Transcript Helga Greenfield June 18 2013

Time and Effort Reporting
Lessons Learned:
Problems and Potential Solutions
Helga Greenfield
Associate Vice President for College Relations and
Director of Title III & Government Relations
June 18, 2013
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Top Findings
 OIG and other auditing agencies indicate that Time and
Efforts represent the largest audit findings
Examples of Top Findings
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No certification of effort reports
Kept wrong document
Dated before time period ends
No after-the-fact confirmation from the appropriate
person
Too vague in description “federal program”
Does not account for total compensation
Variances between effort report and billed salaries not
resolved
Pre-populated forms
Completed how paid versus employee worked
No policy on effort reporting-continual late reports
Effort reports not maintained
Timesheets not signed
Why?
 If federal funds used for salaries, then time distribution
records are required.
 Must demonstrate – If employee paid with federal
funds, then employee worked on that specific federal
program/cost objective.
All Circulars have Federal Cost Principals
 Necessary
 Reasonable
 Allocable
 Adequately Documented
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Who Must Participate?
Any Employee who is working on a federal program
 Not contractors
 All employees paid with federal funds
 Some employees paid with non-federal funds
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OMB Circular A-21:
Institutions of Higher Education
More flexible rules and more discretion for professorial and professional staff
 Plan confirmation: Budgeted allocations for
professional/professorial staff; updated to reflect any
significant changes in actual work
 Multiple confirmation Records: variety of records kept in
combination at least monthly
 After-the-Fact Activity Reports:
 Professional/Professorial staff keep records every 6 months
 All other employees keep monthly records
 Signed by employee, principal investigator, or responsible
official using suitable means of verification
 Must reflect activity applicable to each sponsored agreement
and to each category needed to identify F&A Costs
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OMB Circular A-21:
Institutions of Higher Education (cont.)
What is a sponsored agreement:
 Any grant, contract or other agreement between the
institution and the Federal Government.
Facilities and Administration (F&A) Costs:
 Facilities – as depreciation and use allowance, interest on
debt associated with certain building, equipment and capital
improvements, operation and maintenance expenses and
library expenses
 Administration – general administration and general
expenses, departmental administration, sponsored projects
administration, student administration and services, and all
other types of expenditures not listed specifically under one
of the subcategories of Facilities.
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Awareness and Training
How to set up time distribution system:
1. Plan initial funding allocations well
 May use “budget estimates” for initial allocations
 Supervisors need to be on board
2. Develop written time distribution policies and
procedures
 “How to” instructions for employees
 Reporting vacation, travel, long-term leave
 Manual for fiscal side
 Frequency of comparing estimates to actual costs, handling of
deviations, monitoring of system
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Awareness and Training
3.
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Train employees
On mechanics of filling out form
On which federal program cost objective they are working
Training & Refresher training
New employee training
Close supervision
 Supervisors should be aware of deviations of effort from
initial budget estimates
 Be ready to redirect work of employee or adjust grant
supporting salary
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Reasons for Audits
Audit Focus:
 Adequacy of internal controls to ensure salaries and wages
are allowable, allocable and reasonable
 Simply questioning the allowability of costs is not enough to
assure appropriate accountability for federal dollars
 Goal is to help institutions recognize weak internal controls and to
strengthen them so that future funding will be better managed
 Overall, the intention is to assess the adequacy of the College or
University’s effort reporting
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THANK YOU
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