Frequently
Asked Questions about Payroll Distribution, the Plan-Confirmation
System (PCS)
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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
System Review.
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2.
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.
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3.
This all seems so cumbersome. Isn't there a better way?
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 or
more.
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4.
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 person.
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.
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5.
Can a person on sabbatical leave be charged to a ledger
5 account?
Yes, as long as the individual's sabbatical plan included
the effort in question.
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6.
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.
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7.
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 individuals 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
the problem.
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9.
Some
of our faculty received extra compensation during the
academic year. Should this be calculated into the distribution?
No, incidental extra-compensation during the academic
year does not have to be certified. |
10.
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.
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11.
Why are there two reports for graduate students and
post doctoral fellows?
Graduate
Students and Postdoctoral Associates - Service Required
Graduate
Students and Postdoctoral 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
included 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 is 1560.
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