University of Puerto Rico: Unreconciled Payroll Estimates in Federal Grant Charges

The University of Puerto Rico paid $1,772,790 to settle allegations involving unreconciled payroll estimates in federal grant charges. The U.S. Attorney’s Office alleged that the university certified compliance with grant rules while its records failed to reconcile the budget amounts reported to its federal funders. If you work with research payroll, effort reports or grant accounts, that gap between the certification and the accounting is the part of this case you may recognize.

The Payroll Behind the Grant Charges

The University of Puerto Rico payroll allegations concerned salaries and wages charged to grants for calendar 2011. The funders were the National Aeronautics and Space Administration, the Department of Energy and the National Science Foundation. The government alleged that the university failed to meet the time-and-effort reporting requirements intended to ensure that payroll was correctly charged to those grants.

The payroll estimates at issue were the budget amounts reported to the grant funders. Those amounts needed support from time-and-effort records for the salaries charged. The government alleged that the university certified compliance with grant rules while its records failed to reconcile those amounts.

We see the contradiction in the government’s allegation: paperwork asserting compliance, numbers that did not reconcile. A certification cannot do the work of the accounting behind it.

For a grant administrator, that is a specific accounting problem: how the institution supported the salary costs assigned to each award. For a researcher, it is a question about the work those charges represented.

Columbia and Scripps Show the Work Behind the Charge

Columbia University admitted that certain effort reports were inaccurate and that its ICAP program charged federal grants for work outside those agreements. At the Scripps Research Institute, the whistleblower’s complaint alleged that effort-report forms came with total hours already printed. For the University of Puerto Rico, the reconciliation question is whether time-and-effort records supported the budget amounts reported to its funders.

Grant Payroll Settlements and Whistleblower Rewards

The United States recovered the University of Puerto Rico settlement payment in November 2018.

A whistleblower reward is a share of a recovery paid to the person who brings the case. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

What Proof Do You Need as a Whistleblower?

For a grant-payroll case, useful proof connects the work performed, the salary charged to an award and the representation made to the funding agency. We examine the records behind the charge with the person who understands how the institution used them.

For an allegation like the one at the University of Puerto Rico, that means comparing the reported budget amounts with the payroll and time-and-effort records supporting the same grants. The certifications matter because they tell us what the institution represented about those records. The accounting matters because it tells us how salary costs reached the award.

Your role may give you a view into one part of that chain. A researcher may know that time charged to an existing award went into a new proposal. A payroll employee may understand the account codes. A grant administrator may know how an effort report became a certification to an agency. We bring those perspectives together to understand the charge and the decisions behind it.

Your knowledge can connect a salary entry to a decision that a person outside the institution would otherwise miss.

NASA, DOE and NSF Investigated Together

The offices of inspector general at NASA, the Department of Energy and the National Science Foundation jointly investigated the University of Puerto Rico matter. The U.S. Attorney’s Office for the District of Puerto Rico handled the civil case. The Department of Energy’s acting inspector general described the joint investigation as protecting the government from inflated claims.

The 2022 chapter The Federal Inspectors General, in Ethical Standards in the Public Sector, distinguishes audits of a program’s financial management from investigations of specific allegations. Investigators examine files, reports and internal memoranda alongside interviews with witnesses and technical experts.

The report shows an allocation. You may know why it is there. The person who prepared it, approved it or performed the work can explain the process behind it. In a case about unreconciled grant payroll, that explanation can connect the accounting to what the funder was told.

When the Grant Accounts Do Not Match the Work

If you know why salary charges, effort reports and grant certifications tell different stories, speak with our whistleblower experts about the work and the award. We build your strongest grant payroll whistleblower case with you and bring in grant fraud whistleblower lawyers who understand research funding and effort reporting. You bring your knowledge of the institution, and we stay beside you through the case.