Research Effort Verification

Effective July 17, 2024
Executive Sponsor: Vice President for Research
Policy Owner: Associate Vice-President for Research, Director of OSP

It is the policy of The University of Texas at Austin (University) to comply with federal standards and regulations regarding the review and documentation of Personnel Expenses charged to Sponsored Projects. The University requires that all individuals who receive sponsored funding comply with University policies and sponsoring agency regulations regarding the proposing, charging, and reporting of Effort on those Sponsored Projects.

This policy provides information and guidance on Standards for Documentation of Personnel Expenses on sponsored projects set forth by the Federal Office of Management and Budget (“OMB”), 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.

The requirements of this policy are based on the University’s desire to verify Personnel Expenses on Sponsored Projects using the Research Effort Verification system. The University requires this policy be applied consistently across all Sponsored Projects that are charged with Personnel Expenses whether federally funded or not.

Personnel Expenses typically comprise a major portion of the direct costs charged to Sponsored Projects. The University’s practice is to utilize an after-the-fact system to verify that Personnel Expenses charged to Sponsored Projects are allocable, allowable, reasonable, and consistent with the work performed. The Research Effort Verification system provides auditable documentation confirming that the Principal Investigator or other University personnel has verified that Personnel Expenses charged to Sponsored Projects are correct, or the necessary steps will be taken to make corrections. This policy is consistent with “2 CFR §200.430: Compensation – personal services” and provides the framework for acceptable methods of documenting Personnel Expenses on Sponsored Projects.

This policy applies to the Effort of all University Employees who have Personnel Expenses paid from Sponsored Projects or have Committed Effort on Sponsored Projects. This policy also applies to any University Employee involved in the management, administration, or oversight of Sponsored Projects.

Committed Effort:
The amount or percentage of time an Employee has communicated to the sponsor that they will commit to a Sponsored Project over a specified period. Commitments are documented in the award proposal and are included by the sponsor in the award documentation. Sponsor approval may be required when an Employee changes their Committed Effort on a Sponsored Project.

Cost Sharing:
The mandatory or voluntary commitment of institutional resources contained in the proposal/application and resulting Sponsored Project. The concepts of matching and in-kind are synonymous with cost sharing.

Effort:
The proportion of time spent on any University activity expressed as a percentage of time. An Employee’s workload will reflect categories of activities expressed as a percentage distribution that must add up to 100% total Effort. The total Effort reported will always equal 100%, even if they are less than 1.0 full-time equivalent appointment.

Effort Contact:
An administrator assigned by the Principal Investigator’s department who is responsible for assisting in the review of Personnel Expenses on Sponsored Projects.

Effort Contact Review:
Review of Personnel Expenses on Sponsored Projects by the assigned Effort Contact in the Research Effort Verification system. Effort Contacts are responsible for reviewing Personnel Expenses charged to Sponsored Projects and working with Principal Investigators to determine if the amounts charged are reasonable in comparison to Effort Performed.

Effort Performed:
The amount or percentage of time that an Employee contributes to a Sponsored Project over a specific period. The Effort Performed by each Employee on a Sponsored Project should be documented by the Principal Investigator to verify that the amount of Effort contributed to the Sponsored Project is comparable to the Committed Effort.

Employee:
For the purposes of this policy, an Employee is any University faculty or staff member, graduate student, or student employee who is compensated for work performed on a Sponsored Project.

Institutional Base Salary (IBS):
The annual compensation paid for an employee’s appointment (9 or 12 months), whether that employee’s time is spent on research, teaching, administration, or other activities. Recurring supplements, academic salary and endowments are included. IBS does not include one-time supplements, and/ or compensation for special programs and activities. Additionally, IBS does not include payments from other organizations or income that individuals are permitted to earn outside of their institutional responsibilities, such as consulting. IBS may not be increased as a result of replacing University salary funds with Sponsored Project funds.

Key Personnel:
Employees that are essential to carrying out the work of a Sponsored Project, typically those responsible for the design, conduct and reporting of the research.

Personnel Expenses:
All renumeration, paid currently or accrued, for services of Employees rendered during the period of performance under a Sponsored Project, including, but not necessarily limited to, wages and salaries.

Principal Investigator (PI):
A Principal Investigator is defined as the individual responsible for the preparation, conduct, and administration of a Sponsored Project.

Proxy:
A Proxy is defined as an individual with comparable responsibilities on a Sponsored Project to a Principal Investigator who has sufficient knowledge of the work performed to verify Personnel Expenses on the Sponsored Project.

Research Effort Verification:
The system used by Principal Investigators and Effort Contacts to review and verify Personnel Expenses on Sponsored Projects. The Research Effort Verification system provides an opportunity to compare Effort Performed by Employees on Sponsored Projects against their Committed Effort and salary distributions.

Salary Cap:
The maximum annual salary for the level of Effort that can be charged to a Sponsored Project. It does not limit the amount of compensation paid to an Employee but does limit the amount that the funding agency will reimburse for that individual’s Effort on the Sponsored Project.

Sponsored Project:
An externally funded activity that is separately budgeted, accounted for, and governed by specific terms and conditions of the sponsoring organization. A Sponsored Project may be in the form of grant, contract, or cooperative agreement for research, instruction, or public service activities.

General Requirements

The Research Effort Verification system must be used annually by Principal Investigators to verify Personnel Expenses charged to their Sponsored Projects in the prior fiscal year.

The University distributes Personnel Expenses in relation to a percentage of total compensated activities for a position, not as hours worked. All Employee compensated activities equal 100 percent of an Employee’s University Effort, regardless of whether the compensated activities are accomplished in 30, 40 or 50 hours per week, and regardless of the full-time equivalent appointment.

It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When verifying Personnel Expenses charged to Sponsored Projects in the Research Effort Verification system, a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected. Due to this expectation, a deviation of +/- 5% between Effort Performed and Effort Committed is considered a tolerable threshold when the Effort is verified on Sponsored Projects.

The Effort expended on total institutional activities should not exceed 100%. Generally, most faculty have responsibilities for teaching, proposal development, or service that would preclude them from devoting 100% of their time to Sponsored Projects. Thus, in most situations, the University requires that a faculty member not commit more than 95% Effort on Sponsored Projects. If a faculty member wishes to commit 100% Effort to Sponsored Projects at any time, they must complete and submit an attestation form to the Office of Research Support and Compliance that documents that the faculty member is not participating in any other activities (proposal development, teaching, consulting, outside appointments, etc.) during the period in which they are compensated 100% from Sponsored Projects. Key Personnel on Sponsored Projects who do not have responsibilities other than research may commit 100% Effort to a Sponsored Project without submitting an attestation form.

Sponsored Projects may include a Salary Cap. The Office of Sponsored Projects will implement procedures during the budget development process and award management to ensure that it complies with Salary Caps on Sponsored Projects.

Faculty members may not charge a higher monthly salary rate to their Sponsored Projects during summer sessions than the proportionate share of their Institutional Base Salary. The number of months during the summer that a researcher can claim salary on a Sponsor Project may be limited by University policy, summer teaching assignments, and by each individual funding agency. The University will comply with any applicable limitations on summer salary.

Responsibilities

Responsibility of Principal Investigators

Principal Investigators must use the Research Effort Verification system to verify the Personnel Expenses of all Employees working on their Sponsored Projects to confirm that the Effort Committed is reasonably comparable to the Effort Performed.
Principal Investigators must ensure that Personnel Expenses charged to their Sponsored Projects are accurate, allowable, and properly allocated.
Principal Investigators must communicate any adjustments needed to Personnel Expenses charged to their Sponsored Projects to their department administrator and must confirm the adjustments are processed in the payroll system.
Principal Investigators must mark their Sponsored Projects in the Research Effort Verification system as verified to ensure that the Personnel Expenses are accurately charged, or that adjustments will be made to align compensation of salary with Effort Performed.

Appointment and Responsibility of a Proxy

If a Principal Investigator separates from the University prior to verifying the Personnel Expenses on their Sponsored Projects in the Research Effort Verification system, a Proxy will be appointed by the Principal Investigator’s department. The Office of Sponsored Projects will assist in identifying the appropriate Employee to act as Proxy and will provide that Employee with access to the Research Effort Verification system.
The Proxy will be required to comply with the same responsibilities that are required of the Principal Investigator, including, but not limited to, the responsibility of verifying the Personnel Expenses charged to Sponsored Projects.

Responsibility of Effort Contacts

A department may appoint an Effort Contact to assist with the review of Personnel Expenses charged to Sponsored Projects. The appointment of an Effort Contact is at the discretion of the Department based upon need and availability of resources.
Effort Contacts, if appointed, may review the Personnel Expenses charged to Sponsored Projects assigned to them in the Research Effort Verification system. Effort Contacts review Personnel Expenses during the time periods that are communicated to them by the Office of Sponsored Projects.
Effort Contacts may work with the Principal Investigators and other department administrators to identify adjustments needed to the payroll distributions on Sponsored Projects. The purpose of this review is to confirm that the Committed Effort is comparable with the Effort Performed.
When significant changes in Personnel Expenses become known, adjustments to the salary distributions must be made in the payroll system in a timely manner. Effort Contacts may facilitate this process to confirm that payroll corrections are processed.
Effort Contacts may mark Sponsored Projects as reviewed in the Research Effort Verification system upon completing their review, if any.

Responsibility of the Office of Sponsored Projects (OSP)

OSP is responsible for oversight of the effort verification process. This responsibility includes, but is not limited to, implementing and managing the Research Effort Verification system; reviewing applications and proposals for Sponsored Projects submitted by Employees to confirm that they are consistent with University policy; ensuring that a cost sharing form is completed when Personnel Expenses are included on the project as an institutional commitment rather than directly charged to the project; confirming that Effort Contacts, Principal Investigators, and Proxies have appropriately reviewed and verified Personnel Expenses on Sponsored Projects; communication with Principal Investigators and Effort Contacts regarding the Effort verification process; and providing training, guidance, and other support to Employees.
If the Principal Investigator has separated from the University, OSP will attempt to contact the Principal Investigator to confirm the accuracy of the Personnel Expenses charged to their Sponsored Projects. OSP may administratively verify Personnel Expenses on behalf of the Principal Investigator once OSP confirms with the Principal Investigator that the Personnel Expenses are accurate.

HOP 7-1230 Misconduct in Science and Other Scholarly Activities
2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Modified: July, 17, 2024
Next scheduled review: July 2027

Modified: February, 05, 2008
Previously reviewed: January 21, 2015
Reformatting and editorial changes made.

CONTACT	DETAILS	WEB
Office of Sponsored Projects	Email: osp@austin.utexas.edu Phone:512-471-6424	Website: https://research.utexas.edu/osp/
Grants Financial Management	Email: effort@austin.utexas.edu	Website: