Labor is often the highest cost grantee organizations charge to their Federal grants and cooperative agreements and a common audit disallowance when it is done incorrectly. Grantees need to know what the requirements are for time and effort reporting and how the uniform guidance (aka Supercircular) changes these requirements. The new time & effort rules back away from rigid requirements for six-month certifications and monthly personnel activity reports. At the same time, the rules require that grant and non-grant time does not exceed 100 percent — difficult when there are not enough hours in the day. Consequently, time and effort is often misused and misreported. This leads to the need for strong internal controls for the reporting of salaries and wages to ensure that the payroll charged to various grants AND non-grants meets the required thresholds. While the previous standards were more prescriptive in the documentation requirements, the new standards provide more flexibility requiring that nonfederal entities update their internal policies and procedures to define the process. Failure to keep accurate time & effort records can lead to questioned and disallowed costs. This session will include how the rules have changed and reviews time & effort best practices.
1. Understand the purpose and scope of time and effort reporting requirements
2. Understand changes to time and effort reporting under the Uniform Guidance
3. Identify new possible mechanisms for time and effort reporting
Edward (Ted) Waters, Esq.
Feldesman Tucker Leifer Fidell LLP