Where sponsored projects are concerned, the responsibility for personnel hiring and supervision rests with the Principal Investigator for that particular project. The PI must keep in mind that all personnel actions, including those funded by external sponsors, are subject to University policy. Due to the complexity of personnel rules and regulations, the PI should seek out a knowledgeable individual within the department—likely the departmental personnel and payroll liaison—to get assistance with personnel responsibilities, actions, policies, and procedures. All questions regarding employment issues should be addressed to the department’s payroll or personnel administrator. Fringe benefits are an allowable, direct charge to a sponsored award. Fringe benefits must be charged in proportion to the salary paid and certified to the project.
Personnel assigned to sponsored projects, like all other personnel, must be appointed and compensated in keeping with State and University personnel rules. Exempt and Non-Exempt staff, Faculty and all other types of personnel are governed by the policies and procedures found at: https://hr.umbc.edu/policies/.
According to 2 CFR 200 – UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS, Federally sponsored projects (either awarded directly by a Federal agency or by virtue of a subaward through another prime contractor) may not normally be charged for secretarial and administrative salaries, office supplies, postage or telephone costs unless a particular project requires an unusual and extensive degree of administrative support.
OMB also requires the University to maintain records that will substantiate the effort of each individual charged to a sponsored project in accordance with the commitment of effort included in the proposal. Therefore, time records must be carefully maintained. For faculty, staff, and graduate assistants paid on a sponsored project, effort is recorded on the Effort Report distributed to each principal investigator by the Office of Cost Accounting twice per year:
Fall Period: Due March 31st and includes pay periods 1 – 14
Spring Period: Due September 30th and includes pay periods 15 – 26
Effort certification attests to the appropriateness of salaries and wages charged to a sponsored award. To confirm that the distribution of payroll costs represents a reasonable allocation of the work performed by the employee during the period, the effort must be certified by the PI or a responsible official in a position of authority and with firsthand knowledge with respect to the employee and the employee’s work.
Employees who are paid on an hourly basis are not currently included in the effort certification process since the effort of hourly employees is certified when employees sign their timesheets through the time collection process.
Since the great majority of costs associated with sponsored projects are attributable to labor charges, it is incumbent upon the Campus to assure these records are properly maintained.
Any payroll expense that is disallowed by a funding agency or an auditor due to non- certification becomes the responsibility of the respective department or institute.
Final points about effort:
- Due to the combination of sponsor regulations and the relative unstructured nature of research, accounting for the effort of personnel assigned to grants and contracts requires more attention than is typically paid to other academic activities
- The salaries and wages charged to a project must represent the proportionate share of effort that directly benefits the project
- Sanctions for non-compliance can be serious, including criminal charges
- The Principal Investigator is responsible for all financial activity charged to their sponsored projects, including charges associated with personnel
Tuition remission provided to graduate students is an allowable cost if it is in lieu of additional salary for services performed on a sponsored project. If the tuition remission is not salary, it is considered to be student aid. As a rule, student aid is normally not an allowable cost of sponsored projects.
Employee tuition remission is a waiver of tuition and is available to benefit-eligible employees and eligible family members who qualify. Only employee tuition remission is an allowable charge on a sponsored award. All family member tuition remission is unallowable.
Tuition remission charges must be charged to the same project, in the same proportion as the salary. In addition, these costs must be excluded when calculating the Modified Total Direct Costs (MTDC) to determine the overall project’s F&A costs.