Time Studies/Time Tracking & What’s New(s) Public Consulting Group Time Studies/Time Tracking & What’s New(s) 2/22/2019 National Association of State Human Services Finance Officers (HSFo) July 28, 2014 www.publicconsultinggroup.com

Presentation Contents Public Consulting Group 2/22/2019 Presentation Contents “Super Circular” & Time Studies Time Sampling Outside of State Agencies Varying Levels of Scrutiny Contact Information National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Super Circular & Time Studies Public Consulting Group 2/22/2019 Super Circular & Time Studies The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards goes into effect December 26, 2014 for state agencies (https://www.federalregister.gov/articles/2013/12/26/2013-30465/uniform-administrative-requirements-cost-principles-and-audit-requirements-for-federal-awards) National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Super Circular & Time Studies Public Consulting Group 2/22/2019 Super Circular & Time Studies Release of the “Super Circular” brings new attention to cost allocation No specific changes to time studies and time tracking, however: The new circular allows for time “certification” to occur within payroll systems if the system can provide the required level of information Look for new updates to documents such as the Public Assistance Cost Allocation Plan Review Guide, which provides much of the guidance available related to time studies And, see slide 9 for changes related to sub recipient monitoring National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Super Circular & Time Studies (con't) Public Consulting Group 2/22/2019 Super Circular & Time Studies (con't) Are you ready for it? National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Time Sampling Outside of State Agencies Public Consulting Group 2/22/2019 Time Sampling Outside of State Agencies Many State agencies outsource functions to: Child placing agencies (not for profits) School districts County and not for profit agencies performing case management and/or eligibility functions OMB A-87 and “Super Circular” requirements apply: If state staff performing the function would require a time study, non state staff require a time study as well State staff and non-state staff most likely cannot be in the same time study Outside agency time studies must be documented and included in cost allocation plans Federal cognizant agencies are requiring centralized versus decentralized time studies of the time these relationships are a sub recipient relationship 99.9% National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Time Sampling Outside of State Agencies (con’t) Public Consulting Group 2/22/2019 Time Sampling Outside of State Agencies (con’t) Sub recipient “Sub recipient means a non-Federal entity that receives a sub award from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A sub recipient may also be a recipient of other Federal awards directly from a Federal awarding agency”. (Uniform Guidance 200.93) Contract/Vendor “Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this Part does not include a legal instrument, even if the non-Federal entity considers it a contract, when the substance of the transaction meets the definition of a Federal award or subaward (see § 200.92 Subaward)”. (Uniform Guidance 200.22) Another agency is performing a task on behalf of my agency My agency buys a good or a service from another entity National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Time Sampling Outside of State Agencies (con’t) Public Consulting Group 2/22/2019 Time Sampling Outside of State Agencies (con’t) For outside agency claiming: An interagency agreement must be established between entities (and if public assistance agencies, documented in agency cost allocation plans per 45 CFR 95.507 (b)(6)) Entity must comply with requirements of federal award and if subaward is annually above certain value will be subject to an audit $500k through 12/26/2014 and $750k after 12/26/2014 per the Uniform Guidance To “claim” or seek federal reimbursement for subawards, there must be a “certified public expenditure” If passing through grant dollars, the entity may have already received the federal funds If asking another entity to perform a task on your behalf that is not initially funded with grants, there must be a CPE to seek federal reimbursement National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Time Sampling Outside of State Agencies (con’t) Public Consulting Group 2/22/2019 Time Sampling Outside of State Agencies (con’t) The Uniform Guidance clarifies sub recipient monitoring requirements (200.31): “Single state agency” responsible in event of audit Single state agencies must have documented review procedures Interagency agreements must exist spelling out specific responsibilities The state agency is ultimately responsible National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

Varying Levels of Scrutiny Public Consulting Group 2/22/2019 Varying Levels of Scrutiny Oversight of cost allocation plans varies, especially related to sub recipient relationships. Why can one state agency have a plan that has not been updated since 1992 while another is compelled to update their plan for seemingly minor changes? What is a minor change and what is not? Do sub recipient plans need to be submitted to the federal cognizant agency or not? When do we need interagency agreements and when don’t we? To protect funding, all OMB A-87 (now) and Uniform Guidance (future) requirements must be met National Association of State Human Services Finance Officers (HSFo) ) www.publicconsultinggroup.com

Public Consulting Group 2/22/2019 Contact Information Amy Ferraro Manager Public Consulting Group, Inc. aferraro@pcgus.com (617) 717-1149 www.pcgus.com National Association of State Human Services Finance Officers (HSFo) www.publicconsultinggroup.com

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