1. Introduction
Based on the new regulations of the Uniform Guidance (UG), The University Corporation is implementing a new, streamlined process for faculty effort reporting.
The new process eliminates the previously used effort report certification by faculty members. In its place, the new process uses data from the recently created campus-wide ‘Special Pay’ system, and additional systems to track effort for faculty reimbursed time and cost sharing.
The objective of the new procedure is to streamline processes and reduce the administrative burden for Principal Investigators and Research Administrators.
2. Background
Effort reporting is designed to substantiate time spent by employees whose compensation is charged to federal funds.
While previous regulations under circular A-21 were prescriptive with regard to the method, with the implementation of the new Uniform Guidance (UG) 2 CFR 200 the Office of Management and Budget (OMB) has relaxed the requirements for effort reporting.
The new primary focus of UG regulations are the existence of strong internal controls to ensure that time is charged to grants appropriately, while at the same time providing more flexibility in the design of the process.
Regulations related to effort reporting are primarily located in section 2 CFR 200.430.
At TUC, non-faculty effort for hourly employees is tracked via timesheets and for salaried employees via attendance reports. The new procedures impact exclusively the tracking of effort for faculty members.
3. Elements
Faculty Effort is tracked for the following categories:
- Direct faculty pay
- Release time paid from the grant
- Release time as part of cost sharing
4. Modification of Effort Report System
TUC will transition from its previous system of generating individual effort reports for each faculty members based on a percentage basis, to a new system based on data readily available in the campus-wide additional pay system and some few additional tracking sheets.
5. Procedure
5.1 Direct Faculty Pay
Beginning with the fall semester of 2016, CSUN introduced a campus-wide Special Pay system through which all additional pay to faculty members must be processed. This includes payments from sponsored programs administered by TUC. The Special Pay system tracks time effort that is made for each payment, detailed in a fraction of one hundred (.00). As part of the new Additional Pay System, faculty members are required to certify that the actual effort has been committed before any payments are made.
TUC will collect the effort data from the ‘Special Pay’ system and generate reports sorted by faculty member and by project. These reports represent the effort report for direct faculty pay.
5.2 Release Time Paid from the Grant
TUC will maintain an Excel based spreadsheet listing the release time paid from grants administered by TUC.
TUC will collect data on release time paid from the Detailed Trial Balance (DTB) - a General Ledger based detailed project expenditure report. This data is based on the invoicing for release time by the university. The invoicing process involves approvals by the Principal Investigator and college Manager of Academic Resources (MAR) to ensure that the release time has actually been granted and is related to a specific project.
Release time payments are converted into effort measured in days (.00) and sorted by faculty member and by project. This report represent the effort report for release time paid from grants.
5.3 Release Time as Part of Cost Sharing
TUC will maintain an Excel based spreadsheet listing the release time provided to faculty as part of cost sharing projects.
TUC will collect the data from the relevant cost share reports, submitted and certified by the Managers of Academic Resources and maintained at TUC.
The release time payments are converted into effort measured in days (.00) and sorted by faculty member and by project. This report represent the effort report for release time as part of cost sharing.
6. Frequency
Effort reports described in section 5 will be prepared and maintained for each of the following pay periods:
- Fall Semester
- Winter Break
- Spring Semester (including Spring Break)
- Summer Break
7. Notification of the University
After the completion of the time and effort reporting for a particular period, the following contacts at the University will receive an electronic copy of the report:
- Office of Research and Sponsored Projects (ORSP)
- Faculty Personnel & Compensation Programs (Faculty Affairs)
8. Applicability
This procedure is applicable to any contract or grant for which funds are received from a federal agency or where TUC is the sub-recipients of federal funds. This procedure may also apply to any contract or grant from which funds are received from a state agency that uses federal cost principles.
9. Record Retention
The forms must be retained in the project files or office for audit purposes and should be available for inspection in accordance with relevant guidelines.
10. Roles & Responsibilities
10.1 The University Corporation-Sponsored Programs
a) Additional Pay
- Ensure that all additional pay for sponsored programs are processed through the ‘Special Pay’ system;
- On demand/request, gather effort information related to a specific project;
b) Release Time
- Collect all information related to release time from the DTB in a project;
- Convert reimbursement for release time into effort;
- Within 120 days after the end of the reporting period, update and maintain Excel spreadsheet organized by project regarding effort provided through release time;
c) Release Time for Cost Sharing
- Collect all information related to release time for cost sharing from the colleges (MAR)
- Convert information into effort;
- Within 120 days after the end of the reporting period, update and maintain Excel spreadsheet organized by project regarding effort provided through release time for cost sharing;
10.2 Principal Investigator
a) Additional Pay
- Submit all requests for additional pay through the campus-wide ‘Special Pay’ system;
- As part of the payment request for additional pay in the ‘Special Pay’ system, certify the complete and correctness;
b) Release Time
- Provide Manger of Academic Resources (MAR) with information related to release time to be funded from a sponsored program;
c) Release Time for Cost Sharing
- Work with the Manager of Academic Resources (MAR) to plan and gather supporting information relevant to release time for cost sharing
10.3 Manager of Academic Resources (MAR)
a) Additional Pay
- Verify the correctness of the PI’s submission in the ‘Special Pay’ system;
b) Release Time
- Ensure that all relevant release time information will be reported to CSUN-Financial Services for billing in a timely manner;
c) Release Time for Cost Sharing
- Ensure that all relevant release time for cost sharing will be reported to TUC-Sponsored Programs within 60 days after the end of the reporting period;
10.4 CSUN Financial Services
a) Additional Pay
- No role or responsibility
b) Release Time
- Ensure that all relevant release time will be billed to the TUC within 60 days after the end of the semester;
c) Release Time for Cost Sharing
- No role or responsibility
10.5 CSUN-Faculty Affairs
a) Additional Pay
- Operate and maintain ‘Special Pay’ system;
b) Release Time
- No role or responsibility
c) Release Time for Cost Sharing
- No role or responsibility
11. Regulations
11.1 Federal
- Code of Federal Regulations 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
- State Administrative Manual, Section 8752.1
11.2 CSU - Systemwide
- ICSUAM 11003.06
- Board of Trustees Executive Order No. 1000
12. Contact Information
The University Corporation, Sponsored Programs
Mahyar Sadri
Administrative Compliance Analyst
(818) 677-6414
mahyar.sadri@csun.edu
Mail Stop: 8309
13. Implementation
This procedure is valid for any reporting period beginning with the fall semester 2017.