1. What is the
Plan-Confirmation System Review and why do we do it?
The Federal government requires the university to
have an acceptable payroll distribution system. The Plan-Confirmation
System is an acceptable system for payroll distribution
provided it meets certain standards. One of those standards
requires an independent internal evaluation of the system
to ensure the system's integrity and compliance with
standards. That evaluation is referred to as the Plan-Confirmation
OMB Circular A-21 Section J.10c (1)(e) says that "at
least annually" a statement will be signed by
the employee, principal investigator, or responsible
official(s) using suitable means of verification
that the work was performed, stating that the charges
are reasonable in relation to the work that was performed.
How does the University accomplish this?
The requirements of Section J.10c (1)(e)
are met when forms 510, 610, 506/520 turnaround forms,
and 800 forms are processed. That is when the distribution
of an individual's effort is certified. The review
we are conducting now is not related to section J.10c
(1)(e) but to meet the independent internal evaluation
requirement of Section J.10.c(1)(f) to ensure the
system's integrity and compliance with standards.
This all seems so cumbersome. Isn't there a better
There are other acceptable payroll distribution systems.
However, Plan-Confirmation is one of the least
cumbersome systems with certification occurring throughout the year
on forms already being used and only one system
review a year. Under other methods such as After-the-fact
Activity Records or Multiple Confirmation Records, documents must
by certified and collected as often as once a month
Who should actually certify effort and who should
initial and sign the Plan Confirmation System Review Reports and sign the
certification statement on the PCS letter?
The certification of effort statements found on
the various turnaround forms used at the university
(forms 510, 610, 506/520, and 800) should be signed
by a person using suitable means of verification that
the effort being certified is reasonable in relation
to the work that was performed during the period. This
could be the actual individual who performed the work,
the principal investigator, or some other responsible
The Plan Confirmation System Review Reports should be reviewed and initialed
by a person in a position to verify the accuracy of the distributions.
The Department Chair/Director should sign the statement on the PCS letter
certifying that the reports are used in the department to monitor
and, when necessary, change effort distribution.
Can a person on sabbatical leave be charged to a ledger
Yes, as long as the individual's sabbatical plan included
the effort in question.
I know that multiple changes are going to be made in
an individual's distribution before the next review. How do these changes
in effort get certified?
This review requires that you verify the distribution of effort as of
the date of the Plan Confirmation System Review Reports. If the distribution
is incorrect, it needs to be corrected and is "certified" as the appropriate
turnaround form is processed
What is the government's rationale for not allowing
secretarial and clerical effort on sponsored projects?
The government believes that the effort of secretarial
and clerical staff should be included as part
of the facilities and administrative (F&A) costs
of the institution reasoning that it is difficult
to track or isolate the effort of this category
of staff who are likely to be working on many
different projects and activities at the same time. So, unless
the time of administrative and clerical staff
is specifically identified and approved in the budget,
it will not be allowed as a direct charge. This
is not necessarily the case with non-federal sponsors.
8. My Plan Confirmation System Review Reports are missing the names of
individuals who have joined the department. Why is this so?
Most likely these are individuals who arrived
after the listing was run. These indivduals should be on the
listing for the next review. If the person has been in the department
for some time, and is not listed, contact PERC so they can research
Some of our faculty received extra compensation during
the academic year. Should this be calculated into
No, incidental extra-compensation during the academic
year does not have to be certified.
Why does every page need to be initialed? Likewise,
why do we need to give detailed explanations rather then
just being able to indicate that the distribution
is okay and signing?
Every page needs to be initialed so it is clear that
each person's distribution has been reviewed. The detailed
explanations show that the reviewer is using the system
appropriately and understands the issues surrounding
the distribution of effort.
Why are there two reports for graduate students and post doctoral fellows?
Graduate Students and Postdoctoral Associates
- Service Required
Graduate Students and Post doctoral Fellows - NO Service Required
Graduate students and postdocs appointed by
506/520 forms are appointed to positions that either require services
or do not require services in return for the monies they receive.
Individuals with appointments that do not require service do not
require effort certification. The NO Service Required Report is includded
for your reference and verification to make sure the student/post
doc is classified appropriately. The distinction between "service
required" and "no service required" is made by using position codes
and subcodes. In the case of graduate students, position code 0999
and subcode 1690 is used to denote "no service required"; for post
docs the "no service required" position code is 0095 and subcode