Time and Effort (T&E) Documentation for Federal Programs Rebecca Patterson, Grants Administration David McLaughlin, Federal Fiscal Compliance and Reporting Wednesday, May 7, 2014

 Introduction to T&E requirements ◦ Where do T&E requirements come from? ◦ What are the requirements for T&E?  Substitute system for T&E  Questions?!?! Session Overview 2

Introduction to Time and Effort Requirements

◦ 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 – Standards for Financial Management Systems ◦ Applicable grant requirements Where do T&E requirements come from? 4

 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 What is the purpose of T&E documentation?

 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. When is T&E documentation required?

 Semi-annual certification ◦ Employees that work on a “single cost objective”  Personal Activity Reports (PAR) ◦ Employees that work on “multiple cost objectives” What type of T&E documentation is required to support payroll expenditures?

 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 is semi-annual certification?

 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 must semi-annual certification include?

 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 What is a Personal Activity Report (PAR)?

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.

 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)

 Federal consolidation—only, combining federal funds in SWP budget (or no consolidation):  Time and effort requirements: normal semi-annual/PAR rules apply. Schoolwide programs (SWP) cont.

 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 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). Ed-Flex

 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:

 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. Key questions to ask yourself (continued)

 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. Summary 22

Substitute System for Time and Effort

 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 24

 Employees supported by single cost objective submit semiannual certification  Regardless of whether LEA implements substitute system September 7, 2012, USDE Guidance: Single Cost Objective 25

“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.” Determining Single Cost Objective 26

 Supplemental math teacher serves low- achieving 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 I: Title I, Part A, and State Compensatory Funds 27

 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 II: Two Sections of IDEA-B 28

 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 III: Perkins and State Funds 29

Employee is an instructional coach for teachers working in two federal programs:  80% funded from Title I, Part A  20% funded from Perkins  This is a multiple cost objective. Example IV: Multiple Federal Grants 30

Multiple cost objective employees may submit semiannual certification, if:  LEA submits management certification to TEA  Employee completes schedule and certification  Is in effect for and subsequent school years Applies to all LEAs, including ESCs and charters New USDE Guidance (September 7, 2012) 31

 Form on Substitute System page (search for “Substitute System” or follow link from Grants page)Substitute SystemGrants  LEA must complete/submit form every school year  Form submitted by mail as specified on Substitute System page Substitute System  We anticipate mailing letters by May of each year. LEA Requirement: Management Certification 32

 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 Conditions for Employee Participation 33

 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% Employee Schedule Requirements 34

 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 Employee Schedule and Certification 35

 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 TEA-Developed Schedule and Certification 36

 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 TEA FormTEA Form 37

 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: Schedule TEA FormTEA Form 38

 Name, position, schedule period, and district info will auto populate certification Demonstration of TEA Form: Name TEA FormTEA Form 39 Entered Manually on Schedule Populates on Certification

 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: Programs TEA FormTEA Form 40

Demonstration of TEA Form: Program Dropdown List TEA FormTEA Form 41 Select SOF from dropdown list

Demonstration of TEA Form: Manual Program Entry TEA FormTEA Form 42

 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: Time Worked TEA FormTEA Form 43

Demonstration of TEA Form: Schedule Row TEA FormTEA Form 44

Demonstration of TEA Form: Minutes Dropdown TEA FormTEA Form 45 Select period of minutes from dropdown list

Demonstration of TEA Form: Activity Description TEA FormTEA Form 46 Manually enter activity

Demonstration of TEA Form: Associate Program by Letter TEA FormTEA Form 47 Select SOF Code (from above) from dropdown list

Demonstration of TEA Form: Minutes by Program TEA FormTEA Form 48

Demonstration of TEA Form: Schedule with Multiple Rows/Programs TEA FormTEA Form 49

Demonstration of TEA Form: Program List with Minutes Charged to Multiple Programs TEA FormTEA Form 50 Funding Percentages auto-calculate as time is entered

 Lunch accounted for on last row of schedule  Lunch minutes are not part of program calculation Demonstration of TEA Form: Accounting for Lunch TEA FormTEA Form 51

 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: Certificate TEA FormTEA Form 52

 Name, position, schedule period, and district information auto fills from schedule Demonstration of TEA Form: Identifying Information TEA FormTEA Form 53

 Manually enter total number of hours worked  Manually enter total number of lunch hours (actual hours, rather than lunch periods)  Check the following:  Total hours times 60 (a) equals total minutes Demonstration of TEA Form: Hours TEA FormTEA Form 54

Demonstration of TEA Form: Hours TEA FormTEA Form 55

Demonstration of TEA Form: Fund Codes TEA FormTEA Form 56 Enter the appropriate Fund Code for each SOF

 USDE September 7, 2012, letterletter  Chief Grants Administrator section of the Grants page of TEA websiteGrants  Substitute System page of TEA website (search for “Substitute System” or follow link from Grants page) Substitute SystemGrants Resources and Further Information 57

Questions?

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