Office of Special Education TIME AND EFFORT REPORTING Presenters: Michael Wynn, CFE

Office of Special EducationTIME AND EFFORT REPORTING

Presenters:Michael Wynn, CFEGrants Management Certified

Nancy Jo Serna, CPAGrants Management Certified

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Time and Effort Regulations

2 CFR 225(Formally known as OMB Circular A-87)

Attachment B, Item 8h

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Time and Effort Overview

Financial Management Requirements:•Written policies and procedures

•Staff training•Required Documentation

•Estimates and Quarterly Comparisons•Adjustments and Revisions

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Time and Effort Reporting Documentation

• Time and Effort documentation is required for all employees paid with federal funds.

• These records are in addition to payroll documentation.

• Not applicable for contractors.

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Time and Effort Reporting Definition

Cost ObjectiveA function, organizational subdivision,

contract, grant, or other activity for which cost data are needed and for

which costs are incurred.

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Time and Effort Reporting Documentation

Semi-Annual Certification:A certification that the employee worked solely

on a single Federal award or cost objective (activity).

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Time and Effort Reporting Documentation

Semi-Annual CertificationWhen an employee works 100% on a single federal award or cost objective, the certification must be:•Prepared after-the-fact (dated), and•Prepared at least every 6 months (semi-annually), and•Account for total activity for which the employee is compensated; and•Signed by the employee or supervisory official having firsthand knowledge of the work performed

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Personnel Activity Report (PAR): A record maintained by an employee who works on multiple activities or

cost objectives.

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Time and Effort Reporting Documentation

Time and Effort Reporting Documentation

Personnel Activity Report (PAR)When an employee works on multiple activities or cost objectives, the PAR must:•Reflect an after-the-fact distribution (dated) of the employee’s actual activity, and•Be prepared at least monthly, and•Coincide with one or more pay periods, and•Account for total activity for which the employee is compensated; and•Be signed by the employee

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Time and Effort Reporting

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• Personnel Activity Reports or Semi-Annual Certifications?!!! Which one?!!!

Time and Effort Reporting

PAR vs. Semi-Annual Certification

The key to determining the proper documentation is to understand if the employee is working on one cost objective or activity or multiple cost objectives or activities.

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Time and Effort Reporting

PAR vs. Semi-Annual Certification

There are only four possible options to consider when determining whether to complete a semi-annual certification or personnel activity report. All possible circumstances will apply to one of the four options.

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Time and Effort Reporting

PAR vs. Semi-Annual CertificationDecision Making Tools

Decision Making RubricDecision Making Graphic

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Time and Effort Reporting

Decision Making Rubric

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Decision Making Rubric

COST OBJECTIVE

Single Multiple

GRANT AWARDS(or funding

source)

SingleSemi-Annual Certification

(A)

PAR(C)

MultipleSemi-Annual Certification

(B)

PAR(D)

Time and Effort ReportingDecision Making Graphic

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Time and Effort ReportingExample A

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Time and Effort ReportingSemi-Annual Certification ExampleExample A: Single Award/Single Cost Objective

•A sub-recipient could have an employee funded with a single federal award and working on a single cost objective.•IDEA Part B Sec. 611, a Special Education teacher works with students with disabilities ages 6-21, 100% of their time and is charged to Flowthrough grant only, semi-annual certification is required.

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Time and Effort ReportingExample B

Example B

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Time and Effort ReportingSemi-Annual Certification Example

Example B: Multiple Awards/Single Cost Objective

•A sub-recipient could have an employee funded with more than one federal award (or funding source) working on a single cost objective, where the awards support the cost objective.•IDEA Part B Sec. 611 supports students ages 3-21 and Sec. 619 supports ages 3-5. A Special Education teacher works with students with disabilities ages 3-5 only and is charged to Flowthrough and Preschool grants, a semi- annual certification is appropriate.

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Time and Effort ReportingExample C

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Time and Effort ReportingPAR Example

Example C: Single Award/Multiple Cost Objectives

•A sub-recipient could have an employee funded with a single federal award and working on multiple cost objectives.•IDEA Part B, Sec. 611 requires tracking of Proportionate Share costs. A Speech Therapist provides services to public school students with disabilities and provides services to non-public school students with disabilities, a PAR is required.

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Time and Effort ReportingExample D

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Time and Effort ReportingPAR Example

Example D: Multiple Awards/Multiple Cost Objectives

•A sub-recipient could have an employee funded with multiple federal awards (or funding source) and working on multiple cost objectives.•IDEA Part B Sec. 611 for Other State Activities supports Transition Services (TS) and Enhancing Opportunities for Students with Disabilities (EOSD) grants. If a person works as a Transition Coordinator (TS) and a Planner Monitor (EOSD), a PAR is required.

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Time and Effort Reporting

• Estimations– Determined before services are performed do not

qualify as time and effort documentation.

• Comparisons & Adjustments– Adjust quarterly if actual and budgeted differ 10%

or more– Adjust annually if actual & budgeted differ less

than 10%

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Time and Effort ReportingFrequently Asked Questions

Q: What are the Program Fiscal Review requirements?A: Must have proper Time and Effort documentation to support expenditures related to employees charged to federal grants. – Must be the correct form (PAR or Semi-annual Cert)– Must be on file for all employees charged to the grants– Must be signed after the fact, and have date of period– Must have the grant name

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Time and Effort Reporting

Frequently Asked QuestionsQ: What occurs if documentation is not on file or not in compliance during a Program Fiscal Review?

A: A finding will be written if noted during a review. Corrective Action to ensure compliance will be necessary. May result in questioned costs.

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Time and Effort ReportingSend questions related to IDEA Part B, Sec. 611 to:

Michael Wynn, wynnm@michigan.gov

Nancy Jo Serna, sernan@michigan.gov

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