Office of Extramural Support University of Wisconsin-Extension What You Really, Really Need to Know About Effort Certification 7/27/2016 1 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 It’s required by federal regulation and University policy for all individuals working on sponsored projects Starting November 2007, UW-Madison, UWMilwaukee, and UW Extension, will use the Effort Certification and Reporting Technology (ECRT) system. 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 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) 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 related to your UW duties What Counts in Your 100% Effort? Sponsored Project Activities: This is your effort on: Activities you can allocate to a sponsored project include: Federal grants or contracts (e.g. NIH, NSF, DOD) Non-federal research projects (e.g. a foundation grant or industry sponsored project) 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 the sponsor (i.e. salary cost sharing) 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 Activities NOT Included in Your 100% UW Effort Outside consulting Serving on an NIH study section or an NSF peer review panel 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% Who Certifies the Effort Statement? An individual’s effort must be certified by a responsible person with suitable means of verifying that the work was performed. Each faculty member, academic staff member, and PI/PD is responsible for certifying his/her own effort PIs/PDs certify for graduate students and classified staff There are some exceptions made for practical reasons (e.g. someone other than the PI/PD of a large Center grant has better knowledge of the work that was performed). Contact your department effort coordinator or OES for help with exceptions. 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 How to Certify (continued) “I certify that the salary changed, including any salary transfers, and the effort certified this period reasonably reflect the work performed. I further certify that I am in a position that provides me with a 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 OES to revise the Effort Statement before you certify it Sample Effort Statement 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 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 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 individual’s own average work week. Effort reporting tracks the reasonable approximation of actual activity on projects and should not simply mimic budgeted amounts Help is Available Your department administrators and effort coordinators Your dean’s office Office of Extramural Support (ecrtmanager@uwex.edu) Reference materials are located at www.uwex.edu/business-services/extramural/effort