Project Effort Confirmation

Scope

This policy applies to any portion of Institutional Base Salaries (“IBS”) paid in full or in part on federal and federal pass-through sponsored research awards.

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Policy Statement

1. To meet the federal documentation requirements identified  in 2 CFR part 200.430 (Compensation - personal services), Indiana University requires Award Project Directors (Confirmers) of federal and federal pass-through awards to annually review and confirm the percent of effort for each individual charged to their awards. The percent of effort is based on the proportion of Institutional Base Salary allocated to the project. Award Project Directors (Confirmers) are required to confirm that the percent of effort and associated IBS compensation allocated reasonably reflects employee efforts on the project.
2. The requirements of this policy are in addition to those set forth in SPA-11-003, which requires Award Project Directors (Confirmers) and departmental fiscal officers (or delegates) to conduct regular reviews of all expenditures allocated to federal and federal pass-through awards and to ensure appropriate and timely corrections via cost transfers.

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Reason for Policy

The purpose of this policy is to provide direction with respect to documentation of compensation on federal and federal pass-through awards in accordance with Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, 2 CFR part 200.430 Compensation - personal services.

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Procedures

A. Project Statements

1. Project Statements are issued annually based on calendar year as detailed on the ORA website.
2. For each federal or federal pass-through sponsored award, project statements record each employee’s IBS allocated on the respective award. The Award Project Director (Confirmer) has the responsibility for confirming that the proportion of IBS allocated to the award reasonably corresponds to the employee’s effort.
3. Project Statements are available during January and February for fiscal officers and their delegates to review salary allocations with their Award Project Directors. Any final modifications to salary distribution for the prior calendar year should be completed prior to March 1^st.
4. ORA will send an email notification to the Award Project Director (Confirmer) that the annual Project Statement is ready for confirmation on March 1st, and the Award Project Director (Confirmer) must review and approve the project statement by March 31st. Extensions are allowed on an exception basis and may be granted only with prior ORA approval.

B. Mid-Year Project Statements

On occasion, Award Project Directors leave IU in the middle of the calendar year, and are not available to confirm Project Statements the following March. In those instances, Project Statements may be prepared mid-year so that the confirmation of the Project Statements may be completed by the Award Project Director prior to their departure from IU. Fiscal Officers and their Delegates should contract ORA to prepare the mid-year Project Statements.

C. Cost Transfer

All cost transfers on federal (including federal pass-through) cost reimbursable grants and contracts must adhere to IU Policy SPA-11-003, Cost Transfers on Cost Reimbursable Grants and Contracts.

D. Approved Practice Plan Effort

Retroactive pay adjustments and payroll cancellations that will change the percentage of IBS allocated to federal or federal pass-through sponsored research awards on a previously confirmed project statement require prior approval by ORA.

E. Approved Practice Plan Effort

For Approved Practice Plans, IU School of Medicine faculty may include the fixed component of practice plan salaries as part of their IBS allocated to awards, in addition to the portion of IBS paid directly by IU. In such cases, the percent of effort on the project statement shall apply equally to both sources of compensation allocated to the award.

F. Uncompensated Effort

For federal (including pass-through) projects involving uncompensated effort used as committed cost share and/or individuals serving as key personnel, the applicable department should ensure to keep documentation certified by such individuals indicating their actual effort provided over a set time. Such documentation may be in the form of an email from the uncompensated individuals, at intervals no less than every 6 months, that provide the time period, the name of the project, and confirmation of the actual effort (FTE or person months) provided by said individual on the project.  Documentation should be retained by the departmental business office for audit purposes.

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Definitions

Approved Practice Plans: Those practice plans approved by Indiana University to recover salary costs related to research conducted under the auspices of Indiana University.

Project Statements: Project statements are issued annually recording employee IBS allocation to the respective award.

Institutional Base Salary (IBS):  The annual compensation paid by Indiana University for an individual’s appointment, whether that individual’s time is spent on research, instruction, administration, or other activities. This includes, if appropriate, compensation from both Indiana University and an Approved Practice Plan.  IBS does not include overload or supplemental payments.

Award Project Director (Confirmer): The award principal investigator listed in the Kuali Coeus system for the overall award (Kuali Coeus “A” Node).

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Sanctions

Failure to adhere to the principles and processes in this policy may result in the disallowance of award costs.

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History

This policy was made effective on January 30, 2020, and was updated on December 31, 2020.

A non-substantive revision to the title of the Responsible Administrator was made on March 20, 2024. 

Previous Versions:

• Effective Dates: January 30, 2020 through December 31, 2020

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