THE UNIVERSITY OF TEXAS AT EL PASO OFFICE OF RESEARCH AND SPONSORED PROJECTS EFFORT REPORTING POLICY

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Patience Jefferson
6 years ago
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1 A. PURPOSE The purpose of this policy is to establish appropriate guidelines for ensuring compliance with Effort Reporting/Certification requirements on sponsored projects in accordance with and up to the limits prescribed in the Office of Management and Budget (OMB) Circular A-21 Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Education Institutions and the University of Texas System Policy UTS 163 B. PERSONS AFFECTED This policy applies to all employees of the University of Texas at El Paso (UTEP) whose compensation is charged in whole or in part to a funded project and to parties that are approving and/or reviewing proposed or actual effort commitments on sponsored projects, including: Principal Investigator(s) Key Personnel Administrators responsible for approving Effort Commitments (i.e. chairs, deans or directors) The Office of Research and Sponsored Projects C. DEFINITIONS 1. Effort. The total amount of time spent by University personnel on teaching, service, research and other. a. Committed Effort: Time spent on a project that is contributed to the project at no cost to the funding agency or cost shared. (Allowability and responsibility of contributed effort commitments are detailed in Cost Share Policy) b. Charged Effort: Time spent on a project for which project personnel will be compensated from a grant or contract. 2. Percent Effort. Percent effort, as it relates to certification of effort in accordance with the OMB Circulars, is defined as an individual s total institutional activities, or 100% maximum. It is not defined as a percent of a regular 40 hour workweek or as a percent of FTE of an academic appointment or other staff appointment. Effort can be certified regardless of location of the certifying individual. An individual may perform essential Page 1 of 7

2 project related activities in locations such as home, external laboratories, conferences, or off campus/site project related meetings. 3. Effort Certification. Effort Certification is the documentation of the amount of actual effort committed on a federally sponsored project. Certifying individuals are responsible for reporting and certifying actual effort on a project. This certification of effort is based on actual time and is not related to percent of payroll distribution. OMB Circular A-21, Section J 10 defines compensational effort, allowability of effort charged as a direct cost, and distribution of compensational effort; Section 10, (2), 1, (e) defines reasonable certification methods. 4. Primary Individual and/or Principal Investigator (PI) and Project Director (PD). The PI or PD is the individual who will direct the project and who is designated by the University as responsible for completing it as agreed upon. The Primary Individual is an individual who has knowledge concerning actual effort commitments on a sponsored project and who is responsible for certification of this effort for all grant compensated personnel. 5. Institutional Base Salary (IBS). IBS is the total guaranteed annual compensation an individual receives from the University, whether the individual s time is spent on research, teaching, or other activities. The IBS shall be used to compute salaries charged as reimbursable costs or Cost Sharing on sponsored projects unless sponsored policies further limit salary charges. IBS includes compensation for instruction, public service, research and/or other activities. IBS excludes fringe benefit payments, reimbursed expenses, temporary supplemental compensation for incidental work, income earned outside of duties to the University, and any portion of compensation deemed to be at-risk. D. POLICY The policy of the University is: 1. To follow the requirements set forth by The Office of Management and Budget (OMB) Circular A-21, Cost Principles for Education Institutions, Subpart J, Section 10. regarding the charging of compensation for effort to a sponsored project and means of verification. For the University to be compliant, costs must: Page 2 of 7

3 a. Be approved by the appropriate administrator responsible for the commitment of effort (e.g. chair, dean, or director). b. Be verifiable from University payroll records. c. Be charged to the applicable project or program. d. Be necessary and reasonable for proper and efficient accomplishment of project or program objectives. e. Be allowable under the applicable cost principles and funding source requirements. f. Not be paid by the Federal Government under another award. g. Be provided for in the approved budget to and from the awarding agency. h. Conform to established and allowable minimum and maximum effort. i. Conform to other provisions of the Circular, as applicable. j. Be reportable and certifiable k. Are directly identifiable with the project or program. l. Represent costs incurred during the period of performance of the award. 2. Minimum and Maximum Effort: Minimum acceptable effort, charged or contributed should be measurable, auditable, and compensable. All effort should be sufficient and realistic to affect the accomplishment and execution of project objectives. a. Minimum Effort: minimum effort of 1% is defined as the least/minimum auditable and certifiable amount of actual time spent to accomplish project or program objectives. b. Maximum Effort: maximum effort of 100% is defined as the maximum amount of actual time spent to accomplish project or program objectives. It is generally not realistic to charge 100% effort of a faculty member to sponsored projects since 100% effort represents the total activity of an employee, including teaching, service, mentorship and other. 3. Reasonable: A cost, such as effort compensation, may be considered reasonable if the goods or services acquired and the amounts paid for them are consistent with the action that a prudent person would have taken under the circumstances. Page 3 of 7

4 E. RESPONSIBILITIES: 1. The PI/PD and his/her primary department with which the sponsored program or project is affiliated are ultimately responsible for meeting actual effort reporting and certification. Page 4 of 7

5 F. PROCEDURE for Personal Effort Reporting System (PERS) 1. The PER System is a paper based effort reporting system based on paid effort. ORSP receives monthly paper reports and accumulates these reports to send to the PI on a semester basis. 2. The PD/PI, key personnel and other certifying officials must understand and be aware of the responsibilities and impacts of budgeting, committing, and certifying effort. Of main concern is the importance and legal responsibilities of effort certification. 3. The Office of Research and Sponsored Projects will: a. Ensure compliance with effort reporting requirements in accordance with University policies and the OMB Circular b. Ensure training and notification processes are in place for compliance with applicable policies and regulations c. Verify that effort requested or committed is included in project proposals, that such effort is properly budgeted and that the effort charged to the grant is properly disclosed and approved by the Chairmen and Dean of the PI/PD s home department/college (multiple chairs and deans must approve effort if grant budgeted effort is across departmental/college lines). d. Ensure at post award that the effort is approved at the proposed level by the funding agency. e. Approve electronic appointments of grant charged effort by individuals through the Define payroll system based on duly approved budget. f. Receive and distribute on a semester bases the Personal Effort Certification Reports (PER S) from the Payroll Office and distribute them to the responsible party. Page 5 of 7

6 g. Track and keep files for PER S, follow up with a minimum of two (2) reminder notices and 1 delinquent notice for outstanding PER S, and consolidate all completed PER S to be included in the official grant file at close out. h. Notify all appropriate offices and administrators when certifying official indicates changes of committed effort on the PER S, to ensure proper allocation of effort to the appropriate grant. G. PROCEDURE for Effort Certification Reporting Technology (ECRT) 1. ECRT is a web based effort certification program that requires on line reporting and certification of actual effort committed to a project. 4. The PD/PI, key personnel and other certifying officials will be trained to understand and be aware of the responsibilities and impacts of budgeting, committing, and certifying effort. Part of the training will detail the importance and legal responsibilities of effort certification. 5. The Office of Research and Sponsored Projects will: a. Ensure compliance with effort reporting requirements in accordance with University policies, UTS 163 and the OMB Circular b. Ensure training and notification processes are in place for compliance with applicable policies and regulations c. Verify that effort requested or committed is included in project proposals, that such effort is properly budgeted and that the effort charged to the grant is properly disclosed and approved by the Chairmen and Dean of the PI/PD s home department/college (multiple chairs and deans must approve effort if grant budgeted effort is across departmental/college lines). d. Ensure at post award that the effort is approved at the proposed level by the funding agency. e. Approve electronic appointments of grant charged effort by individuals through the Define payroll system based on duly approved budget. Page 6 of 7

7 f. Ensure that notifications are sent every six (6) months that the certification period within ECRT has opened and that certification should be accomplished by the PI and all support staff (excluding students, and key personnel which is PI on his/her own project) within 30 days. g. Track and process each certified record, follow up with a minimum of two (2) reminder notices and 1 delinquent notice for outstanding certifications. Notify all appropriate offices and administrators when certifying official indicates changes of committed effort within ECRT, to ensure proper allocation of effort to the appropriate grant. Page 7 of 7

4.12 Effort Certification

4.12 Effort Certification 4.112 Grants and Cooperative Agreements 4.1121 The Public Health Service ("PHS") and the National Science Foundation ("NSF") have regulations promoting objectivity in research by requiring that a university