Effort Coordinator Training

The UW Effort Project TeamRuth Fruehling Chip Quade

October, 2007

Research and Sponsored ProgramsThe Graduate SchoolUniversity of Wisconsin–Madison

Introduction

• Background

• What we’re going to cover today

• Why is this important?

Effort Project: Kicked off in June 2006

• Assess current business processes related to effort management

• Identify opportunities for improvement

• Retire the PAR system

• Launch a Web-based effort certification system

– Effort Certification and Reporting Technology (ECRT)

• Improve policies and procedures

• Raise the level of understanding about effort

Today’s topics

• Effort 101 – includes:

– Basics of effort on sponsored projects

– UW-Madison effort reporting policies

• Key business process changes

• Key ECRT concepts

• ECRT demonstration – includes:

– How faculty and staff use ECRT to certify effort

– What you will do (with ECRT, and in general)

• Special circumstances and how to handle them

Why is this important?

• “Effort” is important because:

– Federal regulations about effort are very specific

– The principles may not be well understood at UW-Madison

– Effort reporting is a hot topic among auditors

• We're conducting this training because:

– Certification with ECRT starts November 1, 2007

– Faculty and staff will get training too: either on-line or in person

– Faculty and staff will be instructed to contact you for assistance

– You play a key role in the effort management process

Effort Basics, Part I:Fundamental principles

What is “Effort”?

• The time you spend on an activity, expressed as a percentage of all the time you spend on your UW job duties

What is Effort Certification?

• If you work on a sponsored project, you're required to assure the sponsor that:

1. You did, in fact, devote effort to the project at a level that corresponds with how you were paid from the project

2. You've met your commitments of effort to the project, regardless of whether the sponsor provided salary support

• What’s new about this?

– Nothing, but people may not have been thinking about it this way!

It's not an exact science

• Precise accounting is not required

• Sponsors recognize that research, teaching, service, and administration are often inextricably intermingled

• Reasonable estimates are expected

– But there are some rules to follow!

Certifying 100% of your UW Effort

• If you work on a sponsored project, what's important is the effort on that project in relation to your other effort

• Therefore, you must certify 100% of your UW effort

– The current PAR forms show only effort on federal sponsored projects (and not even all of it!)

Okay, what does “100% effort” mean?

• 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

Sponsored and Non-Sponsored Activities

• The federal government is very specific about the activities that are allocable to sponsored projects

– Example:

• Mentoring a graduate student is a sponsored activity if it's specific to a sponsored project

• Otherwise, it's instruction – a non-sponsored activity

• When determining your effort distribution, you must distinguish between activities that are allocable to sponsored projects and those that are not

Putting it all together

• The pie represents your UW effort

• The challenge is to figure out:

– How big is the whole pie?

– What is the relative size of the slices?

Sponsored Activity

Non-Sponsored Activity

Effort Basics, Part II: Assuring that salary charges are reasonable, given the work that was performed

What counts as UW 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

What is outside of UW 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

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 the subject area is sponsored activity

Some specifics:

• Writing a proposal for a new project or competing continuation does NOT count as a sponsored activity

– A problem for PIs who are funded 100% on sponsored projects!

• Lab meetings not specific to a project do not count as sponsored activity

• 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

Effort that's 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 cannot be de minimis

• Proposal writing cannot be de minimis

Reasonable estimates and the degree of tolerance

• There is an acceptable variance between your actual effort and the effort as certified on the statement

• The UW defines this to be: five percentage points out of your 100% UW effort

• Example:

– Effort statement shows 50% of your salary was paid by the sponsored project

– No cost sharing

– It is permissible to certify 50% effort on the project if your actual effort on the project could reasonably be determined to fall between 45% and 55% of your total UW effort

A word of caution

• If you are paid 100% on sponsored projects, and…

• If you spend 5% of your time on regular, well-defined committee work or administration or if you write grant proposals:

– The five percent rule does NOT mean that you can certify 100% of your effort on sponsored projects

– It only describes a degree of tolerance in certifying for a single project

• You cannot charge salary to the sponsor for activities that are not allocable to sponsored projects!

"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

Effort Basics, Part III: Assuring that commitments to sponsored projects have been met

What is a commitment?

• The amount of effort you propose in a grant proposal or other project application, and that the sponsor accepts – regardless of whether you request salary support for the effort

• Specific and quantified

• Example:

– You propose 30% effort for twelve months

– You request salary support for 10% of your effort

• The effort commitment is 30%

For whom are commitments recognized?

• 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

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 narrative – but only when specific and quantified:

• Example: "Professor Jones will devote 10% of his time during the academic year to this project."

Actual 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

PI's minimum commitment of effort

• The PI/PD's minimum required commitment to each project is 1% effort, except for:

– 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

When the awarded budget is less than proposed

• You cannot assume that the effort commitments are automatically reduced in proportion to the budget reduction

• Your options are:

– 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

No-cost extensions

• Award terms and conditions apply throughout the project period, including a no-cost extension period

• At the same time, sponsors recognize that PI effort may be reduced as the project is winding down

• It is in the best interests of the institution and the PI to notify the sponsor of a decrease in effort

Effort Basics, Part IV: Managing effort over the lifetime of a project

The life cycle of effort

There’s more to it than just signing a form…

Salary charges must be consistent with actual effort

• When you devote 40% effort for six months and 20% for six months, it is not acceptable to:

– Charge salary at a constant 30% rate, or

– Certify effort at a constant 30% rate

• But a short-term fluctuation is acceptable:

– An effort deficit of not more than two months, with…

– Catch-up in a comparable period, such that it all evens out

Some changes in effort require prior approval from the sponsor

• A significant change in work activity is:

– A 25 percent (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

More about changes in effort

• Example:

– The PI's committed effort is 40%

– The PI wants to reduce it to 30%

– The drop 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

Rebudgeting

• 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

UW-Madison effort certification policies and procedures

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

Who certifies for whom?

• 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

More about who certifies for whom

• 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

When must effort be certified?

• For classified staff: 4 times a year

– Periods of performance (PPs) correspond to calendar quarters

• For everyone else: 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

How to determine effort for a six-month period

• Use the Effort Calculator that will be available from within ECRT

– Check the “Add-on Tools” link

Activity

Average

DOD Award A 25%

NIH Award B 20%

NSF Award C 21%

Jan Feb Mar Apr May Jun

50% 50% 50% 0% 0% 0%

30% 30% 30% 20% 10% 0%

5% 5% 5% 5% 5% 100%

• Some examples:

Whose effort can be certified with ECRT?

• Faculty, staff, graduate students, postdoctoral researchers except:

– Those with no UW payroll

– Anyone who self-certifies, leaves the UW, and can no longer log in with their NetID

• Student hourly effort is not certified via ECRT

– The timesheet serves as the mechanism for certifying effort

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

Important Changes in Business Processes

Recap: Some things you’ve already heard today

• Researchers must certify effort, not payroll

• The role of the Effort Coordinator will be significantly different than the traditional role of the PAR Coordinator

• No more paper PARs

– The process for following up on uncertified statements will be different

Certification and salary cost transfers

• 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

New treatment of cost-shared effort

• Know the distinction between four types of cost-shared effort:

– Mandatory cost sharing

– Voluntary committed cost sharing

– Voluntary uncommitted cost sharing

– NSF Institutional cost sharing

• No changes for three of these, but a big change for one of these!

Mandatory cost sharing

• Required by the sponsor as a condition for proposal submission and award acceptance

– This effort was certified with the PAR system

– It will be pre-loaded into ECRT

– No real change: It will appear on the effort statement, and it must be certified

Voluntary committed cost sharing

• Not required by the sponsor as a condition for proposal submission, but once offered and accepted it becomes a commitment

– It was not possible (or required) to certify this on the PAR form

– This effort MUST be certified with ECRT

– For a while, this effort cannot be pre-loaded into ECRT

– A certifier must ADD it to the effort that appears on the statement

Voluntary uncommitted cost sharing

• Extra effort over and above an individual's commitment; not pledged in the proposal or stated in the award documents

– This effort is not auditable and should not be documented or tracked

– It was not certified with the PAR system

– It will not be pre-loaded into ECRT

– Certifiers should not add it to the effort that appears on the statement

NSF institutional cost sharing

• Not stated in the proposal, but established by the UW to meet an NSF requirement (1% of costs on certain unsolicited awards)

– This effort was certified with the PAR system

– It will be pre-loaded into ECRT

– No real change: It will appear on the effort statement, and it must be certified

New treatment of commitments

• ECRT can track an individual's progress toward meeting commitments

• Data about commitments will be loaded into ECRT when it becomes available, starting when the Grants system goes live

• Many business processes related to commitments will be rolled out at that time

Key ECRT Concepts

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

Effort statement

• 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

• Also called an effort certification card or effort card

Reminder!

• A sponsored project has:

– a scope of work

– a budget

– specific terms and conditions

What an effort statement looks like

We’ll explain the various columns later!

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

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

You are at the center of the process

FacultyCertifiers

RSP

DepartmentResearch

Administrator

DepartmentPayroll

Coordinator

DepartmentHR Coordinator

Dean’s Office

AcademicStaff

Certifiers

Effort Coordinator

Primary and secondary effort coordinators

• If a department has more than one effort coordinator

– Only the primary EC can process the effort statements

– The secondary can view statements and reports, enter notes, and assist certifiers but cannot process a statement

Current effort versus historical effort

• An effort card is completed when:

– The statement has been certified, AND…

– You have processed the certification

• Once completed, it becomes a historical effort card

• Anything else is a current effort card

An effort statement’s life journey

UnderConstruction

Ready forCertification

Reopened forRecertification

Returned

Certified Processed

ECRT Demonstration

Special circumstances and how to handle them

Special circumstances, part 1

• Graduate students, postdocs, and non-PI classified staff who work on multiple sponsored projects for different PIs:

– Who certifies their effort?

• See the Effort Coordinator’s Guide, page 63

• People with appointments in multiple departments:

– Is there more than one effort statement?

– Which effort coordinator processes the certification?

• See the Effort Coordinator’s Guide, page 72

Special circumstances, part 2

• People with appointments at more than one campus (for example, Madison and Extension):

– Is there more than one statement?

• See the Effort Coordinator’s Guide, page 72

• People who change from classified to academic staff positions during a period of performance:

– Is there more than one statement?

– Who should certify the effort?

• See the Effort Coordinator’s Guide, page 71

Special circumstances, part 3

• People who take a position in a new department during a period of performance, even if the appointment type doesn’t change:

– Which effort coordinator processes the certification?

• See the Effort Coordinator’s Guide, page 71

• People who leave the UW during a period of performance:

– How do they certify before leaving?

– If they don’t certify before leaving, what happens?

• See the Effort Coordinator’s Guide, page 69

Special circumstances, part 4

• People with effort on sponsored projects but no UW payroll, whose effort cannot be certified with ECRT:

– How is their effort certified?

• See the Effort Coordinator’s Guide, page 68