Federal Fiscal & Reporting Requirements

Stolen From: Janice Hay, Finance Coordinator

Amended by:Amelia Courts

Title III Directors’ Conference

May 2009

Time and Effort

• If federal funds are used for salaries “time distribution records” must be kept

• Must demonstrate that employees paid with federal funds actually worked on the specific federal program

• Type of documentation depends on the number of “cost objectives” the employee worked on

• These cost objectives must be connected to the employee’s salary source

• What is a cost objective?– A specific grant award, or other category of costs, that

requires the grantee to track specific cost information

Time and Effort (Cont’d)

• If an employee works on a single cost objective:– Semi-Annual Certification

– Signed by employee and supervisor every six months

– Example: “I hereby certify that for the period January 1, 2009 through June 30, 2009 one-hundred percent (100%) of my time and effort was spent on Title III Administration.”

Time and Effort (Cont’d)

• If an employee works on multiple cost objectives:– Personnel Activity Report (PAR)

– After-the-fact-record

– At least monthly

– Total activity for which the employee is compensated

– Signed and dated by employee (supervisor may also sign)

  NAME Enter your name here                    

WEST VIRGINIA DEPARTMENT OF EDUCATION

  MONTH/YR May-09                    

OFFICE OF INTERNATIONAL SCHOOLS

                                               ALLOCATION OF WORK DAYS HOW WAS THE DAY SPENT (IN HOURS)  

DATE

WORK LOCATION NW

Title III

SPED WL IS

FLAP

PAR

WVD

TOTAL

ON

TRV

ADM

CORR PD

PROD

GRT

MON TA

Other

TOTAL

1                                         

2Saturday 1.00              1.00                     

3Sunday 1.00              1.00                     

31Sunday 1.00              1.00                     

TOTALS10.0

0              10.00                     

    NW ESLSPED WL IS

FLAP

PAR

WVD

TOTAL

ON

TRV

ADM

CORR PD

PROD

GRT

MON TA

Other

TOTAL

% of Time   #DIV/0! #DIV #DIV/0!#DIV/0! #DIV/0!#DIV/0!#DIV/0! #DIV/0!   #DIV/0!#DIV/0!#DIV/0! #DIV/0!#DIV/0!#DIV/0!#DIV/0! #DIV/0!#DIV/0! #DIV/0!

Equivalent Days (Hr/7.5)                                        

Total Scheduled Work Days                                        

Total Actual Hours Worked (Days)                       Date             

Time and Effort (Cont’d)

• Quarterly comparisons of actual costs to budgeted distributions– If a variance of 10% or greater exists

• Adjust expenditures to reflect costs of the actual time reported.

• In order to minimize future differences, adjust estimated distributions for future payrolls to activity performed in the previous quarter. This should help minimize the difference in actual wages paid to time recorded.

– If difference is less than 10%, may make adjustment annually

Time and Effort (Cont’d)

EXAMPLE 1 EXAMPLE 2Hours as Recorded on Time and Effort Records

220 Hours Title III

300 Hours local

350 Hours Title III

170 Hours local

% of Total 42% 58% 33% 67%Adjustment of expenditures for prior quarter required NO YES

Amount of quarterly adjustment required None (Annual adjustment is

necessary when variance <10%)

17% of salary expense for the quarter (or $1,912.50)

should be moved from Title III to local

Adjustment of budget for future payments required NO YES

Amount of adjustment required NO 67% of $11,250 = $7,537.50

33% of $11,250 = $3,712.50

PERIOD: January-March, 2009SALARY: $45,000 annually/$11,250 per quarter (Includes fringe)TOTAL HOURS FOR PERIOD: 520 (Includes holidays and/or leave hours taken)BUDGETED AND PAID: 50% Title III and 50% local ($5,625 Title III and $5,625 local)

Time and Effort-Example of PAR

Day of Month

Number of hours worked by funding source

Annual/Sick/Holiday Hours (Do Not Include in Total

Hours) Total HoursTitle III local

1 2 2 4 AL 42 0 0 8 H 03 2 6 0 84 4 4 0 8

Etc.Totals 8 12 20% of Total 40% 60%

This example calculates the variance based on hours actually worked. If a variance occurs and the prior quarter’s payroll records require an adjustment, the adjustment will be made to all wages paid, so the adjustment will then also align the payment of leave taken to correspond to hours worked.

Employee Name: ______________________________ Month:________________ Year:___________Employee Signature:_____________________ Supervisor Signature:_____________________________

Maintenance of Effort

• Time and Effort Records are not required for contractual employees

• To maintain as much control as possible over federal funds, it is important for the LEA to develop clear, transparent and detailed contracts that clearly delineate why services are reasonable and allowable under the Title III program.

• Maintenance of Effort records will be monitored as part of 2009-10 Consolidated Monitoring

EDGAR §80.32(C)-(E)

Inventory Management

Inventory Management-EDGAR §80.32(c)-(e)

• Equipment– Federal definition of Equipment (OMB Circular A-122)

• Tangible personal property

• Useful life of more than one year

• Acquisition cost of $5,000 or more

– For purposes of maintaining Title III Inventory

• As above, except– Useful life of more than one year, regardless of acquisition

cost» PDAs, Computers, Cell phones, Copiers, Projectors, Etc.

Inventory Management-Equipment

• Must have adequate controls in place to account for:

– Location of equipment

– Custody of equipment

– Security of equipment

• LEA should have procedures in place and documentation to track and account for the location and assignment of equipment at all times

– A tracking system must be implemented for requesting and signing out equipment to be used off-site

Equipment (Cont’d)• Property records

– Description, quantity, serial number, model number or other ID, acquisition date, cost, percent of federal participation and grant award year, location, use and condition, and disposition data (to include date of disposal and sale price)

– All blanks are to be completed• Must be updated immediately when new equipment is

purchased• Physical inventory

– At least every two years (LEA may require annually)• Name of person and date of physical inventory is to be

recorded• Evidence that the physical inventory is reconciled to inventory

records maintained at the LEA• Control system to prevent loss, damage & theft

– All incidents must be investigated

Equipment (Cont’d)

• Must protect against unauthorized use– May use for other projects as long as use is incidental and

does not interfere with authorized use

• When property is no longer needed, must follow disposition rules– Transfer to another federal program

– Over $5,000 – Keep or sell, but must pay a share based on the percentage of federal ED participation at initial acquisition

– Under $5,000 – May keep, sell, or dispose of it with no obligation to ED

• When property is lost, damaged or stolen– Follow procedures in the WVDE Procedures Manual Capital

Asset System (Send copy of documentation to SEA)

Title III funds:Required & Authorized activities

Administrative funds

Carryover & Reallocation

LEA Title III Required Activities

1. Increase English proficiency by providing high-quality language instruction education programs (Title III Section 3115)

2. Provide high-quality professional development to classroom teachers– Of sufficient intensity and durantion…

LEA Title III Authorized Activities

1. Upgrading program objectives and effective instruction strategies

2. Improving instruction by acquiring materials, software, assessment…

3. Providing:– Tutorials and academic or vocational education– Intensified instruction

4. Developing programs coordinated with other relevant programs

5. Improving the English and academic achievement

6. Providing community outreach programs, family literacy…

7. Improving instruction

8. Carrying out other activities that are consistent

LEA Title III funds• Title III application Action Steps

http://wvconnections.k12.wv.us/documents/SampleActionSteps_000.doc

• Title III Scoring Guide http://wvconnections.k12.wv.us/documents/TitleIIIEvalRubric0910.xls

• Administration Costs (Title III Section 3115)• No more than 2% for administration (include direct and indirect

costs)

• Subgrant expenditures are:– Allowable, applicable and reasonable

• Eliminate Carryover – Title III awards will be for 1 year• *only in extenuating circumstances will the award be

revised

Questions and Answers?

• ED Elements & Indicators doc http://www.wvcpd.org/cmsprgm.aspx?name=2009%20GATE&ProgramID=4

Summer Professional Development• http://wvconnections.k12.wv.us/summerprogram.html • http://www.wvcpd.org/cmsprgm.aspx?

name=2009%20GATE&ProgramID=4

Thank You!