Fiscal Compliance for Title III

1. Fiscal Compliance for Title III Stephanie English, Chief Monitoring & Compliance Section School Business Division 919-807-3686 senglish@dpi.state.nc.us

2. Fiscal Compliance Items Included:  Time and Effort Documentation  Equipment records  Contracts/Invoices  Administration Limitation

3. Time and Effort • Applies to every employee funded from federal funds. • Purpose: To document that the appropriate federal program is receiving the benefit of the services supported by grant funds. • Time and Effort documentation is required by OMB Circular A-87, Attachment B, Item 8 (h), and is in addition to the standards for payroll documentation.

4. Two Types of Participating Employees: • Single Cost Objective • Multiple Cost Objectives

5. What is a Cost Objective? • A federal term referring to a grant objective. • Some federal cost objectives have corresponding state cost objectives, such as State ESL (054) and Title III (104) • Some programs that may “look like” other programs are NOT the same cost objective, such as ESL (054/104) and Migrant (051)

6. Employees Who Are Employed 100% In A Single Cost Objective Employees must have at least semi-annual certifications that they worked solely on that program. Certifications must be signed by the employee or the supervisor who has first hand knowledge of the work performed.

7. What does a “semi-annual certification” look like? • A simple statement: “I, Stephanie English, certify that I spent 100% of my time for the period of July 1, 2008, through December 31, 2008, on Title III ESL activities.” OR • A “blanket” statement signed by the supervisor with first-hand knowledge of employees’ work.

8. Multiple Cost Objective Employees • Salaries and wages must be supported by completing monthly personnel activity reports (PAR forms) unless a substitute system has been approved. • PAR Forms MUST • Reflect an after-the fact distribution of the actual activity of each employee; • Account for the total activity for which each employee is compensated; • Be prepared at least monthly and must coincide with one or more pay periods; and • Be signed by the employee.

9. What does a PAR form look like?

10. Important notes about PARs • PAR forms must be supported by more detailed documentation, such as a calendar with daily entries regarding activities supporting each cost objective • Results of PAR forms must be reconciled against payroll (usually a finance function)

11. Substitute Systems: Substitute systems for allocating salaries and wages to federal grants may be used only if approved by the cognizant agency. DPI is the cognizant agency for LEAs/Charter Schools.

12. Which LEAs are approved to use substitute systems?

13. Special Note on Schoolwide Schools • In a Title I Schoolwide School, all funds lose their identity. • Employees in a Schoolwide School may be paid from any fund source, or any combination of funding sources, and their effort statement would state “100% Title I Schoolwide School”, making a certification statement the appropriate documentation. • Employees in a Schoolwide School who are paid from federal funds are the ones who document their time and effort.

14. Equipment Federal regulations require certain records to be kept Not to be confused with “fixed assets” tracking What to track?  Items with a useful life > 1 year  Police report filed if the item “disappears”

15. Equipment Education Department General Administrative Regulations (EDGAR) 34 CFR 80.32 (d) Management requirements (1) Property records must be maintained that include…

16. Description of the property • Serial number or other identification number • Source of property • Who holds title • Acquisition date • Cost of the property • Percentage of Federal participation in the cost • Location, use, and condition • Disposition data (including date of disposal and sale price)

17. Other Equipment Management Requirements: • Physical inventory (reconciled with property records at least once every 2 years) • Control system • Adequate maintenance procedures

18. Contracts/Invoices • Contracts for personnel services MUST be specific – who, what, when, where, why. • Invoices must contain the same basic information – it is not enough to just refer to the contract number.

19. Contracts (cont’d) • Suspension/Debarment • Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. • Debarred Vendors list – State and Federal can be found at http://www.ncpandc.gov/QuickReference.html

20. Administration Limitation • Administrative Cost is limited to 2% of current year allotment • What is considered Administrative Cost? • Indirect Cost rate may result in excess Administrative cost • Unspent portion of allowable Admin expenditures can be carried forward to the next year

21. Questions?

22. Resources Federal information: OMB Circulars EDGAR http://www.ncpublicschools.org/fbs/finance/federal/

23. Contact Stephanie English, Chief Monitoring & Compliance Section 919-807-3686 senglish@dpi.state.nc.us