Title I Administrative MeetingSeptember 30, 2010

OMB Circular A-87, Attachment B, Section 8(h) “Support of Salaries and Wages”

Standards regarding time distribution are in addition to the standards for payroll documentation.

If Federal funds are used for salaries and wages, then “time distribution records” are REQUIRED.

Records must demonstrate employee worked an appropriate amount on the specific Federal Program

100% on a Single Cost ObjectiveCharges for their salaries and wages will:Be supported by periodic certifications that

the employee worked solely on that program for the period covered by the certification

Certifications will be prepared at least semi-annually

Signed by the employee and/or supervisory official having first hand knowledge of the work performed (both signatures recommended)

Employee’s time spent on multiple cost objectives:

An employee who works on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports (PARs) More than one Federal awardA Federal award and a non-Federal awardAn indirect cost activity and a direct cost

activity

Personnel Activity Reports(PARs) Need to complete at least monthly, after the

work has been completed.Must reflect employee’s total work time and

identify portion spent on the federal project.Must be signed by the employee.Must be supported with documentation of

actual effort, not estimates.

Supporting DocumentationCould be:Work CalendarWork ProductTime LogClass Schedule

The employee who signs off on the PAR must have supporting documentation for the actual effort, not estimates.

No Standard Format used for PARsThe required information that must be on

PARs:Employer’s NameEmployee’s Name/PositionFederal program/CFDA#Reporting Period100% of Work activitiesEmployee’s Signature

Time and Effort Reporting and Claims for Federal Funds

If payroll is processed based on budgeted or estimated time and activities than payroll records must:Make quarterly comparisons;If the difference is greater than 10% than payroll

charges must be adjusted at the time of comparison and subsequent quarterly estimates must be amended to more closely reflect actual activities;

If less than 10%, the adjustment can occur at the end of year (adjustments are a must)

Consequences for not keeping federal grant time and effort reports

The lack of time and effort is the single largest audit finding by the OIG

Costs that do not have adequate documentation are deemed “unallowable” and subject to repayment!

Avoid Possible Loss of FundsDistricts should have:Written policies and procedures for periodic

certifications and personnel activity reportsWritten policies and procedures for properly

allocating costs to t he federal programs and properly train staff on the procedures.

OMB Circular A-87 can be found:http://www.whitehouse.gov/omb/

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