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Time and Effort ReportingTime and Effort ReportingLessons Learned: Lessons Learned:

Problems and Potential SolutionsProblems and Potential Solutions

Helga GreenfieldAssociate Vice President for College Relations and

Director of Title III & Government Relations

June 18, 2013

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Top Findings OIG and other auditing agencies indicate that Time and

Efforts represent the largest audit findings OIG and other auditing agencies indicate that Time and

Efforts represent the largest audit findings

Examples of Top Findingso No certification of effort reportso Kept wrong document o Dated before time period endso No after-the-fact confirmation from the appropriate

persono Too vague in description “federal program”o Does not account for total compensationo Variances between effort report and billed salaries not

resolvedo Pre-populated formso Completed how paid versus employee workedo No policy on effort reporting-continual late reportso Effort reports not maintainedo Timesheets not signed

o No certification of effort reportso Kept wrong document o Dated before time period endso No after-the-fact confirmation from the appropriate

persono Too vague in description “federal program”o Does not account for total compensationo Variances between effort report and billed salaries not

resolvedo Pre-populated formso Completed how paid versus employee workedo No policy on effort reporting-continual late reportso Effort reports not maintainedo Timesheets not signed

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Why? If federal funds used for salaries, then time distribution

records are required.

Must demonstrate – If employee paid with federal

funds, then employee worked on that specific federal

program/cost objective.

If federal funds used for salaries, then time distribution

records are required.

Must demonstrate – If employee paid with federal

funds, then employee worked on that specific federal

program/cost objective.

Necessary

Reasonable

Allocable

Adequately Documented

Necessary

Reasonable

Allocable

Adequately Documented

All Circulars have Federal Cost Principals

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Who Must Participate?

Not contractors Not contractors

Any Employee who is working on a federal program

All employees paid with federal funds All employees paid with federal funds

Some employees paid with non-federal funds Some employees paid with non-federal funds

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OMB Circular A-21:Institutions of Higher Education

Plan confirmation: Budgeted allocations for professional/professorial staff; updated to reflect any significant changes in actual work

Plan confirmation: Budgeted allocations for professional/professorial staff; updated to reflect any significant changes in actual work

Multiple confirmation Records: variety of records kept in combination at least monthly

Multiple confirmation Records: variety of records kept in combination at least monthly

After-the-Fact Activity Reports: Professional/Professorial staff keep records every 6 months All other employees keep monthly records Signed by employee, principal investigator, or responsible

official using suitable means of verification Must reflect activity applicable to each sponsored agreement

and to each category needed to identify F&A Costs

After-the-Fact Activity Reports: Professional/Professorial staff keep records every 6 months All other employees keep monthly records Signed by employee, principal investigator, or responsible

official using suitable means of verification Must reflect activity applicable to each sponsored agreement

and to each category needed to identify F&A Costs

More flexible rules and more discretion for professorial and professional staff

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OMB Circular A-21:Institutions of Higher Education (cont.)

Any grant, contract or other agreement between the institution and the Federal Government.

Any grant, contract or other agreement between the institution and the Federal Government.

Facilities – as depreciation and use allowance, interest on debt associated with certain building, equipment and capital improvements, operation and maintenance expenses and library expenses

Administration – general administration and general expenses, departmental administration, sponsored projects administration, student administration and services, and all other types of expenditures not listed specifically under one of the subcategories of Facilities.

Facilities – as depreciation and use allowance, interest on debt associated with certain building, equipment and capital improvements, operation and maintenance expenses and library expenses

Administration – general administration and general expenses, departmental administration, sponsored projects administration, student administration and services, and all other types of expenditures not listed specifically under one of the subcategories of Facilities.

What is a sponsored agreement:

Facilities and Administration (F&A) Costs:

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Awareness and Training

May use “budget estimates” for initial allocations Supervisors need to be on board

May use “budget estimates” for initial allocations Supervisors need to be on board

1. Plan initial funding allocations well

How to set up time distribution system:

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

“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

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Awareness and Training

On mechanics of filling out form On which federal program cost objective they are working Training & Refresher training New employee training

On mechanics of filling out form On which federal program cost objective they are working Training & Refresher training New employee training

3. Train employees

Supervisors should be aware of deviations of effort from initial budget estimates

Be ready to redirect work of employee or adjust grant supporting salary

Supervisors should be aware of deviations of effort from initial budget estimates

Be ready to redirect work of employee or adjust grant supporting salary

4. Close supervision

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Reasons for Audits

Adequacy of internal controls to ensure salaries and wages are allowable, allocable and reasonable Simply questioning the allowability of costs is not enough to

assure appropriate accountability for federal dollars

Goal is to help institutions recognize weak internal controls and to strengthen them so that future funding will be better managed

Overall, the intention is to assess the adequacy of the College or University’s effort reporting

Adequacy of internal controls to ensure salaries and wages are allowable, allocable and reasonable Simply questioning the allowability of costs is not enough to

assure appropriate accountability for federal dollars

Goal is to help institutions recognize weak internal controls and to strengthen them so that future funding will be better managed

Overall, the intention is to assess the adequacy of the College or University’s effort reporting

Audit Focus:

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THANK YOUTHANK YOU