Compliance

Federal Compensation Compliance

The federal government and certain other project sponsors mandate that a person in responsible charge of the project review the salary paid to each person on the project to determine if it reasonably reflects the work expended on the project. For compliance purposes, SIUE has determined that the principal investigator (PI) approved by the sponsor is the person in responsible charge and is responsible for reviewing the compliance reports.

This review is required annually and at close-out of the project. To meet this requirement, SIUE will provide a compensation report annually and at project close-out that the PI is to review. However, PIs are to monitor their project budgets and charges throughout the project period to correct errors as they arise. Failure to comply with requirements may result in personnel expenses being removed from the grant account and charged to a unit account.

Relevant SIUE policies include:  

• Overload Compensation - 1M1
• Policy Governing Sponsored Projects - 1M2
• Implementation Guidelines Concerning Research - 1M5
• Cost Sharing on Sponsored Projects - 1M8
• Review of Compensation Charged to Sponsored Projects - 1M11
• Conflicts of Interest and Commitment – 1Q9

Instructions for Reviewing Compensation Reports

The PI will receive an email similar to the one below from SIUE’s federal compensation compliance (FCC) system annually and at close-out of the project. The PI is responsible for:

• reviewing the salaries charged to the project through contracts/changes of assignment and payroll certifications
• reviewing that the corresponding payments were in accordance with effort proposed and expended on the project +/-5% through FCC
• correcting all errors in a timely manner.

View detailed instructions on using the FCC system below. You will use your SIUE e-id and password to log into the system.  You must login through the campus network using a browser other than Internet Explorer.

Detailed instructions with screenshots [pdf]

There are two views within FCC. The first, which you see when you log in, is the Account Summary.  The second, which is accessed from the Account Summary, is the detailed allocation for a single individual.  You must view each individual to create a record of your review for compliance purposes. 

View of account summary, or everyone paid from one 76 account(s):

• The date range that automatically shows in the date range field is the date range from the last time the account was run in the system. If you want to see a previous run, you can change the date range using the dropdown menu. For example, the annual run is 10/1 – 9/30, so if your account closes on 10/15, the dropdown menu after 10/15 will show 10/1 – 10/15; you can access the previous annual report using the dropdown menu.
• Click “view” to see the details regarding a person paid on the 76 account.
• Click “download CSV” to download the data shown on this page.

Allocation, one individual’s distribution of 100% effort during each pay period in the date range chosen:

You must view each individual to create a record of your review for compliance purposes.  The actual distribution is expected to be within 5% of the proposed effort on the project.  Note the following.

• The federal requirement is to review 100% of an individual’s effort.  Therefore, the percentages shown are based on the percentage of salary paid per account.
• The distribution of part-time employees, including graduate assistants (GA), is also 100%.  The distribution is 100% of their salary.  Therefore, both a 25% and 50% GA paid from one account will show as 100% on that account.  A 50% GA paid from two accounts will show as 50% on each account.  You will need to use the GA’s contract to verify that the number of hours they were contracted to work.
• If a person is listed twice, that person likely changed units during the date range chosen.  Review the “organization description” column.  If there are two units, you  need only review one of the lines as both should contain the same data.
• Redistributions can affect the percentage distribution on the pay periods in which they took effect.  For example, a change of assignment was processed in July but retroactively took effect in June.    The June, July, and August distributions may be different.
• If the distribution is changing significantly and there were no changes of assignment or University pay increase, then consider disputing the pay period so the grant accountant can determine if the cause of the discrepancy.
• The first column, “Payno,” is the pay period; it corresponds with the date range of the pay. You can correlate it with pay certifications.
• The second column, “Payid,” indicates the person being paid was staff or graduate assistant (SM), faculty (FA), student worker (ST), or part-time (BW).
• If you find an error, check the “dispute” box, write a “dispute note,” and click the red “dispute” button located at the top or the bottom of the page to save the dispute. If you want to dispute all pay periods for the same reason (e.g., the person should have been removed but the change of assignment wasn’t processed), you may dispute the first pay period and include in your note that you are disputing all periods. Note, if you do not click the dispute button, the dispute will be lost.
• Your grant accountant will contact you to ensure that the appropriate correction is executed.
• You are only able to dispute your own accounts.
• Click “download CSV” to download the data shown on this page.