Frequently Asked Questions About Effort Reporting
Page Updated: May 31st, 2017
Who Must Certify
I work on a non-federally funded project only. Do I still need to certify my effort?
Anyone who works on a federal or non-federal sponsored project must certify their effort or have it certified by the PI or PI Designee. This includes faculty, academic staff, university staff, graduate students, and postdoctoral trainees. The University applies the same standards for fiscal accountability to both federal and non-federal sponsored projects.
I am a University worker on a sponsored project. Will I need to certify?
Unless you are the PI, you will not need to do your own certification. The PI, or someone else with suitable means of verification, will certify for you.
What does the effort coordinator do? Do they certify effort too?
The Effort Coordinator is a key resource to the faculty and the department in the effort reporting process. Effort certification in ECRT is a two-step process: 1) the faculty or staff member certifies the statement, and 2) it must then be reviewed and processed by an Effort Coordinator. Until the Effort Coordinator has reviewed the certification and submitted it to RSP, the certification is not complete.
I hold joint appointments in two different colleges. Each is a half-time appointment. Who is my effort coordinator?
For each individual in the ECRT system, a primary department has been assigned. The effort coordinator in your primary department will process your statement. It is possible that s/he will need to confer with the effort coordinator in your secondary department should any cost transfers, etc., be required.
What is IBS?
Institutional base salary (IBS) is the annual compensation paid by the University of Wisconsin-Madison for an employee's appointment, whether that individual's time is spent on research, instruction, administration, or service. Institutional base salary excludes any income that an individual is permitted to earn outside of duties for UW-Madison. It also excludes any compensation paid by the UW Medical Foundation. It may include salary paid from State funds, Grants or Contracts, Gifts and Endowments, and/or other UW funds.
What types of activities can I charge to my grant?
These types of activities can be charged to a sponsored project:
- Directing or participating in any aspect of the research related to the specific project
- Providing research patient care
- Writing a progress report for the project, sometimes called a continuation proposal
- Holding a meeting with lab staff to discuss the specific research project
- Activities contributing and intimately related to work under the agreement, including:
- Participating in appropriate seminars
- Consulting with colleagues about specific aspects of the project
- Delivering special lectures about specific aspects of the ongoing activity
- Attending a scientific conference held by an outside professional society to present research results
- Reading scientific journals to keep up to date with the latest developments in one's field
- Mentoring graduate students on the specific research project
- Making an invention disclosure, and some other activities related to pursuing intellectual property
What activities cannot be allocated to my sponsored project?
The following cannot be charged to a sponsored project:
- Proposal-writing, except for non-competing continuations (progress reports); this includes:
- Developing necessary data to support the proposal
- Writing, editing, and submitting the proposal
- Administration, including service as a department chair or dean
- Instruction, office hours, counseling for students, and mentoring graduate students on something other than a specific research project
- Clinical activity, except patient care for an IRB-approved sponsored research activity
- Service on an IRB, IACUC, selection committee, or other similar group
- Course or curriculum development not specific to the faculty member's research project
- Writing textbook chapters
- Work that falls outside of the definition of total UW effort (see the complete definition in the Effort Glossary), such as:
- Service as the primary editor of a journal
- Peer review of manuscripts, regardless of whether compensation is received
- Advisory activities for sponsors, including service on an NIH study section or NSF review panel, regardless of whether compensation is received
Effort and Payroll
I am a new administrator, and am unclear about whether we want our researchers to certify their payroll or their actual effort?
They should certify their actual effort, up to the sum of their paid and unpaid commitments. They should NOT report effort that is ABOVE the sum of their paid and unpaid commitments because that effort above the committed level is voluntary uncommitted costs-sharing, and it does not have to be documented.
Example: Dr. X is paid 10% on a sponsored project and has an additional cost-sharing commitment of 5% of his effort. If Dr. X worked 15% of his time on the project, we want him to certify 15%. If he worked 20% on the project, we want Dr. X to certify 15%.
This gets back to the purpose of effort certification, which is: to provide assurance to the sponsor that the researcher has met his/her commitment. "Extra effort" is uncommitted cost sharing and is not tracked, and is not auditable.
Effort and Instruction
For purposes of effort reporting, what does "instruction" mean?
"Instruction" means the preparation, evaluation, and delivery of teaching and training activities of the University, regardless of whether offered on a credit or non-credit basis. It also includes instruction-related activities such as thesis advice, mentoring of students and similar activities. Effort related to instruction is included in a faculty member's total UW effort.
Mentoring and Sponsored Research
What about mentoring of students that relates to a faculty member's sponsored research?
Mentoring of students related to a sponsored research project is appropriately included in effort directly charged to a faculty member's sponsored agreement. OMB Circular A-21 states that charges to sponsored agreements may include reasonable amounts for activities contributing and intimately related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences.
Effort and Administration
For purposes of effort reporting, what does "administration" include?
Administration includes effort incurred for services that benefit common or joint university or departmental activities or objectives in deans/chancellors' offices, academic departments or programs and divisions, and organized research units. Proposal preparation is also included in administration, and therefore cannot be charged to federally sponsored projects.
Effort and Review Panels
Is effort that is related to service on review panels or other advisory activities for federal sponsors included within my total University effort?
Effort related to review panels or other advisory activities for federal sponsors, whether you are reimbursed or not by the federal agency, is not included in your total effort for effort reporting purposes.
Effort and Other University Activities
How do I classify effort related to thesis committees, search committees, faculty senate committees or activities, compliance committees, and similar activities?
These types of activities are considered to be administrative or instructional in nature and are part of your nonsponsored activity. They cannot be charged to a sponsored project, though in a few instances the effort associated with an activity may be so small as to be considered de minimis.
De Minimis Effort
I am an academic staff member and work 100% on a sponsored research grant. I am also on the UW's Committee on Women, an activity that I spend a few hours a year on. Is that ok?
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 represent less than one percent of the individual's total UW effort.
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.
100% Research Appointments
What provision is made to provide money for grant application preparation for research faculty paid 100% on federal grants? What is the source of the funds and who is responsible for providing those funds for grant application preparation? What provision does the UW make for service on the Faculty Senate by 100% federally funded research faculty? What provision does the UW make for service on the Human Subjects IRB by 100% federally funded research faculty? Who is responsible for assuring that those provisions for funding are in place?
Faculty should consult with their department administrator and chair to determine the source of funding for non-grant activities. Generally, any departmental/school sources, including but not limited to 101 (GPR) funds, gifts, endowments, etc., may be used to fund these activities. Departments and colleges are responsible for assuring that provisions for funding are in place. It is not a function of the effort reporting process to monitor or certify that funding is available. The effort reporting process is simply the mechanism that allows faculty and staff to provide assurance that the compensation paid from grants and contracts is reasonable in relation to the effort expended on those agreements.
An emeritus faculty member has been hired back at a 40% appointment to teach. Can this individual "volunteer" time on a sponsored research project?
Even though the faculty member is on a 40% appointment, the effort devoted to the sponsored project must be considered part of the individual's total UW effort. It could be implied that, by approving the application for the grant, the department officials have approved a change in the scope of the appointment to include research.
Do I need a separate funding source for each teaching, administrative, clinical or service activity in which I participate?
No. Only your individual sponsored projects must be segregated by funding source. It is important to remember that the salary distribution must match or be lower than the effort you are committing to the project. Under no circumstance should you ever charge salary to a sponsored project that represents more effort than you are devoting to the project.
What non-grant funds can be used to support the activities that can't be charged directly to grants?
Virtually any University budget that doesn't have other restrictions placed on it by the funding source, including 101 (GPR) funds. Gifts and endowments are appropriate sources if the activities are consistent with donor intent.
% of Non-Federal Sources Required for University Activities
If we set a college or departmental policy and pay everyone a set percentage (e.g. 5%) from non-grant funds, have we met our obligation to cover non-sponsored effort with non-sponsored funds?
While the percentage you set may be the right funding mix for some, others may work significantly more or less on research. So, while this approach seems like a simple solution, it does not meet the federal standards. Each individual's portfolio of activities should be reviewed to determine the appropriate mix of grant and non-grant funding for the individual.
What risk areas should we focus on as a school, college, or department?
The following areas are receiving significant attention nationally:
- 100% research faculty - are they involved in activities that should be funded by sources other than their grants?
- Faculty with 5 or more federal awards - are they overcommitted? Are the percentages of salary distributed to each of their projects reasonable?
- Change in Level of Effort - are faculty seeking permission to change the level of effort proposed in their grant when required (typically when the change is 25% or more)?
- Faculty with 1 or 2% of their effort on many awards - are they contributing the effort promised?
- Faculty Effort Certification - is it timely?
- Retroactive Salary Cost Transfers - are they infrequent, but timely when necessary? Of particular concern are those affecting time periods for which faculty have already certified their effort.
- Total effort commitments (paid and cost shared) to the sponsor - are they met?
- University effort reporting policy - is it being followed?
Effort and Intellectual Property
Is effort related to pursuing intellectual property (e.g. making an invention disclosure, meeting with WARF to discuss an invention disclosure, reviewing internal action on a patent application and/or reviewing a draft patent application) on UW awards included within my total University effort and can it be directly charged to grants?
Yes, consistent with the spirit of Bayh-Dole, reasonable levels of activity related to pursuing intellectual property can be charged directly to the appropriate grant. As with any effort charged to sponsored agreements, effort associated with the pursuit of intellectual property must be directly related to the sponsored project that is being charged. Where more than one award or activity contributed to the development of the intellectual property, the effort distribution should be based on proportionate support provided under the awards or other equitable relationship. The effort must also occur within the award period. These activities should be included within total University effort for effort reporting purposes.
Minimum Effort for Key Personnel
Is there a minimum level of effort required for key personnel in grant applications?
In keeping with federal policy, it is the UW's policy that all PIs must have some minimal commitment to the sponsored project. NIH also requires that all key personnel have a measurable commitment to the project. While many sponsors will allow key personnel other than the PI to have no measurable effort on a project, it is advisable to quantify the commitments of all key personnel.
NIH - Other Significant Contributors
Can a faculty member be noted as contributing to a grant without committing effort?
NIH grants now have an "Other Significant Contributors" field available. This allows the PI to identify individuals who have committed to contribute to the scientific development or execution of the project but are not committing any specified measurable effort. The following is a quote from the NIH 424 (R&R) instructions: "OSCs are individuals who have committed to contribute to the scientific development or execution of the project, but are not committing any specified measurable effort (in person months) to the project. These individuals are typically presented at effort of zero person months or as needed (individuals with measurable effort cannot be listed as Other Significant Contributors). Consultants should be included if they meet this definition. This would also be an appropriate designation for mentors on Career awards."
Average Work Week
I am currently a faculty member at UW. I often tend to work 50 or sometimes even more hours per week. The precise number changes from week to week and month to month and reflects the uneven nature of research, teaching, and administration. It appears to me that the admission of working extra hours can only penalize the individual. As an example, faculty members A and C receive the same amount of money from the grant ($37,500) and perform the same number of hours' work (10 per week), yet because C works longer hours, he/she is apparently receiving too much from the grant, and should in fact receive less ($25,000) for the same amount of work. It seems therefore that all faculty members should take care not to work more than their allotted hours per week. Am I correct in making this conclusion?
The university does not specify the number of hours per week a faculty member must work. There is an expectation that members of the faculty will work the hours necessary to carry out the professional responsibilities of their position. There is also the realization that the number of hours required for any activity will change over time. That's one of the reasons effort reporting is based on a percentage of effort rather than a number of hours.
Faculty appointments generally specify an annual salary amount that is negotiated between the department/college and the individual faculty member. That rate of pay covers all the activities you perform for your department - research, teaching, outreach, public service. Sponsors expect that the salary charged to their project for the effort performed will be at the same rate as the salary charged to other activities performed by the faculty member.
Effort on grants is to be based on your total university effort. The principle is that sponsors are not to be charged at a higher rate per unit of effort than the institution pays an employee for effort directed towards other university activity. The percent of salary allocated to your grant should be commensurate with the percent of your total university work effort, directed towards the goals of the grant. This principle demonstrates that regardless of the activity engaged in for the university the compensation for that effort is at a consistent rate.
Effort and UWMF Clinical Work
I am a faculty member in the School of Medicine and Public Health. I work as an FTE. My appt is split into 40% of UW effort to work on research grants at UW and 60% on UWMF clinical work. What do I report effort on?
You only report on the UW portion, not on your overall (non UW) professional effort. Your 40% UW research work constitutes your total UW effort. Your institutional base salary includes UW research on sponsored projects, but, excludes any UWMF clinical work. SMPH faculty/academic staff need to consider their UW appointment/institutional base as completely separate from UWMF clinical work.
Your UW work (40% appt) is the portion that you report your full effort on, and that comprises your 100% UW effort. If you are 80% research funding, you would be expected to expend 80% of your non-clinical time on grant activities and 20% time on non-sponsored or departmentally funded work (ex: 20% on activities such as: writing proposals, instruction, sitting on committees, etc). 50% research funding would mean you would spend half of your non-clinical time on grant activities, etc. Effort reporting aims to tell our sponsors that you've met your commitment.
Note: Definition of Institutional base salary (IBS) is the annual compensation paid by the University of Wisconsin-Madison for an employee's appointment, whether that individual's time is spent on research, instruction, administration, or service. Institutional base salary excludes any income that an individual is permitted to earn outside of duties for UW-Madison. It also excludes any compensation paid by the UW Medical Foundation. It may include salary paid from State funds, Grants or Contracts, Gifts and Endowments, and/or other UW funds.
Funding Grant Proposals
How is my effort preparing my next grant proposal funded?
During the effort reporting period in which you prepare the proposal, the percentage of your effort spent on proposal preparation must be funded by University sources other than sponsored projects. However, if you are writing a progress report or a request for non-competing funding, those activities may be appropriately charged to the sponsored project.
Funding Grant Proposals for 100% Research Faculty
What if there is a 100% researcher and s/he is going to apply for a new grant? How is that person to be paid for the time that will be devoted to preparing the proposal?
A portion of salary consistent with the effort needed for preparing the proposal should be paid from non-federally funded sources, including 101 (GPR), gifts, endowments, etc. during the period when the researcher is writing the proposal The percent should be consistent with % effort spent on proposal preparation.
100% Research and Other Activities
What if that same person teaches or is involved in other scholarly activities and is 100% funded for research. Is that okay?
Faculty members, because of the scope of their activities associated with university effort, generally may not be 100% research. Academic staff may in some cases have their salary charged 100% to sponsored projects. However, charges to sponsored agreements may only include reasonable amounts for activities contributing to and directly related to work under the agreements, such as delivering special lectures about specific aspects of the ongoing activity, writing reports and articles, participating in appropriate seminars, consulting with colleagues and graduate students, and attending meetings and conferences. If the teaching and other activities are NOT contributing to and directly related to the work under the agreements that are paying the salary, then a portion of the individual's salary proportionate to the non-grant effort must be paid from other sources.
Appropriate Source of Funding for Grant Writing
Can a faculty member use a non-federal sponsored funding source (i.e. pharmaceutical dollars) to cover their grant writing effort?
Generally, no. It would be very unusual for any grant or contract to allow funds to support a new grant proposal. While not all non-federal grants and contracts are subject to the same rules as federal grants and contracts, we are still bound by the cost accounting standards and the issue of consistency in how we classify costs. These costs are specifically noted in OMB Circular A-21 as indirect and we must be consistent in classifying them as such. In addition, it could be viewed as a violation of our fiduciary responsibility to expend the non-federal sponsor funds in a manner that does not directly benefit the project they are intended to support.
Minimum % Required for Proposal Preparation
Is there a "policy" or "point of clarification" on the minimum appropriate % of effort needed for grant writing? I recall a meeting at which 2.5% and 5% were thrown around as possible minimums.
There is no guideline or directive from the UW (or the federal government) on the minimum appropriate effort for grant writing since it varies broadly by faculty member and by the specific proposal. The level of effort should be based on each faculty member's individual situation and the time that is devoted to any particular proposal.
What about vacation time when there are multiple grants? How does one insure that each grant pays their fair share of vacation time?
The university applies a consistent practice of paying vacation and other accrued leave from the funding in place at the time the leave is taken. If grant funds are not being used to support the individual at the time leave is taken, the department will cover the leave costs. This is a fairly common practice at institutions and is viewed as acceptable because we are consistent in the application and do not discriminate between funding sources.
Reduction or Increase in Effort
Is it sufficient for a faculty member to simply tell his/her Program Officer about a change of effort greater than 25% of current effort?
While it is important that the researcher maintains a good relationship with the Program Officer, this is not sufficient. Any decrease in effort greater than 25% by key personnel (as listed in the Notice of Grant Award) must be approved prior to the change and in writing by the sponsor's Grants Officer. The request must be processed through the UW Office of Research and Sponsored Programs in advance of the change.
An increase in effort greater than 25% for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored agreements. If there is a change in the scope of work, it must be approved prior to the change and in writing by the sponsor's Grants Officer. The request must be processed through the UW Office of Research and Sponsored Programs in advance of the change.
No Cost Extensions and Effort
What are the effort requirements of a PI for a no-cost extension period? Does the original effort commitment extend to the no-cost extension period?
With the exception of grant programs that have a specific minimum effort requirement (i.e. NIH K type awards), effort commitments are not required to be updated when requesting or receiving a no-cost extension. A thorough analysis of sponsor polices and Federal regulations have concluded that a no-cost extension simply provides additional time in which the originally proposed effort may take place.
Rarely, there might be instances when a commitment is necessary during the NCE period. Specific grant programs may require a specific minimum effort requirement, which continues into the NCE period (i.e. NIH award types: K, R35, DP1). Therefore, before preparing the NCE request, review the terms and conditions of your award to determine if a specific commitment must continue.
Reduction of Cost Shared Effort
When there is a reduction in effort for an individual with both cost shared and directly charged salary, to which component does the reduction apply?
Unless the cost sharing is a mandatory requirement of the grant, the reduction can be taken from either the paid effort or the cost-shared effort.
Where does the data in ECRT come from?
ECRT is not a system that creates or re-creates information. It receives it from source systems and displays it. Entry of data is not done in ECRT, but instead is done in those source systems.
Each week, PeopleSoft Grants provides ECRT information on Commitment, Project PI, Project Title and Cost Sharing. The information in PeopleSoft Grants is created when users enter data in WISPER which becomes stored when users generate data in PeopleSoft Grants. The data is stored in a database called SFD (Shared Financial Detail).
Each week, HR/Payroll provides ECRT information on Department, Certifier (Appointment/Demographic) and Payroll information. The information in HR/Payroll is created when users enter data in the source systems which becomes stored when users save data. The data is stored in a database called SFD (Shared Financial Detail).
If there are any changes you would like made to the information that is displaying in ECRT, you will need to work in those source systems to re-enter or revise the information. Changes will then be a part of the weekly information that is sent to ECRT.
I am still not clear as to how summer salary or other salary relates to your effort during the academic year and how to report this.
The effort certification process is conducted on a semi-annual schedule for all faculty, including those on 9-month appointments. The certification periods are from January - June and July - December. The rate of pay one can receive from a grant for work during the summer is based on the 9- month academic year salary rate. While summer salary is considered part of institutional base salary, it is generally a unique line or designation in the grant proposal.
For example, assume the 9 month salary is $3,000 per month for a full-time appointment and you commit 50% effort for two months during the summer. The rate of pay for those two summer months would be $1,500 per month for 50% effort per month.
I will be out of the country doing research during the effort certification period, and will not have access to the internet. Can my administrator certify my effort statement?
Only a person with a suitable means of verifying how you spent your time can certify your statement in your absence. All requests for delegating certification authority are reviewed by the Associate Vice Chancellor for Research Administration and approved on a case-by-case basis.
To request a delegation of authority:
- Ensure that the Designee has completed the mandatory effort training
- Access the Form for Requesting a Delegation of the PI's Certification Authority on the RSP Effort Reporting Page
- List the projects to be delegated
- Sign and date the document, verifying the intent to delegate
- Have the Designee sign, verifying agreement to act on your behalf
- Send the original to RSP
The RSP Effort Administrator will notify both you and the Designee when the change has been made via email.
I am the Director of a large Center, but the PI of record is the Dean of our college. The Dean has no day-to-day involvement in the Center. Who should certify the effort for the university staff and graduate students that work at the Center?
In some situations the named Principal Investigator is not the person with the most suitable means of verification of effort for staff on the project. One example might be the PI of a large Center grant who has delegated the day-to-day operations of the Center to a Director or Manager. For that project, certification of staff effort is most appropriately handled by the Director or Manager, not the PI.
Voluntary Uncommitted Cost Sharing
A faculty member in our department performed more effort than what was proposed on one of his budgets. Does he need to declare this as cost sharing?
No. This is called voluntary uncommitted cost sharing and is a contribution of non-sponsored effort. It is not auditable and does not need to be reported.
Shifts in Funding Source
What should happen when a faculty member maintains the committed level of effort but shifts how this effort is funded?
The committed effort not funded by the grant becomes a cost sharing commitment. For example, a faculty member notes 20% effort on a proposal with requested funding for the full 20%. After the proposal is awarded, the PI discovers a need to reduce his/her compensation from the award (gets paid at 15% from the award) but does not reduce his/her effort committed to the award (still at 20% effort). This creates a 5% cost sharing situation which should be documented on the effort statement and in the cost sharing system.
Use of Cost Sharing and Commitment Update Form
When should I use the Cost Sharing and Commitment Update Form?
The Cost Sharing and Commitment Update Form is used to initiate changes in SFS to sponsor paid or cost shared effort commitments. You may need to contact the sponsor if the change is 25% or greater (see UW-Madison Effort Guidelines, Section 1.3.3). An update may be necessary when there is a change in the specifics of sponsor paid effort or cost shared effort from what you proposed initially or what has been entered into the system, e.g., dates, percentages, or personnel. Note that this form is also used when you want to notify RSP that a non-payroll or third party cost sharing expense has occurred.
Routing of Cost Sharing and Commitment Update Form
Where do I send the Cost Sharing and Commitment Update Form to be processed?
Departmental staff should send the update forms to their Dean's or Director's office for approval. Dean's or Director's offices should send approved update forms to firstname.lastname@example.org.
Changes to Cost Sharing and Effort Commitments
If a payroll cost sharing commitment also changes an effort commitment, what should I do?
Submit the Cost Sharing and Commitment Update Form that indicates the change to the Payroll Cost Share Expense. If the cost share change also changes an effort commitment, you may need to contact the sponsor if the change is 25% or greater (see UW-Madison Effort Guidelines, Section 1.3.3). The RSP staff person processing the update form will make changes to the payroll cost share and the effort commitment data as needed.
Flow of Payroll Cost Sharing Information into ECRT
After cost share calculates and I see it in WISDM on the Cost Share Expenditures tab, how does it get to ECRT?
Information is loaded on a weekly basis into the ECRT system. The process is manual and typically takes place on Monday or Tuesday.
Appearance of Payroll Cost Sharing Updates
If I requested an update to a payroll cost sharing commitment, when will I see the changes reflected in the system?
The cost share calculation runs once a week, typically over the weekend. Salary and fringe information should be loaded and available in WISDM on the Monday following the calculation. The F&A for these expenses, however, calculates 2-6 days later. Depending on when an update was entered, it may take about two weeks for the new information to appear in WISDM and ECRT.
At this point, matching the transactions requires doing an analysis using the SFD Transaction tool in WISDM. The process is described in CSWG BPR 8. An enhancement is in the works so that information in the Cost Share Expenditures tab will be displayed summarized by person and pay period. Detail will also be available on a pay period level. The updated displays, once in place, should render the SFD Transaction analysis largely unnecessary.
Source of ECRT Commitment Percentage
Where is the commitment percentage in ECRT coming from?
The commitment column is comprised of data taken directly from the SFS Extensions commitment system. Data in SFS Extensions originates in the Projects tab in WISPER. Commitment schedules are usually captured at the award setup stage and serve as a baseline for managing effort. For schedules that do not span over an entire effort certification period, the commitment column will display a prorated value (e.g. a 50% commitment row scheduled from 1/1 – 3/31 will prorate to 25% in the commitment column in ECRT for the 1/1 – 6/30 certification period).
Computing Commitment Percentages
How do I compute the percentage for the commitment line that I enter in WISPER?
The numerator in the calculation is the person-month(s) commitment that was offered to the sponsor. This figure is easy to identify in the proposal.
Choosing a denominator can be a challenging task, given all the variables to consider. For A-basis employees, the budget period should be the denominator used when computing the effort commitment. For example, a 2-month commitment for an A-basis employee with a budget period of 12 months would result in a 16.67% commitment (2/12). Be cognizant that most guidance on this topic is geared toward sponsored projects that have 12-month budget periods. In reality, not all awards follow this standard. If the budget period is 6 months and it is the Department's intention to evenly spread out the commitment, then use 6 months as the denominator when computing the percentage for the effort schedule.
If the commitment within a sponsor budget period is being satisfied in a specified block of time, it is important to schedule it accordingly. For example, a person with a 1.0 person-month commitment can be scheduled as 16.67% (1/6 mo.) over a six-month timeframe if that's when the effort is being exhausted.
Also remember that key personnel have the option of meeting their commitment in a fluctuating manner throughout the course of a budget period. For example, an individual with a 20% commitment over a 12-month budget period can meet it by expending 10% effort in the first 6 months of the project and 30% effort in the last six months.
The percentage entered in the commitment line in WISPER is being used to create the baseline commitment levels in ECRT.
Computing Commitment Percentages for C-basis Employees
What about C-basis employees? How should their commitment percentages be computed?
C-basis employees bring another variable to the table. The denominator in the calculation can vary depending on the number of summer months being paid. The results may range from 8% (1/12 mo.) to 10% (1/10 mo.) for a 1 month summer commitment.
One way to avoid this variation is to simply assume 3 months (6/1-8/31) as the denominator for summer salary and to enter the commitment during June-August only. This practice removes the guesswork of selecting a denominator that is based on having to know future summer salary plans that are far from being set in stone.
This notion is true as well for cost sharing commitments that are supported by salary that is paid during the academic year. The person setting up the effort schedule should use "9" as the denominator, with the resulting percentage only spanning over the academic months (e.g. 1/9 mo.=11% over the period 9/1-5/31).
In an attempt to standardize this calculation, some Divisions have advised Departments to consistently use 11.5 months as the denominator, regardless of pay basis. To illustrate, 1.0 person-month always equals a rounded value of 9% (1/11.5 mo.). Applying this method for all cases can become problematic if the sponsor budget period differs from the typical 12 mo. budget period. It's important to break the habit and adjust the denominator accordingly to match the atypical budget period. If you are working with a 20 month budget period and a 1.0 person-month commitment, the effort computation would result in 5% (1/20 mo.). The pitfall of applying the 9% throughout the budget period is that the percentage being captured in the effort system is overstating the true commitment (9%*20 mo.=1.8 person-months).
Commitment vs. Certified Effort
Should the certifiers certify to match the new commitment values in ECRT?
It depends. The new commitment column is offered in ECRT as a suggestion and should not be the only factor that's considered during the certification process. It may help certifiers document their effort in situations where drawing salary from their sponsored projects was decided against, thus creating a cost sharing situation. However, providing this information may lead to certifying and documenting voluntary uncommitted cost share, which is frowned upon. Consider the following scenario for an explanation:
The PI committed 1.0 person-month (paid) each budget period that aligns with the calendar year. For the first effort certification period, the effort card reflects an 8.33% commitment value. As the project progresses, the PI decides to work the entire 1.0 mo of committed paid effort in the second half of the budget period instead of splitting it between both certification periods. It would be inappropriate to document any effort in the first certification period, as it would be considered voluntary uncommitted cost share.
In this scenario, it would be acceptable to certify 0% in Jan.-June and 16.67% in July-Dec. We would not want, however, for the PI to certify anything in Jan.-June if he works and certifies 1 month in July-December. Remember, certified effort on a sponsored project that is not borne by the sponsor becomes cost sharing. And, in this scenario, any effort certified during the Jan.-June time period would be voluntary uncommitted cost sharing.
Here are some tips that can aid certifiers and ECs through this challenging task:
- Managing effort requires cross referencing multiple effort statements and knowing the projections for future salary/cost share.
- Review commitments at a sponsor budget period basis. Effort fluctuations within a budget period are acceptable and do not require sponsor approval, per section 1.3.2. in the Effort Guidelines that can be found here.
Commitment vs. Computed Effort
Does the commitment percentage have to match the computed effort in ECRT?
No. Because the commitment percentage merely acts as a guide, it is not imperative for this figure to mirror the computed. The typical practice on campus, while setting up awards, is to evenly distribute commitments over each sponsor budget period. If the commitment is a paid 1.0 person-month each budget period, campus generally prefers to spread it out as 8.33% (1/12 mo.), given the uncertainty of when the committed effort will actually be performed and paid out.
Commitment vs. Computed Effort Scenarios
As an Effort Coordinator, how should I be handling my job and advising certifiers when I encounter discrepancies in the commitment and computed effort columns in ECRT?
Please consider the following scenarios and reference the point that applies to your situation for guidance.
Computed effort is less than the commitment percentage:
- The certifier reported additional effort in the previous certification period or is anticipating increasing their effort in the subsequent cert period, thus explaining the reduction. As long as the shifting occurs within a sponsored budget period, nothing needs to be changed. It is discouraged for departments to prepare update forms to have the commitment column match the computed, as this fluctuation is all too common and managing the volume of these types of requests is not the best use of resources.
- The PI decided to forego expending the sponsored project funding for his/her salary. Unless an approval from the sponsor is obtained for significant reduction in effort, the department will need to prepare and route an update form to document the effort as voluntary cost share in order to satisfy the effort commitment.
- The Department mistakenly did not pay the certifier from the sponsored project. Thus, a salary cost transfer must be initiated to retroactively correct the problem.
Computed effort is more than the commitment percentage:
- The certifier reported a lesser amount of effort in comparison to the commitment baseline in the previous certification period or is anticipating a lesser amount of effort in the subsequent period, thus explaining the need to increase. As long as the shifting occurs within a sponsored budget period, nothing needs to be changed. It is discouraged for departments to prepare update forms to have the commitment column match the computed, as this fluctuation is all too common and managing the volume of these types of requests is not the best use of resources.
- The certifier worked more than the commitment and paid him/herself from the grant for the additional effort. As long as the terms of the award do not prohibit this action (e.g., rebudgeting across cost categories is permitted and no salary limits exist), nothing needs to be done.
- The certifier worked more than the commitment and paid him/herself from the grant for the additional effort, plus the effort is a combination of paid and cost shared effort. Lower the cost share so the overall computed effort matches the commitment, unless the cost share is a mandatory requirement of the award.
Computed vs. Certified Effort: Scenarios
As an Effort Coordinator, how should I be handling my job and advising certifiers when I encounter discrepancies between the computed effort and certified effort columns in ECRT?
If the computed effort shows appropriate progress toward meeting the commitment for the certification period, then the certified effort should be commensurate with the computed effort. If the computed effort does not show appropriate progress or if certified effort differs from computed effort, then some action should be taken. Determining what action should be taken depends on: 1) whether or not computed effort indicates that appropriate progress is being made toward meeting the effort commitment, 2) whether the effort is to be paid by the sponsor (Payroll) or by the University (Cost Share), and 3) whether the computed effort or the certified effort reflects the more appropriate percentage for the effort certification period.
Please consider the following scenarios and reference the point that applies to your situation for guidance:
Computed effort is less than the certified effort:
- Assuming that the computed effort shows appropriate progress toward meeting the commitment for the certification period, if the computed effort is less than the certified effort, then the certifier should reduce the amount of certified effort.
- Assuming that the computed effort does not reflect appropriate progress toward meeting the commitment for the certification period, then the computed effort should increase to reflect appropriate progress. This can be accomplished by either a) initiating a salary cost transfer to show salary paid to the certifier or b) submitting a Cost Share and Commitment Update Form to indicate cost shared effort on the project. Once the computed effort accurately indicates appropriate progress toward meeting the commitment for the certification period, the certified effort should reflect the computed effort.
Computed effort is more than the certified effort:
- Assuming that the computed effort shows appropriate progress toward meeting the commitment for the certification period, if the computed effort is more than the certified effort, then the certifier should increase the amount of certified effort.
- Assuming that the computed effort exceeds the amount necessary to meet the commitment for the certification period, then the computed effort should decrease to reflect appropriate progress. This can be accomplished by either a) initiating a salary cost transfer to decrease salary paid to the certifier or b) submitting a Cost Share and Commitment Update Form to lower cost shared effort on the project (if the cost share is a mandatory requirement of the award, work with your RSP accountant to verify that the obligation will still be met). Once the computed effort accurately indicates appropriate progress toward meeting the commitment for the certification period, the certified effort should reflect the computed effort.
Computed effort and certified effort are within 5% of 100% total effort:
A precise assessment of effort is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate. If a reasonable estimate of the actual effort is within five percentage points of the effort percentage shown on the statement, it is permissible to certify the level of computed effort that appears on the statement. Differences between computed effort and certified effort that are 5% or less (based on 100% total effort) should be reviewed further. Effort cards should be returned to the certifier to verify that the level of effort was certified correctly.
- Assuming the level of effort was certified incorrectly, the certifier should revise their certification to certify their effort at the computed effort level.
- Assuming the level of effort was certified correctly, the effort coordinator should follow the appropriate instructions above for "Computed Effort is Less than Certified Effort" or "Computed Effort is More than Certified Effort."