Original Policy Source | APPM Section II Item 32 |
Policy Approval Authority | University Council |
Responsible Division | Division of Research and Innovation Partnerships |
Responsible University Office | Sponsor Programs Administration |
Responsible Officer(s) | Assistant Vice-President |
Contact Person | Dara Little, dlittle@niu.edu |
Primary Audience |
Faculty
Staff Administration |
Date Submitted to Policy Library | 04-18-2019 |
Status | Active |
Adoption Date | 04-22-2019 |
Last Review Date | 03-17-2023 |
Policy Category/Categories |
Finance / Risk Management
Human Resources / Employment Sponsored Funding/Grants and Contracts |
To set forth in writing NIU's responsibilities for ensuring the proper charging of labor costs to federally funded sponsored awards.
As a recipient of sponsored funding, NIU must provide assurance to our sponsors that the assignment of salary and associated fringe benefit costs to the project they support are fair, consistent, and timely.
Federal regulations under Uniform Guidance 2 CFR 200.430 contain specific regulatory requirements for internal controls for documenting salary charges on sponsored awards. To comply with these requirements, NIU uses an after-the-fact verification process to confirm that all salaries charged to federally sponsored awards are reasonable and consistent with the work performed. These records must reasonably reflect the total activity for which the employee is compensated, including federally funded and other sponsored activities as well as non-sponsored activities, not exceeding 100%.
NIU's certification process provides the means for verifying that salaries and wages charged to the award are consistent with the employee's effort on the project. Severe penalties and funding disallowances can occur from inaccurate, incomplete, or untimely effort reporting.
All faculty, staff, and students who receive pay from sponsored awards must verify the accuracy of their time (i.e., effort) per the procedures established by NIU. Effort for hourly employees is verified via their time sheets and effort for salaried employees is verified via an Effort Statement.
The Effort Statement should be reviewed and signed by the person who has knowledge of the work performed on the project. This may be the individual, the Principal Investigator (PI), and/or a responsible university official(s).
For all faculty, as well as non-faculty who are serving as PI:
Salary verification is done twice a year covering periods January 1 to June 30 and July 1 to December 31.
At the end of each period, Sponsored Programs Administration (SPA) prepares Effort Statements for all individuals who have been paid from sponsored funds during the verification period. These individuals are required to certify that the salaries and wages charged to an award accurately reflect the work performed on the project.
The following table shows the estimated distribution schedule for each verification period:
Effort Period | Distribution* | Collection** |
---|---|---|
January 1 thru June 30 | Approx. Nov. 1 | Approx. Dec. 1 |
July 1 thru December 31 | Approx. May. 1 | Approx. June 1 |
Effort Statements use all relevant HRS source data posted into the general ledger during the verification period, all PAY journals posted during the verification period, plus SPA initiated adjusting entries made in the beginning of the verification period, to support the Effort Statements. It is imperative that all entries made to adjust personnel activity charged to a grant happen in the actual verification period.
Departments need to make sure that salary charges are posted to grants in a timely manner, as well as ensure that salary adjustments are made in accordance with SPA's cost transfer policy.
Failure to ensure the accuracy of salary charges on sponsored awards can result in disallowed costs, fines, or suspension or loss of federal funding.
Approved by APPM Advisory Committee January 4, 2007
Modified February 27, 2017
Modified April 22, 2019
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