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What You Really, Really Need to Know About Effort Certification

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Title: What You Really, Really Need to Know About Effort Certification


1
What You Really, Really Need to Know About Effort
Certification
Office of Research Sponsored Programs
2
What is Effort Certification?
  • Effort Certification is our means of providing
    assurance to sponsors that faculty and staff have
    met their commitments, paid or unpaid, to
    extramural projects
  • Its required by federal regulation and
    University policy for all individuals working on
    sponsored projects
  • 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 systemis
being implemented right now!
3
Why Should We Care?
  • Effort commitments and certification are the
    subject of much attention from federal sponsors
    and auditors
  • Erroneously certifying effort can be viewed as
    fraud
  • Sanctions can apply to both the institution and
    the individual

4
Recent Institutional Audits and Fines
  • Northwestern University 5.5 million (2003)
  • Johns Hopkins University (for one investigator)
    2.6 million (2004)
  • East Carolina University 2.4 million (2004)
  • Harvard University/Beth Israel Deaconess Medical
    Center 3.25 million (2000 2004)
  • Dartmouth 37,780 (2005)
  • University of Connecticut - 2.5 million (2006)

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

6
What Counts in Your 100 Effort?
Sponsored Project Activities
  • 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)
  • 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
  • ... even if your salary is not completely paid by
    thesponsor (i.e. salary cost sharing)

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

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

9
Pay Sources Should Reasonably Reflect Activity
OMB Circular A-21 J10b(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
10
Who Certifies the Effort Statement?
  • An individuals effort must be certified by
    aresponsible person with suitable means of
    verifying that the work was performed.
  • Each faculty member, academic staff member, and
    PI is responsible for certifying his/her own
    effort
  • PIs certify for graduate students, postdocs, and
    non-PI classified staff
  • 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.

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

12
How to Certify (continued)
  • 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.
  • If it is a reasonable estimate for the time
    period
  • Certify by clicking the Certify button
  • Otherwise
  • Work with your department administrator and
    effort coordinator or RSP to revise the Effort
    Statement before you certify it

13
Sample Effort Statement
14
Red Flag Issues
  • Late effort certification
  • Effort certified by someone without suitable
    means of verification
  • A distribution of effort that leaves too little
    non-sponsored time to credibly cover teaching,
    administrative, or other university duties

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

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

17
Help is Available
  • Your department administrators and effort
    coordinators
  • Your deans office
  • Research and Sponsored Programs
    (effort_at_rsp.wisc.edu)

Reference materials are located
at www.rsp.wisc.edu/effort
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