What You Really, Really Need to Know About Effort Certification

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

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 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? • 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:

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 individual’s 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 individual’s 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 dean’s office • Research and Sponsored Programs (effort@rsp.wisc.edu) Reference materials are located at www.rsp.wisc.edu/effort