BALTIMORE CITY PUBLIC SCHOOLS (CITY SCHOOLS) DEPARTMENT: DEPARTMENT OF GRANTS ADMINISTRATION SUBJECT: FINANCE NEW EDGAR 2CFR PART 200.430(I) COMPLIANCE TIME DISTRIBUTION RECORDS FY 2015 ( ANNUAL CERTIFICATION)-FIRST PERIOD I. PURPOSE: Explain the process to Principals, Directors, Officers, and Grant Managers for completing certification affidavits for federal funded employees (full partial, temporary, and stipend payments) as required by the New Edgar Rules. II. GOVERNING POLICY/REGULATORY IMPLICATIONS: A. Code of Maryland Regulations (COMAR) 13 A.02.01.02, Section 5-101, Education Article, Annotated Code of Maryland B. Codified Title 34 of the Code of Federal Regulations C. U.S. Department of Education newly updated Education Department General Administrative Regulations (EDGAR), http://www2.gov/policy/fund/reg/edgarreg/ed.gov.html III. IMPLEMENTATION GUIDELINES: A. The new EDGAR regulations (former OMB A-87 circular). If federal funds are used for salaries, then time distribution records are required 200.430 (i). To demonstrate allocability for employees paid with federal funds evidence must be provided that shows the employee worked on a specific federal program cost objective 200.403(a). This does not include contractors. As a condition of receiving the grants, including IDEA and Title I, school districts must comply with EDGAR regulations. 2 CFR Part 200 describes specific documentation requirements that when a salary is either fully or partially paid by a federal grant. B. Employees Fully Funded by a Federal Grant 1. The 2 CFR Part 200.430(i) guidance for employees fully funded by a federal grant states that the Salaries and wages of such employees will be supported by periodic certification that the employees worked solely on that program for the period covered by the certification. 2 CFR Part 200 further states that the certification will be prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed. C. Employees Partially Funded by a Federal Grant 1. Some employees salaries are paid by a combination of funding sources. For example, the salary of a full-time employee may be paid.5 by Title I and.5 by CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 1
BALTIMORE CITY PUBLIC SCHOOLS (CITY SCHOOLS) DEPARTMENT: DEPARTMENT OF GRANTS ADMINISTRATION SUBJECT: FINANCE NEW EDGAR 2CFR PART 200.430(I) COMPLIANCE TIME DISTRIBUTION RECORDS FY 2015 ( ANNUAL CERTIFICATION)-FIRST PERIOD local dollars, In these instances, 2 CFR Part 200 states that a distribution of the employee s salary is supported by personnel activity reports or equivalent documentation if working multiple cost objectives. Complying with this regulation requires that such employees keep Time and Effort logs. If the employee is split-funded but works a single cost objective, the Substitute- Employee Time Distribution form can be used for certification purposes. D. Temporary Employees funded through federal programs must be certified. E. Employees receiving stipend payments from federal programs must also be certified. F. City Schools Requirements in Response to 2 CFR 200.430(i) 1. The standards noted above require that City Schools supervisory personnel complete certification affidavits for fully funded staff on a bi-annual basis. In addition, compliance with the requirement will also require that staff oversee the maintenance of Time and Effort logs for partially grant-funded employees. 2. All principals, supervisors, and grant managers who currently employ federally- funded staff will receive specific directions on the maintenance of the required documentation. It is expected that all staff comply fully with EDGAR requirement and with the procedures that City Schools Grants Administration Office has established. INSTRUCTIONS Principals and Grant Managers must complete an affidavit if they have federally-funded staff assigned to their Cost Center. Please see the directions below as they apply to your area of responsibility. School Principals The Employee Certification form will serve as the affidavit. The Employee Certification form lists only those staff members in your school who are paid from one of the many federal grants in the BCPS. The pre-printed form includes the staff member s Job Title, Cost Code (funding source), and Full Time Equivalent (FTE). Each principal must sign for receipt of the Employee Certification Form. CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 2
BALTIMORE CITY PUBLIC SCHOOLS (CITY SCHOOLS) DEPARTMENT: DEPARTMENT OF GRANTS ADMINISTRATION SUBJECT: FINANCE NEW EDGAR 2CFR PART 200.430(I) COMPLIANCE TIME DISTRIBUTION RECORDS FY 2015 ( ANNUAL CERTIFICATION)-FIRST PERIOD For each employee on the summary list, indicate by circling Yes if the employee is (a) working in your school and (b) performing the duties of the grant that is funding the person s salary. If either condition (a) or condition (b) is not true, then circle the No response for that particular employee. If you circle No for any employee, indicate the reason for the No by providing a response on the Additions/Corrections/ Deletions page. If you have federally-funded employees in your school who do not appear on the pre-printed Employee Certification form, use the Reconciliation form: Add the employee s name to the Corrections sheet. If an employee is erroneously listed on your Cost Center summary as a federally-funded staff person, record the correct funding source for that employee on the Corrections sheet. For split-funded employees complete the attached Time and Effort form that may be used. Maintain Time and Effort logs of split-funded employees if the employee works multiple cost objectives, effective the start date of the employee is assigned to the grant. On a daily basis, the employee should record on The Time & Effort form the number of hours and a summary of grant related tasks performed. Weekly, employees must sign, date and submit the Time and Effort form to the Principal and /or Grant Manager. If the employee is split-funded but works a single cost objective, use the Substitute Employee Time Distribution forms. Grant Managers in Central Offices 2 CFR Part 200.430 (i) verification requirements also apply to non school-based grant managers who oversee federal programs. Each grant manager must follow the same verification steps as outlined above for principals. Certify each employee on your pre-printed list as working on grant activities and salary paid using grant funds. It is more likely that grant manager rosters include a higher number of partially-funded staff, which requires the maintenance of Time and Effort logs. Therefore, in addition to certifying that the employee is working on grant activities, the Grant Manager must also ensure that proper Time and Effort documentation is maintained by anyone who is not funded 100% by the federal grant. Submit copies of employees Time and Effort logs with the Employee Certification forms. CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 3
BALTIMORE CITY PUBLIC SCHOOLS (CITY SCHOOLS) DEPARTMENT: DEPARTMENT OF GRANTS ADMINISTRATION SUBJECT: FINANCE NEW EDGAR 2CFR PART 200.430(I) COMPLIANCE TIME DISTRIBUTION RECORDS FY 2015 ( ANNUAL CERTIFICATION)-FIRST PERIOD Certification Periods for FY2015 are: First Certification covers the period of July through December 2014. Second Certification covers the period of January through June 2015. CONTACT INFORMATION: Name of Contact Person: Pauline D. Edwards, Director Grants Administration Phone Number: (410) 396-8940 Contact Email: pedwards@bcps.k12.md.us Name of Contact Person: Ray Anuforo, Grants Management Administrator Grants Administration Phone Number: (410) 396-8909 Contact Email: ranuforo@bcps.k12.md.us CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 4
Reconciliation Form Directions: If there are any discrepancies on your Federally Funded Employee Certification report, please check the corresponding box below that best describes your situation. Attach this form with your employee certification form and return items to the appropriate supervisor as described on the set of directions by the deadline. An error exists on my employee certification form. The following describes the situation: Missing the names of permanent federally funded employees. Missing the names of temporary federally funded employees. Employee listed has an incorrect costing string (fund number). Incorrect full time employee (FTE) status. Incorrect position title recorded for employee. Incorrect subject assignment recorded for employee. Other: Please note any needed corrections on the reverse side of this page. Name: Date: CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 5
Reconciliation Form ADDITIONS/CORRECTIONS Employee # Position # Employee Name Effective Date Job Title Cost Code FTE Area: Cost Center: 1. 2. 3. 4. DELETIONS Employee # Position # Employee Name Effective Date Job Title Cost Code FTE Area: Cost Center: 1. 2. 3. CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 6
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Time and Effort Log (Instructions for all Federally-Funded Staff) 1. Complete all header information. Name of Grant Fund Number Week of School Number 2. Provide the total hours worked for each day of the week. For split-funded staff, only show the time devoted to grant related duties. 3. For each day worked, provide a brief summary of the service that was provided. 4. Sign and date the form. Ensure that the form is signed and dated by the supervisor. (Weekly signatures are recommended) CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 12
Baltimore City Public School System Time and Effort Log Name of Grant: Week of: Fund Number: School Number: Monday Tuesday Wednesday Thursday Friday Total Hours Worked: Total Hours Worked: Total Hours Worked: Total Hours Worked: Total Hours Worked: Summary of Service: Summary of Service: Summary of Service: Summary of Service: Summary of Service: Employee s Signature: Authorizing Supervisor: Date: Date: CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 13
Time and Effort Log CITY SCHOOLS- 2015 ANNUAL CERTIFICATION PAGE 14