California State University, Bakersfield Office of Grants, Research, and Sponsored Programs (GRaSP) DH D108 – 661.654.2231 Scenarios for Payment of Indirect Staff and Faculty Working on Projects .Revised: April 2009. Implemented: July 1, 2008 Background Federal guidelines 2CFR Part 220 Section J.10 (OMB Circular A-21) define how individuals are to be paid for their work on research, special projects, or sponsored programs (or collectively, “projects”) funded by means of grants or contracts awarded by sponsoring agents. Specifically, payment for this work must be processed through the institution’s payroll system in a manner consistent with the institution’s policies and procedures for all employees. At CSUB, Expenditure Transfers, Billing Requests, Direct Pays, etc. cannot be used as methods to pay employees for work on projects or to reimburse departments for loss of employee time. Billing Requests are used to reimburse a department for faculty release time only. In addition, federal guidelines require that charges to projects for employee services must be certified after the fact as being correct. For all employees working on a project(s), a Certification of Effort ReporT (CERT) serves as an after-thefact time sheet (see separate samples of Staff/Administrators CERT and Faculty CERT). Federal guidelines also require that employee pay for indirect (campus) work must be kept fiscally separated from pay for direct (project) work to avoid “double-dipping.” Pay is charged as a direct expense to the project for employees who work exclusively on a project(s), thus causing no conflict with the institution’s negotiated indirect cost rate. However, special hiring and time certification procedures are required when university personnel work on projects since their wages are already being charged as part of the indirect rate. If the work performed for a project is substantially different from the work an individual (including faculty) performs for the institution, and/or the project work imposes a burden on the primary position (in terms of time required to achieve primary tasks), a payroll method must be used to charge the time directly to the project; this serves as a means to remove those charges from the indirect pool. It is the responsibility of the Primary Investigator/Program Director (PI) to initiate the appropriate hiring procedures, make sure proper certifications are obtained, and monitor the project expenses on a continuous basis to confirm employees are being paid correctly. Human Resources (HR) and GRaSP are available to assist with this process. Described below are several scenarios illustrating how staff employees, administrators, and faculty can be paid for their work on projects in compliance with federal guidelines. The guiding rule is that both the school and the sponsor pay their fair share of the employee’s time. Not described here are the specialized reporting procedures required by federal guidelines for “cost-share/match” or volunteer time; because reporting requirements are so cumbersome, CSUB discourages including match or volunteer time in proposed budgets during the project proposal stage. In all cases, the PI must confirm with GRaSP that project funds are available and that required hiring procedures are followed before employees or faculty begin work on a project. Scenarios for Staff Employees and Administrators Except for those hired as “hourly intermittent,” all project employees (including those who work 100% on a single project) must submit a Certification of Effort ReporT (CERT, see separate sample) since they do not fill out monthly time cards. Staff and administrators CERTs are due on the 20th day of the following month. When project budgets do not allow for 100% administrative support, hiring a dedicated part-time employee as in Scenario One below is the preferred method in order to avoid conflict with the Project Pay Scenarios Page 1 of 3 California State University, Bakersfield Office of Grants, Research, and Sponsored Programs (GRaSP) DH D108 – 661.654.2231 indirect rate and maximize hours and benefits for the employee. Scenarios Two through Four are options if Scenario One is not practical for the situation. Scenario One: Direct Staff Support for Multiple Projects When there are several open projects that have budgeted for part-time administrative assistance, it is recommended that the school Dean work together with the PIs to hire an individual who does not already have a full-time primary position as administrative support with a university department. That individual then provides direct support for several projects on a full- or part-time basis. The PIs process Hire Forms for their projects (standard search procedures apply), and the percentage of time the employee works on each project is estimated as full-time-equivalent (FTE). When the percentages vary over time and/or projects are completed, the PIs must assure that FTE percentage changes are processed promptly (by email or by Labor Cost Distribution forms as required by HR). Hourly intermittent employees who submit positive time sheets approved by their supervisors for each project each month do not have to submit CERTs; however, all other project employees must submit CERTs to GRaSP each month. Scenario Two: Indirect Departmental Staff Support for a Project When a departmental staff employee performs work for a project(s), and that work is similar to his/her primary position (e.g., processing expense reimbursement forms and making travel arrangements), and the work is occasional and transitory and does not place a burden over time on accomplishment of primary tasks, the work is considered part of the primary assignment as departmental administrative support. In this case, the employee does not receive additional compensation, and the department does not receive reimbursement for the employee’s time. The project is not charged. Scenario Three: Long-Term Departmental Staff Support for a Project When work for a project(s) will continue over an extended period of time (over 90 days) and is performed by a departmental staff employee, and there is a burden on the employee’s primary assignment and/or the project work is substantially different from the employee’s primary position (see note below), then the PI submits an additional employment Hire Form (standard search procedures apply) to GRaSP for percentage FTE hours. The project will have to pay the employee’s overtime rate and/or the department will have to reduce the percentage FTE for the employee’s primary position. The employee submits a CERT to GRaSP each month. Note: A burden on the primary assignment exists if one or more of the following conditions is present: (a) the departmental employee needs to work extra hours in order to complete primary and/or project tasks; or (b) the employee works fewer hours on the primary position in order to complete the project tasks; or (c) another departmental employee is asked to perform the other individual’s primary tasks in order to free up time for the project tasks. The work is considered substantially different if it requires different types of tasks or additional skills or knowledge levels than those required for the employee’s primary position. Scenario Four: Short-Term Departmental Staff Support for a Project When a departmental staff employee performs work for a project(s) that is occasional and/or occurs during a specific time period, and the additional workload is performed outside the normal primary position hours, a Special Consultant form is prepared by the PI to charge the project and pay the employee. The Special Consultant form is submitted to GRaSP for a one-month pay period after the work is completed. Specific minimum and maximum daily rates apply. The form is certified by both the employee and the PI and serves as a certified time sheet for the project that is separate from the employee’s primary position. Project Pay Scenarios Page 2 of 3 California State University, Bakersfield Office of Grants, Research, and Sponsored Programs (GRaSP) DH D108 – 661.654.2231 Scenarios for Faculty Every faculty member who receives pay from a source other than general university funds must complete a Certification of Effort ReporT (CERT, see separate sample). Total time worked includes release time, matching/cost-share time, and paid work for projects and the Extended University as well as regular faculty assignments (teaching and departmental/administrative release time). A 40hour work week for full-time employment is assumed, and CSUB additional employment policy allows employees to work up to 25% more than full-time (10 hours/week assumed). A full-time faculty load equals 15 WTUs per quarter (including school-sponsored administrative or other release time), or 45 WTUs per academic year. The CERT form adjusts the total time worked (up to 125% time) to 100% effort per federal guidelines. Note that pay rate, 125% maximum allowed calculations, and 100% time/effort are factors that are independent from one another, and actual hours worked can vary among faculty members and by time period. All the following scenarios require that a CERT be submitted to GRaSP by the faculty member within 30 days after the end of each academic time period: each quarter (including summer) and each academic break (winter and spring). Scenario One: Release Time When a faculty member receives funding from a sponsor for release time from teaching a course(s) or other regular duties to work on a project(s), the Dean’s Office submits a Billing Request to GRaSP to charge the project and reimburse the department based on the number of Weighted Teaching Units (WTUs) released for each project each quarter (see note below). It is the Dean’s responsibility to confirm with GRaSP that the funding is available before the release time is granted to the employee. Note: The reimbursement rate is negotiated during the proposal stage of the award and is included in the proposed budget. Most sponsors do not require that the pay rate is equivalent to the specific faculty member’s base rate (with one big exception being the National Science Foundation). The reimbursement amount is approved when the Dean signs the Proposal Routing sheet. Scenario Two: Long-Term Project Work When a faculty member receives an additional appointment to work on a project(s) for an extended time period over and above their regular assignments (based on a project, fiscal, or academic year), GRaSP calculates the monthly percentages (see note below) for the project work in advance for the project year and submits an Authorization for Additional Employment for Exempt Employee Form to Human Resources. Paychecks are paid out on a monthly basis. Note: The faculty pay rate, percentage time, and percentage pay must conform to sponsor requirements. CSUB has two accepted methods for adjusting the employee’s academic year pay rate to a 12-month base salary for project work. The rate is decided upon when preparing the budget proposal before the project is funded. Scenario Three: Short-Term Project Work This is similar to Staff Employees and Administrators Scenario Four above. When a faculty member receives an additional appointment to work on the project(s) during an academic break or for a specified short-term period, the PI submits an Authorization for Additional Employment for Exempt Employee Form (similar to the staff Special Consultant Form) to GRaSP. These forms are submitted for a one-calendar-month pay period within 21 days after the work is completed. Specific minimum and maximum daily rates apply. This work is estimated as a percentage of time worked, and the faculty member submits a CERT to GRaSP after each academic time period. Project Pay Scenarios Page 3 of 3