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University Policy 27

Personnel Activity Reporting System

Formerly Executive Memorandum 83-65
Initially approved February 15, 1983
Revised January 22, 2001
Revised:  February 25, 2019

Policy Topic:  Business Administration and Auxiliary Services; Research and Sponsored Activities
Administering Office: Office of Research Administration


The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) issued by the U.S. Office of Management and Budget, sets forth the principles that determine allowable costs for work performed by colleges and universities under contracts, grants, and other forms of sponsored agreements. These principles govern the charges that may be made to sponsored agreements, financial administration of sponsored agreements, and the documentation that must be maintained for Federal audit of allowable costs.

Contracts and grants at Western Carolina University are administered in accordance with the provisions of 2 CFR 200.


“Sponsored Agreement” is defined as externally funded activities in which a formal written agreement, i.e., a grant, contract, or cooperative agreement, is entered into by WCU and by a sponsor.

“Cost Share” is defined as the portion of a total sponsored project’s costs that are paid by WCU, rather than by the sponsor. Cost sharing of direct expenditures represents a redirection of departmental or institutional resources to support sponsored research activities. When a sponsored agreement includes cost share, it becomes a binding commitment that WCU must provide.

“Payroll Verification” is defined as a methodology to document that payroll distributions to sponsored agreements are accurate through an after-the-fact review by the principal investigator.

“Institutional Base Salary” is defined as an annual compensation paid for an individual’s appointment whether that individual’s time is spent on research, teaching, administration, or other activities.


2 CFR 200.430 - Compensation, stipulates that, when personnel costs are charged to a sponsored agreement or contributed as cost-sharing, they must be supported by a report of personnel activity which verifies (a) that the costs charged are actual, (b) that the work was performed, and (c) that the distribution of activity represents a reasonable estimate of work performed. The principal features of the personnel activity reporting system at Western Carolina University are these:

  1. The Payroll Verification Report documents the Principal Investigator’s after-the-fact review to confirm the payroll charges for the work performed on a project does not exceed their proportionate share of their institutional base salary. This action confirms that the final amount charged to the sponsor is accurate. University cost-sharing in sponsored agreements must also be documented in the payroll verification report, but is not reflected in the payroll.
  2. Each employee who is paid wholly or in part from a sponsored agreement or whose effort is pledged for cost-sharing in a sponsored agreement will report a distribution of activity that accounts for 100% of the activities covered by his/her institutional base salary. The percent of effort associated with each sponsored agreement, each cost-sharing commitment, and other University duties must be separately identified by account name and number.
  3. Employees engaged in sponsored agreements must complete payroll verification reports on a minimum schedule of once each academic term.


  1. The Payroll Verification Report form will be distributed to each affected employee by the Office of Research Administration. When issued, the report form will reflect payroll allocation for one or more sponsored agreements and for other University duties.
  2. The Payroll Verification Report form is to be reviewed by the employee and/or accountable officer, revised if necessary, and endorsed by the accountable officer for each sponsored activity.
  3. Payroll Verification Reports will be made at the end of each semester on the following schedule, and must be returned within 8-weeks of distribution:

January 1 – May 31: Distributed by June 30

June 1- August 31: Distributed by September 30

September 1 – December 31: Distributed by January 31.

  1. The completed Payroll Verification Reports will be returned to and maintained by the Office of Research Administration.
  2. The percentage of an employee's effort that is pledged to a sponsored agreement and the percentage of their compensation charged to that agreement must not be significantly dissimilar.


This policy will be reviewed every 2-4 years and revised as necessary.


2 CFR 200: OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards:

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