Time and Effort Time and Effort ReportingReporting

Grants OfficeGrants Office

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Know The BasicsKnow The Basics

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When is Time and Effort When is Time and Effort Required?Required?

Time and Effort reporting is Time and Effort reporting is required when any part of an required when any part of an employee’s salary is:employee’s salary is: Charged to a Federal programCharged to a Federal program Used as match for a Federal programUsed as match for a Federal program Paid with non-Federal funds (State)Paid with non-Federal funds (State)

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Where are the Where are the Requirements?Requirements? Time and Effort reporting is required Time and Effort reporting is required

under 2 CFR Section 225 (formerly under 2 CFR Section 225 (formerly Federal Office of Management and Federal Office of Management and Budget’s Circular A-21, Budget’s Circular A-21, Cost Cost Principles for Educational Principles for Educational Institutions)Institutions)

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Who is considered an employee?Who is considered an employee?

Salaries, wages and benefits Salaries, wages and benefits are charged under object codes are charged under object codes 1, 2, and 3 1, 2, and 3

An employee is NOT a vendor An employee is NOT a vendor or independent consultantor independent consultant Time and Effort isn’t needed for Time and Effort isn’t needed for

non-employeesnon-employees Time and Effort isn’t needed for Time and Effort isn’t needed for

employees using time sheets or employees using time sheets or honorariumshonorariums

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What is Effort?What is Effort?

Total effort is defined as Total effort is defined as whatever amount of time a whatever amount of time a person devotes to fulfilling person devotes to fulfilling his/her program-related his/her program-related responsibilitiesresponsibilities

OMB Circular No. A-21, J10c(2)(a)-(f)OMB Circular No. A-21, J10c(2)(a)-(f)

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Effort Reporting is…Effort Reporting is…

A way for an employee to certify A way for an employee to certify that…that…

1.1. Effort supported (paid) by a Effort supported (paid) by a grant sponsored project has grant sponsored project has been performed as promisedbeen performed as promised

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Effort Reporting…Effort Reporting…

Is required by Federal regulation Is required by Federal regulation and District policy for all and District policy for all individuals working on grant individuals working on grant funded sponsored projectsfunded sponsored projects

Makes salary sources for the Makes salary sources for the period congruent with effort period congruent with effort spent for the periodspent for the period

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Why Does Time & Effort Why Does Time & Effort Continue to be an Audit Continue to be an Audit Problem?Problem? Large % of Federal Education Funds Large % of Federal Education Funds

Used for StaffingUsed for Staffing Staff TurnoverStaff Turnover Decentralized responsibilitiesDecentralized responsibilities CommunicationCommunication Complexity of applying requirements Complexity of applying requirements

to variety of situationsto variety of situations People don’t like it!People don’t like it!

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Why should We Care?Why should We Care?

Signed effort reports are considered legal Signed effort reports are considered legal documents in which an individual attests to documents in which an individual attests to the accuracy of the effort spent on the accuracy of the effort spent on sponsored projectssponsored projects

Erroneously certifying effort reports can be Erroneously certifying effort reports can be viewed as fraudviewed as fraud

We are obliged by Federal regulations to We are obliged by Federal regulations to exercise good stewardship of those fundsexercise good stewardship of those funds

1.1. Effort is a part of that stewardshipEffort is a part of that stewardship

2.2. Personnel costs are the majority of program Personnel costs are the majority of program costscosts

False Claims Act, 31, U.S.C., sections 3729 & 3721False Claims Act, 31, U.S.C., sections 3729 & 372104/20/2304/20/23

What type of reporting is What type of reporting is needed?needed?

Single cost objective Single cost objective

→→Semi annual certificationSemi annual certification

Multiple cost objectives Multiple cost objectives →Monthly time reports or →Monthly time reports or Personnel Activity Reports Personnel Activity Reports (PARs)(PARs)

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What is a “cost objective”?What is a “cost objective”?

A particular set of work activities A particular set of work activities for which cost data is for which cost data is accumulatedaccumulated

A-21 Definition: A-21 Definition: Compensation for Compensation for personal services covers all amounts paid personal services covers all amounts paid currently or accrued by the institution for currently or accrued by the institution for services of employees rendered during the services of employees rendered during the period of performance under sponsored period of performance under sponsored agreements. P. 255 EDGAR agreements. P. 255 EDGAR

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What are some typical examples of What are some typical examples of single cost objectives?single cost objectives?

Example 1:Example 1: An employee funded 100% by the An employee funded 100% by the grant who provides services only to the grant who provides services only to the special population identified in the grantspecial population identified in the grant

Example 2:Example 2: An office assistant who works An office assistant who works 100% of the time for a sponsored program 100% of the time for a sponsored program and is funded partially with local funds.and is funded partially with local funds.

Example 3: An early childhood education Example 3: An early childhood education teacher funded 80% with “pass-through” teacher funded 80% with “pass-through” and 20% with district funds if there isn’t a and 20% with district funds if there isn’t a difference in activities performed.difference in activities performed.

Since there is no difference in the activities Since there is no difference in the activities Semi-Annual certification is only needed.Semi-Annual certification is only needed.

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What are some typical What are some typical examples of multiple cost examples of multiple cost objectives?objectives?Example 1:Example 1: An employee provides counseling An employee provides counseling

services to TRIO student 60% of the time services to TRIO student 60% of the time and college counseling services to the and college counseling services to the general student population 40% of the general student population 40% of the time. The counseling objectives are time. The counseling objectives are different for the TRIO students and must different for the TRIO students and must be documented for verification and be documented for verification and continuation of the program. continuation of the program.

Since the counseling is intended for different Since the counseling is intended for different purposes, PAR is required monthly.purposes, PAR is required monthly.

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Another example of multiple Another example of multiple cost objectivescost objectives

Example 2:Example 2: An accountant manages several An accountant manages several categorical budgets as well as the college’s categorical budgets as well as the college’s Work Force Training Center budget.Work Force Training Center budget.

Although the budgets within the Center Although the budgets within the Center deals with multiple categorically-funded deals with multiple categorically-funded grants, the categorical programs are grants, the categorical programs are intended for different purposes, multiple intended for different purposes, multiple cost objectives are reported.cost objectives are reported.

Time and Effort reporting is required monthly.Time and Effort reporting is required monthly.

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What is a semi-annual What is a semi-annual certification?certification?

A statement that individual(s) worked A statement that individual(s) worked solely on activities related to single solely on activities related to single cost objectivecost objective

Completed at least every six monthsCompleted at least every six months

Signed and dated by employee Signed and dated by employee andand supervisor with first-hand knowledge supervisor with first-hand knowledge of work performedof work performed

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What is a monthly time report?What is a monthly time report?(PAR)(PAR)

Accounts for total time / activityAccounts for total time / activity Prepared & signed at least Prepared & signed at least

monthlymonthly Signed and dated by employee Signed and dated by employee

and supervisorand supervisor Reflects actual work performed Reflects actual work performed

(not budgeted)(not budgeted) Agrees to supporting Agrees to supporting

documentationdocumentation04/20/2304/20/23

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What type of supporting What type of supporting documentation is needed?documentation is needed? Requires a judgment call Requires a judgment call Examples include, but are not limited Examples include, but are not limited

to:to: Grant activities and goalsGrant activities and goals Number of students servedNumber of students served Number of reports generatedNumber of reports generated Calendars or work logsCalendars or work logs

Contact the Grants Office for adviceContact the Grants Office for advice

Ext. 6948Ext. 694804/20/2304/20/23

When is an accounting When is an accounting adjustment required?adjustment required?

If the difference is 10% or more: If the difference is 10% or more: Payroll charges must be adjusted at the Payroll charges must be adjusted at the

time of the comparisontime of the comparison

AND:AND: The following quarter’s estimates The following quarter’s estimates must be adjusted to more closely reflect must be adjusted to more closely reflect actual activityactual activity

If the difference is less than 10%:If the difference is less than 10%: No action required until the end of the yearNo action required until the end of the year

BUT:BUT: At year-end At year-end any any payroll charges to payroll charges to federal awards that exceed actual time and federal awards that exceed actual time and effort must be reconciledeffort must be reconciled

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Who should sign the Who should sign the reports?reports?

Monthly reportsMonthly reports (PARs) must (PARs) must be signed by the employeebe signed by the employee

Semi annual certificationsSemi annual certifications must be signed by employee must be signed by employee and supervisor having first-hand and supervisor having first-hand knowledge of work performedknowledge of work performed

Internal controls Internal controls through the through the District requires the employee & District requires the employee & supervisor to sign both formssupervisor to sign both forms

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Time and Effort: Tracking / Calculation

Employee Name:  

Position/Title:  

  Track Hours WorkedFUNDING SOURCE July August September October November December

Restricted Program Account Hrs. Effort % Hrs. Effort % Hrs. Effort % Hrs. Effort % Hrs. Effort % Hrs. Effort %

      0%   0%   0%   0%   0%   0%

      0%   0%   0%   0%   0%   0%

      0%   0%   0%   0%   0%   0%

      0%   0%   0%   0%   0%   0%

      0%   0%   0%   0%   0%   0%

  Subtotal 0 0% 0 0% 0 0% 0 0% 0 0% 0 0%

Unrestricted Program                          

      0%   0%   0%   0%   0%   0%

      0%   0%   0%   0%   0%   0%

  Subtotal 0 0% 0 0% 0 0% 0 0% 0 0% 0 0%

Match Fund To Program                          

      0%   0%   0%   0%   0%   0%

      0%   0%   0%   0%   0%   0%

  Subtotal 0 0% 0 0% 0 0% 0 0% 0 0% 0 0%

Other Leave                          

Sick/Vac/Holiday            

Other            

  Subtotal 0 0 0 0 0 0

                           

Total Hours/Month 0   0   0   0   0   0  

Total Actual Work Hours 0 0 0 0 0 0

Total Distribution of Efforts   0%   0%   0%   0%   0%   0%

Caution:Caution:

Beware of Beware of

Re-organization!Re-organization!

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Administrators: Changes can Administrators: Changes can affect program activitiesaffect program activities

President, Vice Presidents, President, Vice Presidents, Deans usually not allowable Deans usually not allowable charges to federal programcharges to federal program Requires good documentation to Requires good documentation to

supportsupport Could be a supplanting issueCould be a supplanting issue

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Other Requirements for Charging Other Requirements for Charging Compensation to Federal ProgramsCompensation to Federal Programs

Reasonable and necessaryReasonable and necessary Compensation consistent with Compensation consistent with

nonfederal activities of the Districtnonfederal activities of the District Leave buy-out at termination is an Leave buy-out at termination is an

indirect charge or may be charged to indirect charge or may be charged to the Divisionthe Division

Other leave (vacation/sick) is subject Other leave (vacation/sick) is subject to OMB Circular A-21, J 10 and to OMB Circular A-21, J 10 and Appendix A, Part 225Appendix A, Part 225

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Tips……Tips……

Know the BasicsKnow the Basics Train employees on the mechanics Train employees on the mechanics

of filing out forms (new employees)of filing out forms (new employees) Identify which program cost Identify which program cost

objectives they are working onobjectives they are working on Communicate:Communicate:

WhoWho needs to communicate needs to communicate whatwhat changes (budget/personnel changes)changes (budget/personnel changes)

Be ready to redirect work of Be ready to redirect work of employees or adjust grant salaryemployees or adjust grant salary

Ask the Grants Office for help if Ask the Grants Office for help if neededneeded

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DiscussionDiscussion

Missing Time and Effort report Missing Time and Effort report documentation is one of the documentation is one of the most frequent and costly audit most frequent and costly audit findings in the state. findings in the state.

How can your department How can your department ensure that every employee ensure that every employee required to report time and effort required to report time and effort does so?does so?

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For Additional InformationFor Additional Information

See OMB Circular A-21See OMB Circular A-21 ExamplesExamples Sample formsSample forms

Time and Effort FAQsTime and Effort FAQs

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Questions?Questions?

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