Policy Number: 93
Effort Certification Reports
I. POLICY AND GENERAL STATEMENT
It is the policy of The University of Texas Health Science Center at Houston ("university”) to comply with federal guidelines and regulations regarding effort certification of persons on sponsored projects and to maintain records that accurately reflect the effort contributed by personnel to sponsored projects. Effort certification policies, procedures and reports are essential to ensure that the salaries and wages charged to these sponsored projects are allocable, allowable, consistently treated and reasonable. The purpose of this policy is to describe the methods used by the university to achieve these requirements. The failure to maintain accurate effort reporting may result in civil or criminal fraud investigations. The university utilizes the After-the-Fact Activity Records method of accounting for effort under the Office of Management and Budget Circular A-21 ("OMB A-21"), to which compliance is required.
These requirements apply to all employees whose salaries are charged directly, in whole or part, to sponsored projects or are used to meet cost-sharing or matching requirements on sponsored projects and/or have committed effort to sponsored projects, including faculty, professional and non-professional employees, as described below.
Faculty with joint appointments (e.g., with the university and The University of Texas M. D. Anderson Cancer Center) will account only for their activity associated with the university.
A. Sponsored Project Accounts
Sponsored Project Accounts are those accounts involving:
B. Established Timeframes
The designated department representative is responsible for ensuring that the completed effort certification reports are submitted no later than 30 calendar days after receipt.
Primary Individuals and faculty members must complete effort certification reports for their own efforts and for efforts of supporting individuals.
Primary Individuals must certify their own effort reports and must certify effort for employees they directly supervise. They must also verify the reasonableness of the effort certification reports for all other individuals who are paid from their sponsored accounts. University departments and Primary Individuals are responsible for ensuring that all effort certification reports comply with this policy.
Committed Effort: The amount of effort proposed in a grant or other project application that is accepted by a sponsor, regardless of whether salary support is requested for the effort.
Effort: The reasonable estimate of work performed by the employee on a sponsored project during the period covered by the effort report. Effort is based on total institutional activities and does not assume a 40-hour work week or any other standard work week. Effort worked during the period must support any amount compensated. To ensure this, effort must be greater than or equal to funding during the period. If effort is greater than funding, cost sharing may need to be reported.
Effort Certification: A means of confirming that the effort supported or paid by the sponsor has been performed and effort committed in support of a project (but not paid by the sponsor) has been performed.
Minimum Level of Committed Effort: The minimum level of committed effort that may be expended for a Primary Individual listed on every sponsored project on which he or she is involved.
Maximum Level of Committed Effort: The maximum level of committed effort that may be expended for a Primary Individual listed on every sponsored project on which he or she is involved.
Percent of Effort: The proportion of effort expended by an individual for the institution in relation to the amount of time he or she is employed. In all cases, effort for any individual must total 100 percent, even if his or her FTE (full-time equivalent) status is less than 100 percent. Thus a part-time employee (e.g., .5 FTE) will always report 100 percent effort.
Individual: Anyone who has paid effort and/or committed effort on a sponsored project. Where appropriate in this policy the following subcategories will be utilized:
Primary Individual: A person listed as principal investigator, project director, co-investigator, co-project director, or a person with comparable responsibilities on a sponsored project application. A Primary Individual typically, but not always, carries an academic (i.e. faculty) appointment.
Supporting Individual: An employee other than a Primary Individual who has expended effort on a sponsored project. The supporting individual may or may not have been identified on the funded application and typically does not have committed effort greater than the amount paid on that specific sponsored project.
Institutional Base Salary: The total guaranteed annual compensation an individual receives from the university, whether the individual’s time is spent on research, teaching, patient care or other activities. Institutional base salary shall be used to compute salaries charged to federal sponsored projects unless sponsored policies further limit salary charges. Institutional base salary includes compensation for instruction, patient care, public service, research, and/or other activities. Institutional base salary excludes fringe benefit payments; reimbursed expenses; temporary, supplemental compensation for incidental work; income earned outside of duties to the institution; and any portion of compensation deemed to be at-risk.
Total Institutional Activities: Those activities for which an individual is paid by the university. Common activities include administrative duties, instruction, patient care, public service and research.
University Funds: Any funds under the auspices and control of university, including, but not limited to, state, designated, sponsored and/or gift accounts.
A. Approval Process for Sponsored Project Proposals
Per HOOP Policy 64 Applications or Proposals for Sponsored Project Funds, proposals should be submitted to the Office of Sponsored Projects as soon as possible (at least 10 working days before the application deadline) to expedite the review process.
As part of this approval process, each Primary Individual’s supervisor must review and approve the anticipated committed effort in proposals and must ensure that each Primary Individual listed in proposals with a specific committed effort is aware of and has approved his or her participation in the activity. This approval process must also include a review by the Primary Individual's supervisor of the mandatory and voluntary committed cost sharing contained in proposals.
B. Institutional Base Salary
The institutional base salary shall be used to compute salaries charged to federal sponsored projects unless sponsor policies further limit salary charges.
C. Effort Certification
1. Distributing Effort Certification Reports: Sponsored Projects Administration is responsible for distributing effort certification reports electronically to Primary Individuals working on sponsored projects.
2. Calculating Effort: Effort certification reports are based on a reasonable estimate, recognizing that administration, patient care, research, service, and teaching are often inextricably intermingled. Many individuals have multiple responsibilities that must be measured, monitored, and reported. In the course of a workday, the separation among these areas of activity can sometimes be hard to discern, which heightens the need to have effective effort reporting systems.
Effort shown on the effort certification report must be reported in percentages and all effort must equal 100%. If an individual is less than a 1.0 FTE, his or her effort must be converted to 100%. For example, an individual may be funded as .5 FTE, of which .3 is dedicated to Grant A and .2 to Grant B. In terms of effort, however, 100% of this person's effort would be reported as 60% effort on Grant A and 40% effort on Grant B.
3. Effort Attestation: Effort certification reports must contain an attestation statement indicating that the certifier has suitable means of verification and the amounts shown are a reasonable estimate of actual work performed during the stated period.
4. Criminal Penalties: Criminal charges may be brought against an individual who certifies a falsified report.
5. Total Institutional Activities: Effort is based on total institutional activities, including all cost sharing activities, and does not assume a 40-hour workweek or any other standard workweek. It is important to remember that the effort certification report and payroll records are not the same.
6. How to Delineate Total Institutional Activities: Total institutional activities are grouped on effort certification reports according to the classification of expenditures used by the university in its facilities and administrative rate proposal. These classifications may include organized research, instruction, departmental research, patient care, other institutional activities, etc.
7. Minimum and Maximum Levels of Committed Effort: The required minimum level of committed effort listed for a university Primary Individual is 2% on every sponsored project he or she is involved in. Exceptions to this minimum level of effort are granted for equipment and instrumentation grants, doctoral dissertation grants, and augmentation grants. The minimum level and the Primary Individual’s actual effort should be commensurate with his or her responsibilities on that sponsored project.
The maximum level of committed effort for a university Primary Individual who has effort commitments on sponsored projects is as follows:
Executive Leadership (Presidents, Vice Presidents, Deans, Institute Directors)
Academic Leadership (Department Chairs, Division Directors )
Tenured and Tenure-track Faculty
Non Tenure-track Faculty
If a Primary Individual holds more than one position, his or her effort commitments will be limited to the lowest effort cap applicable to any of the positions. There are rare occasions for a Primary Individual to be appointed 100% on sponsored projects. These occasions are rare because the Primary Individual generally performs other activities whose costs are not allowable under OMB A-21.
Exceptions to these minimum and maximum levels require review, approval and signatures by the faculty member, the faculty member's department chair and the respective dean.
8. Changing an Effort Report Prior to Certification: If necessary, changes may be made to an effort report before certification to reflect actual effort worked on the sponsored project. If a change in the effort report impacts funding, the responsible party must submit a Personnel Action Request. If the Personnel Action Request is retroactive, the responsible party must also submit the appropriate documentation to the Post Award Finance (PAF) Team, in compliance with the retroactive personnel action policy (see HOOP Policy 137 Processing Retroactive Personnel Actions). In addition, the responsible party must submit a Cost Transfer Request to the PAF Team, in compliance with the cost transfers policy (see HOOP Policy 96 Cost Transfers).
9. Policy Enforcement: Violations of this policy will be handled in accordance with the appropriate disciplinary policy for faculty, administrative and professional, and classified staff. Travel restrictions will be imposed on faculty who have outstanding effort certification tasks after the 30-day certification window has closed. These restrictions will include travel on University funds or using University time. Additional consequences for untimely completion of effort certification reports may include, but are not limited to, moving all non-certified salary expenses off the sponsored account and onto a departmental unrestricted account.
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