Consequences for Failing to Complete Training and Certify Effort

Page Updated: January 1st, 2015

Background

Effort certification is required by extramural sponsors including the federal government. A failure to certify effort correctly and in a timely manner could jeopardize the UW's federal research funding. To protect the interests of the UW and ensure compliance with federal policies, the university is instituting consequences for failing to certify effort and complete the training. Any faculty or academic staff member who fails to fulfill the appropriate responsibilities noted below may be the subject of disciplinary action, up to and including dismissal, under university policies and procedures.

The responsibilities of a principal investigator with effort on sponsored proejcts include:

  • Completing the UW's effort training program
  • Certifying his or her effort in a timely manner, in accord with the UW Certification Calendar
  • Certifying effort for the graduate students, postdoctoral researchers, and non-PI classified staff who work on his or her projects in a timely manner, in accord with the UW Certification Calendar

The responsibilities of a non-PI faculty or academic staff member with effort on sponsored projects include:

  • Completing the UW's effort training program
  • Certifying his or her effort in a timely manner, in accord with the UW Certification Calendar

The responsibilities of the effort coordinator include:

  • Reviewing the certified effort statements in order to identify any follow-up actions that may be required
  • Processing the effort statement in a timely manner
Consequences for Failing to Complete Training and Certify Effort

To be considered timely, effort statements must be completed within the 90-day certification period. The certification process requires two steps. The effort statement must be:

  1. Certified by the principal investigator, non-PI faculty or academic staff member, and
  2. Reviewed and processed by the effort coordinator.

Only after both steps are accomplished is the effort statement regarded as complete, making it an official record of the university.

Administrative and Fiscal Consequences

If effort statements are not completed in a timely manner, administrative or fiscal consequences will ensue.

Administrative consequences are enacted if effort statements are not completed within the 90-day certification period.

Administrative Consequences for Principal Investigators

The university will provide no support for extramural activities on behalf of principal investigators who do not fulfill their responsibilities. Specifically, the university will not:

  • Submit a grant proposal or other project application to sponsors for extramural projects
  • Execute award agreements
  • Establish accounts for spending extramural funds for new or continuing projects
  • Process other documents such as material transfer agreements

Administrative Consequences for Co-investigators, Senior/Key Personnel or other Faculty and Academic Staff

The university will not submit a grant proposal or other project application that lists an individual who has not fulfilled the responsibilities included above.

If effort statements are not completed (certified and processed) by 30 days after the end of the certification period, fiscal consequences will be implemented.

Fiscal Consequences

If effort statements are not completed by 30 days after the end of the 90-day certification period, the university will transfer sponsored salary charges corresponding to incomplete effort statements to the Dean's/Director's suspense project. Fringe benefit charges associated with the sponsored salary charges and F&A charges associated with salary and fringe will also be transferred off the sponsored project. It is expected that Deans and Directors will flow these charges down to department chairs.

Accordingly, this means that July-December effort statements must be completed no later than April 30th. Effort statements for January-June must be completed no later than October 31st. In order to allow time for resolution of any issues, there will be a thirty day window after the certification period ends. At that point, fiscal consequences will be applied. No additional time can be taken, and costs moved into a suspense account cannot then be transferred to any sponsored project. The effort reporting and certification timelines are illustrated at the following link: https://www.rsp.wisc.edu/chap4/rn/Effort_Timeline.pdf