Office of Special Education TIME AND EFFORT REPORTING Presenters: Michael Wynn, CFE Grants Management Certified Nancy Jo Serna, CPA

Time and Effort Regulations 2 CFR 225 (Formally known as OMB Circular A-87) Attachment B, Item 8h

Time and Effort Overview Financial Management Requirements: Written policies and procedures Staff training Required Documentation Estimates and Quarterly Comparisons Adjustments and Revisions

Time and Effort Reporting Documentation Time and Effort documentation is required for all employees paid with federal funds. These records are in addition to payroll documentation. Not applicable for contractors.

Time and Effort Reporting Definition Cost Objective A function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred.

Time and Effort Reporting Documentation Semi-Annual Certification: A certification that the employee worked solely on a single Federal award or cost objective (activity).

Time and Effort Reporting Documentation Semi-Annual Certification When an employee works 100% on a single federal award or cost objective, the certification must be: Prepared after-the-fact (dated), and Prepared at least every 6 months (semi-annually), and Account for total activity for which the employee is compensated; and Signed by the employee or supervisory official having firsthand knowledge of the work performed

Time and Effort Reporting Documentation Personnel Activity Report (PAR): A record maintained by an employee who works on multiple activities or cost objectives.

Time and Effort Reporting Documentation Personnel Activity Report (PAR) When an employee works on multiple activities or cost objectives, the PAR must: Reflect an after-the-fact distribution (dated) of the employee’s actual activity, and Be prepared at least monthly, and Coincide with one or more pay periods, and Account for total activity for which the employee is compensated; and Be signed by the employee

Time and Effort Reporting Personnel Activity Reports or Semi-Annual Certifications?!!! Which one?!!!

Time and Effort Reporting PAR vs. Semi-Annual Certification The key to determining the proper documentation is to understand if the employee is working on one cost objective or activity or multiple cost objectives or activities.

Time and Effort Reporting PAR vs. Semi-Annual Certification There are only four possible options to consider when determining whether to complete a semi-annual certification or personnel activity report. All possible circumstances will apply to one of the four options.

Time and Effort Reporting PAR vs. Semi-Annual Certification Decision Making Tools Decision Making Rubric Decision Making Graphic

Time and Effort Reporting Decision Making Rubric Decision Making Rubric COST OBJECTIVE Single Multiple GRANT AWARDS (or funding source) Semi-Annual Certification (A) PAR (C) (B) (D)

Time and Effort Reporting Decision Making Graphic

Time and Effort Reporting Example A

Time and Effort Reporting Semi-Annual Certification Example Example A: Single Award/Single Cost Objective A sub-recipient could have an employee funded with a single federal award and working on a single cost objective. IDEA Part B Sec. 611, a Special Education teacher works with students with disabilities ages 6-21, 100% of their time and is charged to Flowthrough grant only, semi-annual certification is required.

Time and Effort Reporting Example B

Time and Effort Reporting Semi-Annual Certification Example Example B: Multiple Awards/Single Cost Objective A sub-recipient could have an employee funded with more than one federal award (or funding source) working on a single cost objective, where the awards support the cost objective. IDEA Part B Sec. 611 supports students ages 3-21 and Sec. 619 supports ages 3-5. A Special Education teacher works with students with disabilities ages 3-5 only and is charged to Flowthrough and Preschool grants, a semi- annual certification is appropriate.

Time and Effort Reporting Example C

Time and Effort Reporting PAR Example Example C: Single Award/Multiple Cost Objectives A sub-recipient could have an employee funded with a single federal award and working on multiple cost objectives. IDEA Part B, Sec. 611 requires tracking of Proportionate Share costs. A Speech Therapist provides services to public school students with disabilities and provides services to non-public school students with disabilities, a PAR is required.

Time and Effort Reporting Example D

Time and Effort Reporting PAR Example Example D: Multiple Awards/Multiple Cost Objectives A sub-recipient could have an employee funded with multiple federal awards (or funding source) and working on multiple cost objectives. IDEA Part B Sec. 611 for Other State Activities supports Transition Services (TS) and Enhancing Opportunities for Students with Disabilities (EOSD) grants. If a person works as a Transition Coordinator (TS) and a Planner Monitor (EOSD), a PAR is required.

Time and Effort Reporting Estimations Determined before services are performed do not qualify as time and effort documentation. Comparisons & Adjustments Adjust quarterly if actual and budgeted differ 10% or more Adjust annually if actual & budgeted differ less than 10%

Time and Effort Reporting Frequently Asked Questions Q: What are the Program Fiscal Review requirements? A: Must have proper Time and Effort documentation to support expenditures related to employees charged to federal grants. Must be the correct form (PAR or Semi-annual Cert) Must be on file for all employees charged to the grants Must be signed after the fact, and have date of period Must have the grant name

Time and Effort Reporting Frequently Asked Questions Q: What occurs if documentation is not on file or not in compliance during a Program Fiscal Review? A: A finding will be written if noted during a review. Corrective Action to ensure compliance will be necessary. May result in questioned costs.

Time and Effort Reporting Send questions related to IDEA Part B, Sec. 611 to: Michael Wynn, wynnm@michigan.gov Nancy Jo Serna, sernan@michigan.gov