Transcript What is Time and Effort

University of Massachusetts Dartmouth
Office of Research Administration
What You Really, Really Need
to Know About Effort
Certification
7/17/2016
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What is Effort Certification?
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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
A new, improved Effort Certification system
is being implemented right now!
Why Should We Care?
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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
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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?
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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 UML
These activities are divided into:
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Sponsored project activities
Non-sponsored activities, such as:
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Administration, including duties as chair, dean, etc.
Instruction
Research without external funding
Public service and outreach, when closely related
to your UML duties
What Counts in Your 100% Effort?
Sponsored Activity
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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 clinical trial)
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
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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% UML Effort
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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 UMD is +/- 5%
Who Certifies the Effort
Statement?
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An individual’s effort must be certified by a
responsible person with suitable means of verifying
that the work was performed.
Each faculty member and PI is responsible for
certifying his/her own effort
PIs certify for graduate students, postdocs, and PI
staff
There are some exceptions made for practical
reasons (e.g. someone other than the PI of a large
Center grant has better knowledge of the work that
was performed). Contact ORA for help with
exceptions.
How to Certify
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You verify that the statement shows a reasonable
estimate of the actual effort worked. Things that may
help you verify this include:
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teaching schedules
outside activity forms
“other support” forms
leave reports
calendars
correspondence
How to Certify (continued)
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“I certify the salary charged, salary transfers
processed and effort certified this period reasonably
reflect the work performed in the designated period,
and that I have sufficient technical knowledge and/or
I am in a position that provides me with suitable
means of verification that the work was performed.”
If it is a reasonable estimate for the time period:
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Certify by clicking the Certify button
Otherwise:
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Work with your effort coordinator to revise the Effort
Statement before you certify it
Sample Effort Statement
Red Flag Issues
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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)
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Post-certification revisions
Significant data inconsistency between
the Effort Statement and other
documentation such as:
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Outside activity forms
Other support forms
Leave reports
Points to Remember
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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
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Your administrator
Office of Research Administration
Reference materials are located at
http://www.umassd.edu/grants_contracts/