Document 17771998

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What is a Salary Transfer? Why do we do them?
 What are best practices?
 What makes a good justification?
 Resources

 Salary Transfers document a reallocation of salary so the salary
is consistent with actual effort.
› % effort is less than the % paid
› % effort is more than the % paid

A federal requirement that pay must be a reasonable reflection
of effort performed.

OMB A-21, Cost Principles for Educational Institutions

“Whenever it is apparent that a significant change in work
activity that is directly or indirectly charged to sponsored
agreements will occur or has occurred, the change will be
documented over the signature of a responsible official and
entered into the system.”
NOTE: Primary responsibility for compliance is with the department.

Personnel processing transfers are trained to comply with University
and sponsor policies on cost transfers.

Guidelines outlined in GIM 14, Delegation of Signature Authority for
Sponsored Projects are followed.

Expenditure review process is in place to detect posting errors within
a reasonable time frame (e.g. 30 days)

Salary distributions are reviewed on a monthly basis and adjustments
made in a timely manner.
 For recertifications
› Make copies of the “POSTED” OSET for the FEC and for the
faculty member’s home department, if different.
› Submit “POSTED” salary transfer with recertifications.
 Provide adequate and complete justifications.
 Request advance budgets. Request advance budgets.
 Restrict use of grant budgets as temporary budgets while
waiting for late awards.
All salary transfers require (per GIM 15) :
› The reason for transferring the expenditure.
› Evidence that the transfer benefits the budget to be
charged.
› Verification that the transfer is within the approved
guidelines of the budget and is in support of its objectives.
› The reason the expenditure was initially charged to the
incorrect budget.
1.
Provide the reason for the transfer and why it was
charged to the wrong budget number. If effort was
previously certified, explain why the effort was
considered to be correct then but now requires a
change.
2.
How did this employee's work benefit the grant
budget to be charged?
3.
(OVER 120 DAYS) Provide a complete statement that
fully documents the reasons the transfer date is
greater than 120 days from the original transaction
date.

The following justifications are from actual salary
transfers.
› #1 and 2 are required by all salary transfers.
› #3 is required for any salary transfer completed over
120 days from the date of the original transaction.
1.
Redistribution of effort.
2.
Prof X is the PI on this budget.



Certified: 8/11/10
Recertified: 6/6/11
OSET: 8/31/10
1.
The sub budget for this grant was not yet set up. Now that it
has been created, we can transfer the appropriate
transactions to it.
2.
As Co-Investigator at the partnering academic affiliate site,
Dr. X will offer expertise on study designs, analysis and other
scientific matters. He will participate in Protocol Team
meetings, provide leadership on scientific proposals and
oversee the development of technology that will be
distributed to clinical sites for project implementation.
3.
The sub budget for this grant was not yet set up. Now that it
has been created, we can transfer the appropriate
transactions to it.
Certified: 5/31/10
Recertified: 9/9/11
OSET: 8/4/11
OVER 120 DAYS
1.
See attached [PI responding by email]: “If this is all
meeting requirements, then I’ve certainly been doing
20% time on this study. I’m OK with it as long as …
everyone is good with the regulatory part of it.”
2.
Charges reflect the actual FTE contributed to the
grant for Dr. X.
3.
Paying dept. did not communicate with the home
dept. about the actual FTE contributed to the grant.
OSET effective as of April 1.
Certified: 9/14/10
Recertified: 11/3/10
OSET: 10/25/10
OVER 120 DAYS
1.
Prof X was supposed to be paid on budget 63-xxxx
from 6/1/10-5/31/10. She was placed on the M’s
recapture account until we could get the advance
budget set up.
2.
10% of Prof X’s time was attributed to the
X492/HIV project and therefore should have been
paid on budget 63-xxxx.
3.
Prof X distribution changes were sent to her home
department Fiscal Manager but it was never
processed and this was not discovered until now.
Certified: 8/11/10
Recertified: 6/6/11
OSET: 2/23/11
OVER 120 DAYS
1.
Dr. X’s effort was placed on the holding budget
while we waited to receive the subcontract and
new budget number.
2.
Dr. X’s effort during this time was directly
attributable to the Sxxxx Study.
3.
Due to competing priorities, the analyst did not
move the funds in a timely manner.
Certified: 10/5/10
Recertified: 7/13/11
OSET: 3/17/11
OVER 120 DAYS
1.
Dr. X’s pay on 75-xxxx was a placeholder for his
work on the PPGG project. PPGG was not extended
in time to pay Dr. X for the 5/1/-8/31 period.
2.
Dr. X’s effort actually went to the benefit of PPGG
during this whole period.
3.
The authorization to extend PPGG was very late in
arriving and was entered as soon as it came.
Certified: 9/27/10
 Recertified: 5/2/11
 OSET: 11/29/10
 OVER 120 DAYS

1.
The project started January 1, but effort was not
started until May 15 due to a miscommunication with
the budget manager. The PI did not realize he wasn’t
being paid on the grant and certified his FEC.
2.
The effort reflects the actual time the PI worked on the
project and was paid by the correct budget.
3.
There was a delay in getting approval from the PI to
transfer his effort to the project requiring a
recertification of his FEC. After I received the approval, I
forgot to submit the transfer.
Certified: 10/5/10
 Recertified: no date provided; stamped in MAA on May 2, 2011
 OSET: 2/7/11
 OVER 120 DAYS

1.
Dr. X’s FTE should be paid on 65-xxxx for his grant
preparation efforts.
2.
65-3687 is the Endowment fund for research.
3.
The discrepancy was discovered during the budget
projection process. The delay was caused by the reorganization in the dept.




Certified: 9/23/10
Recertified: 5/2/11
OSET: 10/13/11
OVER 120 DAYS
1.
The effort was calculated incorrectly for budget 61xxxx. Percent effort was applied to UW salary, not
IBS.
2.
This is the actual work done on this grant.
3.
The incorrect calculation of effort was discovered
during a review of the terms and conditions of the
award.




Certified: 9/23/10
Recertified: 5/2/11
OSET: 10/13/11
OVER 120 DAYS





MAA Website, Salary Transfers:
http://f2.washington.edu/fm/maa/fec/managing/salary-transfer
GIM 15, Transfer of Expenditures Between Budgets
http://www.washington.edu/research/osp/gim/gim15.html
GIM 9, Advance Budget Numbers:
http://www.washington.edu/research/osp/gim/gim9.html
MyFinancial Desktop Help:
http://f2.washington.edu/fm/myfd/preparingtrans
NIH Grants Policy Statement, Section 7.5 , Cost Considerations, Cost Transfers,
Overruns, and Accelerated and Delayed Expenditures
http://grants.nih.gov/grants/policy/nihgps_2010/nihgps_ch7.htm
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