Office for Sponsored Research and Award Administration

LD forms require OSRAA approval in the following instances:

• LD is for a prior fiscal year
• A redistribution of labor that is more than 90 days following the end of the month in which the salary was posted
• Any change in effort, including future distribution, that affects the project scope of work
• Any change in effort that will revise key personnel effort by 25% or more for the current project budget period

Complete the OSRAA Labor Distribution Form through DocuSign and file in the Payroll role in Nolij. OSRAA approval is not required for current or future period LDs unless key personnel effort is revised by 25% or more for the project budget period or the project scope of work is changing. See Labor Distribution Instructions for specific DocuSign guidance.

Complete the OSRAA Labor Distribution Form through DocuSign, adding OSRAA as a Recipient so the DocuSign form routes to OSRAA for approval. Once approved, OSRAA will return the approved LD to the Business Center to process in Banner. See Labor Distribution Instructions for specific DocuSign guidance.

Complete the OSRAA Labor Distribution Form through DocuSign, adding OSRAA as a DocuSign Recipient so the form routes to OSRAA for approval. Also add PayMaster as a DocuSign Recipient so that the form is routed to central payroll for processing, as required for prior year redistributions. See Labor Distribution Instructions for specific DocuSign guidance.

Yes. However, once certification of effort has been completed, only in certain circumstances will subsequent salary adjustments be permitted. If a PAR was previously signed, the PI must provide an explanation as to why the effort was certified prior to reallocating salary.

If it is determined that a redistribution of salary is appropriate, the PAR form must be revised, recertified and filed in Nolij. The completed LD form should be attached to the corrected PAR form.

Federal regulations governing administration of sponsored project personnel expenses (2 CFR §200.430 (i-1,viii)) require that institutions receiving sponsored awards have support documentation available for how payroll allocations are determined and subsequently entered into the accounting system. These allocations must be under the direction of the PI or an individual that understands the tasks and objectives to be conducted and the individuals that need to be assigned to those tasks or program objectives.

Additionally, sponsored project salary expenses must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Filing the LD form when future labor distributions are updated for new or continuing projects allows OSU to document this internal control system.

Lastly, significant changes to key personnel effort are flagged and captured before they take place, allowing OSU to comply with sponsor prior approval requirements.

Yes. As of Fall 2017, all authorized signatures are captured electronically through DocuSign.

Yes, as long as the email identifies the labor distribution and contains the certifications regarding effort of key personnel and whether there is a change in the scope of work. The detailed email must be attached as back-up documentation to the OSRAA Labor Distribution form in DocuSign.

A minimum of two signatures/approvals are required for every LD – the PI and the Business Center/Department authorizer.

A third signature - Dean/Director/Dept. Head – is required if the LD is for a distribution of PI’s labor.

A fourth signature – OSRAA - is required if the LD meets the criteria needing OSRAA review and approval.

Multiple PIs may approve the LD in DocuSign. Each PI must be added as a Recipient in DocuSign so that the form will route to each approver.

An individual may not approve their own labor distribution. The PI’s supervisor should sign the LD. For example, a PI who is Dept. Head should obtain Dean (or official designee) signature on the LD. The PI still completes the certifications for 25% effort revision and change in scope of work.

Obtaining a secondary level of approval for an individual’s own effort distribution documents OSU’s system of internal control, complying with requisite federal regulation, such as 2 CFR §200.430.

Consistent with checks and balances built into other expenditure and payroll processes at OSU, a distribution of labor should be signed by an authorizer who did not prepare the distribution. This ensures segregation of duties and further documents OSU’s system of internal control.

If more rows are needed for current and/or revised distribution sections, additional lines may be unhidden or inserted into the Excel LD form or multiple forms may be used, as long as all forms are signed by each approver.

The justification must include sufficient information to describe and document the circumstance of the LD, including why the salary was charged incorrectly to the original index and how the salary directly benefits the receiving project. The new salary distribution must match where the individual worked during the period(s) affected by the redistribution. If the transfer is 90 days or more from the initial payroll charge, include an explanation as to why salary was not transferred in a timely manner.

Also include information as to a change to the scope of work or revision of key personnel effort by 25% or more, if applicable.

Example 1:
Jane Doe’s salary was set up on Dr. Bird’s nest project N0254A due to a transposition error. The salary should have been set up on Dr. Lyon’s jungle project N0524A since that is where Jane Doe worked. The error was not immediately discovered because Dr. Bird has numerous students assigned to N0254A.
Example 2:
Dr. Lyon’s salary distribution is being updated from index N0524A to the continuation project index N0524B created for the current budget year.
Example 3:
Dr. Green’s salary distribution is being updated from P0123B to P0123C because a new index had to be set up for a change in F&A rate for year three of the grant.

Key Personnel are individuals, typically Principal Investigators, Project Directors, and Co-Investigators, whose effort is absolutely essential to the success of the proposed activity, either because of their critical leadership positions within the proposal (and consequently their intellectual guidance) or because of the uniqueness of the expertise they are contributing relative to the proposed scope of activity. The replacement of any of these individuals requires approval from the sponsor, as does disengagement from the project or reduction of project effort by 25% or more. Importantly, the level of key personnel effort includes all project effort, whether reimbursed by the sponsor or paid from institutional sources (cost-share).

Note that a sponsor may have a more specific definition of key personnel, per the terms and conditions of the award. OSRAA will identify Key Personnel in the PI Letter when the award notification email is distributed.

The certifications for change in key personnel effort and change to scope of work are applicable and required on all LD forms. If the LD is for non-key personnel, the certification may indicate that the distribution “will not” revise key personnel effort by 25% or more.

An increase in effort of 25% or more for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored awards. If there is a change in the scope of work, it must be approved prior to the change and in writing by the sponsor's Administrative/Grants Officer. The request must be processed through OSRAA in advance of the change.

While it is important that the PI maintain a good relationship with the Program Officer, this is not sufficient for documentation of sponsor approval. Any decrease of 25% or more of key personnel planned project effort, or change to the scope of work, must be approved prior to the change and in writing by the sponsor's Administrative/Grants Officer. The request must be processed through OSRAA in advance of the change.

The LD certification for revision of key personnel effort is for the current project budget period, not the specified period of distribution on the LD. The certification is intended to promote proactive dialogue between the PI, Business Center, and OSRAA regarding whether the change requires prior approval from the sponsor.

While it is true that project plans often change and effort may fluctuate over the life of the award, OSU is required to have an established method of monitoring effort changes as they occur, in order to comply with the requirement to request sponsor prior approval for key personnel effort changes of 25% or more.

Not necessarily. OSRAA will review the LD within the parameters of the regulations governing the award and specific project terms and conditions. If there is a significant revision in effort for the current project budget period but project effort will be at or near the promised level of effort over multiple budget periods, sponsor approval may not be required as long as OSU documents that the overall project effort meets the individual’s level of effort promised in the proposal and/or award.

For example, if effort is reduced more than 25% for the current budget period but will increase in a later period (or has already increased in a previous period), it may not be necessary to request sponsor approval because OSU can document that the overall effort commitment for the individual will meet the promised effort over the life of the project. The PI should still indicate on the LD form that the effort is being reduced 25% or more for the current budget period and provide information about the overall level of effort remaining as committed. OSRAA will review the LD and determine if any action is needed or if the form may simply be filed as documentation.

OSU maintains compliance with effort monitoring and certification requirements in several ways, one of which is asking the PI to confirm whether the current LD will revise key personnel effort by 25% or more during the current project budget period.

Per federal regulation (2 CFR §200.308 part c (iii)), OSU must have a process in place to identify and seek prior sponsor approval for a reduction of 25% or more of the original amount of time devoted to the project by key personnel.

Similarly, if key personnel effort is increased 25% or more, OSU needs to confirm that the revision does not signify a change to the scope of work, which also requires prior approval of the sponsor.

If these significant effort changes are only addressed during the quarterly PAR certification review, OSU is not in compliance with the federal prior approval regulation, as PARS are after-the-fact effort confirmation. OSU would then be in the noncompliant position of asking sponsor approval for a significant effort reduction or change to the scope of work after it has already taken place.

Part of OSRAA’s review of the LD form is to determine the specific effort requirements under the terms and conditions of the particular sponsored award. This is why it is important to include enough information on the LD form to explain when overall project effort will not be revised by 25% or more, even if the current budget period’s effort is significantly changed. Examples below show scenarios where effort is changed but may not rise to the level of requiring sponsor approval.

Note that these are provided only as examples - some sponsors have more restrictive prior approval terms.

Example 1:

Dr. Doyle’s effort on S0123A will be reduced by 30% for the months of June-September, 2016 so that he can increase effort on DA247B where the research is season dependent. Dr. Doyle’s effort for S0123A will increase again to focus on S0123A project work in October, after the current season. Overall project effort for S0123A will not be reduced by 25% or more and he will fulfill his effort commitment on the award.

Example 2:

Dr. Bennett will be increasing her effort on G0125C by 30% because the graduate student on the project left unexpectedly and the field analysis must be completed. The scope of the project will be unchanged.

Example of minor change in key personnel effort (<25%):

• Proposal indicates 20% effort of key personnel
• After the proposal is awarded, key personnel effort is reduced to 16% Calculation: (20% - 16%) / 20% = 20% change in effort

Example of major change in key personnel effort (>25%):

• Proposal indicates 20% effort of key personnel
• After the proposal is awarded, key personnel effort is reduced to 10% Calculation: (20% - 10%) / 20% = 50% change in effort