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TIME AND EFFORT NEW FLEXIBILITY GUIDELINES
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ALLOCATING PAYROLL COSTS: TIME DISTRIBUTION Rules set out in OMB Circular A-87 Must demonstrate that employees paid with federal funds actually worked on the specific federal program Applies to all employees who are paid with federal funds
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TIME DISTRIBUTION Overview of process: Estimate how employee will work Pay based on estimate Reconcile estimates to how actually worked Necessary documentation: Payroll records Personnel activity report
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PERSONNEL ACTIVITY REPORT Must be maintained for all employees whose salaries are: Paid in whole or in part with federal funds Used to meet a match/cost share requirement
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COMPENSATION FOR PERSONNEL SERVICES Includes all compensation paid for services rendered during the award period Salaries Wages Fees Incentive awards Fringe benefits Pension costs Allowances for off-site pay Incentive pay Location allowances Hardship pay Cost of living differentials
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PAYROLL RECORDS Payroll must be: Documented Approved by a responsible official of the organization
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PERSONNEL ACTIVITY REPORT (CONT.) Must meet the following standards After the fact Account for total activity Signed by employee or supervisor with first hand knowledge Prepared at least monthly and coincide with one or more pay periods
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PERSONNEL ACTIVITY REPORT (CONT.) Time increments reported on PARs should be sufficient to recognize: Number of different activities performed The dynamics of these responsibilities
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EXAMPLE OF PERSONNEL ACTIVITY REPORT
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SUBSTITUTE SYSTEM(S) Florida currently has an substitute system in place approved in 1996 and many districts have implemented this system. In addition to our current system in place a ‘new’ option will be offered that allows employees with schedules that do not change from week to week to certify time and effort on a semi-annual basis.
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CURRENT SUBSTITUTE SYSTEM DESIGNATED REPORTING MONTHS During the designated reporting months, participating employees will be required to keep a record of the actual distribution of their time and effort. These records, or Personnel Activity Report (“PAR”) forms, will be executed by employees and collected during the 3 months your District elects.
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CURRENT SUBSTITUTE SYSTEM (CONT.) The Goals Of The Substitute System: Establishes advance allocations of employees’ time and effort on individual grant awards or cost objectives used to support the employees’ salaries and benefits. Requires employees to report the actual time and effort spent on various projects on a percentage basis for comparison with advance salary allocations. Reconciles differences between advance allocations of salary/related costs and employee reports of actual time and effort dedicated to various grant awards or cost objectives. Produces documentation which summarizes both actual employee time distribution and employee funding on an annual basis.
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CURRENT SUBSTITUTE SYSTEM (CONT.) The District’s substitute system must address the following areas: 1) participating employees 2) required personnel documentation 3) frequency of reporting 4) monitoring deviations 5)reconciliation process 6) record keeping requirements.
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CURRENT SUBSTITUTE SYSTEM (CONT.) PARTICIPATING EMPLOYEES The personnel activity reporting system will be utilized by all employees who work on two or more cost objectives where at least one cost objective is a federal award. If an employee worked on a single federal award or cost objective, the employee will not execute the PAR. The employee will execute a semi- annual certification that the employee worked solely on that program for the period covered by the certification. These certifications will be signed by the employee at least twice per year.
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CURRENT SUBSTITUTE SYSTEM (CONT.) REQUIRED PERSONNEL DOCUMENTATION Personnel Activity Reports The District should produce a Personnel Activity Report (PAR) for each participating employee. The PAR form will document the actual time spent on individual cost objectives. For each of the three reporting months of a fiscal year, each participating employee should complete a PAR containing the employee’s name, fiscal year, reporting month, and EFFORT statement. The PAR requests information on the number of actual hours worked and the program or cost objectives upon which the employee worked. Actual effort should reflect the specific program or cost objectives upon which the employee worked. The total number of hours the employee either works or takes leave should be reflected.
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CURRENT SUBSTITUTE SYSTEM (CONT.) FREQUENCY OF REPORTING Participating employees must report their actual effort in 3 months designated by the District office. When the average level of effort difference between the actual time records and the initially estimated time is more than 10% during any fiscal year, then the employees position funding should be adjusted for the following fiscal year.
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CURRENT SUBSTITUTE SYSTEM (CONT.) MONITORING DEVIATIONS Role of Supervisors The accuracy of this system is heavily dependent upon the supervisor’s oversight of the system. The consistency that individual local and federal program cost objectives pay it’s fair share for the benefits received is important equal to the level of funding. To this end, it is the responsibility of the supervisor to seriously review the reports of employees and alert the program management of any deviations.
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CURRENT SUBSTITUTE SYSTEM (CONT.) Monitoring At the end of each reporting month, the participating employee’s supervisor should review the employee(s) PAR. If the supervisor notices that the average ACTUAL EFFORT for that week deviates from the anticipated effort statement by greater than 10%, the supervisor must either redirect the efforts of the employee or bring the deviation to the attention of the appropriate division leadership to either adjust the funding source or justify not adjusting the funding source. If reason exists to questions the accuracy of the employee reporting, the supervisor should discuss the form with the employee and make any necessary adjustments.
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CURRENT SUBSTITUTE SYSTEM (CONT.) At the end of the month, each employee’s total percentage of ACTUAL EFFORT must be compared to the EFFORT statement to determine the amount of any deviations. Any deviations will be resolved through the reconciliation process and will impact future budget allocations for successive months.
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CURRENT SUBSTITUTE SYSTEM (CONT.) District’s Substitute System should provide for a reconciliation between the PAR form as completed by the employee and budgeted position funding. Thus, the PAR allows for a comparison between actual employee effort and employee funding. Employee funding as reflected on the position funding report must be consistent with the percentage breakdown of the employee’s actual time and effort.
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CURRENT SUBSTITUTE SYSTEM (CONT.) RECORD KEEPING REQUIREMENTS: PAR forms are to be maintained for a period of five years by the District Office.
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CURRENT SUBSTITUTE SYSTEM (CONT.) COST ALLOCATION PLANS FOR CERTAIN EMPLOYEES: Certain employees in the District may have ‘blended’ responsibilities that are not easily categorized as benefiting a specific federal cost objective. When it would too burdensome to categorize the work conducted by supervisory employees who oversee many different cost objectives and clerical staff serving many individuals. Therefore, the time and effort of these employees will be recorded based on a simplified cost objective, such as “supervisory activities,” or “clerical activities”.
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CURRENT SUBSTITUTE SYSTEM (CONT.) Allocation of time and effort for these employees will be made on the following basis: Supervisory Employees — Time spent by supervisory employees on purely supervisory activities will be allocated based on the time allocations on the Personnel Activity Report of the supervised employees. (For example, if a supervisor conducts only supervisory activities associated to the cost objectives for which the five or more employees work on, the supervisor’s time and effort distribution will be attributed based on an average of the same cost objectives. If the supervisor works on other - non-supervisory activity(ies) that are outside of the scope or cost objectives that the five or more employees work on, then the supervisor must list such activity(ies) and indicate the time spent.) The supervisors’ Personnel Activity Report will include Supervisory Activities and Other (non-supervisory activities ).
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CURRENT SUBSTITUTE SYSTEM (CONT.) Clerical Employees—Time spent by clerical employees who provide support for five or more employees working on many cost objectives. (For example, if a clerical employee conducts only clerical activities associated to the cost objectives for which the five or more employees work on, the clerical employee’s time and effort distribution will be attributed based on an average of the same cost objectives. If the clerical employee works on clerical activity(ies) that are outside of the scope or cost objectives that the staff they support work on, then the clerical employee must list such activity(ies) and indicate the time spent.) The clerical employees’ Personnel Activity Report will include Clerical Activities and Other Clerical Activities.
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TIME AND EFFORT UPDATE USED issued new guidance that aims to further reduce the burden of documentation requirements while also ensuring that the overall objective of time-and-effort reporting continues to be met.
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SYSTEM GUIDELINES Eligibility for ‘new’ system Currently work on a schedule that includes multiple activities or cost objectives that must be supported by monthly personnel activity reports. Work on specific activities or cost objectives based on a predetermined schedule. Not work on multiple activities or cost objectives at the exact same time on their schedule.
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IMPLEMENTATION OF SUBSTITUTE SYSTEM Implementation of the ‘new’ system (and our current system) is subject to approval by FDOE. Districts currently approved for our substitute system will be required to reapply if adding this new option.
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ACTIONS TO EASE THE BURDEN OF TIME AND EFFORT REPORTING Substitute System for Time and Effort for Employees Supported by Multiple Cost Objectives.
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SYSTEM GUIDELINES In lieu of personnel activity reports, eligible employees may support a distribution of their salaries through documentation of an established work schedule. Work schedule may be in a style or format already used by an LEA.
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SYSTEM GUIDELINES-EMPLOYEE SCHEDULES Must indicate a specific cost objective that the employee worked on for each segment of the employee’s schedule. Must account for the total hours for which each employee is compensated during the period reflected on the employees schedule. Must be certified at least semiannually and signed by the employee and a supervisor having firsthand knowledge of the work performed.
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EXAMPLE OF A FIXED WORK SCHEDULE
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EXAMPLE OF TIME- AND-EFFORT CERTIFICATION- EMPLOYEE WITH FIXED SCHEDULE
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MORE INFORMATION OR QUESTIONS Contact: Alricky Smith, CPA Director of Audit Resolution and Monitoring Phone: (850) 245-9875 E-Mail: Alricky.Smith@fldoe.orgAlricky.Smith@fldoe.org
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