The Council on Governmental Relations (COGR) Guide to 2 CFR 200.430 offers comprehensive guidance to institutions of higher education on interpreting and implementing the federal regulations governing compensation for personal services on federal awards. The Guide provides a detailed comparison between the Uniform Guidance and its predecessor, OMB Circular A-21, highlighting key updates such as increased flexibility in payroll documentation, a stronger focus on robust internal controls, and the requirement for thorough, consistently applied institutional policies and procedures.
A central theme is the expanded definition of compensation, which now includes a broad array of benefits beyond traditional salary and wages, and the expectation that institutional compensation policies must be both federally compliant and consistently applied across similar positions. The Uniform Guidance maintains the requirement that compensation be reasonable, aligned with established institutional standards, and properly documented, but shifts away from rigid effort reporting toward reliance on effective internal controls and records that accurately reflect work performed, ensuring activities do not exceed 100% of workload.
The Guide addresses a wide range of compensation scenarios, such as extra service pay, intra-institutional consulting, compensation during periods outside the academic year, and special cases like part-time appointments and sabbatical leave. It emphasizes the need for institutions to define concepts such as institutional base salary (IBS) and extra service pay in clear, written policies, and to maintain rigorous documentation practices that provide reasonable assurance of accuracy, allowability, and proper allocation of costs. The flexibility now permitted in documentation methods is balanced by the ongoing requirement for clear distinctions between allowable and unallowable costs and for systematic review and updating of institutional procedures in response to changing federal guidance and audit expectations.
In conclusion, the COGR Guide underscores the importance for institutions to maintain clear, robust internal controls and consistently applied policies when managing compensation charged to federal awards. It encourages regular review of compensation practices to ensure continued compliance with federal regulations and preparedness for audits, recognizing both the complexity of academic work and the evolving nature of federal requirements.
