After-the-Fact (Effort) Reporting Policies and
Procedures
Revised 6/14/99
Table of Contents
1.0 Introduction
The Federal Government’s Office of Management and Budget (OMB) issued Circular A-21, on February 26, 1979 (subsequently revised), establishing principles for determining costs applicable to grants, contracts, and other agreements with educational institutions. All Federal agencies that sponsor research and development, training, and other work at educational institutions must apply the provisions of this Circular in determining the costs incurred for such work.
Circular A-21 deals extensively with the principles to be used in charging both direct and facilities and administrative (indirect) costs to grants, contracts, and other agreements. This analysis of the Circular, however, is limited to those provisions relating to compensation for personal services and, specifically, to the manner in which the Medical University of South Carolina complies with those provisions.
Compensation for personal services covers all amounts paid currently, or accrued by the University, for services of employees rendered during the period of performance under sponsored agreements. Such amounts include salaries, wages, and fringe benefits. Circular A-21 Section J.8. provides three methods for handling payroll distributions: a system of plan-confirmation, a system of after-the-fact activity records and a system of multiple confirmation records.
Circular A-21 Section J.8.b(2) sets forth criteria that a payroll distribution system must have to be acceptable which is prelude to selecting a method for handling payroll distributions.
1) The payroll distribution system must:
a) be incorporated into the official records of the institution
b) reasonably reflect the activity for which the employee is compensated by the institution, and
c) encompass both sponsored and all other activities on an integrated basis, but may include the use of subsidiary records. (Compensation for incidental work described in Section J.8.a. need not be included.)
2) The method must recognize the principle of after-the-fact confirmation or determination so that costs distributed represent actual costs.
3) The payroll distribution system must allow confirmation of activity allocable to each sponsored agreement and each of the categories of activity needed to identify F&A cost and the functions to which they are allocable.
4) The payroll distribution system must reflect categories of activities expressed as a percentage distribution of total activities.
5) The 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.
6) The system must provide for independent internal evaluations to ensure the system’s effectiveness and compliance with the above standards.
7) For systems which meet these standards, the institution will not be required to provide additional support or documentation for the effort actually performed.
2.0 Purpose and Scope
2.1 After-the-Fact Reporting System
The Medical University of South Carolina uses the After-the-Fact Reporting System as the basis for its distribution of salaries and wages for all faculty and staff. Under this system the distribution of salaries and wages is supported by activity reports. According to Circular A-21, MUSC’s after-the-fact reporting system must meet the following standards:
1) The activity reports must reflect the distribution of activity expended by employees covered by the system (compensation for incidental work as described in Circular A-21 section J.8.a need not be included).
2) These reports must reflect an after-the-fact reporting of the percentage distribution of activity of employees. Charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated by activity records.
3) The reports must reasonably reflect the activities for which employees are compensated by the institution. To confirm that the distribution of activity represents a reasonable estimate of the work performed by the employee during the period, the reports must be signed by the employee or appropriate official using suitable means of verification that the work was performed.
4) The system must reflect activity applicable to each sponsored agreement and to each category needed to identify F&A costs and the functions to which they are allocable.
5) For professorial and professional staff, the reports must be completed quarterly. For other employees, the reports must be completed monthly and may coincide with one or more periods.
6) Where the institution uses time cards or other forms of after-the-fact payroll documents as original documentation for payroll and payroll charges, such documents shall qualify as records for this purpose, provided that they meet the above five requirements.
2.2 Employees Covered
The employees covered by the After-the-Fact Reporting System are all professorial and
other employees which includes:
1) All University Faculty, except faculty with 100% effort in instruction.
2) All other University personnel who:
a) Cost share or charge activity directly either to one or more sponsored agreements
b) Distribute their activities to more than one direct or indirect activity
c) Split their effort between direct and indirect activities
d) Have any or all of their effort charged to indirect research or indirect instruction
3) Affiliate Personnel - See Affiliate Policies and Procedures
3.0 Procedures
3.1 Activity Reports
An Activity Report (Exhibit 1) is provided to every employee covered under the After-the-Fact Reporting System either monthly or quarterly throughout the fiscal year. This form will reflect the percentage of effort spent in total for each column (UDAK) for the respective pay periods. The Activity Report will be sent by Grants and Contracts Accounting to the Department Effort Coordinator who will distribute the Activity Reports to the appropriate employees. Each employee or the appropriate official with firsthand knowledge of the employee’s activities must review, sign and date the Activity Report, and return it to the Department Effort Coordinator. The Department Effort Coordinator will forward the signed Activity Report to the Office of Grants and Contracts Accounting to be kept on file. If adjustments to an employee’s actual effort have been made on the Activity Report it may activate a PEAR form to be processed through the department’s normal channels (see the "Significant Changes on an Activity Report" section below, Item 3.4).
The Activity Report may be signed by a Dean, Chair, Director, Principal Investigator or Business Manager without the employee's signature (See "Exception to Appropriate Official Signature"), provided the appropriate official is prepared to certify that he/she has firsthand knowledge of all the employee's activities. If the appropriate official cannot certify that he/she has firsthand knowledge of all the employee's activities, then the employee must sign the statement. In some cases, an employee may be involved in a number of activities under different supervisors, and no single person other than the employee has firsthand knowledge of all his/her activities. In these cases, the documents must be signed by the employee. Only one signature is required if the person signing can certify all the employee's activities.
Each employee has responsibilities in the operation of the After-the-Fact Reporting System which are set forth in the transmittal memorandum (Exhibit 2) accompanying the Activity Reports.
3.2 Average Hours Per Workweek
The employee certification includes a blank for the average hours worked per week. This information is necessary for Medicare requirements, therefore, those covered employees reflecting effort in either Clinical Instruction, House Staff Instruction, Clinical Services or Hospital Administration are required to provide this information.
3.3 Exception to Appropriate Official Signature
The appropriate official signature is not acceptable for those covered employees reflecting effort in either Clinical Instruction, House Staff Instruction, Clinical Services or Hospital Administration. The covered employee must sign the Activity Report to be in compliance with Medicare requirements.
3.4 Significant Changes on an Activity Report
Circular A-21 states that "charges may be made initially on the basis of estimates made before the services are performed, provided that such charges are promptly adjusted if significant differences are indicated on the Activity Reports". If a significant change on the Activity Report is necessary to reflect actual effort of an employee a new PEAR form must be completed. Although there is no precise definition for the term "significant," it has been construed as a general rule that a change applicable to a given project or activity of 5% or more of an employee’s total effort would warrant an adjustment. These adjustments should be implemented immediately following the Department Effort Coordinators receipt of the signed activity report.
3.5 Retroactive Changes on a Previously Certified Activity Report
A retroactive change in payroll distribution by a PEAR form affecting any previously certified time frame, must be subjected to the closest scrutiny. Such a change would indicate a contradiction of the certified effort and for that reason should be limited to the correction of errors. If a retroactive change should be made, it must be supported by a full explanation and must have approval by the Department Chair, Vice Chair or Business Manager or one level higher. The adjustment should be implemented within 90 days of the receipt of the monthly or quarterly activity reports.
4.0 Internal Audit
The After-the-Fact Reporting System will provide for independent internal evaluation to ensure the system’s integrity and compliance with applicable standards. This independent evaluation will be performed by the Internal Audit Department of the Medical University of South Carolina.
Reviews by Internal Audit will meet the following standards:
1) Reviews will have the objectives of evaluating whether:
a) Certified Activity Reports are adequate, specific, and reasonable.
b) Changes are being promptly identified and reviewed by the department effort coordinator.
c) Prompt decisions on the significant changes are being made and documented by the appropriate official.
2) The review process will include interviews with a representative number of employees covered by the system. These interviews will determine whether:
a) The employee is aware of his/her responsibilities to review and complete each Activity Report.
b) The employee thoroughly understands the nature of a significant change.
c) The employee is reporting significant changes in effort to his/her appropriate official.
3) Follow-up reviews will be made to determine that prompt action has been taken to correct any problems disclosed during the initial review.
4) Internal Audit will document and retain as a part of the official records of the Medical University of South Carolina, the following: the defined scope of the review, tests that have been performed and the results and recommended corrective actions. Internal Audit will report its findings on the After-the-Fact Reporting System in accordance with written institutional policies.
5.0 Guidelines For Department Effort Coordinator
Each department will appoint an individual to perform the duties of the Department Effort Coordinator. A training course on these duties will be administered by Grants and Contracts Accounting for all Department Effort Coordinators. The Department Effort Coordinator will act as the central distribution point between the department and Grants and Contracts Accounting. The responsibilities include distributing the Activity Reports to the appropriate employees, collecting the Activity Reports from the appropriate covered employees, ensuring a signature and date and forwarding the reports to Grants and Contracts Accounting by the stipulated due dates and, if adjustments are necessary to the employee’s effort, notifying the appropriate individual in the department so that a PEAR form is processed through the departments normal channels. The departments are responsible for maintaining adequate documentation to substantiate any changes to a covered employee’s salary distribution that will hold up under internal and external audits.
6.0 Timetable
| Statement Title | Distribution Date | Return Date * |
| 5th of the month | 5th of the following month | |
| October 5th | November 5th | |
| January 5th | February 5th | |
| April 5th | May 5th | |
| July 5th | August 5th |
* All Activity Reports should be returned to the Office of Grants & Contracts Accounting.
For additional assistance in completing the Statements under the After-the-Fact Reporting System see the "Effort Category Activity Guidelines" for a listing, not meant to be all-inclusive, of various activities and the category that the effort should be reflected under.
1) Instruction means the teaching and training activities of an institution. This term includes all teaching and training activities, whether they are offered for credits toward a degree or certification or on a noncredit basis.
a) Instruction (sponsored & classroom) means all teaching and training activities of the institution except clinical setting and housestaff instruction, see definitions below.
b) Instruction in the Clinical Setting means that portion of instruction which involves teaching and training activities carried out with related patient contact when degree candidates are present.
c) House staff instruction means that portion of instruction where interns and residents and fellows are present, such as supervision, consultation, classroom or laboratory settings, either with or without related patient contact.
2) Department supported research means research activities that are not sponsored, consequently not separately budgeted for and accounted. This would include proposal development and research effort allowed by a department and funded through the department’s general funds, such as seed money, start-up funds or interim funding.
3) Organized research means all research and development activities of an institution that are separately budgeted and accounted for by an institution. This term includes research and development activities that are sponsored by Federal and non-Federal agencies and organizations. Cost sharing applicable to sponsored research is a part of organized research.
a) Sponsored and university research means all organized research which is funded internally or by agencies external to the institution, including research training. In addition to the direct effort spent on a sponsored research project this would include time spent administering a sponsored research project, for example, writing the technical report.
b) Cost sharing means mandatory or voluntary effort expended on one account and paid for by another account (typically a non-sponsored account). Mandatory cost sharing is required by some sponsors and is stated on the Notice of Grant Award (NGA). Voluntary cost sharing represents additional effort expended on the project that is not required by the agency.
4) Clinical services means services for which direct patient care is rendered. It does not include effort expended in the following categories; housestaff instruction, instruction in the clinical setting or clinical trials.
5) Administration and internal committees means administrative and support services benefitting either the hospital, the department and/or University objectives.
a) Department administration means administrative and supporting activities that benefit common or joint departmental activities in the deans’ offices, academic departments, divisions and organized research units.
b) General administration means activities that benefit the general executive and administrative functions of the University and other activities of general character which do not relate solely to any major functions of the university (ie. university wide committees).
c) Hospital administration means any administrative responsibility involving a hospital department, other than individual identifiable patient services including teaching or instruction activities for the Medical University hospital staff. Including hospital conferences, standing or special committees involving the medical or administrative operations of the hospital.
6) Other sponsored activities means programs and activities funded by a federal or non-federal sponsor, other than instruction or organized research, such as AHEC.
7) Student services means activities that are established for the primary purpose of contributing to a student’s emotional and physical well-being and to the intellectual, cultural and social development outside the context of the formal instruction program. This includes student activities, cultural events, student newspaper, intramural athletics, student organizations, student health services, etc.
8) Service / Recharge centers means effort devoted to any of the official University service centers or recharge centers, such as lab animal, university transportation, media services, print shop. See website www. musc.edu/research/gca/home.htm for an official list of service and recharge centers, updated each fiscal year.
9) Other university activities means all activities of an institution that are not specifically assigned to any other category, such as development, fund-raising, public relations, rare book collections and any activities or costs which are "unallowable" to sponsored agreements.
Actual effort means the true effort expended during the past fiscal year.
100% Effort means all work performed by the covered employee, including activities relating to any MUSC affiliate for which the employee is compensated. "Affiliates" does not include the V.A. Hospital.
MUSC Activity
Report
Month/Quarter Ending _/_/_
Employee Name: John Doe
Emp. # 123-456-789
Unit#: 222-010
Dept. Effort Coordinator: Jane Smith
This effort reporting information will be
used for two purposes: first to substantiate effort under federal contracts and grants
(ie. Medicare, NIH, NSF, DOE, etc.) second to calculate the future Facilities &
Administrative (indirect) cost rates.
| UDAK: Project Title: |
MUCU
2220010 30800 1010 Medicine Administration |
MUCU
2220010 37800 7110 Medicine "R" Fund |
MUCR
2220100 80175 2021 05 Cardiac Hypertrophy |
Total |
| Categories: (definitions on reverse side) | ||||
| I. Instruction and Training | ||||
| VI. Other Sponsored Activities | ||||
| VII. Student Services | ||||
| VIII. Service/Recharge Centers | ||||
| IX. Other University Activities | ||||
| Total (Effort must total 100%) | 25% | 25% | 50% | 100% |
I (employee or responsible official) certify to the best of my knowledge that the distribution of effort represents a reasonable estimate of activity during the stated period. If categories I.B., I.C., I.V., or V.C. are applicable only the employee can sign this effort report and complete the average work week hours line.
Employee Signature:______________________ Date: _/ _/ _ The above effort represents an average work week of ___hours.
If applicable, Responsible Official Signature: __________________________ PI initials ________
Activity Report Category Definitions
I. Instructionmeans the teaching and training activities of an institution. Includes all activity related to instruction; including preparation time, time spent with students, attending or teaching continuing education classes, etc. Departmental research is not considered as a major function but as a part of the instruction function of the institution.
A.Instruction (sponsored & classroom) means all teaching and training activities of the institution except clinical setting and housestaff instruction, see definitions below.
B.Instruction in the Clinical Setting means that portion of instruction involving teaching and training activities carried out with related patient contact when degree candidates are present.
C.House staff instruction means that portion of instruction where interns and residents and fellows are present, such as supervision, consultation, classroom or laboratory settings, either with or without related patient contact.
II. Department supported research means research activities that are not sponsored, consequently not separately budgeted and accounted. Includes proposal development and research effort allowed by a department and funded through the departments general funds, ie. seed money, start-up funds or interim funding.
III.Organized research means all research and development activities of an institution that are separately budgeted and accounted. This term includes research and development activities that are sponsored by Federal and non-Federal agencies and organizations. Cost sharing applicable to sponsored research is a part of organized research.
A.Sponsored & university researchmeans all organized research which is funded internally or by agencies external to the institution, including research training . In addition to the direct effort spent on a research project this would include time spent administering a research project, ie. writing the technical report.
B.Cost Sharing means mandatory or voluntary effort expended on one account and paid for by another account (typically a non-sponsored account). Mandatory cost sharing is required by some sponsors and is stated on the Notice of Grant Award (NGA). Voluntary cost sharing represents additional effort expended on the project that is not required by the agency.
IV.Clinical services means services for which direct patient care is rendered and can not be included in any other category on the effort report.
V.Administration and internal committees means administrative and support services benefitting either the hospital, the department and/or University objectives.
A.Department administration means administrative and supporting activities that benefit common or joint departmental activities in the deans’ offices, academic departments, divisions and organized research units.
B.General administration means activities that benefit the general executive and administrative functions of the Universtiy and other activities of general character which do not relate solely to any of the major functions of the university (ie. university wide committees)
C.Hospital administration means any responsibility involving a hospital department, other than individual identifiable patient services including teaching or instruction activities for the Medical University hospital staff. Including hospital conferences, standing or special committees involving the medical or administrative operations of the hospital.
VI.Other sponsored activities means programs and activities funded by a federal or non-federal sponsor, other than instruction or organized research, ie. sponsored public service.
VII.Student services means activities that are established for the primary purpose of contributing to a student’s emotional and physical well-being and to the intellectual, cultural and social development outside the context of the formal instruction program, ie. student activities, cultural events, student newspaper, intramural athletics, etc.
VIII. Service / Recharge centers means effort devoted to any of the official University service or recharge centers, such as lab animal, university transportation, media services, print shop. See www.musc.edu/research/gca/home.htm for an official list of service and recharge centers.
IX.Other university activities means all activities of an institution that are not specifically assigned to any other category. Such as development, fund-raising, public relations, rare book collections and any activities or costs which are "unallowable" to sponsored agreements.
THE MEDICAL UNIVERSITY OF SOUTH CAROLINA
ACTIVITY REPORT TRANSMITTAL
PROFESSORIAL AND OTHER EMPLOYEES
MEMORANDUM
TO: John Doe, Cell Biology & Anatomy
FROM: Department Effort Coordinator
SUBJECT: Activity Reports
DATE: August 1, 1999
Attached is a copy of your activity report distributed in accordance with the requirements of the After-the-Fact Reporting System. If you need assistance in completing your activity report under the After-the-Fact Reporting System, please contact me or Grants & Contracts Accounting (792-2850).
A significant deviation under Circular A-21 (federal regulations MUSC must comply to) has been defined as a change of 5% or more in the total effort expended on a given project or activity over a fiscal year. Such a change may require that a modification be made to your salary distribution.
Each employee is responsible for reasonably reflecting, on a percentage basis, the effort expanded on any of the activity report categories whether compensated by MUSC or an affiliate (excluding the V.A. Hospital).
It is recommended that you retain for your files a copy of the completed and signed activity reports to assist you in substantiating the reasonableness of the estimates of your activities during an internal and/or external audit.
The Medical University of South Carolina
Effort Category Activity
Guideline
for the
After-the-Fact Reporting System
This is a listing, not meant to be all-inclusive, of various activities performed by employees covered under the After-the-Fact Reporting System and the category that the individuals effort should be reflected under. Funding notes have been provided to further assist in the identification of the appropriate effort category.
Effort Categories:
I. Instruction and Training
a) Instruction (sponsored & classroom)
b) Instruction in the Clinical Setting
c) Housestaff Instruction
II. Department Supported Research
III. Organized Research
a) Sponsored & University Research
b) Cost Share (no salary charged)
IV. Clinical Services
V. Administration and Internal Committees
a) Department Administration
b) General Administration
c) Hospital Administration
VI. Other Sponsored Activities
VII. Student Services
VIII. Service / Recharge Centers
IX. Other University Activities
| Activity | Effort Category | Funding Notes |
| Membership on a NIH or NSF review panel | V.A. | Expenses reimbursed by the funding agency |
| Other service for NIH or other funding agencies (site visitor, advisory committee member, expert panelist) | V.A. | Expenses paid by the funding agency |
| Editorial service for scientific journal (editorial consultant, Editor or Associate Editor, member of editorial board) | V.A. | No funding or reimbursement of expenses |
| Service to national scientific societies (committee membership, elected office) | V.A. | Some expenses paid by organization |
| Give an invited lecture at a university or scientific conference | V.B. or IX if consulting | Some expenses paid by other university |
| Give an invited presentation to a local medical/scientific organization | V.B. or IX if consulting | Small honorarium |
| Give an invited speech about MUSC research activities to a local civics group | V.B. or IX if consulting | |
| Give an invited presentation for program's certifying agency | V.A. | Expenses paid by agency |
| Serve as committee member for program's certifying agency (policy committee, write questions for national certification examinations) | V.A. | Expenses paid by agency |
| Organize a national scientific conference | V.A. | No funding or conference registration waived |
| Present a paper at scientific meeting | III.A. (specific to project), II or V.A. general | Expenses paid from grant funds |
| Travel to a scientific meeting | III.A. (specific to project), II or V.A. (general) | Expenses paid form other than grant funds |
| Serve on a scientific advisory board for a university or a research institution | V.A. | Expenses paid by other university or institute |
| Serve as a paid consultant on a research grant at another insitution | Outside the 100%-on own time | Expenses paid by grant at other institution |
| Serve as an unpaid consultant on a research grant at MUSC or other institution | Outside the 100%- on own time | |
| Collect preliminary data for new grant applications | II. | |
| Prepare a new grant application | II. | |
| Review/critique colleagues' grants and manuscripts | V.A. | |
| MUSC committee service - College or Department (including Departmental Review, Promotion and Tenure) | V.A. | |
| MUSC committee service - University Search | V.B. | |
| Serve as director of University Research Resource | IX. | Support for portion of salary |
| Recruit and hire laboratory personnel | III.A. | |
| Supervise current laboratory personnel | III.A. | |
| Maintain grant budgets | III.A. | |
| IRB committee/time spent completing IRB form | V.A. |
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