OMB Circular A-21 states, "it is recognized that, in an academic setting, teaching, research, service and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible, nor is it expected. Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate."
Federal regulations clearly acknowledge that precise determinations are not expected, and that reasonable estimates are acceptable.Consistent with the Federal regulations, you are obliged to use your best judgment in your certification, taking into consideration all of the activities that you were engaged in during the course of the reporting period.
Why can't a departmental administrator certify my effort for me?
Federal regulations & HOOP Policy require a certification that the salary charged is reasonable in relation to the effort expended. The regulations further requires that the certification be signed by the principal investigator, responsible official or employee, using suitable means of verification.
In the past, following the broad Federal requirement, the University has permitted a variety of individuals to certify effort, as long as they have the requisite knowledge to do so. The University with input from UT System has determined that best practices dictate that faculty self certify their effort. In addition, a principal investigator is now required to certify the effort of others charged to his/her sponsored project.
Who is required to certify? And how often?
All faculty members who receive any portion of their salary from a sponsored project, or otherwise provide effort on a sponsored project, must self certify their effort. In addition, a principal investigator is required to certify the effort of most other staff who devote effort to their sponsored project (s).
My effort varies during the year. Is it necessary to change my salary funding to reflect short term fluctuations?
No. The Federal regulations specifically acknowledge that this occurs, and state that short term fluctuations (such as one or two months) need not be considered as long as the distribution is reasonable over the reporting period (six months).
Is there a max level of effort I can commit to sponsored projects?
Yes. There are rare occasions for a primary individual to be appointed 100% on sponsored projects. These occasions are rare due to the likelihood the primary individual will perform other activities whose costs are not allowable under OMB A-21.
The required maximum level of committed effort for a university primary individual who has effort commitments on sponsored projects is below.
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.
Exceptions to these minimum and maximum levels require review and approval by the respective Dean and the Executive Vice President for Academic and Research Affairs, by submitting a waiver to email@example.com with all the required signatures.
Executive Leadership (Presidents, Vice Presidents, Deans, Institute Directors)
Can I charge administrative staff directly to my sponsored project?
Generally, administrative staff may not be charged to sponsored projects. There are, however, two major exceptions to that rule:
- where the nature of the administrative work relates directly to the science itself, or
- where the extent of administrative work required by the project is very significant (for example, a Program Project grant).
For further guidance, contact your departments assigned Sponsored Projects Administration, Grants & Contracts team member.
Is the time I devote to writing grant proposals chargeable to my sponsored project?
As a general rule, a portion of a faculty member's time devoted to writing proposals should be charged to non-sponsored sources, as is the case for time devoted to teaching and administration. If the proposal writing relates to providing budget, technical and other materials on a continuing project (i.e., a non-competing renewal of an existing project), that time is part of the effort devoted to that project. For new proposals, if a portion of the proposal is a summary of work done on another sponsored project, that time may be charged to the other sponsored project. However, all other effort devoted to writing grant proposals for either new awards or competitive renewals of existing awards may not be charged to sponsored projects.
If I determine that I need to reduce the effort (& pay) on my sponsored project, where will the funding for that non-sponsored effort be paid from?
Funding for non-sponsored activities such as teaching, administrative activities (including proposal writing as described above), as well as cost sharing on sponsored activities must be charged to non-sponsored sources (i.e., departmental funds). Under no circumstances may the costs associated with these activities be charged to sponsored projects; funding for these activities is a departmental and/or university issue and you should discuss this with your Chair and/or Dean.
I have funds from a clinical contract with a hospital,etc. These accounts always show up in the sponsored section on my effort statement. Do I need to certify?
You do not have to complete traditional certification. Please submit the list of impacted statements to firstname.lastname@example.org. Please include a comment explaining why these individuals should be “No certification required.” The comment will be saved in the notes section for auditing purposes. This is not applicable to Faculty. Faculty are still be required to certify their effort.
Since clinical trial payments are typically received only when milestones are met, there is usually a lag time involved in getting enough money in a clinical trial account to where you can assign salaries. What is the best practice in this case?
HOOP Policy requires an effort commitment of 2% for all sponsored research. If no pay is given from the study, the cost shared portion of the salary should be reflected in the non sponsored/non restricted section of the effort statement. You should add a note to the effort statement explaining the cost sharing.
If you wish to pay salary, SPA suggest the salary be applied when funds become available. This will relieve the cost share for the given period(s). Please be mindful that cost sharing CANNOT occur on other restricted accounts. Cost sharing CAN occur on gifts if meeting the intent of the donor
We recently discovered one of our research faculty is being budgeted 100% on a grant. This grant was approved several years ago and only recently did we get flagged for exceeding the maximum effort. We, as the department, were unaware that this was an issue since the grant itself was intended to recruit these faculty (Emerging Technology Grant).
HOOP Policy 93 states effort caps for faculty that have commitment obligations. If the faculty is over the maximum or not meeting the minimum effort percentage, a waiver is required justifying why they may be over or under the committed effort level. The effort can also be reduced through prior approval. Contact SPA to initiate the reduction with the sponsor.
Is Maximum effort based on the 6 month effort period or by fiscal year?
Its based on calendar year.
Should we just average the maximum effort over the 6 month/fiscal year period or is it at all times? For example, could I have a faculty 100% sponsored for half the year and then 50% sponsored/50% departmental for the other half of the year and not need the maximum effort waiver because averaged over a year it will be within policy?
Effort is reported and tracked every 6 months and should be averaged by that six-month period. The effort calculation worksheet is available to assist in determine effort levels to report.
What happens if a PI/Faculty has left before certifying?
Manual Certification is required. The effort coordinator must have the Effort PDF File printed and signed by the chair of the department or a person with suitable knowledge of the work performed. A manual certification cover sheet should be attached. The document must then be scanned and emailed to email@example.com for processing. Please name your document with Last Name EMPLID Reporting Period (S01 YYYY=Jan-Jun Period and S02 YYYY=July-Dec) EX: Doe 111111 S01 2013
Does effort certification need to be completed for causal/non-permanent/temporary employees?
Yes & No; Certification in eCRT is not completed for casual/nonpermanent/temporary employees. The submission of a timesheet, signed by the employee & their supervisor who uses a suitable means of verification that the work was performed, is the document of record to substantiate salary charges to sponsored projects. The timesheet includes a certification of effort & fulfills the requirements of OMB Uniform Administrative Requirements, 200 CFR §430.
How do I make changes to an incorrect statement?
If the error is with payroll, a PASS transaction must be submitted to correct. If the error is with committed effort, please contact Systems & Reporting. If you believe its a technical error, please contact Systems & Reporting
During the 30-day certification period, statements can be reopened to allow for adjustments of any kind. After the 30-day period, discrepancies on the statement should be notated in the notes & attachment sections of the applicable statement.
All faculty members are required to certify, within a timeframe mandated by the University. Failure to satisfy this requirement will be subject to the escalation schedule and corrective action plan that the university developed and implemented on June 1, 2010.
Are there any other annual effort reporting obligations?
Yes, you should monitor your salary allocation, via ECRT or through your monthly statements of account, to ensure that adjustments are made timely.
I wasn't aware of the effort policy during proposal submission. Is it too late to fix effort problems now?
No, please work with your department SPA Preaward administrator to make applicable adjustments
When we have individuals on funding from another school, within UTHealth, whose responsibility is it to remind the PI to sign off? Should I notify the PI, the other school effort coordinator, or both?
It is the responsibility of each schools PI/Faculty and primary effort coordinator to validate the effort percentages and pay on their accounts. It is also that department’s responsibility to certify and process on time. Although this is the case, you may also feel free to communicate with that schools effort coordinator.
In the past, I have sent a list of individuals paid from clinical contracts, that do not require effort certification to firstname.lastname@example.org to have them automatically processed. Is this still the case?
Yes,you do not have to complete traditional certification. Please submit the list of impacted statements to email@example.com . Please include a comment explaining why these individuals should be “No certification required.” The comment will be saved in the notes section for auditing purposes. This is not applicable to Faculty. Faculty will still be required to certify their effort.
I have an individual with multiple position in different departments/schools. If one position was not certified & became delinquent, the PI would say they certified the effort statement not knowing there was another position. Who should contact the other department/school to certify the remaining lines?
It is the responsibility of each schools PI/Faculty and primary effort coordinator to validate the percentage effort and pay on their accounts. It is also that department’s responsibility to certify and process on time. Although this is the case, you may also feel free to communicate with that schools effort coordinator and/or the effort mailbox.
Please note travel restriction will only be applied the faculty member with the outstanding line.
PASS TRANSACTIONS & EFFORT
What is the retro personnel action process and the steps once an effort card has been closed out and needs to be reopened and certified?
When a retro personnel action is submitted to Systems & Data Reporting (SDR), SDR will submit it to the Post Award Finance Team (PAF) for approval. Once approved by PAF, SDR will enter the retro PA into HCM. The retro PA will be loaded onto the effort card when payroll loads on the 3rd or 17th of each month. Once approved by PAF and the correct data has hit the effort card through data load the effort coordinator can contact the effort team to re-open the card that will need adjusting. The departmental effort coordinator should then place the card on hold to prevent the Faculty member from certifying before adjustments are made. The effort coordinator shall find the individual effort card to be re-opened. The effort coordinator will then need to take the card off hold and make the adjustments under certified effort to match payroll and click “Save to complete later”. Once Save to Complete Later is clicked, the card is ready to be certified by the Faculty member. When certified the card will be back in the effort coordinators “Manage Effort tasks” box for processing.
NOTE: If the request is allowable, the PAF team will check to see if an Effort Report has been generated for the account effected. If an Effort Report has been generated, PAF will check to see if it has been certified by the department. If the Effort Report has already been certified by the department, the PAF team will disapprove the request and forward their disapproval to the SDR team. However, expense can still be transferred from a Sponsored Project Account to an All Other Account.
NOTE: All cards placed on hold should have an effort note as to why it is on hold
Is there an eCRT report that shows effort by individual department for the 6 month or fiscal year period?
The “External Audit Report” will pull an individual or department in a format similar to an effort card. This can be found under Data & Workflow ->View Reports ->External Audit Report.
What is the process of certifying effort for faculty that are above the salary cap and have several staff reporting to them under ecrt®?
The system builds the card from payroll. The salary cap worksheet was developed to assist with salary cap effort calculations. It is the effort coordinator’s responsibility to change the certified effort column during the pre-review prior to opening of the certification period. You can run a report in HCM under UT Effort Reporting>Reports>Funding History File. This report will allow you to retrieve a 6 month period of all the funding PA’s that were submitted and entered on the Department Budget Earn report showing the effort percentage and FTE percentage. You can use this to plug the percentages into the Effort Calculation worksheet. At the very end of the worksheet, it will show you how the effort card should look.
What happens when an effort card is put on hold?
An effort card can only be put on hold by the effort coordinator or the central administrator. When an effort card is put on hold a text box opens and the effort coordinator must make a comment on why the card is being put on hold. Upon completing, an email is automatically sent to the card owner that the card is being placed on hold. This action removes the Certify Button, allowing the effort coordinator to make the necessary changes before the PI has to re-certify.
How do I look at historical effort cards?
Once a card is certified, the certifier can view historical cards by simply logging on and clicking on View My Historical Data. For an effort coordinator to view the card, they must use the Department Dashboard to open any card that is visible. Once open, you have the option to view any period that has passed.
When is the data loaded to ECRT?
Data is loaded to ecrt® after each payroll has completed in HCM. You are able to view this data at any time on the effort statement after a data load. This load happens on the 4th and 20th of each month.
What happens if a PI/Faculty has left before certifying?
Manual Certification is required. The effort coordinator must have the Effort PDF File printed and signed by the chair of the department or a person with suitable knowledge of the work performed. A manual certification cover sheet should be attached and can be found on the Effort Website . The document must then be scanned and emailed to firstname.lastname@example.org for processing. Please name your document with Last Name EMPLID Reporting Period (S01 YYYY=Jan-Jun Period and S02 YYYY=July-Dec) EX: Doe 111111 S01 2013
Can an account be added to an effort card for cost sharing purposes only?
Yes click the "Add Project/Speedtype" link. If the project is closed in FMS, change the search to Inactive.
Can I attach documents to an effort card?
Yes, attachment can added to the statement by clicking the paper clip icon near the bottom of the statement
Can effort statements be reopened?
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:
A non-payroll related adjustment, such as a manual addition of a non-paid project & its associated effort &/or modifying only the certified effort. The request must be made within 30 days of the certification period close.