The Top Ten Things You Should Know Today about Effort on Sponsored Projects

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The Top Ten Things You Should Know Today about
Effort on Sponsored Projects
Office of Research and Sponsored Programs March,
20007
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A Warning

• The most important obstacles in effort reporting
  compliance are misunderstanding and denial, and
  sometimes one obstacle feeds on the other.

Robert J. Kenney, Jr. Director, Grants and
Contracts Practice Hogan and Hartson LLP,
Washington, DC Time and Effort Reporting
Overview and Risk Assessment Report on Research
Compliance, January 2006
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Why are we talking about this?

• The federal government has made effort reporting
  a top target for audits.
• NSFs Office of the Inspector General (OIG) is
  making the rounds of research universities.
• The Department of Justice is involved, filing
  charges under the False Claims Act.
• Many universities have had to pay millions of
  dollars in fines.

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Top 10 Concepts

• Effort is your work on a project, whether the
  sponsor pays your salary or not.
• When you write yourself into a grant proposal,
  you are committing your effort to the sponsor.

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• If you reduce your effort, paid or unpaid, on a
  federal grant by 25, you must have agency
  approval. If you reduce your paid effort, you
  may choose to document cost-sharing so that the
  total effort does not decrease.

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• Many activities cannot be charged to a federally
  sponsored project. For example, the time you
  spend on these activities cannot be charged
• Writing a proposal
• Serving on an IRB, IACUC or other research
  committee
• Serving on a departmental or university service
  committee

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• If you work on a sponsored project, you must
  certify your effort.
• Certifying effort is not the same as certifying
  payroll.

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• Certification must reasonably reflect all the
  effort for all the activities that are covered by
  your UW compensation.
• Effort is not based on a 40-hour work week. Its
  not based on hours at all.

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• Effort must be certified by someone with suitable
  means of verifying that the work was performed.
• Auditors look for indications that
  certification was based on factors other than
  actual, justifiable effort.

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Where is this coming from?

• This is federal policy.
• Its not new it may just sound unfamiliar
• Recent aggressive federal audits have resulted in
  multi-million dollar fines at research
  universities.

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Theres more to it than this, but

• These ten concepts are the foundation for
  everything else.
• This fall, youll stop getting paper forms from
  the Personnel Activity Reporting (PAR) system.
• Were launching a new, easy-to-use Web-based
  effort certification system.
• Youll be hearing more about certification and
  the new Web-based system.

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Where to go for more info

• TBA
• TBA
• TBA