Time and Effort Reporting Office of Superintendent of Public Instruction (OSPI) 3/1/2014

Why Does Time and Effort Continue to be an Audit Problem? Large percent of federal education funds used for staffing. Large percent of federal education funds used for staffing. Staff turnover. Staff turnover. Decentralized responsibilities. Decentralized responsibilities. Lack of adequate communication between program and fiscal staff. Lack of adequate communication between program and fiscal staff. Complexity of applying requirements to variety of situations. Complexity of applying requirements to variety of situations. People dont like it! People dont like it! 3/1/2014

Know The Basics 3/1/2014

Where are the Requirements? Time and effort reporting is required under 2 CFR Section 225 (formerly Federal Office of Management and Budgets Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments). Time and effort reporting is required under 2 CFR Section 225 (formerly Federal Office of Management and Budgets Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments). Attachment B, Selected Items of Cost, Compensation for personal services. Attachment B, Selected Items of Cost, Compensation for personal services. 3/1/2014

When is Time and Effort Required? Time and effort reporting is required when any part of an employees salary is: Time and effort reporting is required when any part of an employees salary is: Charged to a federal program. Charged to a federal program. Used as match for a federal program. Used as match for a federal program. Employees time is split between an indirect and any direct cost objective. Employees time is split between an indirect and any direct cost objective. 3/1/2014

What is an employee? Salaries, wages and benefits are charged under objects 2, 3 and 4. Salaries, wages and benefits are charged under objects 2, 3 and 4. An employee is NOT a vendor or independent consultant/contractor. An employee is NOT a vendor or independent consultant/contractor. No time and effort is needed for non-employees. (See OMB Circular A-133 __.210 for vendor criteria.) No time and effort is needed for non-employees. (See OMB Circular A-133 __.210 for vendor criteria.) 3/1/2014

What type of reporting is needed? Single cost objective Single cost objective Semi annual certification. Multiple cost objectives Monthly time reports or Personnel Activity Reports (PARs). Multiple cost objectives Monthly time reports or Personnel Activity Reports (PARs). 3/1/2014

What is a cost objective? A particular set of work activities for which cost data is accumulated. A particular set of work activities for which cost data is accumulated. For purposes of time and effort reporting: Define cost objectives according to the set of work activities allowable under the terms and conditions of each funding source. (Examples: Parent Involvement or Professional Development in a Federal Program.) For purposes of time and effort reporting: Define cost objectives according to the set of work activities allowable under the terms and conditions of each funding source. (Examples: Parent Involvement or Professional Development in a Federal Program.). 3/1/2014

What are some typical examples of single cost objectives? The set of work activities allowable under: A single federal program. A single federal program. A single required set-aside/reserve in a federal program. A single required set-aside/reserve in a federal program. Federal Special Education and State Special Education. Federal Special Education and State Special Education. A schoolwide program. A schoolwide program. A federal program and its state/local match. A federal program and its state/local match. 3/1/2014

What are some typical examples of multiple cost objectives? The work activities of: A federal program with multiple set-asides/reserves. A federal program with multiple set-asides/reserves. A federally-funded program and a state-and/or locally-funded program. A federally-funded program and a state-and/or locally-funded program. A schoolwide program and a program not combined in the schoolwide program. A schoolwide program and a program not combined in the schoolwide program. 3/1/2014

What is a semi annual certification? Statement (certification) individual(s) worked solely on activities related to a single cost objective during defined dates. Statement (certification) individual(s) worked solely on activities related to a single cost objective during defined dates. Completed at least every six months. Completed at least every six months. Signed and dated by employee or supervisor with first-hand knowledge of work performed. Signed and dated by employee or supervisor with first-hand knowledge of work performed. For internal control purposes, district may request both employee and supervisor sign. For internal control purposes, district may request both employee and supervisor sign. 3/1/2014

What is a monthly time report? (PAR) Accounts for total worked time/activity (including non-federal time). Accounts for total worked time/activity (including non-federal time). Prepared and signed at least monthly. Prepared and signed at least monthly. Signed and dated by employee. Signed and dated by employee. Reflects actual work performed (not budgeted). Reflects actual work performed (not budgeted). Agrees with supporting documentation. Agrees with supporting documentation. 3/1/2014

What type of supporting documentation is needed? Requires a judgment call. Requires a judgment call. Examples include, but are not limited to: Examples include, but are not limited to: Class schedules. Class schedules. Number of students. Number of students. Number of minutes. Number of minutes. Calendars or work logs. Calendars or work logs. 3/1/2014

When is a reconciliation required? Payroll records must be compared to time and effort reports at least quarterly to ensure no unallowable charges to federal awards. Payroll records must be compared to time and effort reports at least quarterly to ensure no unallowable charges to federal awards. 3/1/2014

When is an accounting adjustment required? If the difference is 10 percent or more: Payroll charges must be adjusted at the time of the reconciliation. Payroll charges must be adjusted at the time of the reconciliation. AND: The following quarters budget estimates must be adjusted to more closely reflect actual activity. AND: The following quarters budget estimates must be adjusted to more closely reflect actual activity. If the difference is less than 10 percent: No accounting adjustment is required until the end of the year. No accounting adjustment is required until the end of the year. BUT: At year-end any payroll charges to federal awards that exceed actual time and effort must be eliminated. BUT: At year-end any payroll charges to federal awards that exceed actual time and effort must be eliminated. 3/1/2014

Who should sign the reports? Monthly reports (PARs) must be signed by the employee. Monthly reports (PARs) must be signed by the employee. Semi-annual certifications must be signed by employee or supervisor having first-hand knowledge of work performed. Semi-annual certifications must be signed by employee or supervisor having first-hand knowledge of work performed. For internal control purposes, districts may require both the employee and supervisor to sign. For internal control purposes, districts may require both the employee and supervisor to sign. 3/1/2014

Schoolwide Programs A schoolwide plan must specify programs to be combined. A schoolwide plan must specify programs to be combined. A schoolwide program is a single cost objective if an employee works 100 percent on programs combined Group or Individual Semi-annual certification permitted. A schoolwide program is a single cost objective if an employee works 100 percent on programs combined Group or Individual Semi-annual certification permitted. If an employee works partially on programs combined and partly on those not combined Monthly time report (PAR) required. If an employee works partially on programs combined and partly on those not combined Monthly time report (PAR) required. 3/1/2014

Supplemental Contracts, Stipends, Extra Hours Primary contract and additional contracts may be reported separately. Primary contract and additional contracts may be reported separately. Time and effort may be required for primary contract but not supplemental (or vice versa). Time and effort may be required for primary contract but not supplemental (or vice versa). 3/1/2014

Administrators Superintendent, assistant superintendent, principal, assistant principal are usually not allowable charges to federal programs; Superintendent, assistant superintendent, principal, assistant principal are usually not allowable charges to federal programs; Exceptions require detailed documentation to support. Exceptions require detailed documentation to support. Generally a supplant issue. Generally a supplant issue. 3/1/2014

What is a substitute system? Alternative method for calculating and supporting compensation charges to federal grant funds (usually based on a statistical sample of work performed). Alternative method for calculating and supporting compensation charges to federal grant funds (usually based on a statistical sample of work performed). Used only for federal programs specified in approved substitute system plan. Used only for federal programs specified in approved substitute system plan. Must be approved by OSPI prior to use. Must be approved by OSPI prior to use. Must be statistically sound. Must be statistically sound. Should be periodically reviewed to determine if still appropriate. Should be periodically reviewed to determine if still appropriate. 3/1/2014

Other Requirements for Charging Compensation to Federal Programs Reasonable, necessary and allocable to the program charged. Reasonable, necessary and allocable to the program charged. Compensation consistent with nonfederal activities of the district. Compensation consistent with nonfederal activities of the district. Leave buy-out at termination is an indirect charge. Leave buy-out at termination is an indirect charge. Supplement, not supplant applies to many programs. Supplement, not supplant applies to many programs. 3/1/2014

Tips…… Know the basics. Know the basics. Train and re-train: Train and re-train: Annual training in district. Annual training in district. Explain the why. Explain the why. OSPI Bulletin – Keep it handy. OSPI Bulletin – Keep it handy. Assign central responsibility: Assign central responsibility: Ensure all reports are completed. Ensure all reports are completed. Communicate: Communicate: Who needs to communicate what changes to whom. Who needs to communicate what changes to whom. Ask for help if needed. Ask for help if needed. 3/1/2014

Discussion Missing time and effort report documentation is one of the most frequent and costly audit findings in the state. How does/can your district ensure that every employee required to report time and effort does so? Missing time and effort report documentation is one of the most frequent and costly audit findings in the state. How does/can your district ensure that every employee required to report time and effort does so? 3/1/2014

Questions? ? ?????????????????????????

For Additional Information See OSPI Bulletin See OSPI Bulletin Examples. Examples. Sample forms. Sample forms. 2 CFR Section 225 (OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments2 CFR Section 225 (OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments) 2 CFR Section 225 (OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments Time and effort FAQs (on CPR website) 3/1/2014