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Controller's DivisionOUS Financial Administration Standard Operating Manual (FASOM) |
The content of this policy is current, although it has not yet been transitioned to the new Fiscal Policy format. This will be accomplished as time and resources permit.
One major A-21 requirement is accounting for employee compensation for work done on federally sponsored agreements. It is equally important to provide documentation to support institution claims for indirect cost recovery. Both direct and indirect costs may be disallowed after the fact by auditors who find that documentation is inadequate. The Personnel Activity Report (PAR) system is a means of documenting employee effort expended on sponsored agreements, and FASOM 05.05 describes the process for employing the PAR system within the framework of OUS's policies and procedures.
The PAR system generally consists of the following:
Not all employees are subject to A-21 reporting requirements. FASOM 05.05B explains the criteria for determining subject employees and defines the term "compensation."
Questions concerning project activities and compensation subject to A-21 requirements should be directed to the department or institution PAR Coordinator.
Employees who are paid (totally or partially) from federally funded sponsored agreement -- or employees who are used in mandatory or voluntary cost sharing for those awards -- are subject to A-21 reporting requirements.
The terms used in FASOM 05.05B[3] are defined below:
Classified and student employees whose activities -- all or part -- are designated as Departmental Administration (see FASOM 05.05E[3]) or Sponsored Projects' Administration (see FASOM 05.05E[3]) are subject to A-21 reporting requirements.
Employees who expend all or part of their effort on activities designated as Hospital and Clinics Administration (see FASOM 05.05E[3]) or Hospital and Clinics Instruction (see FASOM 05.05E[3]) are subject to A-21 reporting requirements, regardless of pay source.
Subject employees may be identified partially by computer analysis of payroll or personnel files.
Select employees paid from federally funded Grant or Contract Funds with a federal source of funds code on the BPP/FMS crosswalk table.
Select employees for whom PDB element 085 is coded "subject." PDB element 085, A-21 Code, may have the following values (see FASOM 10.01A[3]085):
| Code | Description |
| Blank | No entry was made and no automated action will be taken on this element. |
| 99 Not Subject | Entered after analysis was made and positive action was taken. This optional code prevents automated pre-printing of the PAR form. |
| 24 Subject | A-21 reporting is completed quarterly. |
Employees engaged in activities listed in the selection criteria in FASOM 05.05B[3] through 05.05B[5] but not paid from federal funds or not already coded "subject" on the Personnel Data Base (see FASOM 05.05B[6]) must complete a PAR form. The form must be prepared manually rather than pre-printed automatically.
All of the previous discussion on subject employees relates to institutions using the "Long Form" for proposing indirect cost rates. An abbreviated formula is used to determine grant and contract indirect cost rates when an institution uses less than $10,000,000 total federal funds per year. For such "Short Form" institutions, only employees paid from federally funded grants and contracts and employees considered to be cost-shared are subject to the A-21 reporting requirements.
[a] Compensation includes all amounts an institution pays employees for services required to fulfill the employees' obligations to the institution. The PAR form shows the current payroll charges for the reporting period and indicates the percentage of pay from each FOAPAL. All current regular pay is normally reported, including overtime, holiday pay, special duty pay, shift differential, stand-by or on-call pay, compensatory pay, summer pay, penalty pay and vacation pay.
[b] Excluded salary or wage items include travel pay differential (i.e., a meal allowance), perquisites and academic supplemental pay. The academic or unclassified supplemental pay is not subject to time and effort reporting if the following are true:
[c] Faculty at Oregon Health Sciences University should exclude Practice Plan compensation from their PAR reporting requirements.
[d] The value of donated services is not incorporated into the PAR system. A-21 recognizes donated service for cost-sharing purposes only and requires supplemental documentation. Donated services are not allowable for full-time employees, but donated services of part-time or non-employees may be allowable for cost-sharing.
The PAR process prescribed in A-21 specifies that activity reports be prepared at least quarterly for academic and classified employees (Graduate Assistants also report PAR data quarterly). For these quarterly reports, payroll data and activity data are accumulated for three months.
PAR reporting tasks and their approximate completion dates for academic and classified employees appear in [a] through [f] below.
Task 1 must be completed between the 7th and the 15th of the first month following the end of a quarter. For example, if a quarter ends June 30, Task 1 must be completed between July 7 and July 15.
The completion date for Task 2 is established by the department or institution.
The completion date for Task 3 is the 10th of the second month following the end of a quarter. For example, if a quarter ends on June 30, Task 3 must be completed by August 10.
The completion date for Task 4 is the 30th of the second month following the end of a quarter. For example, if a quarter ends June 30, Task 4 must be completed by August 30.
The completion date for Task 5 is the 10th of the third month following the end of a quarter. For example, if a quarter ends June 30, Task 5 must be completed by September 10.
The completion date for Task 6 is the 30th of the third month following the end of a quarter. For example, if a quarter ends June 30, Task 6 must be completed by September 30.
Student employees subject to A-21 should report their monthly activities. Each month, PAR forms for students paid that month are pre-printed shortly after the Regular and Supplemental payrolls. They are distributed immediately to institutions and departments for time-keeping purposes. Following the end of the pay period, payroll data and PAR information should be completed and forwarded to the institution business office for payroll and PAR input. Departments should submit the combination Payroll-PAR form to the institution business office in time to meet payroll deadlines. Student PAR data must be input over the terminals or submitted to the Controller's Division quarterly at the same time as PAR data for academic and classified forms.
Some institutions elect an alternative certification process and do not claim administration or cost-sharing for student employees.
The PAR reporting tasks and their approximate completion dates for student employees appear in [a] through [i] below.
The completion date for Task 1 is the 27th or 28th of each month, after the regular payroll cut-off date of the 25th.
The completion date for Task 2 is the 28th or 29th of the month, after the regular payroll cut-off date of the 25th.
The completion date for Task 3 is the 29th or 30th of the month, after the regular payroll cut-off date of the 25th.
Employees report their time from the 16th of the previous month through the 15th of the current month. Because students do not receive their Payroll-PAR forms until the end of the previous month, they must maintain separate records of their activities until they receive PAR forms. At that time, they should transfer information to the Payroll-PAR form. For example, for April payroll, time should be reported from March 16 through April 15. Departments receive Payroll-PAR forms on March 29 or 30. Each student must maintain a separate record of activities from March 16 until receiving a Payroll-PAR form.
The completion date for Task 4 is the 7th or 8th of the month, after the supplemental payroll cut-off date of approximately the 5th or 6th.
The completion date for Task 5 is the 8th or 9th of the month, after the supplemental payroll cut-off date of approximately the 5th or 6th.
The completion date for Task 6 is the 9th or 10th of the month, after the supplemental payroll cut-off date of approximately the 5th or 6th (see FASOM 05.05C[5]c).
The completion date for Task 7 is established by the institution.
The completion date for Task 8 is the same as when Academic and Classified forms are returned to the Controller's Division: the 10th of the third month following the end of a quarter (see FASOM 05.05C[2]e).
Task 9 should be completed when Academic and Classified forms are input: the 30th of the third month following the end of a quarter (see FASOM 05.05C[2]f).
PAR forms are used to document payroll-related effort or activities and to generate various direct and indirect-cost reports. One PAR form is used for academic or classified employees, and a separate form is used for student employees. This section contains instructions to complete each form.
[a] The Academic or Classified Personnel Activity Report form contains the following major sections:
This section is pre-printed for automatically selected reports. The pre-printed items include the institution, employee's name, Social Security number, monthly salary rate, classification codes, position number and major organizational unit. Blocks are also provided to indicate if payroll, budget or PAR data must be adjusted. If no pre-printed PAR form is available, a blank form should be completed. The following items need not be entered manually:
This information is pre-printed on automatically selected reports. For all pay, the quarter ending and the year are shown as well as FOAPAL data. The amount of pay for each FOAPAL and the percentage of total pay that it represents are also shown. The pay blocks provide sufficient space for identifying activities associated with each. Seven pay blocks are available per form. If additional lines of pay data are needed, multiple pages can be produced. The payroll data include only current-period pay items and do not include payroll adjustments on non-current pay items. Non-current pay recorded in a reporting period may require a manually prepared PAR form.
This section should be completed by the employee or a person who has first-hand knowledge of the employee's efforts. Enter the PAR code as defined in FASOM 05.05E. If non-federal monies are used to fund cost sharing, enter the FOAPAL of the project to which the cost sharing applies. Enter the percentage of effort related to each PAR code (rounded to the nearest percent). The sum of such percentages must equal 100%.
Activity reports for classified and student employees are necessary to identify administrative effort in sufficient detail to demonstrate that the work benefits sponsored projects. The administrative effort detail is optional for academic employees. The following list indicates which employees must list or make a statement of tasks performed under particular PAR codes:
Specific administrative committee assignments must be itemized. Committee assignments that solely benefit instruction are recorded as INS (Instruction) and need not be listed (see FASOM 05.05E[5]).
Each form relating to the entire effort of the employee requires a certification statement indicating the activity shown is a reasonable estimate of the work performed. It must be signed and dated by the employee, principal investigator, or other responsible official. The employee's signature is highly preferred.
Space is provided for the department PAR Coordinator's signature or initials and date. Unusual circumstances affecting pay or activities may be noted in the "Comments" section or in unused space in the Administrative Tasks section. When PAR data indicate that the current period payroll or forecast budgeted pay must be adjusted, the blocks provided in the upper right-hand corner of the form should be checked and appropriate institutional documentation for these adjustments initiated.
[a] The Student Payroll-PAR form serves the same function as the Academic or Classified PAR form but adds sections for optional hours worked, payroll input and CWSP certification. The Student Payroll-PAR form contains the following major sections:
Note: Students are defined as employees reported with 105XX pay account codes.
Note: Institutions that elect not to use pre-printed forms should continue to use regular time cards for payroll input but should provide written support of subject time and
effort certifications.
This section is pre-printed for student employees who were paid the previous month. If no pre-printed PAR form is available, a blank form should be completed. The following items need not be entered manually:
This section provides a convenient record of daily hours worked.
The time card elements are incorporated into this section; there is no need to transcribe pay data to a separate time card. Pay FOAPALs are printed every other line to leave adequate space to report multiple PAR data. If pay is CWSP supported, use the second line following the departmental FOAPAL to indicate the 80% pay FOAPAL. There is space for two primary FOAPALs if CWSP is used. Use multiple forms for additional pay. Corrections to pre-printed pay FOAPALs are made by lining out the pre-printed data and adding the new number directly below.
If a student employee is subject to A-21 reporting requirements, this area should be used to identify the pay amount; PAR activity code; cost-shared FOAPAL, if applicable; and the percentage of effort for each activity. This section is required for subject PAR student employees even though other sections of the form are not used.
Provision for the status of the CWSP award is made, as well as required student and supervisory certifications.
This area provides space for the required PAR certification statement and space to indicate specific administrative tasks if the activity is claimed as administrative.
This section is for signatures and comments of business office personnel.
The PAR system identifies and documents the unique activities that make up 100% of compensated effort. Employees subject to A-21's quarterly reporting requirements use the codes in FASOM 05.05E[3] to identify their activities.
The following terms are used frequently throughout the PAR activity codes. Each term is followed by its definition.
This section contains codes used to report PAR activities. Each code is followed by its definition.
Teaching activities of an institution, whether offered for credit toward a degree or certificate or on a non-credit basis, and whether offered through regular academic departments or separate divisions. These activities are typically paid from Educational and General Funds - Instruction budgeted FOAPALs or Current Restricted Fund Instructional/Developmental grants in the sponsored instruction series of funds. INS also includes departmental research activities not classified as separately organized research or cost sharing. Following are examples of activities that qualify as INS:
Effort related to patient services at OHSU's hospital and clinics that involves teaching and instructional activities. This includes time spent giving directions to students and house staff and time associated with grant rounds, patient care conferences and discussion of patient cases. HCI includes both inpatient and outpatient care but excludes activity for which a professional fee is billed for patient care.
Any matching or cost-sharing INS activities required or volunteered toward a sponsored instructional agreement that is separately budgeted and accounted for.
Expenses incurred for administrative and supportive services that benefit common or joint departmental activities or objectives in academic deans' offices and academic departments and divisions. Examples of DAD include the following:
A compensated leave of absence granted a faculty member. Sabbatical leave is recognized as a type of departmental administration expense to be allocated to direct cost functions of the department.
Activities for the general executive and administrative offices of educational institutions, as well as other activities of a general character that do not relate to any single major function of the institution. Allowable expenditures are allocated to the major functions and categories of the institution for purposes of developing indirect cost rates. Examples of GAG include the following:
Activities conducted in separate organizations established to administer sponsored programs, including such functions as grant and contract administration and editing and publishing research-related reports. Examples of such organizations include the following:
Administrative activities of faculty and professional classified staff in departmental units with multiple functions may also be classified as SPA if the effort relates exclusively to sponsored programs. Non-professional classified and student employees may only be designated as SPA if they are in a separately identified organizational unit. (Fair Labor Standards Act definitions of professional and non-professional apply here.) Examples of SPA activities include the following:
Instructional departments must consistently identify administrative effort that solely benefits a single function within that department. For example, if SPA is identified in the instructional department, administrative effort that exclusively benefits instruction must be determined also and reported as INS. Administrative effort that benefits all functional activities in the department must be reported as DAD (see FASOM 05.05E[3]).
Costs of administrative and supportive services that solely benefit OSU's Cooperative Extension Service.
Activities that are for the administration of OHSU's hospital and clinics, i.e., time spent to maintain the basic functions. Examples of HCA include the following:
Note: There is a distinction between these kinds of administrative activities and college and departmental administration, which is coded DAD.
An institution's research and development activities that are separately budgeted and accounted for, including those sponsored by federal and non-federal agencies and organizations. ORE also includes activities involving the training of individuals in research techniques. Where an activity is conducted can determine whether it is research training or regular instruction. If the training activity uses the same facilities as separately budgeted and accounted for research and development, it is considered ORE.
A-21 requires that all organized research and development activities be accounted for, including cost-sharing or matching that is volunteered or required by terms of the proposal or award. Cost-sharing may be funded from any non-federal source.
These activities are associated with projects financed by federal and non-federal agencies and organizations that involve the performance of work other than instruction and organized research. Examples of OSA include:
Whenever these activities are undertaken by the institution without outside support, they are classified as Other Institutional Activities.
Other sponsored activities that are separately budgeted and accounted for may require cost sharing, or an institution may volunteer cost sharing related to the projects. This activity code identifies such cost-sharing efforts.
Effort expended by a central service organization or a department for the administration, supervision, operation, maintenance, preservation and protection of the institution's physical plant.
Activities for the administration of student affairs, including deans of students, admissions office, registrar, counseling and placement services, student advisors, financial aid administration, development of catalogues, commencements and convocations. The expenditures are common to activities recorded in the Student Services FOAPALs.
Effort expended in the administration and operation of a campus-wide library.
Activities related to the administration and operation of a specialized service facility, as defined by A-21 (see FASOM 05.03).
This category includes all institution activities except instruction, organized research, other sponsored activities, indirect cost activities, specialized service facilities, HCI and HCA. Examples of OIA include the following:
The following paragraphs involve somewhat unique situations related to PAR codes.
Occasionally, specific activities do not appear to be described by PAR codes. The department PAR Coordinator or institution grants-and-contracts fiscal manager should be contacted for clarification. Some cases may require unique treatment depending on how various costs are accounted for in indirect-cost-rate proposals.
Compensated absences due to sick leave, vacation leave, military leave, etc., are considered effort that would have been performed had the employee been present for work. Such leave should not be charged to federal funds if the accrual or earnings of the benefits does not accrue on federal funds. Apportionment of leave costs may be necessary if material distortions occur.
Occasionally auditors may review PAR or related payroll data with employees. A review of the department's copy of the PAR form is highly recommended before and during any conversation with auditors. An appropriate institution representative must be present at all federal audit interviews.
Conscientious completion of PAR forms is essential to substantiate various institution costs. The production, distribution, review and treatment of PAR forms and data are also critical. To aid this process, the Controller's Division, each institution and each department has a PAR Coordinator.
Each PAR Coordinator is responsible for ensuring that the following are true:
Each PAR Coordinator is responsible for the distribution, review and return of all documents for employees in his or her respective groups. Below, the tasks that each PAR Coordinator must complete are listed in the order they must be completed:
After the departmental PAR Coordinators return completed PAR forms to the institution PAR Coordinator, they are batched in groups of 50 or less according to employee type -- academic, classified or student -- and according to the quarter. Separate batches are also made for new inputs and adjustments. Each batch is labeled with a form CO-418, PAR Batch Control Form.
PAR data corrections or adjustments must be kept to a minimum. Auditors are likely to consider excessive corrections as serious flaws in the PAR system. Full documentation of reasons for errors must be attached to PAR forms used to make corrections. The most common problem is with activities divided between more than one cost function or indirect-cost category, but not discovered until after the normal reporting cycle.
Adjustments generally fall into four categories:
Employers should consult their department PAR Coordinator to determine whether adjustments are appropriate and to initiate processing of the appropriate documents.
Incorrect pre-printed demographic data should be lined out and the corrections made above or below the pre-printed items in the same box. Incorrect pre-printed payroll data for that accounting period, however, should be lined out and the correct payroll data entered just below it.
Adjustments to the PAR data file should be made using a blank PAR form. The adjusted form should be completed by the institution's PAR Coordinator using the following procedure:
Academic or classified budgeted pay may require changing as a result of reviewing activities and current pay. Estimates of activities and pay established in the initial budget process or subsequent modifications may need to be updated. This is accomplished by submitting appropriate institutional academic or classified budget redistribution documents.
Payroll adjustments require careful consideration. Such adjustments must be made when effort distribution differs significantly from payroll distribution. (In some cases involving cost categories used for indirect-cost-rate proposals, payroll changes are not necessary.) When determining whether effort expended is significantly different from payroll distribution, effort expended on that activity should be compared to the employee's FTE for that activity. If the difference between effort expended and the payroll distribution for an activity is 5% or more of an employee's total effort, an adjustment is required. For example, an employee is paid on four sponsored projects at .25 FTE each (i.e., 25% each) and reports an effort distribution of 22%, 28%, 22% and 28%. Effort expended on each project deviates from the payroll distribution by less than the 5% of total effort, and no payroll adjustment is required. Payroll adjustments should be noted on the returned PAR form. This can be done by checking the "Adjust Current Period Pay" block and adding comments if necessary.
The automated "PAR File" consists of a fiscal-year-to-date component and a project-to-date component. Both components capture selected data from the input of completed PAR forms. Data are compiled periodically to produce a series of reports.
This report lists all pre-printed PAR forms produced after each payroll and alphabetically lists all employees within each organization and the employee's classification (i.e., academic or classified). The employee's name, Social Security number, salary rate, all payroll data, and the percent of current pay as shown on the PAR form are printed on the report. Columns are provided to indicate whether the document is to be returned with current pay or budgeted pay adjusted. Two copies of the report are run quarterly: one for the institutional Research Services office and one for the department PAR Coordinator.
The three PAR output reports below are generated quarterly. Each is a result of the project-to-date component of the "PAR File."
This report is an update of all transactions added or deleted from the Cost-Sharing Master File. One copy of this report is produced for distribution to the institutional Research Services office.
This report is a listing of all cost-shared transactions to FOAPALs no longer on the Chart of Accounts. One copy of this report is produced for distribution to the institutional Research Services office.
This is a report of the Cost-Sharing Master File. One copy is produced for the institutional Research Services office and one for Grant and Contract Management section of the Controller's Division.
The following five PAR output reports are generated annually. Each is a result of the fiscal-year-to-date component of the "PAR File."
This report shows accumulated pay and activity for the year, providing an audit trail for each employee's reporting activity. It is produced after List 13 in two copies, one for the institutional Research Services office and one for the Grant and Contract Management section of the Controller's Division. This report also has on-request year-to-date capability.
This report summarizes employee pay and activity by FOAPAL for each organization. One copy of this report is distributed to the institutional Research Services office and one to the Grant and Contract Management section of the Controller's Division.
This report summarizes cost sharing reported on departmental accounts by Indirect Cost Class (ICC) code within the institution and shows the cost-sharing related to Research, Instruction and Other Sponsored Activities. This report is run after List 13 in two copies. Both copies are for the Grant and Contract Management section of the Controller's Division.
This report lists FOAPALs automatically deleted from the Cost-Sharing Master File. Once a year, usually around January, the Cost-Sharing Master File is run against the Chart of Accounts. If a FOAPAL is not on the Chart, it is deleted from the Cost-Sharing Files and printed out on this report. A single copy of this report is produced for the institutional Research Services office.
This fiscal-year-end report, out of the PAR subsidiary file, lists cost-shared FOAPALs by agency using the second element of the Source of Funds code. One copy is distributed to the institutional Research Services office and one to the Grant and Contract Management section of the Controller's Division.
Note: This electronic document supersedes all previous versions and is subject to change.
Contact: cdwebmaster@ous.edu
Last Updated: 11/23/96
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