Time and Effort Reporting: Documenting Employees’ Personnel Costs

1. Time and Effort Reporting: Documenting Employees’ Personnel Costs Kristen Tosh Cowan, Esq. ktoshcowan@bruman.com Brustein & Manasevit, PLLC Fall Forum 2011

2. THE BASICS ON KEEPING TIME ACCOUNTING RECORDS

3. Terminology • Time and attendance records • Payroll records • Worked 8:00-4:00 • Time and effort records • Time distribution records • Worked 50% on Title I administration and 50% on nonfederal

4. Who must participate? • Any employee who is working on a federal program • Not contractors • All employees paid with federal funds • Some employees paid with non-federal funds

5. A-87: If employee works 100% on single cost objective • Semi-Annual Certification • Signed every six months by supervisor or employee • “This is to certify that Kristen Cowan has worked 100% of her time for the period January 1, 2010, through June 30, 2010, on Perkins Administration.” Signature of employee: Date:

6. A-87: If employee works on multiple cost objectives • Personnel Activity Reports (PAR) • Signed every month by employee • UNLESS, using “substitute system” (then 2 or 3 times per year) • “For the month of September 2009, I spent my time 50% on Title I Program Services and 50% on non-federal programs.” Signature of Employee: Date:

7. PARs must: • After-the-fact record • Total activity for which employee compensated • At least monthly (unless substitute system) • Signed and dated by employee

8. OIG Time and Effort Findings: • 2006 – Columbus - $2.3 million • 2008 – Detroit - $49 million • 2009 – Houston - $238 million • 2010 – Philadelphia - $123 million

9. BRUSTEIN & MANASEVIT: GRANTS MANAGEMENT 101 Time and Effort Documentation QUIZ!

10. Question 1: A district administrator works approximately half time on NCLB Title I, Part A, and half on IDEA. She is required to keep: • Monthly PARs • Semi-annual certifications

11. Question 2: A district administrator works approximately half time on NCLB Title I, Part A, and half on Title I, Part C (Migrant). She is required to keep: • Monthly PARs • Semi-annual certifications

12. Question 3: A district administrator spends 100% of his time on NCLB Title I, Part A, although half of his salary is funded from non-federal sources. He is required to keep: • Monthly PARs • Semi-annual certifications

13. Question 4: A district administrator works approximately half time on NCLB Title I, Part A, and half on non-federal activities, although his salary is funded 100% from Title I, Part A. He is required to keep: • Monthly PARs • Semi-annual certifications • Bail money on hand

14. Question 5: The district’s NCLB Director works on Title I, Part A, Title II, Part A, and 21st Century. The district consolidates its NCLB administrative funds. The Director is required to keep: • Monthly PARs • Semi-annual certifications

15. Question 6: The district has a contract with an SES provider for afterschool tutoring for students. The contract is paid with Title I funds. Do the contractor’s employees need to keep time and effort records? • Yes • No

16. Question 7: Making journal voucher adjustments to accounts typically is unrelated to employees keeping time and effort records. • False • True

17. Question 8: A classroom teacher in a targeted assistance school provides Title I services and is paid with Title I, Part A funds. Just like any other federally-paid employee, she is required to keep time and effort records. • True • False

18. Question 9: A classroom teacher is paid with non-federal funds used for a match under a federal program. Because she is paid with nonfederal funding, she is not required to keep time and effort records. • True • False

19. Question 10: In a schoolwide program, a teacher is paid with Title I funds and works 100% on the schoolwide program plan. What kind of time and effort records is she required to keep? • Semi-annual certifications • Monthly PARs • It depends

20. BIG QUESTION WHAT IS A SINGLE COST OBJECTIVE???

21. What is a “Cost Objective”? • A-87 Definition: A function, organizational subdivision, contract, grant or other cost activity for which cost data are needed and for which costs are incurred.

22. Examples . . . . • A Minimum Set-Aside or Maximum Cap: • Title I- LEA Parent Involvement minimum (at least 1%); • Title III – Cap on administration (no more than 2%) • Program services • Title I program services

23. USDE Guidance: Draft Examples of Single Cost Objectives • An LEA supports a supplemental math teacher to serve low-achieving students with 50% Title I and 50% state compensatory education funds.

24. Draft Examples of Single Cost Objectives • Each elementary school has a part-time librarian 3 days/ week paid with local funds. An LEA adds 2 days/ week for its Title I schoolwide schools paid with Title I Part A funds.

25. Draft Examples of Single Cost Objectives • A preschool special education teacher is funded with 50% IDEA section 611 and 50% with IDEA section 619 funds.

26. Essential Legal Resources • OMB Circulars A-87: Cost Principles for State and Local Governments • HHS Implementation Guide for A-87: ASMB C-10 (1997) • http://rates.psc.gov/fms/dca/asmb%20c-10.pdf

27. Resources, cont. • Cost Allocation Guide for State and Local Governments (or “Green Book”) (Sept 2009) • http://www2.ed.gov/about/offices/list/ocfo/fipao/guideigcwebsite.pdf • Montana Compact • www.bruman.com • Program-specific guidance • USDE officials

28. Ideas for Reducing Burden

29. Consolidated Administration • Combine administration for all NCLB programs • NOT non-administrative activities • Single Cost Objective • Semi-annual certification • LEA needs approval of SEA

30. “Blanket” Semi-Annual Certification • Single cost objective (semi-annual cert) • Multiple employees • Signed by supervisor with first-hand knowledge (principal)

31. Schoolwide Programs • The programs included in the Schoolwide Plan constitute a single cost objective • Need for records depends on the extent of consolidation of federal, state, and local funding • Can be “conceptual” or “virtual” consolidation – not literal

32. Schoolwide time records

33. How to set up a time distribution system

34. How to set up time distribution system: 1) Plan initial funding allocations well • May use “budget estimates” for initial allocations • Supervisors need to be on board

35. CAUTION: Beware of Re-organizations!

36. 2) Develop written time distribution policies and procedures • “How to” instructions for employees • reporting vacation, travel, long-term leave • Manual for fiscal side • Frequency of comparing estimates to actual costs, handling of deviations, monitoring of system

37. 3) Train employees • On mechanics of filling out form • On which federal program cost objective they are working • Refresher training • New employee training

38. 4) Close supervision • Supervisors should be aware of deviations of effort from initial budget estimates • Be ready to redirect work of employee or adjust grant supporting salary

39. USDE “Burden Reduction” Pilot Program • USDE is soliciting ideas for pilot programs: • mechanisms for consolidating funds in schoolwide programs • time and effort reporting under A-87 • documenting compliance with other record keeping and reporting requirements

40. Submit ideas to: • Blog Post: www.ed.gov/blog/ • Email: burden.pilots@ed.gov

41. QUESTIONS??