Handbook of Operating Procedures 7-1010
The University of Texas at Austin
Executive Sponsor: Vice President for Research
February 5, 2008
Section I. General Policy Guidelines
- Policy Statement
It is the policy of The University of Texas to comply with federal guidelines and regulations regarding Effort Certification of Individuals and sponsored projects and to support that policy by detailed procedures to ensure that the salaries and wages charged to these sponsored projects are allocable, allowable, consistently treated, and reasonable.
This policy applies to the Effort of all Individuals who have salaries or wages paid from sponsored projects and/or have Committed Effort to sponsored projects.
Cost Sharing is the mandatory or voluntary commitment of institutional resources contained in the proposal/application and resulting award. The concept of matching is synonymous with Cost Sharing.
Effort is the amount of time spent on any activity expressed as a percentage of Total Institutional Activities for which an Individual is compensated by the University and includes:
- Research or Sponsored Projects (i.e., contracts and grants).
- Instruction and non-sponsored research.
- Administrative duties.
- Other institutional activities/responsibilities.
Completed Effort Certification should reflect all activities conducted under the terms of employment, which typically DOES NOT include:
- Outside consulting.
- Stipend payments.
It is EXTREMELY IMPORTANT to understand that Effort is NOT calculated on a 40-hour workweek or any other standard workweek. In addition, total Effort must equal 100%. (For example, if an Individual averages 60 hours per week during the reporting period and spends an average of 15 hours on a Sponsored Program, that represents 25% Effort. The other 45 hours, allocated to other institutional activities, represents 75% Effort.)
Effort Certification is a means of confirming that all of the Effort committed to a project, whether paid on the sponsored award account or expended in support of a project (but not paid on the sponsored account) has been performed. Effort Certification is not a verification of our payroll system’s accuracy. Payroll distribution allocates an Individual’s salary, whereas Effort Certification verifies the allocation of an Individual’s time expressed as a percentage of his/her Total Institutional Activities.
Committed Effort is the amount of Effort proposed in a proposal or other project application that is accepted by a sponsor, regardless of whether salary support is requested in support of the Effort.
An Individual is anyone who has paid Effort and/or Committed Effort on a Sponsored Program.
Institutional Base Salary (IBS) is the total guaranteed annual compensation an Individual receives from the University, whether the Individual’s time is spent on research, teaching, or other activities. The IBS shall be used to compute salaries charged to Sponsored Programs unless sponsor policies further limit salary charges. IBS includes compensation for instruction, public service, research, and/or other institutional responsibilities. IBS 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. IBS may or may not include additional payment for administrative duties per the written policy of the University.
Total Institutional Activities are those activities for which an Individual is paid by the UT Institution. Common activities include administrative duties, instruction, research, and public service.
This policy provides information and guidance on Effort Certification as prescribed by The University of Texas System in the UT System Policy Library UTS163, Guidance on Effort Reporting Policies. The System policy, adopted by the UT System Board of Regents July 1, 2006, establishes guidelines and processes set forth by the Federal Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions.
The requirements of this policy are based on the University’s desire to properly certify Effort. The University requires that this policy be applied consistently across all sponsored projects whether federally funded or not. Training grants (e.g., the “T” service for NIH) may not require Effort and are usually excluded from Effort reporting.
Salaries and wages typically comprise a major portion of the direct costs charged to sponsored projects. Reports of Certified Effort provide auditable documentation that the level of Committed Effort was met. The primary purpose of Effort Certification is to certify that the salaries and wages charged or contributed as Cost Sharing to sponsored projects are appropriately based on percentages of total Effort expended. Section J.10 of OMB Circular A-21, Cost Principles for Educational Institutions, provides the framework for acceptable methods of documenting the Effort that employees expended on sponsored projects.
Principal Investigators (PI’s) are required to use the University’s Effort certification system to certify the Effort of all persons working on their sponsored projects. Although the PI can authorize Individuals who have direct knowledge of work performed to certify or pre-certify Effort on the project, the PI remains ultimately responsible for the accuracy of the certification. Authorization is performed by the PI within the Effort certification system. PI’s or authorized Individuals must verify the Effort, salaries, and wages charged to sponsored agreements every six (6) months.
- General Requirements
- All researchers should review the provisions of UTS163.
- Principal Investigators are required to use the Effort certification system to certify the Effort of all persons working on their sponsored projects. The PI can authorize Individuals who have direct knowledge of work performed to certify or pre-certify Effort on the project. However, the PI remains ultimately responsible for the accuracy of the certification. Authorization is performed by the PI within the Effort Certification system.
- The PI is responsible for determining the appropriate Effort to be committed on a sponsored project. The Effort must reflect a reasonable estimate of the time that will be required to conduct the project.
- The PI is required to complete the Effort Certification within 45 days of receipt of notification by Contracts and Grants to certify Effort.
- A minimal commitment of 1% is required on the part of the PI and other key personnel during the project. The minimum requirement does not apply to:
- Equipment grants.
- Dissertation grants.
- Other awards intended as “student augmentation.”
- Limited-purpose grants such as travel grants or conference support.
The Effort can be expended during the academic year, the summer, or both.
- The Effort expended on Total Institutional Activities must not exceed 100%. Generally, most faculty have responsibilities for teaching or service that would preclude them from devoting 100% of their time to sponsored activities; exceptions to this include key research staff who do not have other responsibilities. Thus, in most situations, the University requires that a researcher not commit more than 95% Effort on sponsored projects. In all cases, the researcher’s 9-month salary rate cannot exceed his/her Institutional Base Salary (IBS) rate on sponsored programs.
- For NIH awards, the researcher’s academic salary plus summer salary (i.e., “annualized” salary) claimed on a project cannot exceed the annual NIH salary cap. The NIH salary cap is revised every calendar year and is available at http://grants2.nih.gov/grants/policy/salcap_summary.htm.
- The number of months during the summer that a researcher can claim salary may be limited by summer teaching assignments and also by Individual funding agencies. For example, NSF limits summer salary to no more than two-ninths of the regular academic-year salary.
- Should the Effort of the faculty/researcher charged or contributed (Cost Sharing) to sponsored activities exceed the approved amount of the college/center, the PI must gain approval of the dean/chair or director to ensure that the Total Institutional Activities do not exceed 100% or require a release from other institutional responsibilities.
- Commitment of summer Effort for all sponsored activities can be up to, but not more than, 100%, assuming that the researcher does not teach during the summer. Some agencies do not allow payment of 100% salary for all three months during the summer (e.g., NSF). Researchers should check with the guidelines for sponsoring agencies.
- All researchers and others who are authorized to certify or pre-certify Effort are required to complete an Effort training course prior to performing Effort Certification (see also Section II.F below). Subsequent training will be provided in accordance with the following schedule, or more frequently if determined by the requirements of sponsoring agencies:
- For researchers and others who have been previously authorized, training will occur at least once every two years.
- For newly hired, assigned, or engaged researchers or unauthorized persons, training will occur 30 days after the date that the person is:
- hired by the University, or
- otherwise engaged or assigned to perform certification.
Section II. Responsibilities, Training and Monitoring
- PI's Responsibility
The PI is responsible for ensuring that Effort committed on a project is accurate and properly reflected in the Effort Certification system. The Effort Certification must be completed within 45 days of notification by Contracts and Grants to certify Effort. As noted earlier in the policy, the PI can authorize Individuals who have direct knowledge of the work performed to certify or pre-certify Effort on the project. The PI is required to monitor the level of Effort committed to all projects.
- Responsibility of Chair and Dean
The responsibility for determining the balance between the PI’s research, teaching, and service falls to the chair or dean of an academic unit. The deans of the colleges are responsible for setting the minimum and maximum levels that a PI can commit to sponsored projects and for providing the Office of Sponsored Projects with that information.
If a PI successfully obtains funding for more than the amount authorized by the chair or dean during the academic year or for more than three months of summer salary, a reduction in the Effort commitment or in other institutional responsibilities must be effected.
- Responsibility of the Office of Sponsored Projects
It is the responsibility of the Office of Sponsored Projects to ensure that a system is in place to ensure that the PI’s fulfill the requirement for review and certification of salaries, and to assure that the salaries of key personnel charged to sponsored projects correspond to Effort expended on those projects, within the appropriate limitations. Toward that end, OSP is responsible for:
- Reviewing and authorizing the proposal/applications of faculty/researchers.
- Ensuring that the PI has gained approval from the department chair and/or dean for proposals that include Effort exceeding thresholds approved by the chair or dean for time either contributed to or charged to the project.
- Ensuring the faculty member negotiates any adjustments in Effort with other funding agencies if a new award results in the faculty/researcher exceeding the 100% limit of Total Institutional Activities as appropriate and allowable.
- Ensuring that a Cost Sharing form (see http://www.utexas.edu/research/osp/cost_share.pdf) is completed when the Effort on the project is contributed rather than charged to the project. (download AdobeReader)
- Accepting awards on behalf of the University subject to proper verification of the appropriate time and Effort and any approvals required by the department chair/dean and/or sponsor.
- Responsibility of the Contract and Grants Section of the Office of Sponsored Projects
Contract and Grants is responsible for ensuring that the PI certifies the time and Effort of key personnel on the project every six (6) months through the online Effort Certification system. Contract and Grants will review all Effort reports for compliance. If the PI does not certify Effort by the required deadline, Contract and Grants will take steps to notify the PI of the non-compliance by e-mail. If the PI does not comply by the notified deadlines, Contract and Grants will suspend all accounts until the certification is completed.
- Responsibility of the Vice President for Research
The Vice President for Research is the designated responsible party for monitoring and meeting the committed level of Effort and the level of Effort by the Principal Investigator and “key personnel” on all projects. The Vice President for Research is responsible for compliance with this policy and development of education and training programs to assist all administrators, faculty, and staff with understanding the intent and the implications of policies related to Effort Certification. In addition, the Vice President for Research is responsible for establishing an effective monitoring process that is based on risk assessment, identification of internal controls, the identification of monitoring strategies to be deployed, and effectively communicating the monitoring plan criteria to the executive managers. The Vice President for Research has charged the Office of Sponsored Projects with the responsibility for overseeing commitments management and the performance of Effort Certification.
- Effort Reporting Education Program
All administrators and staff involved with the Effort Certification process are required to complete the Effort Certification Education Program. In addition, all faculty members who receive external funding for sponsored activities are required to complete the Effort Certification Education Program.
- Consequences of Non-Compliance
Non-compliance with the Effort Certification policy may lead to suspension of the PI’s research rights and privileges with the University. If a PI does not adhere to the Effort Certification policy, the University has the right to disallow the PI to submit proposals and may inactivate existing accounts in the accounting system. In addition, disregarding the policy may also lead to other disciplinary actions in accordance with University policies.
Falsification of Effort Certification information may lead to criminal charges against the Individual who falsely certified the information and against the PI responsible for the award.
Source: UT System UTS163, Guidance on Effort Reporting Policies. In compliance with Federal Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions.
Previously HOP 11.B.4