For a hardcopy pdf of this document, contact the Office of Compliance (2-8246).
Policy Title: Payroll Certification on Federally Sponsored Projects
Policy Number: 200-40
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Responsible Officer: |
Associate Vice Chancellor of Business & Financial Services and Controller |
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Responsible Office: |
Business and Financial Services – Accounting Office |
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Origination Date: |
01/01/2011 |
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Date of Revision: |
08/01/2017 |
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Date of Last Review: |
08/13/2021 |
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Scope: |
Guidance Concerning Federally Sponsored Projects |
I. Overview
In order to properly substantiate salary costs that are directly charged to federally funded projects, the University will employ the use of annual Payroll Certifications on a project by project basis in lieu of effort reporting. Payroll Certifications are required for salaries of all employees of the University, including hourly employees, part-time employees, adjunct faculty, and students on the University payroll who are paid from federal and federal flow-through funds. The payroll certification method used at the University of California-Riverside (UCR) has been approved by its federal cognizant agency, the Department of Health and Human Services.
II. Policy Statement
Direct salaries and committed cost sharing salaries for personal services on all federal projects for research, training, and service must produce an equitable distribution of charges for an employee’s activities and be documented in a method acceptable under OMB Circular A-21, Cost Principles for Educational Institutions and 2 CFR 200 Uniform Guidance. The Payroll Personnel System (PPS) reflects actual salary and wage costs of employees by Full Accounting Unit (FAU).
Committed cost sharing salaries are based on the non-federal portion of the employee’s actual salary. Salary distributions must adhere to the University’s academic and staff personnel policies. The apportionment of employees' salaries and wages chargeable to sponsored agreements or identified as committed cost sharing must be initiated by the Principal Investigator (PI) or designee using the appropriate departmental personnel services authorization format. All charges and cost sharing for personal services are based on actual salary charges posted in the accounting system and are supported by documentation such as employment contracts, appointment letters, and other written guidance.
Individuals whose payroll is charged and/or identified as committed cost sharing on projects must have worked on the project and be documented in the UCR financial system under the applicable award fund number. The charges must be appropriate and reasonable in relation to work performed, as well as comply with special costing requirements (e.g., NIH Salary Cap, NSF senior personnel salary limits, clerical and administrative salaries charged meeting federal exception criteria, etc.). Non-sponsored activities, such as instruction and department administration, and proposal preparation activities cannot be charged to sponsored projects. The Prime PI must provide the annual payroll certification. The Prime PI is defined as the lead investigator as identified on the campus Notice of Award.
III. Frequency of Certification
Annually, at the end of the award budget period and at the award expiration, a Payroll Certification of actual salaries and committed cost sharing will be required from the Prime PI. This certification will be retained for subsequent review. Certifications that are not made timely will be subject the sanctions provided for in this policy.
IV. Monthly Review
The monthly review of actual salaries charged to an award via the campus Principal Investigator Web Reporting System (PIWRS) financial report compliments the payroll certification process. This review will enable timely identification of errors, initiation of corrections, and timely payroll certifications. PIs are encouraged to complete a monthly review.
V. Compliance
Compliance with this policy is critical for meeting the terms and conditions associated with the fiduciary responsibilities of UCR in the management of federally funded awards. In the event non-compliance conditions occur and upon the approval of the Vice Chancellor-Business & Administrative Services (VC BAS), the uncertified salary charges will be transferred to an unrestricted funding source in the department and/or organization of the Prime PI.
VI. Responsibilities
A. Principal Investigator (PI)
The Prime PI, as designated in the Notice of Award and identified in the UCR financial system, is responsible for reviewing charges and committed cost sharing for personal services in the frequency described below and certifying that all individuals worked on the project, salary charges were appropriate and reasonable in relation to work performed, and that any special costing requirements were met. Annual certifications will be made electronically through the PIWRS. The Prime PI must certify each award within 30 days of notification. In addition, the Prime PI is responsible for the monthly review of project financial reports via the PIWRS (or equivalent) and promptly reporting discrepancies to the department contract and grant administrator for correction.
The PI may request the review of the Payroll Certification report from Co-PIs, project directors, and others with direct knowledge of the project activities. However, the Prime PI is responsible for certifying the project Payroll Certification report.
B. Department
The department contract and grant analyst and financial manager are responsible for the monthly reconciliation of the project’s general ledgers activity, the timely processing of any payroll or other expense adjustments as required, assisting the PI with the interpretation of the PIWRS and Payroll Certification reports, and tracking cost sharing. The Department Head is responsible for ensuring that all payroll certifications and ledger reconciliations are completed within the established timeframe. Uncertified salaries and untimely certification of salary expenditures create an undue compliance risk for the University and are subject to transfer to a departmental unrestricted funding source.
C. Organizational Unit
The organizational unit will receive an early notification if an award has not been certified within 20 days of distribution. If the certified report is not received within 30 days of the PI notification the salary charges will be subject to transfer to a department or organizational unrestricted funding source.
D. Accounting Office
The Accounting Office is responsible for the integrity to the core financial information presented within the PIWRS and the coding of fund attributes that generate the monthly financial reports, annual payroll certification, and annual cost sharing reporting notifications. The Accounting Office will monitor compliance with payroll certifications and cost sharing reporting and take appropriate action with the PI’s department and/or organizational unit.
VII. Contacts
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Subject |
Contact |
Phone |
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Technical Content |
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piwrsfeedback@ucr.edu |
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All other Questions |
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UCRpolicy@ucr.edu |
VIII. Related Policy References
· UC Business and Finance Bulletin A-47, University Direct Costing Procedures
· UCR Payroll Certification Support Website