Personnel Activity Reports (PARs) 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 What are PARs? Federal time and effort reports required by Office of Management and Budget (OMB) Circular A-21 Salary cost sharing effort descriptions Hatch certification dollars report “Invoices” for services PARs . . . What are they? PARs are report formats used to meet the Federal time and effort reporting required by OMB Circular A-21, Section 10. PARs: quantify salary cost sharing efforts report Hatch certification dollars Think of it this way. A PAR is an invoice for the effort provided and salaries charged to a sponsored project. For example, just as you are required to retain invoices for operating expenses charged to a sponsored project, you must also retain documentation for the personnel expenses posted to the sponsored project. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 Q. Why do PARs? A. Federal regulations in Circular A-21, Section J.10: Compensation for personal services requires that educational institutions document 100% of the distribution of charges for personal services paid from federal funds. Why do we have to do PARs? This is the most common question that I receive about PARs except for: “What are these things?” We must do PARs because: Federal regulations (Office of Management and Budget (OMB) Circular A-21, Section J.10. Compensation for personal services) require educational institutions to document 100% of the distribution of charges for personal services paid from federal funds. Documentation that wages and benefits charged to an award are appropriate is required. Information about consequences of non-compliance is provided later in this presentation. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 When is a PARs created? When one of these occurs: Salary is from a Federal/Federal pass-through WBS number (24’s, 25’s & some 26’s) Mandatory Cost Share is entered in SAP Hatch project numbers are in SAP Federal/Federal pass-through - PARs are created when an employee is paid from federal or federal pass-through funds. Federal pass-through funds are funds that are awarded to an agency or other institution and then subcontracted to UNL. For instance, NDEQ may receive funding from EPA and then pass a portion of those funds on to UNL. Those funds then qualify as Federal pass-through because we are bound by federal regulations for them just like NDEQ. Mandatory Cost Share – any cost share that is required by the funding agency, or cost share that has been committed in support of the award by including it in the budget or narrative itself. Hatch project numbers are generally exclusive to East Campus. Hatch project numbers, as well as cost share information, is manually entered into the SAP system. If we don’t have the information, we can’t enter it. This is especially true for Hatch funds. If you know someone should have a form and doesn’t have it, please contact our office so one can be created. Only one of these criteria must be met for a PAR to be generated. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Documenting Personal Services (PARs) 9/17/2018 Documenting Personal Services (PARs) Level of effort can be certified by: employee employee’s supervisor* principal investigator* *if s/he has direct knowledge of all the employee’s effort for the specified work period. Note: PARs & payroll charges should support each other Retro payroll adjustments should prompt a PARs review for that time period Signature policy – Level of effort is to be certified by the employee, the employee’s supervisor, or the principal investigator, provided that s/he has direct knowledge of all the employee’s effort for the specified work period. (If the person certifying level of effort works in a different department, building, campus, state or country, be prepared to prove to federal auditors that this person has direct knowledge of the effort applied.) The best signature is be the employee’s own signature. Who knows best how you spend your time? You do! PARs and Payroll Changes – Salary charges that don’t support PAR information must be changed or the PAR information corrected. (For example, if my PAR says that I spent 25% of my time on project xyz, then the payroll should support that 25% of my salary was charged to xyz (or charged to a state aided cost center & used as cost share for project xyz.) (Johns Hopkins 21%/19%) Retro payroll adjustments – require additional PAR review if the change is material (materiality % not yet defined, but will be conservative – 3%??) It’s reasonable that a two-year delay in submission of a PARs will cause an auditor to question its validity. If your department has delinquent PARs, we are unable to set up new WBS elements for you. (Reminder: Northwestern incurred a fine in excess of $5 million because their effort reporting was insufficient.) 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 Other considerations Administrative or clerical staff salaries are generally not direct charges to an award. However, direct charges for administrative or clerical staff may be appropriate when a major project or activity explicitly budgets for these charges and personnel involved can be specifically identified with the project or activity. “Major project” is defined as a project that requires an extensive amount of administrative or clerical support which is significantly greater than the level of such services routinely provided by academic departments. Examples may be found in OMB Circular A-21, Exhibit C. Approval of charges for administrative or clerical staff salaries usually require extensive data accumulation/entry or extensive travel or conference registrations. Examples of possible administrative or clerical charges which may be identified with the project or activity include production of manuals or large reports. Research centers may also need project specific database management. Include all requests for project specific administrative or clerical support in the project proposal or obtain specific written approval from your sponsor. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 PARs Frequency BW – generated once a month MO – generated three time a year (Jan. – May; June – Aug.; Sept. – Dec.) Federal Circular (OMB A-21) requires us to run PARs for employees paid biweekly no less than monthly. Employees paid monthly must have a report after each academic term. We realize the large administrative burden that federal requirements for PARs frequency causes for PIs and support staff. However, there are ways to minimize the number of PARs needed. For example: Include cost share in proposals only when it’s required by the agency. Carefully plan work schedule ahead of time to minimize the number of PARs transfers and/or corrections. (Note: A PJ entry doesn’t show up on the PARs form and a manually adjusted PARs form must be submitted to Post Award to reflect this.) Develop a standard process for processing and collecting PARs forms that establishes deadlines for disbursing calculated PARs and collecting certified forms. Note: We are working with ASG and other NU campuses to further simplify the PARs form to make it more user-friendly and reduce the amount of time required to complete the form. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 Q. Why must we complete PARs accurately and submit them on time? A. UNL must comply with OMB Circular A-21. Possible consequences of non-compliance: Loss or refund of Federal funds Debarment or inability to receive future federal funds Disallowance of expense items that would require departmental funds substitution What can happen if PARs are not completed correctly and on time? If PARs are incorrect, it can be just as bad if not worse than not submitting them at all. If the employees are just signing the forms because they were instructed to do so and don’t understand what they are signing, there may not be a true reflection of effort. The individual who is completing and signing the form must have direct knowledge of all the employee’s effort. Federal auditors will contact the PI/researcher and inquire about grant activities performed on specific dates, as well as about their understanding of the basics of effort reporting requirements. We already know that many individuals involved in research on our campuses don’t understand the PARs form or process. This is why we are providing training sessions and encouraging you to increase awareness of effort reporting within your units. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 Consequences of non-compliance Recent audit findings: South Florida $7.0 million Northwestern $5.5 million Johns Hopkins $2.6 million There can be lasting consequences if PARS are not completed accurately and in a timely fashion. The experiences of South Florida, Northwestern and Johns Hopkins universities provide examples. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 Points to remember A total of 100% effort must be certified regardless of FTE. All preprinted WBS numbers must have a percentage assigned to them. Cost share is identified with an asterisk (*). 26xxxxxxxxxxx(21xxxxxxxx) 15%* 100% effort – Employees can’t provide more than 100% effort whether they work 12 hours or 65 hours. This includes overload. Overload should be included in their overall effort. The salary information on the right hand side of the form is only for information. The dollar amounts and calculations that will be shown to you are in this training are to be used as guidelines for completing the form. The form is to be a reflection of effort, not how the individual was paid. In a perfect world, the pay should correspond to the effort. However, this is not always the case. The best way to complete these forms is for the employee or someone with direct knowledge of the employee’s effort to distribute the percentages to the corresponding category on the left hand side of the form. Be sure that the form totals 100%. Then sign and return the form. The federal government wants to know if the employee is actually giving effort equal to the amount of pay received from federal funding. If the percentages do not agree to the salary distribution by a material amount (3%), correct payroll. Preprinted WBS # - If a number is preprinted, it indicates Federal or Federal pass-through. Each of these projects should have a separate percentage assigned to it. Please do not subtotal the different categories. For instance: if there are 3 WBS #’s listed under research, don’t add them up and put the total on the line. All percentages that are preprinted or handwritten should total 100%. Cost Share – The first number is the project for which the employee is giving effort. The number in parenthesis is the cost center from which they are actually being paid. The percentage with the asterisk after it is mandatory. If this percentage is not being met, there should be an explanation of how the cost share will be met in the remarks box. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 Points to remember Hatch dollars need a separate % for each project – HATCH0017054(21xxxxxxxx) - 10.0 Payroll Expense Transfers (PJ document type) won’t be reflected on the forms Only certify to cost objects beginning with a “2” or “9.” Ignore all other cost objects. Certify to 100%. Other campuses will certify their numbers to 100%. Hatch dollars should have a separate percentage for each project number listed on the form. Payroll Expense Transfers – PJ document types will not be reflected on the forms. While the numbers on the right hand side of the form are meant to simply be a reminder or guide, please remember that they may not accurately reflect the payroll if a PJ has been processed. “2” or “9” – indicates Lincoln campus or Central administration. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 Points to remember Ignore any negative numbers present, as well as the positive ones to which they correspond. Don’t include fellowships, professorships and work-study when certifying effort. Negative numbers – or “retros” seem to be the most difficult part of PARs. If negative numbers are present, it could mean that forms that have been previously submitted are incorrect. Prior period forms would then need to be corrected. If you have copies of the forms that must be corrected, please make corrections in red and write “REVISION” on the top right of the form. Have the revised forms signed again to reflect the revised information and date. Fellowships, professorships and work-study – There is no effort associated with these payments. Therefore, they should not be included in the calculations that will be used as a guide for completing the form. Numbers for which the 3rd-6th digits are 2307 indicate graduate fellowships and 2215 & 2315 signify work-study and professorships. They should be easily recognized by your department. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 This is a sample PAR. The next PAR shows calculations to use as guidelines for completing the form. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 To verify or figure percentages: Salary Certification: Combine all amounts listed for each individual WBS element and divide by the total salary to determine the correct percentage. Exclude any work-study, fellowships or professorships, when making your calculations. Place that percentage under the proper category 1-9. Any percentages that fall under the same category may be added together if the WBS elements aren’t preprinted under 1-9 or include cost share. Those preprinted on the left-hand side need a separate percentage. Percentages involving a WBS reported for regular pay and cost share should be adjusted to reflect (minus) the cost share percentage. Cost Share: Certify to the percentage showing on the form is correct. If you decrease the percentage, please explain how the required amount of cost share will be met. Hatch: Enter the percent of effort worked on the listed Hatch project(s). Both the Pre-printed and hand entered percentages listed must total 100%. Verify that the percentages equal 100%. Rounding is permitted. If the calculated percentages are correct, print name, sign name, date and return the original form to: Post-Award, 312 N. 14th Street, Alex West, City Campus 0431. If the calculated percentages are incorrect, fix percentages and adjust payroll as needed, sign and submit to Post-Award. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 This is an example of a PAR that includes negative numbers. In this case, one negative is in January and the other in May. For the negative listed in January, it’s clear that it will affect prior period forms as the original charges are not shown here. In this case, you would ignore the negative number as well as the positive number that it corresponds to. The positive number in this case (2528050018006) is larger than the negative number (2610070001001), so you have to reduce the $3,181.16 (positive #) by $2,532.27 (negative #) which will leave 648.89 to be used as for the time period. For the negative listed in May (2528050018005), if you look in prior months, you will notice that it corresponds to a payment made in April to the incorrect child account. Therefore, ignore the negative in May and the corresponding positive in April. If you look at the top line in May (2528050018006), you will see it is the payment for both April and May correcting the negative. This dollar amount should be left alone as it represents pay for the time period. These are relatively simple examples. There may be cases in which you have corrections that span several prior PARs. If so, be certain that the dollar amounts used to do the guideline calculations are representative only of pay received during the work period listed on the top right portion of the form as we are certifying effort for the entire work period. Also, be sure to go back to prior PAR forms and make corrections. You aren’t required to keep copies of completed forms, but it is strongly encouraged. If you don’t have copies, send a request via email for the report(s) you need. We will accommodate your request as quickly as possible. When you request an old form, please include the Employee Name, No., Department No., and Work period. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

Personnel Activity Reports (PARs) 9/17/2018 PARs corrections Remember: 3 Rs Revision Red ink Re-certify When you make corrections to PARs, remember the 3 Rs: Revision - Always mark “REVISION” at the top of the form. Red ink - Make all corrections in RED ink, and never use “white out.” Re-certify - Anytime a correction is made, the form must be re-certified and dated. If you have copies of the forms that need to be corrected, you can use them. If not, contact our office via email and the original forms will be returned to you for corrections and re-certification. 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)

9/17/2018 Questions? Personnel Activity Reports (PARs)

9/17/2018 Contact Information: Shelly Hardies Project Specialist Post-Award, 312 N 14th St., Alexander West City Campus 0431 (402) 472-2247 mhardies2@unl.edu www.unl.edu/osp/home.html 9/17/2018 Personnel Activity Reports (PARs) Personnel Activity Reports (PARs)