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 individuals who expend effort on sponsored projects and to maintain records that accurately reflect the effort contributed by individuals 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 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.

Accountability

Reporting requirements related to this policy apply to individuals with a faculty appointment (both tenure and non-tenure track) and/or individuals with or without a faculty appointment who serve as a principal investigator, co-investigator, project director, co-project director or those with comparable responsibilities on a sponsored project.    All such individuals must complete effort certification statements for their own efforts and for the efforts of research staff, associates and those individuals with non-faculty positions who expend effort and/or salary on the sponsored projects. (This process is referred to as Project Certification.) Effort certification of all individuals must be done timely and by the stated deadline identified upon the opening of the effort certification period.

All Primary Individuals (as defined below), University departmental leadership (Chairs, DMOs, Administrators) and effort coordinators are responsible for ensuring that all effort certification statements comply with this policy.

II. DEFINITIONS

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 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 and for all individuals with a principal investigator, co-investigator, project director, co-project director or those with comparable responsibilities on a sponsored project. 

Individual: Anyone who has paid effort and/or committed effort on a sponsored project. Where appropriate in this policy the following subcategories will be used:

• Primary Individual:  Individuals with a principal investigator, co-investigator, project director, or co-project director role or those with comparable responsibilities on a sponsored project who may or may not have a faculty appointment at the University. This also includes individuals with a faculty appointment at the University who do not have these comparable responsibilities.
• Supporting Individual: An employee who does not have a faculty appointment and does not serve as a Primary Individual on a sponsored project (e.g., research associates, graduate students, postdoctoral research fellows, research staff and other staff level employees) but who does have salary directly charged or cost shared from a sponsored project.  It is the responsibility of the Primary Individual to certify payroll percentage as it equates to the effort for each of these individuals on the sponsored projects for which the Primary Individual is responsible. 

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 for a Primary Individual on each sponsored project. 

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

Project Certification Statement: Effort statement that displays all Supporting Individuals who worked on the Primary Individual’s sponsored projects.

Sponsored Project:  A project funded by a federal or nonfederal 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.        Approval Process for Sponsored Project Proposals

Per HOOP Policy 64, Applications/Proposals or Contracts for Sponsored Projects, proposals must be submitted to Sponsored Projects Administration (SPA) for approval prior to submission. As part of this approval process, each Primary Individual and his/her supervisor 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.

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. Types of Effort Certification: SPA is responsible for formally initiating the effort certification process.  This process generates electronic effort reports for Primary Individuals (Effort Certification Statements).  Primary Individuals will also receive electronic effort reports by project (Project Certification Statements) in order to certify the effort of Supporting Individuals working on their projects.

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 shown on the Effort Certification Statement must be reported in percentages and an individual’s total effort must equal 100% for Primary Individuals. 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 FTE is dedicated to Grant A and .2 FTE 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.

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.

Effort listed on the Project Certification Statements must be certified by project for all Supporting Individuals.  This will be displayed by project and may not total 100% for Supporting individuals. If the Supporting Individual has a 0.5 FTE, the effort distribution would be based on the payroll distribution for each specific project not on the FTE. For example, a Supporting Individual may be funded as .5 FTE with an Institutional Base Salary of $50,000 with a compensation rate of $25,000 (0.5 * $50,000).  If that individual’s payroll distribution is 40% on Grant A and 60% of Grant B, the salary distribution would $10,000 on Grant A and $15,000 on Grant B.  The Primary Individual for Grant A would review 40% payroll distribution on the Project Certification Statement and the Primary Individual for Grant B would review the 60% payroll distribution on the Project Certification Statement.

3. Effort Attestation: Effort Certification Statements must have an attestation statement indicating that the certifier (Primary Individual) has suitable means of verification and that 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 statement.

5. Minimum and Maximum Levels of Committed Effort: 

Minimum Level of Committed Effort - The required minimum level of committed effort listed for Primary Individuals 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. The Primary Individual’s minimum level and actual level of effort shall be commensurate with his or her responsibilities on that sponsored project.

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

Position	Effort Cap
University Executive Leadership (e.g., President, Vice Presidents, all levels of Deans) and Leadership in Clinical Departments (e.g., Clinical Chairs, Clinical Division Directors)	70%
Academic Leadership in Basic Science Departments (e.g., Department Chairs, Division Directors)	80%
Tenured and Tenure-Track Faculty (Clinical and Basic Research)	90%
Non-Tenure-track Faculty (Clinical and Basic Research)	95%

If the 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. 

Requests for exceptions to these minimum and maximum levels must be made in writing for funded proposals prior to expending effort on the project. These exception requests require review and signed approval by the Chief Academic Officer or designee. 

6. 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 party must submit a Personnel Action Self Service (PASS) transaction in Human Capital Management (HCM). If the PASS transaction is retroactive, the responsible party 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. Effort recertification is not allowed after the effort reporting period has closed.

7. 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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