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Effort Reporting

Introduction

UTD maintains systems and procedures documenting the distribution of activity to individual sponsored agreements in compliance with federal regulations as defined by the Office of Management and Budget (OMB) Circular A-21 Cost Principles for Educational Institutions. Any individual who performed work on a federally funded project or the project's principal investigator must certify effort, unless in their absence, this task is delegated to a designee who must have suitable means of verification of the distribution of effort.

Effort Reporting is our means of providing assurance to sponsors that:
  • Salaries charged to sponsored projects are reasonable in relation to the work performed, and
  • Faculty and staff have met their commitments to sponsored projects.

This policy provides information and guidance on Effort Certification as prescribed by The University of Texas System in the UT System Policy Library–Policy #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.

All researchers should review the provisions of UTS163.

Purpose

The University receives significant funding for sponsored programs from the federal government and other external sources. OMB Circular A-21 requires that any individual, who performed work on a federally sponsored project, including federally funded sub awards received from other institutions, industry or State, must certify that the effort, paid or committed, is reasonable. Non-compliance with these requirements would result in disallowance of cost for salary and wages and would limit the recovery of Facilities and Administrative (F&A) costs (i.e. indirect costs) due to the University's failure to isolate research salaries and wages from costs associated with other University activities. Non-compliance would negatively affect the University's reputation and could jeopardize future funding from the federal government and collaborations with other institutions.

Standards

OMB Circular A-21 sets forth the standards for the effort certification processes including the plan confirmation system which is used here at UTD.

Who Must Comply

Acceptance of federal funding by any part of the University requires the institution to adhere to the effort reporting requirements prescribed by OMB A-21.

General Requirements

  1. 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.
  2. 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.
  3. The PI is required to complete the Effort Certification within 45 days of receipt of notification by Office of Post Award Management to certify Effort.
  4. 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 that 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.
  5. 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.
  6. 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.
  7. 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.
  8. 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.