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

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what is effort certification
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!

why should we care
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
recent institutional audits and fines
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)
how is effort determined
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
what counts in your 100 effort
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)
what counts in your 100 effort1
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:

activities not included in your 100 uw effort
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
pay sources should reasonably reflect activity
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
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.
how to certify
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
how to certify continued
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
red flag issues
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
red flag issues continued
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
points to remember
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
help is available
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