Personal Services Reporting Using the Plan Confirmation System

GT prepares invoices to sponsors based on the information in the Institute's accounting records. The salary and fringe benefit charges that appear on these invoices are calculated by the GT Commitment Accounting System and confirmed in the GT Plan Confirmation System (PCS). Salaries charged to sponsored awards are approved by the PI (and/or their financial staff) in accordance with the terms of the award and:

• Are allocable for the project scope,
• Are allowable by the project budget,
• Are reasonable and have been incurred within the Period of Performance, and
• Have been incurred according to all GT accounting policies and procedures.

The distribution of salary and fringe benefits to sponsored projects is a sensitive issue in GT’s operation of its sponsored programs; it therefore receives scrutiny by GT officers, sponsor representatives, and federal government contracting officers and auditors. Learn more about Commitment Accounting requirements here.

Compensation for Personal Services
Compensation for personal services covers amounts earned to date for salary and fringe benefits services of employees rendered during the period of performance under sponsored agreements or other institutional activity.  The payroll distribution, which is incorporated into the official records of GT, must reasonably reflect the activity for which employees are compensated by GT, and it encompasses sponsored and all other activities.

Plan-Confirmation System – Employee Salary Charged to External Sponsored Awards and Cost Share
Under the Plan Confirmation System the distribution of salaries and fringe benefits reflects budgeted, planned, or assigned work activity based on the initial annual budget. This distribution is updated throughout the year to reflect any significant changes in work.

Workload Assignment Forms (WAFs)
The WAF, which includes both actual compensation to date and planned compensation (encumbrances) should be reviewed  by employees on a monthly basis. These forms should be retained during the fiscal year until the Annual Statement of Reasonableness of Salary Charges (ASR) is confirmed.  Unit financial managers may also produce copies for review by individual employees upon request. Employees must report workload changes to their supervisor in a timely manner. See “Employee Responsibilities” in Section 7 of this policy.

Significant Changes in Workload Distribution
Commitment Accounting provides for the modification of an individual's salary distribution, commensurate with any significant change in the employee's workload or the ratio of activities comprising the workload. Specific events, which may cause a significant change in workload distribution include, but are not limited to:

• The beginning or ending of work on a sponsored award,
• A material change in the scope of work on a sponsored award,
• An increase or decrease in the number or level of courses taught,
• A new committee or major administrative assignment or relief from a committee or major administrative assignment,
• The beginning or ending of a sabbatical leave, leave without pay, or prolonged sick leave,
• Status changes from part-time to full-time or vice versa.

The system does not require an adjustment in the employee's workload assignment for day-to-day, or short-term, changes in work schedule. However, the Commitment Accounting department does require an adjustment for all significant changes to an employee's workload. As a general rule, a change applicable to a given project or activity of 5% or more of an employee's total effort over the course of the academic term would warrant an adjustment.

Changes in an employee's workload distribution for future periods are generally acceptable but are subject to the standard documentation requirements noted below. Future period workload distributions should be confirmed monthly via the WAF.

Retroactive Changes in Workload Distribution
Retroactive changes to payroll distributions must be subjected to the closest scrutiny. These types of changes indicate a contradiction of previous monitoring reviews and, for that reason, should be limited to the correction of errors. If a retroactive change must be made, it must be approved and documented in accordance with the requirements found in the Commitment Accounting policy.

Standard Documentation Requirements
GT authorizes the principal investigator (PI) and the properly authorized unit designee (financial manager and staff) to have primary responsibility for the management of sponsored awards. The manual/electronic signatures and/or a system password of those individuals is generally considered sufficient documentation to support standard workload allocation changes.

Primary supporting documentation for PCS salary charges during a fiscal year are defined in the Commitment Accounting Policy.

Retroactive changes that cross fiscal years may be made in extraordinary circumstances by journal entry when supported by appropriate documentation, including a revised Annual Statement of Reasonableness of Salary Charges (ASR) signed by the employee or someone with firsthand knowledge and the departmental approver.

Annual Statement of Reasonableness (ASR) of Salary Charges
The Plan-Confirmation System requires an attestation to be completed annually by the employee, principal investigator, or responsible official that:

• compensation is reasonably allocated to all work performed, and
• compensation was charged to sponsored agreements as direct charges, or
• compensation was charged to both sponsored and non-sponsored funding sources, or
• compensation was charged to multiple non-sponsored funding sources.

The Office of Grants and Contracts Accounting will notify employees to complete the ASR certification, following the completion of the fiscal year.

ASR Signatory Requirements – Certification of Effort
The Annual Statement on the Reasonableness of Salary Charges (ASR) is designed for the employee to confirm that the distribution of salary charges represents a reasonable estimate of the work performed during the stated period. ASRs must be completed annually for any individuals with salary charges on sponsored funding sources. In most instances, only the employee has the information required to complete this certification and therefore ASRs should be completed and signed by the covered employee.

The manual ASR does provide a second certification section to be used in limited instances when the covered employee is not available to complete the certification. When the employees is unable to complete the ASR, the certification may be signed by the employee’s supervisor, PI, or other organizational unit head, with firsthand knowledge of all the employee's activities using suitable means of verification that the work was performed. If the responsible official cannot certify that they have personal familiarity with all of the employee's activities, then the employee is required to sign the statement. In some cases, an employee may be involved in a number of activities under different supervisors, and no single person other than the employee has firsthand knowledge of all their activities. In these cases, the employee must sign the documents.

Unit Financial Manager's Certification
The PCS also requires that the appropriate financial manager in each unit review the ASR statements before returning to them Grants and Contracts Accounting. The financial manager should sign and date each ASR to indicate that the review has been done.