Effort Coordinator Training
The UW Effort Project Team
Ruth Fruehling  Chip Quade
October, 2007
Research and Sponsored Programs
The Graduate School
University of Wisconsin–Madison
Introduction
• Background
• What we’re going to cover today
• Why is this important?
Effort Project: Kicked off in June 2006
•
Assess current business processes related to effort
management
•
Identify opportunities for improvement
•
Retire the PAR system
•
Launch a Web-based effort certification system
–
Effort Certification and Reporting Technology
(ECRT)
•
Improve policies and procedures
•
Raise the level of understanding about effort
Today’s topics
•
Effort 101 – includes:
– Basics of effort on sponsored projects
– UW-Madison effort reporting policies
•
Key business process changes
•
Key ECRT concepts
•
ECRT demonstration – includes:
– How faculty and staff use ECRT to certify effort
– What you will do (with ECRT, and in general)
•
Special circumstances and how to handle them
Why is this important?
•
•
“Effort” is important because:
–
Federal regulations about effort are very specific
–
The principles may not be well understood at UW-Madison
–
Effort reporting is a hot topic among auditors
We're conducting this training because:
–
Certification with ECRT starts November 1, 2007
–
Faculty and staff will get training too: either on-line or in
person
–
Faculty and staff will be instructed to contact you for
assistance
–
You play a key role in the effort management process
Effort Basics, Part I:
Fundamental principles
What is “Effort”?
•
The time you spend on an activity, expressed as a
percentage of all the time you spend on your UW job
duties
What is Effort Certification?
•
If you work on a sponsored project, you're required to
assure the sponsor that:
1. You did, in fact, devote effort to the project at a
level that corresponds with how you were paid from
the project
2. You've met your commitments of effort to the
project, regardless of whether the sponsor
provided salary support
•
What’s new about this?
–
Nothing, but people may not have been thinking
about it this way!
It's not an exact science
•
Precise accounting is not required
•
Sponsors recognize that research, teaching, service,
and administration are often inextricably intermingled
•
Reasonable estimates are expected
–
But there are some rules to follow!
Certifying 100% of your UW Effort
•
If you work on a sponsored project, what's important is
the effort on that project in relation to your other effort
•
Therefore, you must certify 100% of your UW effort
– The current PAR forms show only effort on federal
sponsored projects (and not even all of it!)
Okay, what does “100% effort” mean?
•
Effort is not based on a 40-hour work week
•
100% equals all the activities for which you are
compensated by the UW, regardless of the
appointment percent or number of hours worked
•
Examples:
– If you work a half-time job, your 100% = what you
do for that 0.5 FTE appointment
– If you work 80 hours a week, your 100% = what
you do during those 80 hours
Sponsored and Non-Sponsored Activities
•
The federal government is very specific about the
activities that are allocable to sponsored projects
–
•
Example:
•
Mentoring a graduate student is a sponsored
activity if it's specific to a sponsored project
•
Otherwise, it's instruction – a non-sponsored
activity
When determining your effort distribution, you must
distinguish between activities that are allocable to
sponsored projects and those that are not
Putting it all together
• The pie represents your
UW effort
• The challenge is to
figure out:
– How big is the whole
pie?
– What is the relative
size of the slices?
Sponsored Activity
Non-Sponsored Activity
Effort Basics, Part II: Assuring that
salary charges are reasonable, given
the work that was performed
What counts as UW effort?
•
The activities for which you are compensated by the
UW
•
This includes:
– Externally sponsored research
– Internally-funded or unfunded research
– Instruction, administration, and service on
committees
– Public service and outreach activities directly
related to your UW professional duties
What is outside of UW effort?
•
Activities for which someone else compensates you,
and some activities for which you are not paid
•
Examples:
–
Consulting
–
Leadership in professional societies
–
Peer review of manuscripts
–
Advisory activities for a sponsor (NIH study
section, or NSF peer review panel)
–
Clinical activity funded by the UWMF
–
Activity for a VA appointment
What counts as sponsored activity?
•
Activities contributing to and intimately related to
work under the agreement
•
As long as it's about the specific project, it counts as
sponsored activity:
•
–
Lab meetings, conferences, seminars
–
Writing a progress report
Reading journals to keep up to date on the subject
area is sponsored activity
Some specifics:
•
Writing a proposal for a new project or competing
continuation does NOT count as a sponsored activity
–
A problem for PIs who are funded 100% on
sponsored projects!
•
Lab meetings not specific to a project do not count
as sponsored activity
•
Research patient care
–
The care that is described in the protocol is
sponsored activity
–
Routine patient care is not, even if provided to a
research subject
Effort that's too small to count
•
Activities that you do on an infrequent, irregular basis
can be ignored in your effort calculations if the total
amount of time would not affect your effort distribution
–
•
Possible examples: department meetings, serving
on a search committee – depending on your
individual situation
Some activities should not be counted as separate
from your UW job duties, such as:
–
Requesting your parking assignment
–
Completing a travel expense report
•
Regular, well-defined activities cannot be de minimis
•
Proposal writing cannot be de minimis
Reasonable estimates and the degree of
tolerance
•
There is an acceptable variance between your actual
effort and the effort as certified on the statement
•
The UW defines this to be: five percentage points out
of your 100% UW effort
•
Example:
–
Effort statement shows 50% of your salary was
paid by the sponsored project
–
No cost sharing
–
It is permissible to certify 50% effort on the project
if your actual effort on the project could reasonably
be determined to fall between 45% and 55% of
your total UW effort
A word of caution
•
If you are paid 100% on sponsored projects, and…
•
If you spend 5% of your time on regular, well-defined
committee work or administration or if you write grant
proposals:
•
–
The five percent rule does NOT mean that you
can certify 100% of your effort on sponsored
projects
–
It only describes a degree of tolerance in certifying
for a single project
You cannot charge salary to the sponsor for activities
that are not allocable to sponsored projects!
"Unfunded" or "weekend" work?
•
Activities that are closely associated with your UW
professional duties must be reported as UW effort
•
Examples:
– Proposal writing
– Instruction, administration, service on committees
•
You cannot characterize them as "unfunded" or
"volunteer" activities, or "weekend work," for which no
UW salary is paid
Effort Basics, Part III: Assuring that
commitments to sponsored projects
have been met
What is a commitment?
•
The amount of effort you propose in a grant proposal
or other project application, and that the sponsor
accepts – regardless of whether you request salary
support for the effort
•
Specific and quantified
•
Example:
–
You propose 30% effort for twelve months
–
You request salary support for 10% of your effort
•
The effort commitment is 30%
For whom are commitments recognized?
•
The principal investigator/project director
•
All co-investigators
•
All individuals identified as senior/key personnel in the
grant proposal
–
When the proposal does not explicitly list key
persons, the university defines key personnel for
the purpose of effort reporting as the principal
investigator/project director and all co-investigators
Where are commitments indicated?
•
Some statements in the proposal become
commitments when the university and the sponsor
finalize the award agreement:
–
Requests for salary support and statements about
cost-shared effort in the budget or budget
justification
–
Effort proposed in the narrative – but only when
specific and quantified:
•
Example: "Professor Jones will devote 10% of
his time during the academic year to this
project."
Actual effort can vary over time
•
To meet a commitment, the actual effort need not be a
constant
•
It must add up, over time, to fulfill the commitment
•
Example: If 30% effort is committed for a calendar
year, one way to fulfill this commitment is by spending:
–
40% effort on the project during the first six months
of the year, and
–
20% effort on the project during the last six months
PI's minimum commitment of effort
• The PI/PD's minimum required commitment to each
project is 1% effort, except for:
– When an individual is the PI on multiple clinical trials
• The commitment to any one trial may be less than
1%, as long as the sum of all the commitments
represents a reasonable level of effort
– Equipment and instrumentation grants, doctoral
dissertation grants, and student augmentation
grants
When the awarded budget is less than
proposed
• You cannot assume that the effort commitments are
automatically reduced in proportion to the budget
reduction
• Your options are:
– Keep salaries and effort the same, and reduce other
budget categories
– Keep effort the same, reduce salaries, and
document the increase in cost sharing
– Reduce effort commitments – requesting prior
approval for a key person's reduction of 25% or
more
No-cost extensions
• Award terms and conditions apply throughout the
project period, including a no-cost extension period
• At the same time, sponsors recognize that PI effort may
be reduced as the project is winding down
• It is in the best interests of the institution and the PI to
notify the sponsor of a decrease in effort
Effort Basics, Part IV: Managing
effort over the lifetime of a project
The life cycle of effort
There’s more to it than just signing a form…
Salary charges must be consistent with
actual effort
• When you devote 40% effort for six months and 20%
for six months, it is not acceptable to:
– Charge salary at a constant 30% rate, or
– Certify effort at a constant 30% rate
• But a short-term fluctuation is acceptable:
– An effort deficit of not more than two months, with…
– Catch-up in a comparable period, such that it all
evens out
Some changes in effort require prior
approval from the sponsor
• A significant change in work activity is:
– A 25 percent (or greater) reduction in the level of
committed effort
– An absence from the project of three months or
more
– A withdrawal from the project
• For a PI/PD or key person as listed in the NOGA:
– A significant change in work activity requires prior
approval in writing from the sponsor's Grants
Officer
More about changes in effort
• Example:
– The PI's committed effort is 40%
– The PI wants to reduce it to 30%
– The drop is 25% of the original effort commitment,
so it requires prior written approval
• Other commitment changes must be documented:
– Any other change, for a person listed in the NOGA
– ANY change, for a key person listed in the proposal
but not in the NOGA
Rebudgeting
• PIs generally have some flexibility in managing project
budgets, including salary charges
• However, rebudgeting authority does not confer the
right to:
– Make significant changes in work activity without
prior approval
– Change effort commitments without documenting
the changes
• Rules for changing salary and effort are summarized on
the RSP Web site
UW-Madison effort certification
policies and procedures
Whose effort must be certified?
• Effort must be certified for all UW faculty, staff,
students, and postdoctoral researchers who either:
– Charge part or all of their salary directly to a
sponsored project, or
– Expend committed effort on a sponsored project,
even though no part of their salary is charged to the
project
Who certifies for whom?
• Effort must be certified by a responsible person with
suitable means of verifying that the work was
performed
• At the UW:
– All PIs, faculty, and academic staff members certify
for themselves
– PIs certify for the graduate students, postdocs, and
non-PI classified staff who work on their projects
More about who certifies for whom
• When the PI doesn't have suitable means of verifying
that the work was performed:
– A designee can certify the effort for project staff
• When a staff person works on projects for multiple PIs:
– Any one PI with suitable means of verifying all the
effort can certify, or…
– Individual PIs can each certify part of the effort
When must effort be certified?
• For classified staff: 4 times a year
– Periods of performance (PPs) correspond to
calendar quarters
• For everyone else: twice yearly
– PPs are January - June and July - December
• Certification starts a month or more after the PP
• The certification window is 90 days
• The schedule may be altered during the transition to
ECRT
How to determine effort for a six-month
period
• Some examples:
Activity
DOD Award A
NIH Award B
NSF Award C
Average
25%
20%
21%
Jan
50%
30%
5%
Feb
50%
30%
5%
Mar
50%
30%
5%
Apr
0%
20%
5%
May
0%
10%
5%
• Use the Effort Calculator that will be available from
within ECRT
– Check the “Add-on Tools” link
Jun
0%
0%
100%
Whose effort can be certified with
ECRT?
• Faculty, staff, graduate students, postdoctoral
researchers except:
– Those with no UW payroll
– Anyone who self-certifies, leaves the UW, and can
no longer log in with their NetID
• Student hourly effort is not certified via ECRT
– The timesheet serves as the mechanism for
certifying effort
Recertification
• Up to the certification deadline, you can grant a request
to recertify
– And you can reopen the statement for recertification
• After the certification deadline:
– The PI must submit a written request to RSP
– The written request will be reviewed by the
Associate Vice Chancellor for Research
Administration
– Only in the most compelling of circumstances will it
be granted
Important Changes in Business
Processes
Recap: Some things you’ve already
heard today
•
Researchers must certify effort, not payroll
•
The role of the Effort Coordinator will be significantly
different than the traditional role of the PAR
Coordinator
•
No more paper PARs
– The process for following up on uncertified
statements will be different
Certification and salary cost transfers
• If a salary cost transfer was initiated prior to
certification:
– Researchers should not wait for it to post before
certifying effort
• As a result of certification, a salary cost transfer can be
initiated to bring payroll into line with certified effort
– This is an appropriate and important part of
sponsored projects administration
• Effort certification guidelines do not change the existing
salary cost transfer policy
New treatment of cost-shared effort
• Know the distinction between four types of cost-shared
effort:
– Mandatory cost sharing
– Voluntary committed cost sharing
– Voluntary uncommitted cost sharing
– NSF Institutional cost sharing
• No changes for three of these, but a big change for one
of these!
Mandatory cost sharing
• Required by the sponsor as a condition for proposal
submission and award acceptance
– This effort was certified with the PAR system
– It will be pre-loaded into ECRT
– No real change: It will appear on the effort
statement, and it must be certified
Voluntary committed cost sharing
• Not required by the sponsor as a condition for proposal
submission, but once offered and accepted it becomes
a commitment
– It was not possible (or required) to certify this on
the PAR form
– This effort MUST be certified with ECRT
– For a while, this effort cannot be pre-loaded into
ECRT
– A certifier must ADD it to the effort that appears
on the statement
Voluntary uncommitted cost sharing
• Extra effort over and above an individual's commitment;
not pledged in the proposal or stated in the award
documents
– This effort is not auditable and should not be
documented or tracked
– It was not certified with the PAR system
– It will not be pre-loaded into ECRT
– Certifiers should not add it to the effort that appears
on the statement
NSF institutional cost sharing
• Not stated in the proposal, but established by the UW to
meet an NSF requirement (1% of costs on certain
unsolicited awards)
– This effort was certified with the PAR system
– It will be pre-loaded into ECRT
– No real change: It will appear on the effort
statement, and it must be certified
New treatment of commitments
• ECRT can track an individual's progress toward
meeting commitments
• Data about commitments will be loaded into ECRT
when it becomes available, starting when the Grants
system goes live
• Many business processes related to commitments will
be rolled out at that time
Key ECRT Concepts
Time periods
• Period of performance
– The semiannual or quarterly time period for which
effort must be certified
• Certification period (or certification window)
– The time during which:
• Faculty and staff certify effort
• You review and process the certifications
Effort statement
• The ECRT web page on which certifiers:
– View the payroll distribution and cost-sharing
amounts
– Enter and certify the effort distribution
• Once certified, this becomes an official university
document and is subject to audit
• Also called an effort certification card or effort card
Reminder!
• A sponsored project has:
– a scope of work
– a budget
– specific terms and conditions
What an effort statement looks like
We’ll explain the various columns later!
Sponsored and non-sponsored pay
sources
• For the purpose of effort certification, sponsored effort
includes:
– Fund 133 – Non-Federal Projects (except gifts)
– Fund 142 – Hatch Adams - Land Grant Research
– Fund 143 – Smith Lever - Land Grant Extension
– Fund 144 – Federal Projects
• Non-sponsored pay sources are: everything else
The certifier's primary department
• Based on information in the UW HR/Appointment
system
• Determines which effort coordinator will process the
statement
• For people with multiple appointments:
– A true "primary department" can't always be
determined from HR data
– The ECRT primary department may not be correct
and can be changed within ECRT
You are at the center of the process
Academic
Staff
Certifiers
Dean’s Office
Faculty
Certifiers
Effort Coordinator
Department
HR Coordinator
RSP
Department
Research
Administrator
Department
Payroll
Coordinator
Primary and secondary effort
coordinators
• If a department has more than one effort coordinator
– Only the primary EC can process the effort
statements
– The secondary can view statements and reports,
enter notes, and assist certifiers but cannot process
a statement
Current effort versus historical effort
• An effort card is completed when:
– The statement has been certified, AND…
– You have processed the certification
• Once completed, it becomes a historical effort card
• Anything else is a current effort card
An effort statement’s life journey
Under
Construction
Ready for
Certification
Returned
Reopened for
Recertification
Certified
Processed
ECRT Demonstration
Special circumstances and how to
handle them
Special circumstances, part 1
• Graduate students, postdocs, and non-PI classified
staff who work on multiple sponsored projects for
different PIs:
– Who certifies their effort?
• See the Effort Coordinator’s Guide, page 63
• People with appointments in multiple departments:
– Is there more than one effort statement?
– Which effort coordinator processes the certification?
• See the Effort Coordinator’s Guide, page 72
Special circumstances, part 2
• People with appointments at more than one campus
(for example, Madison and Extension):
– Is there more than one statement?
• See the Effort Coordinator’s Guide, page 72
• People who change from classified to academic staff
positions during a period of performance:
– Is there more than one statement?
– Who should certify the effort?
• See the Effort Coordinator’s Guide, page 71
Special circumstances, part 3
• People who take a position in a new department during
a period of performance, even if the appointment type
doesn’t change:
– Which effort coordinator processes the certification?
• See the Effort Coordinator’s Guide, page 71
• People who leave the UW during a period of
performance:
– How do they certify before leaving?
– If they don’t certify before leaving, what happens?
• See the Effort Coordinator’s Guide, page 69
Special circumstances, part 4
• People with effort on sponsored projects but no UW
payroll, whose effort cannot be certified with ECRT:
– How is their effort certified?
• See the Effort Coordinator’s Guide, page 68