Transcript Slide 1

Time and Effort Reporting:
Documenting Employees’
Personnel Costs
Tiffany R. Winters, Esq.
[email protected]
Brustein & Manasevit, PLLC
Spring 2012 Forum
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Federal Cost Principles
OMB Circulars
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A-21 Institutions of Higher Education (2 C.F.R. 220)
A-87 State, Local & Indian Tribal Governments
(2 C.F.R. 225)
A-122 Non-Profit Organizations (2 C.F.R. 230)
For Profits: Title 48 C.F.R Part 31
Located at:
http://www.whitehouse.gov/omb/circulars_default
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Why?
All Circulars have Federal Cost Principals –
Documentation is required under OMB Circulars!!!
-
-
Necessary
Reasonable
Allocable
Net of Applicable Credits
Total the Actual Cost of the Item (Composition of Cost)
Consistently Treated
Incurred in Accordance with GAAP
Adequately Documented
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THE BASICS
ON KEEPING TIME
ACCOUNTING RECORDS
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Terminology
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Time and attendance records
Payroll records
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Worked 8:00am-4:00pm
Time and effort records
Time distribution records
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OMB Circular A-87:
Compensation for Personnel Services:
 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.
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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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The A-87 Rules!!
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A-87: If employee works
100% on single cost objective
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Semi-Annual Certification
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Completed at least every six months
Signed by a supervisor with knowledge or
the employee
After-the-fact record (dated)
Accounts for the total activity for which
employee compensated
Must coincide with one or more pay
periods
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A-87: If employee works
100% on single cost objective
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Semi-Annual Certification
“This is to certify that Tiffany Winters
has worked 100% of her time for the
period July 1, 2011, through
December 31, 2011, on Title I Admin.”
Signature of employee:
Date:
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A-87: If employee works on
multiple cost objectives
Personnel Activity Reports
 After-the-fact record (dated)
 Accounts for the total activity for which
employee compensated
 At least monthly
(unless substitute system)
 Signed by the employee
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Must coincide with Brustein
one &or
more
pay
periods
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A-87: PARs
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Personnel Activity Reports (PAR)
“For the month of December 2011, I,
Tiffany Winters, spent my time 50% on
Title I Program Services and 50% on
non-federal programs.”
Signature of Employee:
Date:
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BRUSTEIN & MANASEVIT:
GRANTS MANAGEMENT 101
Time and Effort
Documentation
QUIZ!
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Question 1:
A district administrator works
approximately half time on NCLB Title I,
Part A, and half on IDEA. She is required
to keep:
A.
B.
Monthly PARs
Semi-annual certifications
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Question 2:
A district administrator works
approximately half time on NCLB
Title I, Part A, and half on Title I,
Part C (Migrant). She is required to
keep:
A.
B.
Monthly PARs
Semi-annual certifications
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Question 3:
A district administrator spends 100%
of his time on NCLB Title I, Part A,
although half of his salary is funded
from non-federal sources. He is
required to keep:
A.
B.
Monthly PARs
Semi-annual certifications
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Question 4:
A district administrator works
approximately half time on NCLB Title I,
Part A, and half on non-federal
activities, although his salary is funded
100% from Title I, Part A. He is
required to keep:
A.
B.
C.
Monthly PARs
Semi-annual certifications
Bail money on hand
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Question 5:
The district’s NCLB Director works on
Title I, Part A, Title II, Part A, and 21st
Century. The district consolidates its
NCLB administrative funds. The
Director is required to keep:
A.
B.
Monthly PARs
Semi-annual certifications
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Question 6:
The district has a contract with an
SES provider for afterschool tutoring
for students. The contract is paid with
Title I funds. Do the contractor’s
employees need to keep time and
effort records?
A.
B.
Yes
No
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Question 7:
Making journal voucher adjustments to
accounts typically is unrelated to
employees keeping time and effort
records.
A.
B.
False
True
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Question 8:
A classroom teacher in a targeted
assistance school provides Title I
services and is paid with Title I, Part A
funds. Just like any other federally-paid
employee, she is required to keep time
and effort records.
A.
B.
True
False
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Question 9:
A classroom teacher is paid with nonfederal funds used for a match under a
federal program. Because she is paid
with nonfederal funding, she is not
required to keep time and effort records.
A.
B.
True
False
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Question 10:
In a schoolwide program, a teacher is
paid with Title I funds and works 100%
on the schoolwide program plan. What
kind of time and effort records is she
required to keep?
A.
B.
C.
Semi-annual certifications
Monthly PARs
It depends
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OMB Circular A-122:
Nonprofit Institutions
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Similar to A-87 (but not identical)
Need PARs to support salaries and wages
of all staff paid (in whole or in part) with
federal funds
Monthly, after-the-fact records, signed by
employee or supervisor with knowledge
No semi-annual for employees working
100% on single cost objective
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OMB Circular A-21:
Institutions of Higher Education
More flexible rules and more discretion for
professorial and professional staff
3 Options:
 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
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OMB Circular A-21: IHEs (cont.)
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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:
IHEs (cont.)
What is a sponsored agreement:
 Any grant, contract or other agreement
between the institution and the Federal
Government.
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For Profits??????
48 C.F.R. Part 31
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Silent on required documentation….
So what does that mean???
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BIG QUESTION
WHAT IS A SINGLE
COST OBJECTIVE???
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What is a “Cost Objective”?

A-87 Definition:
 A function, organizational
subdivision, contract, grant or other
cost activity for which cost data are
needed and for which costs are
incurred.
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Examples . . .
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A Minimum Set-Aside or Maximum
Cap:
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Title I - LEA Parent Involvement minimum
(at least 1%);
Title III – Cap on administration (no more
than 2%)
Program services
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Title I program services
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USDE OGC Guidance:
Draft Examples of Single Cost
Objectives
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An LEA supports a supplemental math
teacher to serve low-achieving students
with 50% Title I and 50% state
compensatory education funds.
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Draft Examples of Single Cost
Objectives
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Each elementary school has a part-time
librarian 3 days/week paid with local
funds. An LEA adds 2 days/week for its
Title I schoolwide schools paid with
Title I Part A funds.
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Draft Examples of Single Cost
Objectives
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A preschool special education teacher is
funded with 50% IDEA section 611 and
50% with IDEA section 619 funds.
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Semi-Annual Certification
Examples
I, Justin Bieber, certify that I worked solely on
the Federal Grant program from January 1,
2011 to June 30, 2011.
Signature of Employee
____/s/______________
Date: September 1, 2011
Signature of Supervisor
____/s/______________
Date: September 1, 2011
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Semi-Annual Certification
Examples
I, Taylor Swift, certify that I worked 100% of
my time on Title I, Part A Administration
from January 1, 2011 to June 30, 2011.
Signature of Employee
____/s/______________
Date: June 20, 2011
Signature of Supervisor
____/s/______________
Date: June 20, 2011
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Semi-Annual Certification
Examples
January 1 through June 30, 2010
I, Barack Obama, certify that I worked solely
on project, initiatives, and issues which have
implications and consequences based and/or
related to Federal programs and policies.
Signature of Employee
____/s/______________
Date: June 30, 2010
Signature of Supervisor
____/s/_______________
Date: August 2, 1010
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PAR Examples
I certify that for the month of December 2011 I,
Lady Gaga, spent my time working on the
following programs:
Title I, Admin
State programs
Total
100%
100%____
200%
Signed: ___/s/____
January 5, 2012
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PAR Examples
I certify that for the month of December 2011 I,
Michelle Obama, spent my time working on the
following programs:
Title I, Admin
State programs
Total
20%
30%____
50%
Signed: ___/s/____
January 10, 2012
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PAR Examples
Dear Employee:
Please sign the pre-populated form if accurate.
I certify that for the month of December 2011 I, Ashton
Kutcher, spent my time working on the following programs:
Title I, Admin
State programs
Total
Signed: ___/s/_______
January 5, 2012
75%
25%____
100%
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Additional Resources
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Cost Allocation Guide for State and Local
Governments (or “Green Book”) (Sept. 2009)
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http://www2.ed.gov/about/offices/list/ocfo/fipao/
guideigcwebsite.pdf
Montana Compact
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www.bruman.com
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Program-specific guidance
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USDE officials
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Ideas for Reducing
Burden
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Consolidated Administration
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Combine administration for all
NCLB programs
NOT non-administrative
activities
Single Cost Objective
Semi-annual certification
LEA needs approval of SEA
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“Blanket” Semi-Annual
Certification
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Single cost objective (semi-annual cert)
Multiple employees
Signed by supervisor with first-hand
knowledge (principal)
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Schoolwide Programs
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The programs included in the Schoolwide
Plan constitute a single cost objective
Need for records depends on the extent
of consolidation of federal, state, and
local funding
Can be “conceptual” or “virtual”
consolidation – not literal
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Schoolwide time records
If LEA/school
consolidates . . .
Then must keep . . .
All federal, state, and local funds
No time and effort records
Federal only (“Consolidated federal
pot”)
Semi-annual – if works ONLY on
SWP Plan (single cost objective)
Monthly PAR – if works on SWP Plan
and other programs not in Plan
(multiple cost objectives)
Nothing (only Title I funds SWP)
Semi-annual – if works ONLY on
SWP Plan (single cost objective)
Monthly PAR – if works on SWP Plan
and other programs not in Plan
(multiple cost objectives)
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Keeping the right records is
not enough!
Need reconciliation between:
 programs that funded salaries,
and
 programs on which employees
actually worked
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1) At beginning of year, use budget
estimates for salary allocations
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Initially, use budget estimates or
other distribution percentages
determined before the services are
performed
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But these do not qualify as PARs!
May be used for interim accounting
purposes
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2) Compare budget estimates to
actual data and make adjustments
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If difference between actual cost and
budgeted cost is 10% or greater, then
make adjustment quarterly
If difference is less than 10%, then
make adjustment annually
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How to set up time distribution
system:
1) Plan initial funding allocations well
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May use “budget estimates” for initial
allocations
Supervisors need to be on board
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CAUTION:
Beware of
Re-organizations!
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2) Develop written time distribution policies and
procedures
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“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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3) Train employees:

On mechanics of filling out form
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On which federal program cost objective
they are working on
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Refresher training
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New employee training
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4) Close supervision
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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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USDE “Burden Reduction”
Pilot Program

USDE is soliciting ideas for pilot programs:
1.
2.
3.
mechanisms for consolidating funds in schoolwide
programs
time and effort reporting under A-87
documenting compliance with other record keeping
and reporting requirements

Blog Post: www.ed.gov/blog/

Email: [email protected]
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QUESTIONS??
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This presentation is intended solely to provide
general information and does not constitute legal
advice or a legal service. This presentation does not
create a client-lawyer relationship with Brustein &
Manasevit, PLLC and, therefore, carries none of the
protections under the D.C. Rules of Professional
Conduct. Attendance at this presentation, a later
review of any printed or electronic materials, or any
follow-up questions or communications arising out of
this presentation with any attorney at Brustein &
Manasevit, PLLC does not create an attorney-client
relationship with Brustein & Manasevit, PLLC. You
should not take any action based upon any
information in this presentation without first
consulting legal counsel familiar with your particular
circumstances.
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