certification by kA22k6

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									          Office of Extramural Support
        University of Wisconsin-Extension



       What You Really, Really
        Need to Know About
         Effort Certification
1/14/2012                                   1
        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
   Starting November 2007, UW-Madison, UW-
    Milwaukee, and UW Extension, will use the Effort
    Certification and Reporting Technology (ECRT)
    system.
           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
   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?
   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
    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 project)
   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)
 What Counts in Your 100% Effort?
Non-Sponsored Activities:
 Teaching

 Serving as a department chair, and other
  administrative duties
 Serving on university committees

 Attending general departmental faculty
  meetings
 Public service and outreach
    Activities NOT Included in Your
             100% UW Effort
   Outside consulting
   Serving on an NIH study section or an NSF
    peer review panel
 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?
   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/PD is
    responsible for certifying his/her own effort
   PIs/PDs certify for graduate students and classified staff
   There are some exceptions made for practical reasons (e.g.
    someone other than the PI/PD of a large Center grant has better
    knowledge of the work that was performed). Contact your
    department effort coordinator or OES for help with exceptions.
                      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)
   “I certify that the salary changed, including any salary transfers,
    and the effort certified this period reasonably reflect the work
    performed. I further certify that I am in a position that provides
    me with a 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 OES to revise the Effort Statement before
         you certify it
Sample Effort Statement
                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)
   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
   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
   Your department administrators and effort
    coordinators
   Your dean’s office
   Office of Extramural Support (ecrt-
    manager@uwex.edu)

          Reference materials are located at
    www.uwex.edu/business-services/extramural/effort

								
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