UTMDACC INSTITUTIONAL POLICY # ACA0016
EFFORT CERTIFICATION POLICY
PURPOSE
The purpose of this policy is to set forth the policy and process by which The University of Texas
MD Anderson Cancer Center (MD Anderson) manages Effort commitment, charging, and certification.
POLICY STATEMENT
It is the policy of MD Anderson to comply with all federal and University of Texas System guidelines and
regulations for management and Effort Certification on Sponsored Projects. Employees must certify the
accuracy of Effort that is committed to a sponsor in funding proposals and allocated to Sponsored
Projects.
BACKGROUND CONTEXT
Effort reporting and certification is required by the federal government as a condition of receiving federal
funding, and is the system for reporting the amount of Effort (percentage of time) that employees devote
to federally Sponsored Projects. It is also the means for reporting how much Effort has been expended on
a project that was not paid for by the sponsor, but rather was paid for by the institution from institutional or
other non-federal funds (cost-sharing).
SCOPE
Compliance with this policy is the responsibility of all faculty, trainees/students, and other members of
MD Anderson’s workforce.
TARGET AUDIENCE
The target audience for this policy includes, but is not limited to, all faculty, trainees/students, and other
members of MD Anderson’s workforce who have salaries paid from Sponsored Projects and/or
Committed Effort allocated to Sponsored Projects.
DEFINITIONS
Committed Cost Sharing: The portion of the total project costs of a sponsored agreement that are not
reimbursed by the sponsor of the project. These costs are borne by the institution or other non-federal
third parties in direct support of the project, rather than by the sponsor. Committed Cost Sharing is
promised by the institution in the project proposal itself.
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This policy only pertains to cost sharing as it relates to time commitments made by Individuals listed in a
proposal or award. Committed Cost Sharing may be either Mandatory, required by the sponsor, or
Voluntary, proposed by MD Anderson even though not required.
When an award is received in which Committed Cost Sharing was proposed, the Committed Cost Sharing
becomes a binding commitment that MD Anderson must provide as part of the performance of the
Sponsored Project, and must document for audit purposes.
Committed Effort: The amount of Effort proposed in a grant or other project application and accepted by
a sponsor, regardless of whether salary support is requested for the Effort.
Effort: The proportion of time spent on any activity expressed as a percentage of total institutional
activities for which an Individual is compensated by MD Anderson. Total Effort for an employee must
always equal 100%, regardless of part-time or full-time status, and regardless of number of hours worked.
Effort is not calculated on a 40-hour workweek or any other standard workweek. For example, if an
Individual averages 60 hours per week during the reporting period and spends an average of 15 hours on
a Sponsored Program, that represents 25% Effort (15/60) and the other 45 hours, allocated to other
institutional activities, represents 75% Effort (45/60).
Effort Certification: A means of confirming the percentage of Effort spent in support of each Sponsored
Project and all other institutional activities for a given period of time. Effort Certification requires that both
Effort paid by the sponsor and Effort paid by the institution be confirmed. Each Individual's Effort
Certification must account for total Effort (100%).
Payroll distribution and Effort Certification are not the same thing. Payroll distribution describes the
sources of an Individual's salary, while Effort Certification describes the allocation of an Individual's Effort.
Effort Certification reflects a reasonable estimate of a person's activity for which he/she is compensated
by MD Anderson, recognizing that in an academic setting, teaching, research, service, and administration
are often intermingled.
Individual: Anyone who has salary and/or Committed Effort on a Sponsored Program. Where
appropriate in this policy the following subcategories, primary and supporting Individuals, will be utilized.
Institutional Base Salary (IBS): The total guaranteed annual compensation an Individual receives from
MD Anderson. The IBS is used to compute salaries charged to Sponsored Programs unless sponsor
policies limit the maximum annual compensation rate. IBS includes compensation for instruction, public
service, research, clinical, and/or other activities, as well as supplements for administrative assignments
included in an Individual's annual appointment.
Note: The IBS is the amount described as “Total Annual Salary” in the MD Anderson annual appointment
form, and is the same as the “Compensation Rate” that is stored in the HR system files. It is different from
the “Base Salary” defined in MD Anderson’s “Faculty Compensation Program Policy,” which includes only
the “Professional Component” compensation in the annual appointment form.
IBS excludes fringe benefit payments, reimbursed expenses, temporary supplemental compensation for
incidental work, income earned outside of duties to the institution, incentives, and any portion of
compensation deemed to be at risk. At MD Anderson excluded payments include incentive compensation
plans, supplementary annuity program payments, and Team Anderson awards.
Mandatory Cost Sharing: Cost sharing which is required by the sponsor as a condition of obtaining an
award.
Primary Individual: A person listed as a Principal Investigator, project director, co-investigator, coproject director, or someone with comparable responsibilities on a Sponsored Project. A Primary
Individual is usually a faculty member.
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Principal Investigator (PI): The Individual(s) who is the responsible leader of an investigative team and
responsible for the design, conduct, or reporting of a research project or program.
Salary Cap Cost Sharing: A special case of Mandatory Cost Sharing relates to sponsor limitations on
IBS. Salary Cap Cost Sharing is required when an Individual’s Institutional Base Salary exceeds the
maximum annual compensation rate the sponsor is willing to reimburse (the “salary cap”).
If a person’s IBS exceeds the sponsor’s maximum allowed reimbursable salary (the salary cap), then the
salary cap is substituted for the IBS in allocating salary to the award. In such a case, for example, if a
person is committed for 60% Effort, then 60% of the salary cap would be charged to the project. The
prorated excess is a form of Mandatory Cost Sharing that must be funded by an appropriate and
allowable source.
NIH has a capped salary, which is tied to a federal compensation rate, and is adjusted from time to time.
Other sponsors may also occasionally apply a maximum salary rate in their awards.
Salary Cost Transfers: Transfer of salary expenses to one account, after they have already been
recorded on another account. A cost transfer is necessary to effect retroactive adjustments to salary
charges.
Salary Cost Transfers need to be managed within the existing policies and procedures in place to
safeguard appropriateness of the transactions, timing of transactions, and other controls. Salary Cost
Transfers must be initiated within 90 days of the original transaction, and may not be initiated after Effort
Certification, except to transfer salaries off of sponsored agreements.
Sponsored Programs (or Sponsored Projects): Externally-funded activities in which a formal written
agreement (i.e., a grant, contract, or a cooperative agreement) is entered into by MD Anderson and by
the sponsor. A Sponsored Project may be thought of as a transaction in which there is a specified
statement of work with a related, reciprocal transfer of something of value.
The University of Texas System also includes in this category internally-funded activities which are
separately budgeted and accounted for, as a result of a formal application and approval process. At
MD Anderson, qualifying internally-funded activities include Institutional Research Grants, Bridge
Funding, and University Cancer Foundation Research Projects.
Supporting Individual: An employee other than a Primary Individual who has allocated Effort to a
Sponsored Program, whether or not paid by the program. The Supporting Individual may or may not
have been identified on a Sponsored Project application.
Voluntary Committed Cost Sharing: If cost sharing is proposed in a Sponsored Program application
when it is not required by the sponsor, it becomes a commitment of institutional resources when the
program is awarded.
Voluntary Committed Cost Sharing is not allowed on Sponsored Projects except by special exception.
PROCEDURE
1.0
Effort Management
1.1
Effort Commitment and Cost Sharing at Time of Proposal:
A.
Prior to proposal submission, each Primary Individual shall signify awareness and
approval of his/her Effort proposed in the activity.
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1.2
B.
Effort proposed for all primary and Supporting Individuals is included in Sponsored
Project proposals (see: Request for Salary & Fringe Cost Sharing).
C.
A Principal Investigator who wishes to propose Voluntary Committed Cost Sharing to a
sponsor must first submit a Cost-Sharing Waiver Request, which must include
identification of each person whose Effort is proposed to be supported in whole or in part
by the institution through cost-sharing, the amount of cost-sharing proposed for each
person for the duration of the Sponsored Program, and the rationale for requesting a
waiver. The waiver request must be submitted, and must be approved by the Executive
Vice President and Provost or his/her designee, prior to a proposal being submitted to a
sponsoring agency.
D.
A waiver request for salary and fringe is not required in advance of a grant submission to
a Sponsor providing both of the following terms have been met:

There is no voluntary cost-sharing proposed in the application, and

The grant application has received institutional review and approval at the time of
submission.
Minimum Level of Effort Commitment:
Primary Individuals' Effort shall be commensurate with their responsibilities. Faculty must
commit at least 1% Effort to each Sponsored Project for which they serve as a Primary
Individual or as Key Personnel. Exceptions to the minimum level of Effort are for equipment
and instrumentation grants, doctoral dissertation grants, and augmentation grants.
1.3
1.4
1.5
Maximum Level of Effort:
A.
Tenured and tenure-track faculty may not commit more than 90% Effort to Sponsored
Projects, so as to allow reasonable Effort for other responsibilities, such as committee
service, administrative duties, teaching and mentoring, proposal preparation, clinical
duties, and departmental research.
B.
Individuals other than tenure track faculty may allocate up to 100% of Effort to
Sponsored Programs, provided that this is an accurate representation of their full scope
of Effort, and that they do not have other institutional responsibilities.
Effort Commitment at Time of Award:
A.
At the time of award, it is the responsibility of the Principal Investigator and each Primary
Individual to ensure that total Effort commitments meet the requirements of this policy,
and to make necessary adjustments in Effort and salary distribution to reflect changes in
sponsored program portfolio (e.g., addition of new projects, closeout of existing projects,
change in responsibilities for other institutional activities).
B.
If approval of a sponsor is necessary prior to Effort reduction, the Principal Investigator
is responsible for securing this approval in accordance with sponsor requirements.
Effort Commitment Management:
Planning for Effort commitment should be part of the annual planning process between
Primary Individuals and their department chair or head.
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2.0
Effort Certification
2.1
2.2
2.3
2.4
Frequency of Certification:
A.
Effort Certification is required of all faculty and exempt staff on a quarterly basis.
B.
Effort Certification is required of all non exempt staff on a quarterly basis.
Effort Certification Process:
A.
Effort reports are prepared reflecting information in MD Anderson systems about
anticipated distribution of Effort and salary. If the information is correct, the Effort is
certified by the appropriate person. If the information in the system needs to be revised,
revisions must be made on the certification form, and initiated in the systems within the
allowed time period for the certification process.
B.
Certifications must be completed within thirty days of notification that the Effort reports
are ready for review.
Who Signs Certifications:
A.
All faculty certify their own Effort, regardless of whether their role is primary or secondary
on any project.
B.
An appropriate Primary Individual on each Sponsored Project or other activity will certify
the Effort of non-faculty Supporting Individuals with Effort on the projects for which
he/she is responsible. In a simple grant, the Principal Investigator will be the appropriate
person to certify Effort of Supporting Individuals. In a complex grant, with multiple
subprojects and cores, other Primary Individuals, such as a Leader or a Co-Leader may
be the appropriate certifier. The department chair will probably be the appropriate
person to certify department research Effort.
Effort Changes After Certification:
Effort changes after certification are permitted only if they remove incorrect Effort and/or salary
from a Sponsored Project. No changes are permitted after certification which would increase
Effort or salary on a Sponsored Project.
2.5
2.6
Consistency with Other Time Reports:
A.
Faculty who report hours spent on categories of institutional activity on the Physician
Time Allocation Survey (PTAS) are responsible for making sure that this certified survey
is consistent with the certified Effort report.
B.
The two surveys report on different time periods (two weeks versus three months) and
on different bases (hours versus percent Effort). While the results will often not be the
same in the two surveys, they need to be consistent overall.
Education:
All faculty members who have Effort allocated to Sponsored Projects, and non-faculty
members who fall within the definition of Primary Individual, all Effort coordinators, and
department and division administrators, are required to meet mandatory Effort reporting and
Effort commitment training requirements. These training requirements include the following:
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A.
In-person training on Effort reporting and commitment must be completed by the
following (see Effort Reporting Compliance Education Web page):


New hires:

Within forty five (45) days of hire date, or

Prior to the next Effort Certification period, whichever comes first.
Individuals with a change of status/responsibility:
Individuals who subsequently obtain the status or responsibilities of one of the
listed Individuals in Section 2.6 must complete the in-person training on Effort
reporting and commitment:
2.7
Within forty five (45) days of the date the Individual obtained the new status
or responsibilities, or

Prior to the next Effort Certification period, whichever comes first.
B.
Self-administered training module for access to the Effort Certification and Reporting
system (ECRT).
C.
Refresher training as included in the mandatory self-administered Employee Education
Event (see Institutional Mandatory Training Policy (UTMDACC Institutional Policy #
ADM1168)).
D.
Refresher training required to address instances of non-compliance with this policy and
federal Effort reporting and commitment requirements.
Penalties for Noncompliance:
A.
3.0

Compliance with this policy is mandatory. Non-compliance with this policy may result in
the following progressive penalties:

Merit raise ineligibility for non-compliant Primary Individual(s).

Disallowance of salary costs on each affected Sponsored Project. If disallowed,
salary costs will be moved to a departmental account.
B.
In addition, failure to comply with requirements of the Effort Certification Policy and its
accompanying procedures may result in an Individual being subject to disciplinary
sanctions up to and including termination, and may result in civil and criminal penalties.
C.
Disciplinary action for instances of breach of policy including, but not limited to, failure to
file a certified Effort Report or knowingly filing an erroneous Effort Report, will be
administered according to MD Anderson’s institutional Handbook of Operating
Procedures and MD Anderson's Standard of Conduct.
Responsibilities
3.1
Designated Responsible Party:
The Executive Director of Grants and Contracts is the designated person responsible for Effort
reporting and certification. He or she is responsible for carrying out the education program,
administering the certification process, monitoring compliance, and preparing required reports
and assessments.
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3.2
Departmental Effort Coordinator:
Department Effort Coordinators are responsible for coordination between Grants and
Contracts and faculty and research staff in their departments to facilitate administration of the
Effort commitment, charging, and certification process.
3.3
Faculty:
All faculty certify their own Effort on all activities.
3.4
Primary Individuals:
Primary Individuals certify Effort commitment, salary charges, and cost-sharing allocations for
all non-faculty employees with Effort on a Sponsored Project for which the Primary Individual
is responsible.
3.5
Supporting Individuals:
Allocate Effort in accordance with commitments.
3.6
Grants and Contracts:
Administers the Effort reporting and certification process, including training. Is the control point
for quality and regulatory compliance. Conducts monitoring program to evaluate and report on
operating controls.
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ATTACHMENTS / LINKS
Cost-Sharing Waiver Request.
Effort Reporting Compliance Education Web page.
Handbook of Operating Procedures.
MD Anderson's Standard of Conduct.
Request for Salary & Fringe Cost Sharing.
RELATED POLICIES
Faculty Compensation Program Policy (UTMDACC Institutional Policy # ACA0044).
Institutional Mandatory Training Policy (UTMDACC Institutional Policy # ADM1168).
JOINT COMMISSION STANDARDS / NATIONAL PATIENT SAFETY GOALS
None.
OTHER RELATED ACCREDITATION / REGULATORY STANDARDS
OMB Circular A-110 - Uniform Administrative Requirements for Grants and Agreements with Institutions
of Higher Education, Hospitals, and Other Non-Profit Organizations.
OMB Circular A-21 - Cost Principles for Educational Institutions.
University of Texas System Policy # UTS163, Guidance on Effort Reporting Policies.
REFERENCES
None.
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UTMDACC INSTITUTIONAL POLICY # ACA0016
___________________________________________________________________________________
POLICY APPROVAL
Approved With Revisions Date: 08/20/2015
Approved Without Revisions Date:
Implementation Date: 08/20/2015
Version: 51.0
___________________________________________________________________________________
RESPONSIBLE DEPARTMENT(S)
Grants and Contracts
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