What You Really, Really Need to Know About Effort Certification

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Office of Extramural Support
University of Wisconsin-Extension
What You Really, Really
Need to Know About
Effort Certification
7/27/2016
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What is Effort Certification?
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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?
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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
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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?
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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:
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Sponsored project activities
Non-sponsored activities, such as:
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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:
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This is your effort on:
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Activities you can allocate to a sponsored project include:
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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
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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?
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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
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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:
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teaching schedules
outside activity forms
“other support” forms
leave reports
clinical time reports and schedules
calendars
correspondence
How to Certify (continued)
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“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.”
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If it is a reasonable estimate for the time period:
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Certify by clicking the Certify button
Otherwise:
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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
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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)
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Post-certification revisions
Significant data inconsistency between the
Effort Statement and other documentation such
as:
Outside activity forms
 Other support forms
 Leave reports
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Points to Remember
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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
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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
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