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Time and Effort (T&E) Documentation for Federal Programs
Rebecca Patterson, Grants AdministrationDavid McLaughlin, Federal Fiscal Compliance and ReportingWednesday, May 7, 2014
Introduction to T&E requirements
◦Where do T&E requirements come from?
◦What are the requirements for T&E?
Substitute system for T&E Questions?!?!
Session Overview
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Introduction to Time and Effort Requirements
◦2 CFR 225 (OMB Circular A-87)
Appendix B – Selected Items of Cost
╸ 8 – Compensation for Personal Services
H – Support of Salaries and Wages
◦OMB Circular A-133
◦Title 34 CFR 74.21 – Standards for Financial Management Systems
◦Applicable grant requirements
Where do T&E requirements come from?
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Serves as a “receipt” for payroll expenditures
Per the OMB Circular A-87, expenditures:◦Must be allowable◦Must be reasonable◦Must be allocable◦Must be adequately documented
What is the purpose of T&E documentation?
When any part of an individual employee’s salary is:
◦Charged to a federal program, or◦Used as a match for a federal program,
◦Note: Not required for contractors or vendors.
When is T&E documentation required?
Semi-annual certification◦Employees that work on a “single cost objective”
Personal Activity Reports (PAR)◦Employees that work on “multiple cost objectives”
What type of T&E documentation is required to support payroll expenditures?
Statement that individuals(s) worked solely on activities related to a single cost objective
Completed at least every six months
Signed by the employee
What is semi-annual certification?
Employer’s name Employee’s name Employee’s position Description of federal program/single cost
objective Reporting period (at least semi-annually) Statement that 100% of employee’s time worked
on the federal program/single cost objective Employee or supervisor’s signature and date
What must semi-annual certification include?
Accounts for 100% of an employee’s time (not just time worked on federal programs)
Prepared and signed at least monthly Must be completed after the fact Reflects actual work performed (not budgeted) Signed by the employee Agrees to supporting documentation
What is a Personal Activity Report (PAR)?
Frequently Asked Question (FAQ)
Instead of every six months, can the LEA prepare periodic certifications at the end of each semester?
Yes. The requirement is for time and effort to be reported at least semiannually, or twice yearly. Documenting time and effort at the end of each semester (for instance, in December and May) would meet that requirement.
Frequently Asked Question (FAQ)
What if an employee leaves before the end of the certification period?
If the employee is no longer with the LEA at the end of the designated period, the supervisor with direct knowledge of the employee’s schedule would note that the employee is no longer with the LEA on the employee signature line and then sign the certification.
Frequently Asked Question (FAQ)
We use a time card system, do we also need to do paper PARs?
No. As long as the time card system meets the requirements of PARs, no additional documents need to be created.
Schedule changes over 10% require payroll adjustment each quarter, <10% per quarter needs no changes, but all pay is adjusted to actual time spent on the program at year end.
Frequently Asked Question (FAQ) What are T&E requirements for a 100%
federally funded teacher with a stipend? An LEA would need to complete one of the following: 1) Semi-annual certification for the normal contracted
hours, and a contract specifying the type of extra-duty activities and rates of pay, and a weekly/monthly time sheet showing the actual number of hour of extra duty activities completed each period; or
2) Utilize the substitute Time and effort system, if the LEA has been approved to do so by TEA; or
3) Complete monthly Personal Activity Reports (PARS) showing all work performed.
Full consolidation of federal, state, and local funds in SWP budget (with comprehensive consolidated schoolwide plan):
Time and effort requirements: semi-annual certification for each such employee or a semi-annual certification listing all such employees with their signatures.
Schoolwide programs (SWP)
Federal consolidation—only, combining federal funds in SWP budget (or no consolidation):
Time and effort requirements: normal semi-annual/PAR rules apply.
Schoolwide programs (SWP) cont.
Programs included in Ed-Flex: - Title I, Part A (except sections 1111 and 1116)
- Title I, Parts C, D, and F - Title II, Part A, Subparts 2 and 3 - Title II, Part D, Subpart 1 - Title III, Part B, Subpart 4 - Title IV, Part A, Subpart 1 - Title V, Part A
Carl D. Perkins Vocational and Technical Education Act of 1998.
Ed-Flex
Statewide Administrative Waiver – automatic for all LEAs (including Charter Schools), no need to apply for this waiver.
Waives semi-annual Time and Effort requirements (in lieu of the semiannual certification, the employee is required to maintain signed and dated job descriptions identifying the funding source and job duties attributed to the program).
Ed-Flex
Does your organization have a locally developed and approved administrative procedures manual (APM) that includes a description of the process that personnel are required to follow with time and effort requirements?
Key questions to ask yourself:
Does the APM make clear that the PAR should be completed after-the-fact and reflect 100% of actual time spent on each activity and each fund source?
Does the APM include a sample PAR?
Key questions to ask yourself (continued)
What if an employee’s salary is being used to meet a matching requirement?
If an employees salary is used to meet a matching requirement then T&E documentation is required.
Key questions to ask yourself (continued)
Salaries charged to federal grants must be accurately recorded. Semi-annual certification
Monthly PAR
Time must be charged as worked, not as budgeted.
PARs must be submitted at least monthly.
Summary
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Substitute System for Time and Effort
Definition: “A function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred.”
Multiple funding sources may still be single cost objective
September 7, 2012, USDE Guidance: Single Cost Objective
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Employees supported by single cost objective submit semiannual certification
Regardless of whether LEA implements substitute system
September 7, 2012, USDE Guidance: Single Cost Objective
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“The key to determining whether an employee is working on a single cost objective is whether the employee’s salary and wages can be supported in full from each of the federal awards on which the employee is working, or from the federal award alone if the employee’s salary is also paid with non-federal funds.”
Determining Single Cost Objective
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Supplemental math teacher serves low-achieving students on a Title I campus
Paid half from Title I, Part A, and half from state funds
Teaching math to low-achieving students can be fully supported under Title I, Part A
This is a single cost objective.
Example I: Title I, Part A, and State Compensatory Funds
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Preschool special education teacher split-funded between IDEA sections 611 and 619
Teaching preschool special education is allowable under both sections.
This is a single cost objective.
Example II: Two Sections of IDEA-B
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State curriculum specialist develops new CTE courses and initiatives
Funded half with Perkins and half with state general funds
This is a single cost objective.
Example III: Perkins and State Funds
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Employee is an instructional coach for teachers working in two federal programs:
80% funded from Title I, Part A 20% funded from Perkins This is a multiple cost objective.
Example IV: Multiple Federal Grants
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Multiple cost objective employees may submit semiannual certification, if:
LEA submits management certification to TEA Employee completes schedule and certification Is in effect for 2012-2013 and subsequent school years
Applies to all LEAs, including ESCs and charters
New USDE Guidance (September 7, 2012)
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Form on Substitute System page (search for “Substitute System” or follow link from Grants page)
LEA must complete/submit form every school year
Form submitted by mail as specified on Substitute System page
We anticipate mailing letters by May of each year.
LEA Requirement: Management Certification
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Must currently work on a schedule that includes multiple activities or cost objectives that must be supported by monthly PARs
Must work on specific activities or cost objectives based on a predetermined, consistent schedule
May not work on multiple activities or cost objectives at the exact same time
Conditions for Employee Participation
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Employee schedule must:• Indicate specific activity/cost objective employee
worked on for each segment of employee’s schedule• Account for total hours for which each employee was
compensated during schedule period• Be completed again/resubmitted if schedule changes
by more than 10%
Employee Schedule Requirements
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Employees must complete work schedule and certification.
Schedule and certification submitted to LEA business office
Certification must be semiannual at least. Signed by employee and supervisor with
firsthand knowledge of employee’s work
Employee Schedule and Certification
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TEA developed sample employee schedule and certification form
Auto-calculating spreadsheet Includes all elements TEA auditors require LEAs not required to use TEA form If LEAs develop own form, must include all
required elements
TEA-Developed Schedule and Certification
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Spreadsheet includes instructions, schedule, and certificate
All material covered here included in instructions Read instructions first Complete schedule next Finish with certification
Demonstration of TEA Form
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Complete name, position, district, schedule period fields
Complete program table (list of programs worked on)
Identify time worked on programs each day
Demonstration of TEA Form: Schedule
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Name, position, schedule period, and district info will auto populate certification
Demonstration of TEA Form: Name
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Entered Manually
on Schedule
Populates on
Certification
Must list all programs worked on Room for eight programs, including local funds Use dropdown when possible to list programs Dropdown menu available fields A-E For other programs, manual entry fields
F and G
Demonstration of TEA Form: Programs
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Demonstration of TEA Form: Program Dropdown List
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Select SOF from
dropdown list
Demonstration of TEA Form: Manual Program Entry
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Document regular daily schedule Dropdown list for minutes worked, 15-minute
increments Manually type brief description of activity Dropdown letter list (A-H) to associate activity
with program Program list will update with total minutes
Demonstration of TEA Form: Time Worked
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Demonstration of TEA Form: Schedule Row
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Demonstration of TEA Form: Minutes Dropdown
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Select period of minutes
from dropdown
list
Demonstration of TEA Form: Activity Description
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Manually enter
activity
Demonstration of TEA Form: Associate Program by Letter
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Select SOF Code (from
above) from
dropdown list
Demonstration of TEA Form: Minutes by Program
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Demonstration of TEA Form: Schedule with Multiple Rows/Programs
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Demonstration of TEA Form: Program List with Minutes Charged to Multiple Programs
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Funding Percentages auto-calculate as time is
entered
Lunch accounted for on last row of schedule Lunch minutes are not part of program
calculation
Demonstration of TEA Form: Accounting for Lunch
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Much content of certificate autofills from schedule
Following content entered manually: Total hours worked
Total lunch hours
Fund codes
Employee signature/supervisor name and signature
Demonstration of TEA Form: Certificate
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Name, position, schedule period, and district information auto fills from schedule
Demonstration of TEA Form: Identifying Information
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Manually enter total number of hours worked Manually enter total number of lunch hours
(actual hours, rather than lunch periods) Check the following:
Total hours times 60 (a) equals total minutes
Demonstration of TEA Form: Hours
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Manual entry
Demonstration of TEA Form: Hours
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Auto filled
After entering hours, ensure (a) equals (b)
Demonstration of TEA Form: Fund Codes
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Enter the appropriate Fund Code for each SOF
USDE September 7, 2012, letter
Chief Grants Administrator section of the Grants page of TEA website
Substitute System page of TEA website (search for “Substitute System” or follow link from Grants page)
Resources and Further Information
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Copyright © Notice. The materials are copyrighted © and trademarked ™ as the property of the Texas Education Agency (TEA) and may not be reproduced without the express written permission of TEA, except under the following conditions:
1) Texas public school districts, charter schools, and Education Service Centers may reproduce and use copies of the Materials and Related Materials for the districts’ and schools’ educational use without obtaining permission from TEA.
2) Residents of the state of Texas may reproduce and use copies of the Materials and Related Materials for individual personal use only without obtaining written permission of TEA.
3) Any portion reproduced must be reproduced in its entirety and remain unedited, unaltered and unchanged in any way.
4) No monetary charge can be made for the reproduced materials or any document containing them; however, a reasonable charge to cover only the cost of reproduction and distribution may be charged.
Private entities or persons located in Texas that are not Texas public school districts, Texas Education Service Centers, or Texas charter schools or any entity, whether public or private, educational or non-educational, located outside the state of Texas MUST obtain written approval from TEA and will be required to enter into a license agreement that may involve the payment of a licensing fee or a royalty.
For information contact: Texas Education Agency, 1701 N. Congress Ave., Austin, TX 78701-1494; email: [email protected].
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