Assessment/Accountability No Child Left Behind
Title I

Fiscal Information

• How the Federal Government Allocates Funds to States and Districts
• How Districts Allocate Funds to Schools
• Maintenance of Effort, Comparability of Services and Supplement, Not Supplant
• Time and Effort Reporting
• Transferability, Flexibility, and Program Coordination
• Ed-Flex Waivers
• Reservations / Set-Asides
• Carryover Funds
• Show All

Time and Effort Reporting

School districts are required to maintain auditable "time and effort" documentation that show how each Title I employee spent his or her compensated time. Such documentation are written, after-the fact (not estimated or budgeted) documentation of how the time was spent. Time and effort reports should be prepared by any Title I staff with salary charged (1) directly to a federal award, (2) directly to multiple federal awards, or (3) directly to any combination of a federal award and other federal, state or local fund sources.

• Semi-annual certifications are required for Title I personnel whose compensation is funded solely from the Title I grant. These certifications document that he/she has been working solely in activities supported by the Title I grant (although some district policies require monthly reports for such personnel). The certification must (1) cover a semi-annual period (e.g., September-January and February-June, or September-February and March-August), (2) identify Title I as the program, and (3) be signed and dated by an employee and supervisor having first-hand knowledge of the work performed by the employee.

• Monthly reports are required for Title I personnel whose time is charged in part to Title I and in part to other revenue sources (split-funded staff). These reports document the portions of time and effort dedicated to Title I and to other revenue sources. Such records must (1) be completed after-the-fact, (2) account for the total time for which the employee is compensated, (3) be prepared at least monthly, (4) coincide with one or more pay periods, and (5) be signed by the employee and countersigned by an administrator or supervisor.

• Stipends (and other supplemental contracts) must also be reported. Record stipends on semi-annual certifications or monthly reports, whichever is utilized for the particular employee. Alternatively, permitted documentation includes (1) a signed supplemental contract that stipulates Title I work activity, (2) sign-in attendance logs approved by the supervisor (e.g., pay for professional development activities), and (3) employee time/pay slips that specify "Title I" and are approved by the supervisor.

NOTE: If a school operating a schoolwide program consolidates Federal, State, and local funds in a consolidated schoolwide pool, an employee who is paid with funds from that pool is not required to file a semi-annual certification. Because Federal funds are consolidated with State and local funds in a single consolidated schoolwide pool, there is no distinction between staff paid with Federal funds and staff paid with State or local funds. A school that consolidates Federal funds in its schoolwide program is not required to meet most of the statutory and regulatory requirements of the specific Federal programs included in the consolidation. However, the school must ensure that it meets the intent and purposes of the Federal programs included in the consolidation so that the needs of the intended beneficiaries are met. If funds are not consolidated in a schoolwide pool, them time and effort reporting must be maintained for federally funded personnel.

What to watch out for: (1) failing to recognize that a change in position, duties or funding may result in a change in time and effort reporting; (2) failing to provide training to staff who are responsible for completing and/or approving time and effort documentation; (3) reporting time according to how the ratios were budgeted without regard to how the individual actually worked; (4) time and effort reports not reviewed and signed by appropriate staff; (5) entire days' schedule not accounted for (for federal program time reported); or (6) lack of appropriate time and effort records for employees compensated through supplemental contracts, stipends, extra hours, etc.

Time and effort problems can result in: Inappropriate charges to federal programs, inaccurate management information for decision-making, and/or increased risk of audit findings and questioned costs.

The Massachusetts Department of Elementary and Secondary Education is subject to the same reporting requirements as local school districts. To comply with its time and effort requirements, the Department utilizes an automated Federal Time and Attendance Report built with Microsoft Access. At the end of every month, State employees are required to indicate the percent of time spent on each program worked. The employee and his or her administrator then sign the report as a certification. Local school districts may use the sample documents below in furtherance of Title I time and effort compliance requirements:

Sample Title I Time and Effort Records

NOTE: Time and effort reporting guidelines are specified in the U.S. Office of Management and Budget (OMB) Circulars A-87 and A-133. The circulars provide instructions to auditors performing Single Audits of states, local governments, and non-profit organizations. OMB-87 establishes standards for charging employee compensation for federal grants. OMB A-133 lists the compliance requirements for federal education programs, including Title I Part A.