The document, authored by Mary Beth Rudofski in June 2015, provides an assessment of the implementation of new federal Uniform Guidance standards—specifically §200.430 regarding compensation for personal services—at the University of Chicago (UChicago). Rudofski highlights the university's efforts to transition from traditional, often burdensome effort certification processes toward a system more focused on robust internal controls for ensuring the accuracy and allowability of salary charges to sponsored federal awards. The presentation outlines existing procedures, such as the Annual Certification Statements (ACSs) and associated challenges, including delayed certification timelines, artificial fiscal boundaries, difficulty aligning certifications with actual salary allocations, and logistical obstacles arising from staff sharing and faculty transitions.
To address these issues, UChicago reviewed internal controls and identified areas for improvement, such as clarifying Institutional Base Salary definitions, updating cost-sharing policies, and developing transparent, efficient processes for cost transfers and salary allocation documentation. The report also emphasized the need for institutional policies that reasonably approximate work performed, permit timely adjustments, and do not require overly precise breakdowns of salary components beyond internal control thresholds. The concluding recommendations include updating relevant university policies, enhancing internal documentation, providing management-level reporting, and disseminating best practices through a white paper, with plans to integrate these new documentation standards in the subsequent fiscal year. Overall, the report documents a comprehensive institutional response aimed at aligning with federal requirements while optimizing administrative efficacy and transparency.
