Effort Certification

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 employees who expend effort on sponsored projects and to maintain records that accurately reflect the effort contributed by employees to sponsored projects. Effort certification policies, procedures and reports are essential to ensure that the salaries and wages charged to 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 uses the After-the-Fact Activity Records method of accounting for effort as required by the Office of Management and Budget Uniform Guidance (Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards).

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.

Faculty with joint appointments with other institutions (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.

II. DEFINITIONS

Committed Effort: The proposed percentage of time that will be dedicated to the project as submitted in a grant or other project application that is accepted by a sponsor, regardless of whether salary support is requested for the effort or the level of effort officially approved by the sponsor.

Effort: The proportion of time spent on any activity expressed as a percentage of total institutional activities for which an individual is compensated by the University.  Total effort of an employee must always equal 100%, regardless of part-time or full-time status, and regardless of hours worked.

Effort worked during the period must support any amount compensated.  The effort on a sponsored project may be equal to or greater than the salary charged to the project. If effort is greater than funding, cost sharing may need to be reported.

Effort Certification: A means of confirming the percentage of effort spent in support of each sponsored project and all other institutional activities for a given period of time. Effort Certification requires that both effort paid by the sponsor and effort paid by the institution be confirmed. Each individual's Effort Certification must account for total effort (100%).

Effort Certification Statements: Effort Certification Statements are generated for all faculty with compensation and/or cost sharing on sponsored projects (Individual Effort Statements) and for each sponsored project from which non-faculty employees are paid (Project Statements).

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 and/or other activities. 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 and/or administrative work; income earned outside of duties to the institution; and any portion of compensation deemed to be at-risk.

Minimum Level of Committed Effort: The minimum level of committed effort that may be expended by a faculty member on each sponsored project.

Maximum Level of Committed Effort: The maximum sum of committed sponsored effort in total for all sponsored projects that may be expended by a faculty member.

Sponsored Project:  A project funded by a federal or non-federal sponsor through a grant, contract, cooperative agreement, or other instrument under which the University agrees to perform a certain scope of work, according to specified terms and conditions, for a specific budgeted monetary compensation.

University Funds: Any funds under the support and control of the University, including, but not limited to, state, designated, sponsored project and/or gift funding mechanisms.

III. PROCEDURE

A.        Roles and Responsibilities

The University’s effort reporting and certification program is a multi-faceted process that requires collaboration among schools, departments, Sponsored Projects Administration (“SPA”), faculty and University leadership to ensure a robust, compliant and timely program that minimizes risk to the University. 

SPA is responsible for establishing and maintaining the effort reporting policy, processes, system, and procedures. This includes oversight of the semi-annual effort reporting process, ensuring timely reporting and compliance with federal and sponsor effort rules. 

Schools, departments and effort coordinators are responsible for properly allocating effort and payroll to all sponsored projects in a timely manner, reviewing and correcting effort statements on a regular basis, and pre-reviewing effort statements prior to certification.

Faculty are responsible for reviewing and certifying their own semi-annual effort statements and reporting any errors or missing projects to their assigned effort coordinator. Faculty should not certify an erroneous effort statement. 

Principal Investigators/Project Directors (PI/PDs) are responsible for reviewing and certifying non-faculty payroll charged to their sponsored projects and for reporting any errors or missing projects to their assigned effort coordinator. PI/PDs should not certify an erroneous project statement.

B.        Approval Process for Sponsored Project Proposals

Per HOOP Policy 64, Applications/Proposals or Contracts for Sponsored Projects, proposals must be submitted to SPA for approval prior to submission. As part of this approval process, each faculty member and his/her department are responsible for the review and approval of the anticipated committed effort on all proposals. This review and approval must also include all mandatory and voluntary committed cost sharing included in all proposals.

C.        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.

D.        Effort Certification

1. Schedule: Individual and project effort statements are initiated semi-annually for the prior six-month reporting period. The effort reporting schedule and processes are maintained on SPAs website. https://www.uth.edu/sponsored-projects-administration/manage/effort-reporting 

2. Calculating Effort: Effort Certification and Project Certification Statements are based on a reasonable estimate, recognizing that administration, patient care, research, service, and teaching are often inextricably intermingled.

Effort Certification (Faculty)

Effort shown on the Effort Certification Statement must be reported in whole percentages and an individual’s total effort must equal 100%; if an employee is less than a 1.0 full-time equivalent (“FTE,”), his or her effort must be converted to 100%. For example:

FTE	Calendar Months/% effort on grant A	Calendar Months/% effort on grant B	Formula	Reported Effort Grant A	Reported Effort Grant B
0.50	2.4 / 20%	3.6 / 30%	Grant A: (20% / 50%) x 100 = .4 Grant B: (30% / 50%) x 100 = .6	40%	60%
0.80	1.2 / 10%	1.8 / 15%	Grant A (10% / 80%) x 100 = .125 Grant B (15% / 80%) x 100 = .1875	13%*	19%*

*In this example, effort is appropriately reported as a whole number.

Effort on Effort Certification Statements is based on total institutional activities, including all cost sharing activities, and does not assume a 40-hour work week or any other standard work week. It is important to remember that the Effort Certification Statements and payroll records are not the same.

Payroll (Project) Certification (non-faculty)

Payroll percentages listed on the Project Certification Statements must be certified by sponsored project for all non-faculty employees. This will be displayed by project and may not, depending on the circumstances, total 100% for non-faculty employees. If the non-faculty employee is a 0.5 FTE, the effort distribution would be based on the payroll distribution for each specific project not on the FTE. For example:

FTE	Annualized Base Salary	Base x FTE	Reported Grant Effort	Salary Distribution
0.50	$50,000	$25,000	Grant A : 40% Grant B: 60%	Grant A: $25,000 x .4 =$10,000 Grant B: $25,000 x .6 =$15,000
0.80	$50,000	$40,000	Grant A = .12.5%** Grant B = 18.75%**	Grant A: $40,000 x .125 = $5,000 Grant B: $40,000 x .1875 =$7,500

**For non-faculty employees, PI is certifying percent and amount of payroll charged, not % effort.

3. Effort Attestation: Effort Certification Statements must have an attestation statement indicating that the certifier has suitable means of verification and that the amounts shown are a reasonable estimate of actual work performed during the stated period. The University requires the faculty member to certify their own effort statement, and PIs to certify their project statements. Only the faculty member’s supervisor can be named as a delegate to certify effort statements in the event of the faculty member’s extended absence or separation from the University.

4. Effort Non-Compliance Escalation: When a faculty member or PI/PD fails to timely certify effort reports, SPA will initiate an effort certification escalation process described here: Delinquent Effort Certification Escalation Process.

5. Changing an Effort Certification Statement or Project Certification Statement Prior to Certification: If necessary, changes may be made before certification to reflect actual effort worked on the sponsored project. If a change in the effort impacts funding, the responsible department must submit a Personnel Action Self Service (PASS) transaction in Human Capital Management (HCM). If the PASS transaction is retroactive, the responsible department must submit the appropriate documentation and Cost Transfer Request to Post Award Finance (PAF) in compliance with HOOP Policy 96, Cost Transfers. Funding changes after the certification period has ended are not allowed except under extreme circumstances and must be justified and approved in writing.

6. Effort Validation Period: SPA may, pending a compliance review, reopen any non-compliant effort reports for review, correction and recertification. This review and correction process does not allow for additional salaries to be applied to a project after certification.

7. Criminal Penalties: An individual who certifies a false statement may be subject to criminal charges.

E.      Minimum and Maximum Levels of Committed Effort

All senior/key personnel’s minimum and committed level of effort shall be commensurate with his or her responsibilities on that sponsored project.

Minimum Level of Committed Effort - The required minimum level of committed effort listed for all senior/key personnel on each sponsored project is 2%. Exceptions to this minimum level of effort are granted for industry sponsored clinical trials, equipment and instrumentation grants, doctoral dissertation grants, and augmentation grants.

Maximum Level of Committed Effort – Depending on the faculty member’s position at the University, the maximum total sum of all committed effort for all sponsored projects is as follows:

Highest Position	Maximum Research Effort Allowed
University Executive and Clinical Leadership (e.g., President, Vice Presidents, all levels of Deans except as noted below, Clinical Chairs, Clinical Division Directors)	75%
Academic Leadership in Basic Science Departments (e.g., Department Chairs, Division Directors); SPH Associate and Regional Deans	80%
Institute and Center Directors (Clinical)	85%
Tenured and Tenure-Track Faculty (Clinical and Basic Research); Institute and Center Directors (non-clinical)	90%
Non-Tenure-track Faculty (Clinical and Basic Research)	95%

If the faculty member holds more than one position, his or her effort commitments will be based on the highest position held at the University. 

Requests for exceptions to these minimum and maximum levels may be requested annually by completing and submitting an Effort Waiver Form.

F.      Policy Enforcement

Violations of this policy will be handled in accordance with the appropriate disciplinary policy for faculty, administrative and professional, and classified staff. The consequences for lack of timely completion of Effort Certification and Project Certification Statements may include, but are not limited to, the moving of all non-certified salary expenses off the sponsored account and onto a departmental unrestricted account.

Effort Reporting Procedures and Resources

https://www.uth.edu/sponsored-projects-administration/training-guidance/internal-training/effort

IV. CONTACTS

• • Sponsored Projects Administration
  • 713-500-3999
  • [email protected]

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