What You Really, Really Need to Know About Effort Certification Office of Research & Sponsored Programs

Slide 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 It’s 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 system is being implemented right now!

Slide 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

Slide 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)

Slide 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 related to your UW duties

Slide 6 What Counts in Your 100% Effort? 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 the sponsor (i.e. salary cost sharing) Sponsored Project Activities:

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

Slide 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

Slide 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%

Slide 10 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 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.

Slide 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

Slide 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

Sample Effort Statement

Slide 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

Slide 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

Slide 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 individual’s own average work week. Effort reporting tracks the reasonable approximation of actual activity on projects and should not simply mimic budgeted amounts

Slide 17 Help is Available Your department administrators and effort coordinators Your dean’s office Research and Sponsored Programs Reference materials are located at