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Handbook of Operating Procedures
Chapter 10 - Research
Publication Date: April 17, 2012
Responsible Executive: VP for Research


10.05 Managing and Certifying Effort on Sponsored Programs


I. POLICY STATEMENT


The University of Texas at San Antonio (UTSA) is committed to assuring its Sponsors that Effort of faculty and other supporting personnel working on a Sponsored Program is appropriately proposed, performed, reported, certified, and charged to the Sponsored Program Award. In requesting funding for a Sponsored Program or implementing a Sponsored Program Award, UTSA must ensure that the Effort commitments of its employees to such Sponsored Program(s) are reasonable, comply with the applicable federal, state, and University of Texas System (UT System) laws, guidelines and regulations. Commitments of Efforts must also conform to UTSA’s expectations of good management and stewardship of the Sponsored Program, which expectations are reflected in UTSA’s applicable HOP policies, procedures, guidelines and in the training and advice provided by its vice president for research staff.


II. RATIONALE


Federal and state agencies, private foundations, industry, non-profit organizations and other organizations provide significant funding to enable UTSA to conduct instruction, public service, research and training under extramurally funded Sponsored Programs. Generally, compensation for personal services (such as salaries and wages) constitutes the largest expense charged to a Sponsored Program.

Consequently, four (4) UTSA Handbook of Operating Procedures (HOP) policies, 10.05 through 10.08 (collectively referred to as the “Effort-Related Policies”), impact the salary charged or contributed to UTSA Sponsored Programs*. Of these policies, this policy and HOP policy 10.06 (relating to Institutional Base Salary) are directly related to salary or payroll. The other two (2) policies,  HOP policy 10.07 (relating to Cost Sharing) and HOP policy 10.08 (relating to Cost Transfers) apply to salary but also apply more broadly to other activities or items that may be expensed under a Sponsored Program.

The four (4) Effort-Related Policies work together to ensure that (a) salaries and wages UTSA charges to Sponsored Programs are allowable, allocable, consistently treated, and reasonable, and (b) UTSA complies with federal and UT System regulations, policies and guidelines regarding Effort management, reporting, and certification and corresponding payroll charges. These regulations, policies and guidelines are prescribed in the Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions (relocated to 2 CFR Part 220) (A-21) and UT System Policy 163, Guidance on Effort Reporting and Certification Policies (UTS 163). 

This policy serves as the cornerstone of the Effort-Related Policies as its requirements establish the framework for:

    1. the proper management of Effort proposed by faculty and staff on all Sponsored Programs, and
    2. the proper reporting and certification of Effort actually expended on Sponsored Programs.

Finally this policy also explains concepts and defines terms that will be used throughout the Effort-Related Policies. (Note: For the convenience of UTSA’s research community, such definitions will be restated as necessary in each Effort-Related Policy.)

* The Effort-Related Policies are not intended to and will not in any way change the employment relationship between UTSA and any of its employees.  Therefore, no language in these policies can support or serve as the basis of any employment-related claim of any UTSA employee.


III. SCOPE


This policy applies to all employees at UTSA that commit Effort or, in limited circumstances, time to a Sponsored Program.  


IV. WEBSITE ADDRESS FOR THIS POLICY


http://www.utsa.edu/hop/chapter10/10-5.html


V. RELATED STATUTES, POLICIES, REQUIREMENTS OR STANDARDS


UTSA or UT System Policies or the Board of Regents' Rules & Regulations

  1. UT System policy 163, Guidance on Effort Reporting and Certificaion Policies
  2. UTSA HOP policy 10.06, Institutional Base Salary on Sponsored Programs
  3. UTSA HOP policy 10.07, Cost Sharing on Sponsored Programs
  4. UTSA HOP policy 10.08, Cost Transfers on Sponsored Programs

Other Policies & Standards

  1. OMB Circular A-21, Cost Principles for Educational Institutions (relocated to 2 CFR Part 220)

VI. CONTACTS


If you have any questions about HOP policy 10.05, Managing and Certifying Effort on Sponsored Programs, please contact one of the following offices:

Office of Sponsored Project Administration (OSPA)
210-458-4340

OSPA Research Service Centers (RSCs)


VII. DEFINITIONS


Award: Depending on its context, either:  (a) the terms and conditions associated with a Sponsor’s decision to select a UTSA Sponsored Program proposal or application for funding, or (b) the Notice of Award or other documentation reflecting such a decision by the Sponsor.

Committed Effort or Effort Commitment: The amount of Effort identified in a Sponsored Program Award agreement or in a Sponsored Program proposal that is submitted and accepted by the Sponsor for funding regardless of whether or not salary support is requested in support of that Effort.

Cost Shared Effort or Contributed Effort: The percent of Committed Effort that (1) is contributed by an Individual to a Sponsored Program and (2) is to be paid and cost shared by the University or a third-party. It represents Effort committed to the Sponsored Program with University or third-party resources. (For a more detailed definition of Cost Shared Effort and more information relating generally to Cost Sharing, see UTSA HOP policy 10.07, Cost Sharing on Sponsored Programs.) 

Designated Responsible Party for Effort Reporting Compliance (DRP): The Designated Responsible Party is the vice president for research (VPR). The DRP is responsible for overall management of (1) UTSA’s Effort reporting compliance program and (2) the risks of non-compliance with such program.

Effort: The amount of time spent on any activity for which an Individual is compensated by UTSA. Effort is expressed as a percentage of the Individual’s Total Institutional Activities, which Total Institutional Activities typically include work on Sponsored Programs, teaching and instruction, service, or other duties for UTSA.

Effort Certification or Effort Reporting: Formal verification through UTSA’s electronic Effort Certification system that Committed Effort (whether paid from the Sponsored Program account or Cost Shared) has been performed.

Individual: An Individual is any UTSA employee who has Committed Effort (whether paid by the Sponsor or Cost Shared) on a Sponsored Program. Where appropriate in this policy, the following subcategories will be utilized:

    1. A Primary Individual has some responsibility for the overall conduct and management of the research or activity as described in the proposal/application or as identified in the Notice of Award of a Sponsored Program.  A Primary Individual is typically identified in the Sponsored Program Award as the principal investigator , project director , co-investigator, or co-project director and typically, but not always, carries an academic (i.e., faculty) appointment.
      1. The PI/PD: In the Effort-Related Policies, when a duty or responsibility falls squarely on only one Primary Individual, that individual may be referred to as The PI/PD (Principal Investigator or Project Director).
    2. A Collaborating Individual is an employee with an academic appointment who expends Committed Effort on a Sponsored Program but does not serve as a Primary Individual on such Sponsored Program.
    3. A Supporting Individual is an employee other than a Primary Individual who does not have a faculty appointment and has expended Committed Effort on a Sponsored Program.

Maximum Level of Effort Commitment:  The upper limit of (or “cap” on) the Effort that certain Primary Individuals can devote to all activities associated with Sponsored Program(s), as further described in Section IX.B.2.

Minimum Level of Effort Commitment:  The minimum Effort  every Primary Individual is required to expend on each of the Primary Individual’s Sponsored Program(s), as further described in Section IX.B.1.

Sponsored Programs: Activities conducted in research, instruction, training, or public service as a result of a formal written agreement (such as a grant, contract, or cooperative agreement), which agreement is typically obtained as a result of a formal application and approval process. These activities can be funded either externally by government, industry, or private sponsors; or, internally by UTSA. Sponsored Programs are separately budgeted and accounted for, meaning there is a defined scope of work, a budget that identifies the costs to be incurred in the performance of the work, and the accumulation of costs actually incurred in support of the project. Sponsored Programs usually involve a specific commitment of time for each Individual involved in achieving the aims of the project. Sponsored Programs may be thought of as transactions in which there are specified statements of work with a related, reciprocal transfer of something of value.

Sponsors:  Entities, including government, industry, private entities or UTSA, that provide Awards to fund Sponsored Programs at UTSA.

Total Institutional Activities: All activities for which an Individual is compensated by UTSA as a result of their employment, including but not limited to,  serving on UTSA committees, teaching, performing duties associated with UTSA committee-work or teaching, public service, continuous administrative duties (chair, dean, etc.), and research (which may or may not be pursuant to a Sponsored Program).


VIII. RESPONSIBILITIES


    1. Designated Responsible Party for Effort Reporting Compliance (DRP)
      1. Ensures institutional compliance with the Effort-Related Policies, UTS 163, and any applicable federal or state laws, regulations, policies or guidelines, including:
        1. ensuring that education and training programs are available to assist all administrators, faculty, and staff to fully understand the intent and the implications of all applicable effort compliance regulations, guidelines and policies;
        2. approving exceptions to Minimum Levels of Effort Commitment and Maximum Levels of Effort Commitment; and
        3. interpreting or revising the Effort-Related Policies as necessary to conform to UTSA’s changing needs and regulatory changes.
      2. Ensures an effective monitoring process exists at UTSA for effort compliance matters and retains ultimate responsibility for responding to Effort-Related audits and Effort-Related items associated with other audits; and 
      3. Works as needed with the vice president for business affairs and UTSA’s Institutional Compliance Officer to identify, manage, and mitigate the risks associated with non-compliance.
    2. The Institutional Compliance Officer (ICO)
      1. Assesses UTSA’s progress toward full compliance with the Effort-Related Policies, UTS 163, and any other applicable federal or state laws, regulations, policies or guidelines that have been deemed high risk by UTSA’s Executive Compliance Committee (ECC); and
      2. Assists the DRP with the identification, management, and mitigation of the high risks (as defined above) associated with non-compliance.
    3. Collaborating Individual
      1. Understands the key concepts associated with Effort as expressed in this policy; and
      2. Timely and accurately certifies his/her own Effort using UTSA’s electronic Effort Statement.
    4. Primary Individual (including the PI/PD)
      1. Retains primary responsibility for the management and certification of Effort Commitments for each Sponsored Program in which he/she is identified in the proposal/application or Award, including:
        1. ensuring that Committed Effort on such Sponsored Program for him/herself and his/her Supporting Individuals is properly approved, managed and certified;
        2. understanding and complying with the Minimum Levels of Effort Commitment and Maximum Levels of Effort Commitment, as described and expressed in this policy; and
        3. obtaining appropriate approvals from his/her Supervisor as required under the Effort-Related Policies.
      2. The PI/PD retains ultimate responsibility for the management and certification of Effort Commitments on the Sponsored Program he/she leads, including:
        1. consulting with and cooperating with the RSC as needed (a) to ensure that his/her proposal and the actual Award appropriately reflects Committed Effort (including Cost-Shared Effort) and (b) whenever there are changes to the Effort Commitments found in the Award; and
        2. working with appropriate supervisory staff and the RSC to implement any required reductions in Effort or releases from other institutional activities when an Individual’s charged or contributed Committed Effort exceeds established UTSA, college, or departmental policies or standards.  
    5. Primary Individual’s Supervisor (dean, chair, Center/Institute director, or appropriate vice president)
      1. Approves proposed Effort Commitment levels in Sponsored Program proposals for each Primary Individual he/she supervises through routing mechanisms established by the OGCIA; and
      2. Approves any cost sharing found in a proposal for a Sponsored Program, including, but not limited to, Cost Shared Effort.
    6. Office of Sponsored Project Administration (OSPA)
      1. Assists Primary Individuals, Collaborating Individuals, and their respective Supervisors with Effort-Related matters;
      2. Develops educational and training programs to assist administrators, faculty and staff understand and apply Effort-Related Policies;
      3. Submits proposals to Sponsors on behalf of UTSA if the proposals have received appropriate internal UTSA approvals;
      4. Negotiates and accepts Awards on behalf of UTSA subject to priper verification of the appropriate percentages of Committed Effort;
      5. Provides Primary and Collaborating Individuals and their respective Supervisors with awarded Effort Commitment levels, and directs and/or advises such Individuals and Supervisors on the execution of proper appointments associated wtih an Award;
      6. Coordinates with a Sponsor if circumstances change after the Award - including, but not limited to, certain changes in Committed Effort;
      7. In coordination with Sponsors, Primary Individuals and appropriate departmental/college supervisory staff, facilitates any Award amendments and other programmatic or Award adjustments or other actions required by a Sponsor because of changed circumstances;
      8. Monitors Effort Commitments and Effort Certification;
      9. Issues reports on Effort Commitment and Effort Certification; and
      10. Disseminates and implements additional procedures as needed to implement the Effort-Related Policies.

    IX. PROCEDURES


      1. Management of Effort Commitments
        1. Total Institutional Activities, Effort and Committed Effort.
          1. In order for UTSA to receive federal funds for compensation (such as salaries and wages) associated with personal services expended in support of a federally Sponsored Program, UTSA must have a payroll distribution system that reasonably reflects all activities (sponsored and non-sponsored) for which an Individual both expends Effort and receives compensation from UTSA. [OMB Circular A-21, Section J.10.b. (2) (a) (iii)].
          2. Total Institutional Activities consist of all the duties and responsibilities that an Individual has to UTSA because of his/her employment with UTSA. 
            1. Total Institutional Activities for a faculty member INCLUDE but are not limited to:
              1. Public and UTSA service,
              2. Teaching,
              3. Research, and
              4. Some administrative duties.
            2. Total Institutional Activities for a faculty member EXCLUDE:
              1. Outside consulting,
              2. Work performed for another employer (outside employment), and
              3. Work for UTSA that results in the receipt of supplemental compensation from UTSA.
        2. Effort is a subset of Total Institutional Activities.  Effort is the percentage of time spent by one Individual on one type of institutional activity (i.e., teaching) in relation to the time spent on all the Total Institutional Activities for that Individual. Additional attributes of Effort include the following;
          1. Effort should equal 100% but can never exceed 100%.
            1. The following hypothetical case will help illustrate 100% Effort. If a half-time UTSA employee works solely on one UTSA Sponsored Program, he/she will still dedicate 100% Effort to that Sponsored Program. Because a half-time employee will only receive a 50% appointment at UTSA, his/her salary as reflected in UTSA’s records would be one half of what he/she would receive if working full-time. Therefore, documenting both a 50% appointment and 100% Effort in this case will ensure that the Sponsor is not over-charged for services by the half-time employee.
          2. The federal guidelines recognize that institutional activities, including teaching, research, service and administration, are often inextricably intermingled. [See OMB Circular A-21, §J.10.b (1)(c).]  Therefore, Effort is not calculated based on a standard forty (40) hour work week, or any other standard work week, but is calculated as a percentage of the total time spent on Total Institutional Activities.
          3. Effort is based on estimates in which a degree of tolerance is appropriate. [See OMB Circular A-21, §J.10.b(2)(a).]  However, such estimates must appear reasonable in light of the other institutional duties and responsibilities of the Individual. 
          4. Effort must be reported in whole percentages.
        3. Committeed Effort is the type or category of Effort that is the primary focus of the Effort-Related Policies. Committed Effort is the total Effort committed to a Sponsored Program, expressed as the sum of: (1) Effort proposed to be paid by the Sponsor and (2) Cost Shared Effort. Additional attributes of Committed Effort include the following:
          1. Committed Effort may actually be expended during the academic year, the summer, or both.
          2. Committed Effort should be reasonable and commensurate with an Individual's duties/responsibilities under a Sponsored Program.
            1. For example, writing proposals for new grants or Sponsored Programs does not constitute part of an Individual’s Committed Effort on a currently funded Sponsored Program (except in the rare case that the seeking of such grants/external funding is a deliverable under the Sponsored Program). 
          3. Committed Effort (like any other type of Effort) should also be reasonable in light of all institutional duties/responsibilities shouldered by an Individual.
      2. Committed Effort for Primary Individuals
        1. Establishing the Minimum Level of Committed Effort for every Primary Individual on each of his/her Sponsored Programs:
          1. Rule:  Each Primary Individual identified in a particular Sponsored Program must commit to and expend Effort of at least 1% on that Sponsored Program over the period of Sponsored Program performance or over a one year period, whichever is shorter. Said another way, the Minimum Level of Committed Effort for each Primary Individual identified on a Sponsored Program is at least 1% Effort.
            1. Providing Effort "as needed" is not acceptable.
            2. The Minimum Level of Committed Effort may be more than 1% depending on the scope of duties in the proposal or Award.
          2. Exceptions to the Rule: A Primary Individual may be allowed to commit less than 1% Effort if it is approved by UTSA’s DRP, documented in writing and it is one of the following kinds of Sponsored Programs:
            1. Equipment or instrumentation grants,
            2. Doctoral dissertation grants,
            3. Augmentation grants,
            4. Special institutional or training awards.
        2. Establishing the Maximum Level of Committed Effort for certain Primary Individuals on all of his/her Sponsored Programs:
          1. Rule: The Maximum Level of Committed Effort for each Primary Individual who has both an academic appointment and an administrative appointment is 80% Effort at all times.  The Maximum Level of Committed Effort for each Primary Individual who has only an academic appointment is 80% Effort during the academic year and 100% Effort during one (1) or more of the summer months.  Such Primary Individuals may commit Effort to more than one Sponsored Program so long as the cumulative Committed Effort from all such Sponsored Programs does not exceed the applicable Maximum Level of Committed Effort established above. 
            1. Most Primary Individuals who are also faculty have other responsibilities as part of their Total Institutional Activities that would preclude them from devoting 100% of their Effort to Sponsored Program(s)—especially during the academic year.
            2. Most Primary Individuals who are also faculty may have other responsibilities as part of their Total Institutional Activities such as teaching, serving on regulatory committees, or supervising graduate students, that may preclude them from devoting 100% Effort to a Sponsored Program during the summer months. Also, taking a vacation during the summer may preclude a faculty member from devoting 100% Effort to a Sponsored Program. 
            3. Primary Individuals who do not have a faculty appointment, Supporting Individuals, and other Individuals with research appointments (e.g. research postdoctoral positions or research professors) do not have an established Maximum Level of Committed Effort—but, their Effort Commitment cannot exceed 100%.
            4. Any Individual claiming 100% Committed Effort for any time period must ensure that he/she (a) does not perform other UTSA-related duties (e.g., serving on institutional committees) during that time period, and (b) does not work on research activities  that are not related to the Sponsored Program to which he/she has committed all of his/her Effort.
          2. Exceptions to the Rule: Any exception to the above-stated Rule must be documented in writing, must be justified by unusual circumstances, and must be approved by UTSA’s DRP.
      3. Establishing the Effort Commitments for a Sponsored Program
        1. Quantifying/Approving the Effort Commitment found in a Proposal (Pre-Award):
          The Effort Commitment found in a Sponsored Program proposal ensures the sponsor that the proposal carries sufficient manpower/labor resources for the full undertaking of such Sponsored Program–including adequate oversight of the financial, research/scientific and compliance aspects of the Sponsored Program. To this end, the PI/PD, his/her Supervisor, and RSC will take the pre-Award actions/steps outlined below.   
          1. The PI/PD takes the lead and retains the ultimate responsibility for ensuring that his/her proposal for a Sponsored Program reflects an appropriate and reasonable level of Committed Effort for each Individual listed in the proposal and complies with the Effort-Reporting Policies. The PI/PD should consult with the RSC whenever he/she has any pre-award questions or concerns related to Effort and must obtain appropriate, timely approval of the proposal from his/her Supervisor. In addition, the PI/PD will (1) route the proposal of other Primary Individuals and each Collaborating Individual to his/her Supervisor before it is submitted and (2) will allow the Supervisor at least one (1) day to review the proposal and provide comments back to the PI/PD.
          2. Each Primary Individual’s Supervisor [i.e., dean, chair, Center/Institute director, or appropriate vice president] must approve the proposal before the RSC submits it to the Sponsor. Using routing mechanisms established by OSPA, each Primary Individual’s Supervisor should approve such  proposal only after:
            1. The Supervisor has scrutinized the Effort Commitments found in the proposal;
            2. The Supervisor has determined that all appropriate requirements relating to any cost sharing (including, but not limited, to Cost Shared Effort), have been satisfied [See UTSA HOP policy 10.07, Cost Sharing on Sponsored Programs.];
            3. The Supervisor has determined that the Primary Individual’s Committed Effort in the proposal meets the Minimum Level of Committed Effort requirement; and
            4. The Supervisor has paid particular attention to Effort Commitments that may later require a Primary Individual to be relieved of other institutional duties/responsibilities.
          3. The RSC submits the proposal to the Sponsor, consults with the PI/PD and his/her Supervisor if the Sponsor does not accept the proposal as submitted, and negotiates with the Sponsor to set the Effort Commitment levels found in the final Award at levels satisfactory to both the Sponsor and UTSA. 
        2. Ensuring that Appointments Reflect Effort Commitments found in an Award
          The proper management of Committed Effort requires coordination and cooperation between the RSC, the PI/PD, any other Primary Individual, any Collaborating Individual(s), and their respective Supervisors, as UTSA takes steps to institutionalize the Effort Commitment levels found in a final Award into (a) UTSA’s payroll distribution system and (b) UTSA’s Effort reporting/certification system.
          1. The RSC provides the PI/PD, any other Primary Individuals, and Collaborating Individuals and their Supervisors with awarded Effort Commitment levels through internal notices of award mechanisms and communicates with PI/PDs and their Supervisors, regarding the execution of proper appointments for all Individuals involved with the Sponsored Program. 
          2. The PI/PD continues to retain the ultimate responsibility for Effort-related matters associated with the newly-awarded Sponsored Program, including the following:
            1. ensuring that appropriate administrative staff in the department, Center/Institute, or Sponsored Program timely executes appointments on the Sponsored Program accounts to reflect the sponsored and non-sponsored activities of all Individuals associated with the Sponsored Program except for any Collaborating Individual(s);
            2. ensuring that each Primary Individual’s Committed Effort on the Sponsored Program meets the Minimum Level of Effort Commitment  requirement found in this policy and that his/her total Committed Effort (including the newly-awarded Sponsored Program) does not exceed the Maximum Level of Effort Commitment requirement found in this policy;
            3. ensuring that funding is secured for any Cost Shared Effort in the Sponsored Program; and
            4. understanding and monitoring the Committed Effort of him/herself, any other Primary Individuals, Supporting Individuals and Collaborating Individuals on all of his/her awarded Sponsored Programs.
          3. Each Collaborating Individual retains primary responsibility for the following:
            1. ensuring that appropriate administrative staff in the department, Center/Institute, or Sponsored Program timely executes appointments on the Sponsored Program accounts to reflect the Collaborating Individual’s sponsored and non-sponsored activities;
            2. ensuring that the Collaborating Individual’s Committed Effort on the Sponsored Program meets the Minimum Level of Effort Commitment requirement found in this policy and that his/her total Committed Effort (including the newly-awarded Sponsored Program) does not exceed the Maximum Level of Effort Commitment requirement found in this policy; and
            3. promptly notifying his/her Supervisor and the PI/PD of any changes in or inability to meet his/her Effort Commitment as found in the final Award.
        3. Monitoring of Effort Actually Provided
          1. The PI/PD PI/PD will monitor levels of Effort Commitments for all Individuals on Sponsored Programs and communicate any changes or inability to meet any Individual’s Committed Effort as found in the final Award to his/her Supervisor and to the RSC to ensure adherence to this policy and to UTSA’s Cost Transfer Policy. (See UTSA HOP policy10.08, Cost Transfers on Sponsored Programs);
          2. The RSC also monitors levels of Effort Commitments. Additionally, working with Sponsors, Primary Individuals (including PI/PDs) and appropriate departmental/college supervisory staff, the RSC will:
            1. facilitate any Award amendments;
            2. assist the PI/PD with obtaining Sponsor approval in making other adjustments or taking such other action as may be required by the Sponsor to reflect changed circumstances—including changes in Committed Effort; and
            3. assist and support the PI/PD’s efforts to obtain releases from an Individual’s other institutional duties or take other institutional or programmatic actions as required by a Sponsor because of changed circumstances.
      4. Certification of Effort
        1. UTSA is required to certify Effort.
          1. The salaries paid by UTSA to its employees working on Federal grants are generally charged or allocated to those grants based on Effort expended. Therefore, Effort Certification (which describes the allocation of an Individual’s Effort) is different from--but an essential factor in determining-- payroll distributions (which describes the allocation of an Individual’s salary).
          2. Effort Certification provides auditable documentation that the Effort Commitments required as a condition of award of the Sponsored Program have been met and that compensation for personal services charged to a Sponsored Program is appropriate and reflects a reasonable estimate of the amount of Effort expended on a Sponsored Program.  
        2. Method of Certification Effort at UTSA
          1. UTSA relies on an electronic Effort reporting system through which a statement detailing Effort (Effort Statement) is generated for each Individual. Using this system, the Primary Individual and Collaborating Individuals can periodically review, adjust if necessary, and certify that Effort charged to Sponsored Program(s) is reasonable in relation to the work performed. Each Primary Individual (for him/herself and Supporting Individuals) and each Collaborating Individual (for him/herself) must periodically review and certify the Effort Statements associated with their Sponsored Program(s).
          2. The certification of the Effort Statement is a formal attestation of the following:
            1. that the Effort outlined in the Effort Statement is appropriate and reasonable in relation to the work performed on Sponsored Program(s); and
            2. that the certifier has suitable first hand means of verification.
          3. Because a certified Effort Statement is used to confirm that an Individual’s salary/wage charges to Sponsored Program(s) are reasonable in relation to the work performed, all certified Effort Statements become part of the UTSA’s auditable system of record for tracking Effort on Sponsored Programs.
          4. In some instances, however, after consultation with and approval by the RSC, certified Effort that varies no more than five percent (5%) from the original Committed Effort may be permitted.
        3. Timeframe for Effort Certification
          In order to meet the requirements of OMB Circular A-21 as implemented at UTSA, Primary and Collaborating Individuals must certify Effort as follows:
          1. No less than twice a year in accordance with a schedule set out by OSPA; and
          2. Within thirty (30) days after receiving a request for certification from OSPA.
            1. Under special circumstances, the DRP may allow up to forty-five (45) days to complete the requested certification. 
        4. Consequences of not properly or timely certifying Effort
          1. All perons involved in the Effort Certification process are expected to abide strictly by the provisions of this policy and seek guidance when they have questions, concerns, or atypical situations. 
          2. Failing to follow this policy or the policies and guidelines referenced herein or certifying inaccurate Effort Statements (whether done intentionally, knowingly, recklessly, or merely through carelessness or mismanagement) may lead to serious repercussions for both UTSA and the person who improperly certified Effort. Such repercussions may include the following:
            1. Financial penalties;
            2. Expenditure disallowances;
            3. Harm to UTSA’s reputation; 
            4. Criminal charges brought against an Individual who certifies a falsified Effort Statement;
            5. Suspension of a Sponsored Program(s) account for an Individual who does not certify in a timely manner
            6. Suspension or termination from UTSA for significant or repeated failures to certify; and/or
            7. In case of a violation of civil or criminal law, violators may be subject to civil or criminal penalties. Alleged violation(s) may be reported as required to the appropriate oversight agencies.

      X. SPECIAL INSTRUCTIONS FOR IMPLEMENTATION


      None


      XI. FORMS AND TOOLS/ONLINE PROCESSES


      Please see UTSA’s Time and Effort website http://vpr.utsa.edu/osp/te for guidelines and more procedures related to this policy.


      XII. APPENDIX


      None

      Editorial Amendment: December 11, 2013