This policy describes the University's commitment to educate, implement and manage its processes and procedures related to Effort Reporting. The University is committed to ensuring that effort expended on sponsored project agreements is appropriately documented, that salaries and wages charged to sponsored agreements reasonably reflect the effort expended on those sponsored projects, that effort is certified by authorized personnel in a timely manner, and that effort certifications comply with sponsor requirements and federal regulations.
This policy applies to all Drexel University Faculty, Professional Staff Members, including those affiliated with a collective bargaining unit that expend effort on sponsored projects.
The implementation of this policy is the responsibility of the Office of the Comptroller.
- ADMINISTRATIVE OVERSIGHT
The Executive Vice President, Treasurer and COO is the Drexel University official responsible for the administration of this policy.
The mission of Drexel University (the "University") is to promote public good by creating, sharing, and applying knowledge in the public interest. This mission is accomplished in many ways, including but not limited to, conducting inquiry-based and use-inspired research and engaging in creative and scholarly activities.
The University, which includes its faculty, staff, students and administrators, incentivizes its community members to participate in research, creative, and scholarly projects via progressive policies that, for example, encourage and reward research and scholarship in tenure and promotion policies, reward translational research activities through royalty revenue sharing, and allow time away from the campus for consulting.
Since effort reports are a means of documenting and supporting salary charges to sponsored projects as well as other University responsibilities, it is essential that this data be based on reasonable estimates of actual effort expended on each sponsored project and non-sponsored or University funded accounts.
Drexel University's Effort Reporting Policy ensures that the University complies with the Office of Management and Budget Circular Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards ('Uniform Guidance') as well as other sponsor requirements for certifying that effort expended on a project is at least commensurate with the salary charged against the sponsored project. The Uniform Guidance Subpart E § 200.430 (hereafter referred to Uniform Guidance) contains the federal regulatory requirements for acceptable methods of certifying time worked on all federally sponsored projects. It is the University's policy to comply with Uniform Guidance requirements for certifying time spent working on all sponsored projects. As a result of the federal regulatory requirements contained in Uniform Guidance, the University has implemented an after-the-fact web based Banner Effort Reporting System in conjunction with Banner Labor Redistributions as a means of recording, reviewing and certifying that direct labor charges to sponsored projects are reasonable and reflect actual work performed. Effort reporting documents the proportion of time an eligible individual spends on all University activities as a percent of total effort.
Affiliated Institutional Activity: Relates to services performed under terms of a non-sponsored agreement with an affiliated institution.
Banner Effort Reporting System: A web-based application that is part of the University's ERP (Enterprise Resource Planning) system which enables the University to meet the reporting requirements of Uniform Guidance. The application calculates the distribution of effort for all employees paid from any sponsored project, captures certification electronically, and utilizes the Banner Labor Redistribution module to provides a means of correcting and applying retroactive adjustments.
Certifier: An individual who has first-hand knowledge of work performed on specific projects, and who certifies the effort reports attesting to the fact that the work was performed.
Clinical Activity: Refers to the treatment of clinical patients. It includes teaching or supervising residents, interns, and clinical personnel when such teaching effort does not properly belong in the instruction category. It also includes administrative and support services that solely benefit clinical patient care.
Department Administration: Refers to administrative activities in academic dean's offices, departments, divisions, and organized research units that jointly benefit all department activities. Department administration is supported by University funds and is not charged directly to sponsored projects. Examples include: time on academic and research committees, such as human subject review, bio-safety, animal care, and academic planning, administering personnel policies, interviewing and hiring, planning programs, and preparing sponsored proposals.
Effort: Defined as the amount of time spent on a particular activity. This includes the total of all activities associated with a faculty or professional staff member's institutional base salary in which they are engaged in as part of their employment obligation for the university – your "full workload" or "total professional effort" is defined as 100% effort.
Effort Distribution: A distribution that reflects the percentage breakdown of an individual's time actually spent on activities, regardless of where the salary is charged.
Effort Reporting:Method used to confirm to sponsors that the effort spent on a sponsored agreement reasonably reflects the salary and wages charged to that agreement. An effort report is an after-the-fact reporting of activities for which the employee was compensated by the institution.
Faculty Member: Defined as an individual employed by Drexel University in a tenured, tenure-track or non-tenured track position who teaches and/or performs research at any college, school, center or institute within the University. A Faculty Member also is deemed to be exempt under the provisions of the Fair Labor Standards Act (FLSA) and/or applicable state law.
Incidental Effort: Effort in addition to University effort, for which it is customary to accept extra compensation (e.g., honorariums, intra-university consulting, "pay in excess" activities, etc.). Incidental effort is not documented in the Banner Effort Reporting System.
Institutional Base Salary (IBS): The salary that corresponds to the time spent on University professional activities such as research, instruction, clinical activities, and administrative activities and includes any department chair or program director's stipend. This definition of IBS excludes salary or pay for other professional activities such as consulting services, bonuses, and other one-time payments.
Instruction and Other Academic Activity: Refers to the University teaching and training mission. It includes teaching and training activity where the employee is the instructor, whether for credit or not, lectures, independent study, thesis preparation supervision, academic advising, curriculum development, seminar/workshop presentations, and non-sponsored research and scholarly activities, unless there is separate budgeting and accounting for (as in DARE and other seed funding).
Labor Distribution: A distribution that reflects the activities to which salary is charged in the payroll system.
Non-Institutional effort: Effort performed outside the context of the individual's University employment contract. It is not a part of University effort and is not covered by the Banner Effort Reporting System. Employees subject to effort reporting must notify the Office of Research (OR) when performing non-institutional activities for which the University does not receive compensation (i.e. via a purchased service agreement).
Other Institutional Activity: Relates to University activities that are not appropriately reported under any other category. Examples include: institutional advancement, service centers, alumni relations, athletics, museums, theatres and concerts.
Professional Staff Member: Defined as an individual employed in any non-faculty category by Drexel University, including an individual who is deemed to be either exempt or non-exempt under the provisions of the Fair Labor Standards Act (FLSA) and/or applicable state law.
Sponsored Projects:Projects that support research, creative, and scholarly activities funded by sponsors whose funds are administered by the University, or are projects that support research involving humans or animals as research subjects.
Sponsored Project Effort:Effort related to sponsored research, sponsored instruction and training, and other sponsored activities. The Banner Effort Reporting System identifies each sponsored project separately with the commensurate percent effort. Mandatory cost sharing activities must be allocated to the cost sharing fund related to the sponsored project they support. Mandatory cost sharing is effort associated with an identifiable sponsored agreement, which is not sponsor reimbursed and is funded by the University. Sponsored project effort also includes University-funded research (e.g. DARE and other seed funding) that is separately budgeted and accounted for. This category does not include start-up funds or general department research.
University Effort: Relates to work required to fulfill an individual's employment obligation to the University. It may include both sponsored and non-sponsored activities. University effort does not include incidental activities for which no additional compensation is received (e.g. editing a technical paper for a colleague), external consulting, volunteer or uncompensated effort, non-university authorized research effort, or professional services provided outside the institution for non-university compensation.
Uniform Guidance Subpart E §200.430: Federal government document which contains cost principles and other requirements for colleges and universities. This document mandates that Colleges and Universities maintain an effort reporting system that meets the requirements for acceptable methods of certifying time worked on federally sponsored projects
- POLICY STATEMENT
The University is committed to ensuring that effort expended on sponsored agreements is appropriately documented, that salaries and wages charged to sponsored agreements reasonably reflect the effort expended on those agreements, that effort is certified by authorized personnel in a timely manner, and that effort certifications comply with sponsor requirements and federal regulations.
The Policy requires that University Personnel, who allocate salaries and wages to sponsored agreements/projects, comply with the federal regulations contained in Uniform Guidance by recording, reviewing and certifying the effort expended on those agreements. That effort is required to be certified by authorized personnel in a timely manner, and comply with sponsor requirements and federal regulations.
The University requires quarterly certification of exempt and non-exempt employee effort certification forms. The quarterly effort periods are: January – March, April – June, July – September, and October – December. Per the Uniform Guidance, "The non-Federal entity's system of internal controls includes processes to review after-the-fact interim charges made to a Federal awards based on budget estimates. All necessary adjustments must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated." To ensure compliance with this requirement, the certification of all effort forms must be completed within 90 days of the end of the effort period and the submission of related cost transfers must be completed by the earlier of (a) within 90 days of the end of the effort period or (b) within 60 days following the end of the award. This requires that all salary cost transfers are processed within this period. In the case that the final invoice and/or report is due earlier than 90 days, the salary costs will be required to be reflected on the sponsored project at an earlier date in order to allow time for final invoicing and/or reporting.
If a Principal Investigator (PI) or other required staff or graduate student fails to comply with this policy; the University may suspend or withdraw proposal submissions for the PI and may suspend work on a sponsored project. Non-compliance may also lead to other disciplinary actions in accordance with University policies.
- POLICY IMPLEMENTATION
The Executive Vice President, COO and Treasurer administers this policy in collaboration with the Senior Vice President for Research, ensuring it remains consistent with federal regulations, and has primary responsibility for overseeing the process for managing conflicts of interest in sponsored projects.
- EFFECTIVE DATE
This policy on Effort Reporting is retroactive to January 1, 2016.