Payroll Certification on Sponsored Awards

I. POLICY STATEMENT

As a recipient of Federal and non-Federal sponsored awards, Occidental College (“College”)  must comply with all terms and conditions of awarding agency agreements. To meet the requirement to document compensation on sponsored awards, the College has implemented a payroll certification system that ensures that salaries and wages charged to a sponsored award are consistent and reasonable with the effort committed to the award.

II. APPLICABILITY

This policy applies to all members of the College community (including all Principal Investigators; Program Directors; faculty; students; and administrative, professional, nonexempt, and temporary employees) receiving compensation from a Qualifying Award.

III. DEFINITIONS

Institutional Base Salary (IBS): Compensation paid for work performed by faculty members during the academic year, which is based on the faculty member’s regular compensation.

Effort: The percentage or proportion of time spent on Qualifying Awards and other College-compensated employment duties. Total effort must always equal 100%. Effort is not equivalent to hours worked: for example,  part-time employees must certify to 100%, even if their appointment is less than 40 hours per week. 

Payroll Certification: The method for confirming that compensation charged to Qualifying Awards is reasonable in relation to the amount of work performed.

Payroll Certification Reports: Reports required for any employee whose salary (or any portion thereof) is charged to a Qualifying Award. 

Principal Investigator (PI) or Project Director (PD): The person with administrative and fiscal responsibility for an award.

Responsible Individual: The person responsible for certifying that a payroll report is accurate. This includes PIs, PDs, designated supervisors, or any other responsible designee with knowledge of the activities performed by an employee on a Qualifying Award.

Qualifying Award: A Qualifying Award includes (1) any federally-sponsored award, including cost-sharing accounts, and (2) any non-federal sponsored award that requires Effort reporting.

IV. POLICY

All Responsible Individuals must be familiar with the terms and conditions of their Qualifying Award and must certify the Effort of employees’ whose compensation is paid from a Qualifying Award.

Compensation is determined using the College’s payroll system. The College uses as an “after-the-fact Effort reporting” system where the distribution of salaries and wages is supported by activity reports signed by each employee working on the Qualifying Award as well as the Responsible Individual.

The Sponsored Research Office is responsible for administering the Payroll Certification process. This includes the Payroll Certification process (preparing, reviewing, and updating Institutional Base Salary allocations and payroll reports, making appropriate changes to payroll reports, and certifying payroll reports), monitoring compliance, providing guidance and training, and maintaining certification records in accordance with record retention requirements.

A. Payroll Certification

Payroll Certification Reports are distributed at least once per fiscal year. The Responsible Individual must obtain necessary certifications from the employees performing work on their Qualifying Award, and for reviewing, approving, and certifying those reports. Responsible Individuals must also certify their own Effort. The Responsible Individual must share the report with each employee working on the Qualifying Award. Those employees must review the report for accuracy and report any inaccuracies.

Each Responsible Individual must return all Payroll Certification reports within thirty (30) days of receipt. Failure to return the Payroll Certification report within the required timeframe may result in the temporary suspension of compensation charges to the award, reallocation of salary to a departmental account, and/or other administrative actions.

B. Changes to Payroll Certification Report

Salary amounts charged to a Qualifying Award must never exceed the proportion of the Institutional Base Salary associated with the actual Effort devoted to the Qualifying Award. If the payroll distribution on the Payroll Certification Report exceeds the time actually spent on the Qualifying Award, or if there are other errors in the Certification, the affected employee must immediately notify the Responsible Individual, and the Responsible Individual must promptly notify the Sponsored Research Office. The Sponsored Research Office will work with the Responsible Individual and Payroll Office to evaluate the alleged errors. If confirmed, a correction request will be submitted to the Grant Accountant for processing. After posting the correction, an updated Payroll Certification report will be resubmitted to the Responsible Individual and affected employee for certification.

C. Records Retention

Payroll Certification reports will be retained by the Sponsored Research Office for three (3) years from the date of submission of the final Payroll Certification report, in accordance with 2 CFR § 200.334.

V. POLICY HISTORY

Responsible Officers: Controller, Director of Sponsored Research

Effective Date: July 1, 2004

Last Revised Date: February 13, 2026

VI. RELATED POLICIES AND RESOURCES

Uniform Guidance – Office of Management and Budget (“OMB”), Title 2, Subtitle A, Chapter ll of the Code of Federal Regulations, Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, referred to as (“2 CFR 200”) or (“Uniform Guidance”), specifically see Subpart E – Post Federal Award Requirements Compensation – personal services.