OP 65.02: Effort Commitment and Certification

 

[Moderate revision–posted 5/4/26 (replaces 11/4/16 edition)]
[Updated System Regulation number and link–6/3/26; no additional change to OP]
[PDF Version]

 

Operating Policy and Procedure

OP 65.02: Effort Commitment and Certification

DATE: May 4, 2026

PURPOSE: The purpose of this Operating Policy/Procedure (OP) is to outline institutional requirements for determining, managing, and certifying effort; to promote stewardship of extramural funds; and to ensure compliance with federal and state regulations.

REVIEW: This OP will be reviewed every two years after publication by the Assistant Vice President and Controller and the Senior Associate Vice President for Research Operations with substantive revisions forwarded through administrative channels to the Vice President for Research & Innovation (VPR), the Senior Vice President for Administration & Finance and Chief Financial Officer (SVPAF/CFO), the Senior Associate Vice President for Human Resources, and the Provost and Senior Vice President (PSVP).

POLICY/PROCEDURE

1.  Policy Statement

It is the policy of Texas Tech University (TTU) that all faculty and staff comply with state (State of Texas Grant Management Standards) and federal (Uniform Guidance 2 CFR 200.308 and 2 CFR 200.430) regulations, as well as institutional policies regarding proposing, charging, and certifying effort on sponsored project and cost share funds.

University faculty and staff are expected to charge their time to sponsored projects commensurate with the committed effort expended. Salary charges to sponsored projects and cost share serve as the initial data points for the university’s effort reporting system. Certifications are completed after-the-fact via a web-based effort certification system (ECRT/ECC).

2.  Definitions

a.    Certify – To attest authoritatively as being true; to confirm accuracy by an individual with suitable means of verification and authority

b.    Commitment – Committed effort offered to a sponsor in the proposal documents over the life of an award that is specified, quantified, and becomes a binding commitment upon execution of the award agreement

c.    Cost Share – The portion of project costs paid by the university or a third party, rather than the sponsor

d.    Effort – The proportion of time spent on all activities performed, expressed as a percentage of total professional duties; for reporting purposes, effort is calculated in percentages, not hours, with total effort equal to 100 percent

e.    Effort Certifier – Individual identified as having suitable means of verification for certifying effort. Reference section 7.c.

f.    Effort Coordinator – Individual identified at the departmental level responsible for monitoring effort reports and final processing of certified effort statements for their respective department; effort coordinators are typically not effort certifiers, and vice versa

g.    Labor Redistribution – After-the-fact transfer of salary and fringe benefit costs, for past pay periods, from one FOAP (fund/org/account/program) to another

h.    Sponsored Project – Grant, contract, or cooperative agreement funds under which the university agreed to perform a certain scope of work, according to specified terms and conditions, and for specific budget monetary compensation (i.e., Banner funds beginning with 21, 22, 23, and certain 11 or 12 state funds that may be awarded as a sponsored project) and related committed cost share companion funds (xxM funds)

3.  Professional Duties

Faculty and staff appointments are made in accordance with federal, state, and university regulations and employment policies. Appointments are made relative to the needs of the institution to perform duties encompassing time spent on research, teaching, or other activities. In general, OP 32.17, Faculty Appointments and Titles, OP 32.18, Academic Workload Calculation, and OP 70.06, Employee Working Hours, outline workload and working hours necessary to carry out the professional responsibilities of the position. Faculty and staff should apportion their effort based on the composite of all activities performed as part of their university appointment.

Faculty and staff may engage in consulting for entities outside the university in accordance with OP 32.07, Other Employment, Faculty Consulting, and Public Offices, and System Regulation 10.12. Effort expended on such consulting is in addition to university responsibilities and, therefore, excluded from total effort.

4.  Institutional Base Salary

Institutional base salary (IBS) is defined in detail in OP 74.16, Institutional Base Salary. For employees with a nine-month appointment, regular summer appointments are part of IBS and included in effort certifications based on the annualized salary to determine IBS.

5.  Committed Effort

Levels of effort proposed in any sponsored project application should be consistent with the actual effort each individual is expected to expend on the project during the relevant performance period(s). The amount of salary support requested normally is determined by multiplying the proposed level of effort by the individual’s IBS. In some cases, the amount of requested salary support may be less than this amount. In no event should the requested salary exceed the amount determined by multiplying the proposed level of effort by IBS.

a.    Maximum Effort

The total of committed effort in awarded sponsored projects should never exceed 100 percent. In the event that committed effort exceeds 100 percent, effort on one or more projects must be reduced (as discussed below).

b.    Changes in Commitment Level

Once TTU and the sponsor execute an award agreement, the principal investigator (PI) is expected to provide the level of effort to which they have committed.

• A 25 percent or greater reduction in the level of committed effort for the PI must be approved prior to the change and in writing by the sponsor. It is not sufficient to simply communicate the change to the sponsor.

• An increase in effort greater than 25 percent for a PI should be reviewed to assess whether the scope of work for that project has changed and to assess possible impacts on the individual’s ability to meet commitments to other sponsored projects. Any change in the scope of work must be approved prior to the change and in writing by the sponsor.

PIs must contact the Office of Research Services (ORS) if significant changes in commitment are anticipated to ensure agency guidelines are followed.

6.  Effort Training

PIs with active sponsored projects, faculty appointed to sponsored projects, department chairs/directors, and deans must complete an initial online training program with continued trainings every three years thereafter. Effort coordinators must complete a one-time classroom training session (in-person or virtual) conducted by Accounting Services (AS) before being granted access to the ECRT/ECC system.

The following notification procedures are enforced for employees not completing training in accordance with this policy:

• Department chair/director – Approximately 30 days after due date
• Dean and assistant/associate dean for research (ADR) – approximately 45 days after due date
• VPR and the PSVP – Approximately 60 days after due date

7.  Effort Certification

a.    Estimating Effort

It is recognized in an academic setting that teaching, research, service, and administration are often inextricably intertwined. A precise estimate is not always feasible, nor is it expected. Therefore, reliance is placed on estimates in which a degree of tolerance is appropriate. TTU’s acceptable variance is equal to or less than 5 percent of total effort. If a reasonable estimate of actual effort is within 5 percent of the effort shown on the statement (based on salary distributions), it is permissible to certify the level of effort that appears on the statement.

b.    Distinguishing Between Commitment, Salary, and Effort

Fulfillment of an effort commitment is measured over the performance period. An individual’s devoted effort, and thus salary charges, may vary throughout the project. As projects typically span multiple effort periods, the individual is obligated to charge salary to the project and to certify their effort in a manner that is consistent with actual effort. This variation is acceptable if the individual fulfills the overall commitment. It is not permissible to charge a constant salary rate over the performance period if it does not reflect true effort.

c.    Responsible Effort Certifiers

Each effort statement must be certified by a responsible person with suitable means of verification:

• PIs and faculty certify their own effort.
• PIs certify effort of non-faculty and students who work on their projects.
• For students who work on multiple projects, each PI will certify the portion of effort on their individual projects.
• For larger projects, the PI may not have suitable means of verifying the effort for all of their sponsored project staff. In these cases, the PI may request an alternative certifier for AS to establish within ECRT/ECC.

d.    Certification for Personnel Leaving the University

Departments are responsible for notifying ORS and AS prior to a PI leaving the university, and AS will make reasonable efforts to have the PI certify effort prior their departure. If the current effort performance period has not yet concluded, AS will prepare manual statements. In the event certification is not obtained prior to departure, the PI or department chair/director must identify an alternative individual who has suitable means of verification.

e.    Certification Timeline

Effort for all employees is certified on a semi-annual basis within 45 days of the statement becoming available. In general, the periods of performance and the corresponding certification windows are as follows:

Reminder notifications will be sent to certifiers approximately 15, 30, and 45 days into the certification period. Additionally, the department chair/director and the college dean/ADR will receive notification of uncertified statements at approximately day 30 and day 45, respectively.

f.    Consequences for Non-Compliance

After 60 days, AS will provide to the VPR and the PSVP a list of faculty and staff not in compliance with training and/or certification requirements. The VPR and/or the PSVP may authorize any of the following actions to be taken:

• Sponsored project administration services withdrawn and not provided by the institution;
• Suspension of new proposal submissions or award agreement executions on behalf of the faculty or staff;
• Deactivation of current sponsored project funds; and
• Further corrective actions may be taken in accordance with university policies.

g.    Recertification of Effort

Once effort has been certified, subsequent labor redistributions to transfer salary charges among, to, or from sponsored project funds will be closely reviewed by AS and must be in compliance with OP 65.04, Cost Transfers Involving Sponsored Projects and Cost Share Funds. If labor redistributions are approved, the effort statement requires recertification for the impacted certification periods. The PI is required to provide justification for the cost transfer and the recertification of effort.

h.    Falsification of Effort Certification

Any individual who knowingly falsifies an effort certification may be subject to corrective action in accordance with OP 32.04, Conduct of University Faculty.

8.  Roles and Responsibilities

a.    Office of Research Services

• Review proposals, current and pending documents, and award documents to identify and confirm the effort and cost sharing commitments are appropriate, accurate, and compliant with sponsor and institutional policies
• Advise the PI on agency-specific requirements regarding effort commitments and thresholds for prior approval of significant changes (typically >/= 25% reduction in effort); coordinate with AS as needed

b.    Principal Investigator

• Propose effort for sponsored projects in accordance with federal regulations and institutional policy
• Ensure effort devoted is commensurate with commitments to sponsoring agencies
• Certify effort in a timely and accurate manner
• Complete online effort training every three years
• Monitor salary charges and effort monthly
• Notify the effort coordinator in a timely manner of any necessary labor redistributions
• Identify individuals with suitable means of verification when necessary
• Provide justification for recertification of effort statements

c.    Department Effort Coordinator

• Communicate with PIs to ensure appointments are accurate
• Monitor payroll charges within ECRT/ECC to minimize labor redistributions
• Assist PIs with completing and justifying labor redistributions and/or requests for recertification
• Ensure labor redistributions are completed prior to the applicable certification period
• Complete effort and ECRT/ECC training
• Serve as the point of contact for PIs and certifiers

d.    Chairperson/Director and Dean

• Complete online effort training every three years
• Identify an alternative individual with suitable means of verification to certify effort statements associated with projects where the PI is unavailable to certify
• Enforce provisions of this policy

e.    Vice President for Research & Innovation and Provost and Senior Vice President

• Enforce provisions of this policy
• Issue sanctions for noncompliance

f.    Accounting Services

• Serve as the central point of contact for department effort coordinators
• Provide ECRT/ECC and effort reporting rules and regulation training to individuals outlined in section 6
• Maintain and update institutional policies, procedures, and systems for effort certification
• Perform and monitor variance compliance reviews
• Ensure ECRT/ECC produces effort statements that timely and accurately reflect payroll and cost sharing data from source systems
• Ensure effort statements are released, certified, and escalated according to the established timelines
• Review labor redistributions in a timely manner

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