Office of Special Education TIME AND EFFORT REPORTING Presenters: Michael Wynn, CFE Grants Management Certified Nancy Jo Serna, CPA Grants Management Certified 1
Jan 06, 2016
Office of Special EducationTIME AND EFFORT REPORTING
Presenters:Michael Wynn, CFEGrants Management Certified
Nancy Jo Serna, CPAGrants Management Certified
1
Time and Effort Regulations
2 CFR 225(Formally known as OMB Circular A-87)
Attachment B, Item 8h
2
Time and Effort Overview
Financial Management Requirements:•Written policies and procedures
•Staff training•Required Documentation
•Estimates and Quarterly Comparisons•Adjustments and Revisions
3
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.
4
Time and Effort Reporting Definition
Cost ObjectiveA function, organizational subdivision,
contract, grant, or other activity for which cost data are needed and for
which costs are incurred.
5
Time and Effort Reporting Documentation
Semi-Annual Certification:A certification that the employee worked solely
on a single Federal award or cost objective (activity).
6
Time and Effort Reporting Documentation
Semi-Annual CertificationWhen 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
7
Personnel Activity Report (PAR): A record maintained by an employee who works on multiple activities or
cost objectives.
8
Time and Effort Reporting Documentation
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
9
Time and Effort Reporting
10
• Personnel Activity Reports or Semi-Annual Certifications?!!! Which one?!!!
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.
11
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.
12
Time and Effort Reporting
PAR vs. Semi-Annual CertificationDecision Making Tools
Decision Making RubricDecision Making Graphic
13
Time and Effort Reporting
Decision Making Rubric
14
Decision Making Rubric
COST OBJECTIVE
Single Multiple
GRANT AWARDS(or funding
source)
SingleSemi-Annual Certification
(A)
PAR(C)
MultipleSemi-Annual Certification
(B)
PAR(D)
Time and Effort ReportingDecision Making Graphic
15
Time and Effort ReportingExample A
16
Time and Effort ReportingSemi-Annual Certification ExampleExample 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.
17
Time and Effort ReportingExample B
Example B
18
Time and Effort ReportingSemi-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.
19
Time and Effort ReportingExample C
20
Time and Effort ReportingPAR 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.
21
Time and Effort ReportingExample D
22
Time and Effort ReportingPAR 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.
23
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%
24
Time and Effort ReportingFrequently 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
25
Time and Effort Reporting
Frequently Asked QuestionsQ: 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.
26
Time and Effort ReportingSend questions related to IDEA Part B, Sec. 611 to:
Michael Wynn, [email protected]
Nancy Jo Serna, [email protected]
27