Formerly Executive Memorandum 83-65
Initially approved February 15, 1983
Revised January 22, 2001
Revised: February 25, 2019
Policy Topic: Research and Sponsored Activities
Administering Office: Office of Research Administration
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) issued by the U.S. Office of Management and Budget, sets forth the principles that determine allowable costs for work performed by colleges and universities under contracts, grants, and other forms of sponsored agreements. These principles govern the charges that may be made to sponsored agreements, financial administration of sponsored agreements, and the documentation that must be maintained for Federal audit of allowable costs.
Contracts and grants at Western Carolina University are administered in accordance with the provisions of 2 CFR 200.
“Sponsored Agreement” is defined as externally funded activities in which a formal written agreement, i.e., a grant, contract, or cooperative agreement, is entered into by WCU and by a sponsor.
“Cost Share” is defined as the portion of a total sponsored project’s costs that are paid by WCU, rather than by the sponsor. Cost sharing of direct expenditures represents a redirection of departmental or institutional resources to support sponsored research activities. When a sponsored agreement includes cost share, it becomes a binding commitment that WCU must provide.
“Payroll Verification” is defined as a methodology to document that payroll distributions to sponsored agreements are accurate through an after-the-fact review by the principal investigator.
“Institutional Base Salary” is defined as an annual compensation paid for an individual’s appointment whether that individual’s time is spent on research, teaching, administration, or other activities.
2 CFR 200.430 - Compensation, stipulates that, when personnel costs are charged to a sponsored agreement or contributed as cost-sharing, they must be supported by a report of personnel activity which verifies (a) that the costs charged are actual, (b) that the work was performed, and (c) that the distribution of activity represents a reasonable estimate of work performed. The principal features of the personnel activity reporting system at Western Carolina University are these:
January 1 – May 31: Distributed by June 30
June 1- August 31: Distributed by September 30
September 1 – December 31: Distributed by January 31.
This policy will be reviewed every 2-4 years and revised as necessary.
2 CFR 200: OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards: https://www.grants.gov/learn-grants/grant-policies/omb-uniform-guidance-2014.html