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Office of Compliance & Risk Assurance

Office of Compliance & Risk Assurance

A drone shot of University Boulevard at night, with UAB logos on several of the buildings.

As public employees, UAB employees must adhere to the State of Alabama Ethics Law. Additional information is available from the Alabama Ethics Commission and under the tabs below.

Resources

A man working at a desktop computer. The responsible conduct of research (RCR) promotes the aims of scientific inquiry, fosters a research environment that enables scientists to work together toward common goals, and promotes public confidence in scientific knowledge and progress for the public good.

RCR practices and training are also reflective of UAB’s Enterprise Code of Conduct opens a new website and the university’s commitment to not only conducting its operations in ways that promote mutual trust and public confidence, but also UAB’s commitment to federal and non-federal funding and regulatory agencies’ expectations.

You may find additional information regarding RCR and related training by visiting the UAB Office of Research RCR Training site opens a new website.

Students riding in the back of a truck at homecoming, smiling and waving at the camera.UAB covered entities implement certain administrative requirements to protect against the wrongful use or disclosure of protected health information (PHI) in compliance with the Health Insurance Portability and Accountability Act (HIPAA) and Alabama state law.

UAB values and promotes business practices among its covered entities and all members of their workforces and student population to provide privacy and security of PHI.

This education and training applies to all UAB covered entities:

  • School of Dentistry
  • School of Health Professions
  • School of Medicine
  • School of Nursing
  • School of Optometry
  • Joint Health Sciences Departments
  • School of Education and Human Sciences Community Clinic
  • UAB Health Plans
  • other UAB entities that may be added from time to time 

All UAB employees and students assigned to a UAB covered entity or in an area where it has been determined that HIPAA education and training is necessary will need to complete the HIPAA training course as part of their departmental onboarding. In addition to the initial HIPAA training requirement, employees are expected to complete a HIPAA refresher course when required.

HIPAA training for initial education and for the refresher training is available in the Campus Learning System opens a new website. 

UAB Medicine Employees can access the UAB/UABHS HIPAA Information Site opens a new website for education and training information. NOTE: this website is only accessible on campus on UAB-network computers.

A woman working on her laptop in a glass-walled office. Salary costs are often the largest expense charged to sponsored projects. The salary charged to a specific sponsored project must be consistent with the actual activities performed on the project and supported with appropriate, contemporaneous documentation.

For employees receiving extramural support, a certified effort report is the document that represents all UAB activities and is the mechanism used to provide assurance that the salary charged is appropriate in relation to the work performed.

This process includes several layers of individuals who work in concert to ensure effort is timely certified with reasonable accuracy, including the departmental effort officer (DEO), effort reportable employee, and UAB Financial Affairs.

For DEOs and effort reportable employees, it is important to review the UAB Effort Reporting Policy opens a new website and UAB Effort Reporting Procedures opens a new website before reviewing and/or certifying an effort report.

Additionally, effort reportable employees and DEOs are required to complete the training course, “Effort Reporting: Principles, Process, and Certification.” pdfDownload transcript.

UAB effort reporting is conducted within the Oracle system and follows a specific workflow. For a flowchart of the Oracle system distributions and workflow of effort reporting, please see the Effort Reporting Certification Flowchart opens a new website.

Fundamental Principles of Reviewing an Effort Report

When conducting an effort report review, the following principles should be considered.

1. 100% is 100%.

There is no set number of weekly hours that constitute total University effort (e.g. a 40-hour work week). Rather, effort is reflected as a percentage of your total University activities with each activity combining to a total of 100%.

Think of your effort report as a pie that equals your total University activity. Each proportional slice representing a University activity as shown below. Effort on each University activity is reflected as a percentage of your total University activities:

Effort Report Pie Chart Example Federally-sponsored Project30% Non-sponsored activites*49% Foundation-sponsored project20% 1%

2. All activities must be included on the effort report, in the period in which the activity took place. 

Effort is a reflection of activity, not salary support.  Any activity performed on a project must be reported on the effort report in the period in which it took place. Even if there is no salary support, the activity conducted must be reported on the effort report.  Thus, regardless of whether an activity is funded by a federal, non-federal, or departmental/internal source, it requires effort reporting. 

This includes research, teaching, service and administration within the university.  If a sponsored project does not allow for salary, a cost-sharing commitment form should be completed to allow activity/effort on the project to be documented. Departmental administrators can assist with completing these cost-share commitment forms and submission to the UAB Office of Sponsored Programs (OSP).

3. There are no nights/weekends for effort reporting. 

University activities are not performed on one’s own time.  No matter where/when UAB work takes place, it must be included in Total University Effort and allocated to the appropriate project on the effort report.

An effort report reflects the actual time spent on activities (as a proportion of total UAB effort), even if the actual effort does not align with the time originally planned for that activity.  For instance, a proposal’s budget is an anticipated commitment of effort; however, the project may require more/less effort than was anticipated and therefore the effort report may/may not align with the originally proposed budget.

Relevant Dates

Effort is certified by UAB Project Employees on a semi-annual basis (every six months). The table below specifies the periods and the associated dates and deadlines of effort reporting at UAB.

Effort Reporting Period

Dates of Periods

Deadline to Certify

First Half of Fiscal Year (H1)

October 1-March 31

May 31

Second Half of Fiscal Year (H2)

April 1-September 30

November 30

The deadline to certify effort reports is sixty (60) days following the end of the effort reporting period. For H1, the deadline is May 31. For H2, the deadline is November 30.

Effort Reports not certified within sixty (60) days after the end of the reporting period are past due and non-compliant with UAB Effort Reporting Policy and Procedures.

Drone shot of a campus green space with sail-like shelters. Best Practices

  1. Recognize that effort reporting is an ongoing process, not a one-time activity. Keeping track of your actual effort, necessary changes in ACT documents, and sponsor requirements are best done on an ongoing basis, not solely at the end of the reporting period. Communicate often with your departmental staff to help ensure everyone is aware of pertinent deadlines and issues in order to facilitate review for reasonable accuracy.
  2. Review your account statements and payroll distribution reports consistently and at least once a month. You, and in conjunction with your DEOs and other department administrators, should review sponsored project account statements, payroll expense distribution reports and effort statements at least monthly (or bi-monthly). This is an effective way to timely monitor salary expenses on your projects to ensure their accuracy.
  3. Review University information sources detailing your activities documented by the University. Various University information sources may help ensure all activities are included in your effort report and that non-sponsored duties are being adequately reflected in your non-sponsored effort percentage. These include, but are not limited to, OSP e-Reports, appointment letters, annual reviews, information maintained by the department, school, Financial Affairs, IRB, IACUC, award budgets, project personnel lists, travel vouchers, outside activity forms, position descriptions, other support forms, leave reports, etc.
  4. Use of contemporaneous (i.e., routine, day-to-day) work records is a reliable means of documentation. These business documents may help you reasonably estimate and support your assessment of actual effort. These include, but are not limited to, calendars, lab notes, progress reports, meeting notes, etc.
  5. Communicate often with your DEO and/or departmental administrators. This facilitates Oracle/ACT documents to be kept current (e.g., starting work on new projects, stopping and/or reducing work on older projects, etc.) This is an important mechanism for ensuring effort reports are reasonably accurate the first time they are generated and for allowing timely review and certification.
  6. Know your funding agencies’ guidelines. This facilitates an understanding of what specific activities are covered by award funds. Your DEO can be very helpful in this regard.
  7. Use at-risk/pending accounts as necessary to allow for timely and accurate effort report certification even before a grant account is established. Your DEO can help with setting up these accounts in a timely manner. This is an effective mechanism for allowing effort to be appropriately allocated with a project where work has begun, but a grant account has not been established (e.g., contracting delays, etc.) Effort should never be certified to an unrelated grant account.

Training

Below is a list of Effort Reporting training available to the UAB community.  If you believe that you or your department would benefit from more customized training, please contact the Office of Compliance & Risk Assurance.  We are eager to help you satisfy your specific learning objectives.

Additional Tools and Documents

Please keep in mind that submission of a Request for External Activity Approval form does not satisfy the requirement to submit an eLAS time off request.

UAB is committed to conducting its activities in ways that promote and maintain public trust.  To this end, UAB faculty and staff are required to adhere to the standards set forth in the UAB Enterprise Conflict of Interest Conflict of Commitment Policy opens a new website, which establishes requirements for seeking advance approval of external activities.

Requirements for requesting approval of external activities under the policy are satisfied at one form location on the UAB Electronic Forms opens a new website website. See below for specific instructions for completing the Request for External Activity Approval Form.

FAQs and Resources

  • Submitting a Request for External Activity Approval Form
    1. Click on UAB Forms and login with your BlazerID and password. You can also access UAB Forms by navigating to UAB Administrative Systems and selecting the UAB Forms button. Access is only available via on-campus network or UABSecureAccess VPN.
    2. Click "Conflict of Interest and Commitment Forms Suite" on the left menu.
    3. Complete the form questions. Provide as much information as needed for reviewers to make an informed judgment as to whether the external activity meets institutional standards, including “when” you plan to perform the work – whether during evenings, on weekends, rearranging UAB work for external activities days, or on vacation – so that reviewers can anticipate whether or not an eLAS time off request should also be submitted.
    4. If you recognize you need more details about your external activity prior to submitting the form, the “Save Form” button on the left of the screen can be utilized. You can come back to it on the “Submitted Forms” tab on the UAB Electronic Forms website.
    5. Once full and complete, click “Submit” at the bottom of the form. While you are required to obtain approval in advance of your external activity, UAB encourages full transparency, and the electronic form does allow for after-the-fact submissions. You will be expected to describe why the form was not submitted timely. In some circumstances, there may be consequences for non-compliance, particularly if the information was needed by the CIRB for purposes of managing conflicts of interest in research. Remember, obtaining approval in advance of your activity protects you and UAB.
  • Professional Public Service Activities

    Professional public service activities are specifically defined in the UAB Enterprise Conflict of Interest and Conflict of Commitment opens a new website policy and follow the exceptions for conflicts of interest outlined in the federal research regulations. They are activities that are performed for external entities but are considered to be part of an employee’s institutional responsibilities or academic appointment. Professional public service activities may or may not be separately compensated. Typically, outside organizations offer no more than reimbursement of lodging and travel expenses, a minor token of appreciation, or small honorarium to recognize the work performed. As a general rule of thumb, the greater the compensation, the less likely the activity is to be categorized as a professional public service activity.

    It is important to categorize activities properly so that employees and reviewers can identify appropriate treatment. Generally, professional public service activities do not require advance approval by supervisors; however, your school may have stricter requirements for approval of professional public service activities, so check with your dean’s level reviewer. If you are unsure as to how an activity is best categorized, err on the side of external activity and seek approval prior to performing the services.

    Employees must:

    In addition, investigators and institutional officials must:

    • Submit a Notice of Professional Public Service Activity opens a new website form for any resulting financial interest (which includes sponsored or reimbursed travel) exceeding $5,000 acquired from any one entity in the previous 12 months for their participation in professional public service activities;
      • Exception: investigators and institutional officials do not have to submit such form for such financial interest if the financial interest is acquired in return for providing seminars, lectures, presentations, or service on advisory committees or review panels for U.S. federal, state, or local government agencies, U.S. institutions of higher education as defined at 20 U.S.C. 1001(a), U.S. academic teaching hospitals, U.S. medical centers, or U.S. research institutes that are affiliated with a U.S. institution of higher education; and
    • Submit a Notice of Professional Public Service Activity opens a new website form for any financial interest in any amount received from a foreign person or entity (governmental, non-profit, for-profit, etc.).

    For example, if you are invited as a guest lecturer to talk about your scholarship and the University of Hawaii pays for your travel expenses (presumably a value greater than $5,000), you will need to submit a Notice of Professional Public Service Activity.

    As part of one's institutional responsibilities or academic appointment, time away from UAB work to perform professional public service activities generally qualifies for professional leave.

  • Information Maintained in the UAB Forms Database

    Information submitted through Request for External Activity Approval forms is stored within a searchable database. Reviewers have access to data related to employees within the orgs for which they have authority. If a department chair or dean has delegated review to an administrator and is not listed simultaneously as a reviewer, the chair or dean will not have access to the database and will have to work through the delegate to obtain information.

    Reports show an employee’s total portfolio of external activity request forms. If reviewers have questions or concerns about the cumulative amount of time spent engaged in external activities, not simply for one activity at a time, this information may be helpful to address potential conflicts of commitment. For information on accessing the database and running reports, see Training/FAQ UAB Forms (pdf) opens a new website and UAB Electronic Forms Dashboard General Guide (pdf) opens a new website for more information.

  • Additional Information

    The following links provide supplemental guidance for UAB employees and their supervisors on various special circumstances surrounding external activities. For more general FAQs, including those specifically about the forms processes, see FAQs for UAB Electronic Disclosure Form (pdf) opens a new website and Training/FAQ UAB Forms (pdf) opens a new website for more information.

  1. International Resources
  2. Records Retention
  3. Policy Development
  4. Investigations and Reviews

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