Time and Effort
Documentation for
Federal Programs
David McLaughlin, Federal Fiscal Compliance
and Monitoring
James Connolly, Grants Administration
Thursday, May 9, 2013
Session Overview

Introduction to T&E requirements
◦ Where do T&E requirement come from?
◦ What are the requirements for T&E?
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Substitute system for T&E
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Questions?!?!
Introduction to Time and Effort
Requirements
Where do T&E requirements come from?
◦ 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
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What is the purpose of T&E documentation?

Serves as a “receipt” for payroll expenditures
When is T&E documentation required?

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.
What type of T&E documentation is required
to support payroll expenditures?

Semi-annual certification
◦ Employees that work on a “single cost objective”

Personal Activity Reports (PAR)
◦ Employees that work on “multiple cost objectives”
What is semi-annual certification?



Statement that individuals(s) worked solely on
activities related to a single cost objective
Completed at least every six months
Signed by the employee or supervisor with firsthand knowledge of work performed
What must semi-annual certification
include?

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Employer’s name
Employee’s name
Employee’s position
Description of federal program/single cost
objective
What must semi-annual certification include
cont.?



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 is a Personal Activity Report (PAR)?



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Accounts for 100% of an employees 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
Key questions to ask yourself?

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 cont.?

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?
What is an employees 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
Summary

Salaries charged to federal grants must be
accurately recorded
◦ Semi-annual certification
◦ Monthly PAR
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
Time must be charged as worked, not as
budgeted

PARs must be submitted at least monthly
Substitute System for
Time and Effort
What Is Time-and-Effort (T&E) Reporting?

Paying only proportionate share of personnel
costs with federal funds

Salaries charged to federal funds? Time
distribution records required

Contractors not subject to time-and-effort
requirements

Two types of records:
◦ Semiannual certification
◦ Personnel activity report (PAR)
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Semiannual Certification Requirements
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After-the-fact record (dated)
Accounts for total compensated activity
Completed at least every six months
Signed by supervisor with knowledge of
employee
Coincides with one or more pay periods
Traditionally applied to employees supported by
a single cost objective
PAR Requirements
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

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After-the-fact record (dated)
Accounts for the total activity for which
employee compensated
At least monthly
Signed by the employee
Must coincide with one or more pay periods
Traditionally applied to employees supported by
multiple cost objectives
September 7, 2012, USDE Guidance: Single
Cost Objective
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
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
Determining Single Cost Objective
“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.”
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Example I: Title I, Part A, and State Funds
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Supplemental math teacher serves lowachieving 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
Example I: Title I, Part A, and State Funds
(Cont’d)
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
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Single cost objective
Only a semiannual certification is required,
despite federal/state funding split
Example II: Two Sections of IDEA-B
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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.
Single cost objective
Only a semiannual certification is required,
regardless of multiple federal awards
Example III: Perkins and State Funds
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State curriculum specialist develops new CTE
courses and initiatives
Funded half with Perkins and half with state
general funds
Single cost objective
Only a semiannual certification is required,
regardless of split between federal and state
funds
What Are Multiple Cost Objectives?
Employee works on:
 Multiple federal awards (not meeting single cost
objective definition)
 Federal and non-federal awards (again, not
meeting definition)
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What Are Multiple Cost Objectives? (Cont’d)
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Indirect/direct cost activities
Multiple indirect activities allocated using
different allocation bases
Unallowable activity and direct or indirect cost
activity
New USDE Guidance (September 7, 2012)
Multiple cost objective employees may submit
semiannual certification, if:
◦ LEA submits management certification to TEA
◦ Employee completes schedule and certification
◦ Is in effect for entire 2012-2013 school year
Applies to all LEAs, including ESCs and charters
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Ed-Flex Waiver
Substitute system does not affect Ed-Flex.
LEA Requirement: Management Certification
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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
Due September 6, 2013, for 2013-2014
We anticipate mailing letters for 2013-14 by May
17, 2013.
Conditions for Employee Participation
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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
Employee Schedule Requirements

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
compensated during schedule period
• Be completed again/resubmitted if schedule changes
by more than 10%
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Employee Schedule and Certification

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

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TEA-Developed Schedule and Certification
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
TEA developed sample employee schedule and
certification form

Auto-calculating spreadsheet
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Includes all elements TEA auditors require
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LEAs not required to use TEA form

If LEAs develop own form, must include all
required elements
Demonstration of TEA Form
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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: Schedule
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
Complete name, position, district, schedule
period fields
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Complete program table (list of programs
worked on)

Identify time worked on programs each day
Demonstration of TEA Form: Name

Name, position, schedule period, and district
info will auto populate certification
Entered
Manually
on
Schedule
Populates
on
Certification
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Demonstration of TEA Form: Programs
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
Must list all programs worked on
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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: Program
Dropdown List
Select SOF
from
dropdown list
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Demonstration of TEA Form: Manual
Program Entry
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Demonstration of TEA Form: Time Worked
42

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: Schedule Row
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Demonstration of TEA Form: Minutes
Dropdown
Select
period of
minutes
from
dropdown
list
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Demonstration of TEA Form: Activity
Description
Manually
enter activity
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Demonstration of TEA Form: Associate
Program by Letter
Select SOF
Code (from
above) from
dropdown list
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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
Funding Percentages
auto-calculate as time
is entered
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Demonstration of TEA Form: Accounting for
Lunch
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
Lunch accounted for on last row of schedule

Lunch minutes are not part of program
calculation
Demonstration of TEA Form: Certificate

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
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Demonstration of TEA Form: Identifying
Information

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Name, position, schedule period, and district
information auto fills from schedule
Demonstration of TEA Form: Hours

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
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Demonstration of TEA Form: Hours
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Demonstration of TEA Form: Fund Codes
55
Enter the appropriate
Fund Code for each
SOF
Resources and Further Information
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
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)
Questions?
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