Cap cost sharing can contribute toward fulfilling the direct charged effort commitment on a K Award. The sum of the direct charged salary, salary cap cost sharing and K Award cost share should equal the 75% commitment of effort.
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Salary Cap and K Awards
Salary charged to a K Award may not be sufficient to fund the 9 person months effort required by the K Award. Supplementation provides funding for that portion of the 75% effort requirement not paid for by the award. The University may 'supplement' the K Award salary with other institutional funds however, supplementation may not be from other federal funds unless specifically authorized by the federal program from which such funds are derived. In no case may additional PHS funds beyond those provided in the K award be used for salary supplementation. The PI may be paid on other federal awards for the remaining 25% effort.
The question of whether or not Federal support can be used for salary above the K award effort may actually depend on the particular K award. Some K awards actually require other NIH support. Others imply that since the K award experience is considered full-time there is no room for Federal funded activities outside of the K award activities. However, in most cases, if only 75% effort is devoted to the K award, the remaining 25% can be devoted to other projects as long as they are K related and contribute to the K award experience.
The eFECS system utilizes budget profile attributes associated with each budget to determine what FECs and budgets on each FEC are subject to the DHHS salary cap. Once determined, the salary cap cost sharing is then calculated using a combination of the salary dollars and percent distribution directly charged to the budget subject to the salary cap and the effective salary cap threshold. It is critical to note that this calculation is based on the assumption the department has adjusted the directly charged salary to the capped amount.
If the non DHHS sponsor applies the DHHS salary cap then eFECS utilizes the same process above. However, if the non DHHS sponsor charges a unique salary cap amount, i.e., has a different threshold, eFECS does not calculate the amount of the salary cap cost sharing but does place an indicator next to the impacted budget on the FEC to alert the department that they need to make the calculation and manually adjust the salary cap cost sharing prior to the FEC being certified.
First, please check if you can follow the detailed steps of adding cost share: How to Add K Award Cost Share to the FEC | Management Accounting & Analysis (uw.edu)
If budget is not identified as K award, please look up the Grant Contract number using the Budget Profile Report on MyFD. For budgets to be recognized as a K-Award budget, the grant contract number for the specific biennium (currently, 2021), must have a K award recognized 3 characters value, within the substring of the 3rd through 5th characters. K Award budgets - eFECS displays a K award type when the faculty has pay on a budget where the third, fourth and fifth places in the Grant Contract number field in match: K01,K02,K05, K07, K08,K12, K18, K22, K23, K24,K25, K26, K30, K43, K76, K99, KL2. If this is the reason, GCA (firstname.lastname@example.org) could be contacted to update grant contract number.
If budget is NIH Subaward, because of grant contract number NIH provides, FEC coordinator would need to select “ Short- Term shift” as cost share type instead of “ K-award (K)” on the draw down selection when adding cost share.
Effort Policy Questions
Charging and certifying salaries that are not properly supported could lead to audit findings, disallowances, fines, suspension and debarment, as well as other sanctions at the institutional and/or individual level.
For effort certification purposes, University of Washington activities whose inclusion in or exclusion from total effort would not, in the aggregate, affect the percentages of effort allocated to sponsored activity, and therefore do not require separate tracking and funding.
A faculty work week is composed of the average number of hours a faculty member normally works during a week. Hours are to be averaged over the effort reporting period. For many faculty members, this number will vary from one week to another; there is not a standard 40-hour work week for faculty.
Example: If, within a six-month cycle, a faculty member worked thirteen 60-hour weeks and thirteen 40-hour weeks, his/her average work week would be 50 hours. Hours are averaged over the six-month effort reporting cycle.
Faculty are not required to keep track of hours on a daily or even weekly basis. They are, however, expected to estimate, as a percentage of their total compensated (IBS) effort, that what they do on an average per week, regardless of the actual number of hours worked, days of the week or hours of the day, over the reporting period is reasonably reflected on their FEC report. This allows them to certify in good faith that their effort compensated on a sponsored project is reasonable.
This other 20% time is considered “non-sponsored” time. Salary support from non-sponsored funds may be used for activities such as teaching, administration, service, clinical activity, institutional governance and preparing new and competing renewal proposals. In addition, it may be used to fund cost shared effort commitments, i.e., effort devoted toward a sponsored project that is charged to other UW non-grant sources.
Unlike time spent preparing new and competing renewal grant proposals, the time spent on non-competing proposals, supplements and extensions involves reporting work on the existing grant period and therefore does not require non-sponsored funding.
The UW’s effort certification guidelines are based on federal Uniform Guidance, 2CFR 200.430. These regulations pertain to faculty whose salary is funded in any part with federal sponsored funds. The guidelines do not apply to faculty with salary supported only with non-federal sponsored funds. Faculty should follow the non-federal sponsor’s policy, if any.
There are limited options when this occurs. One option is to identify an alternative funding source such as a gift budget to cover the cost. Also, in consultation with and concurrence from the unit head, if the faculty is involved in multiple scholarly (non-sponsored) activities, he/she could examine the possibility of rebalancing those efforts to allow time for proposal preparation or reducing time spent on some non-sponsored activities.
Another potential option is associated with Faculty Reduced Responsibility (RR) Status (GIM 38). This option, which includes the option to volunteer time for scholarly activity including proposal writing, is only available for faculty who have temporarily reduced their institutional responsibilities commensurate with a reduction in the amount of their institutional base salary (IBS) resulting from a loss in external funding. The faculty member must be on approved RR status to utilize this option.
Institutional base salary (IBS) is the annual compensation, including A/B salary as it relates to tenured faculty, paid by the University of Washington for an employee’s appointment, whether that individual’s time is spent on research, instruction, administration, service or clinical activity. IBS excludes any income that an individual is permitted to earn outside of duties for the University of Washington.
The components of IBS are base salary (regular salary, summer salary, paid professional leave and salary for retired faculty); administrative supplements (ADS); endowed supplements (ENS); and clinical salary (UW Physicians (UWP) and Children’s University Medical Group (CUMG)). Note, clinical incentive salaries are excluded from IBS.
It is a federal requirement that all salaries charged either directly to a federally funded sponsored agreement and/or to non-sponsored sources for the fulfillment of a cost-share commitment being met via faculty effort not charged directly to the sponsored agreement, be supported by records that provide assurance that the charges reasonably reflect the work performed. The UW meets these requirements via the faculty effort certification reports (FECs).
FECs are semi-annual reports designed to meet the federal requirements described above. Thus, a faculty member will receive, and must complete, an FEC if he or she is paid by the University of Washington and
- Performs effort paid on federal and/or nonfederal sponsored projects; and/or
- Performs cost-sharing on federal and/or nonfederal sponsored projects.
Yes. Time spent preparing new and competing renewal grant proposals represents an official University activity normally covered under one’s institutional base salary using non-sponsored funding in an amount proportionate to one’s total FTE. Note, see the Reduced Responsibility FAQ section for exceptions.
The purpose of the FEC is to certify that the compensation (institutional base salary) charged to each sponsored agreement is reasonable in relation to all other compensated UW activities. Thus, faculty completing FECs must take into consideration research, instruction, administration, service and clinical activity (excludes clinical incentive payments). See GIM 35.
While technically a federal requirement, the UW presently requires this certification for all sponsored agreements regardless of funding source.
The federal government requires that charges to federal awards for salaries and wages be based on records that represent a reasonable approximation of the work performed on those federal awards relative to the total activity for which the University compensates the faculty member. As part of meeting this requirement, faculty review and certify their effort.
This most commonly occurs when there is original pay and a salary transfer on the same budget. Expanding the budget detail will reveal both the positive and the negative salary transactions.
The federal government requires that effort reports reflect 100% of the faculty members' compensated effort. The change to the FEC to reflect 100% alleviates auditing challenges with federal regulations. Faculty whose Average Paid FTE during a reporting cycle does not equal a 1.0 equivalent Workday salary rate will fall into the above scenario. The averaged IBS value ($) associated with the Average Paid FTE, is then represented as 100% of the faculty member's IBS for the FEC cycle.
The eFECS system will not return a name for individuals who are not required to certify. For example, if the individual does not have a qualifying faculty job code, is not paid on a sponsored project and/or does not have a formal cost share commitment set up in the Cost Share Module, they will not have an FEC and the search box will return the error message above. Separated faculty will continue to appear on the MyFaculty List, but will not appear in the Search box.
Yes click the "+" next to any budget number on the online FEC to view detailed salary information by pay period along with the IBS eligible earn type.
If the OSET is completed before the faculty member certifies the FEC, eFECS will reflect the salary transfer on the online FEC, normally one business day after it posts in the financial system. If the FEC has been certified any post-certification salary transfer, including a transfer that adds a new budget line, will be reflected on the View FEC with post-certification changes for recertification analysis screen (accessible through the link at the bottom left of the FEC).
Notifications are dependent upon the email address that is listed in Workday. If there is no email address listed, eFECS substitutes the faculty member's UWNet ID @ uw.edu and sends notifications to that email address. Login to myuw.washington.edu to ensure forwarding has been selected if the faculty member's email address is anything other than his/her UWNet ID @ uw.edu.
Once an FEC is certified, no changes can be made to the original report. There is, however, a Post Certification view that assists departments in recertifying. This view will display changes that occurred after the FEC was certified. Click on the link “View FEC with post certification changes” for recertification analysis located at the bottom of the FEC.
Once the department completes the online recertification, the new recertified FEC is now the official FEC. Status of this FEC will show "Recertified". FEC coordinators can still navigate to the originally certified FEC by following the link in the bottom left.
If an award is only active for part of the FEC period being reported, the system will prorate the effort. For example: The FEC reporting cycle is 1/1/XX-6/30/XX. The award period ends 2/28/XX and the faculty member provided 20% effort on the award from 1/1/XX - 2/28/XX. The FEC will spread the 20% over the entire FEC cycle thus reducing the effort percent for the quarter to 6.7%.
There is provision for the Chair, Dean, Director or Division Head to certify on a faculty member’s behalf. To do this the department Astra authorizer must assign the ASTRA role “Certify Others” to the Chair, Dean, Director or Division Head. Once this is done they can now enter the name of the faculty they are certifying for in the Search box.
These individuals must have suitable means to confirm the work was completed such as direct supervision or an email from the separated faculty confirming the accuracy of the FEC.
No. All roles in eFECS are set up and removed by the department's ASTRA authorizer.
No, FEC's become available for online viewing after payroll transactions for the final pay period in the FEC cycle have posted or approximately 23 days after the end of the cycle. For mid-cycle reporting of cost sharing, use the Interim Cost Share Report process.
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Yes, the relationship between the amount of effort charged directly to the grant and the amount cost shared is secondary to the PI meeting the combined (total) percent of his/her committed effort.
If the cost share is committed based on percent effort, and necessary approvals have been obtained (e.g., reduction of 25% or more) the reduction need not be prorated between the direct charged and cost shared effort commitment. It is critical however, that the total adjusted commitment be met which could be via direct salary charges only, cost share only or a combination of both. If the cost share is mandatory, i.e., dollar based, specific approval from the sponsor is required unless other sources of cost sharing are permissible and substituted.
Changes can only be made to certified cost share by the faculty member recertifying the FEC. To accomplish, this contact GCA via Grant Tracker for requested changes to pledges. The faculty member should not recertify the FEC until the requested changes have been processed and appear in eFECS. Contact email@example.com for recertification questions.
Cost-share commitments may arise when the proposal reflects a level of effort devoted to the sponsored project that is greater than the funding allocated for the commitment (e.g., 15% effort commitment but only 10% funding requested). They also may arise when the faculty member’s salary exceeds a sponsor’s limitation on the amount of salary that can be reimbursed, as in the case of salary caps imposed by the National Institutes of Health
Cost shared effort, as well as effort paid directly from the grant, is averaged over the FEC cycle for faculty reporting on both academic and calendar cycles. This may result in a percentage appearing on the FEC that is less than the committed amount. For example, if the grant was only active for half of the cycle, a 10% percent commitment will appear as 5% on the FEC. For faculty on an academic cycle, eFECS will identify if the commitment is for spring and upload the full 10% (the un-averaged percent) to the spring quarter in the Cost Share Module.
This message indicates that cost share adjustments have been manually entered to reflect the actual effort performed. Click 'View Details' link, to review the cost share adjustments made. Before certification, cost share effort percentage may be adjusted using the 'Adjust/View Cost Share' button. If the 'Adjust/View' button is not available, contact the department's ASTRA authorizer to request the 'View and Update Effort Report' role.
Yes, with the following caveat. Regardless of whether the cost sharing is percent effort or dollars, if there is a specific commitment of effort by the PI or other key personnel, and the re-budgeting is caused by or results in a significant reduction (i.e. 25% or more) of that commitment, prior approval from the sponsor for this change needs to be obtained. Additionally, significant adjustments between effort and non-effort categories may imply a scope change. If this is the case, the sponsor must be contacted to approve the change.
First, for budget, please check if the budget is active sponsored budget and includes qualified transactions - non-faculty salaries. For person, please check if the person is non-faculty and has qualified IBS (institutional Base Salary) Components of Institutional Base Salary | Management Accounting & Analysis (uw.edu).
Sometimes, specific budget or person is under different org code or different Principal Investigator. Please try selecting all on drop down selections for Org Major Area Level, Org Dept Level and Org SubDivision Level and/or Principal Investigators.
For postdoc budget/individual missing:
Because the postdoc’s effort will show up on the GCCR if they are paid in a salary/wage object code, but not if they are paid under stipend object code. One possible reason this individual or budget isn’t showing up on the GCCR (they would never show up on a FEC since they aren’t faculty), is that the postdoc was paid under 01-50, 01-90 or 08-02. Postdocs on research awards should be paid in object code 01-40, which are considered wages. Stipends would only be used to pay a postdoc on training or fellowship-type awards.
The GCCR pulls the PIs name from the FAS Budget Index. Check to see if it is spelled incorrectly there. If it's incorrect contact GCA via Grant Tracker.
Please contact Workday to further solve this issue because earn type code is usually related to Workday salary information side.
It is preferred that the PI be contacted and sign the GCCRs themselves, even if they are no longer employed by the UW.
In rare instances, when the PI is unable to certify in a timely manner, the department chair, director (of an organization of departmental level program), division head or dean may certify the GCCR. This verification must be supported by written confirmation from the PI (e.g. in an email or memo) that the work was performed by the individual(s) listed on the report. This documentation should be filed with the GCCR.
This is a blanket email that will go out to all WUC codes. If there is no appropriate activity on the budget, it will not appear on your report. For instance, if the only activity is faculty effort, the budget will not appear on the GCCR. The faculty will certify this effort on the FEC.
The Grant and Contract Certification (GCCR) process is an alternative approach to the Faculty effort Certification (FEC) process which the federal government approved for certifying non-faculty effort. This certification, both faculty and non faculty, is a federal requirement. The BARS do not include the appropriate certification statement and were not part of the original agreement with the federal government. To certify on the BARS would depart from the federally approved use of the GCCR to certify effort for non faculty.
To change an incorrect WUC, contact the Payroll Office at firstname.lastname@example.org. Follow the same procedure for PIs who are missing from your GCCRs.
It is most likely because there are no budgets currently assigned to the missing PI. Verify that the budget for which the PI is responsible for certifying has the correct PI EID and PI name in MyFinancial Desktop, Budget Profile.
The situation in which you would need backup documentation is if a previous GCCR has a salary transfer after the fact that will affect it. In addition, you need to have the faculty recertify the GCCR after the salary transfer has posted and you have edited the GCCR to include it. Here is some more information on GCCR changes: Changes to GCCR | Management Accounting & Analysis (uw.edu)
No, the certification must be an original ink signature.
The Grant and Contract Certification Report (GCCR) is required to be maintained in the home department of the Principal Investigator. Therefore, to determine compliance with the GCCR process, MAA relies on the departmental downloads, i.e. if the GCCR has not been downloaded, it has not been certified. Downloading the GCCR removes the report from the overdue list.
Note, when there is a change in PI, the system will create a GCCR for the new PI. This may result in a duplication of a report for a period already certified by the original PI. In this case there is not need for the new PI to certify again. However downloading the GCCR will remove it from the overdue report.
Managing Faculty Effort
While it is important that the researcher maintains a good relationship with the Program Officer, communicating changes solely through the Program Officer is not sufficient.
Any decrease in effort of 25% or more by key personnel (as noted in the Notice of Grant Award) must be approved in writing prior to the change by the sponsors' Grants Officer.
An increase in effort greater than 25% for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored agreements.
Any change in the scope of work must also be approved in writing prior to the change by the sponsors' Grants Officer. All requests must be processed through the UW Office of Sponsored Programs in advance of the change.
From a strict policy stand point, the terms and conditions of the award continue unless amended, so reducing effort by 25% or more would require sponsor approval.
The PI may, however, request that the sponsor approves eliminating or reducing the cost share during the no-cost extension process. While the University may approve the no-cost extension, the reduction of effort must be granted by the sponsor.
K awards present a unique case as they generally carry the requirement for a 75% commitment of total professional effort.
Recertification of the FEC is only required if the level of effort on the sponsored project changes. Documenting the transfer of salaries to a sub budget number is not required as long as it does not change the overall project effort for the respective FEC cycle. This includes salary transfers from a parent budget to a sub budget or between sub budgets within the same project.
eFECS obtains salary and primary position as home department from Workday. Please contact Workday email@example.com to futher solve the issue.
Normally it is acceptable for the effort commitment to be met over the project budget period and not tied to each FEC cycle. It is common for effort to vary from FEC cycle to FEC cycle provided the PI (or key personnel as designated in the Notice of Grant Award) does not (a) absence him/her self from the project for three consecutive months or more, or (b) reduce effort on the grant (direct and cost shared combined) by 25% or more over the budget period.
A PI can reduce their effort 5%, 10%, etc. without any impact on the award. However, prior approval must be obtained if the reduction falls under a sponsor requirement. For most NIH research (non-K) awards, a change of 25% or more requires prior approval. PCORI also requires approval for a greater than 25% change. There are no repercussions for a less than 25% change in either of those circumstances.
Consistent with the spirit of the Bayh-Dole Act, reasonable levels of activity related to pursuing intellectual property can be charged to grants.
These activities may include making an invention disclosure, meeting with UW’s tech transfer office (CoMotion) to discuss an invention disclosure, meeting with a patent attorney about a UW invention and/or reviewing internal actions on patent applications.
As with any effort charged to sponsored agreements, effort associated with the pursuit of intellectual property must be directly related to the sponsored project that is being charged. Where more than one award or activity contributed to the development of the intellectual property the effort distribution should be based on proportionate support provided under the awards or other equitable relationship.
The effort must also occur within the award period for it to be eligible for direct charging. These activities should be included within total University effort for effort reporting purposes.
UWFT Changes to Effort Reporting
A faculty member’s appointment is not impacted as a result of being placed on Reduced Responsibility (RR). Rather, it impacts his/her compensated FTE (e.g. salary reduction with proportionate reduction in responsibilities). When a faculty member’s salary has been reduced based on RR status, it is recognized that his or her University responsibilities will be reduced accordingly, giving the faculty member the opportunity to engage, if desired, in uncompensated activities that are outside his or her RR status such as scholarly activity including proposal preparation.
For example, a 1.0 FTE faculty member loses 25% funding and moves into a 75% RR status (65% of the non-RR status is funded from other grant sources; 10% is funded from non-sponsored UW sources for scholarly activities). The remaining 25% unfunded time may be used as uncompensated time on additional scholarly activities while in RR status of 75%. It is important to note however, that the faculty member’s unit must provide funding for scholarly activity, e.g. proposal preparation, as described in GIM 38 - Funding Support for Institutional Scholarly Activities.
proposal preparation effort must come from non-sponsored funds. Just like full-time faculty, part-time faculty (those with an appointment of less than 1.0) may not volunteer their time for proposal writing or other non-sponsored activities. Note, part-time is NOT the same as reduced responsibilities (See GIM 38 – Faculty Reduced Responsibility Status Involving External Funding)
If employed by the UW, no matter faculty is less than 100%, or retired. Faculty can’t work on proposals in their free time without compensation. The unit would need to pay for that time doing proposals. The only exception is for de minimis proposals, e.g. if they just had to sign a couple documents but not actually do a full proposal.
Effort Reporting Process
If faculty is not paid on any sponsored budgets and no longer has a cost share commitment for specific period, there will be no FEC for this period.
Please contact your department Astra authorizor to grant you the eFECS Effort Reporting access.
An FEC most commonly will need to be recertified in the eFECS system when there is a retroactive change in salary distributions and/or cost share commitments/effort that has a material impact on the percentages previously certified to for sponsored budgets, i.e., the adjustment changes the percentages. If there are no (or minimal) changes impacting sponsored budgets, a recertification is not necessary.
While we strive to avoid the recertification of FECs as they are frequently reviewed and questioned by auditors, it is critically important that when an error is detected, the FEC be corrected even if it requires it to be recertified. One common cause of this is late receipt of awards from sponsors.
It is recommended that, in these cases, an advance budget be requested, especially if the anticipated receipt of the award is past the complete by date for the FEC. Also, while the late certification of an FEC is non-compliant with UW policies, it is a lesser issue than knowingly certifying an incorrect FEC.
First, do not certify the FEC. Make sure all corrections have been made before doing so as eFECS will automatically update the FEC information to incorporate changes processed if it has not been certified thus avoiding the need to recertify. If you do certify your FEC and a correction is subsequently made you will need to recertify it.
Second, contact your FEC coordinator to inform him/her there is a problem with what is reflected on the FEC as it does not reasonably reflect your actual effort. This most commonly results from incorrect salary distributions or an issue related to cost sharing. In these cases a retroactive salary distribution correction and/or cost share adjustment can be made.
While it sometimes can take time to get changes processed and result in the FEC certification being delinquent, it is the better option than to knowingly certify to something incorrect.
If you go to the bottom of FEC, there should be a “ view recertifiable FEC” selection.
(or “View FEC with post certification changes for recertification analysis” )
After you click this link, it would direct you to the updated FEC.
If you cannot see this link :
eFECS would show earn type codes in the following list : 'REG', 'S/L', 'SUM', 'PLP', 'TFA', 'ADS', 'ENS'. Please check see if the OSET is under these earn type codes.
As of March 2017, recertifications are processed electronically. Follow the instructions on MAA website. Note, the ASTRA role “View and Update Effort Report” is needed to process a recertification online.
Recertifications after 10/11/23 will follow a manual process. Contact firstname.lastname@example.org if there is an FEC that needs recertification.
Certifications of outstanding FECs will be done via a manual process that has been developed by the Effort Reporting Team. To initiate the process of manual certification, please reach out to email@example.com with the faculty’s name and period end date of the FEC that needs to be certified.
The last day to make effort report changes depends on what you’re trying to do:
- Payroll Adjustments/Retro pay – After 7/14 this is a manual process. Contact firstname.lastname@example.org.
- Certifications, recertifications (if it’s available), comments, view/adjust cost share – Update in eFECS until 10/11
For more information about the timeline, refer to Faculty Effort Certification (FEC).
The last day to tag non-FEC Cost Share is 7/31/23.
Faculty effort cost share will be captured as part of the FEC process through 10/11/23.
After 7/14/23, salary transfers impacting pay periods ending 6/30/23 and prior will need to be done using a Journal Entry.
Salary transfers that affect Sponsored Awards after 7/14/23, must also follow a manual process to update the FEC. Contact email@example.com to initiate the process.
If you have cost transfer questions that do not impact sponsored awards, submit a ticket via UW Connect Finance (available beginning 7/6/23). To learn more, refer to Customer Support.
If a faculty member is clearly not being compensated (must be for entire pay periods) by the University then proposal preparation time would be considered volunteer time, i.e., performed on one’s own time. As such, no alternative (non-sponsored) funding needs to be obtained since no UW compensation is being received. However, if partial salary is being paid during the period in question this effort would be considered part of said compensation and a non-sponsored funding source needed.
The FEC process is conducted on a semi-annual schedule for faculty on 9 month appointments. Spring (3/16-6/15) and summer (6/16-9/15) effort is combined into a single FEC (March 16 - September 15). The rate of pay one can receive from a grant for work during the summer portion of this cycle is based on their 9 month academic year salary rate. While summer salary is considered part of institutional base salary, it is generally a unique line/designation in grant proposals.
For example, if the 9 month salary is $3,000 per month for a full-time appointment and there is a commitment of 50% effort for two months during the summer portion of the spring/summer cycle, the rate of pay for those two summer months would be $1,500 per month for 50% effort per month. On the FEC, the summer compensation will be added to the compensation received during the spring quarter for each sponsored budget and for 'Other Salary Sources'. The percent for each budget will then be calculated by dividing the total compensation charged to the budget divided by the total compensation received over the two quarters, i.e., FEC period.