Are you using percentage points or percent of the committed effort? I was at a Compliance conference last week in Austin and sat in on a discussion regarding Efforts. There was talk regarding a "generally accepted variance of 5%" of the committed effort amount, but nowhere is that generally accepted variance documented. Of course the difference between 5% of committed effort and 5 percentage points could be a fair amount of money, especially if the individual is at, near or over the salary cap. Laura R Hemrick, CRA Research Compliance Officer University Compliance Office Wake Forest University Health Sciences Winston-Salem, NC 27157 336-716-4403 Fax: 336-777-3039 CONFIDENTIAL & ANONYMOUS HOTLINE - 877-880-7888 Submit web report: www.tnwinc.com/webreport -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Lori Johnson Sent: Thursday, June 14, 2007 2:07 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] Time and Effort Policy Hi Kim, We are investigating the same issues when it comes to a tolerance threshold. We currently use a 10% variance as our academic period is 9 month and the circular says a fluctuation of 1 to 2 months is allowable. 1/9 equals 11 %, so we went with the 10% variance. I am very interested in what other institutions are allowing! We ask the faculty member to certify actual effort, then compare that to actual payroll. If it is within the 10% variance for the entire time period, we leave it alone. Our internal audit teams is asking us to consider the academic period as one semester and cut the tolerance to 5%. Any ideas from anyone on that? We don't (at this time) have a policy on how much effort can be charged. We have some research faculty at 100% effort on sponsored projects. We apply our T & E policy to federal and non-federal sponsored projects alike. We do allow re-certification, but only with permission and documentation of extenuating circumstances or error. Hope this helps. Lori Johnson Kim Dunbrook-Babbie wrote: >I have the following policy questions related to time and effort. > >1. OMB Circular A-21 allows for a degree of tolerance for allocation of >costs and effort > > a. What tolerance thresholds does your Institution use for time and >effort? I have seen many that use 5%. > > b. How is the tolerance threshold trained to staff? For example if >a time end effort report lists the PI effort at 25% and the PI believes >their effort is 25-30% would you have the PI change the effort listed >or leave it unchanged as it is within a 5% tolerance? > > c. If a time and effort report for a research tech or a PI has >payroll at 100% charged to a grant but the research tech/PI knows that >their effort for the time period was only 97% to the grant and 3% was >administrative time is it your policy to correct the payroll charged to >97% or is the 3% variance within the threshold and therefore no >correction is made? > > >2. Do you have a policy regarding the maximum amount of effort that can >be charged to a sponsored project for faculty members or any group of >employees? > >3. Does your effort reporting apply to both Federal, (including federal >pass through) and non-federal sponsored projects or only Federal? > >4. Under what circumstances do you allow changes to be made to the >certification of effort form after it has been certified? > >Thank you for your help > >Kim Babbie >(518) 262-5496 > > >----------------------------------------- >CONFIDENTIALITY NOTICE: This email and any attachments may contain >confidential information that is protected by law and is for the sole >use of the individuals or entities to which it is addressed. >If you are not the intended recipient, please notify the sender by >replying to this email and destroying all copies of the communication >and attachments. Further use, disclosure, copying, distribution of, or >reliance upon the contents of this email and attachments is strictly >prohibited. To contact Albany Medical Center, or for a copy of our >privacy practices, please visit us on the Internet at www.amc.edu. > > >====================================================================== > Instructions on how to use the RESADM-L Mailing List, including >subscription information and a web-searchable archive, are available >via our web site at http://www.hrinet.org (click on "Listserv Lists") >====================================================================== > > -- Lori Johnson Fiscal Officer Grants & Contracts Accounting Campus Box 8219 Idaho State University 282-3899 ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
