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  • Slide 1
  • Special Considerations Cost Sharing & Effort Reporting Presenters: Jennifer Camp Robert Ellington April 10, 2015
  • Slide 2
  • 2 Agenda Cost Sharing Overview Pre-Award Process Cost Share Set-up Post-Award Process Special Cost Share Procedures - Exceptions Words from a Sponsor NSF Audits of Cost Share Expenditures Summary 2
  • Slide 3
  • 3 Overview Mandatory cost sharing - required by the sponsor as a condition of the award, which must be indicated in the program announcement Voluntary cost sharing specifically pledged on a voluntary basis in the proposal budget or the Federal award on the part of the Institution Commonly in the form of contributed effort Third-party cost sharing - provided by entities outside of Georgia Tech In-kind contributions - value of non-cash contributions provided by the Institute or other third parties Examples: Tuition remission Waived overhead External contributions from third party 3 What is Cost Sharing? The portion of project costs not paid by Federal funds
  • Slide 4
  • 4 Overview 4 Sponsor Portion $250,000 Georgia Tech Portion $250,000 Total Project $500,000
  • Slide 5
  • 5 Overview 200.306 Cost sharing or matching Federal agencies must include policies relating to cost share in the notice of funding opportunity Fixed price award types cannot be used in programs which require mandatory cost sharing or matching Voluntary cost share under Federal research proposals is not expected and cannot be used as a factor during the merit review of applications or proposals All mandatory cost sharing is auditable and must be accounted for and tracked in the Institutes official accounting records Cost share expenses must generally meet the same criteria as a direct cost to the project (allowable, allocable, etc.) 5
  • Slide 6
  • 6 Pre-Award Process Office of Sponsored Programs (OSP) Policies & Procedures http://policy.research.gatech.edu http://policy.research.gatech.edu Pre-award Project Management and Proposal Development Policy 2.5 Cost Sharing Post-award Management Financial Administration Policy 4.3 Cost Sharing OSP Forms Library http://www.osp.gatech.edu/forms-library http://www.osp.gatech.edu/forms-library Cost Sharing Form - document used for any cost share commitment that will be sent to the sponsor Internal institutional support ($) not required by the sponsor; requests must be submitted to the appropriate source (e.g., School, Dean, EVPR) for approval and kept by the requesting unit Coming soon GT Tracs 6
  • Slide 7
  • 7 Pre-Award Process Mandatory cost share approvals are obtained using the Proposal Routing Form and Cost Share Approval Form Signature of an institutional official is required on the cost share form to ensure non-federal funds have been secured to meet cost share commitments 7
  • Slide 8
  • 8 Pre-Award Process Source of funds for cost sharing must be identified and approval obtained from the person with authority to commit those funds Departments should seek funding for cost sharing commitments from the School/Center or Deans Office prior to the Executive Vice president for Research (EVPR) Office If the funding source is "To Be Determined", the unit originating the proposal will be financially obligated until an allowable source is committed Third-party cost sharing must be supported at the proposal stage by obtaining written documentation from the outside entity indicating their commitment Cost Sharing Frequently Asked Questions http://grants.gatech.edu/main/wp-content/uploads/2014/03/FINAL_Cost- share-FAQ_1.pdf 8
  • Slide 9
  • 9 Cost Share Set-up Cost share funds are available to the Project Director/Principal Investigator (PD/PI) if/when the proposal results in a sponsored award Upon receipt of a sponsored award, OSP obtains a sponsored project number and a cost sharing project number from the applicable accounting department Grants & Contracts Accounting or GTRI Accounting This process establishes projects for the PD/PI and the responsible unit to charge during the project performance period Sponsored and cost share project budgets, provided by OSP to the appropriate accounting office, will be established at the funded amounts of the sponsored award and cost share obligation, respectively 9
  • Slide 10
  • 10 Cost Share Set-up It is the responsibility of the PD/PI or the unit business officer to work with the Dean s Office, EVPR Office, etc. to make committed cost share funds available from that authority's funding sources EVPR Office obligations PD/PI must submit a written request for the necessary cost share funds Generally provided through GTRC matching grants OSP provides the Office of the President a monthly management report of all outstanding cost sharing commitments associated with pending sponsored proposals 10
  • Slide 11
  • 11 OMB Uniform Requirements - 2 CFR 200 Cost share commitments are auditable and must meet the same criteria as a direct charge to an award Any expenses that cannot meet the following criteria are not eligible to be reported as cost share 1.Necessary and reasonable for proper and efficient accomplishment of project objectives 2.Allowable, allocable, reasonable, and consistently treated under applicable federal costs principles 3.Are verifiable from the official Institute accounting records 4.Are incurred during the project period of the grant or during the pre-award phase, when authorized by the sponsor 11
  • Slide 12
  • 12 OMB Uniform Requirements - 2 CFR 200 Acceptable Cost Share Criteria (Continued) 5.Documented in the approved sponsor budget 6.Are not paid by the Federal government under another award, Exception: Unless authorized by federal statute to be used for cost sharing or matching; requires additional institutional review/approval 7.May only be cost shared on one project 8.Conform to other provisions of 2 CFR 200 12
  • Slide 13
  • 13 OMB Uniform Requirements - 2 CFR 200 Facilities & Administrative (Indirect) Costs Unrecovered indirect costs Difference between the amount charged to the award and the amount of the Institutions approved negotiated F&A rate May be allowable as cost sharing expense only with the prior approval of the Federal awarding agency Values for Recipient Contributions - Services and property Must be established in accordance with the applicable cost principles See 200.434 Contributions and donations 13
  • Slide 14
  • 14 OMB Uniform Requirements - 2 CFR 200 Volunteer or Employee Services Volunteer services may be counted as cost sharing if the service is an integral and necessary part of an approved project o Professional personnel o Technical personnel o Consultants o Other skilled labor o Unskilled labor Rates for volunteer services must be consistent with those paid for similar work in the recipients organization Volunteer services shall be documented and supported by the same methods used by the recipient for its own employees Documented after-the-fact (Hours, Date, Rate) and certified 14
  • Slide 15
  • 15 OMB Uniform Requirements - 2 CFR 200 Third Party Donations Assessed value of donated property must not exceed fair market value at the time of donation o Expendable equipment o Office supplies o Laboratory supplies o Workshop supplies o Classroom supplies o Buildings o Land 15
  • Slide 16
  • 16 OMB Uniform Requirements - 2 CFR 200 Voluntary Committed Cost Sharing Not expected under Federal research proposals Cannot be used as a factor during the merit review of applications or proposals Beware of expressions of support in budget narratives and scope of work that are not included in the budget $ Dont say it if you dont really mean it! 16
  • Slide 17
  • 17 Post-Award Process Office of Grants & Contracts (G&C) Accounting o Policy 3.9 Cost Share Expenses http://grants.gatech.edu/main/policies-procedures-and-forms/policies-and- procedures/ o Notice 08-II Cost Share Certification http://grants.gatech.edu/main/policies-procedures-and-forms/manuals-and- notices/ G&C Forms o Cost Share Certification Form - document throughout the life of the award; preferably by semester http://grants.gatech.edu/main/policies-procedures-and-forms/standard- forms/ o Delayed cost share certification requests will follow the late cost transfer review process 17
  • Slide 18
  • 18 Post-Award Process The PD/PI and unit business officer must identify appropriate charges to be applied against cost share projects throughout the life of a sponsored award All required cost share obligations must be met and properly documented in the Institute accounting system before projects can be financially closed Delays can result in delayed financial reporting, billing, and/or collections Failure to meet the cost share obligation can result in loss of sponsor funding 18
  • Slide 19
  • 19 Post-Award Process Managing Cost Share Projects in the GM System: Cost Sharing Projects Specific projects must be assigned or identified (GTF, GTRC, etc.) to account for mandatory cost sharing expenditures required on a specific sponsored project At project initiation, OSP identifies the amount of the cost sharing obligation for each agreement A separate project number is established to account for the expenditures as they are incurred during the performance of the sponsored activities Occasionally other cost sharing projects are established to provide additional or alternate funding for cost sharing expenditures Identify these projects to the G&C Project Accountants 19
  • Slide 20
  • 20 Post-Award Process Other (Unlinked) Cost Share Occasionally expenditures made from other projects (projects not specifically identified as cost sharing projects) may be allowable to meet the required cost share obligations This type of activity does not meet the Institute requirements for separately budgeted and accounted for expenditures, it can be recognized to meet cost sharing requirements if it is properly documented and supported. When this occurs, the following steps must be taken: a)If possible, a separate project should be established that is identified as a cost sharing project for the sponsored agreement b)Costs should be moved to that project by cost transfer 20
  • Slide 21
  • 21 Post-Award Process Other (Unlinked) Cost Share (continued) c)If the costs were incurred in a prior year on a state funded project: o Costs to be recognized as cost sharing must be documented on a separate schedule supported by project ledgers that identify the specific charges to be recognized o Additional approvals required (see Late Cost Transfer Policy) o A written certification statement must be prepared and signed by the PD/PI indicating that the cost share expenditures identified: 1.Were incurred on behalf of the sponsored agreement 2.Meet the cost sharing requirements stated in the sponsored agreement 3.Have not been claimed as direct charges or cost sharing on any other sponsored project 21
  • Slide 22
  • 22 Post-Award Process Facilities & Administrative (F&A) Charges State Cost Sharing Projects Unless there is restriction in the sponsored agreement that precludes recognition of F&A charges on cost sharing expenditures, G&C will recognize F&A charges on cost sharing projects at the applicable F&A rate Charges will be recorded in the G&C Accounting System records and will be reported on the PEB Facilities & Administrative (F&A) Charges - GTF or GTRC Projects GM System does not charge F&A costs to projects funded by GTF or GTRC G&C will recognize F&A charges on cost sharing expenditures made with these funds for reporting purposes unless there is a restriction in the sponsored agreement that precludes recognition of F&A charges on cost sharing 22
  • Slide 23
  • 23 Post-Award Process Initiating Cost Share Budgets Budgets will be entered as funding is provided State funded budgets are established by the Unit Financial Manager and Budget Office GTRC funded cost share budgets are established by G&C/GTRI Accounting upon notification from the Office of the Provost Financial Administration 23
  • Slide 24
  • 24 Post-Award Process Reported on OSP Project Header 24
  • Slide 25
  • 25 Post-Award Process
  • Slide 26
  • 26 Post-Award Process PEB Report- Cost Share Summary Includes ALL related/linked cost share projects Cost Share Obligation Reported in Demographic Section 26
  • Slide 27
  • 27 GM PEB Post-Award Process
  • Slide 28
  • 28 Special Cost Share Procedures - Exceptions In-Kind Cost Share Certification Required for Third Party Cost Share Expense Required for Donated Services or Facilities Recorded in GM System as Other Memo In-Kind Cost Share Tuition Remission Requires Specific Sponsor Approval Accounting for In-Kind Tuition Remission Recorded in GM System as Other Memo 28
  • Slide 29
  • 29 Special Cost Share Procedures - Exceptions Sample Certification Letter Certifications from 3 rd party entities (i.e., sub-awardees) Certifications Required by Sponsors Accounting system support must be attached Additional approvals are required if >120 day from original posting date 29
  • Slide 30
  • 30 Special Cost Share Procedures - Exceptions Accounting for In-Kind Tuition Remission The Institute currently has no accounting system to document the amount of tuition waivers on state-funded cost sharing projects In accordance with federal regulations, cost sharing expenditures must meet the same requirement as direct cost Certain sponsors may recognize the cost of tuition waivers as in-kind cost sharing when the amount of the waivers is properly documented and reported to the sponsor This type of in-kind cost sharing must be fully documented in the project proposal and budget 30
  • Slide 31
  • 31 Special Cost Share Procedures Exceptions Accounting For In-Kind Tuition Remission *Coming Soon Automated Tuition Waiver Cost Share Form 31
  • Slide 32
  • 32 Special Cost Share Procedures Other Considerations Institute 1% Minimum Effort Policy See OSP Policy 2.1.6 with training video NIH salary cap for faculty NIH cap for graduate student salaries NSF 2/9 Rule 32
  • Slide 33
  • 33 Special Cost Share Procedures Exceptions 33 Cost Share vs. Fund Spend Pattern Report http://grants.gatech.edu/main/reports-and-documents/campus-reports/
  • Slide 34
  • 34 Special Cost Share Procedures Exceptions 34
  • Slide 35
  • 35 Special Cost Share Procedures Exceptions 35
  • Slide 36
  • 36 Audits of Cost Share Expenditures Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule (2 CFR 200) Subpart F: Audit Requirements Allowable Costs - Test of Expenditures Verifiable from Institute Financial Records Tests of In-Kind Cost Share Documentation Audit Test Procedures Allowable costs Allowable Funding Source 36
  • Slide 37
  • 37 Summary Cost share obligations identified by OSP at the time of the acceptance of a new award Separate projects are established for each cost share obligation and fund source Cost share project budgets represent available funds State cost share budgets set by Budget Office GTRC funded cost share budgets set by G&C Accounting (as approved) 37
  • Slide 38
  • 38 Summary Cost share obligations are presented on PEB Cost share obligations must be met to avoid adjustments to direct cost expenditures Cost share obligations must be recorded in Institute official accounting records Special procedures may require additional work for the Unit Financial Managers 38
  • Slide 39
  • 39 Questions Contact: [email protected]@business.gatech.edu OR Jennifer Camp 404-894-5526 [email protected] 39
  • Slide 40
  • Services Reporting Using the Plan Confirmation System (PCS)l Services Reporting Using the Plan Confirmation System (PCS) Personal Services Reporting Using the Plan Confirmation System
  • Slide 41
  • 41 Personal Services Reporting Using the Plan Confirmation System Why Personal Services Reporting (aka: Effort Reporting) OMB Uniform Administrative Requirements Plan-Confirmation System: Professorial and Professional Employees, Graduate Students After-the-Fact Activity RecordsNon-Professional Employees (Hourly) Salary Planning and Distribution (SPD) System SPD Center Electronic Workload Assignment Form (EWAF) Departmental Responsibilities Related to the Plan Confirmation System Process Annual Statement of Reasonableness (ASR) of Salary Charges and Signatory Certification Requirements Employee Responsibilities SPD Redistributions NIH Salary Cap NSF 2/9ths Salary Limitation Level of Commitment 41 Plan Confirmation System
  • Slide 42
  • 42 Overview As a major research university that manages over 3,500 sponsored agreements (>6,000 Non-GTRI Projects), Georgia Institute of Technology must have: Financial systems and procedures in place to assure compliance with the terms and conditions of the agreements as well as with State and Federal regulations concerning sponsored programs. The distribution of salary and fringe benefits charged to sponsored programs is the majority of project expenditures and therefore a very important process. 42 Plan Confirmation System
  • Slide 43
  • 43 Background The Federal Government's Office of Management and Budget (OMB) Uniform Administrative Requirements Establishes principles for determining costs applicable to grants, contracts, and other agreements between Federal agencies and educational institutions. All Federal agencies that sponsor research and development, training, and other work at educational institutions must apply the provisions of the Uniform Requirements in determining the costs incurred for such work. 43 Plan Confirmation System
  • Slide 44
  • 44 OMB Uniform Administrative Requirements The Federal Government's Office of Management and Budget (OMB) Uniform Administrative Requirements The provisions of OMB Uniform Requirements apply to all units of Georgia Tech other than the Georgia Tech Research Institute. Employees of Georgia Tech Research Institute utilize hourly time sheet procedures designed to comply with Federal Acquisition Regulations 31.2, which have different requirements for the documentation of personal services expenses. The GTRI Policies & Procedures Manual includes specific instructions for GTRI time sheet preparation and time reporting. 44 Plan Confirmation System
  • Slide 45
  • 45 OMB Uniform Administrative Requirements OMB Uniform Administrative Requirements: Details Standards of Documentation for Compensation- Personal Services Georgia Tech uses: The Plan Confirmation System for Professorial and Professional Employees, and Graduate Students. The After-the-Fact Activity Records System for Non- Professional Employees (Timesheets). 45 Plan Confirmation System
  • Slide 46
  • 46 Plan-Confirmation System Under this method, the distribution of salaries and wages of professorial and professional staff applicable to sponsored agreements is based on budgeted, planned, or assigned work activity, updated to reflect any significant changes in work distribution. 46 Plan Confirmation System
  • Slide 47
  • 47 Plan Confirmation System & OMB Uniform Requirements OMB Uniform Requirements A plan-confirmation system used for salaries and wages charged directly or indirectly to sponsored agreements will meet the following Standards of Documentation: 200.430(i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect work performed. 47 Plan Confirmation System
  • Slide 48
  • 48 Plan Confirmation System & OMB Uniform Requirements OMB Uniform Requirements 200.430(i)(1)(i) Be supported by a system of Internal Control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. 200.430(i)(1)(ii) Be incorporated into the official records of the non-Federal entity. 48 Plan Confirmation System
  • Slide 49
  • 49 Plan Confirmation System & OMB Uniform Requirements OMB Uniform Requirements 200.430(i)(1)(iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity not exceeding 100% of compensation. 200.430(i)(1)(iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis. 200.430(i)(1)(v) Comply with established accounting policies and practices of the non-Federal entity. 49 Plan Confirmation System
  • Slide 50
  • 50 Plan Confirmation System & OMB Uniform Requirements OMB Uniform Requirements 200.430(i)(1)(vii) Support the distribution of the employees salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and direct cost activity; two or more indirect activities; etc. 50 Plan Confirmation System
  • Slide 51
  • 51 Employees Covered by the Plan-Confirmation System Professorial and Professional Staff The Georgia Tech Plan-Confirmation System covers all professorial and professional staff employees who meet the following requirements at any time during the fiscal year: 1.All academic personnel paid monthly whose activities are distributed to either one or more organized research projects, other sponsored agreements, or cost-sharing projects. 2.All other monthly paid personnel whose: a)Activities are distributed directly either to one or more organized research projects, other sponsored agreements, or cost-sharing projects. b)Distribute their activities to one or more indirect (Facilities and Administrative) activity. c)Split their effort between direct and indirect (Facilities and Administrative) activities. d)Have any or all of their effort distributed to Departmental AdministrationInstruction, Departmental Administration-Research and/or Other Sponsored Agreements. 51 Plan Confirmation System
  • Slide 52
  • 52 Employees Covered by the Plan-Confirmation System Monthly Paid Graduate Students Graduate Student Employees- Covered The Plan-Confirmation System is used as the basis for its distribution of salaries and wages for all appointed graduate students who are paid on a monthly basis from sponsored, cost-sharing, general research and departmental administration accounts. Graduate Student Employees Not Covered Hourly Paid Graduate Students Graduate students who are paid on an hourly basis shall report their time worked on bi- weekly time documents. 52 Plan Confirmation System
  • Slide 53
  • 53 After-the-Fact Activity Records Non-Professional Employees Georgia Tech uses the After-the-Fact Activity Records system for non- professional employees. OMB Uniform Requirements states: Charges for salaries and wages of nonexempt employees, must be supported by records indicating the total number of hours worked each day. The use of time documents, as prescribed under current Georgia Institute of Technology payroll procedures, meets the requirements of OMB Uniform Requirements for non-professional employees, and no additional activity reporting is necessary for the non-professional employees. 53 Plan Confirmation System
  • Slide 54
  • 54 The Salary Planning and Distribution (SPD) System Features Feature List Manages distribution of salary charges to projects Accepts Payroll System Transactions Accepts Changes Made by Campus units Manages Distribution of Fringe Benefit charges Manages Distribution of tuition remission (GSTRP) charges Identifies Employees Covered By the Plan Confirmation System. Provides detailed salary distribution data for all employees and generates required monthly allocation and annual effort reports. 54 Plan Confirmation System
  • Slide 55
  • 55 The Salary Planning and Distribution (SPD) Center in Grants and Contracts Accounting Manages the SPD System and schedules processes. Manages the Personal Services Reporting (PSR)Tutorial Plan Confirmation System online WEB training. Alternative training - distributes copies of the Personal Services Reporting using the Plan-Confirmation System booklet to Plan employees. Maintains the records of employees who have completed the PSR Tutorial or Acknowledgement Form. Manages the eASR system and manual certified Annual Statements of Reasonableness (Employee and UFO Signs) for each Fiscal Year Provides Plan Confirmation System and SPD System Training. 55 Plan Confirmation System
  • Slide 56
  • 56 Plan-Confirmation System Training Personal Services Reporting Tutorial and Confirmation OHR TRAINS Web based training. Video, questionnaire, and confirmation statement. http://grants.gatech.edu/spdPSR_Training.php http://grants.gatech.edu/spdPSR_Training.php Personal Services Reporting Using the Plan Confirmation System Booklet (alternative training) Read and sign Acknowledgement Form Other Training Available on Web TechWorks/ Refresher Training Demo on EWAF and EASR application logon pages 56 Plan Confirmation System
  • Slide 57
  • 57 What is EWAF? Electronic Workload Assignment Form Beginning in FY2005, the SPD Center sends monthly email notifications to all Covered Employees. The email notification provides instructions about the Workload Assignment Form and provides an encrypted web link to their EWAF report to print, review, and retain a copy of for the current fiscal year. EWAF has an Alert when personal services allocations have been updated in the current month. 57 Plan Confirmation System
  • Slide 58
  • 58 Electronic Workload Assignment Form 58 Plan Confirmation System
  • Slide 59
  • 59 Reviewing EWAF Using TechWorks EWAF is also available on TechWorks Same System used for Employee Self Service Select Electronic Workload Assignment Form Use GaTech Staff ID and Password Feature is available for all employees Covered Employees receive EWAF Other Employees receive monthly breakdown of salary 59 Plan Confirmation System
  • Slide 60
  • 60 What do Departments need to do to help? Help Employees gain access to EWAF Valid email address in Campus Directory for email notification. Access EWAF on Techworks. Make sure employees know the projects they are working on each month. Remind employees to make TIMELY changes when required If employees identify a problem or the need to change past or future salary distributions: Click on a Report a Change or Issue button at bottom of Web report. It will produce an email with the subject line pre-worded to indicate: SPD Salary Distribution Change Needed per Workload Assignment Form Review. Enter the email address for the appropriate PI or unit business officer to be notified and your return address would be pre-populated. In the body of the email, explain what needs to be changed on your past or future salary distribution. 60 Plan Confirmation System
  • Slide 61
  • 61 Report A Change or Issue 61 Plan Confirmation System
  • Slide 62
  • 62 Electronic Annual Statement of Reasonableness 62 ASR Signature Certification GA Techs annual effort certification. Email Notification to employee. Electronically signed/dated by employee. Electronically certified/dated by Unit Financial Manager. Deadline date, usually 8/31. Plan Confirmation System
  • Slide 63
  • 63 Manual Annual Statement of Reasonableness 63 ASR Signature Certification GA Techs annual effort certification alternative. Signed and dated by Employee and UFO. Exception basis certified by person with first hand knowledge. Indicate any Dept Admin activities. Return by deadline date, usually 8/31. Plan Confirmation System
  • Slide 64
  • 64 Key points for Covered Employees to remember 1. Complete the Personal Services Reporting OHR TRAINS tutorial and confirmation. 2. Alternate: read the Personal Services Reporting Using the Plan-Confirmation System Booklet and complete & return the Acknowledgement Form 3. Review and retain Electronic Workload Assignment Forms (EWAF) 4. Report any changes to Supervisor or Unit Financial Manager Timely 5. Confirm the Annual Statement of Reasonableness of Salary Distribution. 64 Plan Confirmation System
  • Slide 65
  • 65 SPD Redistributions SStarting in FY10 all redistributions to externally funded sponsored projects require electronic justification in the SPD system. OOver 120 Day redistributions: EEffective November 1, 2007 salary distributions to externally funded sponsored projects are not allowed over 120 days from date of payment. EExclusions are to same fund transfers, GTF, or GTRC projects. SSpecial request for over 120 redistributions has to be approved by Director of G&C, Assoc VP of Finance, and Assoc Vice Provost for Research. BBeginning FY2016, the 120 Days limitation reduces to 90 days to comply with the new OMB Uniform Requirements. 65 Plan Confirmation System
  • Slide 66
  • 66 NIH Salary Cap (G&C Notice 14-II) All NIH/DHHS Grants, Contracts, and Cooperative Agreements (including flow- thru awards from other Institutions) are subject to the NIH Salary Cap. Congress limits the amount of compensation an individual can receive under an NIH Award. The limitation is equal to the Federal Executive Level II pay scale on awards issued after 12/22/2011, which is updated yearly. Amounts over the cap should be accounted for in a companion cost-sharing project if possible . Amounts over the cap may not be counted as mandatory cost share and must be separately tracked and certified Example: PI Monthly Salary is $18,000, NIH Cap is $14,975 75% Effort devoted to NIH Grant (75% * $18,000) = $13,500 Maximum that can be direct charged (75% of cap) = $11,231 Charge difference of $2,269 to a companion cost-sharing project linked in the Grants system to the specific NIH sponsored fund/project Why? So that the salary cap adjustment and the actual project effort are visible in the accounting system. 66 Plan Confirmation System
  • Slide 67
  • 67 Personal Services Reporting Using the Plan Confirmation System G&C Notice 14-II 67 Plan Confirmation System
  • Slide 68
  • 68 NSF 2/9ths Rule Salary Limitation(G&C Notice 09- III) NSF 2/9ths Rule Salary Limitation(G&C Notice 09-III) The National Science Foundation limits the amount of compensation on senior personnel that can be charged to NSF funded projects, including flow-thru awards from other Institutions during a fiscal year. Total compensation cannot exceed two months (2/9ths) of an employees base, academic year salary. The limit applies to total salaries charged to ALL NSF funded projects combined for that employee. 68 Plan Confirmation System
  • Slide 69
  • 69 NSF 2/9ths Rule Salary Limitation(G&C Notice 09- III) 69 Plan Confirmation System
  • Slide 70
  • 70 Level of Commitment. Actual effort percentages (per ASR) for key personnel should not be significantly less than the committed effort level (per proposals). Significant reductions require agency notification and approval. PIs/ Unit Financial Officers need to monitor Level of Commitment for their sponsored projects ( especially prior to year end close for correct ASRs). 70 Plan Confirmation System
  • Slide 71
  • 71 Personal Services Reporting Using the Plan Confirmation System Questions? 71 Plan Confirmation System
  • Slide 72
  • 72 Personal Services Reporting Using the Plan Confirmation System - Q&A Questions & Answers? 72 Plan Confirmation System
  • Slide 73
  • 73 Personal Services Reporting Using the Plan Confirmation System - Q&A 1. Plan Confirmation System The Plan Confirmation System is used to support the salary distribution for all employees on campus except for: a. Faculty members with only one sponsored project. b. GTRI employees performing research activities. c. Graduate Research Assistants performing sponsored research d. Office of Sponsored Program employee 73 Plan Confirmation System
  • Slide 74
  • 74 Personal Services Reporting Using the Plan Confirmation System - Q&A 2. Electronic Workload Assignment Form If an employee providing services on a sponsored research project does not receive an Electronic Workload Assignment Form email notification, they should: a. Wait until next month to see if one arrives. b. Contact the Unit Financial Officer to obtain a copy of the Form. c. Go to TechWorks and log on thru Electronic Workload Assignment Form link to produce report. d. Contact Unit Financial Officer or SPD Center that you are not receiving the EWAF email notifications. e. Forget about it, since it is not important. 74 Plan Confirmation System
  • Slide 75
  • 75 Personal Services Reporting Using the Plan Confirmation System - Q&A 3. Electronic Workload Assignment Form An employee covered by the Plan Confirmation System is to: a. Review Electronic Workload Assignment Forms and discard if no changes are required. b. Review Electronic Workload Assignment Forms upon receipt and report any changes to the Unit Financial Officer. c. Review Electronic Workload Assignment Forms upon receipt and report any changes to the Unit Financial Officer, and keep Forms on file for the year. d. Review Electronic Workload Assignment Forms each semester for possible changes. 75 Plan Confirmation System
  • Slide 76
  • 76 Personal Services Reporting Using the Plan Confirmation System - Q&A 4. Salary Planning and Distribution (SPD) System The SPD system is designed to make changes to an employees' salary distribution: a. Once each month. b. As often as needed throughout the month. c. Only when a new sponsored project is received. d. At the beginning of each semester. 76 Plan Confirmation System
  • Slide 77
  • 77 Personal Services Reporting Using the Plan Confirmation System - Q&A 5. Annual Statement of Reasonableness of Salary Charges The Annual Statement of Reasonableness of Salary Charges (ASR) is to be signed by: a. The Department Head b. The Project Director c. The employee and the Unit Financial Officer d. The Unit Financial Officer 77 Plan Confirmation System
  • Slide 78
  • 78 Personal Services Reporting Using the Plan Confirmation System THANK YOU FOR ATTENDING 78 Contact: [email protected] [email protected] Robert Ellington, 404-894-3488 [email protected] Plan Confirmation System