Background information to explain effort, ECRT, effort concepts, and effort reporting at UW-Madison.
At time of award, UW records the commitment and the cost share, if any, into the WISPER record project tab. The commitment is reflected in the individual's effort card. We track commitments for PIs and Key Personnel only. The award document will name PI and key personnel. If there is cost share, it feeds into the UW cost share system and is reflected in the individual's effort card. When the individual is paid by the project, that payroll information is fed to the effort card. The effort card will be certified by the certifier and then reviewed and processed by the effort coordinator, using ECRT, our effort certification system.
certified every six months for anyone paid on sponsored projects. The
periods covered are January through June, and July through December.
The effort cards display information for this six month period, and the
certifier certifies based on activity in that period. A three month
effort certification window opens one month after the end of the period
covered, in August (for Jan-Jun salary) and February (for July-Dec
salary). This certification window is the time when the cards are
finalized by being certified and processed. At the end of this period,
all certified and processed cards are locked and cannot be reopened without an approval from RSP.
Certification is our
way of telling the sponsor that we kept the promise we made in our
proposal. The effort card becomes the official documentation that we
fulfilled our commitment to the project. Failure to document that
fulfillment puts us out of compliance and risks audit findings, fines
and other punishments.
During the certification window, certifiers use ECRT to display the cards they must certify. The cards contain information for the six month certification period. A card is generated for all employees, but only those paid by sponsored funds are required to certify. A line is generated for every sponsored project the person was paid from and/or is PI on. That line will identify the project number, show the suggested commitment level, the percentage of salary payrolled on the project, and the percentage of salary cost share on the project. The salary numbers ECRT provides come directly from payroll. The cost share numbers come from the cost share system. ECRT calculates a "computed effort" level equivalent to your payroll percentage plus your cost share percentage.
Under normal circumstances, effort matches the way payroll was set up, so normally we simply certify as we were paid plus cost-share. In other words, usually we just match the "computed effort" numbers ECRT provides. There is an exception: PIs also certify 1% for each project for which they serve as PI but didn't get paid from this period. This one percent s the minimum level of effort for an active grant, representing the PI's oversight of the project. A PI must show 1% effort level on all projects where he is PI, even if not paid on those projects.
Of course, the reason we certify is to make sure everything is correct. If a "certifier" discovers that his or her actual effort on a project is significantly different than how he or she was paid, then departmental staff should be informed so they can initiate a cost transfer to correct the problem. In other words, if your certification numbers don't match the "computed
effort" numbers, which equal payroll plus cost share,
then we need to adjust payroll with a salary cost transfer to match salary with actual effort.
We are required to certify the minimum required effort. In most cases, that will be equivalent to the salary paid plus the cost share (if any). If a certifier certifies less than the payroll amount, this is an admission of being overpaid by the grant. An example of this would be if I was paid 10% by the grant, but I certify that I only put 5% of my time into the project. I'm telling the sponsor that I was overpaid by 5%. If the certification is correct, a salary cost transfer would be required to remove the excess salary from the grant. In most cases, under certification is simply an error by the certifier, and should be corrected by recertifying at the appropriate amount. Conversely, a certifier should not certify more than salary plus cost share, because that would be certifying more than the minimum required amount. Certification of the minimum required amount doesn't mean that you only put that minimum amount of effort into the project, but that you put at least that amount of effort into the project.
Faculty and Academic staff certify their own effort cards. Students and Classified staff effort cards are certified by their supervisors. The certifier must have a reasonable means of verification of the effort. In some cases, a student or classified staff member will have effort on multiple projects, in those cases the various PIs should communicate outside of the ECRT system to confirm that the individual put in the minimum required amount of effort into the project. The person assigned the card should complete all the certifications and submit the card following confirmation that the appropriate amount of effort was put in.
Some Students and Classified Staff Self-Certify. Why? The ECRT system uses payroll and appointment data to assign people to various PI's effort-certification lists. It's not elegant because it has to deal with some messy real-world situations. If someone has multiple appointments, it has a certain way of dealing with them. For example, let's say someone is employed as a lecturer and an RA during the certification period. The lecturer position takes precedence and that gives the individual the right to certify herself. The system can't split out the lecturer part from the RA part, so she can go ahead and certify herself for both the lecturer and RA time. Next time around, that individual may or may not have the ability to self-certify; it will depend on what kind of appointments she has.
PIs certify a minimum of 1% effort on all their projects. 1% has been determined to be the minimum amount of effort required to put forth on a project if you are PI. This will typically be coded in as official cost share, but sometimes it is not entered as official cost share. This 1% obligation can be certified by taking one percent off the non-sponsored amount at the bottom of the card, and putting it on the project that needs the minimum 1%. This many need to be done several times to cover all the projects on which the certifier is PI.
Cost Share. Cost Share is when we share the cost of a project with the sponsor. For Effort purposes, only Salary Cost Share is of interest, because it increases the amount of effort that must be reported. When salary cost share is part of a proposal, it will be coded into the cost share system at time of award for tracking purposes. The cost share system feeds data into ECRT and populates the cost share column of the effort card. Computed Effort, the suggested amount of effort to report on a given row in the effort card, is equivalent to the payroll percentage plus the cost share percentage. Just like any other commitment, we are obligated to track and fulfill cost share commitments, and to be able to document for the sponsor that the promised amount of cost share has been provided. Cost share increases the effort on a project. If you need to make a cost share update, utilize the cost share update form.
Salary Cap. The Salary Cap is enforced on higher salary individuals paid on NIH or other DHHS grants. These individuals have been identified and they and their departments receive extensive information about the salary cap and what needs to be done to comply with it. Effort Reporting is a key component of complying with the salary cap. Anyone who exceeds the salary cap must be paid a certain amount of salary from non-sponsored sources in the months that he or she is paid on NIH or other DHHS funds. The amount of non-sponsored funding required is called the Implied Cap Cost Share. This will NEVER be coded as official cost share. It is an amount beyond the NIH/DHHS compensation plus any official cost share.
The bottom line is that any one affected by the cap will certify at a higher percentage than what shows in the effort card as the Computed Effort, which equals payroll + official cost share. RSP provides a report, the salary cap consideration report, at the beginning of every effort certification window that gives a suggested certification level based on the person's payroll and the amount she or he is above the cap. If the payrolled amount is correct, then the certifier should certify at the level RSP suggests, which will always be higher than the amount of computed effort shown on the effort card. An updated report is provided a month before the end of the certification window. Furthermore, L&S provides additional reports, information and assistance in complying with the cap. An improperly certified card is a big problem for someone over the cap and paid on NIH or other DHHS funds. Over the cap certifiers and effort coordinators should pay close attention to the RSP salary cap consideration report and to any communication from L&S regarding salary cap related effort certification. If you have questions, please contact the L&S Post Award Office.
More info on salary cap: https://kb.wisc.edu/ls/page.php?id=42851
Re-opening Cards. There are times when a certified and processed effort card needs to be reopened following the end of the effort certification window for that card. In those cases, a memo addressed to the Director of RSP must be created, detailing the reason for the reopening the card, and forwarded to the divisional office for approval. Please contact the L&S post award, gift and grants office if you think you need to reopen a completed effort card. Before the effort certification deadline, effort cards may be certified, processed and returned by the EC to the certifier for recertification as many times as needed. The formal re-open request is only needed after the effort certification window closes.
Salary Transfers. Salary transfers affect effort reporting. When a salary cost transfer posts, the effort card is updated with the new payroll information. During a certification period, if you know a salary cost transfer will be coming through, hold off on certification and processing until the cost transfer posts and the card is updated with the new information. If you certify using the pre-transfer payroll levels as a guide, the certification will be incorrect and will need to be redone after the cost transfer posts.
RSP Effort Page and ECRT: https://www.rsp.wisc.edu/effort/index.html
Effort Training For Certifiers: https://www.rsp.wisc.edu/effort/training/
UW Effort Policy: https://www.rsp.wisc.edu/effort/uwMadisonEffortPolicyFINAL2007-08-29.pdf
Guidelines for Effort Reporting: https://www.rsp.wisc.edu/effort/ectraining/GuidelinesForEffortReporting.pdf
Effort Glossary: https://www.rsp.wisc.edu/effort/effortGlossary.html
Effort Coordinator's Guide: https://www.rsp.wisc.edu/effort/ectraining/ECGuide.pdf