Fiscal Compliance for Title III Keisha Davis Monitoring & Compliance Section School Business Division

Fiscal Compliance Items Included:  Time and Effort Documentation  Equipment  Contracts/Invoices  Administration Limitation  Indirect Cost  Supplement/Supplant  BAAS

Time and Effort Applies to every employee funded from federal funds. Purpose: To document that the appropriate federal program is receiving the benefit of the services supported by grant funds. Time and Effort documentation is required by OMB Circular A-87, Attachment B, Item 8 (h), and is in addition to the standards for payroll documentation.

Two Types of Participating Employees: Single Cost Objective –Employees must have at least semi-annual certifications that they worked solely on that program. –Certifications must be signed by the employee or the supervisor who has first hand knowledge of the work performed. Multiple Cost Objectives –Monthly Personnel Activity Reports (PARs) –Signed by employee

What does a “semi-annual certification” look like? A simple statement: “I, Wonderful Employee, certify that I spent 100% of my time for the period of January 1, 20XX, through June 30, 20XX, on Title III activities.” OR A “blanket” statement signed by the supervisor with first-hand knowledge of employees’ work.

Multiple Cost Objective Employees Salaries and wages must be supported by completing monthly personnel activity reports (PAR forms) unless a substitute system has been approved. PAR Forms MUST Reflect an after-the-fact distribution of the actual activity of each employee; Account for the total activity for which each employee is compensated; Be prepared at least monthly and must coincide with one or more pay periods; and Be signed by the employee.

What does a PAR form look like?

Important notes about PARs PAR forms must be supported by more detailed documentation, such as a calendar with daily entries regarding activities supporting each cost objective Results of PAR forms must be reconciled against payroll (usually a finance function)

Which LEAs are approved to use substitute systems?

Special Note on Schoolwide Schools In a Title I Schoolwide School, all funds lose their identity. Employees in a Schoolwide School may be paid from any fund source, or any combination of funding sources, and their effort statement would state “100% Title I Schoolwide Activities”, making a certification statement the appropriate documentation. Employees in a Schoolwide School who are paid from federal funds are the ones who document their time and effort.

Additional Training There is a presentation on web at: presentations/summer12/timeeffort.pdf

Questions?

Equipment Federal regulations require certain records to be kept Not to be confused with “fixed assets” tracking What to track?  Items with a useful life > 1 year  Police report filed if the item “disappears”  Include small “attractive” items

Equipment Education Department General Administrative Regulations (EDGAR) 34 CFR (d) Management requirements (1) Property records must be maintained that include…

Description of the property Serial number or other identification number Source of property Who holds title Acquisition date Cost of the property Percentage of Federal participation in the cost Location, use, and condition Disposition data (including date of disposal and sale price) Equipment (cont’d)

Other Equipment Management Requirements: Physical inventory (reconciled with property records at least once every 2 years – annual is good) Control system Adequate maintenance procedures DPI Equipment Disposition process – under the “Monitoring” headinghttp://

Questions?

Contracts/Invoices Contracts for personnel services MUST be specific – who, what, when, where. Payments from object code 311 must be supported by a valid written contract. Invoices must also be detailed – it is not enough to just refer to the contract number.

Contracts (cont’d) Suspension/Debarment –Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Debarred Vendors list – State can be found at: – Federal can be found at:

Questions?

Administrative Costs Administrative Cost is limited to 2% of current year allotment

Indirect Cost Indirect cost is not the same as administrative costs, but makes up the administrative cost If your indirect cost rate is more the limitation, you may be limited in the amount of indirect cost you can recover

Example Allotment of $100,000; 2% administrative cost limitation means that $2,000 is the maximum administrative cost that can be charged. (100,000 x 2%) LEA’s indirect cost rate is 3%, the entire $100,000 allotment is spent in the first 12 months, and the expenditures include $40,000 in object code 311 – Contracted Services. Therefore, there are $60,000 in ‘qualifying’ expenditures; thus, only $1,800 can be recovered from indirect cost ($60,000 x 3%)

Questions?

Supplement, Not Supplant What services is the LEA required by other Federal, State, local laws or regulations to provide? How has the LEA demonstrated that it is not using Title III funds to provide services that it is required to make available under State, local or other Federal laws? How has the LEA demonstrated that it is not using Title III funds to provide services that it provided in the prior year with State, local or other Federal funds?

Still Unsure… If you are not sure of compliance based on the answers of the three (3) previous questions, please talk to your Title III Program Consultant. However, a rebuttable of the presumption of supplanting can be if State and Local funds have been reduced so that required services could not be met any other way, but thorough documentation must be kept.

Questions?

BAAS What is it? BAAS is a new Budget and Amendment Approval System (BAAS) at DPI BAAS will replace the budget/amendment subsystem of BUD The GL and Salary adjustment (202) subsystem of BUD has NOT gone away. What you use is different, but interfaces with BAAS

A Look at BAAS If you want to use the system, you must subscribe using your NCID and password. Directions can be found at: Look for ‘Subscribing to BAAS’ Will have inquiry access only

Questions About BAAS? DPI Help Desk at:

Questions?

Resources Federal information: OMB Circulars, EDGAR

Contacts Monitoring & Compliance Section: Keisha Davis Karen Frazier