OMB Uniform Guidance New Standards for Confirming Compensation Charges. November 20, 2014

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1 OMB Uniform Guidance New Standards for Confirming Compensation Charges November 20, 2014

2 Agenda Overview of Uniform Guidance (UG) The UG and Personal Compensation Key Elements ecrt Demonstration Wrap-up

3 Poll Question 1 Do you think that there will be less of a focus on after-the-fact confirmation of salaries and wages by auditors as a result of the Uniform Guidance? 90% 80% 70% 60% 50% 40% 30% 85% 20% 10% 0% 15% Yes No 3

4 Overview

5 Overview of Uniform Guidance Feb 2011: Presidential Memo: Reduce Administrative Burden Feb 2012: Advance Notice of Proposed Guidance (public comments) Feb 2013: Notice of Proposed Guidance (public comments) Dec 2013: Final Uniform Guidance issued Dec 2014: Final Guidance effective, baseline metrics collected, best practices published Metrics listed in OMB Memorandum M issued 9/30/14

6 Overview of Uniform Guidance Intention: Reduce administrative burden - reduce risk of waste, fraud, and abuse Eliminated Duplicative and Conflicting Guidance A-21 A-102 A-50 A-87 A-89 A-110 A-122 A-133 Now: All OMB guidance streamlined in 2 CFR 200 Applicable to all types of grantees (excluding hospitals)

7 UG and Personal Compensation

8 Effort Reporting and the UG - what changed? 1. Requirements and standards have been streamlined across most entities that receive Federal awards. 2. Specific frequency, methodology requirements, and examples have been eliminated. 3. Phrases suitable means of verification and first hand knowledge are not included. 4. New standards for documentation of personnel expenses have been defined.

9 Sec : Compensation personal services (h) - Use of institutional base salary for IHE (i)(1) 9 standards for documenting personnel expenses (i)(3) Nonexempt employee records must indicate the total number of hours worked each day (i)(4) Salaries and wages for cost sharing must be supported in the same manner (i)(6) Alternative performance- or milestone-based proposals encouraged

10 (i)(1) 9 standards for documentation Charges to Federal awards must be based on records that accurately reflect the work performed. In addition, the records must: i. Be supported by a system of internal control that provides reasonable assurance about the accuracy, allowability, and proper allocation of the charges ii. iii. iv. Be incorporated into the entity s official records Reasonably reflect the total activity for which the employee is compensated by the entity, not exceeding 100% of compensated activities, or Institutional Base Salary Encompass both federally assisted and all other activities compensated by the institution on an integrated basis v. Comply with the entity s established accounting policies and practices vi. vii. viii. ix. Support the distribution of the employee s salary and wages among specific activities or cost objectives if the employee works on multiple activities Budget estimates may be used for interim accounting purposes Records may reflect categories of activities expressed as percentage distribution of total activities Precision about activities is not always feasible and not expected

11 (i)(1)(i) - System of Internal Control Requirement: Provide reasonable assurance about the accuracy, allowability, and proper allocation of the charges Should be in compliance with guidance in COSO framework ecrt: Applicable payroll, cost sharing, commitment, and financial data is fed directly from the institutions key source systems. Certifiers indicate the appropriate component of effort expended on activities that effort is systematically matched against charges and any differences require resolution.

12 (i)(1)(i) - Official Records Requirement: ecrt: Be incorporated into the entity s official records Whether installed locally or hosted remotely, the ecrt solution is considered the system of record supporting payroll charges to federally-sponsored programs

13 (i)(1)(iii), (iv), (vii), (ix) - Total Activity Requirement: ecrt: 100% of compensated activities, or Institutional Base Salary All activities integrated - federal and non-federal Support the distribution among multiple activities Expressed as a percentage distribution of all activities Huron and institution determine the applicable compensated activities, then incorporate these elements into data feeds Configurability provides different levels of detail and allocation

14 (i)(1)(viii) - Budget estimates Requirement: Budget estimates (estimates determined before the services are performed) are insufficient support for charges but may be used for interim accounting purposes if: The estimates are reasonable approximations of the activity actually performed. Significant changes are identified and entered into the records in a timely manner. An after-the-fact review of the interim charges is performed to ensure that all necessary adjustments are made so that the final amount charged to the Federal award is accurate, allowable, and properly allocated.

15 Poll Question 2 Do you anticipate making any changes to your overall effort reporting process as a result of the Uniform Guidance? 50% 45% 44% 40% 35% 30% 25% 20% 15% 10% 5% 27% 29% 0% Yes No Not Yet Sure 15

16 ecrt Demo

17 ecrt System Overview Payroll Data Financial Data Management and Other Reports HR Data Grants Data Personal Compensation Documentation Cost-Sharing Data (optional) Commitment Data (optional) Confirmation data and after-the-fact adjustment data can be transmitted back to the institution s source systems, if desired

18 ecrt Process Flow The diagram assumes quarterly certification, though any certification frequency (or combination of certification frequencies) can be accommodated in ecrt. Oct 1st Nov 1st Dec 1st Jan 1st Period of Performance Jan 21st Feb 28th Monthly Payroll and Adjustments Monthly Payroll and Adjustments Monthly Payroll and Adjustments Automatic System Processes ecrt Effort Statement Oct Dec Adjustments Oct Dec Adjustments Pre-Review Certification Period Automatic Notifications Users Review and Certify Effort Statements based on an Institution s Configurations and Security. Processes Initiated by End Users Reporting Capabilities on all ecrt Data Reporting Capabilities on all ecrt Data Reporting Capabilities on all ecrt Data Reporting Capabilities on all ecrt Data Reporting Capabilities on all ecrt Data Reporting Capabilities on all ecrt Data

19 Wrap-up

20 (i)(1) 9 standards Requirement Supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated Incorporated into the official records of the institution Reflect the total activity for which the employee is compensated by the institution, not exceeding 100% of compensated activities Encompass both federally assisted and all other activities compensated by the institution on an integrated basis Comply with the established accounting policies and practices of the institution Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on multiple activities If using budget estimates for the initial charges, the system must provide that significant changes are identified and entered into the records in a timely manner. Include salaries/wages for those employees used to meet cost sharing requirements on Federal awards All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated Description of applicable ecrt functionality Applicable payroll, cost sharing, commitment, and financial data is fed directly from the institutions key source systems. Certifiers indicate the appropriate component of effort expended on activities that effort is systematically matched against charges and any differences require resolution. The ecrt solution, whether installed locally or hosted remotely, is considered the system of record supporting payroll charges to federally-sponsored programs. During implementation, Huron works closely with the institution to determine the compensated activities and Institutional Base Salary for all applicable personnel, and incorporates these elements into the ecrt application. During implementation, Huron works closely with the institution to determine the applicable compensated activities, and incorporates these elements in an integrated manner into ecrt. The ecrt solution s flexibility enables the system to be set up consistent with the institution s policies and procedures. Huron personnel review the institution s policies and practices to determine if any changes are necessary to meet compliance requirements. The ecrt solution can be configured to provide different levels of detail on an effort statement, including the ability to distribute time associated to a single pay source amongst multiple activities. Huron will provide guidance on meeting the compliance requirements while configuring an effort statement with the level of detail appropriate to the institution. While payroll charges based on budget often serve as the initial reference for certification, any significant (as defined by the institution, with Huron s guidance) differences between actual activities and budget are specifically identified and require action. Reports and dashboards are built into the application to assist with monitoring outstanding action items and confirming all variances have been reconciled. Cost sharing is a key data element on an ecrt certification statement, and can be incorporated from a number of different data sources. Statements are automatically generated for certification for individuals with any type of cost sharing on Federal awards. Any significant adjustments due to differences between actual activities and budget are specifically identified and require action. Alerts can be established to automatically notify individuals when action items need to be resolved in the system.

21 Contact Information Jennifer Hubert Director (312) Nick Gallegos Director (312)

22

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