Colleagues,
If you have grants or contracts supporting any employees who have been on strike for any amount of time this semester, please read the following excerpt from guidance we received from UCOP yesterday:
1. Effort Reporting
The University can only charge wages to a federal award under 2 C.F.R. 200 if the federal
awarding agency receives commensurate benefits from the wages charged.1 Hence,
campuses need to take steps now to ensure that only wages (and associated fringe
benefits), tuition, and fees for work performed by Graduate Student Researchers or faculty
in support of a grant are charged to that grant, and that either effort reports or payroll
certifications (as applicable to each campus) are accurate. If campuses are unsure whether
work was performed on a grant by a Graduate Student Researcher or faculty member, they
should make or move charges (wages, tuition, and fees) for that work on an unrestricted
account until the PI (or authorized person) can verify the underlying work and confirm
accurate effort reports or accurately certify payroll. PIs who have first-hand knowledge
that work was performed on the grant do not need to move those charges off the grant.
Shifting funds does not impact pay; it only changes what university account is charged for
the expense.
Campuses are responsible for identifying unrestricted accounts. For example, campuses
could identify a university-level unrestricted account for this purpose. As appropriate,
charges can be shifted back to the grant once additional information is obtained regarding
the performance of work or, if allowed, once the work is made up.
While this guidance applies to Federal grants and contracts, we expect similar guidance regarding state-funded research.
Our Finance office has created a process to exclude expenditures related to the salaries and wages of individual researchers employed in the bargaining units impacted by the strike from Federal and State grants. Expenditures charged against these grants since the beginning of the strike period (November 14th, 2022) will not be billed to any of our sponsor agencies unless, at a later time, those expenditures are found to be valid. UC Merced will move these expenditures to unrestricted funds and the appropriate related expense accounts to cover the pay of these researchers. We do not yet know the mechanisms the UC will use to withhold pay (or not). We are still awaiting guidance from UCOP about the possibility of making up work that was missed during the strike and how that might be reported. What we do know is that federal law requires you to report effort accurately. At this point, we ask you to do no more than keep the best records you can about the work your employees have done.
We will provide further guidance as it becomes available.
The attached FAQs document was also distributed.
