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Compensation – Personal services (2 CFR 200.430 )

For Institutes of Higher Education (IHEs), 2 CFR 200.430(i)(1)(x) recognizes that a precise assessment of factors that contribute to costs is therefore not always feasible, nor is it expected. ASU utilizes the several internal controls to ensure payroll charged to sponsored accounts are reasonable and allowable.

  • Offer letter documenting title/role on project
  • Institutional base salary (IBS) based upon initial time split estimate is applied to project accounts (sponsored and non-sponsored) via % in the PeopleSoft HRIS payroll system. (2 CFR 200.430(i)(1)(ix))
  • Timesheets are submitted by the worker and reviewed/approved by the supervisor in the PeopleSoft system. The Department Time Administrator (DTA) is responsible for the final electronic submission of timesheets and the maintenance of the associated time reporting records. Note that 2 CFR 200.430(i) does not require time tracking.
    • Non-exempt employees will enter hours worked over the biweekly pay period by using an electronic timesheet.
    • Exempt employees report only paid leave over the biweekly pay period on the electronic timesheet.
  • Regular reconciliations of payroll and discussions with Principal Investigator (PI) to confirm reasonability and if adjustments are needed to the existing payroll distribution.
    • Changes to correct errors or make adjustments to better reflect work performed on the grant are made via the cost transfer payroll redistribution process in PeopleSoft. Departments initiate and approve the transaction which is then routed to the central Post Award Services (PAS) team for review and final approval.
  • For federally-funded awards, ASU’s After-The-Fact Review Report complements the PeopleSoft payroll system, ensuring compliance with the effort certification requirements of 2 CFR part 200 subpart E §200.430.
    • An after-the-fact report is system-generated after the end of each semester (fall, spring & summer) with a detailed list of pay by worker/period posted to each award. The lead PI for the award receives the report and has a final opportunity to review reasonability of pay. Any corrections approved via the payroll redistribution process described above are reflected on the report. The PI’s acknowledgement of the report is time-stamped.

UG recognizes special considerations and possible limitations when determining allowable personnel compensation costs on a federal award for Institutes of Higher Education (IHEs).

Compensation – Fringe benefits

Property management

ASU’s Capital Asset Management (CAM) team is responsible for ensuring that all ASU capital assets are appropriately tracked, safeguarded and accounted. See their website for additional information:

ASU’s Cognizant auditing agency: Office of Naval Research

Procurement (2 CFR 200.318)

Competition (2 CFR 200.319)

ASU’s policy for maximum practical competition (PUR 108-01) requires that ABOR’s policy be followed, which states:

“All specifications…shall seek to promote overall economy for the purposes intended, encourage competition in satisfying the University’s needs, and shall not be unduly restrictive.”

ABOR Policy Manual 3-805.B.1
Procurement methods (2 CFR 200.320)


Small purchases

Sealed bids & formal advertising

Affirmative contracting steps (2 CFR 200.321)
Sole source
Conflict of interest

PUR 108-02 requires that ABOR’s policy be followed, which states:

No person preparing or assisting in the preparation of specifications, plans, or scopes of work shall receive any direct benefit from the utilization of those specification, plans, or scopes of work.

ABOR Policy 3-805.C.1

Exception criteria is contained within both policies.

Loaned equipment
Handling lost or stolen equipment

Federal payment (2 CFR 200.305)

Draws are initiated in ASU’s financial system using the “Create Invoices for Cost Reimbursable Award Transactions” to generate an invoice for unbilled expenses. Once completed, the Workday task “Record Letter of Credit Drawdown” is run, grouping generated invoices into one request per letter of credit account. This request is then routed through several steps to ensure strong internal controls:

  • Approve Letter of Credit Drawdown Event: Post Award Services (PAS) Manager/Lead role
  • Complete LOC-Request Draw in Sponsor Portal: PAS Initiator
  • Attach Draw Confirmation to SharePoint: PAS Initiator
  • Review attached draw confirmation in SharePoint: PAS Manager/Lead role
  • Identify payment in Cashpro to initiate payment application steps: Cash Management Specialist
  • Record amount received for letter of credit drawn down: Cash Management Specialist
  • Approval by Accountant – ASU Treasury

Procedures: Job Aid – Letter of Credit Draw Downs

Program Income (2 CFR 200.307)

ASU has experience managing both additive and deductive program income. Comprehensive published guidance for handling program income is found here:

Financial reporting


2 CFR 200.344

Clearing overruns (deficits) and disallowed costs
Fixed Price Agreements