Sponsored Program Salary Adjustment Procedure

1. Purpose

Boston University receives substantial funding from the federal government and other sources in the support of sponsored programs. Office of Management and Budget Uniform Guidance, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal requires recipients of federal funding to maintain a system that documents and supports individual distribution of activities and associated payroll charges to sponsored agreements. Boston University applies these standards to all sponsors through the Personnel Activity Report (PAR) system which is driven by salary information recorded in the University’s payroll system.

In accordance with OMB Uniform Guidance, whenever it is apparent that a significant change in work activity that is charged to sponsored agreements will occur or has occurred, the change will be documented with the signature of a responsible official and entered into the system. The Salary Adjustment Request Form is the mechanism used by the University to retroactively record these changes in the University payroll system.

2. Covered Parties

This procedure applies to all individuals with salaries and wages supported by sponsored awards.

3. Definitions

Effort

Effort is the time spent on any University activity by an individual, expressed as a percentage of the individual’s Total University Effort.

Effort Certification

Effort Certification is the certified affirmation by the individual completing each PAR that the percentages of effort reported on the form are accurate and reasonably reflect their professional activity during the reporting period.

Cost Transfers:

Cost transfers are the reassignment of expenses to or from sponsored projects after initially being charged to a separate funding source.

Salary Adjustments:

Salary adjustments are the transfer of payroll expenses to or from sponsored projects after initially being charged to a separate funding source.

4. University Policies

Principal Investigators (PI) and Department Administrators (DA) should ensure charges to sponsored projects are accurate and in accordance with direct charging practices described in OMB Uniform Guidance and university policy. On a monthly basis, the DA should run financial reports for each sponsored project using Boston University’s Grants Management (Distributed) Reports, which are found in the “Reporting” tab of the BUWorks Central Portal. The administrator should work with the PI to review these reports to identify legitimate errors.

Unallowable costs, erroneously charged to an award, must be promptly transferred to your Departmental University Cost Center, Discretionary Account, or other non-sponsored project account.  Departments should work with their Sponsored Programs – Post Award Research Administrator if they have any questions on how to resolve.  Find your SP-Post Award RAResearch Administrator A Sponsored Programs team member w....

Review the Charging of Direct Costs to Sponsored Awards Procedure for reasonableness, allowability, and allocability of charges.

Salary adjustments are allowable if they are initiated to correct such errors, made on a timely basis and include appropriate justification and supporting documentation. Moreover, the costs being transferred must be allocable to the award the charges are being transferred to, if applicable.

The University’s records must contain appropriate documentation supporting an adequate evaluation of the transfer. The results must be accurate and complete. Frequent, tardy, or inadequately explained transfers, especially when they involve accounts with cost overruns, raise questions about the appropriateness of the transfers themselves, as well as the overall reliability of our accounting system and internal controls. As such, all salary adjustments involving sponsored projects must be reviewed and approved by the Research Accounting department within Sponsored Programs Post Award.

A. Processing Salary Adjustments

Retroactive payroll adjustments that involve Sponsored Programs are submitted to Research Accounting for approval and processing through SAP “Personnel Actions.” All such Personnel Actions (PA) – other than the “Salary Cost Distribution form” – must include a Salary Adjustment Request Form (SARF), which can be found here. For the Salary Cost Distribution form, the contents of the SARF are contained within the Salary Cost Distribution form itself in SAP.

Student salary transfers are processed via OnBase.  Instructions on completing a Student Salary transfer can be found here. When submitting a Salary Cost Distribution form in SAP or a Salary Adjustment Request Form, the following principles must be followed:

• Complete the form accurately and in its entirety. When the adjustment is being processed on any SAP form other than the Salary Cost Distribution form it must still be completed in its entirety and attached to the SAP PA form with all necessary supporting documentation
• Exclude the fringe calculation in the adjustment amount
• Requests for transfers in excess of 90 days from the original transaction date require additional documentation and approval as noted below

Additionally for CRC faculty on accrual, adjustments must include all original salary and accrual changes

All salary transfers must be properly documented in the Salary Cost Distribution form or on the Salary Adjustment Request Form and must include the following information:

If within 90 days of the original transaction date*:

• Justification supporting the necessity of the transfer.
• A detailed explanation of what caused the error and how it was discovered. An explanation that states “to correct a clerical error” or “transfer to correct grant or contract” is not sufficient.

If in excess of 90 days of the original transaction date*: In addition to the information listed above, the following is necessary:

• The reason for the delay in processing the adjustment.
• Identification of the controls that will be implemented or what action has been taken to ensure the error does not occur again.
• Approval by the Principal Investigator. If using any SAP PA form other than the Salary Cost Distribution form Principal Investigator signature is required. In the instances where signatures are not available, an email evidencing PI approval is adequate.

*Original transaction date is the effective date of the original charge posted to SAP.  For example, if the months of August, September, and October are being moved, the effective date is 8/1/20xx.  If the entry is being done on November 2^nd, this is a >90 day entry as the effective date is August 1^st and not August 15^th which was the payment date.

All Salary Cost Distribution forms and Salary Adjustment Request Forms are reviewed along with all supporting documentation and may be rejected or approved by Research Accounting on an exception basis. A common exception involves the set-up of a sponsored program source with an award date occurring in the past, also known as a “late award.” When appropriate, the department is encouraged to request a preaward account to ensure charging is allocated to the appropriate funding source.

Salary transfers made simply to “spend down” a sponsored project with available funding or to meet deficiencies caused by overruns or other fund considerations will not be approved. Transfers from sponsored program sources to unrestricted accounts (e.g.: departmental budgets) will always be allowed and must be completed in a timely manner to ensure accurate reporting to sponsors.

Requests not approved by Research Accounting will be returned to the individual who initiated the salary adjustment.

Terminated Employees

If a salary adjustment is required for an individual who is no longer an employee of Boston University, a paper SARF must be completed in its entirety and routed to the SP-Post Award Research Administrator.  Sponsored Programs will work with Human Resources to key this on the back end so that Payroll records are reflected accordingly.

B. Effort Certification

Salary payments from sponsored projects require certification of Personnel Activity Reports (PARs) that the salaries and wages charged to sponsored projects are consistent, fair, and timely with the effort contributed. In accordance with federal regulations, the PAR must be updated to reflect the accurate salary distribution corresponding to the expended effort. If the percentages on the PAR do not reflect the true level of effort, a salary adjustment must be performed.

Consequently:

• If the adjustment being requested affects an original transaction date for which a Personnel Activity Report (PAR) has been printed and distributed, federal regulations require that the % of Effort Expended column on the employee’s PAR be corrected to reflect the accurate salary distribution corresponding to the effort expended. The employee’s certified PAR must be submitted with the SARF or attached via the Personnel Action Form in SAP.
• If the adjustment being requested changes the effort percentages for an employee whose PAR has previously been certified and submitted, that PAR must be revised to include the adjustment and attached to the SARF or attached via the Personnel Action Form in SAP. Paper When the adjustment is greater than 90 days, SARFs must be approved by the Principal Investigator and contain a detailed explanation of the need for the adjustment and subsequent recertification. The PAR must list the revised effort percentages with each change initialed by the employee. All documentation must be approved by the Assistant Vice President, Sponsored Programs Post Award or, if unavailable, by the Sponsored Programs Post Award Assistant Director, Compliance.

The University will not accept salary adjustments that will increase the level of effort on a sponsored project beyond the level certified on the Personnel Activity Report.

5. Responsible Parties

6. Related Policies and References

OMB Uniform Guidance
NIH Grants Policy Statement
BU Effort Certification Policy
Salary Adjustment Request Form

Student SARF Quick Start Guide
Student SARF training document

7. History

This procedure was adopted in June 2011. Updated August 2014; April 2022