Title I schools are subject to time and effort reporting due to federal requirements articulated in OMB Circular A-87.

REQUIREMENTS FOR TIME AND EFFORT

Only employees who are paid solely from Title I may be included on a semi-annual certification.  Previously, MDE and USED indicated that personnel in Title I Schoolwide Programs paid partially with Title I and partially with some other source of funding were eligible for a Semi-Annual Certification provided they functionally had the same job.  This is no longer the interpretation from MDE. 

Recommendation: Only include employees who are full-time (100%) on Title I (or 100% on some other federal program) on a semi-annual certification.  All other employees must use a time and effort log.  When in doubt, default to time and effort reporting.   

Employees who are paid in part by Title I and in part by other funding sources (federal, state or local) must complete and sign a time and effort log on a regular basis.  Supervisors also must sign these forms after every submission.  

Recommendation:  For all employees paid partially out of Title I and partially from some other source, please have employees complete a time and effort log every pay period. Have the employee submit it to you with their time sheet.  Copies should be stored in a personnel folder and the original forwarded to the Office of Funded Programs once they are completed.  Funded Programs will send out monthly reminders if forms have not been forwarded recently. 

All forms must be completed after-the-fact.  This documentation is retrospective in nature.  They must also be signed and returned in a timely manner.   Based on guidance from our auditors, signatures must be dated within a very narrow window of the period covered by the form.  A Semi-Annual Certification covering July-December 2008 cannot be dated from October 2008.  A monthly Time and Effort Log for October 2008 cannot be signed and dated in February 2009. 

Recommendation: Use December 31 and June 30 as the default dates for completing the semi-annual certification forms.  Employees on twelve month contracts should be covered July 1 to December 31 and January 1 to June 30.  The window for ten month employees should be adjusted to start and end dates. 

Time and effort logs must be completed each pay period. All forms should be signed and filed no later than 15 days after the end of the time period covered on the form.

Semi-Annual certifications for July 1, 2008 to December 31, 2008 or (modified period such as August 2008 to December 31, 2008) should be signed by January 23, 2009 and sent to the Office of Funded Programs.  Semi-Annual Certifications for January 1, 2009 though June 30, 2009 must be signed by July 18, 2009.