The Council on Governmental Relations (COGR) Guide to 2 CFR 200.430 offers comprehensive and authoritative guidance for institutions of higher education (IHEs) in interpreting and implementing the U.S. Office of Management and Budget’s (OMB) Uniform Guidance related to compensation for personal services on federally sponsored projects. The guide outlines substantive updates from previous regulations, including increased flexibility in accounting for salaries and wages, a shift away from prescriptive effort reporting and certification, and heightened emphasis on robust internal controls and consistently maintained, transparent institutional policies.
A central theme of the guide is the requirement for clear, written institutional policies that precisely define compensation elements, such as institutional base salary (IBS), extra and overload service pay, incentive compensation, and the boundaries of compensated activities. The document systematically reviews regulatory standards governing allowable and unallowable costs, intra-institutional consulting, salary treatment for both faculty and non-faculty employees, compensation during non-academic periods, and sabbatical leave. It provides particular emphasis on documenting personnel expenses with records that accurately reflect work performed and the allocation of activities, ensuring compliance with federal requirements and institutional accounting policies.
The guide highlights new administrative flexibilities, such as the adoption of alternative payroll documentation systems and performance-based or blended funding approaches, provided they are approved by cognizant federal agencies. It also addresses the implications for part-time faculty, non-faculty professionals, and compliance with the Fair Labor Standards Act. Through practical recommendations, side-by-side regulatory comparisons, and detailed explanations, the guide underscores the core principles of consistency, allowability, reasonableness, and transparency in compensation management. It positions itself as an essential interpretive resource for institutions seeking to strengthen compliance, mitigate audit risk, and adapt to the evolving landscape of federal cost principles.
for the Guide.
