Time and Effort Reporting: Documenting Employees’ Personnel Costs Kristen Tosh Cowan, Esq....
-
Upload
samuel-hawkins -
Category
Documents
-
view
214 -
download
0
Transcript of Time and Effort Reporting: Documenting Employees’ Personnel Costs Kristen Tosh Cowan, Esq....
Time and Effort Reporting:
Documenting Employees’ Personnel
Costs
Kristen Tosh Cowan, [email protected] & Manasevit, PLLC
Fall Forum 2011
Terminology
Time and attendance records Payroll records
Worked 8:00-4:00
Time and effort records Time distribution records
Worked 50% on Title I administration and 50% on nonfederal
3
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
4
A-87: If employee works 100% on single cost objective
Semi-Annual Certification Signed every six months by supervisor or
employee
“This is to certify that Kristen Cowan has worked 100% of her time for the period January 1, 2010, through June 30, 2010, on Perkins Administration.”
Signature of employee:Date: 5
A-87: If employee works on multiple cost objectives
Personnel Activity Reports (PAR) Signed every month by employee UNLESS, using “substitute system” (then 2 or
3 times per year)
“For the month of September 2009, I spent my time 50% on Title I Program Services and 50% on non-federal programs.”
Signature of Employee:Date:
6
PARs must:
After-the-fact record Total activity for which employee
compensated At least monthly
(unless substitute system) Signed and dated by employee
7
OIG Time and Effort Findings:
2006 – Columbus - $2.3 million
2008 – Detroit - $49 million
2009 – Houston - $238 million
2010 – Philadelphia - $123 million
8
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. Monthly PARsB. Semi-annual certifications
10
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. Monthly PARsB. Semi-annual certifications
11
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. Monthly PARsB. Semi-annual certifications
12
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. Monthly PARsB. Semi-annual certificationsC. Bail money on hand
13
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. Monthly PARsB. Semi-annual certifications
14
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. YesB. No
15
Question 7:Making journal voucher adjustments
to accounts typically is unrelated to employees keeping time and effort records.A. FalseB. True
16
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. TrueB. False
17
Question 9:A classroom teacher is paid with
non-federal 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. TrueB. False
18
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. Semi-annual certificationsB. Monthly PARsC. It depends
19
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.
21
Examples . . . . A Minimum Set-Aside or Maximum
Cap: Title I- LEA Parent Involvement
minimum (at least 1%); Title III – Cap on administration (no
more than 2%)
Program services Title I program services
22
USDE Guidance: Draft Examples of Single Cost Objectives An LEA supports a supplemental
math teacher to serve low-achieving students with 50% Title I and 50% state compensatory education funds.
23
Draft Examples of Single Cost Objectives
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.
24
Draft Examples of Single Cost Objectives
A preschool special education teacher is funded with 50% IDEA section 611 and 50% with IDEA section 619 funds.
25
Essential Legal Resources OMB Circulars A-87: Cost Principles
for State and Local Governments
HHS Implementation Guide for A-87: ASMB C-10 (1997)• http://rates.psc.gov/fms/dca/asmb%20c-
10.pdf
26
Resources, cont. Cost Allocation Guide for State and Local
Governments (or “Green Book”) (Sept 2009) http://www2.ed.gov/about/offices/list/ocfo/fi
pao/guideigcwebsite.pdf
Montana Compact www.bruman.com
Program-specific guidance
USDE officials27
Consolidated Administration
Combine administration for all NCLB programs
NOT non-administrative activities
Single Cost Objective Semi-annual certification LEA needs approval of SEA
29
“Blanket” Semi-Annual Certification
Single cost objective (semi-annual cert)
Multiple employees Signed by supervisor with first-hand
knowledge (principal)
30
Schoolwide Programs 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 31
Schoolwide time recordsIf 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)
32
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
34
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
36
3) Train employees
On mechanics of filling out form
On which federal program cost objective they are working
Refresher training
New employee training
37
4) 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
38
USDE is soliciting ideas for pilot programs:1. mechanisms for consolidating funds in
schoolwide programs2. time and effort reporting under A-87 3. documenting compliance with other
record keeping and reporting requirements
USDE “Burden Reduction” Pilot Program
39