1. Time Studies/Time Tracking & What’s New(s)
Public Consulting Group
Time Studies/Time Tracking & What’s New(s)
2/22/2019
National Association of State Human Services Finance Officers (HSFo)
July 28, 2014

2. Presentation Contents
Public Consulting Group
2/22/2019
Presentation Contents
“Super Circular” & Time Studies
Time Sampling Outside of State Agencies
Varying Levels of Scrutiny
Contact Information
National Association of State Human Services Finance Officers (HSFo)

3. Super Circular & Time Studies
Public Consulting Group
2/22/2019
Super Circular & Time Studies
The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards goes into effect December 26, 2014 for state agencies (
National Association of State Human Services Finance Officers (HSFo)

4. Super Circular & Time Studies
Public Consulting Group
2/22/2019
Super Circular & Time Studies
Release of the “Super Circular” brings new attention to cost allocation
No specific changes to time studies and time tracking, however:
The new circular allows for time “certification” to occur within payroll systems if the system can provide the required level of information
Look for new updates to documents such as the Public Assistance Cost Allocation Plan Review Guide, which provides much of the guidance available related to time studies
And, see slide 9 for changes related to sub recipient monitoring
National Association of State Human Services Finance Officers (HSFo)

5. Super Circular & Time Studies (con't)
Public Consulting Group
2/22/2019
Super Circular & Time Studies (con't)
Are you ready for it?
National Association of State Human Services Finance Officers (HSFo)

6. Time Sampling Outside of State Agencies
Public Consulting Group
2/22/2019
Time Sampling Outside of State Agencies
Many State agencies outsource functions to:
Child placing agencies (not for profits)
School districts
County and not for profit agencies performing case management and/or eligibility functions
OMB A-87 and “Super Circular” requirements apply:
If state staff performing the function would require a time study, non state staff require a time study as well
State staff and non-state staff most likely cannot be in the same time study
Outside agency time studies must be documented and included in cost allocation plans
Federal cognizant agencies are requiring centralized versus decentralized time studies
of the time these relationships are a sub recipient relationship
99.9%
National Association of State Human Services Finance Officers (HSFo)

7. Time Sampling Outside of State Agencies (con’t)
Public Consulting Group
2/22/2019
Time Sampling Outside of State Agencies (con’t)
Sub recipient
“Sub recipient means a non-Federal entity that receives a sub award from a pass-through entity to carry out part of a Federal program; but does not include an individual that is a beneficiary of such program. A sub recipient may also be a recipient of other Federal awards directly from a Federal awarding agency”. (Uniform Guidance )
Contract/Vendor
“Contract means a legal instrument by which a non-Federal entity purchases property or services needed to carry out the project or program under a Federal award. The term as used in this Part does not include a legal instrument, even if the non-Federal entity considers it a contract, when the substance of the transaction meets the definition of a Federal award or subaward (see § Subaward)”. (Uniform Guidance )
Another agency is performing a task on behalf of my agency
My agency buys a good or a service from another entity
National Association of State Human Services Finance Officers (HSFo)

8. Time Sampling Outside of State Agencies (con’t)
Public Consulting Group
2/22/2019
Time Sampling Outside of State Agencies (con’t)
For outside agency claiming:
An interagency agreement must be established between entities (and if public assistance agencies, documented in agency cost allocation plans per 45 CFR (b)(6))
Entity must comply with requirements of federal award and if subaward is annually above certain value will be subject to an audit
$500k through 12/26/2014 and $750k after 12/26/2014 per the Uniform Guidance
To “claim” or seek federal reimbursement for subawards, there must be a “certified public expenditure”
If passing through grant dollars, the entity may have already received the federal funds
If asking another entity to perform a task on your behalf that is not initially funded with grants, there must be a CPE to seek federal reimbursement
National Association of State Human Services Finance Officers (HSFo)

9. Time Sampling Outside of State Agencies (con’t)
Public Consulting Group
2/22/2019
Time Sampling Outside of State Agencies (con’t)
The Uniform Guidance clarifies sub recipient monitoring requirements (200.31):
“Single state agency” responsible in event of audit
Single state agencies must have documented review procedures
Interagency agreements must exist spelling out specific responsibilities
The state agency is ultimately responsible
National Association of State Human Services Finance Officers (HSFo)

10. Varying Levels of Scrutiny
Public Consulting Group
2/22/2019
Varying Levels of Scrutiny
Oversight of cost allocation plans varies, especially related to sub recipient relationships.
Why can one state agency have a plan that has not been updated since 1992 while another is compelled to update their plan for seemingly minor changes?
What is a minor change and what is not?
Do sub recipient plans need to be submitted to the federal cognizant agency or not?
When do we need interagency agreements and when don’t we?
To protect funding, all OMB A-87 (now) and Uniform Guidance (future) requirements must be met
National Association of State Human Services Finance Officers (HSFo) )

11. Public Consulting Group
2/22/2019
Contact Information
Amy Ferraro
Manager
Public Consulting Group, Inc.
(617)
National Association of State Human Services Finance Officers (HSFo)

12. Public Consulting Group
2/22/2019
Public Consulting Group, Inc.
148 State Street, Tenth Floor, Boston, Massachusetts 02109
(617) ,