The University must assure that work performed in support of sponsored programs justifies the payroll charges (i.e., wages and salaries) to a sponsored program. Payroll costing allocations used to direct the application of future payroll charges among sponsored and non-sponsored fund sources are budget estimates; therefore, after-the-fact review is needed to confirm that the charges reasonably reflect the work performed in support of individual sponsored programs as well as the work performed for other University activities. An employee’s payroll charges for work performed on a federal sponsored program must not exceed 100% of the employee’s institutional base salary and must be proportionate to the work performed in support of the sponsored program during the period.

Level of Support from Sponsored Programs: Total (100%) University effort for full-time faculty generally includes responsibilities not related to sponsored programs, such as non-sponsored research, instruction, administration, advising students, University service or clinical activity which may not be paid by sponsored funds. In addition, time spent preparing proposals for future funding (e.g., competitive, new, or renewal applications for sponsored funds) generally may not be charged to federally funded sponsored programs. Salary support for these other University activities must come from non-federal University sources, except when a sponsored program is specifically awarded for those purposes. It may be appropriate for certain research faculty to be fully supported from federally funded sponsored programs but only in cases where other University responsibilities do not exist. Incidental work and de minimis activities, over and above or separate from those duties assigned to a faculty member (e.g., on occasion teaching a continuing education course; rare, non-routine time spent in advising students) do not need to be accounted for separately.

Approach: The University requires that a responsible person confirm payroll allocation confirmation (PAC) reports detailing the payroll charges for each employee charged (or cost shared, see University policy FIN-051: Proposing and Managing Cost Sharing on Sponsored Programs) to one or more sponsored program during the reporting cycle.

Reporting Cycle: PAC reports will be generated periodically, approximately 3 months after the end of each reporting period. This lag is intended to allow for the timely identification and correction of errors before PAC report generation.

Level of Precision Required: The Uniform Guidance recognizes that “teaching, research, service, and administration are often inextricably intermingled in an academic setting” and stipulates that “When recording salaries and wages charged, a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected.”

Therefore, the University requires that when reviewing and confirming payroll charges on a sponsored program, the responsible person must only confirm that the charges are reasonable in relation to the work performed.

1. Roles and Responsibilities:
   Each individual with responsibilities in the PAC process must thoroughly understand the proper method of reviewing, completing, and confirming PAC reports such that payroll charges on sponsored programs reasonably reflect work performed in support of individual sponsored programs during the report period.

   The following offices and positions have roles and responsibilities in the PAC process.

   1. Responsible Persons are responsible for:
      • Understanding and employing the principles, policies, and procedures related to accurate and timely confirmation of PAC reports.
      • Communicating with school/department/unit administrators in the establishment of accurate and timely payroll costing allocations across various sponsored and non-sponsored activities.
      • When present, complying with sponsor requirements regarding any significant reductions (normally >25%) in effort or changes in the scope of work.
      • Identifying and communicating to the school/department/unit reporting coordinators, situations where payroll accounting adjustments are necessary and when payroll allocations need to be updated for future charges.
      • Reviewing, explaining, and correcting any inaccuracies or omissions on PAC reports to accurately reflect work committed and performed on sponsored programs prior to confirmation.
      • Confirming, in a timely manner, that all payroll charges, their own and those of others working on sponsored programs under their direction, accurately reflect work performed in support of individual sponsored programs.
      • Responding to any questions posed by reviewers regarding the PAC process or reports.

   2. School/Department/Unit Payroll Reporting Coordinators are responsible for:

      • Understanding and employing the principles, policies, and procedures related to accurate and timely confirmation of PAC reports.
      • Establishing effective processes to assist with compliance with policies and associated procedures.
      • Moving PAC reports forward via the system for confirmation in a timely manner.
      • When necessary, reassigning in a timely manner, PAC reports to another responsible person.
      • Assisting and providing guidance to responsible persons in their accurate and timely confirmation of PAC reports.
      • Acting promptly to coordinate/process payroll accounting adjustments based upon confirmations by the responsible person.
      • Reviewing and acting on submitted PAC reports in a timely manner.

   3. School/Department/Unit Personnel Responsible for Payroll Allocations are responsible for:

      • Establishing proper/timely payroll costing allocations for persons supported by sponsored programs to appropriately allocate payroll charges.
      • Performing payroll accounting adjustments in a timely fashion in support of accuracy in the application of payroll charges to various sponsored and non-sponsored fund sources.

   4. Department Chairs/Division Heads are responsible for:

      • Understanding and employing the principles, policies, and procedures related to accurate and timely confirmation of PAC reports.
      • Maintaining effective processes to assist with compliance with policies and associated procedures.
      • Maintaining effective practices to assist with proper and timely updates to payroll costing to appropriately allocate costs across various sponsored and non-sponsored fund sources.
      • Taking corrective action when notified that PAC report confirmations have not been completed by the applicable deadline.

   5. The Office of Sponsored Programs is responsible for:

      • Establishing and communicating policies and procedures related to PAC report confirmation consistent with the requirements of the Uniform Guidance.
      • Providing direction and guidance to those involved in the payroll allocation confirmation process.
      • Reviewing and updating, when needed, the methodology for data included on periodic PAC reports for accuracy and completeness.
      • Generating and distributing the PAC reports and confirming requests in a timely manner.
      • Taking action to address instances of non-compliance with this policy and associated procedures.
      • Maintaining completed PAC reports as required by University policy IRM-017: Records Management.

2. Compliance with Policy:
   If the PAC reports are not confirmed timely and properly, the Office of Sponsored Programs will take actions to remain in compliance with federal requirements. These actions may include:

   1. Withholding submission of proposals, other project applications or other documents such as material transfer agreements.
   2. Placing active sponsored projects/awards ‘on hold.’
   3. Moving uncertified payroll charges on sponsored programs to non-sponsored accounts.

   In addition, failure to comply with the requirements of this policy and its related procedures may result in penalties levied against the departments, divisions, schools, and/or the University. Additionally, failure to comply with these requirements by individuals with roles and responsibilities in the certification process may result in disciplinary action up to and including termination or expulsion in accordance with relevant University policies.

   Questions about this policy should be directed to the Office of Sponsored Programs.