Subcontract Vs. Procurement
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A Labor Distribution (LD) should be processed immediately after an error is discovered and for future distributions. Future distributions can be processed via OSCAR once the OSRAA Labor Distribution Form is completed and authorized.
Examples of circumstances that require LD adjustment:
- Delays in funding resulted in charges being initially directed to a non‐sponsored project account
- The Principal Investigator (PI) discovers an error during a monthly account reconciliation review
- The PI or other personnel on the project change their effort and there is a delay in the communication of this change, or it is communicated after the current period payroll cutoff dates
- During the effort certification process, the certifier realizes that payroll does not accurately reflect effort
If a sponsored award does not have an index established in OSU’s financial system, labor charges must be posted to a departmental, gift or pending index while awaiting set up of the project index. Under no circumstances should sponsored awards be used as holding accounts for expenses which will subsequently be transferred elsewhere, including to competing or noncompeting continuations of the same project for which the notice of award or new index number has not yet been received.
Pending index accounts are strongly recommended if a delay in award funding or execution is anticipated. The timely set up of a pending index will likely eliminate the need to process labor distributions and other cost transfers.
No. LD forms must be completed for all labor distributions affecting sponsored projects, regardless of the timeframe. However, only certain forms require OSRAA approval.
LD forms that may be processed at the Business Center and directly filed in the Payroll role in Nolij, without OSRAA approval:
- Future and current distributions that do not signify a change to the project scope of work
- Future and current distributions that do not revise key personnel effort by 25% or more for the current project budget period
- A redistribution of labor that is prior to 90 days following the end of the month in which the salary was posted and does not affect a prior fiscal year
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.
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.
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.
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.
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.
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.
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.
Dr. Lyon’s salary distribution is being updated from index N0524A to the continuation project index N0524B created for the current budget year.
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.
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.
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.
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.
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.
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.
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
The Proposal and Award Management Unit will support “full lifecycle” assistance to Principal Investigators and staff. Award set-up is now part of the Proposal Award Management Unit. So if your proposal questions, award set-up questions, award management questions, or outgoing subaward questions, the Proposal and Award Management Team is available to assist you.
The Cash and Financial Management Unit will be responsible for all review grant/contract expenditures, approve/disapprove award budget changes, prepare all required financial reports and payment requests, complete/verify all closeout requirements, and close awards in Banner. So if you have questions related to award budget changes, invoicing, financial reporting or closeouts, the Cash and Financial Management Team is available to assist you.
The Research Costing and Analysis Unit will be responsible for review and oversight of OSU’s Effort Reporting System and grant-related labor re-distributions. In addition, this unit will maintain OSRAA’s policies and procedures, provide external audit coordination for OSU. The unit will also be responsible for annual subrecipient monitoring. So if you have questions related to policies and procedures, roles and responsibilities, or external audits, the Research Costing and Analysis Unit is available to assist you.
The Data and Systems Unit will be responsible for system support for OSRAA. Examples of those systems are Cayuse and Banner. They will also perform web maintenance, data analysis, data reports and overall systems integrity for OSRAA. So if you have questions related to data or systems, the Data and Systems Unit is also available to assist you.
For any award-related or general questions, you can contact us at firstname.lastname@example.org.
For outgoing subaward questions, you can contact us at email@example.com.
The main phone number to contact us is 541-737-4933.