Time Distribution Report OMB Circular A-87, Attachment B. Paragraph 8 h. Standard Operating Procedures 900-004

What is a TDR? What is a TDR? Time Distribution Report Regulations Who are required to complete TDR’s? All Employees performing federal activities. Where is this requirement established? Time Distribution reporting requirements are part of the allowable cost as defined by the U.S. Office of Management and Budgets (OMB). OMB circulars are applied to all federal grants, contract and cooperative agreements. What is required? The type of record that must be kept is based on the job responsibilities of the individual charged to the grant. What are consequences for not keeping/maintaining TDR’s? The lack of report is the single largest audit finding by the US Office of Inspector General (OIG). Provide documentation to support the COST, in federal expenditures or return that amount to the US Department of Education. What are the implications if Employee falsify documents? Failure to follow guidelines may have serious consequences, including disallowed costs, which would require reimbursement, increased Federal oversight, monitoring, and audit and loss of future Federal funding. Individual s who deliberately falsify, or knowingly allow falsified reports to be processed, maybe subject to disciplinary action including, but not limited to, suspension from participation in sponsored agreements. Government action s may include debarment from government funding and civil and/or criminal sanctions under the False Claims Act. What is a TDR? Time Distribution Report Regulations

Why do Locally funded employees working on Federal Funded Activities have to complete a TDR? TDR demonstrates the employee’s efforts. 34 C.F.R §300.163 Maintenance of State financial support: A state must not reduce the amount of a State financial support. It does not matter if it is IDEA funding, Title I or Head start, all employee’s funded with federal grants must document the time they spend working on the “grants” objectives to demonstrate that the amount budgeted and claimed is accurate.

Why do we need to maintain Time Distribution Report? Guam Department of Education receives significant funding for sponsored projects from the Federal Government. Proper effort certification verifies charges for salaries and wages to Federally funded sponsored projects to reasonably reflect actual work performed. These guidelines explain administrative requirements and financial procedures for maintaining compliance with government and other regulations regarding effort certification. How long should we retain these records? §74.53 Maintain records for at least 3 years that is the period until the statute of limitations expires. However, the length of time to keep records depends on the action, expense, or event. Note: The implementation of the revised TDR would take effect after the timekeepers are trained in Summer 2010. OMB Circular A-87, Attachment B. Paragraph 8 h.

TDR DOCUMENTS Reflect an after-the fact distribution of actual activity. Account for the total activity for which each employee is compensated. Are prepared at least monthly and coincide with one or more pay periods. Are signed by the employee and Supervisor.

SOP Amendments Page 222 Section IV: GENERAL: #4. DELETE Page 222 Section V. DEFINITIONS. #2 . Employee Identification number. Page 224 Section VI . #2. c) The original Time Distribution Report(s) (TDRs), Timesheets, and Turn around Payroll Document must be submitted to Time Keepers no later than 5:00 P.M. Friday of the Pay period Ending (PPE). #3. a). Project Directors (i.e. School Administrators and Program Managers/Director located at the school/work/program site(s) must review and certify the Time Distribution Reports (TDRs) and/or timesheets prior to submitting to Time Keepers by 5:00 p.m. Friday, of the pay period ending. Page 225 Verification of Time Distribution Report (TDR) with Payroll Office. #4 DELETE

Common Errors/ Risks RISKS Entire days/ hours schedule not accounted for. Program Codes do not match job assignment.(examples – Employee is assigned as a 1:1 Aide, TDR is reflecting English as a Second Language (ESL), Program . Employee who is re-assigned to another program (temporary or permanently). Employee/Supervisor signatures are missing Employees do not reflect lunch hour. EIN # missing RISKS Documentation on how individuals spend time on federally funded projects is subject to federal audit and can be cause for institutional or individual disallowances. Federal audit disallowances can result in serious financial penalties for institutions. In addition, criminal charges may be brought against an individual certifying to falsified efforts. Federal auditors included effort reporting as a specific audit focus.

Time Distribution Reporting Flow Process EMPLOYEES Submit TDR and / or Time sheets to the Payroll Turn Around Document Project Director/Program Managers/Directors MUST review and certify all documents before submission to Payroll Office. Submit Timesheets to Payroll Office by Friday PPE or no later than 10:00 A.M. on the following Monday. Time Keepers MUST maintain original TDR with a copy of timesheets at worksite. Federal Programs Personnel will perform compliance review.

GUIDANCE OMB Circular A-87, Cost Principles for State, Local and Indian Tribal Governments, for government entities. EDGAR- Education Department General Administrative Regulations. Part 76 (State Administered Programs). Standard Operating Procedure 900-004