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Fiscal Compliance for Title III. Stephanie English, Chief Monitoring & Compliance Section School Business Division 919-807-3686 [email protected]. Fiscal Compliance. Items Included: Time and Effort Documentation Equipment records Contracts/Invoices - PowerPoint PPT Presentation
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Fiscal Compliance for Title III
Stephanie English, ChiefMonitoring & Compliance Section
School Business Division919-807-3686
Fiscal Compliance
Items Included: Time and Effort Documentation Equipment records Contracts/Invoices Administration Limitation
Time and Effort
• Applies to every employee funded from federal funds.
• Purpose: To document that the appropriate federal program is receiving the benefit of the services supported by grant funds.
• Time and Effort documentation is required by OMB Circular A-87, Attachment B, Item 8 (h), and is in addition to the standards for payroll documentation.
Two Types of Participating Employees:
• Single Cost Objective
• Multiple Cost Objectives
What is a Cost Objective?
• A federal term referring to a grant objective.
• Some federal cost objectives have corresponding state cost objectives, such as State ESL (054) and Title III (104)
• Some programs that may “look like” other programs are NOT the same cost objective, such as ESL (054/104) and Migrant (051)
Employees Who Are Employed 100% In A Single Cost Objective
• Employees must have at least semi-annual certifications that they worked solely on that program.
• Certifications must be signed by the employee or the supervisor who has first hand knowledge of the work performed.
What does a “semi-annual certification” look like?
• A simple statement: “I, Stephanie English, certify that I spent 100% of my time for the period of July 1, 2008, through December 31, 2008, on Title III ESL activities.”
OR• A “blanket” statement signed by the
supervisor with first-hand knowledge of employees’ work.
Multiple Cost Objective Employees• Salaries and wages must be supported by completing
monthly personnel activity reports (PAR forms) unless a substitute system has been approved.
• PAR Forms MUST•Reflect an after-the fact distribution of the actual activity of each employee;•Account for the total activity for which each employee is compensated;•Be prepared at least monthly and must coincide with one or more pay periods; and•Be signed by the employee.
What does a PAR form look like?
Month: January 2009 Position Number: 045 Employee:
Effort:
Week 1: January 1-3 Supervisor's Initials:Column D
PERCENT ALLOCATIONPercentage of time this week spent on each cost objective
(Column B / Column C x 100%)
50%50%
Week 2: January 4-10 Supervisor's Initials:PERCENT ALLOCATION
60%40%
Week 3: January 11-17 Supervisor's Initials:PERCENT ALLOCATION
65%35%
Week 4: January 18-24 Supervisor's Initials:PERCENT ALLOCATION
50%50%
Week 5: January 25-31 Supervisor's Initials:PERCENT ALLOCATION
45%55%
2/2/2009Date
2/3/2009Date
Migrant 14
Migrant
TIME - Cost Objective
16
Column BTIME - Cost Objective
Total hours this week spent on each cost objective
Title IIICOST OBJECTIVE
4
16Migrant 16
PERSONNEL ACTIVITY REPORT
Ted D. Behr
Employee time and effort is allocated 50% to Title III and 50% to Migrant Education.
Joe Johnson
Ted D. Behr
COST OBJECTIVE TIME - Cost Objective
Title III 18
Monthly Percent Allocation
Supervisor's Signature and Title
Migrant 22
88/160 = 55% Title III
I hereby certify that the information contained in this Time and Effort Report accurately reflects actual time and effort distribution forthe month reported.
40
Employee's Signature
COST OBJECTIVE TIME - Cost Objective
Title III
COST OBJECTIVE TIME - Cost Objective
Title III 26
4
Column CTIME - Total
Total hours worked this week
8
Column ACOST OBJECTIVE
Cost objectives upon which time was spent this week
Title IIIMigrant
72/160 = 45% Migrant
TIME - Total
TIME - Total
TIME - Total
40
40
TIME - Total
32
24
Important notes about PARs
• PAR forms must be supported by more detailed documentation, such as a calendar with daily entries regarding activities supporting each cost objective
• Results of PAR forms must be reconciled against payroll (usually a finance function)
Substitute systems for allocating salaries and wages to federal grants may be used only if approved by the cognizant agency.
DPI is the cognizant agency for LEAs/Charter Schools.
Substitute Systems:
Which LEAs are approved to use substitute systems?
As of December 1, 2008, the following LEAs have approved substitute time reporting systems under OMB Circular A-87:
Anson County Granville County Richmond County
Avery County Haywood County Rockingham County
Bladen County Halifax County Rutherford County
Brunswick County Jackson County Elkin City
Buncombe County Charlotte-Mecklenburg Schools Swain County
Cumberland County Mitchell County Transylvania County
Davie County Moore County Wake County
Durham County Nash-Rocky Mount Schools Yancey County
Graham County Pender County
Only those school systems that have submitted documentation for their substitute system and have received official notification from DPI have beenapproved to implement their substitute systems. All other school systems should be complying with A-87 requirements for time and effort reporting.
If you have any questions, please contact the Monitoring and ComplianceSection at (919) 807-3686.
UPDATE:DPI Approved SubstituteTime Reporting Systems
for LEAs
Special Note on Schoolwide Schools
• In a Title I Schoolwide School, all funds lose their identity.
• Employees in a Schoolwide School may be paid from any fund source, or any combination of funding sources, and their effort statement would state “100% Title I Schoolwide School”, making a certification statement the appropriate documentation.
• Employees in a Schoolwide School who are paid from federal funds are the ones who document their time and effort.
Equipment
Federal regulations require certain records to be kept
Not to be confused with “fixed assets” tracking
What to track? Items with a useful life > 1 year
Police report filed if the item “disappears”
Equipment
Education Department General Administrative Regulations (EDGAR) 34 CFR 80.32
(d) Management requirements
(1) Property recordsmust be maintained that include…
• Description of the property• Serial number or other identification number• Source of property• Who holds title• Acquisition date• Cost of the property• Percentage of Federal participation in the cost• Location, use, and condition• Disposition data (including date of disposal and
sale price)
Other Equipment Management Requirements:• Physical inventory (reconciled with
property records at least once every 2 years)
• Control system• Adequate maintenance procedures
Contracts/Invoices
• Contracts for personnel services MUST be specific – who, what, when, where, why.
• Invoices must contain the same basic information – it is not enough to just refer to the contract number.
Contracts (cont’d)
• Suspension/Debarment– Non-Federal entities are prohibited from
contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred.
• Debarred Vendors list – State and Federal can be found at http://www.ncpandc.gov/QuickReference.html
Administration Limitation
• Administrative Cost is limited to 2% of current year allotment
• What is considered Administrative Cost? • Indirect Cost rate may result in excess
Administrative cost• Unspent portion of allowable Admin
expenditures can be carried forward to the next year
Questions?
Resources
Federal information:OMB CircularsEDGAR
http://www.ncpublicschools.org/fbs/finance/federal/
