Revised 12/13
Revised 12/13
Table of Contents
General Post-Award Office Responsibilities ................................................................................... 1
Receipt of an Award .................................................................................................................................... 1
Establishment of Sponsored Indexes ......................................................................................................... 1
Approval Queue ........................................................................................................................................... 1
Providing Orientation & Training to Project Directors & Principal Investigators .............................. 2
Approval of Budget Modifications & Cost-transfer Requests................................................................. 2
Invoicing of Sponsors .................................................................................................................................. 2
Deposit of Payments .................................................................................................................................... 2
Oversight of Fiscal & Administrative Compliance Issues ....................................................................... 3
Development & Submission of Financial Status Reports......................................................................... 3
Oversight of Level of Effort Reporting ...................................................................................................... 3
Oversight of Closeout Activities ................................................................................................................. 3
Annual Audits .............................................................................................................................................. 4
General Principal Investigator Responsibilities .............................................................................. 5
Award Negotiation & Pre-Award Costs .................................................................................................... 5
Management of the Award ......................................................................................................................... 5
Expenditures During the Life of the Project ............................................................................................. 6
Project Fiscal Management ........................................................................................................................ 6
Project Closeout ......................................................................................................................................... 12
General Procedures for the Fiscal Management of a Grant Award or Contract ...................... 14
Allocable Costs ........................................................................................................................................... 14
Allowable & Unallowable Costs ............................................................................................................... 15
Reasonable Costs ....................................................................................................................................... 15
Expenditures Procedures .......................................................................................................................... 15
Travel Procedures...................................................................................................................................... 15
International Travel Supported by Federal Funding ............................................................................. 16
Meals & Light Refreshments .................................................................................................................... 16
Consultants ................................................................................................................................................. 16
Bid Requirements ...................................................................................................................................... 18
Bid Thresholds ........................................................................................................................................... 18
Memoranda of Agreement ........................................................................................................................ 18
Stipend Payments ...................................................................................................................................... 20
Payroll Action Form (PAF) ...................................................................................................................... 21
Student Employees .................................................................................................................................... 22
Graduate Service Appointments (GSA) .................................................................................................. 23
Employees with Official Work Stations in Other States ........................................................................ 23
Insurance Eligibility for All Temporary Employees .............................................................................. 23
Level of Effort Reporting .......................................................................................................................... 23
Ownership & Control of Equipment ....................................................................................................... 23
Indirect Cost Recovery (ICR) ................................................................................................................... 24
Project Over Expenditures and Unallowable Costs ............................................................................... 25
Closing the Grant Index ............................................................................................................................ 25
Program Income ........................................................................................................................................ 26
Revised 12/13
General Procedures for Project Monitoring & Reporting ........................................................... 27
Signature Authority................................................................................................................................... 27
Record Keeping.......................................................................................................................................... 27
Subcontractors (Sub-awards) ................................................................................................................... 27
Financial Reports (Banner Finance System) ........................................................................................... 27
Animal Care & Use Protocol Review Compliance (IACUC) ................................................................. 45
Protection of Human Subjects Compliance (IRB) .................................................................................. 45
Investigator Significant Financial Interest Disclosure ........................................................................... 45
Records Retention...................................................................................................................................... 45
APPENDIX: Level of Effort Reporting ........................................................................................ i-ix
Revised 12/13
General Post-Award Office Responsibilities
The function of the Post-Award area within the Office of Grant and Research Development
(OGRD) includes overseeing the financial administration of externally funded grants and
contracts received by EWU. (Incidentally, Academic Affairs oversees the financial
administration of internally funded grants, such as the Faculty Research Grants.) Some of the
OGRD responsibilities include:
Receipt of an Award (Signature Authority)
The Associate Vice President of Business and Finance has the Board of Trustees’ authorization
to accept awards on behalf of EWU. All sponsored awards must be processed by the OGRD to
be reviewed and accepted on behalf of the university. Any Notice of Award (NOA) or
agreement documents that are sent directly to the PI should be sent to the OGRD immediately
upon receipt. The OGRD reviews all terms and conditions of an award and assures the
sponsor’s requirements are compatible with applicable laws and EWU’s policies and
procedures. Since a sponsored award binds both the sponsor and EWU to certain contractual
commitments, it is important that the terms are clearly understood and that all concerns are
resolved before the award is accepted. Most awards require the signature of an authorized
institutional official to formally accept the terms and conditions of the award. The OGRD is
responsible for obtaining the authorized institutional signature of the Associate Vice President
of Business and Finance. PIs are cautioned not to sign any agreements for sponsored support,
patents or copyright licenses, biomaterials, equipment loans, work for hire, confidential
disclosure agreements, materials transfer, or event subcontracts. These agreements bind the
university to certain obligations and, as such, can be signed only by the Associate Vice
President of Business and Finance or in some cases, the Purchasing Department.
Establishment of Sponsored Indexes
Once an award has been accepted for the university, exclusive index and fund numbers are
established for each new contract or award, against which obligations and expenditures will be
charged. The use of the awarded funds is restricted to the sponsor-approved project budget and
the terms and conditions of the award. The PI will receive written notification of the index
number, fund number, organization number, program number, and grant number assigned to
their award. The award identification numbers will also be sent by the OGRD to the Purchasing
Department. The Purchasing Department will send a signature card out and contact the PI to set
up the approval queue for electronic purchase requisitions.
Approval Queue
For new grant indexes, the Purchasing Department will determine if a grant approval queue has
been established for the Banner organization in which the grant resides. The Purchasing
Department will update the fund in that queue and notify the approver or primary finance person
for the area. If an approval queue has not been established for the organization, the Purchasing
Department will verify whether the Project Director has access to the Banner Finance System.
If the PI does not have access, the Purchasing Department will contact the College or
Department finance personnel to determine how requisitions approval will be handled, either by
the PI or the College or Department finance personnel.
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Providing Orientation and Training to Project Directors or Principal Investigators in the
Financial Administration of the Award
Once an award has been accepted by the university and the index number is established, the
OGRD will contact the PI in writing to schedule an orientation meeting. It is equally important
for new and experienced PIs, along with any other personnel responsible for assisting the PI in
fund management, to attend the orientation session as terms and conditions, reporting
requirements, project and budget modification requirements, and procedures will vary with each
award and each sponsor.
Approval of Budget Modifications and Cost-transfer Requests
The OGRD staff assist with monitoring budgets, budget modifications, cost transfers, and
expenditures against grant and contract accounts for compliance with university, state, federal,
and sponsor guidelines to ensure policies are consistently applied. In many cases, sponsors have
granted the university the ability to approve some budget changes between budget categories
that are less than 10% of the overall budget. In other cases, a budget revision will need to be
approved by the sponsor in writing. The OGRD will review and approve all requests to
sponsors for budget revisions and modifications prior to submission to the sponsor.
Additionally, the OGRD must review and approve all transfer of costs and budget modifications
signed by both parties.
Invoicing of sponsors/ initiating the submission of cash drawdown for federal awards
The OGRD staff prepares invoices quarterly, monthly or as required in the Notice of Award or
contract. Occasionally, the OGRD staff will need to work closely with the PI to determine the
nature of expenditures for proper identification on invoices. When an award is “Firm-Fixed
Price” the OGRD will usually invoice in four quarterly equal dollar amounts with the last
invoice dated when the project is complete. When an award is “cost reimbursement;” meaning
the university is reimbursed after expenditures are paid, the OGRD will invoice either by the
frequency designated in the award documents or on a regular basis based on the flow of
expenditures posting to the index, typically on a monthly basis. In some cases, funds are
transmitted electronically to EWU from the funding agency. The General Accounting Office
will coordinate with the OGRD to submit electronic cash drawdown requests.
Deposit of payments
All checks and payments on agreements are mailed to:
Student Financial Services/ Office of Grant and Research Development
Eastern Washington University
202 Sutton Hall
Cheney, WA 99004-2448
In the unlikely event the PI receives a payment from a sponsor, the PI should deliver the check
to the Cashier’s office located on the 2nd floor of Sutton Hall immediately with instructions for
the Cashier’s office to call the Office of Grant and Research Development to obtain information
needed to make sure it is deposited in the correct index, fund, and account number.
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Oversight of Fiscal and Administrative Compliance Issues Relative to Fiscal and
Administrative Management of Funded Projects.
The OGRD staff assist in monitoring budgets, budget modifications, and all expenditures
against grant and contract indexes for compliance with university, state, federal, and sponsor
guidelines to ensure policies are consistently applied. Each expense charged to the index must
be directly related to the project, must be allowable under the terms and conditions of the award,
and must be included in the sponsor-approved budget. All paperwork and documentation for
expenditures must be sent to the OGRD office for approval/signature before being paid;
including, but not limited to, Payroll Action Forms (PAF), purchase requisitions, Memorandum
of Agreements (MOA), invoices, and travel authorizations. The OGRD staff will review the
paperwork and the index’s budget to ensure the expenses are included in the budget and review
the Banner accounting system to verify adequate funds are available at that time of the expense.
If there are questions, concerns, or missing paperwork the PI will be contacted immediately;
however, expenses charged to the index are still the direct responsibility of the PI, not the
OGRD.
Development and Submission of Financial Status Reports to Sponsors
The OGRD staff is available to assist in all financial reporting requirements of the project
including progress reports and final reports. It is essential the PI provide the required forms to
the OGRD staff to facilitate timely completion of the forms. Federally funded awards usually
require the OGRD to prepare and submit annual Financial Status Reports (FSR 269 or Federal
Financial Report FSR 425) at the end of each year of the award or as required in the Notice of
Award or Grant Agreement. A copy of all completed Financial Status Reports will be provided
to the PI as they are prepared. The PI must assist the OGRD in completing final financial
reports by providing any information requested by the OGRD in a timely manner.
Oversight of Level of Effort Reporting
All federally funded grants, including grants funded with federal pass-through funds, require
monthly Level of Effort reports to be generated and signed by the employee and the PI working
on the grant. The OGRD prepares all of the Level of Effort monthly reports, named the
“Personnel Activity Report,” on federally funded projects and sends them out for signature.
These reports are generated and issued one to two months after the date payroll was paid by a
federally funded grant. They must be reviewed, signed, and returned to the OGRD for further
processing and reporting. Please note that the Department Chair or Dean must also sign the
Level of Effort reports for the PI’s effort.
Oversight of Close-out Activities, including Transferring of Residual Funds
The close out reporting process is a multi step process that includes OGRD working directly
with the PI and/or their support staff to accurately report the final financial status of the project.
The PI’s tracking spreadsheet and the current Banner index reports should be compared to
determine if all expenses have posted to the index. If there are expenses that have not posted,
copies of the documents submitted for payment along with a spreadsheet listing the outstanding
expenses must be submitted to the OGRD post-award staff member working to submit the final
invoice. All discrepancies between the PI’s records and the Banner index must be substantiated
with appropriate documentation in order to reconcile the index. Nearly every contract or grant
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requires a final financial statement to be submitted with the PI’s final program report or with the
final invoice. A copy of the PI’s final program report must be submitted to the OGRD.
When the final payment from the sponsor is received, the OGRD staff will review the Banner
accounting reports to make sure the index is at $0 cash balance and all expenses included on an
outstanding expense list have posted to the index. If additional expenses were posted to the
index, they must be transferred out of that index before it can be closed. No encumbrances
against the index should be showing at this time. If there are encumbrances, they must be
resolved and deleted. The OGRD will discuss any questions with the PI and close the index
when the cash balance reaches $0.
If the index is for a “Firm-Fixed Price” contract and there is a positive cash balance, the
remaining indirect costs budgeted will be distributed according to the university’s indirect
distribution policy if they are equal to or greater than $100. The remaining balance is then
distributed to the PIs indirect cost recovery index/fund.
Annual Audits
The State of Washington conducts annual audits of the University and all grants and contracts
are included in this audit. Any grant or contract is subject to an in-depth review by state
appointed auditors. The OGRD coordinates all external audits with the PI and other university
units, as appropriate. Should a PI be contacted regarding a records request directly by an
external agency, please refer them to the OGRD immediately. The OGRD will provide all
necessary information.
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General Principal Investigator (PI) Responsibilities
The Project Director (PD) or Principal Investigator (PI) is the primary individual in charge of a
grant, contract, cooperative agreement, or other externally sponsored activity. The term “project
director” is commonly used in relation to education and public service projects or programs,
while the term “principal investigator” is commonly used for research projects. Since the terms
are generally used interchangeably by the Office of Grant and Research Development (OGRD)
staff and by many sponsors, the term “PI” is used throughout this document to mean principal
investigator or project director.
In some cases, multiple investigators (Co-PI) are named in applications for external funding.
However, agencies and the university require that one individual be designated as the principal
investigator since both the agency and the university must have one individual designated as
ultimately responsible for the conduct of the project. If co-investigators are named on an
application without identifying an individual as the PI, the person listed first is considered the PI
by the university and the agency.
The National Science Foundation (NSF) has clarified their definition of a Principal Investigator
to state that regardless of what an investigator is called, there is no distinction between the
“scientific stature of PIs,” regardless of whether they are called a PI or a co-PI. All will be
equally responsible for the project, but the first name listed will be the contact PI for the NSF.
Award Negotiation/Pre-Award Costs
The PI negotiates any requested changes to the proposed scope of work and budget with the
sponsor in collaboration with the OGRD. If the sponsor requests budget changes, the PI must
obtain the approval of the OGRD before submitting a revised budget to the sponsor. Some
funding agencies may grant limited pre-award expenditures if prior approval is obtained.
However, PIs should note that such approvals are allowed by the OGRD with the understanding
that the PI’s department assumes all risk associated with the establishment of an index prior to
receipt of an award notice from the sponsor. If the award is never received or if the effective
date of the award falls outside of the agency-allowed pre-award period, the PI and his or her
department and/or college will be responsible for all costs incurred.
Management of the Award
The PI is responsible for the proper conduct of the work (performance of the project activities)
and for the administrative and financial management of the project. The OGRD staff assists the
PI with administrative and financial management of the award. While the university is the legal
recipient of awards and ultimately is legally responsible to the sponsor for the performance of
the funded activities and the proper use of sponsor funds, the university cannot meet its
responsibilities to the sponsor unless the PI meets his/her responsibilities. Only the PI can truly
know if expenses charged to a grant or contract index/fund are legitimate, project-related costs.
Only the PI can assure performance of the technical aspects of the project and completion of
sponsor-required technical reports. The university is responsible for maintaining adequate fiscal
controls and ensuring that fiscal policies are applied consistently. Therefore, management of
externally funded projects is truly a partnership between the PI and the OGRD.
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Expenditures During the Life of the Project
This handbook describes various types of expenditures, which may be included in the project
budget and the processes for the expenditure of the funds. PIs are encouraged to develop a
spreadsheet for tracking the expenses approved for payment and update it every month after the
Banner accounting system month-end close. Month-end close occurs around the tenth of the
following month.
Project Fiscal Management
The PI is responsible for complying with all the financial terms and conditions of the award.
This includes ensuring that costs are correctly charged to the index according to the sponsorapproved project budget and the terms and conditions of the award. Each expense charged to
the index must be directly related to the project, must be allowable under the terms and
conditions of the award, and must be included in the sponsor-approved budget. Any questions
concerning the allowability of costs should be directed to the OGRD staff prior to incurring the
cost. The OGRD staff can assist the PI in determining if the cost is allowable under the current
budget or if a budget revision is required. The PI is ultimately responsible for all costs charged
to their index. While the PI may delegate some responsibility for the day-to-day management of
finances or other tasks to departmental business staff, the PI remains accountable for
compliance with university and sponsor requirements. Such designated employees need to be
included on the signature card and the signature card must be submitted to the Purchasing
Office. If the original signature card has already been sent to Purchasing, an additional card
may be obtained and the designee can sign the card and send it to Purchasing. The PI must
attend Banner Basics, 201, and 204 training in order to monitor the index activity and generate
financial reports. Training sessions may be scheduled online at
www.ewu.edu/trainingscheduler.
Ultimately, the PI and the PI’s unit are responsible for any over expenditures or any costs that
are determined to be unallowable by the sponsor, OGRD, or auditors. It is therefore incumbent
upon the PI to carefully monitor all expenditures charged to his/her indexes and to implement
whatever processes are necessary to ensure compliance with the terms and conditions of the
award. To accomplish this, it is recommended that the PI require that he/she or his/her designee
approve all project-related expenses in advance of the expenditure.
1. Personnel Costs: The major expenses in most projects are personnel costs. The PI has
the responsibility to initiate the preparation of a Payroll Action Form (PAF) for
him/herself and for other non-student personnel paid by the grant or contract. Most
departmental and college support staff are familiar with the preparation of PAFs and
may have the responsibility of preparing them for the personnel within their
departments. PAFs should always be prepared prior to or at the beginning of a project or
personnel related task.
PAFs for faculty are generated at the departmental or college level and all positions are
assumed to be “in load” and part of the faculty’s regular appointment unless the grant or
contract budget specifies the effort as overload or summer salary. As a general rule,
faculty may not work beyond 34% overload.
Rev. March 24, 2016
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The staff in the Office of Human Resources, Rights and Risk prepare PAFs for all
classified and administrative exempt employees. If the classified or administrative staff
person being hired for the position on a grant or contract is currently a University
employee, the PI must write a memorandum or send an email to Human Resources
explaining the facts relating to their employment on the grant. The memo must contain
start and end dates of employment on the grant, the index number(s) to which the salary
is to be charged for all duties, the percentage of time to be applied, and the rate of pay.
There may be multiple index numbers for an individual working on more than one job.
The total percentage of time must equal 100% for a full time position when the
percentages of time allocated to each job are totaled. In most cases the rate of pay must
be consistent with their current rate of pay. If a classified staff person from a different
department is needed to work on a grant project, written permission must be obtained
from their department chair and identified as to whether the person will be performing
the activities during their cyclical leave.
If the position is a new position, the PI should contact the Office of Human Resources
about recruitment and hiring procedures. Grant and contract funding does not give the
PI the flexibility to by-pass university policies and procedures concerning new
employment. Requests for new positions are submitted through an online portal called
PeopleAdmin, and Human Resources will provide the necessary access information and
instructions for PIs to enter positions into PeopleAdmin. PIs should keep in mind that
any costs for recruitment (i.e., advertising, travel expenses for candidates brought in for
interviews, background checks, etc.) generally must be borne by the grant or contract,
but those costs cannot be incurred prior to its start date. Note: for grant-funded
positions that are part of the division of “Academic Affairs,” the relevant Dean’s office
may assist the PI with the PeopleAdmin processes.
If an existing grant-funded position is re-defined in a grant renewal to take on new or
additional duties, and if additional salary is budgeted and approved in the grant for that
position, the university policies and procedures must also be followed to put the changes
into effect. No grant-funded employee is guaranteed an increase in salary that is
included in the grant, unless the relevant position is determined to be eligible for the
increase under university policies and procedures. Contact the Office of Human
Resources for guidance on how to modify duties for a grant-funded position and to
determine if the modified position is eligible for a salary change. Note: although a
position may be budgeted in a grant renewal for additional duties and additional salary,
the effective date of those changes will not be determined until after the position is
modified and re-examined by Human Resources for the salary consequence. Salary
changes may not be applied retroactively to the date of the grant renewal.
Termination of employment of administrative exempt staff or classified staff due to nonrenewal of a grant, or due to a decline in grant funding for the affected position, must be
processed in accordance with university policy and practice, and the relevant bargaining
unit contract (if applicable to the affected position). As a result, any layoff actions
require advance notice to the Office of Human Resources:
·
For classified positions, a minimum of 45 days advance notice is required. For
example, if grant funding for a classified position ends on 9/30/20xx, then you must
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contact Human Resources to seek assistance with the layoff process no later than
8/15/20xx. This advance notice is required because the affected classified staff person
must be given 30 days advance written notice of the impending layoff action, and
Human Resources requires at least 15 days preparation time. Remember – classified
staff are covered under a bargaining unit contract, and lay off of classified grant funded
employees must comply with both the relevant terms of the contract and university
policy and practice.
·
For administrative exempt positions, the affected employee who will be laid off is
not given 30 days advance notice. Instead, the employee is given 30 days severance
payment. Additionally, the employee’s accrued unused vacation leave will be cashed
out to him/her at the end of their employment. A minimum of 14 days advance notice
must be given to Human Resources, to allow for preparation of the severance check as
well as other required preparations.
PAFs and Request to Fill/Change forms must be signed by the PI, or other persons with
designated budget authority, and the Dean of the College before being routed through
the OGRD for signature with sufficient lead-time for routing and processing prior to the
start date of the appointment.
PIs are encouraged to contact the Office of Student Employment (SEO) at 509.359.2525
to first determine if the skills required by an open part-time or temporary position are
suitable for students. Open student positions must be advertised (i.e. posted through the
Office of Student Employment) for at least 48 hours. Under special circumstances, it
may be possible to hire a specific individual for an open position if the position requires
specialized skills and/or experience held by that individual. These cases require a
written explanation and approval by the Office of Student Employment. Additional
information is available at http://access.ewu.edu/Student-Employment.xml
Non-work study students must apply on-line to the PI’s department through EagleAXIS
utilizing the On Campus Application. They are required to attend a Student
Employment Workshop and complete their hiring paperwork with SEO prior to starting
work. The PI and the student must complete and sign the On Campus Non Work Study
Requisition located in the Document Library in EagleAXIS. The PI will access this
document in the Document Library as students do not have access authorization (keep a
copy for the departmental records).
Work study students must also apply on-line to the department through EagleAXIS
utilizing the On Campus Application. At the required Student Employee Workshop, the
student will receive a work study authorization memo to provide to the PI that verifies
eligibility. This authorization memo needs to be returned to SEO with the On Campus
Work Study Requisition (keep a copy of both for the departmental records).
When new or existing students are to change time to new indexes, the PI should email
the following information to the Student Employment Office: 1) the student’s name and
ID number, 2) the index to be added along with the start and end dates, 3) the
individual’s job title and rate of pay, and 4) the supervisor’s name and timesheet
approver’s name. Generally, five days are needed to complete this process, as the
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Student Employment Office must request position numbers from Budget Services.
To comply with federal regulations, the university has implemented an after-the-fact
time and effort reporting system (see Appendix for full discussion) to verify that all
personnel costs charged to federally funded indexes are appropriate based on the actual
time and effort spent on the project. The purpose of the time and effort report is to
document the percentage of time that each employee being paid from a federal grant is
working per designated indexes. The PI is responsible for certifying all time and effort
charged to the designated index. The University’s Level-of-Effort Report must be
completed and returned to the OGRD on a monthly basis. If the time actually spent on
the project differs from the time for which the staff person was paid from the project, the
PI must contact the OGRD to determine whether a revised PAF needs to be prepared or
a correction to the percent of effort shown on the Personnel Activity Report needs to be
made before returning it to the OGRD.
2. Purchase Requisitions, Memoranda of Agreements (MOA), and Travel Authorizations:
All planned expenses have University forms that need to be completed in advance of
making the expenditure. Forms need to be routed to OGRD for authorizing signature
after the PI signs them. The OGRD will then forward the forms on to the appropriate
department. The PI should always keep a copy of every form, invoice, and documents
for reference. It should be noted that invoices or reimbursements, on average take 30
days to be paid. The PI must generate online purchase requisition forms for all supplies
and equipment needed and submit invoices for payment when the items are received. If
the payment is in the form of a reimbursement, the original receipt(s) must be submitted
with the purchase requisition form to the OGRD. When a department procurement card
is used to purchase items, the Monthly Detail Statement form must be generated and
must designate the index for each charge and be routed to the OGRD for authorizing
signature. An MOA must be generated to contract for services provided by a nonuniversity employee that cost less than $10,000. Go to EWU
home>Administration>Business & Administration>Contract Services to find the
guidelines for generating Memorandum of Agreements under the title, “Instructions.”
The contractor’s/consultant’s travel costs may be included on the MOA. The
consultant/contractor must invoice for partial or full payments for work done during the
time period the MOA is in effect. The PI must sign, date, and write “ok to pay” on the
invoice. The invoice must include the index number and Purchase Order number to
ensure payment from the proper index.
Travel Authorization forms must be approved prior to travel. All University travel
needs to have prior approval and is documented using a “Travel Authorization” Form
(TA). Usually university departments have a designated employee who creates the TA
form for all employees in their area. Each form is assigned a unique number for
identification within the department. The department staff person may have a worksheet
to complete to get the details of one’s trip. The traveler will need to make their hotel
reservation and reserve it with a personal credit card. Ask for an email confirmation and
turn in a print out with your travel worksheet. If the hotel room rate is higher than
government lodging rate but it is the lowest in the vicinity of the event the traveler needs
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to complete a “lodging exception” form, which can be found at EWU
Home>Administration>Business & Administration>Travel>Travel Forms. Artistic
Travel Agency is used to book all university airline and rental car reservations. Once a
TA is prepared, the traveler may receive a travel advance of funds up to the amount
listed in box 6 for per diem. The desired dollar amount needs to be written in on the
blank line at the top of box 8 and then the traveler signs in this box. The supervisor,
budget authority, grants office, etc. will sign in box 9. The travel advance check will be
mailed to the traveler a week prior to the travel with instructions attached. The traveler
does not need to keep receipts for food; however, for parking, gas, shuttle, taxi fares etc.
it is recommended that receipts be maintained and it is required for any expense greater
than $50. After travel is complete, the bottom portion of the TA form is completed and
employee signs again in the “Certification” box. The department staff will let the
traveler know if any of the travel advance funds need to be returned to the university.
Instructions on how to go about this will be included with the check. The budget
authority, grants office, travel accounting and accounts payable will all sign in the box
below as the form goes through its processing.
To procure food for meetings where meals are provided, a Light Meals and
Refreshments Form must be completed. This form must be signed by the PI and
attached to a purchase requisition or to an Event Planning Interdepartmental Purchase
Order (IDPO) along with a meeting agenda and list of meeting attendees and forwarded
to OGRD. The Light Meals and Refreshments Form can be found at EWU
Home>Administration>Business & Administration>Travel>Meals and Light
Refreshments. In all cases, federal per diem guidelines must be followed. Per diem
information may be found at EWU Home>Administration>Business & Administration>
Travel> Per Diem Rates (meals and lodging).
The State of Washington governor or legislature may issue special regulations restricting
expenditures at any time. Grants and contracts must comply with these regulations,
regardless of the source of funding, or be deemed exempt. Please check with the OGRD
Post-award Staff regarding these special conditions.
When making purchases from university departments; such as, the MARS Lab or EWU
Print Services, an Interdepartmental Purchase Order (IDPO) Form must be completed.
Normally, the department making the purchase is responsible for preparing the IDPO.
The index and fund numbers must be included on the form and the other department
from which the purchases are made will complete the form and forward it to OGRD for
authorizing signature. The PI must sign the form to indicate the items purchased have
been received.
3. Expense Transfers: If costs were charged to the index in error, a determination as to the
appropriate index to which the expense should have posted must be made. A journal
voucher entry (JVE) must be prepared indicating to which index the expense was
incorrectly posted and to which index the expense should be posted. The OGRD will
assist in generating this form and obtaining the needed support documentation, if
necessary. The PI must send an email message (or other written documentation) to the
OGRD post-award staff member authorizing the transfer of the expense. The written
authorization must include documentation supporting the expense, such as the Detailed
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Transaction listing (FGRODTA) generated by the Banner Finance System showing the
expense as posted. If a JVE is generated within the PI’s department, the expense
transfers should be submitted to the OGRD for approval within sixty (60) days of
incurring the cost. Should a delay in identifying a missed charge occur past 60 days; the
correction should be made immediately upon the identification of the error. Conversely,
expense transfers are also necessary if an appropriate grant/contract expense is charged
to another index in error. The expense must be transferred to the correct grant/contract
index. Should the OGRD identify a pattern of inappropriate charges necessitating large
numbers of expense transfers, the PI will be contacted to discuss modifications to the
PI’s procedures to ensure expenses are charged appropriately from the onset.
4. Monitoring Sub-contracts: If the project includes subawardees (contractors), the PI is
responsible for working with OGRD Pre-Award staff to generate sub-contracts for
signature and is responsible for reviewing all invoices submitted by the subawardee and
determining that all costs are appropriate and allowable. Payment of subawardee
invoices is tied to the subawardee’s performance in meeting the goals outlined in their
scope of work. Once the PI has determined the charges are appropriate, the work has
been done, and approves the invoice; the OGRD staff will process it for payment. The
PI must review all such invoices in a timely manner so the university can meet its
obligation to pay the subawardee in a timely manner. The PI must sign, date, and write
“ok to pay” on the invoice. The index number and subcontract number must appear on
the invoice to ensure payment from the proper index.
5. Cost Sharing/Matching: It is the PI’s responsibility to document all cost sharing
associated with the project. This includes timely submission of “GRANT MATCH --Cash Expenditure Contribution” forms provided by the OGRD to document hours
worked on the project each month. If the PI is using a percentage of the salary paid by
another index as match, a “COST SHARING EFFORT INQUIRY REQUEST” must
be provided to OGRD with the Banner index number for all university cost sharing
committed to the project. OGRD will prepare monthly Personnel Activity Reports and
send them to the employee for signature. The PI also verifies the information, signs, and
returns the forms to OGRD. Cost sharing must be documented as it occurs – the PI
should not wait until the project is nearing the end date to start documenting cost
sharing.
When cost-share or matching requirements are included in the award budget, the PI is
responsible for obtaining documentation from collaborative partners who provide
services or supplies. If student time is used as match, copies of their time sheets may be
used as documentation of time worked. When volunteer time is used for matching, each
volunteer must sign in on a sheet listing time spent. The dollar amount to be attributed
to a volunteer’s time is determined by using the state authorized volunteer wage. The
hourly rate may be increased if sufficient documentation is provided to support that the
specific volunteer holds special skills that would be reimbursed at a higher rate.
Copies of all documentation must be submitted to the OGRD as cost sharing/ matching
funds are subject to audit to the same degree as grant and/or contract funds expended.
6. Budget Revisions: Because the budget approved by the sponsor was an estimate based
on the PI’s knowledge at the time of the application, it is not uncommon for PIs to
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determine, once the project is underway, that the budget needs to be modified to reflect
changed circumstances. The PI should contact the OGRD as soon as he/she determines
modifications of the sponsor-approved budget are needed. In many cases, sponsors have
granted the University the ability to approve some budget changes between budget
categories that are less than 10% of the overall budget. In other cases, a budget revision
will need to be approved by the sponsor in writing. The OGRD will review and approve
all requests to sponsors for budget revisions prior to submission to the sponsor. The
OGRD must review and approve all transfer of costs and facilitate a budget modification
signed by both parties.
7. Co-Mingling of Funds: The use of the funds in a grant and/or contract index is restricted
to the sponsor-approved project budget and the terms and conditions of the award.
Under no circumstances may funds or expenditures for a specific project be commingled
with any other index even if unexpended funds remain at the end of the project.
Project Closeout
The PI is responsible for preparing and submitting the final technical report to the sponsor
according to the schedule outlined in the award. A copy of all technical or programmatic
reports during the life of the award, including final reports must be provided to the OGRD.
Approximately 100 days prior to the end of the grant period, the PI should review the budget
and compare it with actual expenditures and determine whether or not the performance of the
funded activities will be completed by the end of the grant period. If additional time is needed,
the PI should contact the OGRD well in advance of the project end date to discuss requesting an
extension of the project. In some cases, sponsors have delegated authority to the university to
grant a one-time, no-cost extension. If the university can approve the extension, the OGRD
staff will direct the PI to prepare and submit a request for the no-cost extension. If the extension
request must be submitted to the sponsor, the OGRD will coordinate the request with the PI.
The OGRD staff will prepare and submit the final financial report and final invention and
property reports, if required. The PI must assist the OGRD in completing final fiscal reports
and final invention reports by providing any information requested by the OGRD in a timely
manner.
Initially, the PI’s tracking spreadsheet and the current Banner Accounting reports should be
compared to determine if all expenses have posted to the index. If there are expenses that have
not posted, copies of the documents submitted for payment along with a spreadsheet listing the
outstanding expenses must be submitted to the OGRD post-award staff member working to
submit the final invoice. All discrepancies between the PI’s records and the Banner index must
be substantiated with appropriate documentation in order to reconcile the index’s expenditures.
If expenses are not on this index’s Banner reports but should have posted some time ago, it is
necessary to find copies of the paperwork and determine if an incorrect index code was used and
the expense posted to another index or if it is being held up for more information by another
department. The OGRD post-award staff will generate the paperwork needed to move the
expense with the PI’s approval. Internal expenses such as telephone, postage, and copier
charges usually post one month after the charges occur. It is important to estimate these
expenses and include them on the final invoice if they have not posted to the index by the final
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invoice due date. It is important to note that long distance telephone charges may lag by one to
three months before they are posted to an index.
If PAFs or timesheets are not changed to different Indexes after the ending date of the award,
additional paperwork must be completed to move the charges to another allowable index. If this
occurs the OGRD post-award staff will assist in guiding the PI as to who needs to be contacted
to make this transfer.
Another step in the process is for the PI to review whether there are any “commitments or
encumbrances” listed on the index’s Banner accounting reports. If there are open purchase
orders, they will be listed on the reports and must be closed out in order to close out the index.
For all Purchase Orders, Memorandums of Agreement and subcontracts, email Bill Santiago in
Purchasing with the PO or C number and request that it be closed. For all travel authorizations,
email Travel Accounting and request that it be closed.
It is a condition of the award that all required reports be submitted to the sponsor according to
the schedule provided in the award documents. Failure to submit reports in a timely and
acceptable manner can result in the rejection of pending proposals without consideration and
withholding of final payment. It also puts in jeopardy the faculty member’s and the university’s
eligibility for future grant opportunities. It is therefore incumbent upon the PI to make sure all
reports are completed and submitted to the sponsor on time. Any costs disallowed by the
sponsor due to the PI’s failure to submit required reports according to the sponsor’s schedule
will be the responsibility of the PI, department, or the PI’s unit head (dean or center director).
Procedural guidance, references and links to applicable policies, and detailed information about
various Banner INB financial reports for PIs follow in the next sections of this handbook.
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General Procedures for the Fiscal Management of a Grant Award or
Contract
The receipt of a grant or a contract in no way constitutes authorization to circumvent any
university policy or procedure. In fact, externally sponsored projects are closely regulated and
audited for compliance with university, state, federal, and sponsor guidelines. Each expense
charged to the index must be directly related to the project, must be allowable under the terms
and conditions of the award, and must be included in the sponsor-approved budget. The State of
Washington conducts annual audits of the university in accordance with OMB Circular A-133
(referenced below) and all grants and contracts are included in this audit. Any grant or contract
is subject to an in-depth audit by state appointed auditors.
The Federal government’s cost principles for educational institutions must be used to guide all
costs incurred for sponsored projects and research; including all activities sponsored by Federal
and non-Federal agencies and organizations.
The Office of Budget Management (OMB) continually updates and describes these principles in
great detail at http://whitehouse.gov/omb/circulars/

2 CFR Part 220 (OMB Circular No. A-21)- Cost Principles for Educational
Institutions.

2 CFR Part 215 (OMB Circular No. A-110)- Uniform Administrative Requirements
for Grant Agreements With Institutions of Higher Education, Hospitals, and Other NonProfit Organizations.

OMB Circular No. A-133- Audits of States, Local Governments, and Non-Profit
Organizations.
The State of Washington Office of Financial Management’s (OFM) accounting policies and
procedures will be followed in the financial administration of all grants and contracts. If the
sponsor’s accounting procedures conflict with those of OFM, the OFM policies and procedures
will be applied.
Links to the OFM accounting policies and procedures are available on the EWU Website at
EWU Home>Administration>Business & Administration>Auxiliary & Business
Services>Purchasing. Then view External Websites listing for Washington State Office of
Financial Management.
Allocable Costs
All costs must be reasonable, allowable, and allocable to a specific sponsored agreement.
According to 2 CFR Part 220 (OMB Circular A-21), a cost is allocable to a sponsored
agreement if it is incurred solely to advance the work under the sponsored agreement. Further,
it should benefit both the sponsored agreement and the other work of the institution in
proportions that can be approximated through the use of reasonable methods.
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Allowable and Unallowable Costs
OMB Circular A-21 states the federal government definitions and examples of allowable and
unallowable costs.

Examples of Allowable Costs: Direct costs related to the specific scope and objective of
the project; such as, personnel, communication costs, operating supplies and materials,
travel, equipment, and similar costs.

Examples of Unallowable Costs: Alcoholic beverages, bad debts, traffic tickets, alumni
activities, commencement costs, decorations, donations and contributions, entertainment
costs, and lobbying costs.
Reasonable Costs
A cost may be considered reasonable if the nature of the goods or services acquired or applied,
and the amount involved, reflect the actions a prudent person would have taken under the
circumstances prevailing at the time the decision to incur the cost was made. In other words,
apply the “front page of the newspaper” test: would a prudent person consider this a reasonable
expense or use of public funds?
Expenditures Procedures
The PI should review the budget for allowable costs and identify any items that may require
modifications. All expenditure documents such as Payroll Action Forms (PAFs), Travel
Authorizations (TAs), Hiring Recommendations, and others must be approved and signed by the
PI and forwarded to the OGRD for budget verification. If these documents are prepared
electronically, they will be processed electronically using the appropriate approval queues.
Travel Procedures
Regardless of the grant or contract guidelines, all travel must comply with the State of
Washington approved rates unless federally allowed rates or funding agency rates are less
than the state rate. In the case of lower federal rates, the federal rates will apply to
federal grants or contracts. For a complete discussion of EWU's travel regulations refer
to the EWU Office of Travel webpage: EWU Home>Administration>Business &
Administration>Travel or you may contact them by phone at 509.359.2249.
PIs are responsible for the information contained in the “Employee Travel Guide” link
under “How to Travel” on the EWU Office of Travel webpage. You will find
information on the following:
 State Travel Policy
 making reservations
 travel authorization procedures
 travel advances
 reimbursement of transportation expenses
 subsistence and lodging rules and rates
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 meals and light refreshments guidelines
 instructions on how to complete travel authorization and expense voucher forms
Any and all travel allowed by a grant or contract must be approved by the OGRD prior to
being sent to Travel Accounting. The individual travelling must complete the appropriate
travel authorization form, secure the signature of the PI and department approval, and
forward the form to the OGRD. If the PI is travelling, his/her department chair must also
sign the form to approve the travel prior to forwarding to the OGRD.
International Travel Supported by Federal Funding
The Fly America Act of 1974 requires that U.S. flag air carriers will be used to transport
personnel and property when costs are charged directly to a grant or contract. This
includes air transportation to, from, between, or within a country other than the U.S.
when U.S. flag air carriers are "available" even though:
 comparable or a different kind of service can be provided at less cost by a foreignflag air carrier, and
 foreign-flag air carrier service is preferred by, or is more convenient for, both the
government and the traveler.
If you have a grant or contract that requires international travel, please contact the OGRD
for additional information on the requirements of the Fly America Act.
Meals and Light Refreshments
The Office of Financial Management State Administrative and Accounting Manual Sections
10.40.60-70 and 70.10.10-40 regulate the policy for meals and light refreshments. Generally,
food and refreshments are not an allowed expense to be charged to grants and contracts unless
specifically permitted by the terms and conditions of the grant award. The PI and the
appropriate dean or project director, or vice president must approve the expenditure for meals
and light refreshments for meetings or formal training sessions prior to the event by submitting a
Meals and Light Refreshments form. The PI is responsible for completing a Purchase
Requisition and the Meals and Light Refreshment form prior to the event. A formal agenda,
attendance roster or registration list, and an additional list of non-registered persons attending
the event must be attached and submitted to the OGRD for processing.
The EWU Meals and Light Refreshments Policy can be accessed on the Travel Accounting
website: EWU Home>Administration>Business & Administration>Travel.
Consultants
Consultants are unaffiliated, non-EWU employees who are hired for short duration, usually for
problem solving, evaluation, or to provide specialized technical knowledge or expertise.
Compensation must be in hourly or daily rates. Travel expenses are budgeted separately from
compensation. University employees or students may not be paid as consultants on sponsored
projects.
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Personal services may be provided by subawardees (contractors or consultants). Generally, the
characteristics of personal services are:

Services are professional or technical in nature and meet more specialized needs.
Work is predominantly intellectual and varied.

Work is independent from the day-to-day control of the agency; consultant maintains
control of work methods.

Work requires regular exercise of judgment, discretion, and decision-making;
involves providing advice, opinions, or recommendations; may have policyimplications for agency; often addresses management-level issues.

May require advanced or specialized knowledge, or expertise gained over an
extensive period of time in a specialized field of experience.

Work may be original and creative in character in a recognized field of endeavor, the
result of which may depend primarily on the individual’s invention, imagination, or
talent.

Consultant generally assumes risk of loss if the requirements are not satisfied.
Examples of Personal Services: accounting services, actuarial services, analysis and assessment
of processes, appraisal services, business analysis, guest speakers, grant writing, operational
assessments, statistical analysis, public relations, medical and psychological services,
investigations.
Generally, the characteristics of purchased services are:

Services are more repetitive, routine, or mechanical in nature; following established
or standardized procedures as contrasted with customary and regular exercise of
discretion or independent judgment.

Services contribute to the day-to-day business operations of the agency, rather than
the management or policy side of the agency, and may meet more general needs of
the agency.

Services generally involving completion of an assigned task, rather than an entire
project.

Decision-making and analysis, if required, is more routine or perfunctory in nature.

Services that are generally performed based upon agency discretion.
Examples of purchased services: advertising in newspapers, bookkeeping services, credit card
service, document storage, drug testing and screening (standard tests), engraving service,
environmental monitoring, HVAC system maintenance service, landscaping, linen rental
service, language translation service, vehicle inspection, temporary employment service,
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telephone interview service.
Bid Requirements
Effective July 26, 2009, state agencies and higher education institutions must use Washington
Electronic Business Solutions (WEBS) as Washington’s common vendor registration and bid
notification system. Both formal and informal competitive solicitations need to be posted on
WEBS by EWU’s Purchasing Office. You may contact Purchasing for assistance on the
quoting process.
Bid Thresholds Purchases up to $10,000 may be made without competitive bids based on buyer experience and
knowledge of the market. The bidding process applies when a single order exceeds $10,000 or
if annual dollars spent with a particular vendor for repetitive small purchases of similar
commodities exceed $10,000. Goods and services that exceed or are projected to exceed
$10,000 must go through the quoting process to show evidence of competition. A hard copy
purchase requisition must be submitted for goods and services that need to go through the
quoting process. The quoting process does not apply to goods and services that are purchased
against a state contract.
PIs should consult with the Purchasing Department for questions concerning the quoting
process. PIs can also visit the Purchasing Department (http://access.ewu.edu/purchasing.xml) to
obtain other information.
Memoranda of Agreement (MOA)
The PI is responsible for generating Memoranda of Agreements for personal services provided
on a grant or contract by a consultant for an amount not to exceed $10,000. MOAs may be used
for personal services, which exceed the $10,000 threshold provided one or more of the
following conditions are met:
1. The individual providing the services was identified in the grant or contract proposal and
is critical to the successful conduct of the program.
2. The services are critical to the instructional mission of the university.
3. The services are advertised and a bidding process is used to obtain the contractor.
4. The services to be provided are limited in nature and the scope of work does not pose a
high risk or potential liability to the university.
The Memoranda of Agreement is a form-fill .pdf and can be found on EWU’s web site under
Administration>Business & Administration>Contract Services/Everything MOA>Memorandum
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of Agreement (MOA).
The “Contractor Information” section of the MOA (bottom left of form) must be signed by the
contractor in order for payments to be made. The PI must provide an original to the OGRD for
processing at least two weeks prior to the performance of services. Signature authorization on the
MOA by the OGRD indicates that sufficient funds are available in the restricted index and the
services and associated expenses are allowed and allocable to the grant fund. The Purchasing
Department will assign a Banner number to the MOA and one signed copy will be returned to the PI
at the department mail stop indicated by the PI on the MOA.
The PI must instruct the contractor to submit an invoice directly to the PI after services have
been performed. The contractor may submit their own invoice or use the Contractor Invoice
template at http://access.ewu.edu/Accounts-Payable/AP-Forms.xml. It is the contractor’s
responsibility to prepare and submit the invoice. Refer to additional information if a check is to
be prepared and ready on the date of the performance of the services.
When services are complete, the PI must sign the Contractor’s invoice indicating the
authorization to pay the invoice, attach a photocopy of the fully signed MOA referencing the
Banner number, and forward to the Office of Grant and Research Development in Showalter
210 for processing.
Some important things to consider when using an MOA:
1. MOAs on which the contractor is paid in a single payment show as an expense on the
university's accounting system at the completion of services. Therefore, the funds are
not encumbered by the system when the contract is initiated. It is therefore incumbent
upon the PI to commit the funds in their own records so funds are not inadvertently
spent for other purposes. This is especially crucial if the services are provided over a
relatively long period of time.
2. An MOA to be paid in progress intervals must be expensed in one fiscal year. If the
services are provided across fiscal years, a second MOA must be generated for the
second year of services. Eastern Washington University’s fiscal year ends on June 30
for each year.
3. In order for the contractor to be reimbursed for expenses other than direct compensation
(such as travel, mileage, and meal per diem), the PI must complete an A-19 invoice
voucher to forward to the OGRD. The A-19 invoice voucher must indicate the MOA
contract number, a description of the expenses, and the grant or contract index number.
Original receipts must be supplied for expenses (i.e., airline tickets, hotel expenses),
which normally require receipts.
The A-19 must be signed by the individual contractor when there will be a
reimbursement for expenses such as travel mileage and meal per diem that do not
require receipts.
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Reimbursement will only be made at the state or funding agency allowed rates for
mileage, hotels, etc., regardless of the actual cost.
4. Compensation for the performance of services equal to or greater than $600, along with
any expenses included in the total contract amount not specifically identified, will be
reported to the Internal Revenue Service on a 1099 Form as taxable income.
5. Significant expenses, such as airline tickets and lodging may be paid directly on behalf
of the contractor using a Purchase Order. The MOA contract number needs to be
included on the Purchase Requisition and the expenses need to be listed and identified as
being paid by a Purchase Order on the MOA.
6. If additional expenses are not included in the total contract amount and are not paid on a
Purchase Order, then the PI needs to check that they will be paid in addition to the
contract amount on the MOA and identify those expenses and their estimated costs.
Expenses incurred that are not identified on the MOA cannot be reimbursed without a
receipt regardless of whether or not a receipt is normally required.
7. Students may not be paid on MOAs. When working under an MOA, the contractor is
not considered an employee of the university and is, therefore, not covered under
Worker’s Compensation.
Stipend Payments
When payments are made to non-university employees who have participated in a grant
or contract program for purposes other than to provide services (i.e.: classroom teacher)
an A-19 invoice voucher must be prepared, signed by the PI, and forwarded to the OGRD
for processing.
Some important tips to consider when completing the A-19 form:
a) The proper name of the grant or contract program should be indicated in the
agency box.
b) If the checks are to be picked up rather than mailed to the individual
receiving payment, this should also be noted along with the name and
campus extension number of the individual who will be picking up and
distributing the checks to the individuals listed on the A-19 invoice voucher.
The date the checks are to be picked up should be included on the invoice
voucher, if applicable.
c) A brief explanation of the reason for the payment should be provided.
d) The PI or designee should sign and date the agency approval box.
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e) The grant to which the expenditures are to be charged should appear in the
fund and program index columns near the bottom half of the page. The total
dollar amount of all checks to be issued should be entered in the amount
column.
f) When multiple people are receiving stipends, attach to the A-19 invoice
voucher a table (OGRD has a formatted table that can be sent electronically
upon request) listing the following information for each individual who is to
receive payment:
 Name
 Permanent mailing address
 Social security number
 Payment amount
 Column for the Accounts Payable Department to insert the voucher
number used for payment
Depending on the circumstances for which an individual receives a stipend (i.e.,
participation in a class, fellowship award, and student living allowance), the stipend
amount may be reported to the Internal Revenue Service (IRS) on a 1099 Form as taxable
income. If the stipend amount is determined to be subject to Federal income tax, EWU
will issue the recipient a 1099 Form at the end of the year. PIs are advised to contact the
Accounts Payable Department at the time an A-19 invoice voucher is submitted to
determine if the stipends to be paid are reportable to the IRS.
Payroll Action Form (PAF)
The PI has the responsibility to initiate the preparation of a Payroll Action Form (PAF) for
him/herself and for other non-student personnel paid by the grant or contract. Most
departmental and college support staff are familiar with the preparation of PAFs and may have
the responsibility of preparing them for the personnel within their units.
PAFs for faculty are generated at the departmental or college level, while the staff in the Office
of Human Resources, Rights and Risk prepare the PAFs for all classified and administrative
employees. Blank PAF forms can be requested from the Office of Human Resources, Rights
and Risk. If the classified or administrative person being hired for the position on a grant or
contract is currently a University employee, the PI must write a memorandum or send an email
to Human Resources explaining the facts relating to their employment on the grant. The memo
must contain the inclusive dates of employment, the index number(s) to which the salary is to
be charged against for all duties, the percentage of time to be applied, and the rate of pay. There
may be multiple index numbers for an individual working on more than one job. The total
percentage of time must equal 100% for a full time position when the percentages of time
allocated to each job are totaled. In most cases, the rate of pay must be consistent with their
current rate of pay.
If the position is a new position, the PI should contact the Office of Human Resources, Rights
and Risk about recruitment and hiring procedures. Grant and contract funding does not give the
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PI the flexibility to by-pass university policies and procedures concerning new employment.
PIs should keep in mind that any costs for recruitment (i.e., advertising, travel expenses for
candidates brought in for interviews, background checks, etc.) generally must be borne by the
grant or contract.
The PI should contact the Office of Human Resources, Rights and Risk to start the hiring
process by developing the job description and position announcement. This electronic process
is online.
Student Employees
Part-time or temporary positions (exempt from Civil Service) on grants and contracts must first
be posted and made available to students. Students qualifying for employment through the
university must be at least half-time (i.e., enrolled for 6 credits or more for Undergraduate and 5
credits or more for Graduate students) and cannot work more than 19 hours per week (exclusive
of the hours worked on established academic breaks).
PIs are encouraged to contact the Office of Student Employment to first determine if the skills
required by an open part-time or temporary position are suitable for students. Open student
positions must be advertised (i.e., posted through the Office of Student Employment) for at least
48 hours. Under special circumstances, it may be possible to hire a specific individual for an
open position if the position requires specialized skills and/or experience held by that
individual. These cases require a written explanation and approval by the Office of Student
Employment.
Students cannot begin working until a Part-time Employment Authorization Form, IRS Form
W-4, and Immigration and Naturalization Service From I-9 have been completed and processed.
A start date and end date should be specified for each index a student is authorized to charge to.
This ensures that the index will not be available to charge to once the grant agreement has
ended. Once a student is hired, PIs are responsible for ensuring that the students’ time sheets
are accurate and timely. Concealing or delaying the report of hours worked on payroll
documents is a violation of state law and may result in disciplinary action. The PI, by signing
or electronically approving the time sheet, certifies that the number of hours reported as worked
during a pay period is accurate and complete.
PIs should not allow students to work during regular class time. If an individual works during
regularly scheduled class time when that class has been canceled, it should be noted on the time
sheet. Similar documentation should be provided when a student works during finals week (i.e.,
no class or final scheduled at a different time.) For electronically filed timesheets, a note should
be maintained in the PI’s files documenting the situation in case of an audit being conducted at
a later date.
Hours worked must be tracked for pay increments. Each PI is responsible for tracking these
hours. Students should receive a two-step increment when they have worked 450 hours at the
same job in the same department, effective the following pay period.
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Graduate Service Appointments (GSA)
Graduate Service Appointments are rare on grants and contracts. The GSA must be in the
approved budget and the purpose and the compensation amount per quarter or per academic
year must be described in the budget justification. The PI should coordinate all GSAs with the
Graduate Program Office. In the event a grant award funds a GSA, the PI must issue a
memorandum to the Dean’s Assistant to generate a PAF for the graduate student’s quarterly
payroll. The Graduate Program Office must approve all PAFs for GSAs prior to submission to
the OGRD.
Employees with Official Work Stations in Other States
Individuals employed by grants and contracts that are permanently stationed in states other than
the state of Washington are subject to the payroll tax rates and income tax laws that are in effect
in the state in which they work. PIs must notify Human Resources of new employees who may
be subject to other states’ payroll laws.
Insurance Eligibility for All Temporary Employees
Temporary, hourly employees whose average employment is at least half time, or 522 hours,
over a period of six consecutive months are eligible for employer provided benefits. After
initial insurance eligibility is established, a temporary employee must be in pay status at least 8
hours a month in order to maintain benefits. If a separation or break in service of one month
occurs, eligibility must be re-established.
Level of Effort Reporting (See APPENDIX for a complete discussion.)
Ownership and Control of Equipment
Equipment acquired through sponsored projects becomes the property of the university, unless
restricted by the sponsor, and is inventoried and tagged by EWU’s Inventory Control Office.
Government awards that finance equipment through a grant normally vest title of the equipment
to the grantee. If purchased through a contract, title may remain in the possession of the
grantor. Under no circumstances does equipment purchased through a sponsored project
become the property of the PI or any other personnel. However, the PI must control the use and
condition of the equipment.
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As the end of the grant period nears, the PI should consult the OGRD to determine appropriate
disposition of project equipment. Title will generally transfer to the University, but not always.
Depending on the funding agency and program, the sponsor may request return of the property
or require equipment inventory documentation be submitted. Often, obsolete equipment may be
sold and the PI’s department can retain the proceeds. Occasionally, funding agencies require
the university to submit an annual report itemizing equipment on hand acquired by grant funds
even after the grant has ended.
Indirect Cost Recovery (ICR)
Indirect Cost Recovery (ICR), sometimes referred to as Facilities and Administrative (F&A)
costs or overhead, are real costs of conducting research or managing projects that are not easily
identifiable. Indirect costs are expenses incurred by the university such as building and
equipment use and depreciation, operation and maintenance costs, central and departmental
administrative costs, library expenses, and student administration and services. EWU’s
recovery of funds for indirect costs is based on its negotiated rate with the federal government
and is applied to the salaries and wages of a grant or contract budget. When the university does
not fully recover indirect costs related to a project from a sponsor, it must cover these costs from
other university funds.
The university negotiates its federally approved ICR agreement through its cognizant agency,
the Department of Health and Human Services (DHHS). The current ICR rate is for 62.8% of
salaries and wages (exclusive of fringe benefits) and is applied to salary and wage costs
budgeted on or after July 1, 2008. Unless otherwise specified by the granting or contracting
entity, this rate is to be used on all applications and/or contracts for external funding including
those from private, local, state, and federal sources.
EWU redistributes indirect costs according to university policy. The ICR distribution based on
a 100% recovery is:
Grants Administration
38.25%
Academic Department
17.00%
University Infrastructure
15.00%
Participating Faculty
12.75%
College
4.25%
Provost
7.75%
Library
5.00%
Total
100.00%
Although a significant percentage of the ICR are used in direct support of university
services and operations, a portion is also distributed to the PI. ICR are distributed to PIs,
in part to support special initiatives which may relate to a current grant or contract
program, to provide seed money for securing additional external funding, and as an
incentive to continue to participate in proposal development and grants and contracts.
Although PIs have access to the ICR returned to them, ICR are not personal funds. They
Rev. March 24, 2016
24
are university funds for discretionary purposes. Expenditures must be for universityrelated purposes, and any equipment, supplies, or goods purchased using ICR become
the property of the university. An individual indirect cost recovery index and fund will
be established for participating faculty when a grant with ICR is awarded.
EWU has a few programs that fall within the category of self-support. Since selfsupport programs rely on the combined efforts of their staff to keep those programs in
operation and since these programs are in themselves their own self-funded departments,
the amount of indirect costs recovered by them will be the Faculty and Department
shares of 29.75%. Due to the fact that the administrative structure of such programs is
usually under the auspices of a college, the college will retain 4.25%. The deans will
reserve the right to redirect their recovery in support of the program. The remaining
66% will be distributed according to the original plan.
Project Over Expenditures and Unallowable Costs
The PI and the PI’s unit are responsible for any over expenditures or any costs that are
determined to be unallowable by the OGRD or auditors. It is therefore incumbent upon the PI
to carefully monitor all expenditures charged to his/her restricted indexes and to implement
whatever procedures are necessary to ensure compliance with the terms and conditions of the
award. The OGRD will consult with the PI and provide examples of spreadsheets that may be
used to monitor expenditures.
Closing the Grant Index
The PI is responsible for preparing and submitting the final technical report to the sponsor
according to the schedule outlined in the award. A copy of all technical or programmatic
reports during the life of the award, including final reports must be provided to the OGRD.
Items generally required at the close of each project index are:
1. submission of the final technical report by the PI through the university;
2. submission of the final invention statement by the PI through the university;
3. submission of the final financial/fiscal report by the university;
4. accounting for, and determining disposition of, any equipment purchased under the
project;
5. proper disposition of any over expenditures; and
6. any other requirements of the sponsor.
The PI must ensure that a record of all project expenses, both grant funded expenditures and
matching contributions, has been submitted to the OGRD. Any cost sharing or matching
committed to the project must be documented as if it were a cash transaction. While the
financial reports provided by the university adequately identify the transactions on the actual
grant or contract it is the PI’s responsibility to compile the records for in-kind contributions and
expenses paid by other sources of funding which are used to satisfy match or cost-share
requirements of the agreement.
Rev. March 24, 2016
25
Included in this record should be an assurance that all personnel commitments (grant funded,
university funded, and in kind) to the project have been fulfilled. Timesheets and Personnel
Activity Reports that certify the time spent by each individual on the project on a monthly basis
should be kept on file as part of this record. Both the individual donating the time and the PI
must sign these records. The PI’s signature documents their review and approval of the time
contributed.
Cost sharing must be documented as it occurs – the PI should not wait until the project is ending
to start documenting cost sharing. The records should be reviewed and, if any omissions are
noted, proper corrective action should be taken prior to the last month of the project.
Frequently, projects cannot be closed after the termination date because open commitments, or
encumbrances still remain as a result of last-minute purchases. The PI must further review open
commitments regularly during the life of the project to determine whether they are still
necessary to complete the project or should be canceled. The Banner accounting system can
provide a list of open commitments (FGIOENC) and will list the totals by account code on the
(FRRGITD) Grant Inception to Date Report.
Some charges, such as copier costs, telephone charges, report printing charges, and
interdepartmental billings normally show on the accounting system at least one month later than
they are charged. These costs must be considered in planning the project close out.
It is a condition of the award that all required reports be submitted to the sponsor according to
the schedule provided in the award documents. Failure to submit reports in a timely and
acceptable manner can result in the rejection of pending proposals without consideration and
withholding of final payment. It also puts in jeopardy the faculty member’s and the university’s
eligibility for future grant opportunities. It is therefore incumbent upon the PI to make sure all
reports are completed and submitted to the sponsor on time. Any costs disallowed by the
sponsor due to the PI’s failure to submit required reports according to the sponsor’s schedule
will be the responsibility of the PI first, then the department and last of all the College in which
the PI resides.
Program Income
Occasionally a grant will generate program income; however, the university cannot retain
program income. Income generated by a grant must be used to finance the non-federal share of
the project or reduce the federal agency’s share of expenses. For non-federal awards, the
specific award document will provide guidance on the treatment of program income. Any and
all program income that has been received on behalf of the grant must be accounted for during
the grant close out. For guidance relating to federal agency agreements refer to Title 2 of the
Code of Federal Regulations, Part 215.24 (Uniform Administrative Requirements for Grants and
Agreements With Institutions of Higher Education, Hospitals and Other Nonprofit
Organizations - Post-Award Requirements, Program Income).
Rev. March 24, 2016
26
General Procedures for Project Monitoring and Reporting
Signature Authority
PIs are cautioned not to sign any Notice of Awards or agreements for sponsored support, patents
or copyright licenses, biomaterials, equipment loans, work for hire, confidential disclosure
agreements, or materials transfer. These agreements bind the university to certain obligations
and, as such, can be signed only by the Associate Vice President of Business and Finance.
However, PIs, or their designees are required to sign all documents to authorize expenditures
against the grant or contract index.
Record Keeping
The PI is responsible for complying with all the financial terms and conditions of the award and
should, therefore maintain accurate records for the entire duration of the grant. While the PI
may delegate some responsibility for the day-to-day management of finances or other tasks to
departmental business staff, the PI remains accountable for compliance with University and
sponsor requirements. The PI may contact the OGRD for assistance in establishing record
keeping systems for monitoring grant and contract expenditures.
Subcontractors (Sub-awards)
If the project includes subawardees (contractors), the PI is responsible for reviewing all invoices
submitted by the subawardee and determining that all costs are appropriate and allowable.
Payment of subawardee invoices is tied to the subawardee’s performance in meeting the goals
outlined in their scope of work. Once the PI has determined the charges are appropriate, the
work has been performed, and approves the invoice; the OGRD staff will sign the document and
forward it to the Accounts Payable Department for payment. The PI must review all such
invoices in a timely manner so that the university can meet its obligation to pay the subawardee
in a timely manner.
Financial Reports
The OGRD maintains detailed fiscal records of each sponsored program index using the
university’s financial management accounting program, Banner Finance. The PI should access
the EWU Banner INB [PROD] web site and generate the financial reports, which provide the
details of the index and fund status. The PI should carefully review the financial reports and
any discrepancies between the University’s records and the PI’s records should be brought to
the attention of the OGRD for immediate resolution.
Rev. March 24, 2016
27
The PI is responsible for all costs charged to his/her sponsored program indexes. While
the PI may delegate some responsibility for the day-to-day management of finances or
other tasks to departmental business staff, the PI remains accountable for compliance
with University and sponsor requirements. The delegation of this authority must be
submitted to the Purchasing Office, in writing- generally on the signature card for each
grant. Once the PI completes the signature card it must be forwarded to the Purchasing
Department.
The PI must attend Banner INB training in order to monitor the account activity and
generate financial reports. Training sessions (Banner Finance 201 - Introduction to
Banner Finance and Banner Finance 204 - Reports and Queries) may be scheduled by
accessing https://web.ewu.edu/trainsched/.
The Banner reports, FRRGITD - Grant Inception to Date and FGRODTA - Detailed
Transaction Activity should be produced each month after month end closing. Generally, month
end closing occurs approximately the 10th day following the end of the prior month.
Additionally, all existing encumbrances, by department can be monitored by using the
FGIOENC – Organizational Encumbrance List form.
Step-by-step instructions for producing the FRRGITD, Grant Inception to Date Report and the
FGRODTA - Detailed Transaction Activity Report as well as monitoring encumbrances by
accessing the FGIOENC – Organizational Encumbrance List form are as follows:
Instructions for Producing FRRGITD, Grant Inception to Date Report
The FRRGITD form is used to produce a printed report or electronic file of the grant budget
status. This report provides inception to date grant information across fiscal years (if
applicable). The following provides instructions on producing a printed report and electronic
copy of the report.
Note: It is recommended that the browser pop-up option be disabled before attempting to
generate a printed or electronic report.
1. From the Banner Main Menu, enter FRRGITD in the Go To field and press enter.
Rev. March 24, 2016
28
2. The Process Submission Controls form displays. Click on Next Block to access the
Printer Control section of the form.
Rev. March 24, 2016
29
3. Enter the following in the Printer Control section of the form to generate a printed
report:

Printer: Select the applicable department printer from the drop down list.

Lines: Enter 44 in order for data on the report to print properly.
Note: To generate and save an electronic version rather than a printed copy of the report, enter
the following:

Printer: Enter DATABASE.

Lines: Enter 55.
4. Click on Next Block to access the Parameter Values section of the form.
5. Enter the following in the Values fields in the Parameter Values section of the form.
Note: Use the down arrow key on the keyboard to move from field to field.

Chart of Accounts: Enter capital E (for Eastern Washington University’s chart of
accounts). This field is case sensitive.
Rev. March 24, 2016
30

As of Date: The grant inception date is required to obtain prior fiscal year
information. Enter the applicable date using the following format; MM/DD/YY (for
example 07/01/07).

Enter Grant Option: Enter R for a range of grants or S for a specific grant.

Grant From: If R is entered in the Enter Grant Option field, enter the starting
grant number.

Grant To: If R is entered in the Enter Grant Option field, enter the ending grant
number.

Specific Grants: If S is entered in the Enter Grant Option field, enter the desired
grant number.
Note: PIs generally should use the “Specific Grants” option even if they have more than one
grant because the grant numbers are assigned sequentially and it is rare that a PI will have 2
grants next to one another.
Rev. March 24, 2016
31
6. Click on Next Block to access the Submission section of the form.
7. If desired, the parameters selected can be saved for future retrieval. Select the Save
Parameter Set as check-box; enter a unique name (such as your department name) in
the Name field, and a description of the report in the Description field (for example
GrantReport).
8. Click on the Save icon in the tool bar.

If a printed report was selected the report will print at the designated printer. No
further steps are necessary.
9. If a database report was selected, click on Options in the menu bar. Select the Review
Output from the drop down list.
Rev. March 24, 2016
32
10. The Saved Output Review form displays. Double click in the File Name field.
11. Double click the applicable file name in the list displayed (the number in the Number
field corresponds with the file name displayed).
12. The view output displays.
13. The electronic file displayed may be saved. The following steps pertain to saving an
electronic file.
14. Click on Options in the menu bar and select Show Document (Save and Print File).
15. A confirmation dialog box displays. Click on Yes.
A browser window displays. Name and save the electronic copy to the desired file
location. Because the data is continually changing, printing a hard copy for reference is
recommended.
Instructions for Producing FGRODTA, Detailed Transaction Activity Report
This Detailed Transaction Activity report lists all transactions posted to your index. It
can be produced for all transactions inception to date or for a specific time period during
the life of the program.
1. From the Banner Main Menu, enter FGRODTA in the Go To field and press enter.
Rev. March 24, 2016
33
2. The Process Submission Controls form displays. Click on Next Block to access the
Printer Control section of the form.
3. Enter the following in the Printer Control section of the form:
Rev. March 24, 2016
34

Printer: Select the applicable department printer from the drop down list.

Lines: Enter 44 in order for data on the report to print properly (a different number
may be needed depending on the printer used.)
Note: To generate and save an electronic version rather than a printed copy of the report, enter
the following:

Printer: Enter DATABASE.

Lines: Enter 55.
4. Click on Next Block to access the Parameter Values section of the form.
5. Enter the following in the Values fields in the Parameter Values section of the form.
Note: Use the down arrow key on the keyboard to move from field to field.

Fiscal Year: Enter the two-digit current fiscal year (for example enter 08 for the
fiscal year beginning July 2007)

Chart of Accounts: Enter capital letter E (for Eastern Washington University’s chart
of accounts). This field is case sensitive.

From Organization Code: Enter the department Organization code.
Rev. March 24, 2016
35

From Fund Code: Enter the applicable six-digit Fund code or leave blank for all
funds.

From Account Code: This field is optional. To generate a report with only specific
Account activity, enter the desired Account code (for example Account 71400 for
supplies), otherwise leave blank.

From Date: Enter the desired date, or the first day of the month for the desired
accounting period using the following format; MM/DD/YY (for example 07/01/07).

To Date: Enter the desired date, or the last day of the month for the desired
accounting period using the following format; MM/DD/YY (for example 07/31/07).

Include Accrual for Last Prd: Enter Y.

Print Organization Totals: Enter Y.

Commitment Type: Enter U.
Rev. March 24, 2016
36
6. Click on Next Block to access the Submission section of the form.
7. If desired, the parameters selected can be saved for future retrieval. Select the Save
Parameter Set as check box, enter a unique name (such as July Detail) in the Name
field, and a description of the report in the Description field (such as your department
name).
8. Click on the Save icon in the tool bar.

If a printed report was selected the report will print at the designated printer. No
further steps are necessary.
Rev. March 24, 2016
37
9. If a database report was selected, click on Options in the menu bar. Select the Review
Output from the drop down list.
10. The Saved Output Review form displays. Double click in the File Name field.
Rev. March 24, 2016
38
11. Double click the applicable file name in the list displayed (the number in the Number
field corresponds with the file name displayed).
12. The view output displays.
13. The electronic file displayed may be saved. The following steps pertain to saving an
electronic file.
Rev. March 24, 2016
39
14. Click on Options in the menu bar and select Show Document (Save and Print File).
15. A confirmation dialog box displays. Click Yes.
16. A new browser window displays with the output data.
Rev. March 24, 2016
40
17. To save the data to the desktop or computer drive, click on the File toolbar option in the
browser window.

Select Save as from the drop-down list.
Rev. March 24, 2016
41
18. A Save as dialog box displays. Enter the following then click Save.

From the Save In field, select the desired save location (for example; My
Documents)

In the File name field enter the desired file name (for example “August Detail”).

The Save as type defaults to a web page file type. It is not necessary to change the
file type.
Rev. March 24, 2016
42
Instructions for Viewing Encumbrances
To view all existing encumbrances, by department, use the FGIOENC – Organizational
Encumbrance List form.
1. From the Banner Main Menu, enter FGIOENC in the Go To field and press enter.
2. The Organizational Encumbrance List form displays. Enter the following data in the key
block and use the tab to move from one field to the next field:

COA: Enter E. This field is case sensitive.

Fiscal Year: Enter the applicable fiscal year (for example; 08 for fiscal year
beginning July 1, 2007).

Index: Enter the applicable six-digit Index Code.
Rev. March 24, 2016
43
3. Click on Next Block to view data.
Rev. March 24, 2016
44
Animal Care and Use Protocol Review Compliance
The Institutional Animal Care and Use Committee (IACUC) ensures that animals used in
research or teaching are treated humanely by considering:
1. Replacement of experimental animals by alternatives.
2. Refinement of housing, handling and experimental procedures to reduce discomfort,
pain, fear, stress, and suffering.
3. Reduction of numbers of animals used.
The Protocol Review Form (PRF) is required for research or teaching projects involving warmblooded animals. A Change of Protocol Form must be submitted and approved if an
amendment to an existing, approved protocol is necessary. The Animal Care and Use Policy
may be found at http://cfweb.ewu.edu/policy/PolicyFiles/EWU_302_03.pdf
Protection of Human Subjects Compliance
EWU’s Institutional Review Board (IRB) must review and approve all research projects that use
people as subjects. It is critical that PIs read and adhere to the
http://access.ewu.edu/Documents/Grants/human%20research%20policy.pdf. All key personnel
awarded federally sponsored grants and contracts must complete training on the protection of
human subject participants if their project includes the use of human subjects.
Investigator Significant Financial Interest Disclosure
PIs must complete and return the Conflict Disclosure Form, which certifies they do not have a
financial conflict of interest with an element of a funded project or which discloses actual or
potential conflict and includes a plan to manage any conflict of interest. Typically, PIs sign the
Conflict Disclosure Form at the time of the submission of the proposal; however, it may be
necessary to sign an additional form should contract terms and conditions warrant.
This form can be found at EWU Home>Administration>Research and Scholarship>Office of
Grant and Research Development>Frequently Requested Forms.
Records Retention
The Revised Code of Washington (RCW 40.14) requires the University to maintain all financial
and programmatic records for a period of at least six (6) years from the date of the issuance of
the audit report, which includes the specific grant or program. Should the PI intend to leave the
employment of EWU, he/she must contact the OGRD to determine the appropriate storage and
disposition of any records related to all externally funded projects or programs.
Rev. March 24, 2016
45
Level of Effort Reporting
Introduction
Federal agencies provide funding to Eastern Washington University for a variety of research,
scholarship and service activities. Appropriately certified effort reports provide auditable
documentation to demonstrate that the funding agency received the level of effort described and
expected by the proposal process, the award process, and all subsequent communications with
the funder during the period of funding.
Policy
Faculty, staff, and students who provide compensated and/or uncompensated work for a federal
agreement, principal investigators/project directors, and their supervisors must adhere to the
procedures set forth in EWU Policy 302-06: Effort Reporting and related regulations and as
defined by generally accepted accounting principles. Federal grants, contracts, cooperative
agreements and subrecipient agreements awarded to the university are referred to as "federal
agreements" in this document. This policy also applies to principal investigators/project
directors (i.e., the persons responsible for carrying out the scope of work identified in a federal
agreement awarded to the university) and the supervisors of those persons performing work on a
federal agreement.
Responsibilities
EWU, through the Office of Grant and Research Development (OGRD) is to: (1) certify to the
funding agency, for federal agreements, that the effort expended on the agency's projects
justifies the salary charged to the projects; (2) assure the funding agency that the commitment
indicated (including mandatory and voluntary committed cost sharing) in the proposal and
subsequent award is met in accordance with the funder's terms and conditions; and, (3) require
monthly effort reporting from each person whose salary is charged to or provided as cost
sharing on one or more federal agreements.
Sanctions
Costs may be disallowed, funding may be reduced or terminated and other penalties imposed on
the university if auditors find effort reporting to be inaccurate, incomplete, or untimely. In
addition, criminal charges may be brought against any individual reporting falsified effort. As a
result, any person who violates Effort Reporting Policy 302-06 is subject to disciplinary action
and the availability of grant funds will be suspended until corrective action is taken and time
and effort reporting obligations are met. Violations or non-compliance with EWU Policy 30206 also may be subject to EWU Policy 302-205 (Ethics in Research).
Reporting Violations
Suspected violations of the effort reporting policy and/or relevant federal regulations should be
reported to the Provost, the college Dean, OGRD, the University President, or to other EWU
leaders.
Procedures
OGRD has established a system for employees to review and certify salaries.
Rev. March 24, 2016
i
It is the responsibility of OGRD to:
(1) distribute monthly Level of Effort (LOE) reports to appropriate personnel for review,
modification as necessary and signature;
(2) follow up with personnel who have not returned the LOE report within 45 days of issuance;
(3) ensure that a system is in place for employees committing time to a federal agreement to
meet their requirements for review and certification of salaries and to assure that the salaries of
personnel charged or contributed to federal agreements correspond to the effort expended on
these projects.
(a) For salaried employees, OGRD calculates the anticipated level of effort on a
monthly basis and prepares level of effort reports.
(b) For non-salaried employees, the approved hourly timesheet is used to satisfy the
requirement for effort certification.
(4) maintain copies of completed level of effort reports for a period of six years from the
issuance of the state audit report which includes the specific federal agreement; and
(5) ensure that any required adjustments of effort are negotiated with and approved by the
funding agency.
Salaried employees, who perform compensated and/or uncompensated work on federal
agreements shall:
(1) certify that information contained in monthly level of effort reports is fair and reasonable.
If the information is NOT accurate, the employee needs to revise it to more accurately reflect
the activities for which the employee was paid or contributed time.
(2) submit reports to their direct supervisor and the principal investigator/project director for
the federal agreement on which they are being paid or to which time is being contributed (or
their department chair as applicable) for approval and certification.
Principal Investigators/Project Directors are ultimately responsible for the accuracy of the effort
certification. Principal Investigators/Project Directors on federal agreements shall:
(1) review the LOE reports for accuracy;
(2) sign approved LOE reports and forward them to OGRD;
(3) work with OGRD as necessary to make permanent payroll adjustments to a federal
agreement if an employee has significantly revised the LOE report.
Who is subject to effort reporting?
All employees paid from or contributing compensated or uncompensated time to federal
agreements are subject to effort reporting.
How is effort determined for the purpose of federal effort reporting?
Level of effort is based on the total salary for the month and will always equal 100%. It may
represent more than one work activity (e.g. research, instruction, service) and more than one
source of funding. Level of effort is not the same as full time equivalent (FTE).
Why is effort reporting required?
Since educational institutions employ a variety of staff that are not required to use hourly
timesheets, OGRD prepares a “Monthly Level of Effort Report" to be used to document staff's
time and effort worked on a federal agreement. The details of the federal regulations requiring
Rev. March 24, 2016
ii
effort reporting are located at Title 2 Code of Federal Regulations (CFR) Part 220 Cost
Principles for Educational Institutions. These regulations apply "to research and development,
training, and other sponsored" programs performed by EWU employees under federal
agreements.
To comply with federal regulations, the university has implemented a monthly, after-the-fact
time and effort reporting system to verify that all personnel costs charged to a federal agreement
are appropriate based on the actual time and effort spent on the project.
What is federal pass-through funding?
Federal pass-through funding is federal funding for programs received by a state, governmental
entity, non-profit, or various other entities and that is then awarded to EWU. Under this
arrangement, EWU is a sub-recipient of federal funds.
Direct federal grants, contracts, cooperative
agreements
Federal pass-through funding or
sub-recipient agreements
Since the source of funds was the federal government, those funds still retain their federal
identity. Therefore, any individual paid wages from federal pass-through dollars is also required
to complete the “Monthly Level of Effort Report”.
How is effort reporting accomplished?
The OGRD prepares the “Monthly Level of Effort Report” on federally funded projects and sends
them out for signature. A blank form appears on the next page. These reports are generated and
issued one to two months after the date payroll was paid. The reports must be reviewed and signed
by both the employee and the Principal Investigator (PI) working on the grant, and returned to the
OGRD to be retained in its files. If the time actually spent on the project differs from the time paid
from the project, the PI must contact the OGRD to determine whether a revision to the distribution
of payroll needs to be made before returning the Level of Effort report to the OGRD. Please note
that the Department Chair or Dean must also sign the Level of Effort reports for the PI’s effort. The
PI is responsible for all costs charged to his/her sponsored program indexes. While the PI may
delegate some responsibility for the day-to-day management of finances or other tasks to
departmental business staff, the PI remains accountable for compliance with University and sponsor
requirements.
Rev. March 24, 2016
iii
MONTHLY LEVEL OF EFFORT REPORT
Name: Researcher
Effort Period: February 20XX
Dept/MS: Geology – SCI 130
Level of effort (LOE) reporting is required by federal regulations and applies to the effort of all
EWU personnel who have all or a portion of their salaries/wages paid from federal funds. The
purpose of the LOE report is to certify that the pay was a reasonable reflection of effort and
ensure that salaries/wages charged to federally-supported programs are allocable, allowable,
and consistently treated. It is important to understand that LOE is based on the total salary for
the month and will always equal 100%; LOE is not the same as full time equivalent (FTE).
Your signature and that of your supervisor and PI/Dept. Chair provide the necessary
certification that the percentages are a fair and reasonable estimate of your activities for the
indicated month. If the information provided is not accurate, please revise it to more closely
reflect the activities for which you were paid by the University.
1. Sponsored
Programs
ACTIVITY
Index
No.
Fund
No.
LEVEL OF EFFORT %
Index
Salary
%
Full Time
Equivalent
FTE%
2. Cost Sharing
FROM:
Cost Sharing
TO:
3. Other
Activities
4. TOTAL
ACTIVITIES
Employee Signature: ________________________ Date: _____________________
Direct Supervisor Signature: ____________________
Date: ________________
Principal Investigator/Dept. Chair: ______________________ Date: ____________
If you have questions, call the Grants Office at 359-6567. Return copy with ALL
signatures to SHW 210.
Rev. March 24, 2016
iv
Monthly Level of Effort Report Examples - Four examples have been provided.
(1) The first example shows Researcher #1 with both the Level of Effort and Full Time
Equivalent (FTE) for the position of 100%.
Total FTE = 100%
(a 100% time position)
Total Effort = 100%
Sponsored
Program
index 501870
100%
1. Sponsored
Programs
ACTIVITY
Index
No.
501870
Fund
No.
216580
Sponsored
Program index
501870 100%
LEVEL OF EFFORT %
Index
Salary
%
100
4000.00
Full Time
Equivalent
FTE%
100
2. Cost Sharing
FROM:
Cost Sharing
TO:
3. Other
Activities
4. TOTAL
ACTIVITIES
Rev. March 24, 2016
100% 4000.00
100%
v
(2) The next example is for Researcher #2 with the Level of Effort equal to 100% and the
Full Time Equivalent (FTE) equal to 110%.
Total FTE = 110%
(a 100% teaching position + 10%
research overload)
Total Effort = 100%
Sponsored
Program
index 502785
9.09%
Sponsored
Program index
502785 10%
Other
activities
index 100652
90.91%
1. Sponsored
Programs
ACTIVITY
Index
No.
Fund
No.
Other activities
index 100652
100%
LEVEL OF EFFORT %
Index
Salary
%
502785
210856
9.09
500.00
Full Time
Equivalent
FTE%
10
100652
120149
90.91
5000.00
100
100%
5500.00
110%
2. Cost Sharing
FROM:
Cost Sharing
TO:
3. Other
Activities
4. TOTAL
ACTIVITIES
Rev. March 24, 2016
vi
(3) Researcher #3 has less than a full-time position. Researcher #3’s Level of Effort is
equal to 100% and the Full Time Equivalent (FTE) is equal to 75%.
Total Effort = 100%
Total FTE = 75%
(a 15% research position + 60%
other activities)
Sponsored
Program
index 506590
20%
Sponsored
Program index
506590 15%
Other activities
index 200896
60%
Other
activities
index 200896
80%
1. Sponsored
Programs
ACTIVITY
Index
No.
Fund
No.
Unemployed
25%
LEVEL OF EFFORT %
Index
Salary
%
506590
220495
20
600.00
Full Time
Equivalent
FTE%
15
200896
133957
80
2400.00
60
2. Cost Sharing
FROM:
Cost Sharing
TO:
3. Other
Activities
4. TOTAL
ACTIVITIES
Rev. March 24, 2016
100% 3000.00
75%
vii
(4) The fourth example shows Researcher #4 with both the Level of Effort and Full Time
Equivalent (FTE) for the position of 100%. 5% cost sharing is being provided from nonfederal funding.
Total Effort = 100%
Total FTE = 100%
(a 100% time position)
Sponsored
Program
index 501870
5%
Sponsored
Program
index
501870 5%
Cost sharing
on index
500862 paid
from index
100499 5%
Cost sharing
on index
500862 paid
from index
100499 5%
Other
Activities
90%
1. Sponsored
Programs
ACTIVITY
Index
No.
Other
Activities
90%
LEVEL OF EFFORT %
Index
Salary
%
501870
216580
5
200.00
Full Time
Equivalent
FTE%
5
100499
120149
5
200.00
5
Cost Sharing 500862
210990
90
3600.00
90
2. Cost Sharing
Fund
No.
FROM:
TO:
3. Other
Activities
100499
4. TOTAL
ACTIVITIES
Rev. March 24, 2016
120149
100% 4000.00
100%
viii
Where do I find answers to my questions about EWU’s effort reporting policy and related
sanctions for non-compliance?
EWU adopted Policy 302-06: Effort Reporting effective March 23, 2012. It is located on EWU’s
website at http://cfweb.ewu.edu/policy/PolicyFiles/EWU_302_06.pdf. The OGRD staff is also
available to answer your questions. Call 509-359-6567 or stop by and talk with one of the PostAward staff located in Showalter Hall 210 and 209A.
Where can I find the federal regulations that require effort reporting?
The federal government’s cost principles for educational institutions must be used to guide all costs
incurred for sponsored projects and research; including all activities sponsored by federal and nonfederal agencies and organizations.
The Office of Management and Budget (OMB) continually updates and describes these principles in
great detail at http://whitehouse.gov/omb/circulars/
•
2 CFR Part 220 (OMB Circular No. A-21)- Cost Principles for Educational Institutions.
•
2 CFR Part 215 (OMB Circular No. A-110)- Uniform Administrative Requirements for
Grant Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit
Organizations.
Rev. March 24, 2016
ix