Effort Reporting and Certification for Sponsored Activities (A-68)
Original Implementation: January 29, 2008
Last Revision: April 17, 2012
This policy establishes requirements for recording and reporting employee effort to comply with federal and state laws and regulations [Office of Management and Budget Circular A-21 and Texas Uniform Grant Management Standards II (B)(11)(h)(1-5,7)].
Effort reporting is a process that uses after-the-fact activity records to certify that only allowable payroll expenses are charged to or contributed (cost-shared or matched) to grants, contracts, and other sponsored agreements, and that effort commitments to sponsored agreements are met as specified in the agreement.
- Effort reports are required for faculty and staff who devote effort (paid or cost-shared) to one or more sponsored agreements that are funded by state or federal sponsors.
- Effort is defined as the amount of time spent on a particular activity and is not based on a traditional 40-hour work week. The total effort associated with institutional base salary is defined as 100% effort. This includes instruction, departmental administration, departmental research, sponsored projects, and other activities.
- Effort expended for extra compensation as defined in Salary Supplements, Stipends and Additional Compensation (E-9), or for work not compensated by the university, is not included in effort calculations. Refer to Compensation from Grants, Contracts and Other Sponsored Agreements (E-74).
- Effort reports should reasonably reflect the activities for which employees are compensated by the institution. However, it is recognized that, in an academic setting, teaching, research, service, and administration are often inextricably intermingled. Therefore, 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.
- Tolerance is defined by the university as +/- five percent (5%) of the committed effort. Effort certification report adjustments may be required when: 1) certified effort does not match salary expenditures within the tolerance limit for the time period covered by the report; 2) there are payroll cost transfers; or 3) revised personnel actions are generated.
- Project directors (PDs) or principal investigators (PIs) are responsible for ensuring that effort certification reports are completed accurately and in a timely manner for each individual subject to this policy and paid and or cost-shared from a grant, contract, or other state/federal sponsored agreement for which they serve as PD/PI.
- To confirm that the distribution of activity represents a reasonable estimate of the work performed by the employee during the period, reports will be certified by the employee, PD/PI, or other responsible person with suitable means of verification that the work was performed.
- Effort certification reports are generated electronically in the Banner system for individuals when any portion of a salary is paid or cost-shared in a reporting period from state and/or federally sponsored funds. Electronically certified forms are maintained in the Banner system; manually signed forms are retained by the Office of Research and Sponsored Programs (ORSP) for the appropriate period of time.
- Effort attributed to any state and/or federally sponsored agreement (grant, contract, or cooperative agreement) must represent work specific to the agreement. Intentional falsification, forgery, or fraudulent alteration of effort certification reports constitutes fraud. Criminal and/or employee discipline measures may be pursued.
- Training in the effort certification process is mandatory for all employees who certify payroll expenses charged to or contributed (cost-shared or matched) to externally funded grants, contracts, or other sponsored agreements subject to effort reporting requirements, and for departmental and other employees involved in the effort reporting process. ORSP provides and documents training activities.
Procedures for effort reporting and certification are outlined in the Grants and Contracts Procedures Manual published on the ORSP website.
Cross Reference: ORSP Grants and Contracts Procedure Manual; Office of Management and Budget Circular A-21, J.10. (2 C.F.R. § 220, Appendix J.10.); Texas Uniform Grant Management Standards II (B) (11) (h) (1-5, 7); Salary Supplements, Stipends and Additional Compensation (E-9); Compensation from Grants, Contracts and Other Sponsored Agreements (E-74)
Responsible for Implementation: Provost and Vice President for Academic Affairs
Contact for Revision: Director, Office of Research and Sponsored Programs; Controller
Forms: Banner Effort Certification Reports
Board Committee Assignment: Academic and Student Affairs