fiscal compliance for title iii keisha davis monitoring & compliance section school business...

Fiscal Compliance for Title III

Keisha DavisMonitoring & Compliance Section

School Business Division919-807-3682

lakeisha.halldavis@dpi.nc.gov

Fiscal ComplianceItems Included:

Time and Effort Documentation

Equipment records

Contracts/Invoices

Administration Limitation

Indirect Cost

Supplement/Supplant BAAS

Time and Effort

• Applies to every employee funded from federal funds.

• Purpose: To document that the appropriate federal program is receiving the benefit of the services supported by grant funds.

• Time and Effort documentation is required by OMB Circular A-87, Attachment B, Item 8 (h), and is in addition to the standards for payroll documentation.

Two Types of Participating Employees:

• Single Cost Objective– Employees must have at least semi-annual

certifications that they worked solely on that program.

– Certifications must be signed by the employee or the supervisor who has first hand knowledge of the work performed.

• Multiple Cost Objectives– Monthly Personnel Activity Reports (PARs)– Signed by employee

What does a “semi-annual certification” look like?

• A simple statement: “I, Wonderful Employee, certify that I spent 100% of my time for the period of January 1, 20XX, through June 30, 20XX, on Title III activities.”

OR• A “blanket” statement signed by the

supervisor with first-hand knowledge of employees’ work.

Multiple Cost Objective Employees• Salaries and wages must be supported by completing

monthly personnel activity reports (PAR forms) unless a substitute system has been approved.

• PAR Forms MUST• Reflect an after-the-fact distribution of the actual activity of

each employee;• Account for the total activity for which each employee is

compensated;• Be prepared at least monthly and must coincide with one or

more pay periods; and• Be signed by the employee.

What does a PAR form look like?

Month: January 2009 Position Number: 045 Employee:

Effort:

Week 1: January 1-3 Supervisor's Initials:

Column DPERCENT ALLOCATION

Percentage of time this week spent on each cost objective

(Column B / Column C x 100%)

50%

50%

Week 2: January 4-10 Supervisor's Initials:

PERCENT ALLOCATION

60%

40%

Week 3: January 11-17 Supervisor's Initials:

PERCENT ALLOCATION

65%

35%

Week 4: January 18-24 Supervisor's Initials:

PERCENT ALLOCATION

50%

50%

Week 5: January 25-31 Supervisor's Initials:

PERCENT ALLOCATION

45%

55%

2/2/2009Date

2/3/2009Date

Migrant 14

Migrant

TIME - Cost Objective

16

Column BTIME - Cost Objective

Total hours this week spent on each cost objective

Title III

COST OBJECTIVE

4

16

Migrant 16

PERSONNEL ACTIVITY REPORT

Ted D. Behr

Employee time and effort is allocated 50% to Title III and 50% to Migrant Education.

Joe Johnson

Ted D. Behr

COST OBJECTIVE TIME - Cost Objective

Title III 18

Monthly Percent Allocation

Supervisor's Signature and Title

Migrant 22

88/160 = 55% Title III

I hereby certify that the information contained in this Time and Effort Report accurately reflects actual time and effort distribution forthe month reported.

40

Employee's Signature

COST OBJECTIVE TIME - Cost Objective

Title III

COST OBJECTIVE TIME - Cost Objective

Title III 26

4

Column CTIME - Total

Total hours worked this week

8

Column ACOST OBJECTIVE

Cost objectives upon which time was spent this week

Title III

Migrant

72/160 = 45% Migrant

TIME - Total

TIME - Total

TIME - Total

40

40

TIME - Total

32

24

Important notes about PARs

• PAR forms must be supported by more detailed documentation, such as a calendar with daily entries regarding activities supporting each cost objective

• Results of PAR forms must be reconciled against payroll (usually a finance function)

Which LEAs are approved to use substitute systems?

Special Note on Schoolwide Schools

• In a Title I Schoolwide School, all funds lose their identity.

• Employees in a Schoolwide School may be paid from any fund source, or any combination of funding sources, and their effort statement would state “100% Title I Schoolwide Activities”, making a certification statement the appropriate documentation.

• Employees in a Schoolwide School who are paid from federal funds are the ones who document their time and effort.

Additional Training

There is a presentation on web at: http://www.ncpublicschools.org/docs/fbs/conferences/presentations/summer12/timeeffort.pdf

Questions?

Equipment• Federal regulations require certain records

to be kept• Not to be confused with “fixed assets”

tracking• What to track?

Items with a useful life > 1 year

Police report filed if the item “disappears”

Include small “attractive” items

Equipment

Education Department General Administrative Regulations (EDGAR) 34 CFR 80.32

(d) Management requirements

(1) Property records

must be maintained that

include…

• Description of the property• Serial number or other identification number• Source of property• Who holds title• Acquisition date• Cost of the property• Percentage of Federal participation in the cost• Location, use, and condition• Disposition data (including date of disposal and

sale price)

Equipment (cont’d)

Other Equipment Management Requirements:

• Physical inventory (reconciled with property records at least once every 2 years – annual is good)

• Control system• Adequate maintenance procedures• DPI Equipment Disposition process

– http://www.ncpublicschools.org/fbs/finance/federal/ under the “Monitoring” heading

Questions?

Contracts/Invoices

• Contracts for personnel services MUST be specific – who, what, when, where.

• Payments from object code 311 must be supported by a valid written contract.

• Invoices must also be detailed – it is not enough to just refer to the contract number.

Contracts (cont’d)• Suspension/Debarment

– Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred.

• Debarred Vendors list – State can be found at: http://www.pandc.nc.gov/PnCInformation.htm – Federal can be found at: https://www.sam.gov/portal/public/SAM/

Questions?

Administrative Costs

• Administrative Cost is limited to 2% of current year allotment

• What is considered Administrative Cost? • Unspent portion of allowable Admin

expenditures can be carried forward to the next year (assuming sufficient carryover exists)

Indirect Cost

• Indirect cost is not the same as administrative costs, but is part of it

• If your indirect cost rate is more the limitation, you may be limited in the amount of indirect cost you can recover

• Your actual rate can be applied to qualifying expenditures if the total is less than the administrative cost limitation.

Example

• Allotment of $100,000; 2% administrative cost limitation means that $2,000 is the maximum administrative cost that can be charged. (100,000 x 2%)

• LEA’s indirect cost rate is 3%, the entire $100,000 allotment is spent in the first 12 months, and the expenditures include $40,000 in object code 311 – Contracted Services.

• Therefore, there are $60,000 in ‘qualifying’ expenditures; thus, only $1,800 can be recovered from indirect cost ($60,000 x 3%)

Questions?

Supplement, Not Supplant

• What services is the LEA required by other Federal, State, local laws or regulations to provide?

• How has the LEA demonstrated that it is not using Title III funds to provide services that it is required to make available under State or local laws or other Federal laws?

• How has the LEA demonstrated that it is not using Title III funds to provide services that it provided in the prior year with State, local or other Federal funds?

Still Unsure…

• If you are not sure of compliance based on the answers of the three (3) previous questions, please talk to your Title III Program Consultant.

Questions?

BAAS

• What is it?• BAAS is a new Budget and Amendment

Approval System (BAAS) at DPI• BAAS will replace the budget/amendment

subsystem of BUD• The GL and Salary adjustment (202)

subsystem of BUD has NOT gone away.

A Look at BAAS

• If you want to use the system, you must subscribe using your NCID and password.

Directions can be found at:

http://www.ncpublicschools.org/fbs/

Look for ‘Subscribing to BAAS’

• Will have inquiry access only

Questions About BAAS?

E-Mail• DPI Help Desk at:

dpi.incidents@its.nc.gov

Questions?

Resources

Federal information:

OMB Circulars, EDGARhttp://www.ncpublicschools.org/fbs/finance/federal/

Contacts

Monitoring & Compliance Section:

Keisha Davis919-807-3682lakeisha.hallddavis@dpi.nc.gov

Karen Frazier919-807-3738karen.frazier@dpi.nc.gov