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Revised 12/13 2 Table of Contents

General Post-Award Office Responsibilities...... 1 Receipt of an Award...... 1 Establishment of Sponsored Indexes...... 1 Approval Queue...... 1 Providing Orientation & Training to Project Directors & Principal Investigators...... 2 Approval of Budget Modifications & Cost-transfer Requests...... 2 Invoicing of Sponsors...... 2 Deposit of Payments...... 2 Oversight of Fiscal & Administrative Compliance Issues...... 3 Development & Submission of Financial Status Reports...... 3 Oversight of Level of Effort Reporting...... 3 Oversight of Closeout Activities...... 3 Annual Audits...... 4

General Principal Investigator Responsibilities...... 5 Award Negotiation & Pre-Award Costs...... 5 Management of the Award...... 5 Expenditures During the Life of the Project...... 6 Project Fiscal Management...... 6 Project Closeout...... 12

General Procedures for the Fiscal Management of a Grant Award or Contract...... 14 Allocable Costs...... 14 Allowable & Unallowable Costs...... 15 Reasonable Costs...... 15 Expenditures Procedures...... 15 Travel Procedures...... 15 International Travel Supported by Federal Funding...... 16 Meals & Light Refreshments...... 16 Consultants...... 16 Bid Requirements...... 18 Bid Thresholds...... 18 Memoranda of Agreement...... 18 Stipend Payments...... 20 Payroll Action Form (PAF)...... 21 Student Employees...... 22 Graduate Service Appointments (GSA)...... 23 Employees with Official Work Stations in Other States...... 23 Insurance Eligibility for All Temporary Employees...... 23 Level of Effort Reporting...... 23 Ownership & Control of Equipment...... 23 Indirect Cost Recovery (ICR)...... 24 Project Over Expenditures and Unallowable Costs...... 25 Closing the Grant Index...... 25 Program Income...... 26

Revised 12/13 General Procedures for Project Monitoring & Reporting...... 27 Signature Authority...... 27 Record Keeping...... 27 Subcontractors (Sub-awards)...... 27 Financial Reports (Banner Finance System)...... 27 Animal Care & Use Protocol Review Compliance (IACUC)...... 45 Protection of Human Subjects Compliance (IRB)...... 45 Investigator Significant Financial Interest Disclosure...... 45 Records Retention...... 45

APPENDIX: Level of Effort Reporting...... i-ix

4 General Post-Award Office Responsibilities

The function of the Post-Award area within the Office of Grant and Research Development (OGRD) includes overseeing the financial administration of externally funded grants and contracts received by EWU. (Incidentally, Academic Affairs oversees the financial administration of internally funded grants, such as the Faculty Research Grants.) Some of the OGRD responsibilities include:

Receipt of an Award (Signature Authority) The Associate Vice President of Business and Finance has the Board of Trustees’ authorization to accept awards on behalf of EWU. All sponsored awards must be processed by the OGRD to be reviewed and accepted on behalf of the university. Any Notice of Award (NOA) or agreement documents that are sent directly to the PI should be sent to the OGRD immediately upon receipt. The OGRD reviews all terms and conditions of an award and assures the sponsor’s requirements are compatible with applicable laws and EWU’s policies and procedures. Since a sponsored award binds both the sponsor and EWU to certain contractual commitments, it is important that the terms are clearly understood and that all concerns are resolved before the award is accepted. Most awards require the signature of an authorized institutional official to formally accept the terms and conditions of the award. The OGRD is responsible for obtaining the authorized institutional signature of the Associate Vice President of Business and Finance. PIs are cautioned not to sign any agreements for sponsored support, patents or copyright licenses, biomaterials, equipment loans, work for hire, confidential disclosure agreements, materials transfer, or event subcontracts. These agreements bind the university to certain obligations and, as such, can be signed only by the Associate Vice President of Business and Finance or in some cases, the Purchasing Department.

Establishment of Sponsored Indexes Once an award has been accepted for the university, exclusive index and fund numbers are established for each new contract or award, against which obligations and expenditures will be charged. The use of the awarded funds is restricted to the sponsor-approved project budget and the terms and conditions of the award. The PI will receive written notification of the index number, fund number, organization number, program number, and grant number assigned to their award. The award identification numbers will also be sent by the OGRD to the Purchasing Department. The Purchasing Department will send a signature card out and contact the PI to set up the approval queue for electronic purchase requisitions.

Approval Queue For new grant indexes, the Purchasing Department will determine if a grant approval queue has been established for the Banner organization in which the grant resides. The Purchasing Department will update the fund in that queue and notify the approver or primary finance person for the area. If an approval queue has not been established for the organization, the Purchasing Department will verify whether the Project Director has access to the Banner Finance System. If the PI does not have access, the Purchasing Department will contact the College or Department finance personnel to determine how requisitions approval will be handled, either by the PI or the College or Department finance personnel.

Providing Orientation and Training to Project Directors or Principal Investigators in the

5 Rev. July 21, 2018 Financial Administration of the Award Once an award has been accepted by the university and the index number is established, the OGRD will contact the PI in writing to schedule an orientation meeting. It is equally important for new and experienced PIs, along with any other personnel responsible for assisting the PI in fund management, to attend the orientation session as terms and conditions, reporting requirements, project and budget modification requirements, and procedures will vary with each award and each sponsor.

Approval of Budget Modifications and Cost-transfer Requests The OGRD staff assist with monitoring budgets, budget modifications, cost transfers, and expenditures against grant and contract accounts for compliance with university, state, federal, and sponsor guidelines to ensure policies are consistently applied. In many cases, sponsors have granted the university the ability to approve some budget changes between budget categories that are less than 10% of the overall budget. In other cases, a budget revision will need to be approved by the sponsor in writing. The OGRD will review and approve all requests to sponsors for budget revisions and modifications prior to submission to the sponsor. Additionally, the OGRD must review and approve all transfer of costs and budget modifications signed by both parties.

Invoicing of sponsors/ initiating the submission of cash drawdown for federal awards The OGRD staff prepares invoices quarterly, monthly or as required in the Notice of Award or contract. Occasionally, the OGRD staff will need to work closely with the PI to determine the nature of expenditures for proper identification on invoices. When an award is “Firm-Fixed Price” the OGRD will usually invoice in four quarterly equal dollar amounts with the last invoice dated when the project is complete. When an award is “cost reimbursement;” meaning the university is reimbursed after expenditures are paid, the OGRD will invoice either by the frequency designated in the award documents or on a regular basis based on the flow of expenditures posting to the index, typically on a monthly basis. In some cases, funds are transmitted electronically to EWU from the funding agency. The General Accounting Office will coordinate with the OGRD to submit electronic cash drawdown requests.

Deposit of payments All checks and payments on agreements are mailed to: Student Financial Services/ Office of Grant and Research Development Eastern Washington University 202 Sutton Hall Cheney, WA 99004-2448

In the unlikely event the PI receives a payment from a sponsor, the PI should deliver the check to the Cashier’s office located on the 2nd floor of Sutton Hall immediately with instructions for the Cashier’s office to call the Office of Grant and Research Development to obtain information needed to make sure it is deposited in the correct index, fund, and account number.

Oversight of Fiscal and Administrative Compliance Issues Relative to Fiscal and Administrative Management of Funded Projects. The OGRD staff assist in monitoring budgets, budget modifications, and all expenditures 6 Rev. July 21, 2018 against grant and contract indexes for compliance with university, state, federal, and sponsor guidelines to ensure policies are consistently applied. Each expense charged to the index must be directly related to the project, must be allowable under the terms and conditions of the award, and must be included in the sponsor-approved budget. All paperwork and documentation for expenditures must be sent to the OGRD office for approval/signature before being paid; including, but not limited to, Payroll Action Forms (PAF), purchase requisitions, Memorandum of Agreements (MOA), invoices, and travel authorizations. The OGRD staff will review the paperwork and the index’s budget to ensure the expenses are included in the budget and review the Banner accounting system to verify adequate funds are available at that time of the expense. If there are questions, concerns, or missing paperwork the PI will be contacted immediately; however, expenses charged to the index are still the direct responsibility of the PI, not the OGRD.

Development and Submission of Financial Status Reports to Sponsors The OGRD staff is available to assist in all financial reporting requirements of the project including progress reports and final reports. It is essential the PI provide the required forms to the OGRD staff to facilitate timely completion of the forms. Federally funded awards usually require the OGRD to prepare and submit annual Financial Status Reports (FSR 269 or Federal Financial Report FSR 425) at the end of each year of the award or as required in the Notice of Award or Grant Agreement. A copy of all completed Financial Status Reports will be provided to the PI as they are prepared. The PI must assist the OGRD in completing final financial reports by providing any information requested by the OGRD in a timely manner.

Oversight of Level of Effort Reporting All federally funded grants, including grants funded with federal pass-through funds, require monthly Level of Effort reports to be generated and signed by the employee and the PI working on the grant. The OGRD prepares all of the Level of Effort monthly reports, named the “Personnel Activity Report,” on federally funded projects and sends them out for signature. These reports are generated and issued one to two months after the date payroll was paid by a federally funded grant. They must be reviewed, signed, and returned to the OGRD for further processing and reporting. Please note that the Department Chair or Dean must also sign the Level of Effort reports for the PI’s effort.

Oversight of Close-out Activities, including Transferring of Residual Funds The close out reporting process is a multi step process that includes OGRD working directly with the PI and/or their support staff to accurately report the final financial status of the project.

The PI’s tracking spreadsheet and the current Banner index reports should be compared to determine if all expenses have posted to the index. If there are expenses that have not posted, copies of the documents submitted for payment along with a spreadsheet listing the outstanding expenses must be submitted to the OGRD post-award staff member working to submit the final invoice. All discrepancies between the PI’s records and the Banner index must be substantiated with appropriate documentation in order to reconcile the index. Nearly every contract or grant requires a final financial statement to be submitted with the PI’s final program report or with the final invoice. A copy of the PI’s final program report must be submitted to the OGRD.

When the final payment from the sponsor is received, the OGRD staff will review the Banner accounting reports to make sure the index is at $0 cash balance and all expenses included on an 7 Rev. July 21, 2018 outstanding expense list have posted to the index. If additional expenses were posted to the index, they must be transferred out of that index before it can be closed. No encumbrances against the index should be showing at this time. If there are encumbrances, they must be resolved and deleted. The OGRD will discuss any questions with the PI and close the index when the cash balance reaches $0.

If the index is for a “Firm-Fixed Price” contract and there is a positive cash balance, the remaining indirect costs budgeted will be distributed according to the university’s indirect distribution policy if they are equal to or greater than $100. The remaining balance is then distributed to the PIs indirect cost recovery index/fund.

Annual Audits The State of Washington conducts annual audits of the University and all grants and contracts are included in this audit. Any grant or contract is subject to an in-depth review by state appointed auditors. The OGRD coordinates all external audits with the PI and other university units, as appropriate. Should a PI be contacted regarding a records request directly by an external agency, please refer them to the OGRD immediately. The OGRD will provide all necessary information.

8 Rev. July 21, 2018 General Principal Investigator (PI) Responsibilities

The Project Director (PD) or Principal Investigator (PI) is the primary individual in charge of a grant, contract, cooperative agreement, or other externally sponsored activity. The term “project director” is commonly used in relation to education and public service projects or programs, while the term “principal investigator” is commonly used for research projects. Since the terms are generally used interchangeably by the Office of Grant and Research Development (OGRD) staff and by many sponsors, the term “PI” is used throughout this document to mean principal investigator or project director.

In some cases, multiple investigators (Co-PI) are named in applications for external funding. However, agencies and the university require that one individual be designated as the principal investigator since both the agency and the university must have one individual designated as ultimately responsible for the conduct of the project. If co-investigators are named on an application without identifying an individual as the PI, the person listed first is considered the PI by the university and the agency.

The National Science Foundation (NSF) has clarified their definition of a Principal Investigator to state that regardless of what an investigator is called, there is no distinction between the “scientific stature of PIs,” regardless of whether they are called a PI or a co-PI. All will be equally responsible for the project, but the first name listed will be the contact PI for the NSF.

Award Negotiation/Pre-Award Costs The PI negotiates any requested changes to the proposed scope of work and budget with the sponsor in collaboration with the OGRD. If the sponsor requests budget changes, the PI must obtain the approval of the OGRD before submitting a revised budget to the sponsor. Some funding agencies may grant limited pre-award expenditures if prior approval is obtained. However, PIs should note that such approvals are allowed by the OGRD with the understanding that the PI’s department assumes all risk associated with the establishment of an index prior to receipt of an award notice from the sponsor. If the award is never received or if the effective date of the award falls outside of the agency-allowed pre-award period, the PI and his or her department and/or college will be responsible for all costs incurred.

Management of the Award The PI is responsible for the proper conduct of the work (performance of the project activities) and for the administrative and financial management of the project. The OGRD staff assists the PI with administrative and financial management of the award. While the university is the legal recipient of awards and ultimately is legally responsible to the sponsor for the performance of the funded activities and the proper use of sponsor funds, the university cannot meet its responsibilities to the sponsor unless the PI meets his/her responsibilities. Only the PI can truly know if expenses charged to a grant or contract index/fund are legitimate, project-related costs. Only the PI can assure performance of the technical aspects of the project and completion of sponsor-required technical reports. The university is responsible for maintaining adequate fiscal controls and ensuring that fiscal policies are applied consistently. Therefore, management of externally funded projects is truly a partnership between the PI and the OGRD.

9 Rev. July 21, 2018 Expenditures During the Life of the Project This handbook describes various types of expenditures, which may be included in the project budget and the processes for the expenditure of the funds. PIs are encouraged to develop a spreadsheet for tracking the expenses approved for payment and update it every month after the Banner accounting system month-end close. Month-end close occurs around the tenth of the following month.

Project Fiscal Management The PI is responsible for complying with all the financial terms and conditions of the award. This includes ensuring that costs are correctly charged to the index according to the sponsor- approved project budget and the terms and conditions of the award. Each expense charged to the index must be directly related to the project, must be allowable under the terms and conditions of the award, and must be included in the sponsor-approved budget. Any questions concerning the allowability of costs should be directed to the OGRD staff prior to incurring the cost. The OGRD staff can assist the PI in determining if the cost is allowable under the current budget or if a budget revision is required. The PI is ultimately responsible for all costs charged to their index. While the PI may delegate some responsibility for the day-to-day management of finances or other tasks to departmental business staff, the PI remains accountable for compliance with university and sponsor requirements. Such designated employees need to be included on the signature card and the signature card must be submitted to the Purchasing Office. If the original signature card has already been sent to Purchasing, an additional card may be obtained and the designee can sign the card and send it to Purchasing. The PI must attend Banner Basics, 201, and 204 training in order to monitor the index activity and generate financial reports. Training sessions may be scheduled online at www.ewu.edu/trainingscheduler .

Ultimately, the PI and the PI’s unit are responsible for any over expenditures or any costs that are determined to be unallowable by the sponsor, OGRD, or auditors. It is therefore incumbent upon the PI to carefully monitor all expenditures charged to his/her indexes and to implement whatever processes are necessary to ensure compliance with the terms and conditions of the award. To accomplish this, it is recommended that the PI require that he/she or his/her designee approve all project-related expenses in advance of the expenditure.

1. Personnel Costs: The major expenses in most projects are personnel costs. The PI has the responsibility to initiate the preparation of a Payroll Action Form (PAF) for him/herself and for other non-student personnel paid by the grant or contract. Most departmental and college support staff are familiar with the preparation of PAFs and may have the responsibility of preparing them for the personnel within their departments. PAFs should always be prepared prior to or at the beginning of a project or personnel related task.

PAFs for faculty are generated at the departmental or college level and all positions are assumed to be “in load” and part of the faculty’s regular appointment unless the grant or contract budget specifies the effort as overload or summer salary. As a general rule, faculty may not work beyond 34% overload.

The staff in the Office of Human Resources, Rights and Risk prepare PAFs for all classified and administrative exempt employees. If the classified or administrative staff 10 Rev. July 21, 2018 person being hired for the position on a grant or contract is currently a University employee, the PI must write a memorandum or send an email to Human Resources explaining the facts relating to their employment on the grant. The memo must contain start and end dates of employment on the grant, the index number(s) to which the salary is to be charged for all duties, the percentage of time to be applied, and the rate of pay. There may be multiple index numbers for an individual working on more than one job. The total percentage of time must equal 100% for a full time position when the percentages of time allocated to each job are totaled. In most cases the rate of pay must be consistent with their current rate of pay. If a classified staff person from a different department is needed to work on a grant project, written permission must be obtained from their department chair and identified as to whether the person will be performing the activities during their cyclical leave.

If the position is a new position, the PI should contact the Office of Human Resources about recruitment and hiring procedures. Grant and contract funding does not give the PI the flexibility to by-pass university policies and procedures concerning new employment. Requests for new positions are submitted through an online portal called PeopleAdmin, and Human Resources will provide the necessary access information and instructions for PIs to enter positions into PeopleAdmin. PIs should keep in mind that any costs for recruitment (i.e., advertising, travel expenses for candidates brought in for interviews, background checks, etc.) generally must be borne by the grant or contract, but those costs cannot be incurred prior to its start date. Note: for grant-funded positions that are part of the division of “Academic Affairs,” the relevant Dean’s office may assist the PI with the PeopleAdmin processes.

If an existing grant-funded position is re-defined in a grant renewal to take on new or additional duties, and if additional salary is budgeted and approved in the grant for that position, the university policies and procedures must also be followed to put the changes into effect. No grant-funded employee is guaranteed an increase in salary that is included in the grant, unless the relevant position is determined to be eligible for the increase under university policies and procedures. Contact the Office of Human Resources for guidance on how to modify duties for a grant-funded position and to determine if the modified position is eligible for a salary change. Note: although a position may be budgeted in a grant renewal for additional duties and additional salary, the effective date of those changes will not be determined until after the position is modified and re-examined by Human Resources for the salary consequence. Salary changes may not be applied retroactively to the date of the grant renewal.

Termination of employment of administrative exempt staff or classified staff due to non- renewal of a grant, or due to a decline in grant funding for the affected position, must be processed in accordance with university policy and practice, and the relevant bargaining unit contract (if applicable to the affected position). As a result, any layoff actions require advance notice to the Office of Human Resources: · For classified positions, a minimum of 45 days advance notice is required. For example, if grant funding for a classified position ends on 9/30/20xx, then you must contact Human Resources to seek assistance with the layoff process no later than 8/15/20xx. This advance notice is required because the affected classified staff person must be given 30 days advance written notice of the impending layoff action, and 11 Rev. July 21, 2018 Human Resources requires at least 15 days preparation time. Remember – classified staff are covered under a bargaining unit contract, and lay off of classified grant funded employees must comply with both the relevant terms of the contract and university policy and practice. · For administrative exempt positions, the affected employee who will be laid off is not given 30 days advance notice. Instead, the employee is given 30 days severance payment. Additionally, the employee’s accrued unused vacation leave will be cashed out to him/her at the end of their employment. A minimum of 14 days advance notice must be given to Human Resources, to allow for preparation of the severance check as well as other required preparations.

PAFs and Request to Fill/Change forms must be signed by the PI, or other persons with designated budget authority, and the Dean of the College before being routed through the OGRD for signature with sufficient lead-time for routing and processing prior to the start date of the appointment.

PIs are encouraged to contact the Office of Student Employment (SEO) at 509.359.2525 to first determine if the skills required by an open part-time or temporary position are suitable for students. Open student positions must be advertised (i.e. posted through the Office of Student Employment) for at least 48 hours. Under special circumstances, it may be possible to hire a specific individual for an open position if the position requires specialized skills and/or experience held by that individual. These cases require a written explanation and approval by the Office of Student Employment. Additional information is available at http://access.ewu.edu/Student-Employment.xml

Non-work study students must apply on-line to the PI’s department through EagleAXIS utilizing the On Campus Application. They are required to attend a Student Employment Workshop and complete their hiring paperwork with SEO prior to starting work. The PI and the student must complete and sign the On Campus Non Work Study Requisition located in the Document Library in EagleAXIS. The PI will access this document in the Document Library as students do not have access authorization (keep a copy for the departmental records).

Work study students must also apply on-line to the department through EagleAXIS utilizing the On Campus Application. At the required Student Employee Workshop, the student will receive a work study authorization memo to provide to the PI that verifies eligibility. This authorization memo needs to be returned to SEO with the On Campus Work Study Requisition (keep a copy of both for the departmental records). When new or existing students are to change time to new indexes, the PI should email the following information to the Student Employment Office: 1) the student’s name and ID number, 2) the index to be added along with the start and end dates, 3) the individual’s job title and rate of pay, and 4) the supervisor’s name and timesheet approver’s name. Generally, five days are needed to complete this process, as the Student Employment Office must request position numbers from Budget Services. To comply with federal regulations, the university has implemented an after-the-fact time and effort reporting system (see Appendix for full discussion) to verify that all personnel costs charged to federally funded indexes are appropriate based on the actual 12 Rev. July 21, 2018 time and effort spent on the project. The purpose of the time and effort report is to document the percentage of time that each employee being paid from a federal grant is working per designated indexes. The PI is responsible for certifying all time and effort charged to the designated index. The University’s Level-of-Effort Report must be completed and returned to the OGRD on a monthly basis. If the time actually spent on the project differs from the time for which the staff person was paid from the project, the PI must contact the OGRD to determine whether a revised PAF needs to be prepared or a correction to the percent of effort shown on the Personnel Activity Report needs to be made before returning it to the OGRD.

2. Purchase Requisitions, Memoranda of Agreements (MOA), and Travel Authorizations: All planned expenses have University forms that need to be completed in advance of making the expenditure. Forms need to be routed to OGRD for authorizing signature after the PI signs them. The OGRD will then forward the forms on to the appropriate department. The PI should always keep a copy of every form, invoice, and documents for reference. It should be noted that invoices or reimbursements, on average take 30 days to be paid. The PI must generate online purchase requisition forms for all supplies and equipment needed and submit invoices for payment when the items are received. If the payment is in the form of a reimbursement, the original receipt(s) must be submitted with the purchase requisition form to the OGRD. When a department procurement card is used to purchase items, the Monthly Detail Statement form must be generated and must designate the index for each charge and be routed to the OGRD for authorizing signature. An MOA must be generated to contract for services provided by a non- university employee that cost less than $10,000. Go to EWU home>Administration>Business & Administration>Contract Services to find the guidelines for generating Memorandum of Agreements under the title, “Instructions.” The contractor’s/consultant’s travel costs may be included on the MOA. The consultant/contractor must invoice for partial or full payments for work done during the time period the MOA is in effect. The PI must sign, date, and write “ok to pay” on the invoice. The invoice must include the index number and Purchase Order number to ensure payment from the proper index. Travel Authorization forms must be approved prior to travel. All University travel needs to have prior approval and is documented using a “Travel Authorization” Form (TA). Usually university departments have a designated employee who creates the TA form for all employees in their area. Each form is assigned a unique number for identification within the department. The department staff person may have a worksheet to complete to get the details of one’s trip. The traveler will need to make their hotel reservation and reserve it with a personal credit card. Ask for an email confirmation and turn in a print out with your travel worksheet. If the hotel room rate is higher than government lodging rate but it is the lowest in the vicinity of the event the traveler needs to complete a “lodging exception” form, which can be found at EWU Home>Administration>Business & Administration>Travel>Travel Forms. Artistic Travel Agency is used to book all university airline and rental car reservations. Once a TA is prepared, the traveler may receive a travel advance of funds up to the amount listed in box 6 for per diem. The desired dollar amount needs to be written in on the blank line at the top of box 8 and then the traveler signs in this box. The supervisor,

13 Rev. July 21, 2018 budget authority, grants office, etc. will sign in box 9. The travel advance check will be mailed to the traveler a week prior to the travel with instructions attached. The traveler does not need to keep receipts for food; however, for parking, gas, shuttle, taxi fares etc. it is recommended that receipts be maintained and it is required for any expense greater than $50. After travel is complete, the bottom portion of the TA form is completed and employee signs again in the “Certification” box. The department staff will let the traveler know if any of the travel advance funds need to be returned to the university. Instructions on how to go about this will be included with the check. The budget authority, grants office, travel accounting and accounts payable will all sign in the box below as the form goes through its processing. To procure food for meetings where meals are provided, a Light Meals and Refreshments Form must be completed. This form must be signed by the PI and attached to a purchase requisition or to an Event Planning Interdepartmental Purchase Order (IDPO) along with a meeting agenda and list of meeting attendees and forwarded to OGRD. The Light Meals and Refreshments Form can be found at EWU Home>Administration>Business & Administration>Travel>Meals and Light Refreshments. In all cases, federal per diem guidelines must be followed. Per diem information may be found at EWU Home>Administration>Business & Administration> Travel> Per Diem Rates (meals and lodging). The State of Washington governor or legislature may issue special regulations restricting expenditures at any time. Grants and contracts must comply with these regulations, regardless of the source of funding, or be deemed exempt. Please check with the OGRD Post-award Staff regarding these special conditions. When making purchases from university departments; such as, the MARS Lab or EWU Print Services, an Interdepartmental Purchase Order (IDPO) Form must be completed. Normally, the department making the purchase is responsible for preparing the IDPO. The index and fund numbers must be included on the form and the other department from which the purchases are made will complete the form and forward it to OGRD for authorizing signature. The PI must sign the form to indicate the items purchased have been received. 3. Expense Transfers: If costs were charged to the index in error, a determination as to the appropriate index to which the expense should have posted must be made. A journal voucher entry (JVE) must be prepared indicating to which index the expense was incorrectly posted and to which index the expense should be posted. The OGRD will assist in generating this form and obtaining the needed support documentation, if necessary. The PI must send an email message (or other written documentation) to the OGRD post-award staff member authorizing the transfer of the expense. The written authorization must include documentation supporting the expense, such as the Detailed Transaction listing (FGRODTA) generated by the Banner Finance System showing the expense as posted. If a JVE is generated within the PI’s department, the expense transfers should be submitted to the OGRD for approval within sixty (60) days of incurring the cost. Should a delay in identifying a missed charge occur past 60 days; the correction should be made immediately upon the identification of the error. Conversely, expense transfers are also necessary if an appropriate grant/contract expense is charged to another index in error. The expense must be transferred to the correct grant/contract index. Should the OGRD identify a pattern of inappropriate charges necessitating large 14 Rev. July 21, 2018 numbers of expense transfers, the PI will be contacted to discuss modifications to the PI’s procedures to ensure expenses are charged appropriately from the onset. 4. Monitoring Sub-contracts: If the project includes subawardees (contractors), the PI is responsible for working with OGRD Pre-Award staff to generate sub-contracts for signature and is responsible for reviewing all invoices submitted by the subawardee and determining that all costs are appropriate and allowable. Payment of subawardee invoices is tied to the subawardee’s performance in meeting the goals outlined in their scope of work. Once the PI has determined the charges are appropriate, the work has been done, and approves the invoice; the OGRD staff will process it for payment. The PI must review all such invoices in a timely manner so the university can meet its obligation to pay the subawardee in a timely manner. The PI must sign, date, and write “ok to pay” on the invoice. The index number and subcontract number must appear on the invoice to ensure payment from the proper index. 5. Cost Sharing/Matching: It is the PI’s responsibility to document all cost sharing associated with the project. This includes timely submission of “GRANT MATCH --- Cash Expenditure Contribution” forms provided by the OGRD to document hours worked on the project each month. If the PI is using a percentage of the salary paid by another index as match, a “COST SHARING EFFORT INQUIRY REQUEST” must be provided to OGRD with the Banner index number for all university cost sharing committed to the project. OGRD will prepare monthly Personnel Activity Reports and send them to the employee for signature. The PI also verifies the information, signs, and returns the forms to OGRD. Cost sharing must be documented as it occurs – the PI should not wait until the project is nearing the end date to start documenting cost sharing. When cost-share or matching requirements are included in the award budget, the PI is responsible for obtaining documentation from collaborative partners who provide services or supplies. If student time is used as match, copies of their time sheets may be used as documentation of time worked. When volunteer time is used for matching, each volunteer must sign in on a sheet listing time spent. The dollar amount to be attributed to a volunteer’s time is determined by using the state authorized volunteer wage. The hourly rate may be increased if sufficient documentation is provided to support that the specific volunteer holds special skills that would be reimbursed at a higher rate. Copies of all documentation must be submitted to the OGRD as cost sharing/ matching funds are subject to audit to the same degree as grant and/or contract funds expended. 6. Budget Revisions: Because the budget approved by the sponsor was an estimate based on the PI’s knowledge at the time of the application, it is not uncommon for PIs to determine, once the project is underway, that the budget needs to be modified to reflect changed circumstances. The PI should contact the OGRD as soon as he/she determines modifications of the sponsor-approved budget are needed. In many cases, sponsors have granted the University the ability to approve some budget changes between budget categories that are less than 10% of the overall budget. In other cases, a budget revision will need to be approved by the sponsor in writing. The OGRD will review and approve all requests to sponsors for budget revisions prior to submission to the sponsor. The OGRD must review and approve all transfer of costs and facilitate a budget modification signed by both parties. 15 Rev. July 21, 2018 7. Co-Mingling of Funds: The use of the funds in a grant and/or contract index is restricted to the sponsor-approved project budget and the terms and conditions of the award. Under no circumstances may funds or expenditures for a specific project be commingled with any other index even if unexpended funds remain at the end of the project.

Project Closeout

The PI is responsible for preparing and submitting the final technical report to the sponsor according to the schedule outlined in the award. A copy of all technical or programmatic reports during the life of the award, including final reports must be provided to the OGRD.

Approximately 100 days prior to the end of the grant period, the PI should review the budget and compare it with actual expenditures and determine whether or not the performance of the funded activities will be completed by the end of the grant period. If additional time is needed, the PI should contact the OGRD well in advance of the project end date to discuss requesting an extension of the project. In some cases, sponsors have delegated authority to the university to grant a one-time, no-cost extension. If the university can approve the extension, the OGRD staff will direct the PI to prepare and submit a request for the no-cost extension. If the extension request must be submitted to the sponsor, the OGRD will coordinate the request with the PI. The OGRD staff will prepare and submit the final financial report and final invention and property reports, if required. The PI must assist the OGRD in completing final fiscal reports and final invention reports by providing any information requested by the OGRD in a timely manner.

Initially, the PI’s tracking spreadsheet and the current Banner Accounting reports should be compared to determine if all expenses have posted to the index. If there are expenses that have not posted, copies of the documents submitted for payment along with a spreadsheet listing the outstanding expenses must be submitted to the OGRD post-award staff member working to submit the final invoice. All discrepancies between the PI’s records and the Banner index must be substantiated with appropriate documentation in order to reconcile the index’s expenditures.

If expenses are not on this index’s Banner reports but should have posted some time ago, it is necessary to find copies of the paperwork and determine if an incorrect index code was used and the expense posted to another index or if it is being held up for more information by another department. The OGRD post-award staff will generate the paperwork needed to move the expense with the PI’s approval. Internal expenses such as telephone, postage, and copier charges usually post one month after the charges occur. It is important to estimate these expenses and include them on the final invoice if they have not posted to the index by the final invoice due date. It is important to note that long distance telephone charges may lag by one to three months before they are posted to an index.

If PAFs or timesheets are not changed to different Indexes after the ending date of the award, additional paperwork must be completed to move the charges to another allowable index. If this occurs the OGRD post-award staff will assist in guiding the PI as to who needs to be contacted to make this transfer. Another step in the process is for the PI to review whether there are any “commitments or encumbrances” listed on the index’s Banner accounting reports. If there are open purchase orders, they will be listed on the reports and must be closed out in order to close out the index. 16 Rev. July 21, 2018 For all Purchase Orders, Memorandums of Agreement and subcontracts, email Bill Santiago in Purchasing with the PO or C number and request that it be closed. For all travel authorizations, email Travel Accounting and request that it be closed.

It is a condition of the award that all required reports be submitted to the sponsor according to the schedule provided in the award documents. Failure to submit reports in a timely and acceptable manner can result in the rejection of pending proposals without consideration and withholding of final payment. It also puts in jeopardy the faculty member’s and the university’s eligibility for future grant opportunities. It is therefore incumbent upon the PI to make sure all reports are completed and submitted to the sponsor on time. Any costs disallowed by the sponsor due to the PI’s failure to submit required reports according to the sponsor’s schedule will be the responsibility of the PI, department, or the PI’s unit head (dean or center director).

Procedural guidance, references and links to applicable policies, and detailed information about various Banner INB financial reports for PIs follow in the next sections of this handbook.

17 Rev. July 21, 2018 General Procedures for the Fiscal Management of a Grant Award or Contract

The receipt of a grant or a contract in no way constitutes authorization to circumvent any university policy or procedure. In fact, externally sponsored projects are closely regulated and audited for compliance with university, state, federal, and sponsor guidelines. Each expense charged to the index must be directly related to the project, must be allowable under the terms and conditions of the award, and must be included in the sponsor-approved budget. The State of Washington conducts annual audits of the university in accordance with OMB Circular A-133 (referenced below) and all grants and contracts are included in this audit. Any grant or contract is subject to an in-depth audit by state appointed auditors.

The Federal government’s cost principles for educational institutions must be used to guide all costs incurred for sponsored projects and research; including all activities sponsored by Federal and non-Federal agencies and organizations.

The Office of Budget Management (OMB) continually updates and describes these principles in great detail at http://whitehouse.gov/omb/circulars/

 2 CFR Part 220 (OMB Circular No. A-21)- Cost Principles for Educational Institutions.

 2 CFR Part 215 (OMB Circular No. A-110)- Uniform Administrative Requirements for Grant Agreements With Institutions of Higher Education, Hospitals, and Other Non- Profit Organizations.

 OMB Circular No. A-133- Audits of States, Local Governments, and Non-Profit Organizations.

The State of Washington Office of Financial Management’s (OFM) accounting policies and procedures will be followed in the financial administration of all grants and contracts. If the sponsor’s accounting procedures conflict with those of OFM, the OFM policies and procedures will be applied.

Links to the OFM accounting policies and procedures are available on the EWU Website at EWU Home>Administration>Business & Administration>Auxiliary & Business Services>Purchasing. Then view External Websites listing for Washington State Office of Financial Management.

Allocable Costs

All costs must be reasonable, allowable, and allocable to a specific sponsored agreement. According to 2 CFR Part 220 (OMB Circular A-21), a cost is allocable to a sponsored agreement if it is incurred solely to advance the work under the sponsored agreement. Further, it should benefit both the sponsored agreement and the other work of the institution in proportions that can be approximated through the use of reasonable methods.

Allowable and Unallowable Costs

18 Rev. July 21, 2018 OMB Circular A-21 states the federal government definitions and examples of allowable and unallowable costs.

 Examples of Allowable Costs: Direct costs related to the specific scope and objective of the project; such as, personnel, communication costs, operating supplies and materials, travel, equipment, and similar costs.

 Examples of Unallowable Costs: Alcoholic beverages, bad debts, traffic tickets, alumni activities, commencement costs, decorations, donations and contributions, entertainment costs, and lobbying costs.

Reasonable Costs

A cost may be considered reasonable if the nature of the goods or services acquired or applied, and the amount involved, reflect the actions a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. In other words, apply the “front page of the newspaper” test: would a prudent person consider this a reasonable expense or use of public funds?

Expenditures Procedures

The PI should review the budget for allowable costs and identify any items that may require modifications. All expenditure documents such as Payroll Action Forms (PAFs), Travel Authorizations (TAs), Hiring Recommendations, and others must be approved and signed by the PI and forwarded to the OGRD for budget verification. If these documents are prepared electronically, they will be processed electronically using the appropriate approval queues.

Travel Procedures

Regardless of the grant or contract guidelines, all travel must comply with the State of Washington approved rates unless federally allowed rates or funding agency rates are less than the state rate. In the case of lower federal rates, the federal rates will apply to federal grants or contracts. For a complete discussion of EWU's travel regulations refer to the EWU Office of Travel webpage: EWU Home>Administration>Business & Administration>Travel or you may contact them by phone at 509.359.2249.

PIs are responsible for the information contained in the “Employee Travel Guide” link under “How to Travel” on the EWU Office of Travel webpage. You will find information on the following:  State Travel Policy  making reservations  travel authorization procedures  travel advances  reimbursement of transportation expenses  subsistence and lodging rules and rates 19 Rev. July 21, 2018  meals and light refreshments guidelines  instructions on how to complete travel authorization and expense voucher forms

Any and all travel allowed by a grant or contract must be approved by the OGRD prior to being sent to Travel Accounting. The individual travelling must complete the appropriate travel authorization form, secure the signature of the PI and department approval, and forward the form to the OGRD. If the PI is travelling, his/her department chair must also sign the form to approve the travel prior to forwarding to the OGRD.

International Travel Supported by Federal Funding

The Fly America Act of 1974 requires that U.S. flag air carriers will be used to transport personnel and property when costs are charged directly to a grant or contract. This includes air transportation to, from, between, or within a country other than the U.S. when U.S. flag air carriers are "available" even though:  comparable or a different kind of service can be provided at less cost by a foreign- flag air carrier, and  foreign-flag air carrier service is preferred by, or is more convenient for, both the government and the traveler.

If you have a grant or contract that requires international travel, please contact the OGRD for additional information on the requirements of the Fly America Act.

Meals and Light Refreshments

The Office of Financial Management State Administrative and Accounting Manual Sections 10.40.60-70 and 70.10.10-40 regulate the policy for meals and light refreshments. Generally, food and refreshments are not an allowed expense to be charged to grants and contracts unless specifically permitted by the terms and conditions of the grant award. The PI and the appropriate dean or project director, or vice president must approve the expenditure for meals and light refreshments for meetings or formal training sessions prior to the event by submitting a Meals and Light Refreshments form. The PI is responsible for completing a Purchase Requisition and the Meals and Light Refreshment form prior to the event. A formal agenda, attendance roster or registration list, and an additional list of non-registered persons attending

20 Rev. July 21, 2018 the event must be attached and submitted to the OGRD for processing.

The EWU Meals and Light Refreshments Policy can be accessed on the Travel Accounting website: EWU Home>Administration>Business & Administration>Travel.

Consultants

Consultants are unaffiliated, non-EWU employees who are hired for short duration, usually for problem solving, evaluation, or to provide specialized technical knowledge or expertise. Compensation must be in hourly or daily rates. Travel expenses are budgeted separately from compensation. University employees or students may not be paid as consultants on sponsored projects.

Personal services may be provided by subawardees (contractors or consultants). Generally, the characteristics of personal services are:

 Services are professional or technical in nature and meet more specialized needs. Work is predominantly intellectual and varied.

 Work is independent from the day-to-day control of the agency; consultant maintains control of work methods.

 Work requires regular exercise of judgment, discretion, and decision-making; involves providing advice, opinions, or recommendations; may have policy- implications for agency; often addresses management-level issues.

 May require advanced or specialized knowledge, or expertise gained over an extensive period of time in a specialized field of experience.

 Work may be original and creative in character in a recognized field of endeavor, the result of which may depend primarily on the individual’s invention, imagination, or talent.

 Consultant generally assumes risk of loss if the requirements are not satisfied.

Examples of Personal Services: accounting services, actuarial services, analysis and assessment of processes, appraisal services, business analysis, guest speakers, grant writing, operational assessments, statistical analysis, public relations, medical and psychological services, investigations.

Generally, the characteristics of purchased services are:

 Services are more repetitive, routine, or mechanical in nature; following established or standardized procedures as contrasted with customary and regular exercise of discretion or independent judgment.

 Services contribute to the day-to-day business operations of the agency, rather than the management or policy side of the agency, and may meet more general needs of the agency. 21 Rev. July 21, 2018  Services generally involving completion of an assigned task, rather than an entire project.

 Decision-making and analysis, if required, is more routine or perfunctory in nature.

 Services that are generally performed based upon agency discretion.

Examples of purchased services: advertising in newspapers, bookkeeping services, credit card service, document storage, drug testing and screening (standard tests), engraving service, environmental monitoring, HVAC system maintenance service, landscaping, linen rental service, language translation service, vehicle inspection, temporary employment service, telephone interview service.

Bid Requirements

Effective July 26, 2009, state agencies and higher education institutions must use Washington Electronic Business Solutions (WEBS) as Washington’s common vendor registration and bid notification system. Both formal and informal competitive solicitations need to be posted on WEBS by EWU’s Purchasing Office. You may contact Purchasing for assistance on the quoting process.

Bid Thresholds

Purchases up to $10,000 may be made without competitive bids based on buyer experience and knowledge of the market. The bidding process applies when a single order exceeds $10,000 or if annual dollars spent with a particular vendor for repetitive small purchases of similar commodities exceed $10,000. Goods and services that exceed or are projected to exceed $10,000 must go through the quoting process to show evidence of competition. A hard copy purchase requisition must be submitted for goods and services that need to go through the quoting process. The quoting process does not apply to goods and services that are purchased against a state contract.

PIs should consult with the Purchasing Department for questions concerning the quoting process. PIs can also visit the Purchasing Department (http://access.ewu.edu/purchasing.xml) to obtain other information.

Memoranda of Agreement (MOA)

The PI is responsible for generating Memoranda of Agreements for personal services provided on a grant or contract by a consultant for an amount not to exceed $10,000. MOAs may be used for personal services, which exceed the $10,000 threshold provided one or more of the following conditions are met:

1. The individual providing the services was identified in the grant or contract proposal and is critical to the successful conduct of the program. 22 Rev. July 21, 2018 2. The services are critical to the instructional mission of the university.

3. The services are advertised and a bidding process is used to obtain the contractor.

4. The services to be provided are limited in nature and the scope of work does not pose a high risk or potential liability to the university.

The Memoranda of Agreement is a form-fill .pdf and can be found on EWU’s web site under Administration>Business & Administration>Contract Services/Everything MOA>Memorandum of Agreement (MOA).

The “Contractor Information” section of the MOA (bottom left of form) must be signed by the contractor in order for payments to be made. The PI must provide an original to the OGRD for processing at least two weeks prior to the performance of services. Signature authorization on the MOA by the OGRD indicates that sufficient funds are available in the restricted index and the services and associated expenses are allowed and allocable to the grant fund. The Purchasing Department will assign a Banner number to the MOA and one signed copy will be returned to the PI at the department mail stop indicated by the PI on the MOA.

The PI must instruct the contractor to submit an invoice directly to the PI after services have been performed. The contractor may submit their own invoice or use the Contractor Invoice template at http://access.ewu.edu/Accounts-Payable/AP-Forms.xml. It is the contractor’s responsibility to prepare and submit the invoice. Refer to additional information if a check is to be prepared and ready on the date of the performance of the services.

When services are complete, the PI must sign the Contractor’s invoice indicating the authorization to pay the invoice, attach a photocopy of the fully signed MOA referencing the Banner number, and forward to the Office of Grant and Research Development in Showalter 210 for processing.

Some important things to consider when using an MOA:

1. MOAs on which the contractor is paid in a single payment show as an expense on the university's accounting system at the completion of services. Therefore, the funds are not encumbered by the system when the contract is initiated. It is therefore incumbent upon the PI to commit the funds in their own records so funds are not inadvertently spent for other purposes. This is especially crucial if the services are provided over a relatively long period of time.

2. An MOA to be paid in progress intervals must be expensed in one fiscal year. If the services are provided across fiscal years, a second MOA must be generated for the second year of services. Eastern Washington University’s fiscal year ends on June 30 for each year.

3. In order for the contractor to be reimbursed for expenses other than direct compensation (such as travel, mileage, and meal per diem), the PI must complete an A- 19 invoice voucher to forward to the OGRD. The A-19 invoice voucher must indicate the MOA contract number, a description of the expenses, and the grant or contract index number. Original receipts must be supplied for expenses (i.e., airline tickets, hotel 23 Rev. July 21, 2018 expenses), which normally require receipts.

The A-19 must be signed by the individual contractor when there will be a reimbursement for expenses such as travel mileage and meal per diem that do not require receipts.

Reimbursement will only be made at the state or funding agency allowed rates for mileage, hotels, etc., regardless of the actual cost.

4. Compensation for the performance of services equal to or greater than $600, along with any expenses included in the total contract amount not specifically identified, will be reported to the Internal Revenue Service on a 1099 Form as taxable income.

5. Significant expenses, such as airline tickets and lodging may be paid directly on behalf of the contractor using a Purchase Order. The MOA contract number needs to be included on the Purchase Requisition and the expenses need to be listed and identified as being paid by a Purchase Order on the MOA.

6. If additional expenses are not included in the total contract amount and are not paid on a Purchase Order, then the PI needs to check that they will be paid in addition to the contract amount on the MOA and identify those expenses and their estimated costs. Expenses incurred that are not identified on the MOA cannot be reimbursed without a receipt regardless of whether or not a receipt is normally required.

7. Students may not be paid on MOAs. When working under an MOA, the contractor is not considered an employee of the university and is, therefore, not covered under Worker’s Compensation.

Stipend Payments

When payments are made to non-university employees who have participated in a grant or contract program for purposes other than to provide services (i.e.: classroom teacher) an A-19 invoice voucher must be prepared, signed by the PI, and forwarded to the OGRD for processing.

Some important tips to consider when completing the A-19 form: a) The proper name of the grant or contract program should be indicated in the agency box. b) If the checks are to be picked up rather than mailed to the individual receiving payment, this should also be noted along with the name and campus extension number of the individual who will be picking up and distributing the checks to the individuals listed on the A-19 invoice voucher. The date the checks are to be picked up should be included on the invoice voucher, if applicable. c) A brief explanation of the reason for the payment should be provided.

24 Rev. July 21, 2018 d) The PI or designee should sign and date the agency approval box. e) The grant to which the expenditures are to be charged should appear in the fund and program index columns near the bottom half of the page. The total dollar amount of all checks to be issued should be entered in the amount column. f) When multiple people are receiving stipends, attach to the A-19 invoice voucher a table (OGRD has a formatted table that can be sent electronically upon request) listing the following information for each individual who is to receive payment: . Name . Permanent mailing address . Social security number . Payment amount . Column for the Accounts Payable Department to insert the voucher number used for payment

Depending on the circumstances for which an individual receives a stipend (i.e., participation in a class, fellowship award, and student living allowance), the stipend amount may be reported to the Internal Revenue Service (IRS) on a 1099 Form as taxable income. If the stipend amount is determined to be subject to Federal income tax, EWU will issue the recipient a 1099 Form at the end of the year. PIs are advised to contact the Accounts Payable Department at the time an A-19 invoice voucher is submitted to determine if the stipends to be paid are reportable to the IRS.

Payroll Action Form (PAF)

The PI has the responsibility to initiate the preparation of a Payroll Action Form (PAF) for him/herself and for other non-student personnel paid by the grant or contract. Most departmental and college support staff are familiar with the preparation of PAFs and may have the responsibility of preparing them for the personnel within their units.

PAFs for faculty are generated at the departmental or college level, while the staff in the Office of Human Resources, Rights and Risk prepare the PAFs for all classified and administrative employees. Blank PAF forms can be requested from the Office of Human Resources, Rights and Risk. If the classified or administrative person being hired for the position on a grant or contract is currently a University employee, the PI must write a memorandum or send an email to Human Resources explaining the facts relating to their employment on the grant. The memo must contain the inclusive dates of employment, the index number(s) to which the salary is to be charged against for all duties, the percentage of time to be applied, and the rate of pay. There may be multiple index numbers for an individual working on more than one job. The total percentage of time must equal 100% for a full time position when the percentages of time allocated to each job are totaled. In most cases, the rate of pay must be consistent with their current rate of pay.

If the position is a new position, the PI should contact the Office of Human Resources, Rights and Risk about recruitment and hiring procedures. Grant and contract funding does not give the

25 Rev. July 21, 2018 PI the flexibility to by-pass university policies and procedures concerning new employment. PIs should keep in mind that any costs for recruitment (i.e., advertising, travel expenses for candidates brought in for interviews, background checks, etc.) generally must be borne by the grant or contract.

The PI should contact the Office of Human Resources, Rights and Risk to start the hiring process by developing the job description and position announcement. This electronic process is online.

Student Employees

Part-time or temporary positions (exempt from Civil Service) on grants and contracts must first be posted and made available to students. Students qualifying for employment through the university must be at least half-time (i.e., enrolled for 6 credits or more for Undergraduate and 5 credits or more for Graduate students) and cannot work more than 19 hours per week (exclusive of the hours worked on established academic breaks).

PIs are encouraged to contact the Office of Student Employment to first determine if the skills required by an open part-time or temporary position are suitable for students. Open student positions must be advertised (i.e., posted through the Office of Student Employment) for at least 48 hours. Under special circumstances, it may be possible to hire a specific individual for an open position if the position requires specialized skills and/or experience held by that individual. These cases require a written explanation and approval by the Office of Student Employment.

Students cannot begin working until a Part-time Employment Authorization Form, IRS Form W-4, and Immigration and Naturalization Service From I-9 have been completed and processed. A start date and end date should be specified for each index a student is authorized to charge to. This ensures that the index will not be available to charge to once the grant agreement has ended. Once a student is hired, PIs are responsible for ensuring that the students’ time sheets are accurate and timely. Concealing or delaying the report of hours worked on payroll documents is a violation of state law and may result in disciplinary action. The PI, by signing or electronically approving the time sheet, certifies that the number of hours reported as worked during a pay period is accurate and complete.

PIs should not allow students to work during regular class time. If an individual works during regularly scheduled class time when that class has been canceled, it should be noted on the time sheet. Similar documentation should be provided when a student works during finals week (i.e., no class or final scheduled at a different time.) For electronically filed timesheets, a note should be maintained in the PI’s files documenting the situation in case of an audit being conducted at a later date.

Hours worked must be tracked for pay increments. Each PI is responsible for tracking these hours. Students should receive a two-step increment when they have worked 450 hours at the same job in the same department, effective the following pay period.

26 Rev. July 21, 2018 Graduate Service Appointments (GSA)

Graduate Service Appointments are rare on grants and contracts. The GSA must be in the approved budget and the purpose and the compensation amount per quarter or per academic year must be described in the budget justification. The PI should coordinate all GSAs with the Graduate Program Office. In the event a grant award funds a GSA, the PI must issue a memorandum to the Dean’s Assistant to generate a PAF for the graduate student’s quarterly payroll. The Graduate Program Office must approve all PAFs for GSAs prior to submission to the OGRD.

Employees with Official Work Stations in Other States

Individuals employed by grants and contracts that are permanently stationed in states other than the state of Washington are subject to the payroll tax rates and income tax laws that are in effect in the state in which they work. PIs must notify Human Resources of new employees who may be subject to other states’ payroll laws.

Insurance Eligibility for All Temporary Employees

Temporary, hourly employees whose average employment is at least half time, or 522 hours, over a period of six consecutive months are eligible for employer provided benefits. After initial insurance eligibility is established, a temporary employee must be in pay status at least 8 hours a month in order to maintain benefits. If a separation or break in service of one month occurs, eligibility must be re-established.

Level of Effort Reporting (See APPENDIX for a complete discussion.)

Ownership and Control of Equipment

Equipment acquired through sponsored projects becomes the property of the university, unless restricted by the sponsor, and is inventoried and tagged by EWU’s Inventory Control Office. Government awards that finance equipment through a grant normally vest title of the equipment to the grantee. If purchased through a contract, title may remain in the possession of the grantor. Under no circumstances does equipment purchased through a sponsored project become the property of the PI or any other personnel. However, the PI must control the use and condition of the equipment.

As the end of the grant period nears, the PI should consult the OGRD to determine appropriate disposition of project equipment. Title will generally transfer to the University, but not always. Depending on the funding agency and program, the sponsor may request return of the property 27 Rev. July 21, 2018 or require equipment inventory documentation be submitted. Often, obsolete equipment may be sold and the PI’s department can retain the proceeds. Occasionally, funding agencies require the university to submit an annual report itemizing equipment on hand acquired by grant funds even after the grant has ended.

Indirect Cost Recovery (ICR)

Indirect Cost Recovery (ICR), sometimes referred to as Facilities and Administrative (F&A) costs or overhead, are real costs of conducting research or managing projects that are not easily identifiable. Indirect costs are expenses incurred by the university such as building and equipment use and depreciation, operation and maintenance costs, central and departmental administrative costs, library expenses, and student administration and services. EWU’s recovery of funds for indirect costs is based on its negotiated rate with the federal government and is applied to the salaries and wages of a grant or contract budget. When the university does not fully recover indirect costs related to a project from a sponsor, it must cover these costs from other university funds.

The university negotiates its federally approved ICR agreement through its cognizant agency, the Department of Health and Human Services (DHHS). The current ICR rate is for 62.8% of salaries and wages (exclusive of fringe benefits) and is applied to salary and wage costs budgeted on or after July 1, 2008. Unless otherwise specified by the granting or contracting entity, this rate is to be used on all applications and/or contracts for external funding including those from private, local, state, and federal sources.

EWU redistributes indirect costs according to university policy. The ICR distribution based on a 100% recovery is: Grants Administration 38.25% Academic Department 17.00% University Infrastructure 15.00% Participating Faculty 12.75% College 4.25% Provost 7.75% Library 5 .00% Total 100.00%

Although a significant percentage of the ICR are used in direct support of university services and operations, a portion is also distributed to the PI. ICR are distributed to PIs, in part to support special initiatives which may relate to a current grant or contract program, to provide seed money for securing additional external funding, and as an incentive to continue to participate in proposal development and grants and contracts. Although PIs have access to the ICR returned to them, ICR are not personal funds. They are university funds for discretionary purposes. Expenditures must be for university- related purposes, and any equipment, supplies, or goods purchased using ICR become the property of the university. An individual indirect cost recovery index and fund will be established for participating faculty when a grant with ICR is awarded.

28 Rev. July 21, 2018 EWU has a few programs that fall within the category of self-support. Since self- support programs rely on the combined efforts of their staff to keep those programs in operation and since these programs are in themselves their own self-funded departments, the amount of indirect costs recovered by them will be the Faculty and Department shares of 29.75%. Due to the fact that the administrative structure of such programs is usually under the auspices of a college, the college will retain 4.25%. The deans will reserve the right to redirect their recovery in support of the program. The remaining 66% will be distributed according to the original plan.

Project Over Expenditures and Unallowable Costs

The PI and the PI’s unit are responsible for any over expenditures or any costs that are determined to be unallowable by the OGRD or auditors. It is therefore incumbent upon the PI to carefully monitor all expenditures charged to his/her restricted indexes and to implement whatever procedures are necessary to ensure compliance with the terms and conditions of the award. The OGRD will consult with the PI and provide examples of spreadsheets that may be used to monitor expenditures.

Closing the Grant Index

The PI is responsible for preparing and submitting the final technical report to the sponsor according to the schedule outlined in the award. A copy of all technical or programmatic reports during the life of the award, including final reports must be provided to the OGRD.

Items generally required at the close of each project index are: 1. submission of the final technical report by the PI through the university; 2. submission of the final invention statement by the PI through the university; 3. submission of the final financial/fiscal report by the university; 4. accounting for, and determining disposition of, any equipment purchased under the project; 5. proper disposition of any over expenditures; and 6. any other requirements of the sponsor.

The PI must ensure that a record of all project expenses, both grant funded expenditures and matching contributions, has been submitted to the OGRD. Any cost sharing or matching committed to the project must be documented as if it were a cash transaction. While the financial reports provided by the university adequately identify the transactions on the actual grant or contract it is the PI’s responsibility to compile the records for in-kind contributions and expenses paid by other sources of funding which are used to satisfy match or cost-share requirements of the agreement.

Included in this record should be an assurance that all personnel commitments (grant funded, university funded, and in kind) to the project have been fulfilled. Timesheets and Personnel Activity Reports that certify the time spent by each individual on the project on a monthly basis should be kept on file as part of this record. Both the individual donating the time and the PI must sign these records. The PI’s signature documents their review and approval of the time contributed. 29 Rev. July 21, 2018 Cost sharing must be documented as it occurs – the PI should not wait until the project is ending to start documenting cost sharing. The records should be reviewed and, if any omissions are noted, proper corrective action should be taken prior to the last month of the project.

Frequently, projects cannot be closed after the termination date because open commitments, or encumbrances still remain as a result of last-minute purchases. The PI must further review open commitments regularly during the life of the project to determine whether they are still necessary to complete the project or should be canceled. The Banner accounting system can provide a list of open commitments (FGIOENC) and will list the totals by account code on the (FRRGITD) Grant Inception to Date Report.

Some charges, such as copier costs, telephone charges, report printing charges, and interdepartmental billings normally show on the accounting system at least one month later than they are charged. These costs must be considered in planning the project close out.

It is a condition of the award that all required reports be submitted to the sponsor according to the schedule provided in the award documents. Failure to submit reports in a timely and acceptable manner can result in the rejection of pending proposals without consideration and withholding of final payment. It also puts in jeopardy the faculty member’s and the university’s eligibility for future grant opportunities. It is therefore incumbent upon the PI to make sure all reports are completed and submitted to the sponsor on time. Any costs disallowed by the sponsor due to the PI’s failure to submit required reports according to the sponsor’s schedule will be the responsibility of the PI first, then the department and last of all the College in which the PI resides.

Program Income

Occasionally a grant will generate program income; however, the university cannot retain program income. Income generated by a grant must be used to finance the non-federal share of the project or reduce the federal agency’s share of expenses. For non-federal awards, the specific award document will provide guidance on the treatment of program income. Any and all program income that has been received on behalf of the grant must be accounted for during the grant close out. For guidance relating to federal agency agreements refer to Title 2 of the Code of Federal Regulations, Part 215.24 (Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals and Other Nonprofit Organizations - Post-Award Requirements, Program Income).

30 Rev. July 21, 2018 General Procedures for Project Monitoring and Reporting

Signature Authority

PIs are cautioned not to sign any Notice of Awards or agreements for sponsored support, patents or copyright licenses, biomaterials, equipment loans, work for hire, confidential disclosure agreements, or materials transfer. These agreements bind the university to certain obligations and, as such, can be signed only by the Associate Vice President of Business and Finance. However, PIs, or their designees are required to sign all documents to authorize expenditures against the grant or contract index.

Record Keeping

The PI is responsible for complying with all the financial terms and conditions of the award and should, therefore maintain accurate records for the entire duration of the grant. While the PI may delegate some responsibility for the day-to-day management of finances or other tasks to departmental business staff, the PI remains accountable for compliance with University and sponsor requirements. The PI may contact the OGRD for assistance in establishing record keeping systems for monitoring grant and contract expenditures.

Subcontractors (Sub-awards)

If the project includes subawardees (contractors), the PI is responsible for reviewing all invoices submitted by the subawardee and determining that all costs are appropriate and allowable. Payment of subawardee invoices is tied to the subawardee’s performance in meeting the goals outlined in their scope of work. Once the PI has determined the charges are appropriate, the work has been performed, and approves the invoice; the OGRD staff will sign the document and forward it to the Accounts Payable Department for payment. The PI must review all such invoices in a timely manner so that the university can meet its obligation to pay the subawardee in a timely manner.

Financial Reports

The OGRD maintains detailed fiscal records of each sponsored program index using the university’s financial management accounting program, Banner Finance. The PI should access the EWU Banner INB [PROD] web site and generate the financial reports, which provide the details of the index and fund status. The PI should carefully review the financial reports and any discrepancies between the University’s records and the PI’s records should be brought to the attention of the OGRD for immediate resolution.

The PI is responsible for all costs charged to his/her sponsored program indexes. While 31 Rev. July 21, 2018 the PI may delegate some responsibility for the day-to-day management of finances or other tasks to departmental business staff, the PI remains accountable for compliance with University and sponsor requirements. The delegation of this authority must be submitted to the Purchasing Office, in writing- generally on the signature card for each grant. Once the PI completes the signature card it must be forwarded to the Purchasing Department.

The PI must attend Banner INB training in order to monitor the account activity and generate financial reports. Training sessions (Banner Finance 201 - Introduction to Banner Finance and Banner Finance 204 - Reports and Queries) may be scheduled by accessing https://web.ewu.edu/trainsched/.

The Banner reports, FRRGITD - Grant Inception to Date and FGRODTA - Detailed Transaction Activity should be produced each month after month end closing. Generally, month end closing occurs approximately the 10th day following the end of the prior month. Additionally, all existing encumbrances, by department can be monitored by using the FGIOENC – Organizational Encumbrance List form.

Step-by-step instructions for producing the FRRGITD, Grant Inception to Date Report and the FGRODTA - Detailed Transaction Activity Report as well as monitoring encumbrances by accessing the FGIOENC – Organizational Encumbrance List form are as follows:

Instructions for Producing FRRGITD, Grant Inception to Date Report

The FRRGITD form is used to produce a printed report or electronic file of the grant budget status. This report provides inception to date grant information across fiscal years (if applicable). The following provides instructions on producing a printed report and electronic copy of the report.

Note: It is recommended that the browser pop-up option be disabled before attempting to generate a printed or electronic report.

1. From the Banner Main Menu, enter FRRGITD in the Go To field and press enter.

32 Rev. July 21, 2018 2. The Process Submission Controls form displays. Click on Next Block to access the Printer Control section of the form.

3. Enter the following in the Printer Control section of the form to generate a printed report:

33 Rev. July 21, 2018  Printer: Select the applicable department printer from the drop down list.

 Lines: Enter 44 in order for data on the report to print properly.

Note: To generate and save an electronic version rather than a printed copy of the report, enter the following:

 Printer: Enter DATABASE.

 Lines: Enter 55.

4. Click on Next Block to access the Parameter Values section of the form.

5. Enter the following in the Values fields in the Parameter Values section of the form. Note: Use the down arrow key on the keyboard to move from field to field.

 Chart of Accounts: Enter capital E (for Eastern Washington University’s chart of accounts). This field is case sensitive.

 As of Date: The grant inception date is required to obtain prior fiscal year information. Enter the applicable date using the following format; MM/DD/YY (for 34 Rev. July 21, 2018 example 07/01/07).

 Enter Grant Option: Enter R for a range of grants or S for a specific grant.

 Grant From: If R is entered in the Enter Grant Option field, enter the starting grant number.

 Grant To: If R is entered in the Enter Grant Option field, enter the ending grant number.

 Specific Grants: If S is entered in the Enter Grant Option field, enter the desired grant number.

Note: PIs generally should use the “Specific Grants” option even if they have more than one grant because the grant numbers are assigned sequentially and it is rare that a PI will have 2 grants next to one another.

6. Click on Next Block to access the Submission section of the form.

7. If desired, the parameters selected can be saved for future retrieval. Select the Save Parameter Set as check-box; enter a unique name (such as your department name) in the Name field, and a description of the report in the Description field (for example GrantReport).

35 Rev. July 21, 2018 8. Click on the Save icon in the tool bar.

 If a printed report was selected the report will print at the designated printer. No further steps are necessary.

9. If a database report was selected, click on Options in the menu bar. Select the Review Output from the drop down list.

10. The Saved Output Review form displays. Double click in the File Name field.

36 Rev. July 21, 2018 11. Double click the applicable file name in the list displayed (the number in the Number field corresponds with the file name displayed).

12. The view output displays.

13. The electronic file displayed may be saved. The following steps pertain to saving an electronic file.

14. Click on Options in the menu bar and select Show Document (Save and Print File).

15. A confirmation dialog box displays. Click on Yes.

A browser window displays. Name and save the electronic copy to the desired file location. Because the data is continually changing, printing a hard copy for reference is recommended.

Instructions for Producing FGRODTA, Detailed Transaction Activity Report

This Detailed Transaction Activity report lists all transactions posted to your index. It can be produced for all transactions inception to date or for a specific time period during the life of the program.

1. From the Banner Main Menu, enter FGRODTA in the Go To field and press enter.

37 Rev. July 21, 2018 2. The Process Submission Controls form displays. Click on Next Block to access the Printer Control section of the form.

3. Enter the following in the Printer Control section of the form:

 Printer: Select the applicable department printer from the drop down list.

38 Rev. July 21, 2018  Lines: Enter 44 in order for data on the report to print properly (a different number may be needed depending on the printer used.)

Note: To generate and save an electronic version rather than a printed copy of the report, enter the following:

 Printer: Enter DATABASE.

 Lines: Enter 55.

4. Click on Next Block to access the Parameter Values section of the form.

5. Enter the following in the Values fields in the Parameter Values section of the form. Note: Use the down arrow key on the keyboard to move from field to field.

 Fiscal Year: Enter the two-digit current fiscal year (for example enter 08 for the fiscal year beginning July 2007)

 Chart of Accounts: Enter capital letter E (for Eastern Washington University’s chart of accounts). This field is case sensitive.

 From Organization Code: Enter the department Organization code.

 From Fund Code: Enter the applicable six-digit Fund code or leave blank for all funds.

39 Rev. July 21, 2018  From Account Code: This field is optional. To generate a report with only specific Account activity, enter the desired Account code (for example Account 71400 for supplies), otherwise leave blank.

 From Date: Enter the desired date, or the first day of the month for the desired accounting period using the following format; MM/DD/YY (for example 07/01/07).

 To Date: Enter the desired date, or the last day of the month for the desired accounting period using the following format; MM/DD/YY (for example 07/31/07).

 Include Accrual for Last Prd: Enter Y.

 Print Organization Totals: Enter Y.

 Commitment Type: Enter U.

40 Rev. July 21, 2018 6. Click on Next Block to access the Submission section of the form.

7. If desired, the parameters selected can be saved for future retrieval. Select the Save Parameter Set as check box, enter a unique name (such as July Detail) in the Name field, and a description of the report in the Description field (such as your department name).

8. Click on the Save icon in the tool bar.

 If a printed report was selected the report will print at the designated printer. No further steps are necessary.

41 Rev. July 21, 2018 9. If a database report was selected, click on Options in the menu bar. Select the Review Output from the drop down list.

10. The Saved Output Review form displays. Double click in the File Name field.

11. Double click the applicable file name in the list displayed (the number in the Number field corresponds with the file name displayed). 42 Rev. July 21, 2018 12. The view output displays.

13. The electronic file displayed may be saved. The following steps pertain to saving an electronic file.

14. Click on Options in the menu bar and select Show Document (Save and Print File).

43 Rev. July 21, 2018 15. A confirmation dialog box displays. Click Yes.

16. A new browser window displays with the output data.

44 Rev. July 21, 2018 17. To save the data to the desktop or computer drive, click on the File toolbar option in the browser window.

 Select Save as from the drop-down list.

45 Rev. July 21, 2018 18. A Save as dialog box displays. Enter the following then click Save.

 From the Save In field, select the desired save location (for example; My Documents)

 In the File name field enter the desired file name (for example “August Detail”).

 The Save as type defaults to a web page file type. It is not necessary to change the file type.

46 Rev. July 21, 2018 Instructions for Viewing Encumbrances

To view all existing encumbrances, by department, use the FGIOENC – Organizational Encumbrance List form.

1. From the Banner Main Menu, enter FGIOENC in the Go To field and press enter.

2. The Organizational Encumbrance List form displays. Enter the following data in the key block and use the tab to move from one field to the next field:

 COA: Enter E. This field is case sensitive.

 Fiscal Year: Enter the applicable fiscal year (for example; 08 for fiscal year beginning July 1, 2007).

 Index: Enter the applicable six-digit Index Code.

47 Rev. July 21, 2018 3. Click on Next Block to view data.

48 Rev. July 21, 2018 Animal Care and Use Protocol Review Compliance

The Institutional Animal Care and Use Committee (IACUC) ensures that animals used in research or teaching are treated humanely by considering:

1. Replacement of experimental animals by alternatives. 2. Refinement of housing, handling and experimental procedures to reduce discomfort, pain, fear, stress, and suffering. 3. Reduction of numbers of animals used.

The Protocol Review Form (PRF) is required for research or teaching projects involving warm- blooded animals. A Change of Protocol Form must be submitted and approved if an amendment to an existing, approved protocol is necessary. The Animal Care and Use Policy may be found at http://cfweb.ewu.edu/policy/PolicyFiles/EWU_302_03.pdf

Protection of Human Subjects Compliance

EWU’s Institutional Review Board (IRB) must review and approve all research projects that use people as subjects. It is critical that PIs read and adhere to the http://access.ewu.edu/Documents/Grants/human%20research%20policy.pdf. All key personnel awarded federally sponsored grants and contracts must complete training on the protection of human subject participants if their project includes the use of human subjects.

Investigator Significant Financial Interest Disclosure

PIs must complete and return the Conflict Disclosure Form, which certifies they do not have a financial conflict of interest with an element of a funded project or which discloses actual or potential conflict and includes a plan to manage any conflict of interest. Typically, PIs sign the Conflict Disclosure Form at the time of the submission of the proposal; however, it may be necessary to sign an additional form should contract terms and conditions warrant.

This form can be found at EWU Home>Administration>Research and Scholarship>Office of Grant and Research Development>Frequently Requested Forms.

Records Retention

The Revised Code of Washington (RCW 40.14) requires the University to maintain all financial and programmatic records for a period of at least six (6) years from the date of the issuance of the audit report, which includes the specific grant or program. Should the PI intend to leave the employment of EWU, he/she must contact the OGRD to determine the appropriate storage and disposition of any records related to all externally funded projects or programs.

49 Rev. July 21, 2018 Level of Effort Reporting

Introduction Federal agencies provide funding to Eastern Washington University for a variety of research, scholarship and service activities. Appropriately certified effort reports provide auditable documentation to demonstrate that the funding agency received the level of effort described and expected by the proposal process, the award process, and all subsequent communications with the funder during the period of funding.

Policy Faculty, staff, and students who provide compensated and/or uncompensated work for a federal agreement, principal investigators/project directors, and their supervisors must adhere to the procedures set forth in EWU Policy 302-06: Effort Reporting and related regulations and as defined by generally accepted accounting principles. Federal grants, contracts, cooperative agreements and subrecipient agreements awarded to the university are referred to as "federal agreements" in this document. This policy also applies to principal investigators/project directors (i.e., the persons responsible for carrying out the scope of work identified in a federal agreement awarded to the university) and the supervisors of those persons performing work on a federal agreement.

Responsibilities EWU, through the Office of Grant and Research Development (OGRD) is to: (1) certify to the funding agency, for federal agreements, that the effort expended on the agency's projects justifies the salary charged to the projects; (2) assure the funding agency that the commitment indicated (including mandatory and voluntary committed cost sharing) in the proposal and subsequent award is met in accordance with the funder's terms and conditions; and, (3) require monthly effort reporting from each person whose salary is charged to or provided as cost sharing on one or more federal agreements.

Sanctions Costs may be disallowed, funding may be reduced or terminated and other penalties imposed on the university if auditors find effort reporting to be inaccurate, incomplete, or untimely. In addition, criminal charges may be brought against any individual reporting falsified effort. As a result, any person who violates Effort Reporting Policy 302-06 is subject to disciplinary action and the availability of grant funds will be suspended until corrective action is taken and time and effort reporting obligations are met. Violations or non-compliance with EWU Policy 302- 06 also may be subject to EWU Policy 302-205 (Ethics in Research).

Reporting Violations Suspected violations of the effort reporting policy and/or relevant federal regulations should be reported to the Provost, the college Dean, OGRD, the University President, or to other EWU leaders.

Procedures OGRD has established a system for employees to review and certify salaries.

50 Rev. July 21, 2018 It is the responsibility of OGRD to: (1) distribute monthly Level of Effort (LOE) reports to appropriate personnel for review, modification as necessary and signature; (2) follow up with personnel who have not returned the LOE report within 45 days of issuance; (3) ensure that a system is in place for employees committing time to a federal agreement to meet their requirements for review and certification of salaries and to assure that the salaries of personnel charged or contributed to federal agreements correspond to the effort expended on these projects. (a) For salaried employees, OGRD calculates the anticipated level of effort on a monthly basis and prepares level of effort reports. (b) For non-salaried employees, the approved hourly timesheet is used to satisfy the requirement for effort certification. (4) maintain copies of completed level of effort reports for a period of six years from the issuance of the state audit report which includes the specific federal agreement; and (5) ensure that any required adjustments of effort are negotiated with and approved by the funding agency.

Salaried employees, who perform compensated and/or uncompensated work on federal agreements shall: (1) certify that information contained in monthly level of effort reports is fair and reasonable. If the information is NOT accurate, the employee needs to revise it to more accurately reflect the activities for which the employee was paid or contributed time. (2) submit reports to their direct supervisor and the principal investigator/project director for the federal agreement on which they are being paid or to which time is being contributed (or their department chair as applicable) for approval and certification.

Principal Investigators/Project Directors are ultimately responsible for the accuracy of the effort certification. Principal Investigators/Project Directors on federal agreements shall: (1) review the LOE reports for accuracy; (2) sign approved LOE reports and forward them to OGRD; (3) work with OGRD as necessary to make permanent payroll adjustments to a federal agreement if an employee has significantly revised the LOE report.

Who is subject to effort reporting? All employees paid from or contributing compensated or uncompensated time to federal agreements are subject to effort reporting.

How is effort determined for the purpose of federal effort reporting? Level of effort is based on the total salary for the month and will always equal 100%. It may represent more than one work activity (e.g. research, instruction, service) and more than one source of funding. Level of effort is not the same as full time equivalent (FTE).

Why is effort reporting required? Since educational institutions employ a variety of staff that are not required to use hourly timesheets, OGRD prepares a “Monthly Level of Effort Report" to be used to document staff's time and effort worked on a federal agreement. The details of the federal regulations requiring effort reporting are located at Title 2 Code of Federal Regulations (CFR) Part 220 Cost Principles for Educational Institutions. These regulations apply "to research and development, 51 Rev. July 21, 2018 training, and other sponsored" programs performed by EWU employees under federal agreements.

To comply with federal regulations, the university has implemented a monthly, after-the-fact time and effort reporting system to verify that all personnel costs charged to a federal agreement are appropriate based on the actual time and effort spent on the project.

What is federal pass-through funding? Federal pass-through funding is federal funding for programs received by a state, governmental entity, non-profit, or various other entities and that is then awarded to EWU. Under this arrangement, EWU is a sub-recipient of federal funds.

Since the source of funds was the federal government, those funds still retain their federal identity. Therefore, any individual paid wages from federal pass-through dollars is also required to complete the “Monthly Level of Effort Report”.

How is effort reporting accomplished? The OGRD prepares the “Monthly Level of Effort Report” on federally funded projects and sends them out for signature. A blank form appears on the next page. These reports are generated and issued one to two months after the date payroll was paid. The reports must be reviewed and signed by both the employee and the Principal Investigator (PI) working on the grant, and returned to the OGRD to be retained in its files. If the time actually spent on the project differs from the time paid from the project, the PI must contact the OGRD to determine whether a revision to the distribution of payroll needs to be made before returning the Level of Effort report to the OGRD. Please note that the Department Chair or Dean must also sign the Level of Effort reports for the PI’s effort. The PI is responsible for all costs charged to his/her sponsored program indexes. While the PI may delegate some responsibility for the day-to-day management of finances or other tasks to departmental business staff, the PI remains accountable for compliance with University and sponsor requirements.

MONTHLY LEVEL OF EFFORT REPORT 52 Rev. July 21, 2018 Name: Researcher Dept/MS: Geology – SCI 130 Effort Period: February 20XX

Level of effort (LOE) reporting is required by federal regulations and applies to the effort of all EWU personnel who have all or a portion of their salaries/wages paid from federal funds. The purpose of the LOE report is to certify that the pay was a reasonable reflection of effort and ensure that salaries/wages charged to federally-supported programs are allocable, allowable, and consistently treated. It is important to understand that LOE is based on the total salary for the month and will always equal 100%; LOE is not the same as full time equivalent (FTE).

Your signature and that of your supervisor and PI/Dept. Chair provide the necessary certification that the percentages are a fair and reasonable estimate of your activities for the indicated month. If the information provided is not accurate, please revise it to more closely reflect the activities for which you were paid by the University.

ACTIVITY LEVEL OF EFFORT % 1. Sponsored Index Fund Inde Salary Full Time Programs No. No. x % Equivalent FTE%

2. Cost Sharing FROM: Cost Sharing TO: 3. Other Activities

4. TOTAL ACTIVITIES

Employee Signature: ______Date: ______

Direct Supervisor Signature: ______Date: ______

Principal Investigator/Dept. Chair: ______Date: ______If you have questions, call the Grants Office at 359-6567. Return copy with ALL signatures to SHW 210. Monthly Level of Effort Report Examples - Four examples have been provided.

53 Rev. July 21, 2018 (1) The first example shows Researcher #1 with both the Level of Effort and Full Time Equivalent (FTE) for the position of 100%.

ACTIVITY LEVEL OF EFFORT % 1. Sponsored Index Fund Inde Salary Full Time Programs No. No. x % Equivalent FTE% 501870 216580 100 4000.00 100

2. Cost Sharing FROM: Cost Sharing TO: 3. Other Activities

4. TOTAL 100% 4000.00 100% ACTIVITIES

(2) The next example is for Researcher #2 with the Level of Effort equal to 100% and the Full Time Equivalent (FTE) equal to 110%.

ACTIVITY LEVEL OF EFFORT % 1. Sponsored Index Fund Index Salary Full Time Programs No. No. % Equivalent FTE% 502785 210856 9.09 500.00 10

54 Rev. July 21, 2018 2. Cost Sharing FROM: Cost Sharing TO: 3. Other Activities 100652 120149 90.91 5000.00 100

4. TOTAL 100% 5500.00 110% ACTIVITIES

(3) Researcher #3 has less than a full-time position. Researcher #3’s Level of Effort is equal to 100% and the Full Time Equivalent (FTE) is equal to 75%.

ACTIVITY LEVEL OF EFFORT % 1. Sponsored Index Fund Inde Salary Full Time Programs No. No. x % Equivalent FTE% 506590 220495 20 600.00 15

2. Cost Sharing FROM: Cost Sharing TO: 3. Other Activities 200896 133957 80 2400.00 60

4. TOTAL 100% 3000.00 75% ACTIVITIES 55 Rev. July 21, 2018 (4) The fourth example shows Researcher #4 with both the Level of Effort and Full Time Equivalent (FTE) for the position of 100%. 5% cost sharing is being provided from non- federal funding.

ACTIVITY LEVEL OF EFFORT % 1. Sponsored Index Fund Inde Salary Full Time Programs No. No. x % Equivalent FTE% 501870 216580 5 200.00 5

2. Cost Sharing 100499 120149 5 200.00 5 FROM: Cost Sharing 500862 210990 TO: 3. Other Activities 100499 120149 90 3600.00 90

4. TOTAL 100% 4000.00 100% ACTIVITIES

Where do I find answers to my questions about EWU’s effort reporting policy and related sanctions for non-compliance? EWU adopted Policy 302-06: Effort Reporting effective March 23, 2012. It is located on EWU’s website at http://cfweb.ewu.edu/policy/PolicyFiles/EWU_302_06.pdf. The OGRD staff is also available to answer your questions. Call 509-359-6567 or stop by and talk with one of the Post- Award staff located in Showalter Hall 210 and 209A.

Where can I find the federal regulations that require effort reporting? The federal government’s cost principles for educational institutions must be used to guide all costs incurred for sponsored projects and research; including all activities sponsored by federal and non- federal agencies and organizations.

The Office of Management and Budget (OMB) continually updates and describes these principles in great detail at http://whitehouse.gov/omb/circulars/ • 2 CFR Part 220 (OMB Circular No. A-21)- Cost Principles for Educational Institutions. • 2 CFR Part 215 (OMB Circular No. A-110)- Uniform Administrative Requirements for Grant Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations. 56 Rev. July 21, 2018 57 Rev. July 21, 2018

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