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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 [email protected] [email protected] [email protected] 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: 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: 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: 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: [email protected] [email protected] [email protected] Thank you!