1. What is the Plan Confirmation System Review (PCSR) 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.
2. OMB Circular A-21 Section J.10.c.(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.10.c.(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 to obtain certifications for individuals who did not have a personnel form change in the past year and to meet the independent internal evaluation requirement of Section J.10.c.(1)(f) to ensure the system's integrity and compliance with standards.
3. Who should actually certify effort and who should initial and sign the Plan Confirmation System Review Reports and sign the attestation statement on the PCSR 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 each page initialed by a person in a position to verify the accuracy of the distributions. The Reviewer and Department Chair/Director must also sign the attestation statement on the PCSR letter. The Department Chair/Director is signing to confirm the reports are used in the department to monitor and, when necessary, change effort distribution.
4. 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.
5. 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 (i.e. September 30). If the distribution is incorrect, it needs to be corrected and is "certified" as the appropriate turnaround form is processed.
6. 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.
7. My Department’s 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 Payroll to research the problem.
8. 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.
9. Why does every page need to be initialed?
Every page needs to be initialed so it is clear that each person's distribution has been reviewed.
10. Why is a detailed explanation required, rather than just being able to indicate the distribution was incorrect and signing?
The detailed explanations show the reviewer is using the system appropriately and understands the issues surrounding the distribution of effort.
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 169X is used to denote "no service required"; for post docs the "no service required" position code is 0095 and subcode is 156X.