Payroll Certification on Federally Sponsored Projects
University Policy Number 4015
Related Law & Policy:
- Policy 4006: Sponsored Programs Administration
- Policy 4005: Cost Transfer Policy
- Policy 2108: Direct and Indirect Costs Allocations Under OMB Uniform Guidance
- Policy 2114: Reconciling Departmental and Sponsored Fund Accounting Records
This policy applies to all employees of the University, including hourly employees, part-time employees, adjunct faculty, and students on the University payroll who are working on federally sponsored projects.
Charges or cost sharing for personal services on all federal projects for research, training, and service must produce an equitable distribution of charges for an employee’s activities and be documented in a method acceptable under Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (OMB Uniform Guidance).
The payroll distribution system reflects salary and wage costs of sponsored project accounts and cost sharing expressed as a percentage of total activities not to exceed 100%. The apportionment of employees’ salaries and wages which are chargeable to sponsored agreements or identified as committed cost sharing is initiated by the principal investigator or designee using the appropriate University personnel services authorization format. All charges and cost sharing for personal services are based on actual salary charges posted in the accounting system and are supported by documentation such as employment contracts, supplemental appointment letters, and other written guidance.
Individuals whose payroll is charged or whose effort is identified as committed cost sharing on projects must have worked on the project and be documented in the University financial system using the activity code, the charges must be reasonable in relation to work performed, and charges must be in compliance with special costing requirements (e.g., clerical and administrative salaries charged meet federal exception criteria; no non-sponsored activities, such as instruction, department committees, proposal preparation time charged to the project). The university’s payroll certification method has been approved by its federal cognizant agency, the Office of Naval Research.
Principal Investigator (PI)
The PI is responsible for reviewing charges and committed cost sharing for personal services annually and certifying that all individuals worked on the project, salary or wage charges were reasonable in relation to work performed, and special costing requirements were met. Certifications will be distributed annually based on the project budget anniversary or project end date. PIs must return certifications to the Office of Sponsored Programs within 45 days of distribution.
These individuals are responsible for reviewing and certifying to personnel charges and committed cost sharing for which they have direct responsibility and knowledge at the request of the PI.
Research Faculty, Graduate Research Assistants and Other Employees
These individuals are responsible for reviewing personnel charges and committed cost sharing for which they have direct knowledge at the request of the PI to inform PI certification.
Payroll Certification Liaison
Academic unit administrator responsible for receiving, distributing and collecting payroll certification reports for projects within their unit. OSP will work closely with this individual to ensure the reporting process works smoothly and reports are certified within the required timeframe.
Dean or Dean Designee
This individual will receive notification if payroll certification reports are not returned to OSP within 45 days of distribution. If the certified report is not received within 15 days of the Dean or Dean Designee notification date the salary charges will be moved to a Facilities and Administrative (F&A or indirect) or pool organization code within the PI’s unit.
The Office of Sponsored Programs (OSP) is responsible for generating payroll certification statements within 75 days of the end of the certification period. Payroll certification statements are generated for each project annually based on the start month of the project or project end date, whichever is sooner. OSP is responsible for providing certification statements to the individual(s) designated by the school or college to receive and obtain payroll certifications.
Signed payroll certification reports must be received by OSP within 60 days of the date distributed from OSP to the Payroll Certification Liaison. If OSP does not receive a signed certification within 45 days of the distribution date, a reminder is sent to the PI and Dean or designee. If the certification is not received within 15 days after contacting the Dean or designee, the payroll charges are moved from the sponsored fund code to the PI’s F&A recovery organization code. If the budget is insufficient, charges are moved to the PI’s pool organization code, then to the department chair’s F&A recovery or pool organization code, and finally to the dean’s F&A or pool organization code.
See Policy 4015 Summary for a table summarizing this policy.
V. EFFECTIVE DATE AND APPROVAL
This policy is effective January 1, 2011 and shall be reviewed and revised, if necessary, annually, with changes to become effective at the beginning of the University’s fiscal year, unless otherwise noted.
Maurice W. Scherrens
Senior Vice President
Peter N. Stearns
Date approved: March 14, 2011
Revised: August 21, 2015, effective immediately