SponsoredProjectsComplianceCertificationProgram.ppt

University of Pennsylvania Health System Sponsored Projects Compliance Certification Program Sponsored Projects Effort Reporting Sponsored Projects Compliance Certification Program Welcome to the University of Pennsylvania’s Sponsored Projects Compliance Certification Program. The Program is designed to facilitate compliance with sponsored programs administrative requirements by addressing concepts critical to proper management. The purpose of effort reporting is to provide a reasonable basis for distributing salary charges among direct activities (e.g., sponsored projects and non sponsored activities such as instruction, administration, and clinical activity). This module examines the requirements for charging salary costs to sponsored programs. What is Effort Reporting? Effort reporting is a method for documenting activity expended in support of all sponsored projects OMB Circular A-21 requires that the University document the distribution of activity to each individual sponsored project The method for documenting must: Reasonably reflect the activity for which an individual is paid by the University Reflect all of these activities performed by the individual Include after-the-fact confirmation to ensure that initial salary charges reasonably approximate actual effort Be performed by the individual or a responsible individual who has a “suitable means of verification that the work was performed” Activities Included in Effort Reports Sponsored Projects Activities: Includes effort devoted to grants, contracts, and cooperative agreements sponsored by non-University entities, i.e., state, local, federal governments, foundations, corporations, etc., for purposes of training, clinical trials, and research Non-Sponsored Activities Administration: Includes effort devoted to departmental business activities, curriculum development, proposal and bid preparation, sponsored projects administration, serving on human, animal subjects, recruiting, or radiation safety commi