UM launched an electronic effort/salary reporting system imbedded within U-Approve on January 28, 2018, to meet federal award requirements (2 CFR 200.430.i.8(i)). PAR records are generated from Banner, is completely separate from existing timecard/timesheet efforts, and serves two purposes:
Certify that time paid to an individual from a sponsored program was actual time spent working on that particular grant (effort certification), and/or
Certify that time shown as cost sharing was actual time spent working on that particular sponsored program but charged to another Banner Index Number (Cost Match Certification). Funds from a federal award typically cannot be used as cost match to another federal award. State and private funding can be used as cost match on all funding sources, if not federal pass through funding.
Refer to the PAR Help Guide for information regarding:
- Cost match overview
- Employee approval
- Notification emails
- PI approval/dashboard
- Process route & rules (flowchart of system actions)
- Process timeline notes
- Search functionality
- Videos to assist in understanding the process
If you still have questions after reviewing the help guide, please contact your post award SPS listed in the ORSP departmental assignments.
Email notification and employee verification
On the 28th of each month
Each employee who is paid from, or has salary committed as cost share on, an externally sponsored project, will receive an email notification to personally verify 100% of his/her institutional effort/salary. This email notification is also sent to the departmental research administrators (DRAs) listed in the ORSP departmental assignments.
Once an employee verifies his/her effort/salary, the PAR will electronically route to the principal investigator (PI) of the sponsored project.
Effort percentages reflected in PAR are based on pay amounts. As a result, effort percentages may be skewed if an individual has more than one rate of pay for different work performed. For example, an individual may devote 50% effort to one position/activity for which she is paid $15/hour and 50% to a position where she makes $18/hour. In such cases, the effort percentage for the latter will be larger than 50%. The PAR record “provides reasonable assurance that the charges are accurate, allowable, and properly allocated (2 CFR 200.430)” and it is completely appropriate that the individual review the amount of pay reflected for the work performed, and proceed accordingly.
Two weeks after the 28th
Rather than receiving an email notification when each employee verifies the PAR, the PI will receive one email notification two weeks after the 28th to review and approve (or correct) what was submitted by each employee and, if necessary, add or correct any salary cost share information. Please note that the PI will verify 1) his/her own salary as an employee and 2) again as the PI of the project.
Why do we need personnel effort verification?
Any time a person is paid by a sponsored program, it is a federal requirement that an institution verify that all of that individual’s payroll expenses (effort) are accurate, allowable, and properly allocated. Thus, UM must maintain documentation that verifies all components (100%) of an individual’s effort. Employees are reflected on PAR for two reasons:
They are paid directly from a sponsored program.
There is a cost match commitment of part of their time on at least one sponsored project and a TE indicator has been added to FRAGRNT. Each ORSP post-award sponsored programs specialist (SPS) tracks cost match commitments for all of their assigned sponsored programs. When the effort cost match commitment has been met, the TE indicator is removed. Several cost match reports are available via InfoGriz.
A helpful powerpoint presentation that explains UM's T&E reporting
The University of Montana’s time and effort reporting system is maintained to meet the requirements of OMB Circular No. A-21 J.10.c and 2 CFR 200.430.i. The time and effort report is generated from Banner HR and serves two purposes:
Certify that time paid to an individual from a grant was actual time spent working on that particular award (Time and Effort Certification, left side of the report), and/or
Certify that time shown as cost sharing was actual time spent working on that particular award but charged to another Banner Index Number (Cost Match Certification, right side of report). Funds from a federal award typically cannot be used as cost match to another federal award. State and private funding can be used as cost match on all funding sources, if not federal pass through funding.
People are selected for the report in two ways:
They are paid directly from a grant.
They have been added to FRAGRNT in Banner with a TE indicator because there is a cost match commitment of part of their effort on at least one sponsored project. Each ORSP post-award specialist tracks cost match commitments for all of their assigned sponsored projects. When the cost match commitment on a grant has been met, the TE indicator in FRAGRNT is removed.
Reports must be certified by individual departments promptly and accurately on a monthly basis. It is a federal requirement that the person signing the reports must have first-hand knowledge of the work performed. This can be direct knowledge (i.e., the employee or their supervisor certifies the time) or indirect knowledge (i.e., a department administrator can certify based on written assurance from someone with firsthand knowledge of the time worked). Each person initialing the report must also sign on the last page. The use of rubber stamps or signing another person’s name followed by initials is not allowed.
Sending Out Time and Effort Reports
After receiving from HRS, Time and Effort (T&E) reports are distributed to the departments/units by the TE Budget Analyst. Instructions explaining time and effort reporting procedures and requirements accompanies the departmental reports. This memo clearly indicates that the T&E reports are due back within one month of distribution, giving the specific due date. The TE Budget Analyst electronically maintains the T&E Checklist, recording the date the reports were mailed out to each department/unit and the due date for return of the completed reports.
If for any reason it appears there may be an unusual delay in getting the reports sent, the TE Budget Analyst contacts the director of Sponsored Programs to determine an appropriate course of action, such as rearranging duties to ensure the reports are distributed in a timely manner. If the reports are unexpectedly delayed, the departments/units are notified by the TE Budget Analyst as to when distribution of the reports is anticipated and the expected due dates for their return. This notification allows department personnel ample time to make alternative arrangements to ensure timely submission of the completed reports.
Receiving Completed Time and Effort Reports
When the T&E reports are received back from departments/units, the TE Budget Analyst logs them in on the T&E Checklist and carefully checks to make sure that (1) every salary line has either been initialed or marked to indicate that it is not correct and a payroll cost transfer is forthcoming, and (2) everyone who initialed the individual salary lines also signed the certification at the end of a report. Completed reports are recorded and then distributed to the appropriate post-award specialists for review and data entry of any cost-sharing information. The post-award specialists initial the report and return it to the TE Budget Analyst.
If the reports have not been completed properly, the TE Budget Analyst contacts the department. If an accidental omission, the TE Budget analyst documents this on the report and forwards to the appropriate post-award specialist. If additional action is required, issues are noted and dated on the T&E Checklist and the report is held until corrected.
Dealing with Payroll Redistributions
When ORSP receives a request for payroll redistribution, post-award specialists verify that the department noted the need for a change on the time and effort report for that period. If the time and effort report has not been completed and returned to ORSP, the post-award specialist may process the payroll redistribution (assuming appropriate approvals) but must make a note to verify once the T&E report is received by ORSP that it includes notation of the need for a payroll redistribution.
If the T&E report was already returned to ORSP, the post-award specialist verifies that the T&E report included a notation of the need for payroll redistribution. If that annotation is present on the report, the budget analyst processes the payroll redistribution according to standard procedures. If that notation is NOT present on the report or the T&E was certified as correct, the post-award specialist contacts the department/unit requesting additional documentation from the department/unit to explain why the T&E was certified as correct when it was not. Upon receipt of the additional requested documentation, it is filed with the relevant T&E reports.
Dealing with Past-Due Time and Effort Reports
First Notice – Two Weeks Past Due
If the completed T&E reports are not returned within two weeks of the due date indicated in the distribution memo, the TE Budget Analyst sends a First Notice to the individual to whom the original report was sent. This memo notifies the department/unit that the reports are past due, explains the seriousness of not completing the reports in a timely manner, and requires that the completed reports be submitted within two weeks. Copies of all correspondence and any other communications concerning this matter (i.e., memos or notes from telephone conversations) are retained. If the completed time and effort reports are returned by the noted due date, the TE Budget Analyst proceeds with the steps outlined under “Receiving Completed Time and Effort Reports” above.
Second Notice – Four Weeks Past Due
If the reports are not received within two weeks after the First Notice is sent, the TE Budget Analyst follows-up via phone or email and again indicates the need to complete the report, and explains the seriousness of failure to comply. The TE Budget Analyst records back on the T&E Checklist the date the memo is sent and the date the completed reports are due. Copies of all correspondence and any other communications concerning this matter (i.e., memos or notes from telephone conversations) are retained. If the completed T&E reports are returned by the noted due date, the TE Budget Analyst proceeds with the steps outlined under “Receiving Completed Time and Effort Reports” above.
Final Notice – Six Weeks Past Due
If two additional weeks pass and the reports are still not received, the TE Budget Analyst notifies the ORSP Director who sends a Final Notice memo to the PI, with copies to the department/unit support staff person (if applicable), department chair/unit head, dean or executive officer, appropriate ORSP post-award specialist, and Director of Internal Audit. This memo again indicates the need to complete the report, explains the seriousness of failure to comply, and states that if the delinquent reports are not received within two weeks ORSP staff may cost transfer uncertified personnel costs to the department/unit’s default account. Copies of all correspondence and any other communications concerning this matter (i.e., memos or notes from telephone conversations) are retained. If the completed forms are submitted, the TE Budget Analyst proceeds with the steps outlined under “Receiving Completed Time and Effort Reports.”
Shut Down Notice – Eight Weeks Past Due
T&E reports that are eight weeks delinquent are handled on an individual basis and consequences may include shut down.
Reinstating Shut-Down Accounts
If accounts are shut down due to non-compliance with T&E reports, the TE Budget Analyst and ORSP Director meet with the Director of Internal Audit to determine what corrective measures must be taken before the accounts are reinstated. If the certified T&E reports are subsequently received, the ORSP Director sends a memo to the PI indicating what actions must be taken to reinstate their accounts and what will be the final dispensation of the transferred salaries and benefits. Copies are sent to the department/unit support staff person (if applicable), department chair/unit head, dean or executive officer, appropriate post-award specialist, TE Budget Analyst, and Director of Internal Audit.
Dealing with Chronic Noncompliance
As the TE Budget Analyst reviews files of current and past overdue T&E reports, if any department/unit has had more than one past-due notice in the previous six month period, the TE Budget Analyst forwards this information, along with copies of all correspondence concerning the past-due reports, to the ORSP Director for review. If there is a pattern of non-compliance (rather than isolated incidents), the ORSP Director will consult with the Director of Internal Audit to determine appropriate action.
Retention of Completed Time and Effort Reports
T&E reports are retained per University retention guidelines.