The document, authored by Kim Moreland and presented in June 2015 for the Council on Governmental Relations (COGR), provides an in-depth analysis of the changes to federal compensation standards introduced under the Uniform Guidance (2 CFR 200.430). The presentation highlights that the Uniform Guidance offers greater flexibility in how institutions of higher education (IHEs) account for salaries and wages charged to federal awards, notably by making effort reporting and certification optional rather than mandatory. Instead, the emphasis shifts to the establishment and maintenance of strong internal controls and comprehensive, up-to-date written policies and procedures to ensure accuracy and compliance in charging personnel expenses.
Key themes include the redefinition of compensation as “remuneration,” requirements for reasonable and consistent pay rates, and detailed guidance on categories of allowable compensation such as incentive pay, consulting, extra service pay, and activities outside the academic year. The document underscores the necessity for clear documentation, institutional base salary (IBS) definitions, and adherence to standards ensuring charges to federal awards are accurate, allowable, and properly allocated. It also discusses the acceptance of alternative documentation methods with appropriate approvals and the expectation that payroll costs for cost sharing be documented with the same rigor as those reimbursed by federal funds. Ultimately, while the Uniform Guidance introduces more flexibility, it places significant responsibility on institutions to ensure robust internal controls and accountability, with the potential necessity for traditional effort reporting arising only if other systems fail to meet federal standards.
