Commissioner's Memos

All employees who are paid from federal funds must document their time and effort.

Time and effort reporting requirements are part of the allowable costs, as defined by the U.S. Office of Management and Budgets (OMB).  OMB Circular A-87 outlines the following requirements regarding time distribution records for employees paid with federal (including Title I) funds:

• Employees working exclusively on Title I or solely on a single federal cost objective:  An employee whose salary is paid in whole from Title I funds or 100% from a single funding source must certify, on a semi-annual basis, that he or she “worked solely on that program for the period covered by the certification”.  The certification must be signed by the employee or by a supervisor “having first-hand knowledge of the work performed by the employee”.  This certifies the time and effort of all federally-funded employees in the school, by individual program (see Sample 1).
• Schoolwide is a single objective.  Semi-annual certifications are required for anyone who works 100% in a schoolwide school.  If an employee’s time is split between activities in a schoolwide school and activities not in the schoolwide school, then monthly personnel activity reports (PARs) would be required.
• Employees working on multiple cost objectives:  An employee, who works for more than one federal program, or a combination of a federal program and a non-federal program, must maintain PARs that accurately declare after the fact the percentage of time the employee spent performing Title I and the other duties.  These PARs must (see Sample 2):
•  Reflect an “after-the-fact distribution” of the employee’s actual activity.  That is, they must detail the time the employee actually spent on each activity, not the expected or estimated time distribution.  A-87 permits the use of time distribution estimates for “interim accounting purposes,” so long as the estimates are reasonable approximates of the actual activity, and the estimates are reviewed and adjusted at least quarterly.  The estimates must also:
• account for the total activity for which the employee is compensated;
•  be completed at least monthly; and
•  be signed by the employee.