University provides primer on effort reporting

The process of certifying employee effort on sponsored projects — external grants and contracts — has received increased attention on campus in recent months and generated a number of questions from within the university community.

New interpretations of federal effort certification guidelines by federal auditors have led to renewed scrutiny on university campuses across the country, including UW–Madison. In addition, the Office of Research and Sponsored Programs (RSP) is implementing a new Web-based effort reporting system to replace the previous paper-based Personnel Activity Report (PAR) system. The new system, Effort Certification and Reporting Technology (ECRT), will debut on Thursday, Nov. 1, and should streamline and simplify the effort reporting process while remaining in compliance with current federal standards.

Effort reporting is a means of certifying for external sponsors that salaries charged to a project are reasonable in relation to the work performed and that faculty and staff have met their work commitments to sponsored projects.

In fiscal year 2007, UW–Madison received more than $1 billion in awards from external sponsors, including federal and state governmental agencies and private organizations. As one of the responsibilities associated with managing extramural funds, the university must comply with sponsor requirements to certify faculty and staff effort on sponsored projects. Failing to meet stewardship responsibilities could jeopardize the university’s research funding from federal and other external sources.

The following information is provided to help clarify the effort reporting requirements and process. If you have additional questions, please contact your dean’s office or the RSP office, or visit the Effort page on the RSP Web site.

Q: Do I need to report my effort?

A: Anyone who works on a federal or nonfederal sponsored project must certify their effort or have it certified by the project principal investigator (PI) or PI Delegate. This includes faculty, academic staff, classified staff, graduate students, and postdoctoral trainees. UW–Madison applies the same standards for fiscal accountability to both federal and nonfederal sponsored projects.

Q: Have the policies and guidelines for effort reporting changed?

A: Although federal guidelines have not changed, the interpretation of those guidelines has changed with regard to how to report effort. University policies have been revised to assure that we remain in compliance. Effort is now reported in relation to your total work at UW–Madison, which includes all research, grant writing, teaching, service, outreach and administrative duties. You must report your effort on a sponsored project as a percentage of all the activities for which you are compensated by UW–Madison, regardless of the actual number of hours worked. For example, if you write part of a grant at home on the weekend, this work is still included in your total UW–Madison effort.

For faculty and staff with 100 percent appointments on sponsored projects, this means that all activities pursued at UW–Madison must be directly related to those sponsored projects. If they are not directly related, the activities must be charged to a different source of funds. UW–Madison administrators are currently working to identify sources of support for nongrant activities.

Q: What activities can be charged to my grant or sponsored project?

A: Activities that are directly related to the specific project can be charged to it, including directing or participating in any aspect of the research described in the grant, writing progress reports or research articles on the project, mentoring students working on the project, participating in appropriate seminars, attending scientific conferences to present the research and reading scientific literature to keep up to date with the developments in the research field. For a more complete list of permitted activities, please visit the RSP.

Q: What activities cannot be charged to a sponsored project?

A: Activities not directly in support of the sponsored project cannot be charged to the grant, including administrative duties, committee service (including departmental and shared governance committees), instruction or instructional materials development, writing new or competing proposals, or collecting data to support new proposals. Activities that are considered outside the scope of total UW–Madison effort, such as consulting, peer review of manuscripts and advisory activities for sponsors, including service on an NIH study section or NSF review panel, also cannot be charged to a sponsored project. For a more complete list of excluded activities, please visit visit the RSP.

Q: I am an academic staff member and work 100 percent on a sponsored research grant. I am also on a UW governance committee, an activity on which I spend a few hours per year. Is that OK?

A: Infrequent, irregular activity that would normally be considered “so small” that it is not statistically significant is called de minimis effort. Activities can be considered de minimis in amount when, in the aggregate, they have no impact on your effort reporting percentages.

Depending on the nature and extent of the activity, and on the amount of time it requires in an effort period relative to the individual’s total UW effort for the period, the types of activities that may qualify as de minimis effort include service on ad hoc committees, participation in department and division meetings, and other basic activities of university life. Grant proposal writing and well-defined, regular administrative activity cannot be considered “so small,” and therefore must not be treated as de minimis activity. Consult the RSP if you have questions about a specific activity.

Q: Who should I talk to if I have questions about effort reporting or my current or former activities?

A: Individual circumstances will vary, and RSP intends to handle them on a case-by-case basis. To determine the appropriate actions for your specific situation, contact your dean’s office or the RSP office.

Q: What should I do if I am contacted as part of an audit?

A: You are entitled to seek guidance from RSP before providing information to someone who contacts you as part of an audit. If you receive such a call, you can request to return the call at a later time, then contact RSP.