Office of Research Sponsored Programs What You

Office of Research & Sponsored Programs What You Really, Really Need to Know About Effort Certification

What is Effort Certification? n Effort Certification is our means of providing assurance to sponsors that faculty and staff have met their commitments, paid or unpaid, to extramural projects n It’s required by federal regulation and University policy for all individuals working on sponsored projects n At UW-Madison, UW-Milwaukee, and UW Extension, the Personnel Activity Reporting (PAR) system has been used to certify effort for many years A new, improved Effort Certification system is being implemented right now! Slide 2

Why Should We Care? n Effort commitments and certification are the subject of much attention from federal sponsors and auditors n Erroneously certifying effort can be viewed as fraud n Sanctions can apply to both the institution and the individual Slide 3

Recent Institutional Audits and Fines n Northwestern University – $5. 5 million (2003) n Johns Hopkins University (for one investigator) – $2. 6 million (2004) n East Carolina University – $2. 4 million (2004) n Harvard University/Beth Israel Deaconess Medical Center – $3. 25 million (2000 & 2004) n Dartmouth – $37, 780 (2005) n University of Connecticut - $2. 5 million (2006) Slide 4

How is Effort Determined? n Effort is NOT based on a 40 -hour work week n Effort is based on 100% of the activities for which you are compensated by the UW n These activities are divided into: • Sponsored project activities • Non-sponsored activities, such as: § § Slide 5 Administration, including duties as chair, dean, etc. Instruction Research without external funding Public service and outreach, when closely related to your UW duties

What Counts in Your 100% Effort? Sponsored Project Activities: n This is your effort on: • • Federal grants or contracts (e. g. NIH, NSF, DOD) Non-federal research projects (e. g. a foundation grant or industry sponsored clinical trial) n Activities you can allocate to a sponsored project include: • Writing progress reports; holding a meeting with lab staff; presenting research results at a scientific conference; reading scientific journals to keep up to date with the latest advances in the project topic area n. . . even if your salary is not completely paid by the sponsor (i. e. salary cost sharing) Slide 6

What Counts in Your 100% Effort? Non-Sponsored Activities: n Teaching n Serving as a department chair, and other administrative duties n Serving on university committees n Attending general departmental faculty meetings n Public service and outreach Slide 7

Activities NOT Included in Your 100% UW Effort n Work at the UW VA Hospital n Outside consulting n Serving on an NIH study section or an NSF peer review panel Slide 8

Pay Sources Should Reasonably Reflect Activity OMB Circular A-21 J 10 b(1)(c) says: “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. ” The degree of tolerance at the UW is +/- 5% Slide 9

Who Certifies the Effort Statement? n An individual’s effort must be certified by a responsible person with suitable means of verifying that the work was performed. n Each faculty member, academic staff member, and PI is responsible for certifying his/her own effort n PIs certify for graduate students, postdocs, and non-PI classified staff n There are some exceptions made for practical reasons (e. g. someone other than the PI of a large Center grant has better knowledge of the work that was performed). Contact your department effort coordinator or RSP for help with exceptions. Slide 10

How to Certify n For classified staff, the effort statement shows salary distribution (how you were actually paid) over a three month period, plus any cost-shared effort n For all others, the effort statement shows info for a six month period n You verify that the statement shows a reasonable estimate of the actual effort worked. Things that may help you verify this include: • • Slide 11 teaching schedules outside activity forms “other support” forms leave reports clinical time reports and schedules calendars correspondence

How to Certify (continued) n “I certify the salary charged, salary transfers processed and effort certified this period reasonably reflect the work performed in the designated period, and that I have sufficient technical knowledge and/or I am in a position that provides me with suitable means of verification that the work was performed. ” n If it is a reasonable estimate for the time period: • Certify by clicking the Certify button n Otherwise: • Slide 12 Work with your department administrator and effort coordinator or RSP to revise the Effort Statement before you certify it

Sample Effort Statement

Red Flag Issues n Late effort certification n Effort certified by someone without suitable means of verification n A distribution of effort that leaves too little non-sponsored time to credibly cover teaching, administrative, or other university duties Slide 14

Red Flag Issues (continued) n Post-certification revisions n Significant data inconsistency between the Effort Statement and other documentation such as: • Outside activity forms • Other support forms • Leave reports Slide 15

Points to Remember n Effort reporting is under scrutiny by the Office of Investigators General from NSF, NIH, and other Federal agencies n 100% effort is NOT Based on a 40 -hour work week. It is based on each individual’s own average work week. n Effort reporting tracks the reasonable approximation of actual activity on projects and should not simply mimic budgeted amounts Slide 16

Help is Available n Your department administrators and effort coordinators n Your dean’s office n Research and Sponsored Programs (effort@rsp. wisc. edu) Reference materials are located at www. rsp. wisc. edu/effort Slide 17