Time and Effort (T&E) Documentation for Federal Programs

Report
Time and Effort (T&E)
Documentation for
Federal Programs
Rebecca Patterson, Grants Administration
David McLaughlin, Federal Fiscal Compliance
and Reporting
Wednesday, May 7, 2014
Session Overview

Introduction to T&E requirements
◦ Where do T&E requirements come from?
◦ What are the requirements for T&E?
2

Substitute system for T&E

Questions?!?!
Introduction to Time and Effort
Requirements
Where do T&E requirements come from?
◦ 2 CFR 225 (OMB Circular A-87)
 Appendix B – Selected Items of Cost
╸ 8 – Compensation for Personal Services
 H – Support of Salaries and Wages
◦ OMB Circular A-133
◦ Title 34 CFR 74.21 – Standards for Financial
Management Systems
◦ Applicable grant requirements
4
What is the purpose of T&E documentation?

Serves as a “receipt” for payroll expenditures

Per the OMB Circular A-87, expenditures:
◦
◦
◦
◦
Must be allowable
Must be reasonable
Must be allocable
Must be adequately documented
When is T&E documentation required?

When any part of an individual employee’s
salary is:
◦ Charged to a federal program, or
◦ Used as a match for a federal program,
◦ Note: Not required for contractors or vendors.
What type of T&E documentation is required
to support payroll expenditures?

Semi-annual certification
◦ Employees that work on a “single cost objective”

Personal Activity Reports (PAR)
◦ Employees that work on “multiple cost objectives”
What is semi-annual certification?

Statement that individuals(s) worked solely on
activities related to a single cost objective

Completed at least every six months

Signed by the employee
What must semi-annual certification
include?







Employer’s name
Employee’s name
Employee’s position
Description of federal program/single cost
objective
Reporting period (at least semi-annually)
Statement that 100% of employee’s time worked
on the federal program/single cost objective
Employee or supervisor’s signature and date
What is a Personal Activity Report (PAR)?






Accounts for 100% of an employee’s time (not
just time worked on federal programs)
Prepared and signed at least monthly
Must be completed after the fact
Reflects actual work performed (not budgeted)
Signed by the employee
Agrees to supporting documentation
Frequently Asked Question (FAQ)
 Instead of every six months, can the LEA
prepare periodic certifications at the end of
each semester?
 Yes. The requirement is for time and effort to be
reported at least semiannually, or twice yearly.
Documenting time and effort at the end of each
semester (for instance, in December and May) would
meet that requirement.
Frequently Asked Question (FAQ)

What if an employee leaves before the end
of the certification period?

If the employee is no longer with the LEA at the end
of the designated period, the supervisor with direct
knowledge of the employee’s schedule would note
that the employee is no longer with the LEA on the
employee signature line and then sign the
certification.
Frequently Asked Question (FAQ)

We use a time card system, do we also
need to do paper PARs?

No. As long as the time card system meets the
requirements of PARs, no additional documents need
to be created.

Schedule changes over 10% require payroll
adjustment each quarter, <10% per quarter needs no
changes, but all pay is adjusted to actual time spent
on the program at year end.
Frequently Asked Question (FAQ)





What are T&E requirements for a 100%
federally funded teacher with a stipend?
An LEA would need to complete one of the following:
1) Semi-annual certification for the normal contracted
hours, and a contract specifying the type of extra-duty
activities and rates of pay, and a weekly/monthly time
sheet showing the actual number of hour of extra duty
activities completed each period; or
2) Utilize the substitute Time and effort system, if the
LEA has been approved to do so by TEA; or
3) Complete monthly Personal Activity Reports (PARS)
showing all work performed.
Schoolwide programs (SWP)

Full consolidation of federal, state, and local
funds in SWP budget (with comprehensive
consolidated schoolwide plan):

Time and effort requirements: semi-annual certification
for each such employee or a semi-annual certification
listing all such employees with their signatures.
Schoolwide programs (SWP) cont.

Federal consolidation—only, combining
federal funds in SWP budget (or no
consolidation):

Time and effort requirements: normal semi-annual/PAR
rules apply.
Ed-Flex

Programs included in Ed-Flex:

- Title I, Part A (except sections 1111 and 1116)
- Title I, Parts C, D, and F
- Title II, Part A, Subparts 2 and 3
- Title II, Part D, Subpart 1
- Title III, Part B, Subpart 4
- Title IV, Part A, Subpart 1
- Title V, Part A
Carl D. Perkins Vocational and Technical Education Act
of 1998.

Ed-Flex

Statewide Administrative Waiver – automatic
for all LEAs (including Charter Schools), no
need to apply for this waiver.

Waives semi-annual Time and Effort requirements (in
lieu of the semiannual certification, the employee is
required to maintain signed and dated job descriptions
identifying the funding source and job duties attributed to
the program).
Key questions to ask yourself:

Does your organization have a locally developed
and approved administrative procedures manual
(APM) that includes a description of the process
that personnel are required to follow with time
and effort requirements?
Key questions to ask yourself (continued)

Does the APM make clear that the PAR should
be completed after-the-fact and reflect 100% of
actual time spent on each activity and each fund
source?

Does the APM include a sample PAR?
Key questions to ask yourself (continued)

What if an employee’s salary is being used to
meet a matching requirement?

If an employees salary is used to meet a matching
requirement then T&E documentation is required.
Summary

22
Salaries charged to federal grants must be
accurately recorded.

Semi-annual certification

Monthly PAR

Time must be charged as worked, not as
budgeted.

PARs must be submitted at least monthly.
Substitute System for
Time and Effort
September 7, 2012, USDE Guidance: Single
Cost Objective
24

Definition: “A function, organizational
subdivision, contract, grant, or other activity for
which cost data are needed and for which costs
are incurred.”

Multiple funding sources may still be single cost
objective
September 7, 2012, USDE Guidance: Single
Cost Objective
25

Employees supported by single cost
objective submit semiannual certification

Regardless of whether LEA implements
substitute system
Determining Single Cost Objective
“The key to determining whether an employee is
working on a single cost objective is whether the
employee’s salary and wages can be supported
in full from each of the federal awards on which
the employee is working, or from the federal
award alone if the employee’s salary is also paid
with non-federal funds.”
26
Example I: Title I, Part A, and State
Compensatory Funds




27
Supplemental math teacher serves lowachieving students on a Title I campus
Paid half from Title I, Part A, and half from state
funds
Teaching math to low-achieving students can be
fully supported under Title I, Part A
This is a single cost objective.
Example II: Two Sections of IDEA-B



28
Preschool special education teacher split-funded
between IDEA sections 611 and 619
Teaching preschool special education is
allowable under both sections.
This is a single cost objective.
Example III: Perkins and State Funds



29
State curriculum specialist develops new CTE
courses and initiatives
Funded half with Perkins and half with state
general funds
This is a single cost objective.
Example IV: Multiple Federal Grants
Employee is an instructional coach for teachers
working in two federal programs:



30
80% funded from Title I, Part A
20% funded from Perkins
This is a multiple cost objective.
New USDE Guidance (September 7, 2012)
Multiple cost objective employees may submit
semiannual certification, if:

LEA submits management certification to TEA

Employee completes schedule and certification

Is in effect for 2012-2013 and subsequent school years
Applies to all LEAs, including ESCs and charters
31
LEA Requirement: Management Certification




32
Form on Substitute System page (search for
“Substitute System” or follow link from Grants
page)
LEA must complete/submit form every school
year
Form submitted by mail as specified on
Substitute System page
We anticipate mailing letters by May of each
year.
Conditions for Employee Participation
33

Must currently work on a schedule that includes
multiple activities or cost objectives that must be
supported by monthly PARs

Must work on specific activities or cost
objectives based on a predetermined, consistent
schedule

May not work on multiple activities or cost
objectives at the exact same time
Employee Schedule Requirements

Employee schedule must:
• Indicate specific activity/cost objective employee
worked on for each segment of employee’s schedule
• Account for total hours for which each employee was
compensated during schedule period
• Be completed again/resubmitted if schedule changes
by more than 10%
34
Employee Schedule and Certification

Employees must complete work schedule and
certification.

Schedule and certification submitted to LEA
business office

Certification must be semiannual at least.
Signed by employee and supervisor with
firsthand knowledge of employee’s work

35
TEA-Developed Schedule and Certification
36

TEA developed sample employee schedule and
certification form

Auto-calculating spreadsheet

Includes all elements TEA auditors require

LEAs not required to use TEA form

If LEAs develop own form, must include all
required elements
Demonstration of TEA Form
37

Spreadsheet includes instructions, schedule,
and certificate

All material covered here included in instructions

Read instructions first

Complete schedule next

Finish with certification
Demonstration of TEA Form: Schedule
38

Complete name, position, district, schedule
period fields

Complete program table (list of programs
worked on)

Identify time worked on programs each day
Demonstration of TEA Form: Name

Name, position, schedule period, and district
info will auto populate certification
Entered
Manually
on
Schedule
Populates
on
Certification
39
Demonstration of TEA Form: Programs
40

Must list all programs worked on

Room for eight programs, including local funds

Use dropdown when possible to list programs

Dropdown menu available fields A-E

For other programs, manual entry fields
F and G
Demonstration of TEA Form: Program
Dropdown List
Select SOF
from
dropdown list
41
Demonstration of TEA Form: Manual
Program Entry
42
Demonstration of TEA Form: Time Worked
43

Document regular daily schedule

Dropdown list for minutes worked, 15-minute
increments

Manually type brief description of activity

Dropdown letter list (A-H) to associate activity
with program

Program list will update with total minutes
Demonstration of TEA Form: Schedule Row
44
Demonstration of TEA Form: Minutes
Dropdown
Select
period of
minutes
from
dropdown
list
45
Demonstration of TEA Form: Activity
Description
Manually
enter activity
46
Demonstration of TEA Form: Associate
Program by Letter
Select SOF
Code (from
above) from
dropdown list
47
Demonstration of TEA Form: Minutes by
Program
48
Demonstration of TEA Form: Schedule with
Multiple Rows/Programs
49
Demonstration of TEA Form: Program List
with Minutes Charged to Multiple Programs
Funding Percentages
auto-calculate as time
is entered
50
Demonstration of TEA Form: Accounting for
Lunch
51

Lunch accounted for on last row of schedule

Lunch minutes are not part of program
calculation
Demonstration of TEA Form: Certificate
52

Much content of certificate autofills from
schedule

Following content entered manually:

Total hours worked

Total lunch hours

Fund codes

Employee signature/supervisor name and signature
Demonstration of TEA Form: Identifying
Information

53
Name, position, schedule period, and district
information auto fills from schedule
Demonstration of TEA Form: Hours

Manually enter total number of hours worked

Manually enter total number of lunch hours
(actual hours, rather than lunch periods)

Check the following:

54
Total hours times 60 (a) equals total minutes
Demonstration of TEA Form: Hours
55
Demonstration of TEA Form: Fund Codes
56
Enter the appropriate
Fund Code for each
SOF
Resources and Further Information
57

USDE September 7, 2012, letter

Chief Grants Administrator section of the Grants
page of TEA website

Substitute System page of TEA website (search
for “Substitute System” or follow link from Grants
page)
Questions?
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