Project Payroll Confirmation for Compliance with 2CFR Part 200
The Federal requirements for compensation costs, documentation standards, and payroll confirmation to ensure compliance with 2CFR Part 200. Learn about the importance of accurate records, reasonable allocations, and proper support for personnel expenses.
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Project Payroll Confirmation Sarah Panepinto Director, Office of Grant and Contract Services
2CFR Part 200.430 Compensation Federal Requirement Costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees: (1) Is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non- Federal activities; (2) Follows an appointment made in accordance with a non-Federal entity's laws and/or rules or written policies and meets the requirements of Federal statute, where applicable; and (3) Is determined and supported as provided in paragraph (i) of this section, Standards for Documentation of Personnel Expenses, when applicable.
Standards for Documentation of Personnel Expenses "(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass both federally assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy; (v) Comply with the established accounting policies and practices of the non- Federal entity (See paragraph (h)(1)(ii) above for treatment of incidental work for IHEs.); and (vi) [Reserved]
Standards for Documentation of Personnel Expenses (vii) Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. (viii) Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that: (A) The system for establishing the estimates produces reasonable approximations of the activity actually performed; (B) Significant changes in the corresponding work activity (as defined by the non-Federal entity's written policies) are identified and entered into the records in a timely manner. 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; and (C) The non-Federal entity's system of internal controls includes processes to review after-the- fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
Standards for Documentation of Personnel Expenses (ix) Because practices vary as to the activity constituting a full workload (for IHEs, IBS), records may reflect categories of activities expressed as percentage distribution of total activities. (x) It is recognized that teaching, research, service, and administration are often inextricably intermingled in an academic setting. When recording salaries and wages charged to Federal awards for IHEs, a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected. a (2) For records which meet the standards required in paragraph (i)(1) of this section, the non-Federal entity will not be required to provide additional support or documentation for the work performed, other than that referenced in paragraph (i)(3) of this section.
How will UT Arlington/PIs be compliant with this requirement?
Annually Confirm Accurate Monthly Review Allocate Reallocate Estimates/Interim Charges To Align With Work Performed
Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated PI/Department Responsibilities 1. Development and review of the budget at the proposal stage to determine allowability (verify IBS, estimate percentage) 2. At award stage, review budget and make an estimate of allocable personnel to appoint to the ProjectID 3. On a monthly basis, review available reports to make certain no changes to the estimate are needed. Reports to be reviewed: i. Monthly Project Payroll Report (mentis) ii. Payroll Analysis Report (UT Share) iii. Monthly Financial Statement (UT Share) 4. On an annual basis confirm that payroll charged to the award are accurate, allowable and properly allocated via the i. Cumulative Project Payroll Reports
Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated OGCS Responsibilities 1. Assist in the development and review of the budget at the proposal stage to determine allowability. 2. Monitor that PIs are accessing Monthly Project Payroll Reports on a regular basis. 3. Provide training and guidance on the federal requirements regarding compensation. 4. Monitor that PIs are confirming Cumulative Project Payroll Reports in a timely manner.
Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS) What is IBS Institutional Base Salary (IBS): The base compensation set by UTA for an individual s appointment, whether that individual s professional time for UTA is spent on instruction/teaching, research, service, administration, or other activities, and whether that employee is appointed full-time or part-time. For faculty with a nine month appointment, the IBS is annualized to equal a twelve month total compensation for budget purposes. For example, a faculty member with a full-time 9 month appointment of $90k equates to a maximum IBS of $120k for 12 months or $10k per month. IBS excludes income that an individual may be permitted to earn outside of duties to UTA and most forms of Extra Service Pay. IBS does not include bonuses, one-time payments or incentive pay. Also excluded from the IBS is salary paid directly by another organization including but not limited to income that an individual is permitted to earn outside of their University responsibilities such as consulting or honoraria. IBS may include long-term (at least annually) payments for administrative assignments (For example Department Chairs).
Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS) UT Arlington Institutional Base Salary includes: 1. Salary 2. Overtime 3. Longevity Pay 4. Recurring Administrative Supplements
Some Basics UTA s Payroll Confirmation and Monthly Project Payroll Reports contain information from March 1, 2017 1. Information prior to this time is in ecrt Monthly Project Payroll Reports should be available for all projects that had an end date on or after 3/1/17 Cumulative Payroll Confirmation Reports are available for all projects that had an anniversary date on or after 3/1/17 The anniversary date is every year on the start date of the project to confirm payroll for the preceding year. Projects that have an anniversary date of July 1 will see 4 months of data for the initial confirmation report (March, April, May, June)
On a Monthly Basis Review Monthly Project Payroll Reports Step 1: Log in to mentis and select Report Portal
On a Monthly Basis Review Monthly Project Payroll Reports Step 2: Select the Monthly Project Payroll Report you want to review
On a Monthly Basis Review Monthly Project Payroll Reports Step 3: Open the Report and Review the Data Instructions for Review: Review the Project Salary and Cost Share charged relative to the work each individual is performing and their Institutional Base Salary (IBS) received. If the distribution reasonably reflects and does not exceed the estimated longer term activities being performed (e.g. 90 days) or to be performed on the project, no further action is needed. If the salary (and cost share) allocation does not reasonably reflect or exceeds the activities for the work performed on the project by an individual(s) relative to their IBS, coordinate with your Department Administrative Assistant to process a reallocation of payroll to the interim charges and future estimates as needed. Hourly employee information is available for review of the allocations made to your project. Any corrections should be made with your Department Administrative Assistant. As a reminder to the Administrative Requirements for any sponsored project with applicable or similar terms as stated in 200.308 (c)(3), the PI/PD must receive prior approval from the sponsoring agency if he/she anticipates a disengagement from the research of 3 months or more or will reduce the percent of time originally stated/devoted to the award. Please coordinate any planned disengagement
On a Monthly Basis Review Payroll Analysis Report Instructions for Review: Looking at the person s 100% effort does the allocation reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities?
On a Monthly Basis Review Payroll Analysis Report
On a Monthly Basis Review Monthly Financial Statement Instructions for Review: Review the Project Salary and Cost Share charged relative to the work each individual is performing and their Institutional Base Salary (IBS) received. If the distribution reasonably reflects and does not exceed the estimated longer term activities being performed (e.g. 90 days) or to be performed on the project, no further action is needed. If the salary (and cost share) allocation does not reasonably reflect or exceeds the activities for the work performed on the project by an individual(s) relative to their IBS, coordinate with your Department Administrative Assistant to process a reallocation of payroll to the interim charges and future estimates as needed.
On an Annual Basis Review Cumulative Project Payroll Reports Instructions for Review: 1. Review the Project Salary and Cost Share charged on the Cumulative Project Payroll Report relative to the work each individual is performing and their Institutional Base Salary (IBS) received. 2. If the distribution reasonably reflects the activity performed and earned on the project relative to their IBS, no further action is needed (go to #4). 3.If the salary (and cost share) distribution does not reasonably reflect the project activity for the work performed by an individual(s), coordinate with your Department Administrative Assistant to process a reallocation of payroll for the interim charges. 4.When the salary charges reasonably reflect the work activities performed on the project on the Cumulative Project Payroll Report for all non-hourly individuals, confirm that the salary received did not exceed their proportionate share (to their IBS) of the work performed on the project. Hourly employee information is provided for the PI to review the allocation.
On an Annual Basis Review Cumulative Project Payroll Reports
Effort Certification vs. Payroll Confirmation ecrt vs. Cumulative Project Payroll Reports Every six months One card for every individual The salaries paid to individuals reasonably reflects the actual amount of effort expended on a sponsored project Once a year One card per project The salary received did not exceed their proportional share share (to their IBS) of the work performed on the project
