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Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Special Considerations – Cost Sharing.

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Presentation on theme: "Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Special Considerations – Cost Sharing."— Presentation transcript:

1 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Special Considerations – Cost Sharing and Effort Reporting October 23, 2012 Presenters: Sandy Mason Robert Ellington

2 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Introduction ….. 2 Sponsor Portion $250,000 Georgia Tech Portion $250,000 Total Project $500,000

3 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Overview I. Office of Sponsored Programs - Policies II. OMB Circular A-110 Cost Sharing or Matching III. Managing Cost Share Projects in the GM System IV. Special Cost Share Procedures V. Words from a Sponsor – NSF VI. Audits of Cost Share Expenditures VII. Discussion Summary 3

4 Grants & Contract Accounting & OSP All rights reserved GTRC 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 4

5 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting I. Office of Sponsored Programs – Policies 1. 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. 5

6 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting I. Office of Sponsored Programs – Policies 4. 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. 6

7 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting I. Office of Sponsored Programs – Policies 7. 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. 7

8 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting I. Office of Sponsored Programs – Policies 10. 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. 8

9 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting I. Office of Sponsored Programs – Policies 12. 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. 9

10 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting II. OMB Circular A-110 Cost Sharing or Matching Acceptable Costs C23a: All contributions, including cash and third party in-kind, shall be accepted as part of the recipients 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. 10

11 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 11

12 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 12

13 Grants & Contract Accounting & OSP All rights reserved GTRC 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 recipients organization. 13

14 Grants & Contract Accounting & OSP All rights reserved GTRC 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 employees 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. 14

15 Grants & Contract Accounting & OSP All rights reserved GTRC 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… 15

16 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 16

17 Grants & Contract Accounting & OSP All rights reserved GTRC 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 Dont say it if you dont really mean it! * Beware of expressions of support in budget narratives and work-scope that are not included in the budget figures 17

18 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting III. Managing Cost Share Projects in the GM System Cost Sharing Projects Institute 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. 18

19 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 19

20 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 20

21 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 21

22 Grants & Contract Accounting & OSP All rights reserved GTRC 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 years Specific 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 22

23 Grants & Contract Accounting & OSP All rights reserved GTRC 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 Sources All Cost Share Projects Linked to Main Project Cost Share Obligations are Presented in PEB Demographic Section 23

24 Grants & Contract Accounting & OSP All rights reserved GTRC 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 24

25 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting III. Managing Cost Share Projects in the GM System 25 (A)(B) (C)

26 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting III. Managing Cost Share Projects in the GM System – Summary Reported on OSP Project Header 26

27 Grants & Contract Accounting & OSP All rights reserved GTRC 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 27 Project Summaries Prime Project ID displayed as BOLD Project ID (Rpt link) AwardPj St Project Expire Date TypeSponsor NamePI NameProject TitleLTD BudgetLTD Expend LTD Encumber LTD Balance 21013xx (Cmpl) (Sumry)CmplSumry RxxxxA08/31/12CSHR US DEPT OF ENERGY ARRA:96, XXX (Cmpl) (Sumry)CmplSumry RxxxxA12/31/12SPSD US DEPT OF ENERGY ARRA:458, , , , XX1 (Cmpl) (Sumry)CmplSumry RxxxxA08/31/12CSHR GTRC MATCHING GTRC MATCHING PROJECT 25, XX2 (Cmpl) (Sumry)CmplSumry RxxxxA12/31/12SPSD US DEPT OF ENERGY ARRA:79, , , , XXX (Cmpl) (Sumry)CmplSumry RxxxxA12/31/12SPSD US DEPT OF ENERGY ARRA:460, , , , xx (Cmpl) (Sumry)CmplSumry RxxxxA08/31/12CSHR US DEPT OF ENERGY ARRA:18, (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 ReportAward/Fund SummaryCost Share SummarySponsored 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

28 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting III. Managing Cost Share Projects in the GM System – Summary

29 Grants & Contract Accounting & OSP All 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 29

30 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting GM PEB III. Managing Cost Share Projects in the GM System – Summary

31 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting IV. 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 GIT GM System as Other Memo In-Kind Cost Share Tuition Remission Requires Specific Sponsor Approval Accounting For In-Kind Tuition Remission Recorded in GIT GM System as Other Memo 31

32 Grants & Contract Accounting & OSP All rights reserved GTRC 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 32

33 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 33

34 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 34

35 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting IV. Special Cost Share Procedures – Exceptions Accounting For In-Kind Tuition Remission 35

36 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting IV. Special Cost Share Procedures – Exceptions 36

37 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting IV. Special Cost Share Procedures – Exceptions 37

38 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting VI. Audits of Cost Share Expenditures OMB Circular A-133 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 38

39 Grants & Contract Accounting & OSP All rights reserved GTRC 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) 39

40 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 40

41 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Q & A 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?

42 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Other Questions? Contact: orSandy Mason,

43 Grants & Contract Accounting & OSP All rights reserved GTRC Personal Services Reporting Using the Plan Confirmation System (PCS)

44 Grants & Contract Accounting & OSP All rights reserved GTRC 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 44 Plan Confirmation System

45 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 45 Plan Confirmation System

46 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 46 Plan Confirmation System

47 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 47 Plan Confirmation System

48 Grants & Contract Accounting & OSP All rights reserved GTRC 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). 48 Plan Confirmation System

49 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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. 49 Plan Confirmation System

50 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 50 Plan Confirmation System

51 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 51 Plan Confirmation System

52 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 52 Plan Confirmation System

53 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 53 Plan Confirmation System

54 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 54 Plan Confirmation System

55 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 55 Plan Confirmation System

56 Grants & Contract Accounting & OSP All rights reserved GTRC 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. 56 Plan Confirmation System

57 Grants & Contract Accounting & OSP All 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. 57 Plan Confirmation System

58 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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 and 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 (ie: eWAF and eASR). 58 Plan Confirmation System

59 Grants & Contract Accounting & OSP All 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. 59 Plan Confirmation System

60 Grants & Contract Accounting & OSP All 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. 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 60 Plan Confirmation System

61 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting What is EWAF? Electronic Workload Assignment Form Beginning in FY2005, the SPD Center sends monthly notifications to all Covered Employees. The 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. 61 Plan Confirmation System

62 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Personal Services Reporting Using the Plan Confirmation System 62 Plan Confirmation System

63 Grants & Contract Accounting & OSP All 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 63 Plan Confirmation System

64 Grants & Contract Accounting & OSP All 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 address in Campus Directory for 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 with the subject line pre-worded to indicate: SPD Salary Distribution Change Needed per Workload Assignment Form Review. Enter the 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 , explain what needs to be changed on your past or future salary distribution. 64 Plan Confirmation System

65 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Report A Change or Issue 65 Plan Confirmation System

66 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Electronic Annual Statement of Reasonableness 66 GA Techs annual effort certification. notification to employee. Electronically signed by employee. Electronically certified by Unit Financial Manager. Deadline date, usually 8/31. Plan Confirmation System

67 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Manual Annual Statement of Reasonableness 67 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

68 Grants & Contract Accounting & OSP All 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. 68 Plan Confirmation System

69 Grants & Contract Accounting & OSP All 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. 69 Plan Confirmation System

70 Grants & Contract Accounting & OSP All 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. 70 Plan Confirmation System

71 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Personal Services Reporting Using the Plan Confirmation System G&C Notice 12-I 71 Plan Confirmation System

72 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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. 72 Plan Confirmation System

73 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting NSF 2/9ths Rule Salary Limitation(G&C Notice 09-III) 73 Plan Confirmation System

74 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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. 74 Plan Confirmation System

75 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Personal Services Reporting Using the Plan Confirmation System Questions? 75 Plan Confirmation System

76 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Personal Services Reporting Using the Plan Confirmation System - Q&A Questions & Answers? 76 Plan Confirmation System

77 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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 77 Plan Confirmation System

78 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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 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 notifications. e. Forget about it, since it is not important. 78 Plan Confirmation System

79 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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. 79 Plan Confirmation System

80 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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. 80 Plan Confirmation System

81 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting 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 81 Plan Confirmation System

82 Grants & Contract Accounting & OSP All rights reserved GTRC Special Considerations – Cost Sharing and Effort Reporting Personal Services Reporting Using the Plan Confirmation System THANK YOU FOR ATTENDING 82 Contact: Robert Ellington, Plan Confirmation System


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