Time and Effort Reporting 13 th Annual Title Programs Conference Title II, Part A Workshop June 18 19, 2015 Saralyn Barkley Title II, Part A Specialist sbarkley@doe.k12.ga.us Office of School Improvement Elizabeth Zipperer Title II, Part A Specialist ezipperer@doe.k12.ga.us Office of School Improvement 6/18/2015 1 AGENDA Common to Title II, Part A Federal Regulations Guidance Sample Documentation 6/18/2015 2 For Title II, Part A 6/18/2015 3 1
Salary and wages paid to employees also includes associated benefits If funded either in whole or in part by a federal program must be documented in accordance to federal regulations Payments to employees recorded in any object code in the 100 series Personnel Services (GaDOE LUA Chart of Accounts) 6/18/2015 4 Common Salaries Funded by Title II, Part A 110 CSR teachers 190 Title II, Part A coordinator 113 Sub for CSR teacher 191 Instructional/academic coaches 113 Sub for teachers attending PL 191 Professional learning specialists 114 Sub for paraprofessional attending PL 199 Staff mentoring beyond contracted time 116 Stipends for PL 199 142 Secretary/clerical support 199 Staff providing PL beyond contracted time Recruitment/retention incentives * 6/18/2015 5 Recruitment/Retention Financial Incentives Not subject to time and effort requirements Incentives are not based on any completion of work related to the Title II, Part A grant Authorization for funding by Title II, Part A ESEA SEC. 2123. Local Use of Funds Improving Teacher Quality State Grants Non Regulatory Guidance October 5, 2006, E 1 Expenditure must be documented in compliance with federal grant and local state guidance Guidance and a sample form for documenting recruitment/retention incentives are available on the Title II, Part A webpage 6/18/2015 6 2
Federal Regulations 6/18/2015 7 Federal Regulations CURRENT RULE EXPIRING EDGAR Office of Management and Budget Circular A 87 (Appendix B Section 8 (h)(3 5)) NEW RULE July 1, 2015 EDGAR Uniform Administrative Requirements, Cost Principals and Audit Requirements for Federal Awards 2 C.F.R. Part 200 ( 200.430(i)) 6/18/2015 8 OMB Circular A-87 Appendix A to Part 225 General Principles for Determining Allowable Costs SEC. 8 (h) Support of Salaries and Wages current rule Charges to Federal awards for salaries and wages will be based on payrolls documented in accordance with generally accepted practice of the governmental unit and approved by responsible official(s) of the governmental unit. OMB Circular A 87 Sec. 8 (h)(1) 6/18/2015 9 3
Support of Salaries and Wages Semi Annual Certification If employee works on single cost objective After the fact Account for total activity Signed by employee or supervisor Every six months (at least twice a year) OMB Circular A 87 Sec. 8(h)(3) Personnel Activity Reports (PAR) If employee works on multiple cost objectives After the fact Account for total activity Signed by employee Prepared at least monthly and coincide with one or more pay periods OMB Circular A 87 Sec. 8(h)(4) 6/18/2015 10 Cost Objective Single or Multiple Cost Objective Program, function, activity, award, organizational subdivision, contract, or work unit for which cost data are desired and for which provision is made to accumulate and measure the cost of processes, products, jobs, capital projects, etc. Single Cost Objective Single function or single award (grant) or single activity 6/18/2015 11 Cost Objective Single or Multiple The key to determining whether an employee is working on a single cost objective is whether the employee s salary and wages can be supported in full from each of the Federal awards on which the employee is working, or from the Federal award alone if the employee s salary is also paid with nonfederal funds USEd Guidance Letter to Chief State School Officers on Granting Flexibility for Better Measurement of Success, Sep 7, 2012 6/18/2015 12 4
EDGAR 2 C.F.R. Part 200 Uniform Administrative Requirements, Cost Principals and Audit Requirements for Federal Awards 200.430 (i) Standards for Documentation of 6/18/2015 13 Standards for Documentation of 200.430 (i) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated Be incorporated into the official records of the non Federal entity Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities 6/18/2015 14 Standards for Documentation of Encompass both federally assisted and all other activities compensated by the non federal entity on an integrated basis, but may include the use of subsidiary accounts as defined in the non Federal entity s written policy Comply with the established accounting policies and practices of the non Federal entity Support the distribution of the employee s salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non Federal award 6/18/2015 15 5
Standards for Documentation of Budget estimates alone do not qualify as support for charges to Federal awards. May be used for interim accounting purposes if: Produces reasonable approximations Significant changes to the corresponding work activity are identified in a timely manner Internal controls in place to review after the fact interim charges based on budget estimates All necessary adjustments must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated 6/18/2015 16 Standards for Documentation of (Compliance) For records which meet the standards, the non federal entity will not be required to provide additional support or documentation of the work performed US Department of Labor Fair Labor Standards Act must still be met (i.e. charges for the salaries of non exempt employees must be supported indicating the total hours worked each day) 6/18/2015 17 Standards for Documentation of (Non Compliance) For a non Federal entity where the records do not meet these standards USDE may require personnel activity reports (PARs), including prescribed certifications or equivalent documentation that support the records as required in this section 6/18/2015 18 6
Guidance and Sample Formats for 6/18/2015 19 Review Current Procedures/Documentation Under what circumstances does the LEA pay for release time (substitutes) for teachers for PL? release time (substitutes) for paraprofessionals for PL? stipends for PL? (must align with SBOE rule 160 3 3.04) teacher and/or principal mentors? staff providing PL to other staff members? For each type of personnel expense, what records accurately reflect the work? document accurate payment? document allowability? document the appropriate amount is charged to each funding source? (properly allocated) authorize the expenditure from Title II, Part A? 6/18/2015 20 Personnel Expense Salary for Core Academic CSR Teacher (1000 110) Wholly or Partially Funded by Title II, Part A Semi Annual Certification identifying the teacher name, school, fund source and authorizing signature School Master Schedule that aligns with the class size reduction worksheet designating segments reduced Salary for Substitute for Core Academic Content CSR Teacher (1000 113) Periodic Certification identifying the substitute teacher, date(s) worked, fund source and authorizing signature Allowability Documentation: Documentation that connects the name of the substitute teacher, name of the CSR teacher, date(s) of absence, amount paid substitute, and funding source Procedures for daily pay rate for substitutes 6/18/2015 21 7
Accurately reflects the work Properly allocated when aligned with CSR worksheet and schedule Allowable when schedule is supported by CSR Worksheet. Need authorizing signature 6/18/2015 22 Personnel Expenses Personnel Expense Wholly or Partially Funded by Title II, Part A Salary for Substitute for teacher attending Title II, Part A allowable professional learning (PL) (2210 113) Periodic Certification identifying the substitute teacher name, date(s) worked, fund source and authorizing signature Allowability Documentation: Documentation that connects the name of each substitute teacher with the corresponding name of the core academic teacher attending Title II, Part A allowable professional learning, School, Grade/ Content, date(s) of absence, title of professional learning activity, evidence of teacher s attendance, and evidence of allowability of the professional learning activity attended Procedures for daily pay rate for substitutes 6/18/2015 23 Substitutes Accurately reflects the work Accurate payment Need authorizing signature Allowable participant Allowable PL with agenda, description Properly allocated 6/18/2015 24 8
PL Leave Form Properly allocated Top portion of form 6/18/2015 25 PL Leave Form Allowable PL with agenda, description Authorizing signature? Bottom portion of form Linking sub with teacher s absence 6/18/2015 26 Personnel Expense Stipends for Core Academic Content Teacher, Paraprofessional, Assistant Principal, or Principal Completing Professional Learning (2210 116) Wholly Funded by Title II, Part A Periodic Certification identifying the staff member name, date(s) worked, fund source and authorizing signature. Allowability Documentation: Documentation that connects the name of the staff member, position (if teacher must include grade/ content), site/school, date(s) of absence, title of professional learning activity, evidence of staff member s attendance during off contract hours, amount of stipend to be paid and evidence of allowability of the professional learning activity attended. LEA Policy for payment of stipends (must comply w/ SBOE Board Rule 160 3 3.04). 6/18/2015 27 9
Periodic Certification multiple employees 6/18/2015 28 PL Stipend Allowable PL with agenda, description, etc. Allowable charge if aligns with LEA procedures 160 Allowable participant Accurate payment If aligns with LEA procedures 6/18/2015 29 PL Stipends Properly allocated Properly allocated Allowable PL with attached documents Need authorizing signature 6/18/2015 30 10
PL Sign-In Roster Allowable outside regular school year Allowable participant? needs job assignment 6/18/2015 31 PL Agenda Allowable PL 6/18/2015 32 Personnel Expense Salary for Administrative/ Clerical Support (2210/2230/ 2800 142) Wholly Funded by Title II, Part A Semi Annual Certification identifying the staff member name, job title, site/ school, fund source and authorizing signature. Partially Funded by Title II, Part A Time Log: List of daily work activities (specific enough to determine allowability) for Title II, Part A and all other fund sources that make up part of regular salary. Must include total hours worked for each funding source and percentage of total time worked allocated to each funding source. Must include authorizing signature. (Total percentage of work must not exceed 100%) 6/18/2015 33 11
Personnel Expense Salary for LEA Coordinator for Title II, Part A Program (2230 190) Wholly Funded by Title II, Part A Semi Annual Certification identifying the staff member name, job title, site/ school, fund source and authorizing signature. Partially Funded by Title II, Part A Time Log: List of daily work activities (specific enough to determine allowability) for Title II, Part A and all other fund sources that make up part of regular salary. Must include total hours worked for each funding source and percentage of total time worked allocated to each funding source. Must include authorizing signature. (Total percentage of work must not exceed 100%) 6/18/2015 34 Semi-Annual Certification Semi Annual Certification (Staff working solely on one Federal cost objective) Time Period: through. (date) (date) This is to certify that,, (Employee s Name) (Employee s Job Title) worked solely on Title II, Part A allowable activities as described in the attached job description during the time period indicated above. Signature of employee Accurately reflects work; allowability Printed name of supervisor Date Signature of supervisor Date 6/18/2015 35 Personnel Activity Report Accurately reflects work; allowability Properly allocated Need authorizing signature 6/18/2015 36 12
Personnel Expense Salary for Instructional/ Academic Coach or Professional Learning Specialist All job duties allowable under all funding sources. (2210 190/191) Personnel Expense Salary for Instructional/ Academic Coach or Professional Learning Specialist Some allowable duties and additional job duties not allowable under Title II, Part A. (2210 190/191) Wholly or Partially Funded by Title II, Part A Semi Annual Certification identifying the staff member name, job title, site/ school, fund source and authorizing signature. Partially Funded by Title II, Part A Time Log: List of daily work activities (specific enough to determine allowability) for Title II, Part A and all other fund sources that make up part of regular salary. Must include total hours worked for each funding source and percentage of total time worked allocated to each funding source. Must include authorizing signature. (Total percentage of work must not exceed 100%) 6/18/2015 37 Personnel Expense Salary for Teacher or Principal Mentor (2210 199) Wholly Funded by Title II, Part A Periodic Certification identifying the mentor member name, job title (if teacher must include grade/ content), site/school, fund source, and authorizing signature. Allowability Documentation: Documentation that connects the name of the mentor, name of mentee, position of mentee (if teacher must include grade/ content), site/school, amount of payment for mentoring services provided. LEA Procedures for awarding payments to mentors. Mentor Log of mentoring activities which, for payment, must occur during non contracted time. 6/18/2015 38 Mentor Teacher Allowable participant School or other Worksite: XYZ School District Periodic Certification Teacher Mentor Southside Elementary Certification Period (from/to): July 28, 2014 December 15, 2014 Mentor Name Job Assignment Mentee Name Job Assignment Accurate payment Mentor Payment Julie Jones 3 rd Grade Teacher Sandra Smith 3 rd Grade Teacher $250 Mary Fields 5 th Grade Math Teacher Tom Randall 4 th Grade Math Teacher $250 I certify I have firsthand knowledge the mentor teachers listed above performed the work described on the attached mentor time logs during the Certification Period. Accurately reflects Signature of School Principal Date the work These mentor payments align with District procedures on payment of teacher and/or principal mentors. I authorize the mentor payments listed above as an expenditure from FY15 Title II, Part A funds, 414 1874 2210 199. Authorizing signature; Signature of LEA Title II, Part A Coordinator Date Properly allocated 6/18/2015 39 13
Mentor Teacher Allowable participant Accurately reflects the work 6/18/2015 40 Mentor Teacher Hours documented are supplemental to contracted time 6/18/2015 41 Personnel Expense Wholly Funded by Title II, Part A Salary for Staff Providing Professional Learning (2210 191) Periodic Certification identifying the staff member name, job title, date(s) and authorizing signature. Allowability Documentation: Documentation that connects the name of the staff providing professional learning with the dates and times of professional learning to verify occurrence outside of contract hours, attendance roster, site/school, amount of payment to staff for providing professional learning and evidence of allowability of the professional learning activity provided. LEA Procedures for awarding payments to staff members for providing professional learning. 6/18/2015 42 14
Allowable PL with agenda, description, etc. Properly allocated Outside regular contracted day Authorizing signature Accurate payment 6/18/2015 43 PL Sign-In Roster Outside regular school day Allowable participant 6/18/2015 44 Resources Education Department General Administrative Regulations (EDGAR) and Other Applicable Grant Regulations http://www2.ed.gov/policy/fund/reg/edgarreg/edgar.ht ml Funded by Title II, Part A http://www./school Improvement/Teacherand Leader Effectiveness/Pages/Title II Part A Home.aspx Title II, Part A Education Specialist assigned to your LEA 6/18/2015 45 15
Map and Specialists Carly Ambler Saralyn Barkley Sharon Brown Pam Daniels Greg Petersen Terri Still Elizabeth Zipperer cambler@doe.k12.ga.us sbarkley@doe.k12.ga.us shbrown@doe.k12.ga.us pdaniels@doe.k12.ga.us gpetersen@doe.k12.ga.us tstill@doe.k12.ga.us ezipperer@doe.k12.ga.us 6/18/2015 46 Time and Effort Reporting 13 th Annual Title Programs Conference Title II, Part A Workshop June 18 19, 2015 Saralyn Barkley Title II, Part A Specialist sbarkley@doe.k12.ga.us Office of School Improvement Elizabeth Zipperer Title II, Part A Specialist ezipperer@doe.k12.ga.us Office of School Improvement 6/18/2015 47 16