effort coordinator training the uw effort project team ruth fruehling chip quade october, 2007...
TRANSCRIPT
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Effort Coordinator Training
The UW Effort Project TeamRuth Fruehling Chip Quade
October, 2007
Research and Sponsored ProgramsThe Graduate SchoolUniversity of Wisconsin–Madison
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Introduction
• Background
• What we’re going to cover today
• Why is this important?
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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
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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
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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
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Effort Basics, Part I:Fundamental principles
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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
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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!
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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!
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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!)
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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
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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
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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
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Effort Basics, Part II: Assuring that salary charges are reasonable, given the work that was performed
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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
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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
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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
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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
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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
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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
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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!
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"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
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Effort Basics, Part III: Assuring that commitments to sponsored projects have been met
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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%
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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
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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."
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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
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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
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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
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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
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Effort Basics, Part IV: Managing effort over the lifetime of a project
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The life cycle of effort
There’s more to it than just signing a form…
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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
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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
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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
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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
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UW-Madison effort certification policies and procedures
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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
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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
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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
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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
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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:
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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
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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
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Important Changes in Business Processes
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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
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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
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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!
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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
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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
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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
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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
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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
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Key ECRT Concepts
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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
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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
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Reminder!
• A sponsored project has:
– a scope of work
– a budget
– specific terms and conditions
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What an effort statement looks like
We’ll explain the various columns later!
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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
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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
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You are at the center of the process
FacultyCertifiers
RSP
DepartmentResearch
Administrator
DepartmentPayroll
Coordinator
DepartmentHR Coordinator
Dean’s Office
AcademicStaff
Certifiers
Effort Coordinator
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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
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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
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An effort statement’s life journey
UnderConstruction
Ready forCertification
Reopened forRecertification
Returned
Certified Processed
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ECRT Demonstration
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Special circumstances and how to handle them
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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
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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
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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
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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