Re: Annual Leave Howard M. Kaplan 18 Nov 1998 13:54 EST
A caveat. Any use-or-lose annual leave policy for personnel on federally sponsored agreements will have to take into account the "Compensation for personal services" section of OMB Circular No. A-21 (revised): "Compensation for personal services...include salaries, wages, and fringe benefits (see subsection f). These costs are allowable to the extent that the total compensation to individual employees conforms to the established policies of the institution, CONSISTENTLY APPLIED...." [emphasis added] The caveat recently was underscored for our institution. We received the following interpretation of the Circular's "consistency requirements" from one federal agency's Division of Cost Allocation: "Consistent organizational treatment of cost is a fundamental tenet and basic consideration (section C.2) affecting allowability of cost on Sponsored Agreements. In addition, Appendix A of this Circular requires compliance with four Cost Accounting Standards. Since two Standards involve consistency concepts, it is quite clear that OMB considers uniform cost accounting policy and procedures to be of paramount importance. ... (A) proposed policy (that) REQUIRES [emphasis in original] just those employees working on Sponsored Agreements (rather than all University employees) to take 'forced' vacation time so there are no accrued leave balances at completion of a Sponsored Agreement...seems to violate both consistency standards because it: (1) Is too exclusive and restrictive -- only certain (not all) employees are subject to this policy; and (2) Discriminates against the Federal Government -- artificially inflates direct cost ONLY [emphasis in original] on Sponsored Agreements by requiring this 'forced' vacation time off. ... Accordingly, we believe that implementation of (such a) proposed policy would produce cost disallowances for any 'forced vacation' claims (plus appropriate interest charges)." The operating systems for Sponsored agreement policies get curiouser and curiouser. Howie Kaplan At 11:04 AM 11/18/98 -0600, you wrote: >We are considering establishing a University policy requiring all >employees funded through grants to use, or lose their annual leave by >the end of each grant year. State-funded employees may be paid for up >to 300 hours of accrued annual leave when they terminate their >employment. At the present time annual leave is not factored into our >fringe calculation. Does anyone have a policy like this at their >institution? Thanks. > >John Cavendish, Director >Sponsored Research and Contracts >Southeastern Louisiana University > >>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>> Howard M. Kaplan, Director Research Services & Sponsored Programs Georgia Southern University P.O. Box 8005, Highway 301 So. Building Statesboro, GA 30460-8005 Tel. 912-681-5465; FAX. 912-681-0719; e-mail. xxxxxx@gasou.edu <<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<<