Compensation on Sponsored Agreements | Policies

Purpose:

To establish high standards of internal controls governing salaries and wages on sponsored agreements and to establish processes to review time and effort reporting on federal awards.  This policy is intended to comply with the requirements from the Office of Management and Budget Uniform Guidance (UG) Subpart E – Cost Principles 200.430.

Scope:

This policy is applicable to faculty and staff who are involved in administering sponsored agreements.  

Responsibility:

The interpretation and administration of this policy shall be the responsibility of the Grants and Contracts Accounting Office (GCA) in consultation with the Associate Vice President and Controller.

Policy:

As a recipient of federal funding, Teachers College (TC) is required to comply with the Office of Management and Budget Uniform Guidance (UG) as well as other federal requirements for certifying effort expended on sponsored awards. TC requires all individuals working on sponsored funding to comply with the College policies and sponsored agency regulations regarding the proposing, charging, and reporting of effort on those awards.  The faculty and staff are expected to charge their time to sponsored awards commensurate with the committed effort expended on the activities they perform.  The College’s official payroll system is the basis for confirming payroll charges to federal awards.

Uniform Guidance on Compensation

In accordance with OMB Uniform Guidance Subpart E – Cost Principles 200.430, Teachers College maintains the following:

Institutional Base Salary

• Charges for work performed on federal awards by faculty and/or staff are allowable at the Institutional Base Salary (IBS).  IBS is the annual compensation paid for an individual’s appointment (9 or 12 months), whether that individual’s time is spent on research, teaching, administration, or other activities.  IBS does not include supplemental payments (one time or recurring), administrative supplements and/or compensation for overage/summer overage. 
• 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 rate must be used as the base salary on all grant proposals.  For effort reporting purposes, total institutional effort is 100%, regardless of the individual’s appointment (e.g, 0.5 FTE, .75 FTE, 1.0 FTE).  No individual may commit more than 100% institutional or summer effort or be compensated at a rate that would exceed their annualized IBS.

Effort Reporting Process

• Effort reporting is an internal College process designed to meet regulatory requirements for maintaining records that accurately reflect the work (effort) performed on federally sponsored agreements.
  
  
• The OMB Uniform Guidance (200.430) provides standards for documentation of expenses on federally sponsored awards.  Under these standards, records must be:

1. Supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable, and properly allocated.
2. Incorporated into the official records of the College.
3. Reasonably reflect the total activity for which the employee is compensated by the College, not exceeding 100% of compensated activities.
4. Encompass both federally assisted and all other activities compensated by the College.
5. Comply with the established accounting policies and practices of the College.
6. Support the distribution of the employee’s salary or wages among specific or cost objectives if the employee works on multiple awards or activities regardless of the source of funding.
7. Correspond to the amount of actual charges for salaries and wages rather than be based upon estimates.  Estimates alone do not qualify as support for charges to federal awards.

• Total effort is defined as all professional activities for which the College compensates an individual.  For students, this includes time spent working as paid teaching or research assistants.  Payments to individuals classified as participant support costs are excluded from effort reporting requirements, as participant support cannot be paid to employees (UG 200.75).  For reporting purposes effort is calculated in percentages of compensated effort with the total allocation of effort being 100%.

Note: The percentage is not based on a set number of hours, (e.g, 40 or 50 hours per week).  Rather, the percentage equates to the total of College compensated effort.  For example, if a faculty member works 50 hours per week during an effort certification period and 10 of those hours are devoted to a specific sponsored project, total effort assigned to that project would be 20%.

•  GCA submits the effect reports to the appropriate Principal Investigators (PI) or Departmental Administrators (DAA) on an annual basis.  The PI and/or DAA reviews the reports to verify an employee’s salary distribution directly corresponds with his/her actual effort associated with a project.  If during the review of an effort report, it is discovered that actual time and effort differs significantly from the distribution of salary (by 5% or more in total effort) an adjustment must be made to the payroll system.  The PI and/or DAA reflects the appropriate effort on the report, certifies, and submits the adjustment to GCA.                                                                                                                                     
• Effort reports must be returned to GCA within 45 days at the time of submission.  Failure to follow the provisions of this effort certification policy may place the College and those involved at considerable risk.  If effort reports are not completed and returned in a timely fashion, salary cost associated with uncertified grant activity may be charged to a departmental index.
• Except for rare circumstances, once certification of salary has been completed reallocation is not allowed.  If it is necessary to adjust salary charges for a previously certified effort period, documentation must provide a detailed explanation of the need for the salary adjustment and subsequent recertification.  For more on cost transfers please refer to the TC Policy Library under Sponsored Agreements – Accounting Cost Transfers

Roles & Responsibilities

It is the role of each Principal Investigator and Departmental Administrator with delegated approval authority to:

• Understand  requirements for accurate effort reporting.
• Provide reasonable estimates of effort expended in relation to the aims of the project and other College obligations; verify that PI’s and other personnel time commitments on all activities, prior to and after certification, including instruction, research and other departments activities does not exceed 100%; alert the Departmental Chair and/or Provost of any overlap or discrepancy.
• Comply with sponsor requirements regarding reduction in effort and change status of self and, when required by the sponsor, of key personnel.
• Certify his or her effort and all other personnel for the project.
• Notify GCA of any required adjustments to the T&E report.
• Provide certification of effort to GCA in a timely manner upon receipt of report.

It is the role of the Grants and Contracts Accounting Office to:

• Maintain the effort reporting system.
• Transmit the certification data.
• Monitor the various aspects of compliance, including notification of any delinquency.
• Explain the effort reporting system and justify TC’s performance to auditors.
• Review and approve all requests for retroactive adjustments in accordance with the TC Cost Transfer Policy.

Responsible Office: Controller

Effective Date: August 31, 2016

Last Updated: September 2016