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Federal Fiscal Requirements

1-A) OMB Circular A-87 : Time and Effort :The Federal Government (U.S. Office of Management and Budget (OMB) Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments ) requires all employees, including teachers, paraprofessionals, and other staff that are paid with federal funds to document the time and effort they spend within the program. The portion of the federally paid salary should be reflective of the actual activity, not budgeted, the individual has put forth for that federal program. Time and effort reporting is required when any part of an individual’s salary is charged to a federal program or used as match for a federal program. (See Circular No. A-87.8. Compensation for personal services )

Specific resources: OMB Circular A-87

Attachment A General Principles for Determining Allowable Costs
Attachment B Selected Items of Cost
Attachment C State/Local Wide Central Service Cost Allocation Plans
Attachment D Public Assistance Cost Allocation Plans
Attachment E State and Local Indirect Cost Rate Proposals

If your entity does not have an existing Time and Effort Log, please use the suggested Time and Effort templates ADE developed below.

  1. Semi-Annual Certification :Circular No. A-87. 8.(8).(3) Where employees are expected to work solely on a single Federal award or cost objective, charges for their salaries and wages will be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certifications are required to be prepared at least semi annually.* Individual Semi-Annual Certification Template (Example)* Group Semi-Annual Certification Template
  2. Monthly Personnel Activity Report : Circular No. A-87. 8.(8).(4) Where employees work on multiple activities or cost objectives, a distribution of their salaries or wages will be supported by personnel activity reports or equivalent documentation which meets the standards in subsection (5). Circular No. A-87.8.(h).(7) Salaries and wages of employees used in meeting cost sharing or matching requirements of Federal awards must be supported in the same manner as those claimed as allowable costs under Federal awards.* Monthly Personnel Activity Report Template in Excel (ExamplePersonnelActivityReport)
  3. Time and Effort Check List : Time and Effort Information and examples
  4. Specific Requirements for Time and Effort Reporting : Quick glance of Time and Effort Requirements
  5. FAQ’s : ADE would like to share the Idaho Department of Education’s FAQ;s on Time and Effort at http://www.sde.idaho.gov/site/nclb/program_monitoring_docs/TimeEffortFAQs.pdf
    • Q: Is time and effort required for stipends, supplemental contracts, and/or extra
      hours? A: Yes.
       - Sign-in/attendance logs may be used as time and effort documentation for extra hour pay related to a single cost objective (e.g., pay for math/science training charged to Title II Eisenhower Award).
      -A signed supplemental contract that stipulates a specific single cost objective duty/assignment may be used as time and effort documentation (e.g., pay forsupplemental, after school reading instruction charged to Title I, Part A).
      -A stipend for performing a specific single cost objective responsibility may be used as time and effort documentation so long as the employee signs either the stipend or an after-the-fact certification of performance (e.g., pay for supervision of a particular federal program charged to that program).
      -Multiple cost objective supplemental contracts/stipends must be supported by time and effort reports documenting actual time spent on each objective ( e.g., pay for a supplemental contract to administer a summer school program serving Title I and Special Ed eligible students may be charged to Title I and Special Ed only if supported by a time and effort report).

    1-B) OMB Circular A-122 : Time and Effort

    1. Non-profit Organizations/Community Based Organizations that are governed by OMB Circular A-122 (See Section 8. 13. (1) & (2) Support of salaries and wages) and required to maintain monthly certification for all employees funded with federal funds regardless whether the employee is funded 100% or split effort.
    2. Monthly Personnel Activity Report : Circular No. A-122. 8. 13. (1) & (2) Charges to awards for salaries and wages, whether treated as direct costs or indirect costs, will be based on documented payrolls approved by a responsible official(s) of the organization. The distribution of salaries and wages to awards must be supported by personnel activity reports* Monthly Personnel Activity Report Template in Excel (ExamplePersonnelActivityReport)
    3. Time and Effort Check List : Time and Effort Information and examples
    4. Specific Requirements for Time and Effort Reporting : Quick glance of Time and Effort Requirements

    1-C) OMB Circular A-21: Time and Effort

    *Institutions of Higher Education (Universities and Community Colleges) that are governed by OMB Circular A-21 (See Section J. 10. C. (1), (2) & (3) Compensation for personal services) are required to maintain certification for employees based on approved method for Payroll Distribution.

    1. Plan Confirmation (See Section J. 10. C. (1)(e)) certification must be maintained on an annual basis.
    2. After the Fact Method(See Section J. 10. C. (2)(e)):
      1. a. For Professorial and Professional Staff certification must be maintained on a six month basis.
      2. b. Non-Professional and Other Staff certification must be maintained on a monthly basis and coincide with one or more pay periods.
    3. Multiple Confirmation Records (See Section J.10.C. (3)(f)) certification must be maintained on a six month basis.

    2) Fixed Assets: Fixed asset refers to tangible, non-expendable, personal property having a useful life of more than one year and an acquisition as defined by your District/Charter’s fixed asset policy.

    • The LEA should prepare a detailed listing of general fixed assets that includes all equipment with unit costs of $1,000 or more and useful lives of one year or more; and all land and buildings, and related improvements with costs of $5,000 or more. If the LEA wishes, it may record assets on the general fixed assets listing at a lower threshold amount.
    • Fixed asset report should include property identification tag, asset description, serial #, funding source, purchase date, cost, and location. See USFR or USFRCS VI-E-2.
    • Stewardship Listing: To physically control and help prevent theft of equipment costing less than $1,000, the LEA may wish to maintain a stewardship listing. The governing board should specify the types of items to be placed on the stewardship listing and establish the minimum amount for those items. The stewardship listing should include Location, Identification number, and description.

    More information on Fixed Assets can be found from USFR VI-E Accounting Procedures Fixed Assets or 34 CFR 80.32 Equipment ((d) Management Requirements).

    3) ESS Fiscal Monitoring: Receiving federal grant monies entails both programmatic and financial duties, which include proper programming and expenditure of monies, goals achievement, and related reporting. Information related to the five key areas addressed during the Fiscal Monitoring are Time and Effort reporting, Expenditure Compliance, Fixed Asset Compliance, General Grant Compliance, and Grants Management Compliance. Please see the “ESS Fiscal Monitoring Compliance Questionnaire”.

     4) Resources

    If you have questions regarding the Federal Grant Requirements, please contact Gary Holland from the ADE Audit Unit at (602) 364-3518 or mailto:Gary.Holland@azed.gov or contact the specific grant contact.