West Virginia Department of Education
Offices of Title I and Title II
Effective Date: July 1, 2011
Procedures for Time and Effort
Legal Requirements
The federal government provides information on tracking consolidated
administration costs for the purposes of time distribution under Office of
Management and Budget Circular A-87. Time distribution requirements relate to
the allow ability of using federal funds to support employee salaries. In order to
charge the salary of an employee to a federal program, an agency must be able
to show that an employee worked on that specific federal program or “cost
objective”. As quoted in part from OMB Circular 87, “Where employees work on
multiple activities or cost objectives, a distribution of their salaries or wages will
be supported by personnel activity reports. Such documentary support is
required where employees work on more than one federal grant.” “Personnel
activity reports must meet the standards stated in OMB Circular 87 Section
(h)(5)(a-e). Under federal requirements, all employee compensation charged to
federal grants must be reasonable, necessary and allowable activities of the
grant program. Such compensation must also be consistent with that charged for
similar work in other activities of the district. Furthermore, Title I Part A grants are
subject to statutory provisions which require that federal funds supplement and
not supplant nonfederal funding sources.
Applicability
The standards apply to employee compensation for employees whose salaries
and wages are charged directly or indirectly to federal awards, or are used in
meeting cost sharing or matching requirements of federal awards. Time
distribution records must be maintained by employers to prove the employee
spent sufficient time working on the federal program. Such documentation
includes payroll records in accordance with the practice of the district. The
percentage of costs of an employee’s salaries and wages charged to a federal
award may not exceed the percentage of time the employee actually worked on
the allowable activities associated with the award. The Circular requires written
and certified, after-the-fact documentation of how each employee spent his/her
compensated time. This additional documentation is commonly referred to as
“Time and Effort Documentation.”
Time and Effort Documentation
The time and effort documentation will vary based on the number of “cost
objectives” to which an employee’s time is charged. Time and effort
documentation is required for each separate cost objective. A cost objective is
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defined as the work activities that are allowable under the terms and conditions
of the funding source. There are two types of time and effort reports: one that
documents single cost objective and one that documents multiple cost objectives.
According to Circular A-87, employees working under multiple cost objectives,
(2 or more funding sources), are required to submit monthly activity reports
indicating the amount of time spent for each funding source. Employees working
under single cost objectives, (1 funding source), are required to submit semi
annual certification. Semi-annual certifications and Time and Effort
Documentation should meet the following standards:
 Semi-Annual Certifications must:
o
State that the employee worked solely on activities related to a particular cost
objective for a specified period of time, identify the cost objective and specify the
reporting period covered.
o
Be signed and dated by the employee or a supervisor with first-hand knowledge
of the work performed at least semi-annually, after the work has been completed.
 Time and Effort documentation must:
o
Account for the total activity for which each employee is compensated (i.e., all
hours worked, not simply hours worked on a federal award).
o
Be prepared at least monthly and coincide with one or more pay periods.
o
Be signed by the employee (districts may want to also require a supervisor
signature for internal control purposes).
o
Reflect an after-the-fact distribution of the actual work activity of each employee.
Estimated vs. Actual Reporting
Employee salaries and wages may be assigned to federal grants initially on the
basis of budget or other estimated distribution percentages, determined before
the services are performed. The method used to establish the estimates should
produce reasonable approximations of the actual employee time distributions that
are subsequently reported. Estimates do not qualify as “Time and Effort
Documentation” and may not be used in lieu of time and effort reports. When
estimates are used; districts must compare actual costs based on monthly time
and effort reported, to the estimates used for coding payroll expenditures. This
must occur at least quarterly.
If the comparison shows that the difference between costs based on actual time
reported, and payroll expenditures based on estimated time is 10 percent or
greater, the district must do two things. First, it must adjust the accounting
records to reflect costs of the reported actual time. Second, in order to minimize
future differences, the estimated distributions used to charge payroll for the
following quarter must be changed to reflect the reported actual distributions of
the previous quarter.
Reviewed and revised by the COP – April 2011
Examples of Cost Objectives
A federal award is equal to a single cost objective:
Example: A teacher providing only Title I services 100 percent of the day is
charged 100 percent to Title I, Part A.
Time and Effort Reporting Required: Semi-annual certification.
A federal award is equal to multiple cost objectives:
Example 1: A program director works on Title I, Part A and the district Pre-K
activities. The director is responsible for the district-wide administration of both
programs. To capture the cost of time spent on required activities for each
program, the district must distinguish the cost of salary paid for required state
Pre-K activities from salary paid for Title I activities. To do this, each month the
employee tracks and reports the time spent on each of the two cost objectives,
(1) Title I, Part A activities; and (2) Pre-K activities.
Time and Effort Reporting Required: Time and Effort Documentation, at least
monthly.
A Schoolwide Program equals a single cost objective:
Example 1: Since a Schoolwide Program may be treated as a single cost
objective, all Title I funded teachers providing services to students under the
Schoolwide Plan 100 percent of the time reports that time as a single cost
objective.
Time and Effort Reporting Required: Semi-annual certification. Two separate
federal programs as multiple cost objectives:
Example: The teacher provides services as follows: 50 percent to special
education students under federal IDEA, Part B and 50 percent to Title I students
under Title I, Part A. Since the two fund sources are intended for different
purposes, the teacher reports to two cost objectives.
Time and Effort Reporting Required: Time and Effort Documentation, at least
monthly.
Supplemental Contracts, Stipends, and Extra Hours
OMB Circular A-87 requires time and effort reporting to account for the total
activity for which each employee is compensated. There is no minimum pay level
below which the employee time and effort requirement is waived. However,
activities performed under a supplemental contract, stipend, or authorization for
extra hours are over and above the scope of the employee’s normal employment
contract or agreement. Therefore, for purposes of reporting time and effort,
primary employment contracts or agreements and these additional employment
contracts or agreements may be considered separately. Sign in sheets should be
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maintained for professional development or any activity for which the participants
receive a stipend.
Examples
Example 1: Under a regular 200-day contract a teacher works only on a state
teaching assignment; therefore, his/her salary is charged only to state funds. No
time and effort reporting is required for this teacher under the primary
employment contract because compensation earned under the contract is not
charged to any federally-funded cost objective.
Time and Effort Required: None.
Example 2: Using the example above, the teacher enters into a supplemental
contract with the district to provide Title I, Part A supplemental instruction after
school. This work is charged to federal Title I, Part A funds. For time and effort
purposes, the supplemental contract and regular contract are considered
separately. The teacher reports time and effort only for the work performed under
this supplemental contract.
Time and Effort Required: Time and Effort Documentation required monthly or
in accordance with pay periods.
Following are some suggestions for documenting time and effort for
supplemental contracts, stipends, and extra hours.

Sign-in/attendance logs approved by a program director may be used as
time and effort documentation for extra hour pay related to a single cost
objective (e.g., pay for professional development activities under Title I
Part A or Title II, Part A – Highly Qualified Teachers).

Employee timesheets that specify the cost objective and are approved by
the supervisor may be used as time and effort documentation for extra
hour pay.

A signed supplemental contract or stipend that stipulates specific single
cost objective work activities may only be used as time and effort
documentation as long as the employee and/or immediate supervisor
provides an after-the-fact certification that the work was performed.

Multiple cost objective supplemental contracts/stipends must be supported
by employee time and effort records documenting actual time spent on
each objective (e.g., a supplemental contract to administer a summer
school program serving eligible Title I and special education students may
be charged to Title I and special education funds only to the extent that
such pay is supported by a time and effort report of actual hours worked
on each program).
Sample time and effort forms are available on the WVDE Title I website at this
link: http://wvde.state.wv.us/titlei/fi_tae.html
Reviewed and revised by the COP – April 2011
Time and Effort Documentation for
Title I Part A Schoolwide Projects
I, (principal name), hereby certify that for the period (month, day,
year) through (month, day, year) the following employees at (name of
school building) worked solely on activities allowable under Title I Part
A and approved in our schoolwide program.
(Employee
here if it is
(Employee
(Employee
(Employee
(Employee
name) - signature - may want to indicate funding sources
not all Title I (e.g. 50% Title I 50% state)
name) - signature_______________
name) - signature_______________
name) - signature_______________
name) - signature_______________
Principal’s signature ____________________________Date ______
Federal program director signature________________ Date______
Note: The only teachers that must sign in a schoolwide building are
those funded with federal funds, either Title I funds and/or IDEA
funds (or other federal funds if applicable (e.g. Title II for class size
reduction teachers).
Reviewed and revised by the COP – April 2011
Time and Effort Documentation for Dual Funded Personnel
Name :
_____________
Day of
Month
Month: __________
Year: _________
Number of hours worked by funding source
Total
Number of
Hours
Title I
Title II
State
Other:
1
0
2
0
3
0
4
0
5
0
6
0
7
0
8
0
9
0
10
0
11
0
12
0
13
0
14
0
15
0
16
0
17
0
18
0
19
0
20
0
21
0
22
0
23
0
24
0
25
0
26
0
27
0
28
0
29
0
30
0
31
0
Total
Hours
0
0
Reviewed and revised by the COP – April 2011
0
0
0
Performance Task
Verification of Time and Effort
For employees working under multiple cost objectives, (2 or more funding
sources), monthly activity reports indicating the amount of time spent for each
funding source must be submitted to the immediate supervisor for signature.
Employees working under single cost objectives, (1 funding source), are required
to submit semi annual certification. Copies of these documents shall be on file in
the LEA Title I office and the LEA federal programs office. Records for
documenting time and effort must be maintained and readily available for review
during financial audits and available for review during ESEA monitoring.
Reviewed and revised by the COP – April 2011