Maintenance of Effort Time and Effort Requirements September 2014

Fiscal Requirements Elementary and Secondary Education Act Requirement  Maintenance of Effort OMB Circular A-87 Requirement  Time and Effort Documentation

Maintenance of Effort Districts must demonstrate that the level of state and local funding remains relatively constant year to year. District’s general fund expenditures must be at least 90% of the prior year amounts. State annually determines whether a district has maintained effort.

Maintenance of Effort In addition to Title I, Part A the requirements of Section 9521 apply to:  Title I, Part B, Subpart 3, Even Start  Title I, Part D, Prevention and Intervention Programs for Children and Youth who are Neglected, Delinquent, or At-Risk  Title I, Part F, Comprehensive School Reform

Maintenance of Effort In addition to Title I, Part A the requirements of Section 9521 apply to:  Title II, Part A, Improving Teacher Quality  Title II, Part D, Educational Technology  Title III, Part A, English Acquisition

Maintenance of Effort In addition to Title I, Part A the requirements of Section 9521 apply to:  Title IV, Part A, Safe and Drug-Free Schools and Communities  Title IV, Part B, 21st Century Learning Centers  Title VI, Part B Subpart 2, Rural Education

Failure to Meet the Requirement The Ohio Department of Education must reduce the amount of funds under the covered programs in any fiscal year in the exact proportion* by which the district fails to maintain effort by falling below 90 percent of either the combined fiscal effort per student or aggregate expenditures. *The department uses the measure most favorable to the district.

Waiver to Maintenance of Effort WAIVER – U.S. Department of Education Secretary may waive the requirement if it is determined a waiver is equitable due to:  Exceptional or uncontrollable circumstances  Precipitous decline in financial resources

Included Expenditures These include:  Administration  Instruction  Attendance and Health Services  Pupil Transportation Services  Operation and Maintenance of plant  Fixed charges  Net expenditures to cover deficits for food services and student body activities

Excluded Expenditures  Expenditures for community services, capital outlay, debt service  Supplemental expenses made as a result of a Presidentially declared disaster  Expenditures made from funds by the Federal Government

Data Sources Average Daily Membership  EMIS period N (Yearend) reporting General Fund  EMIS period H (July) reporting  Expenditure per Pupil Rankings  USAS fund code: 001 and 016

Web Based System Maintenance of Effort  Located behind SAFE account  Integrated with EMIS  Automated ESEA and IDEA MOE Calculations  Automated Messages/Reminders  Reports for State and USDOE  History Log  Audit Log

Maintenance of Effort System  MOE Tab: District’s Status: PASS or FAIL  DOCS Tab: Upload Waiver and Supporting Documentation  COMMENTS/HISTORY Tab: Enter comments to the department; History tracks data file updates

Time and Effort Reviewing the basics  What is time and effort reporting?  Why is time and effort reporting important?  Who must participate in time and effort reporting?  Changes in time and effort reporting?  What has changed?  What do the changes mean for district staff?

Time and Effort Basics All positions funded with federal funds must document the time and effort devoted to the federal program.

Types of Time and Effort Single cost objective  Semi-Annual Certifications Multiple cost objective  Personnel Activity Reports (PARS) or Time and Effort Logs

Single Cost objectives A single cost objective is a single function or a single grant or activity. It is possible to work on a single cost objective even if an employee works on more than one Federal award or on a Federal award and a non-Federal award.

Multiple Cost Objective  More than one federal award  Federal award and non-federal award  Work on multiple activities or cost objectives, which are allowable under and chargeable to particular federal program(s)/award(s) and state or local programs/fund source

Semi-Annual Certifications  Employee works 100% on single cost objective  Complete at least every six months  Signed by a supervisor with first hand knowledge or employee

Semi-Annual Certifications  After-the-fact record (dated)  Accounts for the total activity for which employee was compensated

Semi-Annual Certification Example “I hereby certify that for the period January 1, 2015 through June 30, 2015 one-hundred percent (100%) of my time and effort was spent on Title I Administration.”

Single Cost Objective Example 1 A district supports a supplemental math teacher to serve low-achieving students with 50% Title I, Part A and 50% local funds  Teaching math to low-achieving students is a single cost objective because it can be fully supported under Title I Part A.  Only a semi-annual certification is required.

Single Cost Objective Example 2 District supports an elementary school teacher with local funds but also pays her with Title I, Part A funds to provide after-school tutoring for low- achieving students.  The portion of her time spent on after-school tutoring is easily separated from her teaching position by her schedule.  The after-school tutoring is a single cost objective and only a semi-annual certification required.

Single Cost Objective Example 3 A teacher in a schoolwide school is paid with local funds to reduce class size in 1 st grade in the morning and is paid with Title I Part A funds to teach supplemental reading recovery in the afternoon.  Both functions are fully supportable with Title I, Part A funds, and the schoolwide program constitutes a single cost objective.  Only a semi-annual certification is required.

Time and Effort Log Complete at least monthly (unless substitute system) Must coincide with one or more pay periods

Time and Effort Log Account for the total activity for which employee was compensated Must be signed after-the-fact by the employee

Multiple Cost Objectives Example 4 A instructional assistant in a targeted assistance school is paid with IDEA Part B funds to assist in a special education class 30% of the time and he is also paid with Title I Part A funds to assist in the Title I Reading pull-out program 70% of the time. Multiple cost objectives require a Time and Effort Log.

Substitute System Districts may now implement a substitute system, allowing employees working a fixed schedule to use alternative documentation for supporting salaries and wages, such as a teaching schedule. The employee would then certify semi-annually that the schedule reflects actual time worked in each activity for the period being certified.

How to get Approval of the Substitute System Contact: Ohio Department of Education Grants Management Office, Tiffany Davis

Questions?

education.ohio.gov

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