Research and Sponsored Projects Manual (RSP)

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Effective: 2/26/1979

Revised: 3/1/2022

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RSP 502–03: After-the-Fact Review and Acknowledgement of Personnel Costs

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Purpose

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To outline the process for review and acknowledgement of personnel costs for university employees paid from, or with cost sharing committed to, sponsored projects

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Sources

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U.S. Code of Federal Regulations 2 CFR 200.430(i)(1)(viii)(C)
Office for Research and Sponsored Projects Administration (ORSPA)

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Policy

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The After-the-Fact Review Report is ASU’s system developed to meet the requirements of compensation review in 2 CFR 200.430(i) Standards for Documentation of Personnel Expenses which states that:

  • Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed.
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  • Budget estimates (i.e., estimates determined before the services are performed) alone do not qualify as support for charges to Federal awards, but may be used for interim accounting purposes, provided that:
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    • The non-Federal entity’s system of internal controls includes processes to review after-the-fact interim charges made to Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated.
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    • This report, in combination with ASU’s existing strong internal control system, provides an easy-to-understand, intuitive means for ensuring compliance with OMB requirements.
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    • An email notification to prompt periodic review and acknowledgement of interim charges by Principal Investigators is issued following the final pay period of each academic period: spring semester, summer term and fall semester.
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    • After-the-Fact Review Reports are based on compensation. In a single view, the Principal Investigator is able to review and acknowledge that all personnel charges for a sponsored project are accurate, allowable, allocable, and reasonable for the work performed. Any corrections that are needed are made through the standard PeopleSoft payroll distribution process. Upon completion of the redistribution process, the PI acknowledges all personnel expenses are correct. The system creates and maintains a record of acknowledgement for audit purposes to demonstrate compliance with 2 CFR 200.430(i)(1)(viii)(C).

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Cross-References

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For authoritative references, see RSP 101, “General Research Policy.”

For further information, see:

  1. RSP 502–01, “Personnel Employed on Sponsored Projects”

    and

  2. RSP 506–03, “Cost Sharing Documentation for Sponsored Projects.”

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