April 28, 2011

Effort reporting: federal requirement and university policy

by Anne Krapfl

At risk is a black eye among federal funding agencies and the loss of hundreds of thousands of grant dollars. Those federal agencies require that the work -- or "effort" -- charged to a grant not only is completed, but completed during the time period a researcher receives at least part of his or her salary from the grant.

Iowa State always has adhered to this requirement, with its EASE (Employee Activity Summary of Effort) manual and form. What's different, an outcome of a 2009 internal audit, is a university policy that puts some teeth to the practice. The heart of the new Effort Reporting and Certification policy, which took effect Feb. 1 after a year under development, reads:

University departments are responsible for ensuring that the salaries charged to federal and other sources are allowable, appropriate and reasonable. Departments are also responsible for the timely monitoring of salary allocations to sponsored projects and regular reporting through an effort reporting system ...
Inaccurate, incomplete or untimely effort reporting may result in funding disallowances and lead to disciplinary action and/or other sanctions against the responsible individual.

A new FAQ

Get answers to common questions about effort reporting at Iowa State.

What it means

The university is not telling researchers when to work or how much to work, said director of academic policy and personnel Brenda Behling, noting that the policy deliberately makes no reference to hours in a work week. But all faculty and P&S staff who serve as principal investigators (PIs) on sponsored research are personally responsible to certify the amount of effort they and their employees spend on those research activities.

An individual's paid "effort" always equals 100 percent, regardless of the number of hours worked during a reporting period. With budgeting and payroll encumbrances, researchers with federally sourced grants initially make a best estimate of when the work gets done. And then every six months on an EASE form, they certify that the effort reasonably matches the source of pay for the reporting period.

Behling noted that the flexibility of Iowa State's payroll system to actually pay from separate sources for specific months, weeks or even days supports effort reporting.

"We've heard lots of reasons people don't like this practice," Behling said. "It's a federal requirement per the Office of Management and Budget. It's about being in compliance. We don't want to be in a position of having federal funds disallowed."

Summer coverage

A common practice at Iowa State also happens to be one that doesn't comply with the spirit of effort reporting: B-base (nine-month) faculty whose summer salaries are covered by federal grants. They'll need to charge part of their salaries to the grant during the academic year if that's when the work is done. Behling said it's unlikely that the university will pay higher than 90 percent of an employee's salary from his or her federal grant during any pay period.

This cap builds in a little flexibility to effort reporting, but executive vice president and provost Elizabeth Hoffman asked researchers to be especially mindful of two problematic situations:

  • Making a conference presentation (unrelated to the grant) while receiving salary from the grant
  • (For B-base faculty) Taking personal time away while receiving salary from a grant

To take the guesswork out of effort reporting for their faculty, leaders in the College of Liberal Arts and Sciences developed guidelines, one of which caps an individual's federally funded research at 75 percent of total effort during any summer month (May through August). Exceptions require the dean's approval.

Math professor and department chair Wolfgang Kliemann, who is using the LAS guidelines, expressed empathy for both sides of the issue. Research faculty understandably resent administrative add-ons that consume their time; but grant agencies have the right to set reporting requirements for the work they fund, he said.

"Agencies like NSF are not in the business of supporting every minute of someone's time," he said, noting that no one in the math department has more than two months of grant-funded summer salary.

"At the department level, we need to help our faculty do the right thing -- because they want to do the right thing -- but not overburden them," he said. In some cases, that could involve moving summer (grant) funding into the academic year. Other situations demand less paperwork. Encouraging faculty to rethink their effort projections at the outset and accurately track their grant-covered work days, he said, also achieves the desired outcome: compliance.

Required training

The 2009 university internal audit also recommended mandatory training in effort reporting and certifying for all PIs. Staff in the sponsored programs administration office created a course that will be offered via WebCT beginning in mid-May. The office of the vice president for research and economic development will notify all PIs and co-PIs with federally sourced grants -- an estimated 650 people -- who are required to complete the 25-minute training.

In the future, first-time PIs must complete the training within 60 days of their ISU grant accounts being opened.