The Top Ten Things The Top Ten Things You Should Know You Should Know TodayToday about about Effort on Sponsored ProjectsEffort on Sponsored Projects

Office of Research & Sponsored ProgramsMarch, 2007

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A WarningA Warning

The most important obstacles in effort reporting compliance are misunderstanding and denial, and sometimes one obstacle feeds on the other.

Robert J. Kenney, Jr.Director, Grants and Contracts PracticeHogan and Hartson LLP, Washington, DC“Time and Effort Reporting: Overview and Risk Assessment”Report on Research Compliance, January 2006

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Why are we talking about this?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.

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1. Effort is your work on a project, whether the sponsor pays your salary or not.

2. When you write yourself into a grant proposal, you are committing your effort to the sponsor.

Top 10 Concepts

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3. 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

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4. 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

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5. If you work on a sponsored project, you must certify your effort.

6. Certifying effort is not the same as certifying payroll.

Top 10 Concepts

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7. Certification must reasonably reflect all the effort for all the activities that are covered by your UW compensation.

8. Effort is not based on a 40-hour work week.

Top 10 Concepts

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9. Effort must be certified by someone with a suitable means of verifying that the work was performed.

10.Auditors look for indications that certification was based on factors other than actual, justifiable effort.

Top 10 Concepts

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Where is this coming from?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.

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There’s more to it than this, but…There’s more to it than this, but…

These ten concepts are the foundation for everything else.

This fall, you’ll stop getting paper forms from the Personnel Activity Reporting (PAR) system.

•We’re launching a new, easy-to-use Web-based effort certification system.

•You’ll be hearing more about certification and the new Web-based system.

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Where to go for more infoWhere to go for more info

Watch the website www.rsp.wisc.edu/effort. New documentation and training materials will be added rapidly

Watch for training sessions offered through OHRD

Schedule a team to come present at your department