1. Office of Special Education TIME AND EFFORT REPORTING
Presenters:
Michael Wynn, CFE
Grants Management Certified
Nancy Jo Serna, CPA

2. Time and Effort Regulations
2 CFR 225
(Formally known as OMB Circular A-87)
Attachment B, Item 8h

3. Time and Effort Overview
Financial Management Requirements:
Written policies and procedures
Staff training
Required Documentation
Estimates and Quarterly Comparisons
Adjustments and Revisions

4. Time and Effort Reporting Documentation
Time and Effort documentation is required for all employees paid with federal funds.
These records are in addition to payroll documentation.
Not applicable for contractors.

5. Time and Effort Reporting Definition
Cost Objective A function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred.

6. Time and Effort Reporting Documentation
Semi-Annual Certification:
A certification that the employee worked solely on a single Federal award or cost objective (activity).

7. Time and Effort Reporting Documentation
Semi-Annual Certification
When an employee works 100% on a single federal award or cost objective, the certification must be:
Prepared after-the-fact (dated), and
Prepared at least every 6 months (semi-annually), and
Account for total activity for which the employee is compensated; and
Signed by the employee or supervisory official having firsthand knowledge of the work performed

8. Time and Effort Reporting Documentation
Personnel Activity Report (PAR): A record maintained by an employee who works on multiple activities or cost objectives.

9. Time and Effort Reporting Documentation
Personnel Activity Report (PAR)
When an employee works on multiple activities or cost objectives, the PAR must:
Reflect an after-the-fact distribution (dated) of the employee’s actual activity, and
Be prepared at least monthly, and
Coincide with one or more pay periods, and
Account for total activity for which the employee is compensated; and
Be signed by the employee

10. Time and Effort Reporting
Personnel Activity Reports or Semi-Annual Certifications?!!! Which one?!!!

11. Time and Effort Reporting
PAR vs. Semi-Annual Certification
The key to determining the proper documentation is to understand if the employee is working on one cost objective or activity or multiple cost objectives or activities.

12. Time and Effort Reporting
PAR vs. Semi-Annual Certification
There are only four possible options to consider when determining whether to complete a semi-annual certification or personnel activity report. All possible circumstances will apply to one of the four options.

13. Time and Effort Reporting
PAR vs. Semi-Annual Certification Decision Making Tools Decision Making Rubric Decision Making Graphic

14. Time and Effort Reporting
Decision Making Rubric
Decision Making Rubric
COST OBJECTIVE
Single
Multiple
GRANT AWARDS
(or funding source)
Semi-Annual Certification
(A)
PAR
(C)
(B)
(D)

15. Time and Effort Reporting
Decision Making Graphic

16. Time and Effort Reporting Example A

17. Time and Effort Reporting Semi-Annual Certification Example
Example A: Single Award/Single Cost Objective
A sub-recipient could have an employee funded with a single federal award and working on a single cost objective.
IDEA Part B Sec. 611, a Special Education teacher works with students with disabilities ages 6-21, 100% of their time and is charged to Flowthrough grant only, semi-annual certification is required.

18. Time and Effort Reporting Example B

19. Time and Effort Reporting Semi-Annual Certification Example
Example B: Multiple Awards/Single Cost Objective
A sub-recipient could have an employee funded with more than one federal award (or funding source) working on a single cost objective, where the awards support the cost objective.
IDEA Part B Sec. 611 supports students ages 3-21 and Sec. 619 supports ages 3-5. A Special Education teacher works with students with disabilities ages 3-5 only and is charged to Flowthrough and Preschool grants, a semi- annual certification is appropriate.

20. Time and Effort Reporting
Example C

21. Time and Effort Reporting PAR Example
Example C: Single Award/Multiple Cost Objectives
A sub-recipient could have an employee funded with a single federal award and working on multiple cost objectives.
IDEA Part B, Sec. 611 requires tracking of Proportionate Share costs. A Speech Therapist provides services to public school students with disabilities and provides services to non-public school students with disabilities, a PAR is required.

22. Time and Effort Reporting
Example D

23. Time and Effort Reporting PAR Example
Example D: Multiple Awards/Multiple Cost Objectives
A sub-recipient could have an employee funded with multiple federal awards (or funding source) and working on multiple cost objectives.
IDEA Part B Sec. 611 for Other State Activities supports Transition Services (TS) and Enhancing Opportunities for Students with Disabilities (EOSD) grants. If a person works as a Transition Coordinator (TS) and a Planner Monitor (EOSD), a PAR is required.

24. Time and Effort Reporting
Estimations
Determined before services are performed do not qualify as time and effort documentation.
Comparisons & Adjustments
Adjust quarterly if actual and budgeted differ 10% or more
Adjust annually if actual & budgeted differ less than 10%

25. Time and Effort Reporting
Frequently Asked Questions
Q: What are the Program Fiscal Review requirements?
A: Must have proper Time and Effort documentation to support expenditures related to employees charged to federal grants.
Must be the correct form (PAR or Semi-annual Cert)
Must be on file for all employees charged to the grants
Must be signed after the fact, and have date of period
Must have the grant name

26. Time and Effort Reporting
Frequently Asked Questions
Q: What occurs if documentation is not on file or not in compliance during a Program Fiscal Review?
A: A finding will be written if noted during a review. Corrective Action to ensure compliance will be necessary. May result in questioned costs.

27. Time and Effort Reporting
Send questions related to IDEA Part B, Sec. 611 to: Michael Wynn, Nancy Jo Serna,