Salaries, wages, and fringe benefits are allowable on sponsored project/grants to the extent that the total compensation to individual employees conform with KCTCS policies and when charged to a sponsored project, the charges are a reasonable representation of the actual work performed on the sponsored project. The OMB Circular A-21, “Cost Principles for Educational Institutions” provides the framework for acceptable methods of charging and documenting employees’ work performed on sponsored project/grants. The basic requirements are that the costs be allowable, reasonable, and allocable to the sponsored project/grants and treated consistently by the institution as either direct or indirect costs.
KCTCS has chosen the Plan-Confirmation method as outlined in OMB Circular A-21 for the allocation of salary and benefit expenses assigned to project/grants. At the beginning of each fiscal year, salaries are encumbered to a specific funding string(s) based on estimates of time an employee anticipates spending for each particular work activity. These estimates may be computed as number of hours or percentages of effort. The HR System allows for as many different account strings as needed for each different work activity. This information is entered in the HR System from the Payroll Activation and Authorization Record (PAAR) forms. If a new project/grant is received during the fiscal year, the same process should take place at the beginning of the project/grant period.
Federal sponsors require some assurance of the salary charged to a sponsored project is reasonable with respect to the amount of effort put forth on the sponsored project. For all fund 12 project/grant funded employees, as well as employees donating time to a sponsored project as an in-kind contribution (or cost share), KCTCS must provide verification that the salaries charged are relative to the actual effort performed. The OMB Circular A-21 dictates a formal verification be completed at least on an annual basis to confirm effort performed on sponsored project/grants. KCTCS has chosen to certify project/grant effort on a semi-annual basis (July-December and January–June).
At the end of each semi-annual reporting period, SPA will send the Time and Effort Certification forms to the appropriate Business Affairs Officers of each College. The Business Affairs Officers or their designee will be responsible for getting all of the Time & Effort forms reviewed, signed and returned to Sponsored Projects Accounting within 45 days.
Each College is responsible for incorporating all manual journals under $2,000 (per journal line amount) into the salary information of the Time and Effort Certification forms and/or creating a new form if not provided by Sponsored Projects Accounting.
Along with the Time and Effort Certification forms, SPA will send each Business Affairs Officer a query showing the manual journals involving salaries on project/grants that are less than $2,000 (per journal line amount.) It is the College’s responsibility to include these manual salary journals into the Certification forms. If SPA has sent the College a Time and Effort form for an individual whose HR salary was manually changed in the under $2,000 entries, the college makes the changes, in ink, on the Time and Effort Form. If there was a salary adjustment for an employee, for whom there is NOT a Time and Effort form, the College will need to go to the KCTCS/Forms page web site http://www.kctcs.edu/businessservices/FORMS, print out a blank GC5 form and complete all information for the salary adjustment, including the name, account strings, semi-annual base salary and individual charges for each account string with percentages on the form. The completed form must be sent to SPA within 45 days.
If a College processes a manual journal for salary and wage expenses for a prior period in which the Time and Effort Certifications have already been completed, it will be the College’s responsibility to edit and re-submit the Time and Effort Certifications forms that are affected to SPA. In the case where the manual journal necessitates the completion of a new Time & Effort Certification form, follow the instructions for completing a new form as outlined in the previous section.
Signatory Process of Time and Effort Certification/Confirmation Reports
The OMB Circular A-21 states that Time and Effort Certifications must be signed by someone who has first-hand knowledge of the employee’s work activities. This could be the individual employee themselves, the principal investigator/project manager, or a College official, as long as they can verify the salary shown on the Time and Effort Certification form is reasonable in relation to work performed for that time period. A-21 prescribes that only ONE (1) signature is required. However, Colleges at their discretion may require more than one.
Important tips related to Time and Effort Certifications:
Incidental work for which supplemental compensation is paid by KCTCS under the KCTCS overload polices, should not be included on Time & Effort Certifications forms. Time & Effort Certifications requirements are confirmed for the base salary only.
All effort worked on sponsored grants should be reflected on the Time & Effort forms regardless of whether such time is paid by sponsored funds or is an unpaid contribution, i.e., cost share or in-kind match. Cost Share efforts adjustments can be hand written on the Certification form. If an employee has cost shared on a project/grant and a Time and Effort Certification form was not provided by Sponsored Projects Accounting for this employee, the College will go to the KCTCS/Forms page web site http://www.kctcs.edu/businessservices/FORMS/, print out a blank GC5 form and complete all information; employee name, applicable account strings, semi-annual base salary and individual charges for each account string with percentages. The completed form must be sent to SPA within 45 days.
With any OMB Circular A-21 approved apportioning salary method, it is recognized that in an academic setting, teaching, training, and administration are often inextricably intermingled. A precise assessment of factors that contribute to costs is not always feasible nor is it expected. Reliance therefore, is placed on estimates in which a degree of tolerance is appropriate, but we must make a best effort in accurately completing all forms for personnel who expend effort on project/grants.