Formerly Executive Memorandum 83-65
Initially approved February 15, 1983
Revised January 22, 2001
Administering Office: Controller's Office
I. GENERAL AND BACKGROUND INFORMATION
Federal Circular A-21, issued by the U.S. Office of Management and Budget, sets forth the principles that determine allowable costs for work performed by colleges and universities under contracts, grants, and other forms of sponsored agreements. These principles govern the charges that may be made to sponsored agreements, financial administration of sponsored agreements, and the documentation that must be maintained for Federal audit of allowable costs.
Contracts and grants at Western Carolina University are administered in accordance with the provisions of Circular A-21.
II. EFFORT DOCUMENTATION SYSTEM REQUIRED UNDER OMB CIRCULAR A-21
Circular A-21, as revised October 27, 1998, stipulates that, when personnel costs are charged to a sponsored agreement or contributed as cost-sharing, they must be supported by a report of personnel activity which verifies (a) that the costs charged are actual, (b) that the work was performed, and (c) that the distribution of activity represents a reasonable estimate of work performed. The principal features of the personnel activity reporting system at Western Carolina University are these:
1. The Personnel Activity Report substantiates that effort pledged to a sponsored agreement was rendered. Direct charges to a sponsored agreement for salaries, wages, and fringe benefits will be made initially through the payroll procedure and verified in the after-the-fact report of activity. University cost-sharing in sponsored agreements must also be documented in the activity report but is not reflected in the payroll.
2. Each employee who is paid wholly or in part from a sponsored agreement or whose effort is pledged for cost-sharing in a sponsored agreement will report a distribution of activity that accounts for 100% of the activities covered by his/her normal compensation. The percent of effort associated with each sponsored agreement, each cost-sharing commitment, and other University duties must be separately identified by account name and number.
3. Professional and professorial employees engaged in sponsored agreements must complete activity reports on a minimum schedule of once each academic term. Other employees engaged in sponsored agreements must complete an activity report on a minimum schedule of once each month.
III. THE PERSONNEL ACTIVITY REPORTING SYSTEM FOR WESTERN CAROLINA UNIVERSITY
1. The Activity Report form will be distributed to each affected employee by the Grants Accounting Section of the University Controller's office. When issued, the report form will reflect percentages of effort budgeted for one or more sponsored agreements and for other University duties.
2. The Activity Report form is to be reviewed by the employee, revised if necessary, signed by the employee, and endorsed by the accountable officer for each sponsored activity.
3. For EPA personnel, reports will be made at the end of each semester and at the end of Summer School; for SPA personnel, reports will be made monthly.
4. The completed Activity Reports will be returned to and maintained by the Grants Accounting Section of the University Controller's office.
5. The percentage of an employee's effort that is pledged to a sponsored agreement and the percentage of his compensation charged to that agreement must not be significantly dissimilar. The guidelines to be followed in establishing equivalency between percentage of effort and salary are set forth in a document titled "Salary Determinations Pertinent to Grant and Contract Activities and Projects." This document is available in the Office of Academic Affairs and the Grants Accounting Section of the Controller's Office.