eligible

• 9-month base salary

• Salary cap

• Research quarter

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9-month Base

• 9-month base is guaranteed

• Faculty monthly earnings is 1/9th of base

• Faculty monthly pay is 1/12th of base

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9-month Base

• To determine salary charged to grants, two pieces of information are needed:

•Academic year effort (AY)•Summer month effort (SM)

• 9-month base charged directly in FASIS

• FASIS will allow up to 75% of monthly earnings to be directly charged in a given month.

• Effort in excess of 75% is charged outside of FASIS via a salary distribution adjustment (SDA).

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9-month Base

• To calculate the dollar amount charged to grants each month, two pieces of data are used.

•Monthly earnings (1/9th)•Academic year effort (AY)

• To calculate the percent entered in FASIS deployment, two pieces of data are used.

•The dollar amount calculated above•Monthly pay (1/12th)

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Salary Cap

• NIH Cap limits the amount of salary that can be charged to federal awards ($179,700 or $14,975 per month).

• To calculate the dollar amount charged to grants when Cap is in play, two pieces of data are used.

•Monthly cap ($14,975)•Academic year effort (AY)

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Salary Cap• To calculate the percent entered in FASIS deployment

when Cap is in play, two pieces of data are used.

•The dollar amount calculated above•Monthly pay (1/12th)

• Salary in excess of NIH Cap is cost shared on a 192 fund. Some non-federal sponsors also use the NIH Cap to limit the amount of salary charged (e.g. JDRF)

• Other salary restrictions may apply to non-federal awards. For example, a sponsor may require a minimum of 15% effort to charge salary. Effort less than 15% must be cost shared.

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9 Month Salary Calculation Template

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References and Templates

www.northwestern.edu/coststudies/effort.html

Click here to proceed (Northwestern Net Id and Password are required to access this page).

http://www.northwestern.edu/coststudies/secure-docs/effortreference.html

Research Quarter

• Research quarter payments are made using the Summer/Research Quarter Salary Request Form.

• To calculate the dollar amount charged to grants, two pieces of data are used.

•Monthly earnings (1/9th) or monthly cap•Summer month effort (SM)

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Forms-Where Do I get Them?• Summer Salary Forms –Found under Human

Resources- Payroll-Administrator’s Payroll Payment forms website http://www.northwestern.edu/hr/payroll/administratorpayments.html.

• Also under Med Finance’s website

• SDA Forms-Salary Direct Charging form for 9 month faculty- HR website http://www.northwestern.edu/hr/payroll/administratorinfo.html, under Forms

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http://www.northwestern.edu/hr/payroll/administratorpayments.html



“Pseudo” 12 Month Appts.• Faculty with 9-month appointments can be treated as if

they have 12-month appointments in FASIS and grant applications if the department GUARANTEES full 12-month salary for a defined period of time.

• Allows you to use 12-month salary in grant applications.

• Simplifies Effort Reporting.

• Can be done with both tenured and tenure-eligible faculty.

• Must pay full 12-month salary regardless of grant funding.

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Cost TransfersWhat is a cost transfer?

–A cost transfer is the assignment of an expense or expenditure (charge) to a federally or non-federally funded account that was initially recorded in another account.

–A-21 regulations: “…any costs allocable to a particular sponsored agreement under the standards provided in this Circular may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience.”47

Transfers That Increase Audit Risk**Red Flags**

Transfers in the last month of the award or after the award has ended

• Transfers of costs in round numbers

• Transfers without a full detailed explanation

• Transfer to or between sponsored projects

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Cost Transfers Policies & Procedures1. Cost transfers over 1 year from the original transaction date will not

be accepted unless it benefits the sponsor (credits the sponsored

projects).

2. Cost transfers must be supported by timely certified effort reports. If

the certification is over 6 months delinquent past the last date of the

reporting period, the cost transfer may not be accepted.

3. Certified effort must be greater than or equal to the salary charged to

the same sponsored project per effort reporting period. To review the

certified but not charged (cost sharing) amounts, refer to the Cost

Sharing report via ERS -> CERT -> Reporting.49

Cost Transfers Policies & Procedures-Cont.

4. Submit the 90-day justification memo with complete responses to the questions and appropriate signatures. Copies of certified effort reports need to be attached to the 90-day justification for the Dean’s office review.

5. Complete the SDA or 90-day journal with appropriate signatures.

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Where Are My 90 Day Journals?• 90 day salary journals take time to get

processed.

• They require at least 3 to 4 approvals before arriving at Payroll.

• What approvals are required?

• What is the approval workflow for 90 day journals?

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90 Day Payroll Journal Approval Workflow

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The Perfect 90 Day Journal• Never having to do a 90 day journal is the perfect

journal!

• To avoid 90 day salary journals, set up pre-spending chart strings.

• If a salary cost transfer is required make sure that the journals are completed correctly and have all supporting documentation.

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90 Day Justification Memo

Examples of answers to the 90 day memo questions that you should never use:

• I needed to have the expenses match the grant budget.

• Needed to park the expenses somewhere.

• Wanted to use up all the money….Really????

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Poor Planning = Loss • Waiting too long to submit 90 day salary journals-not

approved because they are too old.

• The grant closed and a final invoice has been submitted- Can’t spend the remaining balance.

• Grant is overcharged and must be covered by non-sponsored dollars.

• Make sure that the salary expenses that are to be cost shared are charged to a 192 chart string-do not put them on a regular non-sponsored chart string.

• Be proactive instead of reactive.55

References• Effort Reporting & 90-day Cost Transfer Checklist

http://www.northwestern.edu/asrsp/docs/Effort_checklist.pdf

• ORI Training Materials (including Effort Reporting 101) Download:

http://www.research.northwestern.edu/guide/training

(Click on Research Administration Training Seminar Materials)

• Effort Reporting System (ERS) Logon Page:

https://ersweb.itcs.northwestern.edu/GenericERS

*Note: URLs are case-sensitive56

Break/Questions

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Part II: Effort Reporting

Part II Presentation Overview

• Why does effort reporting take so much effort? Eric Boberg

• Effort Certification & Commitment FSM Workshop Jennifer Wei

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Why do we care about effort?

Required by Federal regulation

• OMB Circular A-21, section J.10 http://www.whitehouse.gov/omb/circulars_a021_2004#j

Documents that effort commitments have been met• Paid effort• Mandatory and voluntary committed cost share

Provides support for salary charged to grants & contracts• Labor ~= 75% of direct research costs

http://www.whitehouse.gov/omb/circulars_a021_2004

http://www.whitehouse.gov/omb/circulars_a021_2004

Why is Effort Reporting Especially Tough in Medical Schools?

• No timesheets

• Inconsistent # of hours

• Varying schedules

• Differing relationships between university, practice plan, VA, etc.

• Research and clinical care can overlap

• Many faculty don’t really care!

What is 100% effort?It is the individual faculty member’s effort required to

meet the contracted obligations.

Usually described in appointment letter

Delineates allocation of time

TEACHING

ADMIN

RESEARCH

CLINIC

SERVICE

GRANT WRITING

STUDY SECTIONS

OUTSIDE CONSULTING

Institutional Base Salary (IBS)

Annual compensation

Paid appointment(s) including NU, NMFF, & chair/center director

Additional Points about IBS: Defined in appointment letter Consistent with the definition of 100% effort Salary cap may apply by certain agencies

Is NMFF salary included in IBS?

YES, because it is:

1) Guaranteed by the university

2) Reported on the university's appointment form and paid by the university

3) Included and accounted for in the university's effort reports

Why Include NMFF Salary in IBS?

Common pay master

Included in both Proposal Submission and Effort Reporting

Allows easier changes in effort and charging salary during year as grants begin and end

You cannot give a raise (i.e. increase university salary) just because someone got a grant

What About the VA?

At NU, VA salary is EXCLUDED from IBS and 100% effort

Separate job, not controlled by University

VA salary is not guaranteed

Language in salary letters must be clear

What Else is Excluded from IBS?

Outside consulting (1 day/week per NU policy)

• Private Industry• Speaking honoraria• NIH or other Study Sections

The K Award Blues

Usually require 75% effort

The K Award BluesK awards have $100,000 salary

cap

$100,000 salary can be 75% funded and fit under the cap

$100K TOTAL

The K Award Blues$100K cap may not cover 75% of

the salary

With a $200,000 salary, cap only covers 1/2 of 75% of salary

$200K TOTAL

More K Award Blues• Effort on other grants can sometimes be “subsumed” in K

effort;

• Unpaid commitment on another NIH grant in the same field of study (approved by the sponsor); salary paid by the K

• Must review terms/conditions of the K award

• During last 2 years of K, may be PI on a NIH project (with approval)

• Effort on non-federal grants usually excluded

• Constant pressure in some specialties for MD’s to do more clinical work

What About Clinical Trials?

CLINICAL CARE RESEARCH

You CANNOT double-dip (i.e. bill for clinical care and then charge effort to the grant/trial).

Some level of effort should be assigned to clinical trial activity, even if it is not committed or directly paid.

No clear answers

When % Effort ≠ % Salary

Salary above cap•K cap = $100,000•Other NIH cap currently $179,700•Both count as cost sharing

Voluntary Committed Cost Share (donated effort)

Cost sharing must be accounted for, and funding source identified at time of application

•No PI should be 100% funded

•There is ALWAYS some NU effort that must be paid from non-sponsored accounts

•Do not use unreasonable number of hours per week to make effort numbers work

•Clinic schedules may be discoverable

•Effort may vary within a certification period as long as overall percentages are maintained

•Even when regulations are unclear or contradictory, you need a plausible, defensible story for how effort was arrived at

•NIH and DOJ may disagree on interpretation; you cannot rely on the “The Project Officer said it was OK” defense

Rules of Thumb


Effort Certification & Commitment

Jennifer Wei

Director of Cost Studies & Effort ReportingOffice of Financial Operations

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Risk of Non-compliance…Institution Period Alleged Issues Settlement

Yale Univ 2007 Cost transfers; summer salary $7.6 million

Univ of Massachusetts Medical School

2006 Cost transfers; unsupported labor charges $24K; triggered Yale & Roger Williams Hospital audits

California Institute of Technology

2006 Timeliness; NSF grants N/A

Howard Univ 2006 Cost sharing on NSF grants N/A

Univ of Pennsylvania 2006/ NSF Timeliness; cost transfers $3.3 million

Univ of Alabama, Birmingham

2005 Research work overstated; Medicare billed for research

$3.4 million

Harvard Univ 2004 Billed for sal & expenses unrelated to federal grants

$2.4 million

Johns Hopkins Univ 2004/ NIH Faculty time & effort overstated $2.6 million

Florida International 2004 Cost transfers and direct costs $11.5 million

Northwestern 2003 Institutional base salary (NMFF-NU); K awards; Assigned certifier

$5.5 million

Northwestern Findings in 2003

• $5.5 million

• Institutional Base Salary presented in Proposal Submission (pre-award) and Effort Certification (post-award)

– NU + NMFF salaries

• Career (K) awards effort -> 75%

• Appropriate certifier

“After-the-Fact” Effort Reporting Practice

Schedule of Effort Reporting

Effort reports are generated 4 times a year (on a quarterly basis)

• Calendar:Qtr Period Effort Forms Available

Q 1 Sept to Nov January

Q 2 Dec to Feb March

Q 3 Mar to May July

Q 4 June to Aug October

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Follow-up Process of Effort Certification

Timeframe Action

Day 0 Effort Reports available

Week 4 1. Effort Report Initial due (~30 days from Day 0)

Week 7 2. Delinquency sent to Chair

Week 10 3. Delinquency sent to Dean’s Office

Week 14 4. Final Due Date;Delinquency sent to Provost / VPR

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Key Principle of Effort Reporting

Principle In Practice

In a given quarter, the certified % of effort must be equal to or more than the % of salary charged and cost-shared to the grant

If salary charges are greater than effort expended, salary must be adjusted per Quarter

Effort commitments (paid and cost shared effort) should be met within the Budget Period

More on Cost Shared Effort

• Mandatory Cost Share (MCS)

- Fund 191 per Dept/Project

• Voluntary Committed Cost Share (VCCS)

- Fund 192 per Dept/Project

- Salary over the cap difference

• Voluntary Uncommitted Cost Share

– DO NOT need to be tracked

Effort Confirmation on a Quarterly Basis

Confirming Effort is the process of verifying that salary (payroll) charged to the project does not exceed actual effort expended.

Payroll % Effort %

Per Quarter

Payroll exceeds Effort after the Certifier attested his/her Effort expended on the project for the reporting period

Payroll %

Effort %

The sponsored account should be credited (refunded) so the sponsor is not overcharged

Special terms and conditions should be reviewed on a case by case basis (i.e. NIH career awards)

Per Quarter

Effort exceeds Payroll after the Certifier attested his/her Effort expended on the project for the reporting period

Effort %

Payroll %

Provided there is available budget and approved by the PI, the additional effort may be charged to the project.

If the project budget cannot cover the extra effort expended, the excess effort must be charged to a non-sponsored source such as a departmental account. This is called Cost Sharing.

Per Quarter

Payroll Charges vs. Certified Effort

Charges to the sponsored accounts (payroll %) should Not be higher than the Certified Effort %

Example: % Under the Certified Effort % generally should not be lower the Payroll %

Key Topics

Who should certify effort?•Faculty must certify their own effort certifications and their research staff’s. BAs and RAs cannot certify effort for the department

Safeguard NetID and Password:•Never give NetID and password to others

Reporting effort must be consistent among all reports: •Effort reports

•Progress reports

•Current pending & support pages (JIT submission)

•Financial status reports87

Key Topics

What Effort Related Issues do we check during Account Close-out?

•Effort certified?

•Payroll charges against effort certified

•NIH salary cap / cost share

•Certified effort on Career awards

•Anything else we are aware

• If you receive a notice from the Effort team, please address the issue(s) as soon as possible

• If you never receive a notice from the Effort team:

THANK YOU!!!

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Question #1

When is it too late in the effort reporting quarter to have a certified effort form dropped for corrections/changes?

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Question #1

•When is it too late in the effort reporting quarter to have a certified effort form dropped for corrections/changes?

Response:

•The current effort form can be accessed again by the Certifier as long as it has not been post reviewed

•ERS Logon -> Click on Cert Menu option -> Click on the current reporting period

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Question #2

If waiting on a late SDA or payroll change, is it better to go ahead and have the PI certify an effort form by putting in cost shared effort in place of the SDA/payroll and then correct at post-review or have the form dropped and re-certified correctly OR tell the PI to wait (past the effort certification deadline) in order to certify effort that appropriately reflects the SDA or payroll? Where is the bigger audit risk?

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Response to Question 2:• Please Do Not wait till it is past the deadline to

have effort certified

• Faculty have No chance to certify Effort before the deadline if Administrator waits for cost transfer and not complete pre-review

• Both Late/missing effort certification and late/ inappropriate cost transfers are major risks... However, Effort should be driving the Payroll distribution

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Question #3

Several of our faculty members are listed on industry clinical trials but no other sponsored projects. As there is 0% effort, they only end up certifying for their non-sponsored portion and have asked me frequently why they are certifying. Would you recommend that they be removed from the ERS system?

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Question #3 Response

•Key personnel are listed per sponsored project, which will trigger ERS to generate an effort report

•Effort forms are still needed to jog the memory when effort was expended

•If the clinical trials are not listed under the Sponsored Account Session, the effort can be entered on the second screen (see the next slide)

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If the clinical trials are not listed on the effort form, enter the effort in the Last university effort category

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Question #4

For the odd start dates, how can we correctly determine the first quarter of effort for that grant? For example, one of my PIs has his start date listed as 05-21-11 on his NOGA and he’s at 30% effort. He’s been at 30% effort, but not for the full 31 days of May, so how to calculate?

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•Chicago Q3 is from 3/1 to 5/31, below is an estimate:

•Estimate: his effort is 3 to 4% on this project for Q3

-March: 0% Effort

-April: 0% Effort

-May: 7 days out of 21 days *30% = ~10% (not exact)

•Next Quarter, effort commitment is 30% as it will be 30% for each month

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Question #5

What is 100% effort for someone with a 50% faculty appointment at NU? For a contributed services faculty appointment at NU? Can a contributed services faculty member apply for a grant at NU with salary? How does a contributed services faculty member certify effort on a grant at NU? Is it required?

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•100% Effort : Estimated total time spent on University activities defined by the Appointment

- May not mean 12 months/Year (depending on appointment)

- May not mean 3 months/Quarter (i.e. floating summer)

•Contributed Services Appointment at FSM

- Generally, No salary from NU

- ERS does not generate Effort reports since NO salary

- If Salary is required, potential option: Subcontract

- If listed as PI or senior researcher, a paper effort report should be generated as Effort is required

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Effort Reporting Training SessionsEffort 101 (4 times a year)

• Effort 101 is required to gain access to the Effort Reporting System (ERS)

• Federal regulations, NU policies & Procedures, Audit updates, key compliance issues, etc.

• Hands-on training (lab)

- Pre Review / Certification / Post Review

- Assignment & Reporting

Faculty Effort Reporting Session per Dept

• Audience: Faculty

• On demand as requested by the department (let us know!)

Brown Bag Sessions

• ERS system update, Reports overview, Others as requested

One-on-one assistance

• Contact your Effort coordinator

Have you attended these classes?

Trainings Classes Available for Effort Administrators:

1. Attend the Research Administration Training Seminar offered by Office of Research Integrity (ORI) prior to attending Effort 101

2. Attend Effort 101 (contact your Effort Coordinator)

3. In addition to Effort 101, the following classes are strongly recommended before or soon after Effort 101:

• FASIS

- HRS101: FASIS Lookup Training

- HRS102: FASIS Deployed Funding

- HRS103: FASIS Temp Administration

- http://www.northwestern.edu/hr/hris/training/index.html

• Project Café NUFinancials/InfoEd class

- FMS505: Managing Sponsored Projects

- http://cafe.northwestern.edu/cafe/calendar/[email protected]

http://www.northwestern.edu/hr/hris/training/index.html

http://cafe.northwestern.edu/cafe/calendar/[email protected]

http://cafe.northwestern.edu/cafe/calendar/[email protected]

Effort Reporting System Support & Project Contact

NetID and password support

• 1-4357 (NUIT)

• NetID and Password Security:

http://www.it.northwestern.edu/netid/security.html

Effort Reporting Operational Support

• Jennifer Wei (7-2473)- Tina Mete (Chicago/Evanston, 1-6755)

- Erin Farlow (Chicago, 3-0323)

That’s all Folks!

Questions?

Suggestions?

Comments?

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