Transcript Time and Effort Reporting Office of Superintendent of Public Instruction (OSPI) 11/6/2015 Why Does Time and Effort Continue to be an Audit Problem?       11/6/2015 Large percent of federal.

Time and Effort
Reporting
Office of Superintendent of
Public Instruction (OSPI)
11/6/2015
Why Does Time and Effort
Continue to be an Audit
Problem?
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Large percent of federal education
funds used for staffing.
Staff turnover.
Decentralized responsibilities.
Lack of adequate communication
between program and fiscal staff.
Complexity of applying requirements
to variety of situations.
People don’t like it!
Know The Basics
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Where are the
Requirements?
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Time and effort reporting is required
under 2 CFR Section 225 (formerly
Federal Office of Management and
Budget’s Circular A-87, Cost
Principles for State, Local, and
Indian Tribal Governments).
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Attachment B, Selected Items of
Cost, Compensation for personal
services.
When is Time and Effort
Required?
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Time and effort reporting is
required when any part of an
employee’s salary is:
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Charged to a federal program.
Used as match for a federal program.
Employee’s time is split between
an indirect and any direct cost
objective.
What is an employee?
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Salaries, wages and benefits are
charged under objects 2, 3 and 4.
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An employee is NOT a vendor or
independent consultant/contractor.
 No time and effort is needed for
non-employees. (See OMB Circular A-133
__.210 for vendor criteria.)
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What type of reporting is
needed?
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Single cost objective
→Semi annual certification.
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Multiple cost objectives
→Monthly time reports or
Personnel Activity Reports
(PARs).
What is a “cost objective”?
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A particular set of work activities
for which cost data is
accumulated.
For purposes of time and effort
reporting: Define cost objectives
according to the set of work activities
allowable under the terms and
conditions of each funding source.
(Examples: Parent Involvement or Professional
Development in a Federal Program.)
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.
What are some typical
examples of single cost
objectives?
The set of work activities allowable
under:
 A single federal program.
 A single required set-aside/reserve in
a federal program.
 Federal Special Education and State
Special Education.
 A schoolwide program.
 A federal program and its state/local
match.
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What are some typical
examples of multiple cost
objectives?
The work activities of:
 A federal program with multiple
set-asides/reserves.
 A federally-funded program and a
state-and/or locally-funded
program.
 A schoolwide program and a
program not combined in the
schoolwide program.
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What is a semi annual
certification?
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Statement (certification) individual(s)
worked solely on activities related to a
single cost objective during defined
dates.
Completed at least every six months.
Signed and dated by employee or
supervisor with first-hand knowledge of
work performed.
For internal control purposes, district
may request both employee and
supervisor sign.
What is a monthly time report?
(PAR)
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Accounts for total worked
time/activity (including non-federal
time).
Prepared and signed at least
monthly.
Signed and dated by employee.
Reflects actual work performed (not
budgeted).
Agrees with supporting
documentation.
What type of supporting
documentation is needed?
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Requires a judgment call.
Examples include, but are not
limited to:
Class schedules.
 Number of students.
 Number of minutes.
 Calendars or work logs.
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When is a “reconciliation”
required?
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Payroll records must be
compared to time and effort
reports at least quarterly to
ensure no unallowable charges
to federal awards.
When is an accounting
adjustment required?
If the difference is 10 percent or more:
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Payroll charges must be adjusted at the
time of the reconciliation.
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AND: The following quarter’s budget
estimates must be adjusted to more closely
reflect actual activity.
If the difference is less than 10 percent:
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No accounting adjustment is required until
the end of the year.
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BUT: At year-end any payroll charges to
federal awards that exceed actual time and
effort must be eliminated.
Who should sign the
reports?
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Monthly reports (PARs) must be
signed by the employee.
Semi-annual certifications must
be signed by employee or
supervisor having first-hand
knowledge of work performed.
For internal control purposes,
districts may require both the
employee and supervisor to sign.
Schoolwide Programs
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A schoolwide plan must specify
programs to be combined.
A schoolwide program is a single cost
objective if an employee works 100
percent on programs combined →
Group or Individual Semi-annual
certification permitted.
If an employee works partially on
programs combined and partly on those
not combined → Monthly time report
(PAR) required.
Supplemental Contracts,
Stipends, Extra Hours
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Primary contract and additional
contracts may be reported
separately.
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Time and effort may be required
for primary contract but not
supplemental (or vice versa).
Administrators
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Superintendent, assistant
superintendent, principal,
assistant principal are usually
not allowable charges to federal
programs;
Exceptions require detailed
documentation to support.
 Generally a supplant issue.
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What is a substitute
system?
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Alternative method for calculating and
supporting compensation charges to
federal grant funds (usually based on a
statistical sample of work performed).
Used only for federal programs
specified in approved substitute system
plan.
Must be approved by OSPI prior to
use.
Must be statistically sound.
Should be periodically reviewed to
determine if still appropriate.
Other Requirements for
Charging Compensation to
Federal Programs
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Reasonable, necessary and
allocable to the program charged.
Compensation consistent with
nonfederal activities of the district.
Leave buy-out at termination is an
indirect charge.
Supplement, not supplant applies to
many programs.
Tips……
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Know the basics.
Train and re-train:
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Assign central responsibility:
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Ensure all reports are completed.
Communicate:
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Annual training in district.
Explain the “why”.
OSPI Bulletin – Keep it handy.
Who needs to communicate what
changes to whom.
Ask for help if needed.
Discussion
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Missing time and effort report
documentation is one of the
most frequent and costly audit
findings in the state. How
does/can your district ensure
that every employee required to
report time and effort does so?
Questions?
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For Additional Information
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See OSPI Bulletin 051-11
Examples.
 Sample forms.
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2 CFR Section 225 (OMB Circular
A-87, Cost Principles for State,
Local, and Tribal Governments)
Time and effort FAQs (on CPR website)
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