1. EFFORT CERTIFICATION REPORTING TECHNOLOGY (ecrt™)

2.  Goals  Explain the requirements for effort reporting and certification  Provide guidance on effort reporting and certification using UTHealth’s effort reporting tool, ECRT

3.  Current SystemNew System-ECRT Method of DistributionElectronic HCM PeopleSoft Web-Based using Payroll data Frequency of Distribution Monthly/Semi- Annually Semi-Annually CertifiersAdministrators, Faculty and Principal Investigators Faculty and Principal Investigators Pre Review Period10 days Certification Window30 days Effort Reporting at UTHealth

4.   After-the-fact confirmation of personnel costs charged to sponsored agreements  The system must be incorporated into the official records of the institution  Certification which encompasses all employee activities on an integrated basis (i.e. 100% effort)  Certification by an individual with suitable means of verification that the work was performed  Independent internal evaluations to ensure the system’s effectiveness and compliance Effort Reporting/ECRT Requirements

5.  Bureaucratic Language Reliability and Reasonableness  “…it is recognized that research, service and administration are 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.” OMB Circular A-21, Section J.10 (Compensation for Personal Services)

6.  Why is there so much emphasis on effort reporting?

7. 

8.  Areas of government focus in audits/investigations related to effort reporting:  Salary charges  Over-commitments  Salary cost transfers and cost sharing  Integration with systems that report time or effort  Roles and responsibilities  Who ensures appropriate salary is charged?  Who ensures level of commitment is reasonable?  Who signs the reports?  Who independently monitors to evaluate system’s effectiveness? Why is there so much emphasis on effort reporting?

9.  Example

10. Regulations and Guidelines

11.   2CFR, Part 220 (Formerly OMB A-21) : Principles for determining the costs applicable to research and development, training, and other sponsored work performed by colleges and universities under grants, contracts, and other agreements with the Federal Government http://bit.ly/2CFRPart220  NIH Grants Policy Statement : NIH grant awards provide for reimbursement of actual, allowable costs incurred and are subject to federal cost principles http://grants.nih.gov/grants/policy/policy.htm Federal Regulations and Guidelines

12.   Effort reports should be prepared on a percentage of effort basis so as to assure consistency with award terms  Reports should reasonably reflect the activities for which employees are compensated by the institution  Research, teaching and administration are often intermingled; a precise assessment of factors that contribute to costs is not always feasible, nor is it expected  Special Note: These expectations and findings from federal/state audits seem to disagree on the level of tolerance. 2CFR PART 220

13.  Because you must certify 100% of your Total Effort, it’s important to know what counts as effort and what doesn’t. The basic rule is: Your Total Effort includes all the professional activities for which you are compensated by the university.  Effort includes:  Sponsored Programs (e.g. grants and contracts)  Non-Sponsored (Departmental) Research  Teaching  Service  Administrative Duties  Other Institutional Activities Defining Effort

14.   Actual conduct of research in furtherance of a grant’s objectives  Administrative effort directly associated with the research  Special lectures, writing reports and articles, participating in seminars, consulting with colleagues and graduate students, attending meetings and conferences  Preparing progress reports  “On the job” training of grant personnel Appropriate Allocations

15.  Inappropriate Allocations  Effort expended on research not related to the objectives of the grant to which it is charged  New proposal writing  General instruction  General administrative activity  Unrelated departmental research  Unrelated clinical activity

16.  Keep in mind…  True UTHealth institutional activities cannot be characterized as unfunded, volunteer, or weekend work - because federal regulations prohibit this.  Activities that are closely associated with your professional duties for which UTHealth pays you must be reported as Total Effort.

17.  If you work on a sponsored project, you're required to assure the sponsor that:  You did, in fact, devote effort to the project at a level that corresponds with how you were paid from the project  You’ve met your commitments of effort to the project, regardless of whether the sponsor provided salary support Assurance to the Sponsor

18.  It’s the PI Responsibility  It is the responsibility of every Principal Investigator/Project Director to certify their own effort and the effort of all support staff working on their sponsored programs, as they have the best first hand knowledge of their sponsored programs.  Faculty will self-certify themselves regardless of who’s project they are working on.

19.  The Certification Process

20.  Areas of Focus/Concern  Minimum and maximum levels of effort commitments  Over-commitments  Administrative duties  Summer appointments  Contributed Effort (aka cost shared effort)

21. Commitments

22.  Making a Commitment of Effort A commitment is the amount of effort you propose in a grant proposal or other project application, and that the sponsor accepts – regardless of whether or not you request salary support for the effort.

23.   A commitment is an obligation for which the university is held accountable.  Commitments are specific and quantified.  Commitments are expressed as a percentage of your work time for a given project period.  Commitments may be adjusted with the approval of the sponsoring agency if changes exceed tolerances (e.g. > 25% reduction for key personnel per NOGA). Commitments Explained

24.  Tracking Effort Commitments Commitments are recognized and must be tracked for faculty. **When the NOGA does not explicitly list key persons, the university defines key personnel for the purpose of effort reporting as the principal investigator.

25.   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. Effort Committed Minimums

26.   The required maximum level of committed effort for a university primary individual who has effort commitments on sponsored projects is as follows: Effort Committed Maximums Faculty PositionEffort Cap Executive Leadership (Presidents, Vice Presidents, Deans, Institute Directors) 70% Academic Leadership (Department Chairs, Division Directors) 80% Tenured and Tenure-track Faculty90% Non Tenure-track Faculty95%

27. Cost Sharing

28.   The funds or resources under the university control that are contributed or allocated to a sponsored project over and above the support provided by the external sponsor of that project. It is that portion of a project cost that is not borne or reimbursed by the sponsoring agency. Below are the various types of cost sharing.  Mandatory Cost Sharing: Cost sharing required by the sponsoring agency as a condition of its support of a particular project. Mandatory cost sharing is usually specified in a program announcement or application package. Mandatory cost sharing is a binding obligation of the university. Cost Sharing Defined

29.   Salary Cap Cost Sharing: results when an individual’s Institutional Base Salary exceeds a sponsor's salary cap. The prorated excess is a form of mandatory cost sharing that must be funded by an appropriate and allowable source  Voluntary Cost Sharing: Cost sharing the university contributes to a project at its own initiative without any requirement for any cost sharing imposed by the sponsoring agency. There are two types of voluntary cost sharing:  Voluntary Committed Cost Sharing: Voluntary cost sharing offered by the university at the time of proposal submission.  Voluntary Uncommitted Cost Sharing: Voluntary cost sharing not offered by the university at the time of proposal submission. Voluntary uncommitted cost sharing is not included in the budget but is contributed after the award has been granted and more resources than awarded are needed to complete the project. Cost Sharing Defined

30.  Cost Sharing Explained  For mandatory or voluntary committed cost sharing, the effort should be confirmed to the project on which the employee expended effort  Funds from one sponsored project may not be used as the source of cost sharing on another sponsored project

31. Version 3.0.2

32.   Employees are assigned to departments by their primary appointment in HCM.  Accounts are assigned to the department number that owns the award.  Incorrect data must be corrected in the source system for it to be corrected in ECRT.  If you see incorrect data, such as Effort Coordinators, send an email to effort@uth.tmc.edu with updated information.effort@uth.tmc.edu Key Points

33.  Office of Research Services-Central Administrators Departmental Effort Coordinators/Support Individuals Primary Individual(PI’s) and Faculty Other Institutional Offices  Audit Services  Institutional Compliance  Office of Sponsored Projects(OSP)  Post Award Finance(PAF) Roles within ECRT

34.   Employee listed as principal investigator, project director, co-investigator, co-project director, or those with comparable responsibilities on a sponsored project application.  Employees who have an academic (i.e. faculty) appointment.  Responsible for the confirming of their own effort  Responsible for confirming all supporting individuals working with them on their awards  NOT responsible for confirming effort for other Primary Individuals Primary Individual

35.   Employee other than a primary individual who has expended effort on a sponsored program.  May or may not have been identified on the funded application and typically do not have committed effort greater than the amount paid on a specific sponsored program.  Departmental Effort Coordinators are responsible for any changes to the effort card if needed.  NOT responsible for confirming their own effort Department Coordinators and Supporting Individuals

36.   Occurs 5 days at the end of the Effort Performance Period  Review status of the card and the payroll sourcing- add any additional accounts.  Update all cost sharing and salary cap information.  Prepare cards for the Certification Period when the PI’s will review and certify cards. Department Coordinators Pre- Review Period

37.   Primary Individuals will receive an automated email message when effort cards are compiled, as well as subsequent reminders if the effort card has not been confirmed.  Access to ECRT is available through any of the following links:  Link provided in e-mail message will take you directly to ECRT.  Office of Research Services web page PI Certification Period

38.  Effort Card Status

39.   This period is 5 calendar days. After the certification period has been completed, there may still be activities that need to be completed. These may include:  A retroactive payroll adjustment may need to be initiated;  identifying and escalating issues if there are Certifiers who have failed to certify within the open certification period;  if effort was certified lower than committed, investigating whether the lower effort requires a letter to sponsor if necessary Processing and Post Review Period

40.   Has the effort report been reviewed to insure that the retroactive labor cost transfer is consistent with the effort confirmed?  Has the NIH salary cap issue been addressed if applicable?  Is this retroactive transfer for a period of more than 90 days? If so, is there a justifiable reason?  Is the expense allowable and will it benefit the grant?  Is there a sufficient justification described on the transfer form?  For federal projects, will this transfer result in a change of greater than 25% in effort of key personnel or in a budget re-allocation of greater than 25%, as proposed in the original award? Retroactive Cost Transfers

41.  ECRT Navigation – Login Screens Since the ECRT system is Shibboleth- enabled, this login page will be displayed. Make sure to select our university.

42.  ECRT Navigation – Login screens Enter your network login and password to log in.

43.  Ecrt Home Page – Navigation Menus Central Administration View

44.  ECRT Home Page- Navigation Menus The various functions that a user can perform are shown around the circle. Clicking any of these links will take the user to the page related to the function. The links a user can see are limited by security rights within the system. Rights are bundled together and associated with Roles.

45.  ECRT Home Page- Helpful links On the left side of the screen there are “Helpful Links.” These links are hyperlinks and will take the user to the sites referenced when they are clicked

46.  Department Coordinators-Home Page

47.  Certifier View (Faculty and PI’s) Certifiers have a limited number of links on the Welcome screen when logged into ECRT. In general, they can certify their effort and the effort of research assistants that work for them. They can also see reports related to their projects. Start the effort certification process by clicking on the link to Certify My Effort

48.  Effort Card

49. 

50.  How do you certify your support staff? You will need to click on Certify My Support Staff- Group View

51.  Payroll Reporting Period Pre-Review PeriodCertification Period 1-Jan-1130-Jun-115-Jul-1118-Jul-1119-Jul-1119-Aug-11 1-Jul-1131-Dec-115-Jan-1218-Jan-1219-Jan-1119-Feb-12 1-Jan-1230-Jun-125-Jul-1218-Jul-1219-Jul-1219-Aug-12 1-Jul-1231-Dec-125-Jan-1318-Jan-1319-Jan-1319-Feb-13 1-Jan-1330-Jun-135-Jul-1318-Jul-1319-Jul-1319-Aug-13 1-Jul-1331-Dec 135-Jan-1418-Jan-1419-Jan-1419-Feb-14 ECRT activities schedule

52.   These reports will be outlined in the reference manual.  Certification Payroll Report  Certification Status Report  Certified effort less than Effort Committed  Certifier Payroll Summary Report  Certifier Salary Activity Report  Certification Status Aging Report  SPES Report (Sponsored Project Employee Summary) Reports

53.   OFFICE OF RESEARCH is here to help. Please contact us if you need any assistance.  713-500-3392  effort@uth.tmc.edu HELP