Policies & Procedures


Section 1

Business and Financial Affairs


Sec. 701-19: Payroll Certification System Guidelines for Federally Sponsored Projects

Responsible Office: Accounting & Fiscal Services, Contracts and Grants Accounting
November 2022

References / Resources

Contact: Contracts & Grants Accounting at (949) 824-0265 or bnajman@uci.edu

A. Purpose and Scope

As a recipient of federal funding, UCI is required to comply with the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) for tracking and reporting of payroll related costs (2 CFR §200.430). To properly manage personnel compensation compliance, and fulfill the salaries and wages federal reporting requirement, UCI implemented a Payroll Certification System (PCS). These Guidelines provide an overview of the UCI’s payroll certification process, and discuss requirements and responsibilities of users of the Payroll Certification System (PCS).

The payroll certification process requires that Principal Investigators (PIs) complete an after-the-fact review of salaries and wages charged to their federal awards, as well as cost shared salaries if applicable, and certify that they are accurate, allowable, properly allocated, and reasonable in relation to work performed. Payroll certification is project based, must take place at least every 12 months, and is due 90 days from the award budget period end date. Details of the payroll certification process, and PCS workflow and document routing, are described on the following website: https://www.accounting.uci.edu/kfs-pcs/index.html..

B. Definitions

Payroll Certification is an after-the-fact review of project salary and wage expenses by the PI, and confirmation that they have been correctly charged, are reasonable and related to work performed, and proposal preparation activities were not charged to the project.

Principal Investigator (PI) is the lead investigator as designated in the Notice of Award and as identified in Kuali Financial System (KFS).

C. Responsibilities

  1. Principal Investigator (PI)

    The PI is responsible for:

    • Timely reviewing charges and committed cost sharing for personnel services on the federal awards
    • Determining whether salary charges were appropriate and reasonable in relation to work performed
    • Within 90 days of the end of the federal award budget period end date, verifying allowability of personnel expenses by certifying them in the Payroll Certification System
    • Ensuring that any special federal costing requirements were met.

  2. Departments

    The department's contract and grant analyst and financial manager are responsible for:

    • Monthly reconciling the project’s general ledgers activity
    • Timely processing of payroll expense adjustments and corrections
    • Assisting the PI in understanding expense activity and payroll certification requirements
    • Assisting the PI in understanding expense activity and payroll certification requirements

    The department head is responsible for ensuring adequate and well-trained personnel with the role of Departmental Payroll Certification Administrator (DPCA) is available to assist PIs with payroll reviews and PCS certifications, and that all ledger reconciliations and payroll certifications are completed within the established timeframe.

  3. Accounting Office

    The Accounting Office is responsible for:

    • Maintaining the integrity of core financial information and coding fund attributes that generate monthly financial reports and annual payroll certifications
    • Notifying campus departments and PIs about the upcoming certification deadlines
    • Assisting PIs and their departments to ensure accuracy of reporting and compliance with federal and University policies, and award terms and conditions
    • Providing training to the PCS campus users
    • Monitoring the return of payroll certifications to Accounting to ensure timeliness and completeness
    • In the event that reports are not certified in a timely manner, escalating reporting delays in an effort to ensure full compliance.

D. Requirements

The University of California’s Payroll, Academic Personnel, Timekeeping & Human Resources System (UCPath) serves all UC employees and reflects actual salary and wage costs of employees by full accounting unit. UCPath feeds payroll data into the KFS Labor Ledger and to PCS where the salary information is displayed for each employee working on a project, allowing for detailed departmental and PI review and certification. Labor distribution is setup in UCPath, and when updates are made, PCS statements are updated to reflect the new payroll.

  1. Salary distributions must adhere to the University’s academic and staff personnel policies.
  2. The apportionment of employees' salaries and wages chargeable to sponsored agreements or identified as committed cost sharing must be initiated by the PI or designee using the appropriate departmental personnel services authorization format.
  3. All charges and cost sharing for personnel services must be based on actual salary charges posted in the accounting system and supported by documentation such as employment contracts, appointment letters, and other written guidance.
  4. Individuals whose payroll is to be recorded as committed cost sharing on projects must have worked on the project and be documented in the campus cost sharing system under the applicable award's fund number.
  5. Charges must be appropriate and reasonable in relation to work performed and must comply with special costing requirements (e.g., NIH Salary Cap, NSF senior personnel salary limits, federal exception criteria for clerical and administrative salaries).

  6. Non-sponsored activities cannot be charged to sponsored projects (e.g., instruction administration, departmental administration, proposal preparation activities).
  7. Each budget period cycle that has federal payroll charges must be certified in PCS.
  8. After the budget period ends, the Departmental Payroll Certification Administrator (DPCA) initiates a certification statement within PCS and PIs are emailed a notification that the statement is available for certification.
  9. The PI must certify salaries for each federally sponsored project within 90 days from the end date of each budget year of the award.

E. Grants Management

Departments are expected to establish a grants management program that includes:

  • Timely setup of personnel on sponsored projects with appropriate approvals.
  • Performance of month-end ledger reviews that will result is timely identification of errors, initiation of corrections, and timely payroll certifications.
  • Transfer of incorrect salary costs within 120 days of the first recording of an expense.
  • If applicable, budgets and a monitoring system for committed cost sharing.
  • Compliance with the costing requirements stated in the terms of the grant and University of California policies and procedures.

F. Frequency of Certifications

Payroll certification of salaries directly charged to the federal project and cost shared by the University, if applicable, is required annually and within 90 days from the end date of each budget period of the award.

G. Retention of Certifications

Payroll certifications must be retained for subsequent review and in accordance with the requirements of the UC Records Retention Schedule which states: "Retain records for 6 years after the expiration/termination of the sponsored agreement, unless otherwise specified in the award agreement.”

H. Non-Compliance

Compliance with these guidelines is critical to UCI’s fiduciary responsibility for the management of federal funds. Uncertified salaries and untimely certification of salary expenditures create an undue compliance risk for the campus. In the event of non-compliance (not completing payroll certifications), Contract and Grant Accounting may initiate any of the following actions upon approval of the Vice Chancellor for Research and Vice Chancellor, Division of Finance and Administration:

  • Transfer uncertified salary charges to an unrestricted funding source in the PI’s department
  • Close all of the PI’s funds and accounts relating to sponsored projects
  • Move grant financial management from the PI and to the Dean
  • Restrict the PI from submitting grant funding proposals.