Late payroll accounting adjustments will not be processed after July 1

Beginning July 1, 2024, payroll accounting adjustments (PAAs) will no longer be processed for past certification periods. This means that:

• Once certified, effort will be considered final.
• Salary cost transfers must either be processed prior to issuance of effort certification documents or corrected during the certification process. For example, researchers must correct effort for: September-December by the end of January; January-May by the end of June; and June-August by the end of September. If effort for a past period isn’t certified, it is an unallowable cost.

Updated practice follows federal guidance

This change was made to align practice with federal guidance, which says that retroactive adjustments or cost transfers more than 90 days old should be rare exceptions (i.e., a change in the sponsors’ terms), they should not be used as a method of managing awards. While the underlying guidance is the same across agencies, the NIH guidance is the most clearly articulated. Peer universities have also implemented this practice.

PAA Office Hours

Leadership from the Enterprise for Research, Innovation and Knowledge will hold virtual office hours and provide a short overview of the change as well as answer questions Fridays from June 14 through July 26 from 9 - 9:45 a.m. 

Regular grant maintenance saves time and reduces risk

The complexity of research administration underscores the need to monitor projects and make personnel changes frequently and on a regular cadence. Awards can be monitored through the PI Portal or Workday Grants Reporting.  

Late corrections can mostly be prevented by frequent, regular grant reconciliation. Including updating appointments monthly. Effort in particular is heavily scrutinized by sponsors and auditors as it makes up the highest percentage of charges to sponsored projects. Sponsors view retroactive corrections to effort charges after certification as an indication of poor award management. Penalties for violations or findings of weak institutional controls can be significant.

Effort certification overview 

Funders ask investigators for a reasonable budget as part of the award application and, once approved, expect that the project be expensed accordingly. After work has begun, researchers are asked to confirm that the effort charges for a period are correct and complete through effort certification. 

Certification reports are generated at the end of each reporting period (three times per year at Ohio State), when Workday collects all payroll information for each employee, which is then used to compute the percentage of salary charged to each funding source. PIs certify effort for themselves and their postdocs, students and biweekly employees. Co-investigators and other professional staff certify their own reports. 

• If the report is correct and complete, the certifier approves. Effort percentages are imprecise and granting agencies consider certified levels of effort within +/- 25% of that committed to be acceptable. 
• If a report is incorrect, it should not be signed and steps should be taken immediately to initiate a correction in Workday through a PAA. When ready, the researcher will be alerted that a corrected effort report is available for certification. 

Effort reporting practices to avoid

Trying to spend a grant down to $0 is not recommended. Under the uniform guidance, charges must “reasonably reflect” what took place – small over- or under-runs are to be expected, given changes in fringe benefit rates over time and other cost differences from the time of proposal. Thus, researchers should avoid:

• Overly precise requests, such as changing an appointment by 17.345% for one month.
• Moving effort from one sponsored award to another because the second was not yet in place. 

Updated June 7, 2024