Research & Sponsored Programs

1. Research & Sponsored Programs Effort Reporting: An Overview of Policy and Procedure

2. Agenda • Background: What is Effort Reporting? • UW-Madison Effort Policy • Key concepts • How to certify: The ECRT system • Special circumstances • Resources

3. Handouts and Resources Resources: • Effort homepage: www.rsp.wisc.edu/effort/index.html • UW-Madison Guidelines for Effort Reporting (https://www.rsp.wisc.edu/effort/ectraining/GuidelinesForEffortReporting.pdf) • UW-Madison Effort Coordinator’s Guide to Certification Practices and Procedures (https://www.rsp.wisc.edu/effort/ectraining/ECGuide.pdf) • Handouts

4. Background: What is Effort Reporting What is Effort Reporting? • Assuring an individual met his or her commitments • The sponsor got what it paid for • Assuring sufficient effort was devoted to justify salary charges • The sponsor paid for what it got Basically, an Effort Report is… a receipt.

5. Background: What is Effort Reporting The basic idea • In a grant proposal, we offer effort • At award time, we make a commitment of effort • Throughout the project, we charge salary to the sponsor • Periodically, sponsors want to know: • Have we devoted enough effort to justify the salary charges? • Even in cases where we are not charging salary to the sponsor, have we fulfilled our commitments? • Precision is not required: Reasonable estimates are expected

6. Background: What is Effort Reporting Authority • As recipients of federal funding, educational institutions must abide by OMB Circular A-21 (Cost Principles for Educational Institutions) • A-21, Section J.10 outlines acceptable methods for supporting charges related to “compensation for personal services” on federal grants and contracts • OMB A-21, J.10: “the reports will be signed by the employee, PI or responsible official(s) using suitable means of verification that the work was performed” • Direct knowledge not needed • First hand supervision not needed

7. Background: What is Effort Reporting Use of Effort ReportsBackground: What is Effort Reporting Government Use: • Verify that labor charges are appropriate based on the amount of work performed • Verify that effort commitments and cost sharing is performed as promised • Verify that sponsored research is appropriately classified (i.e., included in Organized Research F&A base) Institution Use: • Management reporting tools • Are faculty and others working in areas as expected or promised? • Is payroll distribution appropriate? • Where is labor cost sharing occurring? • May be used for other reporting purposes (state teaching requirements, Medicare time reporting)

8. Background: What is Effort Reporting Who certifies? • Certification is required for individuals who have paid or committed effort on sponsored projects • Effort must be certified by a person who has “suitable means of verifying” that the work was performed • Faculty, academic staff, and all PIs certify their own effort • PIs certify for graduate students, postdocs, and non-PI classified staff who work on their projects

9. Background: What is Effort Reporting What the regulations require us to do… • Be careful about what we offer in a proposal • Be careful when making commitments at award time • Change commitments when needed, and document the changes • Fulfill commitments • Charge salary in a way that’s congruent with actual effort • Certify effort in a way that’s congruent with what actually happened

10. Background: What is Effort Reporting What the regulations require us to do… • Not charge a grant for time that doesn’t pertain to the grant • Not charge a grant for time spent writing a proposal for a new project or a competing continuation • Time spent on these activities must be covered by institutional or gift funds • Transfer salary charges off of a grant if the level of effort does not justify the salary charges

11. Background: What is Effort Reporting …And why we do it right. • The consequences of not getting this right can be dire for the university • Effort reporting remains a target for federal auditors • Many universities have paid millions of dollars in fines • Audits are underway at peer research institutions

12. Commitments are Fulfilled Tracking and Management Background: What is Effort Reporting PROPOSAL: Commitments are Offered AWARD: Commitments Become Obligations Commitment Setup Lifecycle of a Grant Documentation & Reporting of Fulfillment

13. UW-Madison Effort Policy: Who, What, When, Where, and Why Who: Whose Effort must be certified? • Effort must be certified for all UW faculty, staff, students, and postdoctoral researchers who either: • Charge part or all of their salary directly to a sponsored project, or • Expend committed effort on a sponsored project, even though no part of their salary is charged to the project

14. UW-Madison Effort Policy: Who, What, When, Where, and Why Who certifies? • Effort must be certified by a responsible person with suitable means of verifying that the work was performed • At the UW: • All PIs, faculty, and academic staff members certify for themselves • PIs certify for the graduate students, postdocs, and non-PI classified staff who work on their projects • When the PI doesn't have suitable means of verifying that the work was performed: • A designee can certify the effort for project staff • When a staff person works on projects for multiple PIs: • Any one PI with suitable means of verifying all the effort can certify or… • Individual PIs can each certify part of the effort

15. UW-Madison Effort Policy: Who, What, When, Where, and Why What is required? • Effort certification and effort training are mandatory • Penalties for non-compliance: The UW will not provide support for extramural activities • Precision is not required in certifying effort • Reasonable estimates are expected

16. UW-Madison Effort Policy: Who, What, When, Where, and Why What is required? • Recertification—up to the certification deadline, you can grant a request to recertify, and you can reopen the statement for recertification • After the certification deadline: • The PI must submit a written request to RSP • The written request will be reviewed by the Associate Vice Chancellor for Research Administration • Only in the most compelling of circumstances will it be granted

17. UW-Madison Effort Policy: Who, What, When, Where, and Why When to certifyand take training: • For classified staff: 4 times / year • Periods of performance (PPs) correspond to calendar quarters • For faculty, academic staff, grad students, and postdocs: twice yearly • PPs are January - June and July - December • Certification starts a month or more after the PP • The certification window is 90 days • The schedule may be altered during the transition to ECRT • Training is required just once—it does not need to be repeated • Training must be done within 90 days of the date on which the person’s first effort statement is available for certification in ECRT (see p. 14 in the Effort Guide) • Training takes 30-40 minutes to complete

18. UW-Madison Effort Policy: Who, What, When, Where, and Why Where to certify: ECRT • An electronic system where individuals certify their effort and where ECs process effort cards • Produced and managed by Huron Consulting

19. UW-Madison Effort Policy: Who, What, When, Where, and Why Why is there an Effort Coordinator (EC) role? What does the EC do? • Review each certification • Initiate any follow-up actions, if necessary (including salary cost transfers, to make payroll congruent with effort) • Document the reasons for any differences between pre-printed effort numbers and certified effort percentages • Approve (or process) each correct certification • Assist certifiers • Keep tabs on who has and hasn’t certified, and nudge delinquents in the right direction

20. UW-Madison Effort Policy: Who, What, When, Where, and Why Why is there an Effort Coordinator (EC) role? What does the EC do? • Four key questions ECs must ask for every card before processing: • What is the effort commitment? • What actually happened? • What were the salary charges? • How much effort was certified in ECRT? • Tools are available to help with ECs monitor and manage effort certification • Help and information are available • Effort Guidance document • EC Guide • Online resources • Handouts

21. Commitments are Fulfilled Tracking and Management Key Concepts PROPOSAL: Commitments are Offered AWARD: Commitments Become Obligations Commitment Setup Lifecycle of a Grant Documentation & Reporting of Fulfillment

22. Key Concepts

23. Key Concepts: Commitments • A statement in the proposal or project application • Specific and quantified • Effort for a PI, co-investigator, or key person, regardless of whether salary is charged • An obligation that the university must fulfill • Example – Professor Jones proposes 30% of her effort for 12 months and requests 10% salary support: • Professor Jones has committed 30% of her effort for that 12-month period

24. Key Concepts: Commitments Commitments Effort Non-Effort PaidEffort Cost-Shared Effort Non-Payroll Cost Sharing Not Paid By Sponsor

25. Key Concepts: Commitments Minimum commitment required; Changing commitments • Minimum commitment: The PI/PD's minimum required commitment to each project is 1% effort, • Exceptions to minimum commitment rule: • When an individual is the PI on multiple clinical trials • The commitment to any one trial may be less than 1%, as long as the sum of all the commitments represents a reasonable level of effort • Equipment and instrumentation grants, doctoral dissertation grants, and student augmentation grants • Commitments can be changed • Some changes require prior written approval from the sponsor • All other changes must be documented • A note in the department administrator’s project file • An email exchange • A note in the ECRT system

26. Key Concepts: Commitments Rebudgeting vs. Changing the level of committed effort: • PIs generally have some flexibility in managing project budgets, including salary charges • However, rebudgeting authority does not confer the right to: • Make significant changes in work activity without prior approval • Change effort commitments without documenting the changes • Rules for changing salary and effort are summarized on the RSP Web site

27. Key Concepts: Commitments For whom are commitments required? • The principal investigator/project director • All co-investigators • All individuals identified as senior/key personnel in the grant proposal • When the proposal does not explicitly list key persons, the university defines key personnel for the purpose of effort reporting as the principal investigator/project director and all co-investigators

28. Key Concepts: Commitments Where are commitments indicated? • Some statements in the proposal become commitments when the university and the sponsor finalize the award agreement: • Requests for salary support and statements about cost-shared effort in the budget or budget justification • Effort proposed in the research plan or project description – but only when specific and quantified: • Example: "Professor Jones will devote 10% of his time during the academic year to this project."

29. Key Concepts: Commitments Limits on total commitments • Commitments can never total more than 100% • Commitments to sponsored projects can add up to a full 100% only if ALL of your UW job duties can be allocated to sponsored projects • This is generally not the case for faculty members, for any consecutive 12-month period • Can academic staff, postdocs, classified staff be paid 100% from sponsored projects? • This is not against the rules, and it’s entirely appropriate in many, but not all, circumstances

30. Key Concepts: Commitments When the awarded budget is less than proposed • You cannot assume that the effort commitments are automatically reduced in proportion to the budget reduction • You have several options: • Keep salaries and effort the same, and reduce other budget categories • Keep effort the same, reduce salaries, and document the increase in cost sharing • Reduce effort commitments – requesting prior approval for a key person's reduction of 25% or more

31. Key Concepts: Effort What is Effort? • Effort is not based on a 40-hour work week • 100% equals all the activities for which you are compensated by the UW, regardless of the appointment percent or number of hours worked • Examples: • If you work a half-time job, your 100% = what you do for that 0.5 FTE appointment • If you work 80 hours a week, your 100% = what you do during those 80 hours

32. Key Concepts: Effort What counts as Effort? • The activities for which you are compensated by the UW • This includes: • Externally sponsored research • Internally-funded or unfunded research • Instruction, administration, and service on committees • Public service and outreach activities directly related to your UW professional duties

33. Key Concepts: Effort UW Institutional Base Salary (IBS) • IBS Includes salary from these sources • Extramural grants, contracts, cooperative agreements from federal and nonfederal sponsors, UW hospital affiliation agreements, gifts, Federal formula Hatch funding, intramural grants, startup, retention, FFS, F&A return, endowment, State of WI GPR, extension funds, WARF funds • Regular Salary, Summer Salary, Regular Wages, Overtime for hourly, Sabbatical, Paid professional leave • IBS Excludes salary from these sources • UW Med Foundation Clinical Practice Plan (paid directly to an individual by the UWMF), VA Med Center, WARF royalties (paid directly to an individual), Outside professional work (consulting, peer review, etc..) • Bonus payments, temporary supplements, tuition remission, lump-sum payments

34. Key Concepts: Effort What does not count as Effort? • Activities for which someone else compensates you, and some activities for which you are not paid • Examples: • Consulting • Leadership in professional societies • Peer review of manuscripts • Advisory activities for a sponsor (NIH study section, or NSF peer review panel) • Clinical activity funded by the UWMF • Activity for a VA appointment

35. Key Concepts: Effort What counts as sponsored activity? • Activities contributing to and intimately related to work under the agreement • As long as it's about the specific project, it counts as sponsored activity: • Lab meetings, conferences, seminars, writing a progress report • Reading journals to keep up-to-date on subject area • Writing a proposal for a new project or competing continuation does NOT count • An issue for some people who are funded 100% on sponsored projects! • Lab meetings not specific toa project do NOT count • Research patient care • The care that is described in the protocol is sponsored activity • Routine patient care is NOT, even if provided to a research subject

36. Key Concepts: Effort Effort that is too small to count: • Activities that you do on an infrequent, irregular basis can be ignored in your effort calculations if the total amount of time would not affect your effort distribution • Possible examples: department meetings, serving on a search committee – depending on your individual situation • Some activities should not be counted as separate from your UW job duties, such as: • Requesting your parking assignment • Completing a travel expense report • Regular, well-defined activities generally should not be treated as de minimis • Proposal writing cannot be de minimis

37. Key Concepts: Effort Unfunded or “weekend” work: • Activities that are closely associated with your UW professional duties must be reported as UW effort • Examples: • Proposal writing • Instruction, administration, service on committees • You cannot characterize them as "unfunded" or "volunteer" activities, or "weekend work," for which no UW salary is paid

38. Key Concepts: Effort Effort can vary over time: • To meet a commitment, the actual effort need not be a constant • It must add up, over time, to fulfill the commitment • Example: If 30% effort is committed for a calendar year, one way to fulfill this commitment is by spending: • 40% effort on the project during the first six months of the year, and • 20% effort on the project during the last six months

39. Key Concepts: Effort Changes in Effort: • A significant change in work activity is: • A 25 %(or greater) reduction in the level of committed effort • An absence from the project of three months or more • A withdrawal from the project • For a PI/PD or key person as listed in the NOGA: • A significant change in work activity requires prior approval in writing from the sponsor's Grants Officer • Example: • The PI's committed effort is 40%. PI wants to reduce committed effort to 30% • The reduction is 25% of the original effort commitment, so it requires prior written approval • Other commitment changes must be documented: • Any other change, for a person listed in the NOGA • ANY change, for a key person listed in the proposal but not in the NOGA

40. Key Concepts: Effort Case Study – calculating effort: • Ron Burgandy is a 9 month faculty who is paid $140,000/year. Ron is awarded a grant from 7/1/12-12/8/12. His budget calls for him to be paid $20,000. What is his effort commitment? • Determine calendar months • $140,000/9 months = $15,555 monthly • Payroll yearly/monthly = $20,000/$15,555 = 1.3 salary months • Determine dates • 8 days in Dec = (8/31) = .26 months • + 5 full months from Jul-Dec = 5.26 project months • Calculate effort • 1.3 salary months/5.26 project months = 25% effort

41. Key Concepts: Cost Share What is Cost Share? • Cost sharing is the portion of the total costs of a sponsored project that is borne by the UW • Cost-shared effort is any work on a sponsored project for which the university, rather than the sponsor, provides salary support • Paid effort is work for which the sponsor provides salary support • Example – With a 30% effort commitment and salary support for 10% of the effort: • 10% is paid effort • 20% is cost-shared effort

42. Key Concepts: Cost Share Mandatory Cost Share vs. Voluntary Committed Cost Share: • Mandatory cost sharing is cost sharing that’s required by the sponsor as a condition for proposal submission and award acceptance • This is reflected on your statement • Voluntary committed cost sharing is cost sharing that is not required as a condition for proposal submission • But, once offered and accepted, it becomes a commitment • Currently, this is NOT reflected in the numbers you see when you log in • However, it must be certified; we’ll show you how

43. Key Concepts: Cost Share IMPORTANT: Cost sharing should be limited only to those situations where: • It is mandated by a sponsor, or • The University has determined that such a contribution is critical to ensure the success of a competitive award or proposal, or • It is necessary to fulfill the University’s requirement of a minimum commitment to the project by the principal investigator or project director. Where cost sharing is not required by the sponsor, necessary to ensure the competitiveness of a proposal, or required as a minimum commitment to the project, PIs and departments or centers/schools should refrain from making such commitments voluntarily. In all situations, the use of cost sharing should be kept to a reasonable level because of the burden that it places on University and departmental resources.

44. Key Concepts: Cost Share Voluntary Uncommitted Cost Share: • When you certify, you must include cost-shared effort up to and including the amount of your cost-sharing commitments • If you’ve put in more time than you were paid to spend, over and above your cost-sharing commitments: • This is voluntary uncommitted cost sharing • This extra effort is not required to be documented or tracked • You should not include it in the effort you certify for a sponsored project

45. Key Concepts: Salary Cost Transfers (SCTs) • If a salary cost transfer was initiated prior to certification: • Researchers should not wait for it to post before certifying effort • As a result of certification, a salary cost transfer can be initiated to bring payroll into line with certified effort • This is an appropriate and important part of sponsored projects administration • Effort certification guidelines do not change the existing salary cost transfer policy

46. Key Concepts: DHHS Salary Cap • See handout 6

47. How to Certify Time Periods: • Period of performance • The semiannual or quarterly time period for which effort must be certified • Certification period (or certification window) • The time during which: • Faculty and staff certify effort • You review and process the certifications

48. How to Certify • The ECRT web page on which certifiers: • View the payroll distribution and cost-sharing amounts • Enter and certify the effort distribution • Once certified, this becomes an official university document and is subject to audit

49. How to Certify Sponsored and non-sponsored pay sources: • For the purpose of effort certification, sponsored effort includes: • Fund 133 – Non-Federal Projects (except gifts) • Fund 142 – Hatch Adams - Land Grant Research • Fund 143 – Smith Lever - Land Grant Extension • Fund 144 – Federal Projects • Non-sponsored pay sources are: everything else

50. How to Certify The certifier’s primary department: • Based on information in the UW HR/Appointment system • Determines which effort coordinator will process the statement • For people with multiple appointments: • A true "primary department" can't always be determined from HR data • The ECRT primary department may not be correct and can be changed within ECRT