9/12/2008 page 1 mde and isd partnership: darkening the dotted lines monitoring and compliance...
TRANSCRIPT
9/12/2008 Page 1
MDE and ISD Partnership:
Darkening the Dotted Lines
Monitoring and Compliance
Training: Financial Management
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Overview
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Financial Management
Pre-Training Assessment Survey
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Financial Management:
Timekeeping
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Timekeeping: Content
Financial Management System
(FMS)
Federal Timekeeping Requirements
2/1/2012 Revised by OSE Page 6
Timekeeping: Components of a Good FMS
Written Policies and Procedures New Staff/Position Training Adherence to Approved Policies and
Procedures Annual Review and Training Updates Timely
2/1/2012 Revised by OSE Page 7
Timekeeping:Regulations
2 CFR 225 (formally OMB Circular A-87, Attachment B, Item 8h)
PowerPoint: Federal Fiscal Requirements. Michigan Department of Education, Office of School Improvement
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Timekeeping: Definitions and Terms
Cost Objective - a function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred
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Timekeeping: Definitions and Terms
Personnel Activity Report (PAR) - record maintained by employee working on more than one cost objective which is prepared after the fact, reflecting the actual total activity of the employee, at least monthly and signed and dated by the employee
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Timekeeping: Definitions and Terms
Semi-Annual Certification - certification that employee worked on a single federal award or cost objective. Must be prepared at least semi-annually, signed, and dated by employee or supervisory official having firsthand knowledge of the work performed
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Timekeeping:Overview
Written Policies and Procedures
Multiple Activities or Cost Objectives
Single Federal Award or Cost Objective
Estimations
Quarterly Comparisons
Adjustments and Budget Revisions
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Policies and Procedures: Payroll Components
There are written policies and procedures governing payroll administration
Salaries from the Financial Expenditure Report (formerly DS-4044) agree with the district’s general ledger payroll accounts for all federal grant programs
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Policies and Procedures: Payroll Components
All salary costs for work performed are within the grant period
Salaries must comply with the employment contract which indicates the annual salary scale for the grant period
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Policies and Procedures: Timekeeping
There are written policies on recording time distribution for employees who work on one or more federal award or cost objective
2/1/2012 Revised by OSE Page 15
Timekeeping: Multiple Cost Objectives
For employees working on multiple activities OR cost objectives:
The district has Personnel Activity reports (PARs)
The PARs are prepared at least monthly
2/1/2012 Revised by OSE
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Timekeeping: Multiple Cost Objectives
The PARs are signed and dated by the employee
The PARs account for the staff person’s actual total activity
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Timekeeping: Multiple Cost Objectives
The PARS are actual real-time records and not prepared in advance of the time period covered
2/1/2012 Revised by OSE Page 18
Example-Personnel Activity Report
Example 1:
Single Award/Multiple Cost Objectives
A school district could have an employee funded with a single federal award and working on multiple cost objectives
In IDEA, a physical therapist could work part time at the local district and part time at a non-public school where data is required for the proportionate share, a PAR is required
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Example-Personnel Activity Report
Example 2:
Multiple Awards/Multiple Cost Objectives
A school district could have an employee funded with multiple federal awards and working on multiple cost objectives
In IDEA, Part B Sec. 611 supports students ages 3-21 and Sec. 619 supports ages 3-5. If the employee works with students 3-5 and 6-21 a PAR is required
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Timekeeping: Single Federal Award or Cost
ObjectiveFor employees working solely on a single federal award OR cost objective:
The district has certifications or a blanket certification showing that the employees worked solely on a single federal award or cost objective
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Timekeeping: Single Federal Award or Cost
ObjectiveThe certifications are prepared at least
semi-annually
The certifications are signed by the employee or a supervisor with first-hand knowledge of the work performed by the employee and are dated after the fact
2/1/2012 Revised by OSE Page 22
Timekeeping: Single Federal Award or Cost
Objective
The certifications are actual real-time records and not prepared in advance of the time period covered
2/1/2012 Revised by OSE Page 23
Example-Semi Annual Certification
Example 1:
Single Award/Single Cost Objective
A school district could have an employee funded with a single federal award and working on a single cost objective
In IDEA Part B Sec. 611, a physical therapist working all their time at the local district, a semi annual certification is required
2/1/2012 Revised by OSE Page 24
Example-Semi Annual Certification
Example 2:
Multiple Awards with Single Cost Objective
A school district could have an employee funded with more than one federal award working on a single cost objective, where the awards support the cost objective
In IDEA, Part B Sec. 611 supports students ages 3-21 and Sec. 619 supports ages 3-5. If the employee works with only ages 3-5 on both awards, a semi annual certification is appropriate.
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Timekeeping: Estimations
The system for establishing estimates produces reasonable approximations of the activity performed
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Timekeeping: Quarterly Comparisons
At a minimum, quarterly comparisons are made of actual costs to budgeted distributions based on monthly activity reports
2/1/2012 Revised by OSE Page 27
Timekeeping: Adjustments
Adjustments are made to costs charged to federal awards based on the activity actually performed
These adjustments can be made annually only if the quarterly comparisons show differences between budgeted and actual costs of less than 10%
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Timekeeping: Budget Revisions
Budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances
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Timekeeping:FAQs
What are the audit requirements?
Your auditor will take a sample of expenditures and request timekeeping documentation for anyone charged to federal funds. If your records are insufficient, the auditor will include a finding in the audit report and may question costs. See the Michigan School Auditing Manual for further information
2/1/2012 Revised by OSE Page 30
Timekeeping:FAQs
What happens if you cannot produce the documentation for the single audit?
Auditor will site 100% of salaries as questioned costs and could result in a penalty of repayment
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Timekeeping: Other Resources
The Michigan School Auditing Manual
Report from the Time Log Work Group, Michigan Department of Education, Office of School Improvement, February 13, 2008
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Timekeeping: Other Information
Contacts
• MDE: Office of Audits
• ISD:
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LEA Fiscal
Review
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Resources
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Committee
Membership