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Sponsored Projects Administration

FEDERAL REQUIREMENTS FOR EFFORT REPORTING

The Uniform Guidance Subpart E §200.430 contains the federal regulatory requirements for internal controls over certifying time expended on sponsored projects. The University’s practice is to utilize an after-the-fact effort reporting system to certify that salaries charged, or cost shared to sponsored awards, are reasonable and consistent with the work performed. The individual’s effort is first assigned to specific awards in the payroll system based on anticipated activities.  Actual effort expended on each project is certified by a responsible person with suitable means of verification that the work was performed at the end of specified reporting periods. The effort certification should be a reasonable estimate of how time was expended. Section §200.430(c) states, “It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting.  When recording salaries and wages charged to Federal awards for IHEs [Institutions of Higher Education] a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.”

The biannual effort certification is the primary means for complying with the federal regulation relating to effort certification

UTHEALTH POLICY

UTHealth has established Hoop 93 to ensure the university complies with federal guidelines & regulations.


Minimum & Maximum Levels of Committed Effort

This policy includes Minimum & Maximum Levels of Committed Effort. UTHealth requires a minimum level of committed effort listed for a university Primary Individual is 2% on every sponsored project he or she is involved in (Excluding 57001). 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:

Position Effort Cap
Executive Leadership (Presidents, Vice Presidents, Deans, Institute Directors) 70%
Academic Leadership (Department Chairs, Division Directors) 80%
Tenured & Tenure- Track Faculty 90%
Non-Tenure- Track Faculty 95%
All Others

100%


Reopening of Effort Statements

During the 30-day certification period, statements can be reopened to allow for adjustments of any kind.

After the close of the certification period, statements that have been certified and processed will not be reopened, unless they meet the below criteria:

Reopened statements have 10 days to complete certification.

After the 30-day period, discrepancies on the statement should be notated in the notes & attachment sections of the applicable statement.


Non Compliance/Travel Restrictions

PI's & Faculty are encouraged to certify effort statements in a timely manner to ensure compliance with Federal & UTHealth policy & regulations. A certification period of 30 days is provided for faculty to certify effort for the previous six month reporting period. Travel restrictions will be implemented on outstanding effort certification cards after the 30 day certification window has closed. These restrictions include travel on University funds or using University time.

After the 30 day certification period, uncertified effort statements, not placed in a hold status, will result in travel restrictions. The statement must be certified & processed to remove the travel restriction. Placing the statement in a hold status after the travel restriction notice is not sufficient for the removal of the travel restriction.

After the 30 day certification period, uncertified effort statements, placed in a hold status, will delay travel restrictions for up to 30 days.

30days after the close of the certification period, ALL uncertified statements, will result in travel restrictions. The statement must be certified & processed to remove the travel restriction.

Effort cards requiring manual certification due to faculty departure or other circumstances should be certified during the 30 day certification window and submitted to the Effort Reporting team at effort@uth.tmc.edu for processing. These statement are subject to travel restrictions.

Effort cards that are reopened for certification after the 30 day certification period will have ten business days to be recertified and processed before travel restrictions are imposed.

Notifications of non-compliance & travel restrictions after the 30 day certification period will follow the below schedule:

Time Period Statement Status Distribute To: Action
February 20th or August 20th 1st Round of Travel Restrictions for Statements, Not in Hold Status Primary Effort Coordinator, Faculty/PI, DMO or equivalent

S&R will inform the respective departmental academic and administrative leadership of noncompliance.

Department team/leadership should communication with researcher to ensure that they understand the specific issues & to receive assurance from the research that the delinquent reports will be completed immediately & that efforts will be made to reduce the likelihood of future non- compliance.

March 20th or September 20th All Un-certified Statements Result in Travel Restriction Primary Effort Coordinator, Faculty/PI, DMO or equivalent

S&R will inform the respective departmental academic and administrative leadership of noncompliance.

Department team/leadership should communication with researcher to ensure that they understand the specific issues & to receive assurance from the research that the delinquent reports will be completed immediately & that efforts will be made to reduce the likelihood of future non- compliance.

2nd Notice >73 to 114 days All Un-certified Statements Primary Effort Coordinator, Faculty/PI, DMO or equivalent, & Dean

S&R will inform the respective Dean of the second report of noncompliance.

Dean will communicate with the researcher in order to receive assurance from the researcher that the delinquent reports will be completed immediately and that efforts will be made to reduce the likelihood of future non-compliance.

3rd Notice > 115 to 156 days All Un-certified Statements Primary Effort Coordinator, Faculty/PI, DMO or equivalent, Dean, & EVP of Research

S&R will inform the Executive Vice President of Research of the 3rd report of noncompliance

EVP will communicate with the researcher to receive assurance from the researcher that the delinquent reports will be completed immediately and that efforts will be made to reduce the likelihood of future non-compliance. EVP will also communicate the consequences of any future non-compliance.

4th Notice> 157 days All Un-certified Statements Primary Effort Coordinator, Faculty/PI, DMO or equivalent, Dean, EVP of Academic & Research Affairs, & President

S&R will 

EVP will inform the President of the noncompliance. They will evaluate the noncompliance. If its determined that the noncompliance does not rise to intentional, willful, or reckless disregard for effort certification requirements, the researcher will meet with the President (or his/her designee) to propose a corrective action plan, consistent with the Disciplinary Guidelines below, that assures compliance with the applicable standards of effort reporting.

If the EVP determines that the noncompliance is the result of a researcher’s intentional, willful, or reckless disregard for the effort certification requirements, including, but not limited to, evidence of repeated failure to heed the recommendations of the Systems & Reporting Team, with respect to effort certification, or where the evidence supports a finding that there is a pattern of disregard for the effort certification requirements, then disciplinary action shall be initiated, consistent with the Disciplinary Guidelines below.


Other action may be implemented as determined by the Chief Compliance Officer and by the Executive Vice President for Research.

Disciplinary Guidelines: 
If, as part of the corrective action plan, disciplinary action is recommended, such action will be taken based on the facts and circumstances relating to the incident(s) of non-compliance.  Disciplinary actions may include, but are not limited to: 
  • Focused retraining of the faculty regarding compliance with effort certification issues and standards until he/she has demonstrated competency on the issue(s) in question
  • Moving all non-certified salary expenses off the sponsored account and to a departmental unrestricted account
  • A recommendation for suspension, without pay, or termination of the offending faculty member or employee. 
Disciplinary action(s) involving UTHealth faculty, administrative and professional staff, or classified staff members shall be administered in accordance with The University of Texas System Board of Regents’ Rules and Regulations and the UTHealth HOOP 133 Faculty Termination, 153 Termination of Employment, or 187 Disciplinary Actions, respectively, as applicable.