New USDE Guidance on Federal Programs Substitute Time and Effort System Cory Green, Chief Grants Administrator David McLaughlin, Federal Fiscal Compliance Officer December 19, 2012 © 2012 The Texas Education Agency

 Paying only proportionate share of personnel costs with federal funds  Salaries charged to federal funds? Time distribution records required  Contractors not subject to time-and-effort requirements  Two types of records: ◦ Semiannual certification ◦ Personnel activity report (PAR) What Is Time-and-Effort (T&E) Reporting? 2

 After-the-fact record (dated)  Accounts for total compensated activity  Completed at least every six months  Signed by supervisor with knowledge of employee  Coincides with one or more pay periods  Traditionally applied to employees supported by a single cost objective Semiannual Certification Requirements 3

 After-the-fact record (dated)  Accounts for the total activity for which employee compensated  At least monthly  Signed by the employee  Must coincide with one or more pay periods  Traditionally applied to employees supported by multiple cost objectives PAR Requirements 4

 Definition: “A function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred.”  Multiple funding sources may still be single cost objective September 7, 2012, USDE Guidance: Single Cost Objective 5

 Employees supported by single cost objective submit semiannual certification  Regardless of whether LEA implements substitute system September 7, 2012, USDE Guidance: Single Cost Objective 6

“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 non-federal funds.” Determining Single Cost Objective 7

 Supplemental math teacher serves low- achieving students on a Title I campus  Paid half from Title I, Part A, and half from state funds  Teaching math to low-achieving students can be fully supported under Title I, Part A Example I: Title I, Part A, and State Funds 8

 Single cost objective  Only a semiannual certification is required, despite federal/state funding split Example I: Title I, Part A, and State Funds (Cont’d) 9

 Preschool special education teacher split- funded between IDEA sections 611 and 619  Teaching preschool special education is allowable under both sections.  Single cost objective  Only a semiannual certification is required, regardless of multiple federal awards Example II: Two Sections of IDEA-B 10

 State curriculum specialist develops new CTE courses and initiatives  Funded half with Perkins and half with state general funds  Single cost objective  Only a semiannual certification is required, regardless of split between federal and state funds Example III: Perkins and State Funds 11

Employee works on:  Multiple federal awards (not meeting single cost objective definition)  Federal and non-federal awards (again, not meeting definition) What Are Multiple Cost Objectives? 12

 Indirect/direct cost activities  Multiple indirect activities allocated using different allocation bases  Unallowable activity and direct or indirect cost activity What Are Multiple Cost Objectives? (Cont’d) 13

Multiple cost objective employees may submit semiannual certification, if: ◦ LEA submits management certification to TEA ◦ Employee completes schedule and certification ◦ Is in effect for entire school year Applies to all LEAs, including ESCs and charters New USDE Guidance (September 7, 2012) 14

Substitute system does not affect Ed-Flex. Ed-Flex Waiver

 Form on Substitute System page (search for “Substitute System” or follow link from Grants page)Substitute System Grants  LEA must complete/submit form every school year  Form submitted by mail as specified on Substitute System page Substitute System  Due February 15, 2013, for  May be retroactive to July 1, 2012 LEA Requirement: Management Certification 16

 Must currently work on a schedule that includes multiple activities or cost objectives that must be supported by monthly PARs  Must work on specific activities or cost objectives based on a predetermined, consistent schedule  May not work on multiple activities or cost objectives at the exact same time Conditions for Employee Participation 17

 Employee schedule must: Indicate specific activity/cost objective employee worked on for each segment of employee’s schedule Account for total hours for which each employee compensated during schedule period Be completed again/resubmitted if schedule changes by more than 10% Employee Schedule Requirements 18

 Employees must complete work schedule and certification  Schedule and certification submitted to LEA business office  Certification must be semiannual at least  Signed by employee and supervisor with firsthand knowledge of employee’s work Employee Schedule and Certification 19

 TEA developed sample employee schedule and certification form  Auto-calculating spreadsheet  Includes all elements TEA auditors require  LEAs not required to use TEA form  If LEAs develop own form, must include all required elements TEA-Developed Schedule and Certification 20

 Spreadsheet includes instructions, schedule, and certificate  All material covered here included in instructions  Read instructions first  Complete schedule next  Finish with certification Demonstration of TEA Form TEA FormTEA Form 21

 Complete name, position, district, schedule period fields  Complete program table (list of programs worked on)  Identify time worked on programs each day Demonstration of TEA Form: Schedule TEA FormTEA Form 22

 Name, position, schedule period, and district info will auto populate certification Demonstration of TEA Form: Name TEA FormTEA Form 23 Entered Manually on Schedule Populates on Certification

 Must list all programs worked on  Room for eight programs, including local funds  Use dropdown when possible to list programs  Dropdown menu available fields A-E  For other programs, manual entry fields F and G Demonstration of TEA Form: Programs TEA FormTEA Form 24

Demonstration of TEA Form: Program Dropdown List TEA FormTEA Form 25 Select SOF from dropdown list

Demonstration of TEA Form: Manual Program Entry TEA FormTEA Form 26

 Document regular daily schedule  Dropdown list for minutes worked, 15- minute increments  Manually type brief description of activity  Dropdown letter list (A-H) to associate activity with program  Program list will update with total minutes Demonstration of TEA Form: Time Worked TEA FormTEA Form 27

Demonstration of TEA Form: Schedule Row TEA FormTEA Form 28

Demonstration of TEA Form: Minutes Dropdown TEA FormTEA Form 29 Select period of minutes from dropdown list

Demonstration of TEA Form: Activity Description TEA FormTEA Form 30 Manually enter activity

Demonstration of TEA Form: Associate Program by Letter TEA FormTEA Form 31 Select SOF Code (from above) from dropdown list

Demonstration of TEA Form: Minutes by Program TEA FormTEA Form 32

Demonstration of TEA Form: Schedule with Multiple Rows/Programs TEA FormTEA Form 33

Demonstration of TEA Form: Program List with Minutes Charged to Multiple Programs TEA FormTEA Form 34 Funding Percentages auto- calculate as time is entered

 Lunch accounted for on last row of schedule  Lunch minutes are not part of program calculation Demonstration of TEA Form: Accounting for Lunch TEA FormTEA Form 35

 Much content of certificate autofills from schedule  Following content entered manually: ◦ Total hours worked ◦ Total lunch hours ◦ Fund codes ◦ Employee signature/supervisor name and signature Demonstration of TEA Form: Certificate TEA FormTEA Form 36

 Name, position, schedule period, and district information auto fills from schedule Demonstration of TEA Form: Identifying Information TEA FormTEA Form 37

 Manually enter total number of hours worked  Manually enter total number of lunch hours (actual hours, rather than lunch periods)  Check the following: ◦ Total hours times 60 (a) equals total minutes Demonstration of TEA Form: Hours TEA FormTEA Form 38

Demonstration of TEA Form: Hours TEA FormTEA Form 39

Demonstration of TEA Form: Fund Codes TEA FormTEA Form 40 Enter the appropriate Fund Code for each SOF

 USDE September 7, 2012, letterletter  Chief Grants Administrator section of the Grants page of TEA website Grants  Substitute System page of TEA website (search for “Substitute System” or follow link from Grants page) Substitute SystemGrants Resources and Further Information 41

Questions?

 Copyright © Notice. The materials are copyrighted © and trademarked ™ as the property of the Texas Education Agency (TEA) and may not be reproduced without the express written permission of TEA, except under the following conditions:  Texas public school districts, charter schools, and Education Service Centers may reproduce and use copies of the Materials and Related Materials for the districts’ and schools’ educational use without obtaining permission from TEA.  Residents of the state of Texas may reproduce and use copies of the Materials and Related Materials for individual personal use only without obtaining written permission of TEA.  Any portion reproduced must be reproduced in its entirety and remain unedited, unaltered and unchanged in any way.  No monetary charge can be made for the reproduced materials or any document containing them; however, a reasonable charge to cover only the cost of reproduction and distribution may be charged.  Private entities or persons located in Texas that are not Texas public school districts, Texas Education Service Centers, or Texas charter schools or any entity, whether public or private, educational or non-educational, located outside the state of Texas MUST obtain written approval from TEA and will be required to enter into a license agreement that may involve the payment of a licensing fee or a royalty.  For information contact: Texas Education Agency, 1701 N. Congress Ave., Austin, TX ; 43