07/14/11
Federal Reporting
-Time & Effort-
Terry Harless, CPA
Executive Director
Internal Operations
Who and Why?
Any employee paid from federal funds.
Serves as a receipt for federal funds spent.
Why is T&E typically problematic?
A large percentage of federal funds are used for
staffing
Staff turnover
Complexity
Lack of communication
No one likes to do it
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Requirements and Guidance
Primarily OMB Circular A-87, Cost Principles for
State, Local and Indian Tribal Governments
Attachment B, Selected Items of Cost, Item 11,
compensation for personnel services
Guidance OMB Circulars –
A-21 Cost Principles for Educational Insti
A-87 Cost Principles for State, Local and Indian Tribal
Govt’s
A-110 Uniform Admin Requirement for Grants and
Agreements w Higher Ed, Hospitals & Non-Profits
A-122 Cost Principles for Non-Profit Orgs
ASMB C-10 Guide for State, Local and Indian Tribal
Govt’s
EDGAR
Memos from federal contacts
Two Types of Documentation
Employees who work solely on a single federal
cost objective complete semi-annual
certifications
Employees who work on more than one cost
objective complete monthly Personnel Activity
Reports (PARS)
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Single Cost Objective
(semi-annual documentation)
Example – I worked exclusively for a single
federal program (no set-asides)
Example – A federal program and its state/local
match
Example – A school-wide program
Multiple Cost Objective
(monthly PAR documentation)
Example – A federal program with set-asides
Example – Spends time on two different
programs
Semi-Annual Certification
Statement that an employee worked solely on
activities related to a single cost objective
Completed every six months
Signed by employee (per A-87) but highly recommend
signature by supervisor too
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WV Dept. Of Education
Time and Effort Documentation
Semi-Annual Certification
In accordance with federal guidelines, when employees work solely on a single federal award or cost objective, charges for the
employee's salary and wages must be supported by a certification signed by an employee or supervisory official having first hand
knowledge of the work performed by the employee.
I hereby cerfify that for the period of January 1, 2010 through June 30, 2010, I worked soley on the single cost objective of:
Title I Part B (example)
Employee Printed Name
Title
Employee Signature
Date
Supervisor Printed Name
Title
Supervisor Signature
Date
PAR Documentation
(multiple cost objectives)
Accounts for total time and activity
Prepared and signed at least monthly
Reflects actual work performed (not budgeted)
Should have supporting documentation
(examples-class schedule, number of students, number
of minutes)
WV Department of Education
Daily Time Record
Month/Year:
Employee:
January/
Position:
Program(s):
Week 1
Hours Worked
Sick Hours
Week 2
Annual Hours
Total
Hours Worked
Monday
Sick Hours
Annual Hours
Total
Monday
Grant
12345
0
Grant
12345
0
Grant
12346
0
Grant
12346
0
Grant
12347
0
Grant
12347
0
Grant
12348
0
Grant
12348
0
Grant
12349
0
Grant
12349
0
Tuesday
Tuesday
Grant
12345
0
Grant
12345
0
Grant
12346
0
Grant
12346
0
Grant
12347
0
Grant
12347
0
Grant
12348
0
Grant
12348
0
Grant
12349
0
Grant
12349
0
Wednesday
Wednesday
Grant
12345
0
Grant
12345
0
Grant
12346
0
Grant
12346
0
Grant
12347
0
Grant
12347
0
Grant
12348
0
Grant
12348
0
Grant
12349
0
Grant
12349
0
Thursday
Thursday
Grant
12345
0
Grant
12345
0
Grant
12346
0
Grant
12346
0
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Monthly Grand Total
Hours Worked
Sick Hours
Annual Hours
Total
Grant
12345
#REF!
#REF!
#REF!
#REF!
Grant
12346
#REF!
#REF!
#REF!
#REF!
Grant
12347
#REF!
#REF!
#REF!
#REF!
Grant
12348
#REF!
#REF!
#REF!
#REF!
Grant
12349
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
#REF!
Total
Employee's Printed Name and Title
Employee's Signature
Date
I certify that this report represents a true recording of effort expended for the period indicated and
that I have full knowledge of those activities.
Supervisor's Printed Name and Title
Supervisor's Signature
Date
WV Department of Education
Quarterly Time Record
1st Quarter (January - March)
Year
Employee
:
Position:
Program(s):
January Grand Total
Hours Worked
February Grand Total
Sick Hours
Annual Hours
Total
Grant
12345
#REF!
#REF!
#REF!
#REF!
Grant
12345
0
0
0
0
Grant
12346
#REF!
#REF!
#REF!
#REF!
Grant
12346
0
0
0
0
Grant
12347
#REF!
#REF!
#REF!
#REF!
Grant
12347
0
0
0
0
Grant
12348
#REF!
#REF!
#REF!
#REF!
Grant
12348
0
0
0
0
Grant
12349
#REF!
#REF!
#REF!
#REF!
Grant
12349
0
0
0
0
#REF!
#REF!
#REF!
#REF!
Total
0
0
0
0
Total
Hours Worked
March Grand Total
Hours Worked
Annual Hours
Total
1st Quarter Grand Total
Sick Hours
Annual Hours
Total
Grant
12345
0
0
0
0
Grant
12345
#REF!
#REF!
#REF!
#REF!
Grant
12346
0
0
0
0
Grant
12346
#REF!
#REF!
#REF!
#REF!
Grant
12347
0
0
0
0
Grant
12347
#REF!
#REF!
#REF!
#REF!
Grant
12348
0
0
0
0
Grant
12348
#REF!
#REF!
#REF!
#REF!
Grant
12349
0
0
0
0
Grant
12349
#REF!
#REF!
#REF!
#REF!
0
0
0
0
Total
#REF!
#REF!
#REF!
#REF!
Total
Sick Hours
Sick Hours
Employee's Printed Name and Title
Annual Hours
Total
Hours Worked
Employee's Signature
Date
I certify that this report represents a true recording of effort expended for the period indicated and that I have full knowledge of those activities.
Supervisor's Printed Name and Title
Supervisor's Signature
Date
PAR Reconciliations
Assumed vs actual must be compared quarterly
If the difference is 10% or more, adjustments must be
made
If the difference is less than 10%, no action is required
until year end
BUT at year end, adjustments must be made to reflect
actual time spent
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The Philadelphia Story (8th largest LEA in nation)
$138 million in FY06 federal grant
funds were either unallowable or
inadequately supported
2 ½ year audit
Most Significant Finding Time & Effort
$123 million of the $138 million (90%)
Philadelphia Defense Attendance sheet combined with
employee job description or
classroom assignment is credible
alternative documentation
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OIG Response “We disagree”
§Attendance sheets show only the amount of
time worked, not the actual activities
performed
§Employees did not always fill them out
§Supervisors did not always approve them
§Job descriptions are not adequate
supporting documentation because they only
include tasks that employees are supposed to
perform, not actual time related to tasks
§Job descriptions did not exist for all
positions paid by grant funds
Final Report ED-OIG/A03H0010
Time and Effort Certifications
We disagree that the TPERs combined with either a staff listing, classroom
assignment, or job description provides accurate and adequate supporting
documentation of an employee’s activities. TPERs document the hours an
employee works and show only the amount of time worked, not the actual
activity/activities performed. Furthermore, we could not rely on the TPERs
because during our audit we noted that PSD did not enforce its own TPER
sign-out policy. Therefore, it could not be determined how much time the
employee actually worked. Another issue we noted with the TPERs was that
they are not regularly approved by managers. As stated in the report (see
Finding No. 1, C), we reviewed 26 TPERs and found that 23 did not have an
employee sign-out time for all employees listed on the TPER and 14 were not
manually approved by the appropriate supervisor. Also, PSD was not able to
locate all the TPERs needed for our salary sample. Therefore, TPERs may not
be an accurate reflection of actual time worked, verified by appropriate
personnel or properly maintained.
Further OIG Response PARS prepared for positions funded
by multiple funding sources were
completed semi-annually, not monthly
as required by A-87
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T&E FAQ’s
Q1. Who should sign PARS?
A2. A-87 requires employee but both employee AND
supervisor is highly recommended
Q2. How do I submit 100% of my time when I only work
three days a week?
A2. If an employee works three days a week, then 60%
employed is 100% of the employee’s time
Q3. Can I use a substitute system?
A3. Possibly, but not recommended and must have
prior approval
T&E FAQ’s
Q4. What about supplemental contracts,
stipends, and overtime?
A4. Give each separate consideration
Q5. Can superintendents’ and principals’ salaries be
charged to federal programs?
A5. Usually not. Would require good documentation.
Probable supplant issue.
A6. I am 100% committed to a program but I am
occasionally asked a non-program question. And what
about time spent at the departmental staff meeting?
A6. If a brief amount of time, it is considered de
minumus and does not need captured
T&E FAQ’s
Q7.The allocation that my district gets for IDEA Part B does not
cover all the costs of the teacher and I am forced to use local
(general) funds to fully fund the position. Does this teacher
have to complete time and effort documentation because she
is paid from IDEA Part B and the general fund, even though the
teacher spends the entire time working on special education?
A7. No. A semi‐annual certification may be completed
because the teacher is working on a single cost objective,
special education program. The teacher is working within the
confines of one program and does not deviate from that
objective.
Q8. My duties always match my funding. So I don’t
need to make adjustments, right?
A8. Really? Red flag to auditors
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A Word About Terminal Leave
Terminal leave costs are not allowable as direct
charges to federal awards
Terminal leave costs include leave payouts and
subsequent employer-paid health care premiums
Terminal leave costs may be utilized as an indirect cost
though – if trackable
Indirect,
7.3%
Direct,
92.7%
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