MAA Brown Bag

1. MAA Brown Bag SALARY TRANSFERS November 2011

2. Agenda • What is a Salary Transfer? Why do we do them? • What are best practices? • What makes a good justification? • Resources

3. What is a salary transfer? • 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

4. Why do salary transfers? • 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.”

5. Best Practices 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.

6. Best Practices • 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.

7. Justifications • 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.

8. Justification Questions • 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. • How did this employee's work benefit the grant budget to be charged? • (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.

9. Examples of Justifications • 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.

10. Redistribution of effort. • Prof X is the PI on this budget. • Certified: 8/11/10 • Recertified: 6/6/11 • OSET: 8/31/10

11. 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. • 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. • 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

12. 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.” • Charges reflect the actual FTE contributed to the grant for Dr. X. • 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

13. 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. • 10% of Prof X’s time was attributed to the X492/HIV project and therefore should have been paid on budget 63-xxxx. • 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

14. Dr. X’s effort was placed on the holding budget while we waited to receive the subcontract and new budget number. • Dr. X’s effort during this time was directly attributable to the Sxxxx Study. • 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

15. 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. • Dr. X’s effort actually went to the benefit of PPGG during this whole period. • 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

16. 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. • The effort reflects the actual time the PI worked on the project and was paid by the correct budget. • 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

17. Dr. X’s FTE should be paid on 65-xxxx for his grant preparation efforts. • 65-3687 is the Endowment fund for research. • The discrepancy was discovered during the budget projection process. The delay was caused by the re-organization in the dept. • Certified: 9/23/10 • Recertified: 5/2/11 • OSET: 10/13/11 • OVER 120 DAYS

18. The effort was calculated incorrectly for budget 61-xxxx. Percent effort was applied to UW salary, not IBS. • This is the actual work done on this grant. • 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

19. Resources • 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