Thanks for your message, Larry (and please forgive my late reply).   We
are a pretty conservative institution, and so I appreciate the
confirmation of our research.  We are a little concerned about applying
this tolerance to exempt staff, because their duties may not be so
intermingled as they are for faculty.  We are considering defining the
tolerance level for staff as 1%.

Has anyone with a 5% tolerance policy been questioned by auditors or
otherwise faced issues concerning exempt staff?

Heidi Davis, Ph.D.

Director of Grants and Sponsored Programs

Marquette Hall 301, Campus Box 71

Loyola University New Orleans

6363 St. Charles Ave.

New Orleans, LA  70118

Direct Line: (504) 865-3086

Grants Office: (504) 865-3084

xxxxxx@loyno.edu

-----Original Message-----
From: Research Administration List
[mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Lawrence Waxler
Sent: Wednesday, October 23, 2013 3:08 PM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Time and Effort Reporting - Tolerance level

Heidi,

I would encourage you to review A-21 Section J. 10. Compensation for
personal services.

You will see that the Feds do allow for some level of tolerance. For
example:

b. (1) (c)
In the use of any methods for apportioning salaries, it is recognized
that, in an academic setting, teaching, research, service, and
administration are often inextricably intermingled. A precise assessment
of factors that contribute to costs is not always feasible, nor is it
expected. Reliance, therefore, is placed on estimates in which a degree of
tolerance is appropriate.

b.  (2) (e)
Direct and F&A charges may be made initially to sponsored agreements on
the basis of estimates made before services are performed. When such
estimates are used, significant changes in the corresponding work activity
must be identified and entered into the payroll distribution system. Short
term (such as one or two months) fluctuation between workload categories
need not be considered as long as the distribution of salaries and wages
is reasonable over the longer term, such as an academic period.

Your question as to what level of tolerance is allowed is, within reason,
defined by your institutional policy. If your institutional policy says
that the effort should be within 1% then the Feds will hold you to that
standard!

At our institution we define the tolerance level as falling within a
"reasonable estimate of the effort you expended". From an A-133
perspective, that is within 5%.

Larry

~~~~~~~~~~~~~~~~~~~~~~~
Larry Waxler, Director
Office of Sponsored Programs
University of Southern Maine
1 Chamberlain Avenue
P.O. Box 9300
Portland, ME  04104-9300
Telephone: 207-780-4413
Telefax: 207-780-4927

>>> Heidi Davis <xxxxxx@LOYNO.EDU> 10/22/2013 5:28 PM >>>
Do any of you have experience with a tolerance level of 5% (absolute
percentage points) for after-the-fact effort reporting?  Our previous
tolerance level was within 1%.  We are considering increasing it and would
appreciate being able to ask a few questions.  Would you please contact me
offline if you can offer any guidance?

We don't have electronic certification system, but our pre-filled Time and
Effort reporting forms would show the charged efforts and allow faculty to
confirm that these efforts are within +/- 5% of their effort
determinations.  One of the things we are concerned about is language from
COGR.  It's Policies and Practices document on Compensation, Effort
Commitments, and Certification warns that ".if the institution's policy is
such that faculty members are expected to know their exact effort the
nearest percentage point, to couple this approach with a 5 percent
variance policy might raise questions (e.g., if an individual knows the
exact effort percentage, why allow a five percent variance?)"  We aren't
sure what would constitute requiring the faculty to know their exact
efforts to the nearest percentage point.   We are wondering a few things,
such as:

.         Whether the fact that we budget efforts to within a single
percentage point (not necessarily a multiple of 5%) will pose a problem.
(To me, a former scientist, this isn't problematic.  If I take a distance
measurement and determine that the average value is 103 nm, but there is
an uncertainty of +/- 5 nm, I would record the value as 103 +/- 5 nm.  I
would not round the average value to 105 nm before reporting it.)

.         Whether the following instructing would be helpful the
university:  "If your grant-related activities are clearly separable from
your other duties and you can confidently determine your effort devoted to
a sponsored project to within a greater level of precision, then you
should adjust the tolerance level accordingly.  Example:  An exempt staff
member is confident that he can determine his effort to within 1%.  His
charged effort for a sponsored project is 25%; the effort he determines
for the project is 23%.  When completing his Time and Effort Report form,
he should indicate that the charged effort is incorrect and specify 23% as
the correct effort."

-Heidi

Heidi Davis, Ph.D.

Director of Grants and Sponsored Programs

Marquette Hall 301, Campus Box 71

Loyola University New Orleans

6363 St. Charles Ave.

New Orleans, LA  70118

Direct Line: (504) 865-3086

Grants Office: (504) 865-3084

 <mailto:xxxxxx@loyno.edu> xxxxxx@loyno.edu

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