grants & contract accounting & osp all rights reserved gtrc special considerations – cost...
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Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
October 23, 2012
Presenters:
Sandy Mason
Robert Ellington
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Introduction …..
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Sponsor Portion $250,000
Georgia Tech Portion $250,000
Total Project
$500,000
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Overview
I. Office of Sponsored Programs - PoliciesII. OMB Circular A-110 Cost Sharing or MatchingIII. Managing Cost Share Projects in the GM
SystemIV. Special Cost Share ProceduresV. Words from a Sponsor – NSFVI. Audits of Cost Share
ExpendituresVII. Discussion Summary
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Special Considerations – Cost Sharing and Effort Reporting
I. Office of Sponsored Programs – Policies
Georgia Institute of Technology
Office of Sponsored Programs
Policies & Procedures Manual
POLICIES AND PROCEDURES
Project Management: 5.0
Subject: Cost Sharing
http://www.osp.gatech.edu/
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Special Considerations – Cost Sharing and Effort Reporting
I. Office of Sponsored Programs – Policies1. Whenever cost sharing is proposed as
part of a sponsored project, the source of funds must be identified and approval obtained from the person with authority to commit those funds.
2. If the source is identified as "To Be Determined", the funds from the unit originating the proposal are obligated until an actual source is committed prior to the time of award.
3. Funds to be provided by entities outside of Georgia Tech, typically referred to as “third-party” cost sharing, must be supported at the proposal stage by written documentation from the outside entity indicating their commitment to provide cost sharing.
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Special Considerations – Cost Sharing and Effort Reporting
I. Office of Sponsored Programs – Policies4. Cost sharing funds are actually made
available to the Project Director/Principal Investigator (PD/PI) when/if the proposal results in a sponsored award.
5. Cost sharing approvals are obtained by way of the Proposal Routing Form and a Cost Sharing Approval Form.
6. The Office of Sponsored Programs (OSP) furnishes a management report of all outstanding cost sharing commitments associated with pending sponsored proposals to the Office of the President on a monthly basis.
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Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
I. Office of Sponsored Programs – Policies7. Upon receipt of a sponsored award,
OSP obtains a sponsored project number and a cost sharing project number from either Grants & Contracts Accounting or GTRI Accounting, as appropriate.
8. This process opens chargeable projects for the PD/PI and the responsible unit to use during the course of the project.
9. The sponsored and cost sharing project budgets, provided by OSP to the appropriate accounting office, will be valued at the funded amount of the sponsored award and at the associated amount of committed cost sharing respectively.
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Special Considerations – Cost Sharing and Effort Reporting
I. Office of Sponsored Programs – Policies10. It is the responsibility of the PD/PI or the
unit business officer to work with appropriate personnel in the Dean’s Office or President’s Office to make available committed cost sharing funds from that authority's sources.
11. In the case of a President's Office obligation, the PD/PI must submit a written request for the necessary cost sharing funds which are generally provided by way of GTRC Matching Grants.
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Special Considerations – Cost Sharing and Effort Reporting
I. Office of Sponsored Programs – Policies12. It is important that the PD/PI and
his/her unit business officer identify appropriate charges to be applied against cost sharing projects throughout the life of a sponsored award.
13. All required cost sharing obligations must be met and properly documented in the Institute accounting system before the projects can be financially closed out.
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
Acceptable CostsC23a: All contributions, including cash and third party in-kind, shall be
accepted as part of the recipient’s cost sharing or matching when such contributions meet all of the following criteria:(1) Are verifiable from the recipient's records.(2) Are not included as contributions for any other federally-assisted project or program.(3) Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.(4) Are allowable under the applicable cost principles.
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
Acceptable Costs (Continued)(5) Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.(6) Are provided for in the approved budget when required by the Federal awarding agency.(7) Conform to other provisions of this Circular, as applicable.
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
Facilities & Administrative (Indirect) Costs
C23b: Unrecovered indirect costs may be included as part of
cost sharing or matching only with the prior approval of the
Federal awarding agency.
Allowable for Recorded Expenditures
Values for Recipient Contributions
C23c: Values for recipient contributions of services and
property shall be established in accordance with the applicable
cost principles.
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
Services by Volunteer or Employee Services
C23h(5i). 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
Volunteer or Employee Services
C23d: Volunteer services furnished by professional and technical
personnel… and other skilled and unskilled labor may be counted as
cost sharing if the service is an integral and necessary part of an
approved project.
Rates for volunteer services shall be consistent with those paid for
similar work in the recipient’s organization.
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
Volunteer or Employee Services (continued)
If the required skills are not found in the recipient organization,
rates shall be consistent with those paid for similar work in the labor
market in which the recipient competes for the kind of services
involved. In either case, paid fringe benefits that are reasonable,
allowable, and allocable may be included.
C23e: When an employer other than the recipient furnishes the
services of an employee, these services shall be valued at the
employee’s regular rate of pay (plus fringe benefits that are
reasonable, allowable, and allocable), provided these services are
in the same skill for which the employee is normally paid.
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
Donated Supplies
C23f: Donated supplies may include such items as expendable
equipment, office supplies, laboratory supplies or workshop
and classroom supplies. Value assessed to donated supplies
included in the cost sharing share shall be reasonable and shall
not exceed the fair market value of the property at the time of
the donation.
Donated Equipment, Buildings, and Land
23h: The value of donated property shall be determined in
accordance with the usual accounting policies of the recipient…
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
Determining the Value of Donated Property
Basis: “Fair Market Value”
Must be documented and certified
C23h(1). The value of donated land and buildings shall
not exceed its fair market value at the time of donation to the
recipient as established by an independent appraiser (e.g.,
certified real property appraiser or General Services
Administration representative) and certified by a responsible
official of the recipient.
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Special Considerations – Cost Sharing and Effort Reporting
II. OMB Circular A-110 Cost Sharing or Matching
* Voluntary Cost Share in proposal becomes mandatory in award
“Don’t say it if you don’t really mean it!”
* Beware of expressions of support in budget narratives and work-scope that are not included in the budget figures
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
Cost Sharing ProjectsInstitute procedures for cost sharing provide for the identification of specific projects to account for cost sharing expenditures required for sponsored projects.
At project initiation, OSP identifies the amount of the cost sharing obligation for each agreement and a separate Project is established to account for the expenditures as they are made during the performance of the sponsored activities.
Occasionally other cost sharing projects are established to provide additional or alternate funding for cost sharing expenditures and these projects need to be identified to the G&C Project Accountants as they are established. This is necessary to assure proper accounting and reporting.
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
Other (“un-linked”) Cost Sharing Expenditures• Occasionally expenditures made from other projects (projects not
specifically identified as cost sharing projects) are to be recognized to meet the required cost share obligations.
• Although 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, and the costs should be moved to that project by cost transfer.
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
Other (“un-linked”) Cost Sharing Expenditures (Continued)
b) If the costs were incurred in a prior year and/or time does not permit the creation of a separate sponsored project:o The costs to be recognized as cost sharing should be
documented on a separate schedule supported by project ledgers that identify the specific charges to be recognized.
o A written certification statement should be prepared and signed by the Project Director indicating that the expenditures identified on the cost sharing schedule (Sample provided in Section IV):
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.
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
Facilities & Administrative (F&A) Charges – State Cost Sharing Projects
Unless there is a specific restriction contained in the sponsored agreement that precludes recognition of F&A charges on cost sharing expenditures, G&C Accounting will recognize F&A charges on cost sharing projects at the current approved rate for that activity.
These charges will be recorded in the G&C Accounting System records and will be reported on the WEB PEB.
Facilities & Administrative (F&A) Charges - GTF or GTRC Projects The GM System does not charge F&A costs to projects funded by GTF
or GTRC G&C Accounting will recognize F&A charges on cost sharing
expenditures made with these funds for reporting purposes, unless there is a specific restriction contained in the sponsored agreement that precludes recognition of F&A charges on cost sharing.
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
OSP Identifies Cost Share Obligation at time of Award
Obligation may cover several yearsSpecific Projects are Established to Account
for and Report all Cost Share Expenditures Initial Cost Share Project Numbers are Assigned to Unit
Budgets are Established when Funding is Provided
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
Additional Projects can be Assigned for Other Funding Sources
GTRC or Other Outside Fund SourcesAll Cost Share Projects Linked to Main Project
Cost Share Obligations are Presented in PEB
Demographic Section
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
Initiating Cost Share Budgets Budgets to be Entered as Funding is Provided State Funded Budgets are to be established by
Unit Financial Manager and Budget Office GTRC Funded Cost Share Budgets are
Established by G&C /GTRI Accounting upon Receipt of Notification from the Office of the Provost Financial Administration
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System
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Calculating The Amount of Funding Required (Examples)
Cost Share Requirement 50,000$ 50,000$ 50,000$
Expenses
Salaries 20,000$ -$ 10,000$
Fringe Benefits 4,800 - 2,500
M & S 8,313 - 12,000
Equipment - 50,000 13,005
Total Direct 33,113$ 50,000$ 37,505$
Recognized F&A (at 51.0%) 16,887$ -$ 12,495$ Total Cost Share Recognized 50,000$ 50,000$ 50,000$
State Funding Required 33,113$ 50,000$ 37,505$
(A) (B) (C)
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System – Summary
Reported on OSP Project Header
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System – Summary
PEB Report – Sponsored Summary Includes ALL related
sponsored projects and
sub-projects
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Project Summaries
Prime Project ID displayed as BOLD
Project ID (Rpt link)
Award Pj St Project Expire
Date Type Sponsor Name PI Name Project Title LTD Budget LTD Expend
LTD Encumber
LTD Balance
21013xx (Cmpl) (Sumry)
Rxxxx A 08/31/12 CSHR US DEPT OF
ENERGY ARRA: 96,122.31 96,122.31 0.00 0.00
2106XXX (Cmpl) (Sumry)
Rxxxx A 12/31/12 SPSD US DEPT OF
ENERGY ARRA: 458,707.00 427,057.11 29,797.26 1,852.63
2106XX1 (Cmpl) (Sumry)
Rxxxx A 08/31/12 CSHR GTRC
MATCHING
GTRC MATCHING PROJECT
25,000.00 25,000.00 0.00 0.00
2166XX2 (Cmpl) (Sumry)
Rxxxx A 12/31/12 SPSD US DEPT OF
ENERGY ARRA: 79,704.00 68,914.66 3,303.48 7,485.86
2506XXX (Cmpl) (Sumry)
Rxxxx A 12/31/12 SPSD US DEPT OF
ENERGY ARRA: 460,208.00 399,843.97 47,025.94 13,338.09
25013xx (Cmpl) (Sumry)
Rxxxx A 08/31/12 CSHR US DEPT OF
ENERGY ARRA: 18,433.69 18,433.69 0.00 0.00
(Rpt link): Cmpl = Complete, Sumry = Summary Pj St (Project Status): A = Active, I = Inactive
Type: SPSD = Sponsored Project, CSHR = Cost Share Project
Award Fund Summaries
Complete Report Award/Fund Summary Cost Share Summary Sponsored Summary
GEORGIA Institute of TECHnology
Project Expense and Budget Report Award Fund: RXXXX
Setid: GT FY 2013 / Period 4
Project Status: All Projects Sponsored/CostShare: All Projects
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Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System – Summary
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
III. Managing Cost Share Projects in the GM System – Summary
PEB Report- Cost Share Summary Includes ALL
related/linked cost share projects
Cost Share Obligation Reported in Demographic Section
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Special Considerations – Cost Sharing and Effort Reporting
GM PEB
III. Managing Cost Share Projects in the GM System – Summary
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
IV. Special Cost Share Procedures - Exceptions
In-Kind Cost Share CertificationRequired for Third Party Cost Share ExpenseRequired for Donated Services or FacilitiesRecorded in GIT GM System as “Other Memo”
In-Kind Cost Share Tuition RemissionRequires Specific Sponsor Approval Accounting For In-Kind Tuition RemissionRecorded in GIT GM System as “Other Memo”
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Special Considerations – Cost Sharing and Effort Reporting
IV. Special Cost Share Procedures - Exceptions
Sample Certification
Letter – Also used for: All “Un-linked” GIT
Cost Share Expenses Certifications Required
by Sponsors** Accounting system support
must be attached
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Special Considerations – Cost Sharing and Effort Reporting
IV. 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 project budget.
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Special Considerations – Cost Sharing and Effort Reporting
IV. Special Cost Share Procedures – Exceptions
Accounting For In-Kind Tuition Remission (Continued) In instances where a sponsor will recognize In-Kind Tuition Remission as cost
sharing, the following procedures should be followed to provide required documentation.
1. When the award is approved and the project is established in the accounting system, a separate cost sharing account should be established to record the In-Kind cost sharing expense as it is incurred.
2. At the completion of each registration period, the Project Director or designated financial manager will direct the preparation and subsequent approval of a “Using Non-Sponsored Tuition and Fee Waivers as In-Kind Cost Sharing” form.
3. A copy of the completed form will be forwarded to the Grants & Contracts Accounting Office where it will be used to record the amount of the waivers to the Cost Sharing Project as In-Kind cost sharing.
4. Project Expenditure and Budget (PEB) reports for the Cost Sharing project will be used to document and support the cost sharing requirement to the sponsor.
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Special Considerations – Cost Sharing and Effort Reporting
IV. Special Cost Share Procedures – Exceptions
Accounting For In-Kind Tuition Remission
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Special Considerations – Cost Sharing and Effort Reporting
IV. Special Cost Share Procedures – Exceptions
Adjusting for Unmet Cost Share Obligations
Adjust to Adjusted Example # 1 Budget Actual Percent (1) Actual
Sponsored 45,000$ 44,844$ (3,074)$ 41,770$ Cost Sharing 43,000 36,833 3,074 39,907 Total 88,000$ 81,677$ (0)$ 81,677$
Sponsored % 51.14% 54.90% 51.14%Cost Sharing % 48.86% 45.10% 48.86%
100.00% 100.00% 100.00%
Note: Unit lost $3,074 of sponsored support.
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Special Considerations – Cost Sharing and Effort Reporting
IV. Special Cost Share Procedures – Exceptions
Adjusting for Unmet Cost Share Obligations
Adjust to Adjusted Example # 2 Budget Actual Percent (1) Actual
Sponsored 102,000$ 101,414$ (60,037)$ 41,377$ Cost Sharing 148,000 - 60,037 60,037 Total 250,000$ 101,414$ -$ 101,414$
Sponsored % 40.80% 100.00% 40.80%Cost Sharing % 59.20% 0.00% 59.20%
100.00% 100.00% 100.00%
Note: Unit lost $60,037 of sponsored support.
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Special Considerations – Cost Sharing and Effort Reporting
VI. Audits of Cost Share Expenditures
OMB Circular A-133 RequirementsAllowable Costs - Test of ExpendituresVerifiable from Institute Financial RecordsTests of In-Kind Cost Share Documentation
Audit Test ProceduresAllowable costsAllowable Funding Source
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Special Considerations – Cost Sharing and Effort Reporting
VII. Summary
* Cost Share Obligation Identified by OSP at the time of the acceptance of new awards
* 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)
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Special Considerations – Cost Sharing and Effort Reporting
VII. Summary
* Cost Share Obligations are Presented on PEB.
* Cost Share Obligation must be met to avoid adjustments to Direct Cost Expenditures.
* Cost Share Obligation must be Recorded in Institute Financial Records.
* Special Procedures may require extra work for the Unit Financial Managers.
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Special Considerations – Cost Sharing and Effort Reporting
Q & A
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1. Authorization to expend funds from a Cost Share project occurs when?
2. The budget for a Cost Share Project funded from Departmental resources is established by _____ ?
3. The Budget for a Cost Share Project funded from GTRC resources is established by _____ ?
4. The best and easiest method to account for Cost Share expenses is _____ ?
5. What happens if a cost-share obligation is not met?
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Other Questions?
Contact: [email protected]
or Sandy Mason, 404-894-5526
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Personal Services Reporting Using the Plan
Confirmation System (PCS)
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Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using the Plan Conformation System
Why Personal Services Reporting (aka: Effort Reporting) OMB Circular A-21 Plan-Confirmation System: Professorial and Professional Employees,
Graduate Students After-the-Fact Activity Records–Non-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
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
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.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
Background
The Federal Government's Office of Management and Budget (OMB) Circular No. A-21, Revised
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 this Circular in determining the costs incurred for such work.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
(OMB) Circular No. A-21
The Federal Government's Office of Management and Budget (OMB) Circular No. A-21, Revised The provisions of OMB Circular No. A-21 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.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
(OMB) Circular No. A-21
OMB Circular No. A-21 identifies three acceptable methods for handling payroll distributions: The After-the-Fact Activity Records system, The Plan-Confirmation system, and A system of multiple confirmation records. 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).
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
Plan-Confirmation System
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.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
Plan Confirmation System & OMB Circular A-21
OMB Circular A-21
A plan-confirmation system used for salaries and wages charged
directly or indirectly to sponsored agreements will meet the
following standards:
J10c(1)(a) A system of budgeted, planned, or assigned
work activity will be incorporated into the official records of
the institution and encompass both sponsored and all
other activities on an integrated basis. The system may
include the use of subsidiary records.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
Plan Confirmation System & OMB Circular A-21
OMB Circular A-21
J10c(1)(b) The system will reasonably reflect only the
activity for which the employee is compensated by the
institution (compensation for incidental work need not be
included).
J10c(1)(c) The system will reflect activity applicable to
each sponsored agreement and to each category
needed to identify F&A costs and the functions to which
they are allocable.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
Plan Confirmation System & OMB Circular A-21
OMB Circular A-21 J10c(1)(d) The system will provide for modification of an individual's
salary or salary distribution commensurate with a significant
change in the employee's work activity.
Short-term (such as one or two months) fluctuation between workload
categories need not be considered as long as the distribution of salaries and
wages is reasonable over the longer term, such as an academic period.
Whenever it is apparent that a significant change in work activity which
is directly or indirectly charged to sponsored agreements will occur or
has occurred, the change will be documented over the signature of a
responsible official and entered into the system.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
Plan Confirmation System & OMB Circular A-21
OMB Circular A-21
J10c(1)(e) At least annually a statement
will be signed by the employee,
principal investigator, or responsible
official(s) using suitable means of
verification that the work was performed, stating that salaries and wages charged to
sponsored agreements as direct charges, and to residual, F&A cost or other categories are
reasonable in relation to work performed.
GA Tech uses the Electronic Annual Statement of Reasonableness (eASR) for
confirmation of effort reported.
To be electronically signed by employee and Unit Financial Manager before the deadline date.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
Plan Confirmation System & OMB Circular A-21
OMB Circular A-21
J10c(1)(f) The system will provide for independent internal
evaluation to ensure the system's integrity and compliance
with the above standards.
Annual Review by Internal Audit
J10c(1)(g) In the use of this method, an institution shall not
be required to provide additional support or documentation
for the effort actually performed.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
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 Administration–Instruction,
Departmental Administration-Research and/or Other Sponsored Agreements.
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Plan Confirmation System
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Special Considerations – Cost Sharing and Effort Reporting
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. This procedure meets the requirements of OMB Circular A-21
After-the Fact Activity records.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
After-the-Fact Activity Records – Non-Professional Employees
Georgia Tech uses the After-the-Fact Activity Records system for non-professional employees. Where an institution uses time cards or other forms of after-the-fact payroll documents as original documentation for payroll and payroll charges, such documents, according to Circular No. A-21, shall qualify as After-the-Fact Activity Records provided the distribution of salaries and wages will be supported by appropriately approved documents.
The use of time documents, as prescribed under current Georgia Institute of Technology payroll procedures, meets the requirements of OMB Circular No. A-21 for non-professional employees, and no additional activity reporting is necessary for the non-professional employees.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
The Salary Planning and Distribution (SPD) System Features
Feature ListManages distribution of salary charges to projectsAccepts Payroll System TransactionsAccepts changes made by campus unitsManages distribution of fringe benefit and tuition
remission (GSTRP) chargesIdentifies employees covered by the Plan Confirmation
System Provides detailed salary distribution data for all
employees and generates required monthly allocation and annual effort reports (ie: eWAF and eASR).
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Plan-Confirmation System Training
Personal Services Reporting Tutorial and Confirmation – OHR TRAINS website.
Video, assessment questionnaire, and confirmation statement. 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 TechWorks / GT Effort Reporting pagelet / Training and Resources
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
What is EWAF?
Electronic Workload Assignment FormBeginning 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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
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
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
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 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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Report A Change or Issue
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Electronic Annual Statement of Reasonableness
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GA Tech’s annual effort
certification.
Email notification to
employee.
Electronically signed by
employee.
Electronically certified by
Unit Financial Manager.
Deadline date, usually 8/31.
Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Manual Annual Statement of Reasonableness
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ASR Signature Certification GA Tech’s 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
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
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
5. Sign the Annual Statement of Reasonableness of Salary Distribution.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
SPD Redistributions
New for FY10 – all redistributions to externally funded sponsored projects require electronic justification in the SPD system.
Beware of transfers involving ARRA-funded sponsored projects (“S” funds).
Over 120 Day redistributions: Effective November 1, 2007 salary distributions to externally funded
sponsored projects are not be allowed over 120 days from date of payment.
Exclusions are to same fund transfers, GTF, or GTRC projects.
Special request for over 120 redistributions has to be approved by Director of G&C, Assoc VP of Finance, and Assoc Vice Provost for Research.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
NIH Salary Cap (G&C Notice 12-I)
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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System
G&C Notice 12-I
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
NSF 2/9ths Rule Salary Limitation(G&C Notice 09-III)
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Level of Commitment.
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.
PI’s/ Unit Financial Officers need to monitor Level of Commitment for their sponsored projects.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System
Questions?
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System - Q&A
Questions & Answers?
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System - Q&A
1. Plan Confirmation SystemThe 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
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System - Q&A
2. Electronic Workload Assignment FormIf 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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System - Q&A
3. Electronic Workload Assignment FormAn 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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan 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.
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan 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
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Plan Confirmation System
Grants & Contract Accounting & OSPAll rights reserved GTRC
Special Considerations – Cost Sharing and Effort Reporting
Personal Services Reporting Using thePlan Confirmation System
THANK YOU FOR ATTENDING
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Contact: [email protected] or
Robert Ellington, 404-894-3488 [email protected]
Plan Confirmation System