Whats New and Whats Not in Time and Effort

1
Whats New and Whats Not in Time and Effort

• Presented by
• Kim Brodie and JoLynn Berge

2
Whats Not New

• Everyone (except Bill Paulson) still hates time
  and effort.
• Districts are still getting findings on time and
  effort.
• Complexity of applying requirements to variety of
  situations remains.

3
What is New

• LESS time and effort findings are being reported!
• Montana Compact non regulatory guidance
  currently under USDE development.
• Washington State Substitute Plan proposal

4
Whats Not New The Basics

• (JoLynn is sure nobody wants to hear her talk yet
  again about TE basics so I have to slip it in
  when she isnt looking)
• The Basics See OSPI Bulletin No. 006-04
• Any employee compensation charged in part or in
  whole to (a) federal grant(s)s or state or local
  funds being used to match a federal grant must be
  supported by.?

5
Whats Not New The Basics

• ...time effort reports (Personnel Activity
  Report or Semi Annual Certification)
• The frequency and content of the time effort
  records required depends on the number of _ _ _
  _ _ _ _ _ _ _ _ _ _ _ on which an employee
  spends his or her time.

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Whats Not New The Basics

• Cost Objectives
• A cost objective is (a practical definition)

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Whats Not New The Basics

• a set of work activities allowable under the
  terms and conditions of a funding source or
  sources.
• Fill in the blanks

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Whats Not New The Basics
9
Whats Not New The Basics

• The minimum requirements for Semi Annual
  Certifications are

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Whats Not New The Basics

• Time period covered (must correspond to pay
  period(s) and be no more than 6 mos.)
• Name or code of cost objective
• Supervisors after-the-fact dated signature
• Statement that the employee worked solely on
  activities of the cost objective for the period
  covered.
• While the minimum requirements for PARs are

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Whats Not New The Basics

• Time period covered (must correspond to pay
  period(s) and be no more 1 mo.)
• Name or code of cost objective
• Employees after-the-fact dated signature
• Cover 100 of the employees compensated time
  (not just the time worked on federal awards)
• Reflect the actual time the employee worked on
  the cost objective

12
Whats Not New The Basics

• Payroll paid based on budgeted (estimated)
  distributions must be compared to actual time
  effort reported at least.how often?

13
Whats Not New The Basics

• Quarterly
• If the quarterly difference is __?__ or more,
  payroll accounts must be adjusted to reflect
  distributions as reported in time effort.
• At year-end, ____ differences must be adjusted in
  the payroll records.

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Whats Not New The Basics

• 10, All
• Additional guidance is available on circumstances
  unique to school districts such as Title I
  Schoolwide programs, flexibility provisions under
  NCLB, school administrators, supplemental
  contracts/ stipends/extra hours, and Medicaid
  Admin Match in the

15
Whats Not New The Basics

• OSPI Bulletin and/or calling OSPI federal grant
  staff.

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Montana Compact Highlights

• Purpose
• Provide national clarification and consistency
  for FAQ on time and effort for USDE grants.
• Non regulatory guidance (currently in draft
  form).
• Developed with input from state and local
  governments including WA.
• Now calling for all constructive feedback...

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Montana Compact Highlights

• The draft grants officially blessed status to
  many current WA state interpretations /
  practices
• Treatment based on employee work activities --
  not payroll distribution.
• Method for payment based on 9-month work-year
  with 12-month payroll.
• TE requirements related to substitute teachers.

18
Montana Compact Highlights

• Aggregate-level payroll adjustments.
• Use of blanket or group certifications for
  employees working 100 in a T. I Schoolwide
  program.
• Treatment of de minimus time.

19
Montana Compact Highlights

• May require a small change to at least one
  prevalent WA state practice
• Treatment for overtime and supplemental / extra
  hourly contracts.

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Montana Compact Highlights

• Calls out risky issuesThose that are clear in
  current guidance but often overlooked by everyone
  but the Auditor in practice
• T E requirements for state and local funds used
  as match to a federal grant.
• T E requirements for indirect charges.
• T E requirements for classroom teachers.

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Montana Compact Highlights

• More to come????
• What issue would you like to see addressed in the
  guidance?
• Call or email
• JoLynn Berge, OSPI

22
Washington State Substitute Plan Proposal

• THIS IS OPTIONAL!!!!!
• THIS IS OPTIONAL!!!!!!!
• THIS IS OPTIONAL!!!!!!!!!!!!
• No district will be required to implement any
  part of the proposal.

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Other Necessary Disclaimers

• This is a proposal that HAS NOT YET been approved
  by the U.S. Department of Education.
• This is a draft, this is only a draft.

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Exception Reporting

• Concept
• Time and effort reporting for staff with a set
  schedule will consist of a signed certification
  stating the schedule was worked exceptions (any
  deviation from the employees set schedule) will
  be reported throughout the work-year.

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Exception Reporting

• Question Who is this intended for?
• Answer Staff who have fixed schedules.
• Example Teacher whose teaches three periods
  Title I and three periods something else.

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Exception Reporting

• Question Who is this NOT intended for?
• Answer Administrators and others who dont work
  a set schedule.
• Example Director of Special Services, oversees
  all federal programs and LAP. Recommend the
  district develop a substitute system.

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Substitute Systems

• Concept
• Time and effort reporting for staff who work on
  multiple cost objectives will consist of a three
  month time study (3 months of time and effort)
  reported throughout the work-year.
• Benefit Only three months of time and effort!

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Substitute Systems

• Question Who is this intended for?
• Answer Administrators, or others who work on
  multiple cost objectives.
• Example Director of Special Services who
  oversees all federal and state programs.
  Prepares monthly time and effort for three
  representative months.

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Questions?

• ?
• ? ?
• ?
• ? ?

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For Additional Information

• See OSPI Bulletin 006-04
• Examples
• Sample forms
• OMB Circular A-87, Cost Principles for State,
  Local, and Tribal Governments