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The Top Ten Things You Should Know Today about Effort on Sponsored Projects. Office of Extramural Support University of Wisconsin-Extension October 2007.
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The Top Ten Things You Should Know Today about Effort on Sponsored Projects Office of Extramural Support University of Wisconsin-Extension October 2007
The most important obstacles in effort reporting compliance are misunderstanding and denial, and sometimes one obstacle feeds on the other. A Warning Robert J. Kenney, Jr. Director, Grants and Contracts Practice Hogan and Hartson LLP, Washington, DC “Time and Effort Reporting: Overview and Risk Assessment” Report on Research Compliance, January 2006
Why are we talking about this? • The federal government has made effort reporting a top target for audits. • NSF’s Office of the Inspector General (OIG) is making the rounds of research universities. • The Department of Justice is involved, filing charges under the False Claims Act. • Many universities have had to pay millions of dollars in fines.
Top 10 Concepts • Effort is your work on a project, whether the sponsor pays your salary or not. • When you write yourself into a grant proposal, you are committing your effort to the sponsor.
Top 10 Concepts • If you reduce your effort, paid or unpaid, on a federal grant by 25%, you must have agency approval. If you reduce your paid effort, you may choose to document cost-sharing so that the total effort does not decrease.
Top 10 Concepts • Many activities cannot be charged to a federally sponsored project. For example, the time you spend on these activities cannot be charged: • Writing a proposal • Serving on an IRB, IACUC or other research committee • Serving on a departmental or university service committee
Top 10 Concepts • If you work on a sponsored project, you must certify your effort. • Certifying effort is not the same as certifying payroll.
Top 10 Concepts • Certification must reasonably reflect all the effort for all the activities that are covered by your UW compensation. • Effort is not based on a 40-hour work week.
Top 10 Concepts • Effort must be certified by someone with a suitable means of verifying that the work was performed. • Auditors look for indications that certification was based on factors other than actual, justifiable effort.
Where is this coming from? • This is federal policy. • It’s not new; it may just sound unfamiliar. • Recent aggressive federal audits have resulted in multi-million dollar fines at research universities.
There’s more to it than this, but… • These ten concepts are the foundation for everything else. • Effort must be certified using the Effort Certification and Reporting Technology (ECRT) System.
Where to go for more info • Watch the website www.uwex.edu/business-services/extramural/effort. Documentation and training materials will be available • Questions? Contact ecrt-manager@uwex.edu