EDGAR: Staffing, Time & Effort

One of the best benefits of federal grant dollars is the ability to add extra staffing; however, there is much to consider about compliance and documentation for federally-funded staff. The Education Department General Administrative Regulations (EDGAR) must be followed when hiring and documenting the time of federally-funded staff. This article and our accompanying EDGAR Staff and Time and Effort Online Course will provide charter districts with a complete overview from the decision to adding new grant positions to how to handle documentation for auditing of those positions.

The CSS federal team makes sure grant staff are properly added in grant applications and follows up with guiding our clients through the documentation required for grant funded positions.

Administrative Procedures Manual

All LEAs are required to have their written procedures for administering federal and state grants gathered on one APM manual. A vast majority of the manual is devoted to financial procedures, and personnel (staffing) under federal is certainly an important part of the manual. The APM manual must include written allowable cost procedures for all federal purchases including payroll positions to be funded by federal grants. In addition, the manual must include a description of the policies and procedures for maintaining job descriptions and time and effort documentation for grant-funded positions.

Allowable Costs for Grant-funded Staff

The first step in justifying staff from federal grants is making sure the position is connected to a need in the Comprehensive Needs Assessment. Is the position necessary to implement a strategy/activity connected to student achievement in the Campus or District Improvement Plan? Before the position is requested in the grant application, the program guidelines of the grant must be read and followed to determine if the position is allowable under that grant. The decision to fund the position with federal dollars should always be a committee decision and documented by sign-in meetings and agendas. Part of the CIP/DIP process would be to evaluate the effectiveness of that position in meeting the improvement plan goals.

Time and Effort

All grant-funded positions should have a properly formatted job description that is signed by the employee and supervisor prior to the first day on the job. The job description should list the fund source and percent of time spent on the federal job in relation to any other job duties. The job description should list any qualifications the employee must have as a requirement of the federal grant. For example, any instructional paraprofessional positions funded by Title I must meet the definition of “highly-qualified.” The purpose of the job description is to clarify the duties that are being funded by the grant and limiting the situation where an employee would be told to work outside of those duties using federal funds.

The type of time and effort documentation will vary depending on how much time the employee spends working in the federal job description duties. There are basically three options:

1. Semi-Annual Certification form – for staff paid 100% from a single federal grant OR is split funded, but only has one job function (single cost objective). The form is filled out at the end of each semester. The form should state that in the semester that just ended, the employee verifies that he or she worked 100% of his or her time in that federal job. It is signed by both the employee and supervisor, or just the supervisor. This means that the employee was not assigned to other job duties paid for my grant funds (a 10% variation is allowed). There is no State-provided template of this form, but CSS provides our clients with samples of Semi-annual Certification forms.
2. Substitute System of Time and Effort – for staff who is “split funded” with a federal grant and any other fund source (multiple job activities). Employees must follow a consistent schedule for the split of time in order to use this system. For example, an employee may have a simple split of 50% of the day for SPED and 50% for Title I and follows the same schedule every week. If the schedule varies and is never consistent, this system may not be used. You must get approved by TEA and be on the list in order to use this system. More information is available at the TEA Substitute System website. The State does provide forms for using the sub system. Once approved, you are good for two years before approval is needed again.
3. Monthly PARs – for staff whose split of time between jobs varies and is inconsistent. Time is tracked every day, and at the end of the month (or pay period) is totaled up to determine how much is paid from each fund source. This is commonly called a “time sheet.” Each day the employee would record the start and end time for each job task in 15-minute increments. Although the employee’s paycheck amount wouldn’t change, the percent from each budget code would change each month according to the percent of time they spent on each job. Like Semi-annual certification forms, there is no State template; however, CSS has them available for paid clients.

What about COVID funds?

Generally speaking, COVID funds are federal funds and follow the same rules. The only exception are ESSER funds. TEA has said that time and effort is not required unless the position is split funded with a job that is not allowed under ESSER. HOWEVER, you must have in your federal grants manual a “disaster exception statement” in your section about time and effort. This means that if you do not have a statement in your manual that says normal time and effort procedures will not be followed (when allowed by TEA) for federal disaster funding, then you must follow your normal written procedures. ESSER staff split with a federal fund that DOES require time and effort (such as Title I) must complete time and effort.

Training

Lastly, it is extremely important to train all staff involved in personnel management in the grant issues related to staffing and HR. Training should be held annually and documented by sign-in sheets, notes, and agendas. This helps you hold staff accountable for following all the procedures outlined in your APM manual so that costly mistakes are not made during auditing.

Need help?

Please contact Charter School Success:

• Sharon Benka sbenka@charterschoolsuccess.com

Have questions?

Ask questions, get answers, and discuss this topic on the Charter School Community Roundtable now.