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Time and Effort Reporting:
Documenting Employees’ Personnel
Costs
Kristen Tosh Cowan, [email protected] & Manasevit, PLLC
Fall Forum 2011
THE BASICS ON KEEPING TIME
ACCOUNTING RECORDS
Terminology
Time and attendance records Payroll records
Worked 8:00-4:00
Time and effort records Time distribution records
Worked 50% on Title I administration and 50% on nonfederal
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Who must participate? Any employee who is
working on a federal program◦ Not contractors◦ All employees paid with
federal funds◦ Some employees paid
with non-federal funds
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A-87: If employee works 100% on single cost objective
Semi-Annual Certification Signed every six months by supervisor or
employee
“This is to certify that Kristen Cowan has worked 100% of her time for the period January 1, 2010, through June 30, 2010, on Perkins Administration.”
Signature of employee:Date: 5
A-87: If employee works on multiple cost objectives
Personnel Activity Reports (PAR) Signed every month by employee UNLESS, using “substitute system” (then 2 or
3 times per year)
“For the month of September 2009, I spent my time 50% on Title I Program Services and 50% on non-federal programs.”
Signature of Employee:Date:
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PARs must:
After-the-fact record Total activity for which employee
compensated At least monthly
(unless substitute system) Signed and dated by employee
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OIG Time and Effort Findings:
2006 – Columbus - $2.3 million
2008 – Detroit - $49 million
2009 – Houston - $238 million
2010 – Philadelphia - $123 million
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BRUSTEIN & MANASEVIT: GRANTS MANAGEMENT
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Time and Effort Documentation
QUIZ!
Question 1:A district administrator works
approximately half time on NCLB Title I, Part A, and half on IDEA. She is required to keep:A. Monthly PARsB. Semi-annual certifications
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Question 2:A district administrator works
approximately half time on NCLB Title I, Part A, and half on Title I, Part C (Migrant). She is required to keep:A. Monthly PARsB. Semi-annual certifications
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Question 3:A district administrator spends 100%
of his time on NCLB Title I, Part A, although half of his salary is funded from non-federal sources. He is required to keep:A. Monthly PARsB. Semi-annual certifications
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Question 4:A district administrator works
approximately half time on NCLB Title I, Part A, and half on non-federal activities, although his salary is funded 100% from Title I, Part A. He is required to keep:A. Monthly PARsB. Semi-annual certificationsC. Bail money on hand
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Question 5:The district’s NCLB Director works on
Title I, Part A, Title II, Part A, and 21st Century. The district consolidates its NCLB administrative funds. The Director is required to keep:A. Monthly PARsB. Semi-annual certifications
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Question 6:The district has a contract with an
SES provider for afterschool tutoring for students. The contract is paid with Title I funds. Do the contractor’s employees need to keep time and effort records?A. YesB. No
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Question 7:Making journal voucher adjustments
to accounts typically is unrelated to employees keeping time and effort records.A. FalseB. True
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Question 8:A classroom teacher in a targeted
assistance school provides Title I services and is paid with Title I, Part A funds. Just like any other federally-paid employee, she is required to keep time and effort records.A. TrueB. False
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Question 9:A classroom teacher is paid with
non-federal funds used for a match under a federal program. Because she is paid with nonfederal funding, she is not required to keep time and effort records.A. TrueB. False
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Question 10:In a schoolwide program, a teacher
is paid with Title I funds and works 100% on the schoolwide program plan. What kind of time and effort records is she required to keep?A. Semi-annual certificationsB. Monthly PARsC. It depends
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BIG QUESTION
WHAT IS A SINGLE COST OBJECTIVE???
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What is a “Cost Objective”?
A-87 Definition: A function, organizational subdivision, contract, grant or other cost activity for which cost data are needed and for which costs are incurred.
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Examples . . . . A Minimum Set-Aside or Maximum
Cap: Title I- LEA Parent Involvement
minimum (at least 1%); Title III – Cap on administration (no
more than 2%)
Program services Title I program services
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USDE Guidance: Draft Examples of Single Cost Objectives An LEA supports a supplemental
math teacher to serve low-achieving students with 50% Title I and 50% state compensatory education funds.
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Draft Examples of Single Cost Objectives
Each elementary school has a part-time librarian 3 days/ week paid with local funds. An LEA adds 2 days/ week for its Title I schoolwide schools paid with Title I Part A funds.
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Draft Examples of Single Cost Objectives
A preschool special education teacher is funded with 50% IDEA section 611 and 50% with IDEA section 619 funds.
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Essential Legal Resources OMB Circulars A-87: Cost Principles
for State and Local Governments
HHS Implementation Guide for A-87: ASMB C-10 (1997)• http://rates.psc.gov/fms/dca/asmb%20c-
10.pdf
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Resources, cont. Cost Allocation Guide for State and Local
Governments (or “Green Book”) (Sept 2009) http://www2.ed.gov/about/offices/list/ocfo/fi
pao/guideigcwebsite.pdf
Montana Compact www.bruman.com
Program-specific guidance
USDE officials27
Ideas for Reducing Burden
Consolidated Administration
Combine administration for all NCLB programs
NOT non-administrative activities
Single Cost Objective Semi-annual certification LEA needs approval of SEA
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“Blanket” Semi-Annual Certification
Single cost objective (semi-annual cert)
Multiple employees Signed by supervisor with first-hand
knowledge (principal)
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Schoolwide Programs The programs included in the
Schoolwide Plan constitute a single cost objective
Need for records depends on the extent of consolidation of federal, state, and local funding
Can be “conceptual” or “virtual” consolidation – not literal 31
Schoolwide time recordsIf LEA/ school consolidates . . . .
Then must keep . . .
All federal, state, and local funds
No time and effort records
Federal only (“Consolidated federal pot”)
Semi-annual – if works ONLY on SWP Plan (single cost objective)Monthly PAR – if works on SWP Plan and other programs not in Plan (multiple cost objectives)
Nothing (only Title I funds SWP)
Semi-annual – if works ONLY on SWP Plan (single cost objective)Monthly PAR – if works on SWP Plan and other programs not in Plan (multiple cost objectives)
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How to set up a time distribution system
How to set up time distribution system:
1) Plan initial funding allocations well
May use “budget estimates” for initial allocations
Supervisors need to be on board
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CAUTION:
Beware of Re-organizations!
2) Develop written time distribution policies and procedures
“How to” instructions for employees reporting vacation, travel, long-term leave
Manual for fiscal side Frequency of comparing estimates to
actual costs, handling of deviations, monitoring of system
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3) Train employees
On mechanics of filling out form
On which federal program cost objective they are working
Refresher training
New employee training
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4) Close supervision
Supervisors should be aware of deviations of effort from initial budget estimates
Be ready to redirect work of employee or adjust grant supporting salary
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USDE is soliciting ideas for pilot programs:1. mechanisms for consolidating funds in
schoolwide programs2. time and effort reporting under A-87 3. documenting compliance with other
record keeping and reporting requirements
USDE “Burden Reduction” Pilot Program
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QUESTIONS??
