Is a Time and Effort Certification form required for both salaried and casual employees?
Yes, 2 CFR 200.430(a) does not differentiate based on the Department of Education’s (Department) classification of the employee type or mechanism for pay. This includes, but is not limited to, Paraprofessional Tutors (PPTs), Part-Time Teachers (PTTs), Paraprofessional Educators (PPEs), and Cafeteria Staff.
Are substitute teachers that are paid with federal funds required to complete the Time and Effort Certification forms?
No, the key issue is accountability for the proper use of federal funds. The Teacher Substitute Employee Automated System (T-SEAS) allows the Department to show that a specific substitute teacher on a specific day was used to replace a specific teacher who was out of the class for a specific reason. Thus, the Department already has the means to demonstrate that federal project funds were appropriately used to pay for a substitute teacher.
Does a contractor need to complete a Time and Effort Certification form?
No, the activity for which the federal funds are being spent is adequately covered in the contract.
Does the requirement apply to Memoranda of Agreements (MOA) with other agencies that are providing the Department with federal funds to perform work for them (the other agencies)?
The requirement for Time and Effort Certifications is dependent upon the appropriating authority for the federal project. Most funds from the United States Department of Education require Time and Effort Certification documentation. Other federal agencies may have different requirements or require that Time and Effort Certifications be completed in other ways. If you receive and expend federal funds under a MOA, you should contact the program manager in the other state department or agency for clarification.
Are stipends subject to Time and Effort Certifications?
No, stipends are not subject to Time and Effort Certifications, but must be supported with adequate documentation to show the stipend is reasonable, necessary, and allocable to the federal award. The School/Office must maintain supporting documentation (stipend contract and stipend sign-in/out sheets) for at least 7 years.
What is a “Cost Objective”?
Cost objective means an activity, mandated set-aside, mandatory minimum or work unit for which cost data are desired. A cost objective may be a major function of the non federal entity, a particular service or project, a federal award, or an indirect (Facilities & Administrative (F&A)) cost activity.
When should the Time and Effort Certification form for a teacher paid over 12 months for 10 months of work be done?
The fact that a 10-month teacher’s salary is prorated over 12 months is irrelevant for the purposes of Time and Effort. The 10-month teacher should complete the appropriate Time and Effort Certification documentation:
Within thirty days after December 31 and within 30 days after June 30 for a single cost objective. The certification must be completed once in each six month period and prepared after the work is performed;
Within 30 days after each month for multiple cost objectives.
Time and Effort Certification is used to certify that the work done by an employee during the preceding six (6) month period was, in fact, completed.
The Department splits some federal funds from a single source into several programs. Do these Department programs count as multiple programs for Time and Effort Certification purposes?
No, even though the Department splits one federal program, or grant award, it is still a single federal program.
What is an example of significant changes that occur in corresponding work activities?
The regulations in 2 CFR 200.430(i)(1)(viii)(B) require that significant changes to work activity must be reported in a timely manner.
For example, if a staff member is paid with 100% Title I grant funds, in order for that staff member’s salary to be allocable to the grant, the staff member must spend 100% of their time working on Title I. The word significant is important as it indicates a more-than de minimis standard for changes in work activity that must be reported. The staff member could spend a few hours or maybe a day or two working on another program/activity, so long as the time spent on that activity does not exceed the de minimis threshold, which is 5 percent. If the staff member has non-Title I job duties that would cause them to spend more than 5 percent of their time on other activities, then there must be an adjustment in how that person is paid or assign those non-Title I duties to someone else.
Do copies of completed Time and Effort Certification forms need to be submitted to the Monitoring and Compliance Branch?
No, original Time and Effort Certification forms and supporting documentation must be maintained at the school, complex area, or state office for at least seven years and be readily available upon request. However, significant changes in corresponding work activities must be promptly identified and reported to the Monitoring and Compliance Branch who will provide technical assistance. For more information in regards to significant changes in work activity, see page 10 of the HIDOE’s “Time and Effort Certifications Guidance Handbook”.
Can Time and Effort Certifications be digitally signed?
Yes, digital and electronic signatures are allowed.
Who can I contact for more information about Time and Effort Certifications?
Please contact the Monitoring and Compliance Branch for more information via email at timeandeffort@k12.hi.us or by phone at (808) 307-3600.
Single Cost Objective Questions
When do I use a Single Cost Objective Time and Effort Certification Form (TE1 or TE1B)?
The TE1 or TE1B forms for single cost objectives should be used when an employee is paid from only one federal fund program ID or is paid from multiple funding sources (including at least one federal fund program ID) for a single cost objective. The school, complex area, and state office should use either form that works best for ease of accurate documentation.
Example A: An employee is paid as a Title I coordinator with both WSF and Title I funds. The employee is working on a single cost objective.
Example B: A high school math teacher’s regular salary is paid with State and local funds. The teacher conducts an after-school support program for Native American students in the school, and also teaches at a summer academic camp for Native American students in the school district; for both of these activities, they are paid from Title VII, Part A funds. Although the teacher could not be paid with Title VII, Part A funds to teach high school math, the portion that the teacher is paid with Title VII, Part A funds is easily segregated from his daily teaching schedule. Accordingly, the teacher’s after-school and summer activities are each a single cost objective and the teacher needs only to file a semi-annual certification for the time they are paid with Title VII, Part A funds.
Multiple Cost Objective Questions
When do I use a Multiple Cost Objectives Time and Effort Certification Form (TE2)?
The TE2 form is used when an employee is paid from more than one program ID, at least one program ID is federal, and the employee works on multiple cost objectives. The TE2 form must account for all of the employee’s time for the period covered (including state/local activities) and support the distribution of the employee’s time across the different cost objectives.