Later this month, the University will launch an intensive effort to ensure that each faculty member properly reports to the federal government the amount of time that is spent on sponsored research, a subject known as faculty effort certification.
A Web-based training module on faculty effort certification will be available for researchers in the School of Medicine starting Aug. 15. A similar module will be available to other researchers a month later.
The training is the product of 18 months’ effort by a broad-based committee, including members of the Office of Financial Management, the Office of Sponsored Programs, and academic units. The group reviewed University systems to assure full compliance with federal regulations. In addition, the committee sought help from national experts and consulted with peer institutions to identify best practices.
“Faculty effort certification is important,” said Arthur Nowell, dean of the College of Ocean and Fishery Sciences and chair of the Board of Deans. “It is important because sponsored research keeps UW moving forward, supports our students and advances our scholarship. Our sponsors require us to accurately document our efforts. It matters to them. And it matters to us as we build our credibility as an institution with noble goals and enviable values.”
The training modules have been tested by about 20 faculty from across campus and have the support of the Faculty Council on Research, the Board of Deans and the Provost’s Office. The intent of the modules is to clarify reporting rules and expectations, and to provide consistent University guidance on this potentially complex subject.
The consequences of not following the regulations in this area can be dramatic. Two years ago, Northwestern University settled with federal authorities for $5.5 million, without admitting any wrongdoing regarding federal allegations of false claims. Last year, Johns Hopkins University agreed to pay $2.6 million, also without admitting any wrongdoing.
In addition, the federal government has issued several clarifications and explanations about how to interpret parts of the regulations, and these clarifications are likely to continue.
“Reporting of faculty effort can be very complicated,” says Sue Camber, assistant vice president for research accounting and analysis. “This is especially true when a researcher’s salary comes from a number of sources.” Camber was a member of the review committee. “When we analyzed our situation, we concluded that we faced many of the same risks as institutions that had recently incurred multi-million dollar settlements. We wanted to settle any confusion that could arise in reporting faculty effort.”
The Web-based education program is mandatory for an estimated 2,500 faculty members engaged in sponsored research. Faculty members who fail to complete the training within the assigned time frame (Aug. 15 to Sept. 14 for deans, chairs, administrative staff and administrators; Aug. 15 to Oct. 31 for School of Medicine Faculty; and Sept. 15 to Nov. 30 for faculty in all other schools and colleges) will lose their authority to submit grant proposals and authorize grant purchases until they complete the training. Individuals who engage in research but are not principal investigators and fail to complete the training cannot be paid on grants until the training is completed.
The training addresses all the important issues in faculty effort certification. It considers the range of complexities that are dependent on an individual’s portfolio of salary and research commitments. There are two versions of the training: the clinical faculty version takes about 90 minutes to complete, while the non-clinical version will take about an hour.
The training modules also contain a list of key contacts if researchers have additional questions.
Because the committee regarded accurate faculty effort reporting as a critical, the training was instituted as soon as the modules were perfected. After this initial training, the information will be incorporated into the grants administration training that is required every three years.
The program is sponsored by the Office of the Provost and the Office of the Executive Vice President. It is coordinated by UW Training and Development and was developed by Educational Technology Services.