1. The Basics of Effort Certification ECRT System Version 4.5

2. Purpose The purpose of this course is to familiarize faculty and their administrative support staff with the University’s revised effort reporting system, in order to comply with Federal regulations and UTPB policies and procedures that govern effort on sponsored projects. This is a compliance issue!

3. Purpose Completion of this course is recommended for: Principal Investigators with active sponsored projects where payment is made through UTPB payroll using sponsored (grant) funds. Department administrative and support staff who provide support to PIs Administrators and other members of the campus research community may also find it useful.

4. Goals After completing this training course, you will be able to: – Define Effort and Effort Certification – Identify the importance of completing Effort Certifications – Define the categories of Effort – Identify how to report actual Effort on the online Effort Certification cards – Gain an understanding of the most common Effort situations

5. Effort Certification: An Introduction Effort certification is Federal law. It is not optional. If you have grants funded by the government, it is a condition of accepting those funds that you certify your effort. Not certifying effort in a timely and correct manner has serious consequences for researcher. At UTPB, failure to complete the effort certification report during the required time period could result in a PI’s research funds being frozen. Not certifying effort in a timely and correct manner has serious consequences for the University. In recent years, several major universities have been assessed large penalties and/or agreed to settlements due in part to effort reporting violations:  Northwestern University for $5.5 million  University of Southern Florida, for $4.1 million  Johns Hopkins for $2.6 million  Harvard University for $3.3 million  University of Alabama Birmingham for $3.39 million.

6. Why do we report Effort? OMB Circular A-21, Section J.10 (Compensation for Personal Services)  Effort reporting requirements 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

7. Effort Certification: What Is Effort? Effort is the proportion of time spent on any activity. It is expressed as a percentage of the total professional activity for which an individual is employed by the University. The online effort certification card, discussed later, documents the proportion of work time devoted to: – Sponsored projects (i.e. contracts and grants) – Teaching and non-sponsored research – Clinical practice – Administration – Other institutional activities It is important to note that effort is not calculated on a 40-hour workweek. If an investigator works 80 hours in a week, 40 hours represents 50% effort. The total time employed constitutes 100% effort. Total effort must equal 100%, regardless of part-time or full-time status. For example, for a graduate student who is employed for only 10 hours, the 10 hours represents 100% effort. The completed Effort Certification card should reflect all activities conducted under the terms of your employment. Activities typically not included under your employment include: – Outside consulting – Stipend payments – Bonus payments – Other employers who pay you directly (i.e. the Veterans Administration) Effort is expressed as a percentage of total employed time and is not reflected in hours. The total effort expended cannot be more than, and cannot be less than, 100%.

8. Effort Certification: Definitions Cost Sharing (Types) Mandatory: – Required by the sponsor as a condition of obtaining an award. – Must be included in the contract or grant proposal to receive consideration from the sponsor. Salary-cap: – Results when an individual’s Institutional Base Salary exceeds a sponsor’s salary limitation or “salary cap”. – The prorated excess is a form of mandatory cost sharing that must be funded by an appropriate and allowable non-sponsored source. Voluntary Committed: (This now very inadvisable!) – Represents effort proposed that was not required by the sponsor and that is in excess of effort paid by the sponsor and or mandatory cost sharing. – Becomes an obligation once the proposal is awarded.

9. Effort Certification: The Difference Between Payroll and Effort Payroll and effort distributions are not the same thing. Payroll distributions describe the allocation of an individual salary, while effort distributions describe the allocation of an individual's activity to individual projects "independent of salary." Effort is not a verification of our payroll system's accuracy. Our effort reporting process relies on payroll distributions to provide a general reminder of the projects on which an individual's salary was charged during the certification period. Whenever payroll does not accurately reflect how the employee spent his or her time, the effort must be corrected on the online effort certification card. Individuals completing online effort certification cards are required to identify other areas where they provided effort with no sponsored salary support and to ultimately report the appropriate distribution of effort over all activities.

10. Effort Reporting at UTPB Method of distributionWeb-based Frequency of distributionSemi-annually Review periodSix Months Certification window30 days

11. Who certifies effort? Faculty members must certify their own effort except in limited circumstances. For all other employees, effort reports must be certified by the Principal Investigator (PI) or by a responsible supervisory official having first hand knowledge of the individuals work assignments of all the employee's professional activities under our employment.  A PI is the primary individual in charge of a research grant, cooperative agreement, training or public service project, or other sponsored project.  Therefore, faculty members may also be required to confirm the effort certifications for people who work in their labs, provided the faculty member has knowledge of all the employee's professional activities. In addition, faculty members are responsible for the timely completion of these effort statements. Faculty members are also responsible, with assistance from University administration, for monitoring their effort commitments.  For the majority of sponsored projects, the researcher and the University commit to levels of effort through the proposal. If the receipt of an award increases an investigator's committed effort to greater than 100%, the investigator must work with administration to revise the level of effort required through communication with the sponsors, reduce effort on other activities, or refuse the award. The University of Texas of the Permian Basin must be consistent with how it proposes effort levels on sponsored awards and how that same effort and related salary will be charged and certified.  Proposals, like effort certification, should not be based on a standard 40-hour workweek. If an individual routinely works 80 hours a week, 8 hours a week is 10% effort, not 20%. The 80-hour base is how effort should be proposed, salary charged, and effort certified. The faculty member is responsible for proposing effort at a level consistent with the time available considering all other effort commitments.

12. Effort Certification: Why? Effort Certification cards provide documentation to support the level of effort performed on each award and University activities. This documentation supports the salary charges on the sponsored accounts. In essence, the effort form is the "invoice" for the salary charges on the award. Most of the University's sponsors consider the online Effort Certification card to be the primary auditable document to support salary costs on an award. Additionally, the effort levels must be documented to support the University's assertion that it is meeting the effort levels to which it committed to through the proposal/award process. The online Effort Certification card proves to the sponsor that it is receiving the level of effort it is paying for and the level of effort it is expecting to receive based on the proposal/award process. In some instances, the University agrees to perform a level of effort without a corresponding salary reimbursement. The online Effort Certification card will document this level of committed cost as well.

13. Effort Certification: Federal Requirements OMB Circular A-21 is the Federal Government's Cost Principles for Educational Institutions. It defines what costs are allowable and allocable to federal agreements. OMB Circular A-21 OMB Circular A-21, section J.10 indicates criteria for acceptable methods for apportioning salaries and wages. It requires a payroll distribution system to initially charge the salaries to the various awards, and accounts according to a plan or estimate of how the individual will spend his or her effort during the period. OMB Circular A-21, section J.10 Circular A-21 also requires an after-the-fact activity report that encompasses all employee activities. The after-the-fact activity report must be performed regularly and must be certified by an individual who has suitable means verifying 100% of an employee's activities. Any differences between the estimate in the payroll distribution and the after-the-fact activity report must be resolved by adjusting the costs on the award. Circular A-21 Note that amendments to requirements are currently (2015) being made under “Uniform Guidance”.“Uniform Guidance”

14. Effort Certification: Risks of not Complying Since Effort Certification cards provide the documentation necessary to support the salary charges on awards, both direct and indirect costs may be disallowed and penalties imposed after reimbursement if auditors find such documentation to be inadequate. Some reasons why an auditor may find an Effort Certification form to be inadequate include:  It was certified by an individual who did not have suitable means of verification of 100% of the individual's activity.  It did not encompass all of the activities performed by the individual under the terms of their employment at the University.  The levels of effort do not appear reasonable, given other conflicting documentation (i.e. clinical schedule, administrative duties, other research grants, etc.) that substantiates the responsibilities of the individual.  In addition, if an effort form is found to be falsified, criminal charges may be brought against the individual certifying the falsified effort certification. As the primary award recipient with oversight accountability to the research sponsor - The University of Texas of the Permian Basin may suspend the research rights and privileges enjoyed by the Principal Investigator (PI) and the research staff when they do not adhere to this policy. If a PI does not adhere to the effort reporting policies, UTPB may not submit proposals for the PI and may inactivate existing accounts in the accounting system. Disregard of these policies may also lead to other disciplinary actions in accordance with the faculty appointment policies. It is the responsibility of the PI to complete the certification process on time.

15. Effort Certification: Completing the Online Form UTPB has implemented the following Effort Certification Procedure for federal and state contracts and grants. Our institution uses the "after-the-fact" method of effort reporting. The process begins with an initial (before-the-fact) estimate of the effort percentage that an employee will contribute to each project to which they will be assigned. The initial estimate is entered in the Human Resources system when the administrative staff submits a Form (PO1) for the employee. This enables employees to be paid and salary costs charged to the account. By clicking on the “certify” button, the PI certifies that the employee reflected on the report actually performed work on the indicated account(s) and in the percentage of effort noted.

16. Effort Certification: Completing the Card Twice a year, PIs are required to log into the system (accessible from http://www.utpb.edu/research- grants/ecrt-certification to certify their effort and the effort of their support staffhttp://www.utpb.edu/research- grants/ecrt-certification The online certification period is a month. Any cards not certified at the end of the period are out of compliance. The system is updated monthly and can be reviewed at any time PIs are strongly encouraged to check the system every 90 days to make any changes to payroll.

17. ECRT Navigation ECRT login is located under ECRT Certification listed under the following link. http://www.utpb.edu/research-grants/ecrt-certification/

18. ECRT- Navigation Login Screens Select our university from the drop down list. Just start typing UTPB into the first box. When UT Permian Basin appears, click it and then click on the “Select” Button to the right.

19. ECRT- Navigation Login Screens Your username will be the same as your assigned email account. The password will be the same password you use to access your email. Click on “Login”

20. ECRT- Navigation Login Screens Important information listing changes will be found here Check this area for useful links to reference guides and external links Click “Continue” to enter ECRT

21. Certification – Certifier Actions Note that your statement and those of any support staff you need to certify, now show on one page. There will be only one option available to PIs and CoPIs: “Statements Awaiting Certification”

22. Certify My Effort The certifier is brought to the Effort Certification screen. The screen must be reviewed by the certifier and then approved to move to the “certification statement”. The Sponsored activity appears in the top part of the card and the Non Sponsored activity appears in the bottom part of the card. There are subtotals for each award as well as the Sponsored and Non Sponsored areas. Support staff will appear in the “Work List” box, top left.

23. Certify My Effort This is the bottom of the certification screen. The text box at the bottom allows certifiers to enter comments, notes or attach a document.

24. Certify My Effort A certifier enters the percentage of effort in the CERTIFIED EFFORT column and checks the CERTIFY CHECKBOXES for both sponsored and non- sponsored accounts, based on best knowledge and suitable means to verify effort. Review and edit effort to ensure accuracy. When all effort has been accounted for, the researcher clicks the “Certify” button below the totals.

25. Certify My Effort The certifier is then presented with a certification message reminding them what they are certifying to. After a final review of the information on the page and the certification statement at the top, the certifier will click the “I Agree” button under the message. After this, the user is returned to the Home Page. The effort card is sent on to the Effort Coordinator for processing, along with any entered notes.

26. Certify My Support Staff Support staff are now displayed in the “Work List:” box”. Top left of your screen. Simply click on the name and follow the same procedures you did to check and certify your own effort. Check boxes before pressing the submit button.

27. Certify My Support Staff To finish the certification, the certifier must press the “I Agree” button. Once that is completed, the effort card is passed to the Effort Coordinator for processing.

28. Processing Certifications - Discrepancies If the PI or support staff member certifies to a percentage that is different than the computed effort, ECRT will notify the effort coordinator of the discrepancies. In this example, a PI has certified 75% of effort to a sponsored account rather than 25% certified effort. Next, 25% of effort has been certified to a non-sponsored account rather than 75%.

29. Processing Certifications If the support staff member certifies to a percentage that is different than the computed percentages, ECRT calculates the dollars related to the changes and shows them to the right of the changed lines. In this example, $20,052 has been cost transferred between the two sponsored projects the staff member worked on. Typically, the staff member would include notes in the bottom section if the effort lines were changed. It is the effort coordinator's responsibility to review the appropriateness of the cost transfers and effort that has been certified. After review, the effort coordinator clicks the “Process” button at bottom of the page. If necessary, the EC can add notes in the box at the bottom of the screen for future reference. After processing, the item is removed from the task list and the status is set to “completed.”

30. Processing Certifications If after reviewing the certification the EC believes there is an error, he/she will indicate the reason why there is a problem in the notes box and click the “Do Not Process” button at the bottom of the screen. This action causes an email to automatically be sent from the EC to the certifier indicating that the certification needs further review and to contact the EC. It also changes the status of the certification from “Certified” back to “In Progress”. The certifier would then reopen the certification, review the EC’s notes, and take appropriate action as needed and resubmit for processing.

31. Effort Recertification If a correction needs to be made to a certified and processed card, the effort coordinator will select effort recertification, and enter the name of the researcher to be corrected.

32. Effort Recertification The Effort Coordinator would select the period desired and click the button at the bottom right to “Open for Recertification”. This will cause an email to be sent to the researcher saying she needs to recertify her time for that period. Note: An Effort Coordinator is allowed to reopen a certification card only if that card is still within its certification period. If the certification is from a closed period, only the Central Administrator has the security privilege to perform this action.

33. For more information… Check out our Research & Grants website at: http://www.utpb.edu/research-grants/ For assistance relating to ECRT & Grants contact Steve Dunkley at 552-3533.

34. Let’s try ECRT out, shall We? This is where you’ll start http://www.utpb.edu/research- grants/ecrt-certification