E.F.F.O.R.T.
Every Federal Fish Ought to Report
Time
Presented by Julia Clay, Monica Ornelas & Crystal Hernandez
Federal & State Programs
Ector County ISD
432.456.8769
Julia.clay@ectorcountyisd.org
Monica.ornelas@ectorcountyisd.org
Crystal.hernandez@ectorcountyisd.org
Agenda
Grant Administration
Legal Framework
Approved Application
Support in Planning & Effectiveness
Audit Reviews
Sound Management Practices
Time and effort Processes
Job Description, Semi-Annual Processes
Questions & Answers
E.F.F.O.R.T.
Make a list of positions you currently fund out of Title
One, Title Two, & Title Three. (211/263/212/255)
List extra duty pay you might fund out these accounts as
well.
Think about the following fund sources too:
IDEA B,
Carl Perkins
Food Service
State Compensatory Education funds
Legal Framework
 6 guide posts for federal grant administration:
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Federal Law
OMB, Circular A- 87 guidance
TEA, NCLB Consolidated Program Guidance
Federal Application for Funding
State & Local Policy Guidance
Federal & State Audits
Federal Law
 NCLB was enacted in 2002 by President George Bush
as a reauthorization of 1965 passing of the
Elementary Secondary Education Act, under Title One,
Part A Statute: Section 1112, reference Local Education
Agency Plans (LEA).
 34 CFR 80.20 & 2 CFR 225 (Code of Federal
Regulations)
 http://www.tea.state.tx.us/index4.aspx?id=4269&me
nu_id=798
OMB Circular A-87
 The Federal OMB dictates federal cost principles for
determining allowable costs.
 Section 8 of OMB Circular A-87 speaks to personnel.
Side by Side Comparison
There are three sections to the OMB, Circular Cost Principles:
1 for non-profit organizations- A-122
1 for colleges and universities- A-21
1 for public schools, ESC’s and open enrollment charter schools- A87
http://ritter.tea.state.tx.us/opge/grantdev/adminresources/CostPrin
ciples_sidebyside_021208.pdf
Personnel
TEA Program Guidance
 Where to find program guidance:
 Federal Application for funding-within each section of
the TEASE NCLB Consolidated Application for funding,
you can select “Program Guidelines”
 On TEA’s NCLB Home Page:
 http://www.tea.state.tx.us/index4.aspx?id=4261&menu_
id=798
 You can select each quick link bar, by program for
program guidance, statute, and other requirements.
State Education Policy Guidance
 If you are required to provide a service by state law,
you may not charge the service to federal dollars.
Texas Education Code is located:
 http://www.capitol.state.tx.us/
 If your local policy dictates that you provide a service,
you may not charge the service to federal dollars.
Approved Application
 BS 6101 of EGRANTS application should support all
payroll.
 Planning pages should reflect the need for the
payroll. PS 3101.
 For state funded positions, your comprehensive
needs assessment, and campus/ district plan should
provide support for your planning with state funds.
Remember, Your District & Campus
Plan,
Support your federal expenditures:
If you don’t have it your campus/district plan and
comprehensive needs assessment, you should not
spend your federal money on it.
Monitor and Adjust
Monitor progress and adjust budget and
Campus Improvement Plan during the year.
• When you amend your budgets, amend your
CIPs/DIP.
• Involve staff in budget plan adjustments.
Keep documentation of meeting notes, agendas, sign
in’s, emails, etc. to justify changes to plans.
Key Audit Findings that support
T&E
OIG Audit Report, Harvey
Public Schools
TEA Audit Report, Ector County
Sound Management Practices
Each LEA, in recognition of its own unique
combination of staff, facilities, and experience, will
have the primary responsibility for employing
whatever form of organization and management
techniques may be necessary to assure proper and
efficient administration of Federal funds.
Regulations: Auditor Guidance
If a position is not in your comprehensive needs
assessment, it cannot be in the campus/district
improvement plan.
• If a position is not in your campus/district
improvement plan, it cannot be in your budget plan
or application.
• If a position is not budgeted for and included in
your approved application, you cannot charge that payroll.
Requirements
Documentation must be maintained which clearly
demonstrates the supplementary nature of the
federal funds and/or activities, as appropriate.
Documentation might include ledgers or budgets
reflecting amount of state and local funds vs. federal
funds for current and preceding years .
Documentation must be produced that demonstrates
procedurally how you manage grant funds.
What auditors will ask to
see:
Written policies and procedures that stipulate the
reporting requirements for time and effort in
accordance with the OMB Circular A-87.
• Payroll records, including authorization forms,
deduction authorizations, direct deposit applications,
leave reports, time and attendance reports.
Other documents auditors will
want to see:
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Personnel files, including employment applications,
employment contracts, employee service records,
certificates, licenses, permits, criminal background
checks and work schedules.
Time and Effort Documentation
 Why is it so important to:
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To keep time and effort uniform
To have time and effort completed monthly
To ensure correct information is provided
To have the approval of both the employee and
supervisor
Job Descriptions
 It is a description of the employee’s duties .
 You must ensure that the description aligns to every
job duty the employee has.
 Job descriptions should include supplemental funding
sources and should align to program goals of the
funding.
 If staff changes positions midyear, their job
descriptions should be signed for their new duties.
Keeping up with job descriptions
 You must have every job description signed.
 Communication is key with other stakeholders.
 Having a system in place to check, recheck and
continually monitor job descriptions is important.
Semi-Annual Certifications
 Ed Flex Waiver applies for Texas, however, we ask for
them anyway- due to auditor’s requesting them.
 Signed “after the fact” twice a year.
Questions?
 Our contact information is as follows:
 Federal State Program Office #432.456.8769
 Email: julia.clay@ectorcountyisd.org
monica.ornelas@ectorcountysid.org
crystal.hernandez@ectorocountyisd.org
Thank you!