Contact information for Effort Reporting Questions: 

  • 1st Contact
    Tina Lawrence
    Compliance Associate
    540.231.2113
    tinalaw@vt.edu
  • 2nd Contact
    Divya Amin
    Associate Director of Assurance and Outreach
    540.231.0950
    amind@vt.edu

Effort reporting is the mechanism used to confirm—after the end of the reporting period—salaries and wages charged to sponsored awards are reasonable in relation to the actual work performed.  The university receives funding for research and other sponsored awards through grants and contracts provided by the federal government and other sponsoring agencies. As a condition of accepting such funding, Virginia Tech must assure that the effort expended on sponsored activity justifies the salary charged to them.  Certification of an effort report (PAR) represents an employee's agreement that the salary charges shown on the report reasonably reflect the effort expended on sponsored awards and other activity for which they were compensated by Virginia Tech.  

Virginia Tech has established a Personnel Activity Report (PAR) system for reporting the percentage of time (i.e., effort) that employees devote to all extramurally sponsored programs to comply with federal regulations regarding compensation charged to federally funded awards.  These federal regulations require that institutions receiving federal funding must maintain processes, procedures and records that are supported by a system of internal controls which provide reasonable assurance that the compensation for salary, wages, and benefits charged to sponsored programs are:

  • Properly allocated.
  • Reasonable for the project.
  • Allowable under the sponsored award documents and federal regulations.
  • In conformity to the established policies and procedures of Virginia Tech.
  • Consistently applied regardless of the source of funds.
  • No more than the percentage of effort actually devoted to the sponsored award.
  • Based on a compensation rate that does not exceed 100% of the Institutional Base Salary (IBS - see OSP 10013 Institutional Base Salary for Sponsored Awards).

The university's effort reporting system (PAR) assures external sponsors that funds are properly expended for the compensation of those individuals working on the awards they sponsor. It provides the principal means for certifying that the compensation charged to sponsored projects is consistent with the effort contributed. All employees involved in certifying effort must understand that severe and substantial penalties and funding disallowances could result from inaccurate, incomplete, or untimely effort reporting.

Finally, sponsors and auditors must also be able to verify that committed cost sharing has been provided during the period of performance. The effort reporting system (PAR) is the mechanism the university uses to document effort supporting cost shared compensation expenses.

In no case can the percentage of an individual’s salary charged to a sponsored award exceed the percentage of the individual’s total effort that is expended on the award during an effort reporting period.  If the percentage of total effort expended in a given effort reporting period is less than the percentage of salary charged to the sponsored award during the period, the salary charges must be reduced to reflect actual effort.

Compensation refers to the range of wages and benefits that employees are provided in return for their work. Payments for all services provided by an employee are treated as an employee's salary and wages, which must be paid by Virginia Tech in accordance with all federal and state regulations and university policies.

IBS is the base annual compensation set by Virginia Tech for an employee whether that individual's time is spent on research, instruction, administration, or other activities. It includes salary increments, augmentations and paid overtime. It does not include extra service pay (i.e. honoraria, awards and overload payments). IBS also excludes any income that an individual earns outside of duties performed for the university. Unless there is prior approval by the federal awarding agency, charges of an employee's salary to a federal award must not exceed the proportionate share of the IBS for the period during which the faculty member worked on the award. See OSP 10013 Institutional Base Salary for Sponsored Awards.

There is no set number of hours that constitute total university effort. All hours spent on work-related university activities (even those over 40 hours per week) must be included in the effort allocation. Total university effort is all time spent in support of university activities compensated through one’s Institutional Base Salary (IBS), regardless of the number of hours that may constitute.  Effort is expressed as a percentage of the total number of hours worked by the individual and is not reflected as hours.  Effort must add up to 100% when allocated on a Personnel Activity Report (PAR).  

Examples:

  • If an employee worked an average of 50 hours per week during an effort reporting period and worked an average of 10 hours per week on a particular sponsored award, the correct effort percentage for that project would be 20% (10 hours divided by 50 total-effort hours). 
  • If an employee averaged 40 hours per week on a sponsored project and averaged 20 hours on an unrelated university project, then the employee’s effort report should show 67% effort devoted to the sponsored project (40 hours divided by 60 total-effort hours) and 33% on the unrelated university project -- regardless of the fact that the employee’s normal work week might be 40 hours.
  • If an individual who is being compensated for a 50% appointment averages 30 hours a week during the effort reporting period, 30 hours a week would represent 100% of their effort. If the same individual only averages working 20 hours in a week, then 20 hours a week represents 100% of their effort.
  • If a graduate student has a full-time appointment for a total of 20 hours per week, then averaging 5 hours a week on a sponsored project during the effort reporting period represents 25% of their effort.

It is acceptable to provide effort to the project in excess of the percent of salary charged (voluntary cost sharing).

Performing a lesser percentage of effort than the percentage of salary charged to a grant is fraudulent and is a prohibited practice.

Payroll or labor distributions are the distribution of an individual's compensation among sponsored projects and other university sources of funds. Effort reports (PARs) are an extract of all payroll system charges for a given employee during the effort reporting period, as recorded on the date the PARs were generated.  Certification of an effort report (PAR) represents an employee's agreement that the salary charges shown on the report reasonably reflect the effort expended on sponsored projects and other activity for which they were compensated by Virginia Tech.

Effort is not just a verification of the salary or payroll distribution charged to sponsored projects, committed cost-sharing effort must also be included in effort reports.

Generally, the process to complete an effort report (PAR) would consist of the following steps:

  • Gather and review lab notes and other documentation about all of your activities during the semester to determine how you spent your time on university activities – your relative percent of effort for various university activities.
  • Review the percentage of total salary charged to each sponsored project (fund) and compare it to your observations and assessment of how you spent your time.
  • Because faculty have responsibility for multiple programmatic activities supported by departmental state operating funds or recovered overhead funds, it is necessary to allocate the effort funded from these non-sponsored sources to quantify the effort by programmatic or functional activity. Review the 5 functional activity categories and their attached definitions and allocate your remaining effort among them based on your effort during the semester.
  • If additional funding changes are needed because the payroll percentages do not accurately reflect a reasonable estimate of the effort performed, then the individual should contact their business manager to initiate a retroactive funding change, sign below and/or mark the NO certification.  A new retro-PAR will be generated for final certification after the corrections have posted.
  • Once all payroll percentages are correct for sponsored projects, related cost sharing, and other activities, then the individual should sign below and/or mark the YES certification.

See Personnel Activity Reports (PARs) Instructions for further details.

Federal agencies define Changes in Status as withdrawal from a project, absence from the project for any continuous period of three (3) months or more, or twenty-five (25%) percent or greater reduction in the time devoted to the project (over the budget year) from the level approved at the time of award. During the planned period of performance, sponsoring agencies have prior notification and approval requirements for changes in Key Personnel status and/or effort. Principal Investigators (PI) receiving sponsored awards are responsible for verifying and following the sponsoring agencies’ prior notification requirements related to changes in personnel status and/or effort for all employees compensated under the PI’s sponsored award.

Example: A PI had committed 50% of total effort to a project. The PI reduced the effort by 25% (0.25*50=12.5) of the original 50% committed effort which resulted in a new committed effort of 37.5% (50.0-12.5=37.5) for the project and thus would require sponsor approval.

“Key Personnel” are the PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered key personnel if their involvement meets this definition. Consultants also may be considered key personnel if they meet this definition.

Note that simply listing a different level of effort in an agency progress report does not constitute formal agency approval for this purpose.

Certification of effort and the allocation of effort should be completed by the individual faculty, staff or student performing the effort or by the Principal Investigator (PI).  Only under exceptional circumstances, such as an employee no longer works at the university or is on extended medical leave, should a responsible official (i.e. supervisor, department head, business manager) certify effort on behalf of faculty or staff. Should this be necessary, federal regulations require that responsible officials maintain documentation of suitable means of verification that the work was performed. Generally such responsible officials will not have detailed or direct knowledge of an employee’s total work effort and should not certify the PAR unless written after-the-fact confirmation from an individual having direct knowledge of the employee’s total work effort is provided.

The university’s policy 3105: Effort Certification contains detailed information and charts describing the process.  Effort reports are issued for salaried employees (pay band 4 and above) charged at least partially to sponsored projects approximately 45 days after each completed semester, or three times per year. The schedule from the policy for Semester PARs is repeated below.  PARs are generated approximately 35 days after the end of each month for salaried employees (pay band 3 or lower) paid at least partially from sponsored funds.  PARs are issued to faculty, extension personnel, professional staff (pay band four and above) and graduate students each semester.  University personnel in pay bands three and below are required to certify direct effort receive a PAR on a monthly basis.  Certification for employees paid by the hour is accomplished through verification by the appropriate individual within TimeClock Plus, the university’s timekeeping system of record.  Employees using TimeClock Plus will not receive a PAR.

 

                         Initial Semester PARS                          Retro PARs                   Non-
Compliance
Report
Semester Regular Issued Due to OSP Retro Issued Due to OSP Issue Date
Fall February 15 March 26 April 1 April 25 May 10
Spring July 1 August 10 August 15 September 10 September 25
Summer October 1 November 10 November 15 December 10 January 5

 

 

Semester PARs are issued for all salaried employees (pay band 4 or above) charged at least partially to sponsored funds.  These include Faculty, Extension and Professional Staff, and Graduate Students.  Monthly PARs are issued for all salaried employees (pay band 3 or lower) charged at least partially to sponsored funds. Documentation and approval of hours worked for employees paid by the hour is accomplished within TimeClock Plus, the university’s timekeeping system of record.  Employees using TimeClock Plus will not receive a PAR.

Teaching, research, outreach, agricultural experiments, and administration are often inextricably intermingled, and a precise assessment of effort on sponsored awards is not always feasible or expected.  Reliance, therefore, is placed on estimates in which a reasonable degree of tolerance is appropriate. 

Most faculty generally have responsibilities for teaching, research, outreach or administration that would preclude them from devoting 100% of their time to sponsored activities. Principal Investigators (PI), department heads, faculty, and department research administrators should regularly review proposed and ongoing sponsored activity to assure that, if other activities required of the faculty member (i.e. teaching, proposal writing, committee assignments) reduce the available effort to devote to sponsored activities, adjustments are made to proposals and payroll distributions consistent with sponsor terms and conditions. 

Yes, federal regulations require that internal controls around compensation must reasonably reflect the total activity for which employees are compensated.  Column B on the effort report is where an employee would report the effort expended above the percentage of effort that was paid directly from the sponsored project, or your voluntary, uncommitted cost sharing. Please note that any salary paid in excess of the NIH salary cap is considered voluntary, committed cost sharing, which must also be certified.

Extra Service Pay (i.e. honoraria, awards, overload payments, wage faculty payments for non-credit continuing education or technical assistance programs) are typically paid as a lump sum for a short term activity and are not considered to be part of the Institutional Base Salary (IBS). However, federal regulations require that internal controls around compensation must reasonably reflect the total activity for which employees are compensated, so these activities do appear on an effort report. 

Unless the circumstances of a particular faculty member demonstrably warrant otherwise, the total effort and total salary costs of a faculty member should normally not be assigned 100% to sponsored projects in a given effort period.  Because of the numerous types of activities performed by faculty (teaching classes, serving on committees, or preparing proposals to seek new funding), in addition to actual work performed on sponsored programs, it would be unusual for faculty to have 100% of their effort charged to externally sponsored projects. All activities such as administration, teaching, mentoring graduate students, and writing proposals must be allocated a percentage of effort, and these cannot be allocated to a sponsored program.  Accordingly, unless the circumstances of a particular faculty member demonstrably warrant otherwise, the total effort and total salary costs of a faculty member should normally not be assigned to sponsored projects in a given effort period.

This is permissible only if the project is for equipment/instrumentation, dissertation and training grants, or other award intended as a “student augmentation”, and limited purpose grants such as travel and conference support.

All Principal Investigators (PI) and other Key Personnel on sponsored awards must have effort, if required, on awards.  Committed effort can be charged directly to sponsored awards or to cost sharing accounts. 

Specific to NIH awards the following clarification was published in 2003 regarding charging effort on federal awards: “…the contribution of Key Personnel [must be] "measurable" whether or not salaries are requested.  Zero percent effort and "as needed" are not acceptable for individuals that the grantee identifies as Key Personnel.” 

“Key Personnel” are the PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered key personnel if their involvement meets this definition. Consultants also may be considered key personnel if they meet this definition.

If the traveler is not providing effort to that project during that effort period, it is then dependent on the traveler's role on the project and how federal regulations must be applied:

  • If the traveler is a principal investigator or a senior researcher: Yes, the effort can be uncommitted cost sharing.
  • If the traveler is an employee with a full time (100% appointment) on another project: No. Travel expenses on a sponsored project are permitted only if the employee contributes effort to that project. The effort must be certified or cost shared to the project during the performance period and the effort period in which the travel occurs.
  • If the traveler is a student who is not an employee or a trainee: Yes. Justify the expenses according to the justification standards and include a statement that indicates that the student travel is done on a volunteer basis.

Committed effort is the amount or percentage of time an individual has communicated to the sponsor they will work on a specific sponsored project over a specified period of time.  Commitments are made in the award proposal and may be documented by the sponsor in award documents.  Changes to reduce committed effort by ±25% of the budgeted level typically require sponsor approval.

Cost sharing is any project costs that are not borne by the sponsor.  Often, cost sharing takes the form of effort; the provision of employee time and related fringe benefits that were committed and provided in support of a project but are paid for by other sources of funding. Federal regulations require that internal controls around compensation must reasonably reflect the total activity for which employees are compensated.  Column B on the effort report is where an employee would report the effort expended above the percentage of effort that was paid directly from the sponsored project, or your voluntary, uncommitted cost sharing. Please note that any salary paid in excess of the NIH salary cap is considered voluntary, committed cost sharing, which must also be certified.

Voluntary uncommitted cost sharing (VUCS) is university faculty or senior researcher effort that is over and above that which is committed and budgeted for in a sponsored agreement.  This differs from mandatory or voluntary committed cost sharing which is cost sharing specifically pledged in the proposal’s budget or award.  Federal regulations require that internal controls around compensation must reasonably reflect the total activity for which employees are compensated.  Column B on the effort report is where an employee would report the effort expended above the percentage of effort that was paid directly from the sponsored project, or your voluntary, uncommitted cost sharing. Please note that any salary paid in excess of the NIH salary cap is considered voluntary, committed cost sharing, which must also be certified.

Mandatory or voluntary committed cost sharing is cost sharing specifically pledged in the proposal’s budget or award and must be certified as effort on the associated award.  It is any project cost not borne by the sponsor (regardless of funding source) and committed by Virginia Tech for the performance of an externally funded project. Such commitments must be explicitly stated in the project budget, described in the proposal narrative, or included within the sponsor's guidelines as a commitment.  This is typically tracked in a separate fund associated with the grant/award, and it is part of the direct effort certified in column A of the effort report.

“Key Personnel” are the PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered key personnel if their involvement meets this definition. Consultants also may be considered key personnel if they meet this definition.

Financial penalties, expenditure disallowances, and harm to the university’s reputation could result from failure to provide accurate effort certifications or failure to comply with the university’s effort reporting requirements (PAR).  Certification of PARs that are known to be materially inaccurate may result in personal disciplinary actions; see OSP 10009 Mandatory Disclosure and Unallowable Costs.  Delinquent or improperly completed PARs may result in departmental penalties (e.g. transfer of salary cost from grant to departmental fund, delays in submitting grant proposals, preventing the posting of expenditures to sponsored projects, delay in the establishment of grant funds) until delinquent PARs are properly completed and delivered to the Office of Sponsored Programs (OSP). All individuals involved in the effort certification process are expected to abide strictly by the provisions of the university’s policy 3105: Effort Certification.

Marking ‘YES’ on the PAR and signing the certification statement confirms the distribution of activity represents a reasonable estimate of the effort expended by the employee during the reporting period.  Certification statements must be completed by the employee, principal investigator, or responsible official, using suitable means of verification that the work was performed

Only under exceptional circumstances, such as an employee no longer works at the university or is on extended medical leave, should a responsible official (i.e. supervisor, department head, business manager) certify effort on behalf of faculty or staff. Should this be necessary, federal regulations require that responsible officials maintain documentation of suitable means of verification that the work was performed. Generally such responsible officials will not have detailed or direct knowledge of an employee’s total work effort and should not certify the PAR unless written after-the-fact confirmation from an individual having direct knowledge of the employee’s total work effort is provided.

Marking ‘NO’ on a PAR and signing the document indicates that changes are needed to the funding distribution prior to final certification. This does not represent the final certification of effort for the period. A payroll funding change must be initiated immediately, but the PAR should still be signed and returned in a timely manner to avoid non-compliance.  A retro-PAR will be generated for final certification after the payroll changes have posted.

Any change in the payroll funding distribution for the current reporting period, subsequent to the initial PAR issuance, or funding changes to the preceding two years will generate a new PAR document (Retro-PAR).  The Retro-PARs will be issued approximately 5 days following the original deadline for the PAR completion date for that semester (April 1, August 15, and November 15).  The Retro-PAR must be certified and returned to OSP no later than 25 days after its issuance.

The Controller’s Office, in conjunction with the Office of Sponsored Programs (OSP), issues a Non-Compliance Report fifteen days following the completion of the Retro-PAR return deadlines (May 10, September 25, and January 5).  A summary Non-Compliance Report will be sent to each Senior Management with the number of uncertified PARs in each department in the senior manager’s area.  Detail Non-Compliance Reports will be sent to department heads showing individual faculty and staff who have uncertified and unreturned PARs.  (see ‘What can happen if I don't certify my effort correctly or in a timely fashion?’ above).

Before a faculty member’s separation from university employment, they should review Banner payroll salary reports for themselves and those for which they are directly responsible to assure effort has been properly charged. Necessary changes should be initiated in writing to the appropriate departmental official to provide justification for any required retroactive payroll funding changes. If the PI is transferring awards to another institution, documented verification of payroll charges and effort should be submitted to the responsible OSP Post Award Associate before the university relinquishes or transfers the award or issues a subaward to the new institution.

Faculty who receive summer salary from sponsored awards must certify to the effort expended on those projects was actually performed during the summer effort period. Effort expended during the academic year cannot be “banked” and counted toward summer effort. Academic year faculty members conducting research during summer months can be compensated by extending their salaried appointment or being paid on a summer session research appointment. Periods of vacation or university effort (meeting with graduate students, attending professional conferences, or preparing future grant proposals or coursework) should not be charged to sponsored projects whether on salaried extended appointments or summer research wages.

Faculty summer wages (P-14) should reflect work directly related to a sponsored agreement and ongoing-university responsibilities, such as working with graduate students, attending or presenting at academic professional conferences, preparing courses or new sponsored proposals or vacations.  It should be very uncommon that 100% of summer pay for a teaching and research faculty member be charged to a sponsored project. Salary charges to sponsored projects during part or all of the prior academic year will allow the appropriate mixture of institutional and sponsored funding during the summer. Salary charges should match subsequent certification of effort.

Summer session research appointments (P-14) must be finalized in Banner in accordance with the applicable pay period deadlines to assure a summer PAR is generated. Posting effort in arrears should be extremely uncommon and the extenuating circumstances documented on the P-14

Charges for work performed by faculty members with less than 12-month appointments on sponsored awards during periods not included in their base salary (i.e. summer) will be at a rate not in excess of the IBS.

Faculty on academic year (9 month) appointments are permitted to earn up to three months of additional salary for effort related to sponsored projects, subject to sponsor policies and appropriate internal approvals.  Policy No. 6200 “Research Extended Appointments” outlines the requirements and procedures for faculty members to extend their 9 month appointments to 10, 11, or 12 months depending on the availability of sponsored funding for additional months of salary and full fringe benefits.  Although the sponsored funding supports the extended employment contract, salary must be charged to reflect actual effort throughout the entire appointment period, not just the summer. Given the continuation of some typical university responsibilities during the summer, such as meeting with graduate students, attending professional conferences, or preparing future grant proposals or coursework, faculty members should have a mixture of sponsored and institutional funding to support their summer activities.  This can be accomplished by making appropriate charges to the project during the academic year, or deferring some institutional funding to the summer period. Faculty members can meet the test of adequate sponsored funding to support their extended appointments any time during the prior 12-month academic year (August 10 through August 9).

Research faculty and postdoctoral associates with a twelve-month appointment are often supported entirely by sponsor funds, with no explicit delineation between summer and academic year effort.  If no university funds are available to support their effort, voluntary committed cost sharing of salary is not possible for those individuals.  Research faculty who are engaged in non-sponsor funded activities, including preparation of future or continuation proposals, meeting with or mentoring graduate students, or attending professional conferences must have departmental funding to support these activities not directly related to their specific sponsored awards, as all their effort cannot be certified as direct effort on sponsored projects.

If an individual devoted some percent of effort to a sponsored award and no effort report (PAR) was received, the PI should immediately notify the departmental business office research the reason no PAR was received.  If the compensation funding was charged improperly, the PI should work with the departmental business office to assure that payroll funding changes are entered into the Banner Labor Redistribution system to generate a retro PAR.

Certain sponsors such as the NIH, (see http://grants.nih.gov/grants/policy/salcap_summary.htm) impose a limit or “cap” on the annual rate of salary reimbursement for a given amount of effort.  Similarly, certain sponsors may limit the amount of salary that can be requested from a specific program; these programs, notably NIH Career Development Awards, may also carry minimum effort requirements. These salary limitations constitute voluntary, committed cost sharing.

The PI and other key personnel must still devote the amount of effort agreed upon irrespective of a sponsor imposed salary cap or program limitation.

Note:  The National Science Foundation (NSF) normally limits salary compensation for senior project personnel on awards made by NSF, to no more than two months of their regular salary in any one year, Virginia Tech defines “any one year” as within an academic year, August 10 to August 9.  This limit includes salary received from all NSF funded grants and NSF flow-through subawards. Salary is to be paid at a monthly rate not in excess of the Institutional Base Salary (IBS) divided by the number of months in the period for which the base salary is paid. As such, proposal budgets submitted to NSF should generally not include funding for an individual investigator or co-principal investigator which exceeds two months of their regular year salary. If additional funding is needed to accomplish the proposed statement of work, any compensation for such personnel in excess of two months must be disclosed in the proposal budget, justified in the budget justification, and must be specifically approved by NSF in the award notice.  The institutional re-budgeting authority extended by NSF does not empower the university to exceed the two month limitation without prior written approval from NSF.

Federal Auditors are looking for patterns that suggest that an effort certification (PAR) is formulated by factors other than actual effort on the project. 

  • What are some examples of those patterns Auditors are looking for?
    • Patterns of retroactive adjustments to effort certifications or retroactive cost transfers. (Do these have a reasonable justification or do they appear to be motivated by desire to “spend down”, transfer unused grant funds, or resolve deficits on other unrelated awards?)

    • Very small effort percentages on many grants.  (Real research project contribution or just salary support?)

    • Research effort certifications that appear not to include accounting for actual administrative and/or teaching and/or outreach effort as part of total effort. (If you certify research effort for your research grants totaling 95% that leaves only 5% for all other work performances – teaching, clinical, administrative. If you are teaching two classes that each meet for three hours a week, classroom time alone equals six hours per week. For 6 hours to be 5% or less of your total effort – leaving at least 95% for your 95% research effort certifications – you need to be prepared to document the claim that your workweek is 120 hours or more.)

      The Faculty Handbook, Section 9.1 “Assignment of Academic Responsibilities”, states that “the usual load for those engaged only in teaching is 12 didactic hours.”  This load would include time for recruiting, committee assignments and routine administrative activities. “A didactic hour is defined… as one contact hour in a lecture course or 0.60 hour for each contact hour in a course designated as a laboratory course.” Loads are “usually adjusted to permit time for other scholarly activities.”  By extrapolation, a faculty member carrying a teaching load of 9 didactic credit hours would have approximately 25% of their effort remaining to allocate to research, proposal writing, etc. 

       
  • What if one or more of these patterns exist in my effort reporting, but are legitimate reflections of my actual effort?
    • Maintain documentation that supports your research contribution – in research content and in time/percentage of effort (calendars, correspondence, work products, etc.)

    • A request for retroactive adjustment to an effort certification that exceeds 90 days or is processed for a previous effort reporting period requires additional  written justification on the payroll funding change subject to the review and approval of the Office of Sponsored Programs (OSP).  See the university’s policy 3255: Cost Transfers on Sponsored Projects.