Policy Content
Please note: This policy is currently under review and subject to change. Please contact the eric_asetta [at] emerson.edu (Executive Director for the Office of Research and Creative Scholarship) with any questions.
Summary
This policy statement provides general guidelines for distributing and reporting labor costs of Emerson employees, post-doctoral fellows, and graduate students to sponsored programs.
Background
Salaries constitute the largest component of expenses charged to sponsored projects. For Emerson, this includes the salaries and wages paid to employees, post-doctoral fellows and students both undergraduate and graduate. It is essential that individuals working on sponsored projects understand the basic principles underlying the allocation of effort, and the charging of salaries, to those projects. There are three important points to keep in mind:
- For regular employees, post-doctoral fellows, and students, their pay is considered to be remuneration (without regard to taxability of the payment) for all work that benefits Emerson.
- Each month, Emerson’s payroll system allocates earned salary to proper projects or cost centers. The allocation is based on the nature of the work performed by the individual and the effort of the individual.
- Sponsors expect to pay only for the portion of an employee's effort that is actually devoted to those projects. Periodically, government and external auditors review non-sponsored payroll charges to enforce this expectation. Effort spent on sponsored projects, but funded by non-sponsor funds, is considered cost sharing on the project and must be identified in the same manner as effort paid for by the sponsor. See Cost Sharing policy.
Federal Regulation
The Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions, establishes the principles for determining costs to grants, contracts, and other sponsored agreements. Section J.10 of the Circular specifies the requirement that the distribution of salaries and wages to awards must be supported by after-the-fact reports.
Policy
Individuals Required to Report Effort Distributions
Employees, post-doctoral fellows, and students who fall within the following classifications must complete monthly reports reflecting the distribution of activity:
- Professionals and nonprofessionals whose compensation is charged, in whole or in part, directly to awards. Nonprofessional employees are defined as those who are subject to the Fair Labor Standards Act; and
- Professionals and nonprofessionals who perform services on sponsored projects to meet cost sharing or matching requirements on awards must report their activity in the same manner as salaries and wages claimed for reimbursement from awarding agencies. See Cost Sharing Policy for exceptions.
Reporting Requirements
Individuals required to report effort distributions must complete and sign after-the-fact reports covering the total activity for which they are compensated and which is required in fulfillment of their obligations to Emerson.
The reports must be signed by the Principal Investigator or by a responsible supervisory official having first-hand knowledge of the activities performed by the employee. The signature certifies that the distribution of the activity represents a reasonable estimate of the actual work performed by the employee during the period covered by the reports.
The reports must be prepared quarterly and must coincide with a pay period.
Effort Categories
In order to calculate applicable Facilities and Administrative (F&A) cost rates, direct costs must be accumulated by major functions of the institution, and F&A costs must be identifiable to each of the major functions. Emerson’s accounting system establishes an individual cost center in which costs are accumulated for each activity in which there is a need to report costs for management purposes. The labor distribution and cost accumulation system used by the College are categorized within the accounting system so that major functional costs are easily identified and summarized.
While compliance with the policy statement is required for time & effort reporting for all covered employees, postdocs, and students, it is particularly important for the following effort areas:
Sponsored Instruction includes instructional activities funded by external sponsors.
Organized Research includes all activity related to a specific externally sponsored research project or to separately budgeted College research. Effort for independent research and study, under fellowships, not administered by the College while faculty member is on leave of absence without pay should not be included on this report. If effort is allocated to this category, the appropriate grant fund number must be provided if not already displayed on the form. Effort related to separately budgeted College research and to externally sponsored research projects should be reported under Sponsored Research.
Examples include:
- Planning of and experimental work on the awarded project
- Preparation of project results
- Supervision of employees on project
- Correspondence and general participation in project related activities
- Readings directed toward project goals
- Administrative effort related to a specific project
- Meetings related to the specific sponsored project
Other Sponsored Activity represents programs and projects financed by federal and non-federal sponsors, which involve the performance of work other than Instruction or Sponsored Programs.
Cost Sharing represents any additional effort expended on sponsored project in excess of the amount awarded. Any explicit commitment to cost-share salary included in a proposal to a sponsor (whether voluntary committed or mandatory) becomes a condition of that award once the proposal is funded, and it must be separately tracked by project and certified in the effort reporting system. See the policy statement, Cost Sharing, for additional explanation.
Non-Sponsored Instruction represents teaching activities.
Examples are:
- Scheduled courses
- Curriculum development
- Continuing education (excluding overload assignment, paid by payroll voucher)
- Academic advising
- Supervising undergraduate, graduate and postdoctoral students in work not related to sponsored agreements
- Short courses, meetings, or developmental assignments related to instruction
Departmental Research represents research effort supported by a department or school, not separately budgeted. This also includes developmental assignments related to research.
Institutional Review Board represents effort only by individuals who serve on any of the Research Regulatory Committees, including Institutional Review Boards and Conflict of Interest in Sponsored Programs Committee.
Collegiate and Departmental Administration represents administrative activities, which include:
- Policy and other committee work including representing college on Faculty Senate or faculty evaluation committee
- Assigning faculty workloads
- Preparing departmental budgets
- Planning departmental operations
- Providing services such as statistical, supportive of, but not chargeable to, sponsored projects
- Writing and/or reviewing proposals (any post award administrative effort to a specific sponsored project should be posted to the Sponsored Research/Other Sponsored Activity category)
- Professional development related jointly to all aspects of the department (short courses, professional meetings, developmental assignments.
Emerson Salary and wages are defined as the pay that an individual receives as remuneration for all work that benefits Emerson.
Procedures
Monthly Budget and Payroll
Preparation of the detailed salary budget is normally the first step in the operating budget process for the coming fiscal year. Based on employee evaluations and available funds, the rate of pay is established for each regular employee. Next, workload assignments are established and salary costs are coded for appropriate cost distribution according to the time intervals to be worked and the percentage of effort budgeted under the planned workload assignments. The coded cost distribution records are established in the budget system. The budget is loaded into the human resource system to create the payroll files for the fiscal year beginning July 1.
Cost sharing is the financial support contributed by Emerson to sponsored research. Cost sharing and matching represent that portion of the project or program costs not borne by the sponsoring agency. The College is expected to recognize the portion of each faculty's time devoted to cost sharing when the cost sharing effort is: i) required as a condition of the agreement, or ii) 10% or more of the faculty member's effort. For more information, refer to the policy statement, Cost Sharing.
Salary costs are posted in the accounting system according to the percentage cost distributions recorded in the human resource or student employment system. Since work assignments are subject to change, principal investigators are expected to constantly monitor the budgeted work assignments and update these predetermined cost distributions by use of the on-line labor distribution system when significant changes occur.
Time & Effort Reporting
The time & effort report is produced quarterly and includes the paid cost distributions for each employee paid by at least one sponsored program. The purpose of the report is to provide assurance that the salary costs, as charged, are representative of the actual time and effort expended by employees during the month. If actual time and effort differs significantly from the payment distribution (5 percent or more of total effort over a 3 month period), an adjustment must be made in the human resource system, which is integrated into the accounting records.
The time & effort report contains the following information
- Home Department (Department Code and Name)
- Month for which time and effort is being reported
- Employee's identification number
- Employee's name
- Classification code
- Title
- Position number
- Cost distribution
- Cost center number(s) from which employee was paid
- Employee's monthly rate of pay
- The intervals during the month for which the employee was paid
- Percentage of time and effort (paid from this cost center for this interval and effort expended for the project)
- Amount paid (from this cost center for this interval and effort expended for the project)
A data field is provided on the form to record a positive confirmation of each employee's cost distribution records. The PI or a responsible supervisory official having first-hand knowledge of the activities performed by the employee is required to confirm that the cost distributions are reasonably representative of the work performed for the period.
The Quarterly Time & Effort Reports are available on about the 3rd day after the quarter-end. The confirmation process is completed prior to the 8th working day of the following month (or 5 business days after the report is available). For example, if August 31 ends on Sunday, the report is available on Wednesday September 4th. The confirmation must be completed by September 11th. (This needs to be updated)
