This policy outlines requirements and procedures to facilitate the Georgia Institute of Technology (GT) compliance with the Federal Government's Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200), hereafter referred to as Uniform Requirements. The Uniform Requirements establish principles for determining costs applicable to grants, contracts, and other agreements between Federal agencies and non-Federal entities (i.e., 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.
GT must have financial systems and internal control procedures in place to assure compliance with the terms and conditions of these agreements and State and Federal regulations concerning sponsored programs. The documentation and support of the distribution of salary and fringe benefits charges to sponsored programs is a critical element of compliance. The requirements for this documentation are defined in section 200.430(i) of the Uniform Requirements and requires salary and fringe benefits to accurately reflect the work performed.
GT requires that the preparation of invoices to sponsors be based on the information in accounting records, including the salary and fringe benefit charges, determined by the GT Commitment Accounting System and confirmed in the GT Plan Confirmation System (PCS). Every invoice must be signed and certified by a GT financial officer, or their designee. The signature certifies that the accuracy of the charges presented on the invoice for payment:
- Are allocable to the project scope,
- Are allowable by the project budget,
- Are reasonable and have been incurred within the Period of Performance, and
- Have been incurred according to all GT accounting policies and procedures.
The distribution of salary and fringe benefits to sponsored projects is a sensitive issue in GT’s operation of its sponsored programs; it therefore receives scrutiny by GT officers, sponsor representatives, and federal government contracting officers and auditors. Learn more about Commitment Accounting requirements here.
Compensation for Personal Services
Compensation for personal services covers amounts paid currently, or encumbered by GT, for salary and fringe benefits services of employees rendered during the period of performance under sponsored agreements or other institutional activity. The payroll distribution, which is incorporated into the official records of GT, must reasonably reflect the activity for which employees are compensated by GT, and it encompasses both sponsored and all other activities on an integrated basis.
Plan-Confirmation System – Employee Salary Charged to External Sponsored Awards and Cost Share
Under the Plan Confirmation System the distribution of salaries and fringe benefits reflects budgeted, planned, or assigned work activity based on the initial annual budget and updated throughout the year to reflect any significant changes in work distribution.
Workload Assignment Forms
The WAF must be reviewed and retained by employees on a monthly basis. These forms must be retained during the fiscal year until the ASR is confirmed. Unit financial managers may also produce copies for review by individual employees upon request. Employees must report workload changes to their supervisor in a timely manner. See “Employee Responsibilities” in Section 7 of this Policy.
Significant Changes in Workload Distribution
The Plan-Confirmation System provides for the modification of an individual's salary distribution, commensurate with any significant change in the employee's workload or the ratio of activities comprising the workload. Specific events, which may cause a significant change in workload distribution include, but are not limited to:
- The beginning or ending of work on a sponsored award,
- A material change in the scope of work on a sponsored award,
- An increase or decrease in the number or level of courses taught,
- A new committee or major administrative assignment or relief from a committee or major administrative assignment,
- The beginning or ending of a sabbatical leave, leave without pay, or prolonged sick leave,
- Status changes from part-time to full-time or vice versa.
The system does not require an adjustment in the employee's workload assignment for day-to-day, or short-term, changes in work schedule. However, the Plan Confirmation System does require an adjustment for all significant changes in an employee's workload. GT provides as a general rule that a change applicable to a given project or activity of 5% or more of an employee's total effort over the course of the academic term would warrant an adjustment.
Changes in an employee's workload distribution for future periods are generally acceptable but are subject to the standard documentation requirements noted below. Future period workload distributions are confirmed monthly via the WAF.
Retroactive Changes in Workload Distribution
Retroactive changes to payroll distributions must be subjected to the closest scrutiny. These types of changes indicate a contradiction of previous monitoring reviews and, for that reason, should be limited to the correction of errors. If a retroactive change must be made, it must be approved and documented in accordance with the requirements found in the Commitment Accounting policy.
Standard Documentation Requirements
GT authorizes the principal investigator (PI) and the properly authorized unit designee (financial manager and staff) to have primary responsibility for the management of sponsored awards. The manual/electronic signatures and/or a system password of those individuals is generally considered sufficient documentation to support standard workload allocation changes.
Primary supporting documentation for PCS salary charges during a fiscal year are defined in the Commitment Accounting Policy (insert link).
Retroactive changes that cross fiscal years may be made in extraordinary circumstances by journal entry when supported by appropriate documentation, including a revised Annual Statement of Reasonableness of Salary Charges (ASR) signed by the employee or someone with firsthand knowledge and the departmental approver.
Annual Statement of Reasonableness (ASR) of Salary Charges
The Plan-Confirmation System requires that at least annually an attestation be completed by the employee, principal investigator, or responsible official that:
- work was performed, and
- compensation was charged to sponsored agreements as direct charges, or
- compensation was charged to both direct and indirect cost categories, or
- compensation was charged to more than one (F&A) indirect cost category, are reasonable in relation to work performed.
The Office of Grants and Contracts Accounting will notify employees to complete the ASR certification, following the completion of the fiscal year.
ASR Signatory Requirements – Certification of Effort
The Annual Statement on the Reasonableness of Salary Charges (ASR) is designed for the employee to confirm that the distribution of salary charges represents a reasonable estimate of the work performed during the stated period. In most instances, only the employee has the information required to complete this certification and therefore ASR's must be completed and signed by the covered employee.
The manual ASR does provide a second certification section to be used in limited instances when the covered employee is not available to complete the certification. When the employees is unable to complete the ASR, the certification may be signed by the employee’s supervisor, PI, or other organizational unit head, with firsthand knowledge of all the employee's activities using suitable means of verification that the work was performed. If the responsible official cannot certify that he/she has personal familiarity with all of the employee's activities, then the employee is required to sign the statement. In some cases, an employee may be involved in a number of activities under different supervisors, and no single person other than the employee has firsthand knowledge of all his/her activities. In these cases, the employee must sign the documents.
Unit Financial Manager's Certification
The PCS also requires that the appropriate financial manager in each unit review the ASR statements before returning to Grants and Contracts Accounting. The financial manager should sign and date each ASR to indicate that the review has been done.
This policy applies to all units of the Georgia Institute of Technology, with the exception of Georgia Tech Research Institute (GTRI). GTRI employees should reference GTRI Policy 6190 - Reporting Time and Paid Leave.
Annual Statement of Reasonableness (ASR)
The Annual Statement of Reasonableness report produced annually for employees using the PCS documenting confirmation and certification that their effort allocation was reasonable and correctly posted in the past fiscal year. This statement shows the amount of salary charged to each of the employee's sponsored awards along with all other activities compensated by GT and the percentage of each amount to the total effort. The manual ASR provides a means of making adjustments in payroll distributions if corrections are required.
A portion of an externally funded award where GT resources are committed and tracked in the Grants Management System.
Externally Funded Awards
An award or agreement by an external Federal or Non-Federal entity that is separately budgeted for in the Grants Management system. Georgia Tech Foundation and Georgia Tech Research Corporation funds are considered to be internally funded.
Period of Performance
The time during which new obligations can be incurred to carry out work on a sponsored award. A Federal awarding agency must include a start and end date of the Period of Performance in the award.
Workload Assignment Form (WAF)
The Workload Assignment Form (WAF) report is produced monthly for employees covered by the PCS to review their effort allocation for accuracy and make timely corrections. Each monthly WAF covers an entire fiscal year, July 1 to June 30, including both actual payments and planned salary distribution for future periods. These forms should be retained by employees covered by PCS during the fiscal year until the ASR is confirmed.
To obtain hard copy forms, please contact the Office of Grants & Contracts Accounting via Service Now.
7.1 Departmental Responsibilities
Unit financial managers should provide instructions and support to employees covered by the PCS to help employees understand their responsibilities with the system. Training is supported by Grants and Contracts Accounting Office via an on-line web tutorial. More information can be found here regarding training. Once completed, an electronic acknowledgement is recorded for all employees whose salaries are charged directly to externally sponsored awards.
7.2 Principal Investigator Responsibilities
Each GT PI is responsible for effectively overseeing and managing their sponsored awards based upon his/her knowledge of the field of study and capabilities to conduct the research in an efficient and productive manner.
7.3 Employee Responsibilities
Employees are responsible for:
- Completing required PSC training and attestations,
- Reviewing and retaining their respective WAF during the fiscal year until the ASR is confirmed,
- Communicating WAF inaccuracies or discrepancies, to their supervisor immediately,
- Reviewing and confirming the ASR by the published deadlines,
- Providing supporting documentation as needed for WAF and ASR confirmations,
- Reporting significant changes to the actual effort given to an award or planned to be given to an award,
- Notifying Commitment Accounting via Service Now in the event of supervisor inaction on WAF and ASR reconciliations.
To report suspected instances of ethical violations, please visit Georgia Tech’s Ethics Helpline, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508
|10-17-2015||Office of Grants & Contracts Accounting||Align with terminology of Fair Labor Standards Act (FLSA)|
|10-01-2015||Office of Grants & Contracts Accounting||Revise Special Documentation Requirements and Limitations – Externally-funded Sponsored Projects from 120 days beyond the original expense posting date to 90 days aligning with close-out requirements of OMB 2 CFR 200.|
|11-05-2014||Office of Grants & Contracts Accounting||Align with requirements of 2 CFR 200|
|04-01-2012||Office of Grants & Contracts Accounting||Administrative review|