 OTAN, Outreach and Technical Assistance Network. Hello, good morning everyone. Welcome back from break. My name is Arturo Ambriz. I'm an education program consultant here at the CDE Adult Education Office. I'll be covering today that we all titled to fiscal compliance overview. And I'll be referring to it on our presentation as AFLA, which stands for Adult Education and Formula Literacy Act. And sometimes I'll refer to it as we all title to. I'd like to mention one more thing before I start is that this presentation will end around noon and then we'll have an hour launch and we'll come back up one for the data and accountability requirements, which will be presented by Dr. Amukela Web. So you definitely want to be back on time. I also want to mention that I hope everyone it's at that speed after going to J presentation. But again, it's hard to compete with that, so just hang in there. Thank you. Okay, the overview topics that we'll be covering today we will go over the statute and regulations that apply to this AFLA grant. We'll cover timely spend funds and carry over, which is basically the parameters of this grant that the agency has to spend the funds. We'll go over the supplement national plan provisions which is the provisions that AFLA funds are supplemental to your stay in local funds for adult education mainly for UK funding because allowability and allocation requirements that the rules and regulations for allowable cost and how much can you charge to the program in proportions to the benefit received. We'll cover also the standards for documentation of personal expenses which is also referred to time and effort records reporting requirements. These are your semi-annual certifications, personal activity reports, or parts, time sheets. The documentation the agency uses to document salaries and wages the time that the employees spend working on those federal programs. We'll also cover matching requirements really quick at the end. That is the 25% requirement much that the agencies have the agency reporting the year on the expenditure claim reports. So with that we know and understand that federal compliance can be complex but as administrators you will need to be familiar with these requirements and sometimes you might not be involved on all the functions of these areas but it's very important that you know who is doing that work and that being said in spite of your level of experience on fiscal whether you have a lot or not so much. If anything please keep a copy of this presentation handy perhaps on your desktop and share with other program and fiscal staff who is involved in the process. Finally for questions if you have any questions as we go through each of these areas please write those on the chat as the presentation go on and my colleague Jim will read those at the end of this area and I'll respond to those. If for some reason don't know the answer or it requires follow-up we'll keep in the Q&A and I'll be sure to respond. Excuse me. Let's start with statute this is for reference the statute is mainly the law that applies to this grant and includes such things such as the provisions for section 31 that Dr. Sackari mentioned yesterday the provisions for supplement as a plan the regulations is mainly EDGAR which stands for Education Department and General Administration Regulations these are the rules that apply to all federal grants issued by the U.S. Department of Education then back in 2015-16 the uniform grant guidance they combine all the circulars and became one one requirements for all federal awards issued by the federal government so EDGAR incorporated the uniform grant guidance which is going to be referred as part 200 or to CFR 200 so again recipients of awful of funds must comply with these requirements so again as administrators you will need to be familiar with this and refer to this when you are planning to spend funds when you are developing your budgets and this is definitely one of those areas that is a collaboration between fiscal and program because program knows the needs of the program part and fiscal knows the internal controls and these requirements some of the slides they have underlying references so what that is is basically a direct link to that reference and lastly I like to mention that there are also other regulations such as Title 34 that might apply to AFLA but these two are the main ones that directly applies to the fiscal compliance this is just a summary for references this is what you have been learning throughout this new administrative orientation and this is just basically a summary of how AFLA funds are awarded by section resource code and the fiscal area of the fiscal area we are reviewing so for instance section 331 has two resource code 3905 which the program areas that can use those funds are AV, adult basic education ELA English language acquisition and EL civics and we also have resource code 3913 under section 331 and those funds are intended for adult secondary education with in California is high school equivalency GED or high set and high school diploma we also have section 225 and 243 so the 243 agencies is those funds are intended to support English language learners co-enroll on a compliance IELC with or without IET literacy and workforce preparation activities my colleague Cory he's the subject expert for this program so he'll be going over today on everything you need to know about section 243 for those agencies that receive this funding and this is the first actual area that we're covering today in is timely spending funds and carryover so AFFLAW funds cannot be carried over from one fiscal year to the next they must be spend it or financially obligated by June 30th funds are considered spend it as of the day of the obligation consisting with title 34 76 section 76 07 so this reference will take you to is a table that includes examples of services materials property and it will tell you the day that they obligate for instance a couple of examples that will help us understand the concept this requirement salaries and benefits they obligate when the services are performed which means that you can only report those up to June 30th comparing to for example computer devices they obligate when the agency makes that written commitment so in many situations you will for example want to order computers or laptops in May or April but they will not be available until May or September so the the funds are considered obligated when you made that written commitment on May or April and you can claim those as part of that fiscal year even though the devices will be received after June 30th so and the planning and collaboration especially for new grantees that this is different from other federal funds that allow carryover planning and collaboration with both fiscal and program to spend obligate these funds is especially important so the window is July 1st to June 30th of the fiscal year financial obligation is basically the definition on the regulation is is defined as orders place for property services contracts and similar transactions that require payment the the written commitment documentation that you will need if you have that situation that you will purchase something on May but or April or June that will be received after June 30th the agency will need to maintain documentation such as a purchase order sign contract a specific description and cost of the item that you order and that's very much for timely spending funds and carryover Jim do we have any questions so far not at this time Arturo good so again if you don't think of any question as we go through sorry one just popped up here okay no problem you can put those on to me later or definitely reach out to your CD consultant so so our first question is it the same for contracts for services that is the same but again each situation is different so if the contract for example services depends on what it is it really depends on what it is so for example if the services is not you want to make a contract for a service like for example a professional development or presentation if the person that's going to provide the presentation is not available before the June 30th but you want that presentation you might be able to pay with that funding with that fiscal year contract contract we cover the that will be dependent on the details of the contract for example if you're contracting for something that is going to start you live first and on then that's the time period that the funds can be used so it really is in the timing and again there are examples on that table and if anything please reach out to your CD consultant and like I think you may have just answered this but the focus by when contract is signed or by when service is provided is again it will depend so if the contract like for example if you have a if you sign in a contract in July but those services are going to start you I mean let me just stand back if that contract depends on the services but if the contract is signed in May or June but the services will start from July on then the obligation really on this case even though it happens on May if the services belong to that fiscal year then that's when you can that's when they obligate that will be July because like for example a lot of the times schools have subscriptions right to software programs you can use Afla funds for whatever month those subscriptions pretend to but for example if you pay for subscriptions on May 2023 or make a contract for those on May 2023 but those subscriptions are again July 1st then you should really be using funds from the new fiscal year from the fiscal year that will start July 1st I hope that answered that question and it looks like we're all caught up you know okay thank you okay we move on to supplement also plan and this is basically the provisions that federal funds must go our supplemental and must go on top or you stay on local funds and on this case again is mainly K funding so what is required the requirements say that funds for adult education and literacy activities under this title shall supplement or increase the level of services and not supplant or replace state or local funds expended for adult education and literacy activities so in other words Afla funds should not be used to pay for services staff programs or materials that will otherwise be paid with state and local funds a leading question that is useful when you're considering spending Afla funds is that to ask if you have been in the absence of Afla funds if the answer is that you can still support or pay for that service equipment or not equipment service or position or materials you should continue using those funds if the answer is no you might be able to use Afla funds considering they comply with the rules and regulations for Afla there are two presumptions of supplanting and this is coming from the OMB compliance supplement which is the federal compliance so the first one is the agency when the supplanting will be presumed if the agency use Afla funds to provide services that the agency provided with no federal funds in the prior year so again in general Afla funds are supplemental and the test is occurring to prior year so the first question when preparing your budget or planning any cause with Afla is to ask how would you pay for this service in the prior year again if you use state and local funds including cave you should continue those using those resources if this is a new cost or is a supplemental service a supplemental cost you might use Afla funds so on this first test the assumption from the feds is that if you use non-federal funds in the prior year you should continue to use those funds and throughout my presentation there are two notes which are questioned but not necessarily we don't require an answer on this presentation but it's to help you understand the requirement the second test is that if the agency use Afla funds to provide services that were required by law regulation and so again the assumption is that if something is required by law it should be allocated for that purpose and Afla funds should not be used for that that's it I like to mention that presumption of supplanted supplanting are reviewable if the agency can demonstrate that they will not be able to offer those services or for the cost well we know federal funds have the federal funds not been available and this reference here the information on the supplement as a plan on the CD website we have frequently asked questions I highly encourage you to visit that it's basically we will have the information that will that you'll need to know to comply with the supplement as a plan requirements of this grant and I also like to say the supplement as a plan is a case by case basis and definitely the specific details should be analyzed on each on separate situation okay we have a couple of questions to practice our understanding of this concept of this provision and this is our first question if you notice I included the answers for reference and for those who like to go back later on and review those questions but I feel that is also useful to understand the requirement and not be guessing which one do we say was the correct one or not so let's see the first one so on this one we have an agency that use state funds to pay for an adult basic education teaching position last year but decided to use federal alfalfa funds on the current year for the same teaching position because they receive additional funding so the answer to this is that this will be a presumption of supplanting because the agency replace in state with alfalfa funds to pay for the same position so in this case it will be bureau or supplanting will be difficult the only way it will be might be possible is if the position had extra responsibilities that are supplemental to the grant or it was something changed that we complied with the supplemental piece and we have one more this one include percentages I just like to mention that percentages are not coming from the rules of regulation so I'm just putting those to help us understand the requirement and most of the time they're really basic percentages 50, 25, 75 so just letting you know that these are not coming from any regulations so in this case we have an agency that rents a copy to be used 50% on alfalfa programs and 50% on non alfalfa programs the agency pay 50% of the rent cost with alfalfa and 50% we stay in local funds in the prior year but fully fully pay 100% pay with alfalfa funds in the current year because the stay in local funds resources were needed for other expenditures and again on this situation supplanting will be presumed that the agency redirects stay in local funds while using alfalfa to fully pay for the cost so on this scenario the agency can only pay up to 50% of the copier cost with alfalfa funds and this will relate to a locability we will be covering in more detail in a minute and that's pretty much it for Supplement Asset Plan James do we have any questions for Supplement Asset Plan? Yes so far there is one and what about budget adjustments if there are still funds in one category and we have an expense in another what is the threshold to be able to spend the funds within another category or do we need to process budget adjustment requests? Okay thank you great question so for alfalfa you can adjust your budget within a resource code for example a resource code 39 if you budgeted for something on the 1000 object code certificated personnel and you have funds available and there is a need to purchase devices or there is a need to pay someone classified so you can shift your cost within a resource code you cannot transfer funds between resource codes you can only shift your budget inside or within the object codes in a resource code I hope that makes sense actually I believe it's okay hold on here let's see if that does respond yes I believe yes Donna said thank you Janice is asking what if you discover a mistake great question thank you Janice so basically that will if there is a mistake like for example and I'm not sure what's the context to the question like for example we go on and do a federal compliance review and we notice that they pay these funds they pay last year with K funds and this year they showing that they pay with Afla funds so the first question a CDE reviewer will ask what was the reason for the budget shift and so if it was an error an error they say well we didn't notice that we pay with K and so we use Afla so if there's an error then the agency will have to reimburse those funds to the CDE the year that they use Afla funds if there's a supplanting violation so I hope that answered the question yes it did okay and I think we're all caught up now of our journal for questions okay thank you I think I went one okay we're moving on to different areas cost allowability and allocation this one has a lot of information and I'm really sorry for having so much information on some of these slides but on this specific one I want to include all these factors because all these are to be considered when you spend in each cost so definitely this one you will need to refer when you're planning to spend Afla funds because all needs to be considered I'll tell you that if the answer to the necessary reasonable and allocable is that you can support those three the rest are pretty standard so what is required to determine whether a cost is allowable or not is to be allowable in other words the cost must be necessary with that means can you demonstrate that there is a need and again program is the expert on this area so that's why I mentioned collaboration between program and fiscal is crucial the cost must be reasonable so reasonable is typically on the procurement department which a lot of the times is also fiscal that's where the person will pay based on the circumstances at the time the decision was made allocable is basically the cost charged to the program in proportion to the benefit received authorized is the requirement that it's not prohibited under Afla Edgar or the uniform guidance or stay a local fund for example sometimes something might be allowable under the factors affecting the availability but if it's authorized on the law for certain areas then that will automatically make it unallowable I will call it documented so that basically goes without saying it's that documentation that includes the planning it includes that you purchase order your evidence of approval and again the collaboration between fiscal and program and last one incurred during the approved budget period again the window to spend or obligate the funds for this grant is between July 1st and June 30th so on the unlockable I like to mention one example that will be referring to it because it's a very important concept so basically unlockable is is the proportion the part that you pay in proportion of the benefit received for instance if you pay a teacher with 50% with Afla funds or any other resources the documentation the time and effort documentation of that teacher must reflect that the program the Afla program receive 50% of the benefits if you another example if you purchase a laptop with 100% Afla funds the expectation is that that computer or that laptop benefits 100% the Afla program and again we'll be seeing more of that but I just want to mention because these factors are again to be considered every time that expenditure is made with federal funds including Afla on the D reference here for 22 section 422 section 426 general provisions and rules for selective items of cost which include advertising alcoholic beverages compensation of personal services which is salaries and benefits so most of the time you will see that the costs are allowable with restrictions you'll find those that are completely unallowable like for example costs for alcoholic beverages the list is an alphabetical order and it's not a complete list of allowable and unallowable costs as it relates to UYOA I'd like to note here that even though a cost must be listed as allowable it must also comply with the supplement as a plan provisions we discussed earlier and also meet those general cost principles noted on the prior slide is it necessary and reasonable a local authorized and adequately documented and incurred on the approved budget for instance costs for travel and compensation for personal services are typically allowable with certain conditions and requirements but if the agency pay for those costs in the prior year with K funds for example then that makes this cost automatically unallowable for this agency so again if you have questions of any of these general provisions you can reach out to the CD consultant or you can reach out to me and we'll have a couple questions to understand the allowable cost and allocation so in this case we have the question is may AFLA funds be used to pay for the salary and related cost of an adult education teacher and a lot of the times without knowing details the answer will be it depends generally salary and related costs are allowable but the cost are subject to restrictions and reporting requirements so in this case it will depend AFLA funds might be used if or considering the teacher provides services to students who are eligible under AFLA and the costs are necessary reasonable and all those requirements and comply with the supplementary supply and provision may AFLA funds be used to purchase office furniture such as desk chairs and cabinets and in this case the answer is no AFLA funds cannot be used for office furniture and in general AFLA funds cannot be used for capital expenditures and equipment with a per unit acquisition cost equals or exceeding the agency's capitalization threshold of $5,000 this is a state impulse requirement and there is a few state impulse requirements such as no equipment over capital expenditure over $5,000 per unit the other one is no indirect costs are allowable to claim under this grant those state impulse requirements are communicated to agencies on the request for applications the RFAs that were just recently submitted for the 23-27 cycle and this question includes I think will help us to understand the allowable proportion concept so in this case we have an agency the rents are copied that is used 50% on AFLA programs and 50% on non-AFLA programs so the question is can the agency charge 50% of the cost to AFLA and 50% to non-AFLA programs and the answer is yes remember the agency can charge up to the benefit received which in this case is 50% on B can the agency charge 75% of the cost to AFLA and 25% to non-AFLA and in this case it will be no 75% is more than the 50% benefit received so again the agency can only change charge up to 50% to AFLA on C can the agency charge 0% to AFLA and 100% to non-AFLA and the answer is yes charging 0% to AFLA and receiving 50% of the benefits is susceptible the feds will love this scenario so again in general allowable proportion concept is when two or more programs share cost plan ahead of the time the cost must be charged to each program in proportion of the benefit or if solely pay pay 100% with one funding source the cost must benefit 100% such funding source and that is pretty much for allowability and allocation James do we have any questions on the Q&A? Yes we do have a couple the first one is a permissible to utilize the AFLA fund to compensate instructors for additional responsibilities such as composing the monthly department newsletters Okay I like the question until the part that it says composing the monthly department newsletters and again that is possible if the additional responsibilities such as composing the monthly department newsletters include AFLA programs so you I can see that as advertising cost again it has to be for advertising for advertising the AFLA programs not the school so that seems like potential and definitely we will ask for more details if you reach out to CDE with that then we will need to know what kind of information is on the newsletter and what other programs because if you included AFLA programs we can do the school will do a cost allocation and you can share that with CDE and then we say that looks adequate but definitely what I like is the additional responsibilities that's definitely the intention of this grant this is supplementary grant to enhance your adult education programs so that's I hope that answered that question but it's if it is or if it is for information that relates to the AFLA program in this case advertising the program not the school that would be allowable and if there are all the programs like CDE that might not be part of AFLA then it will be a cost allocation and AFLA can definitely pay for that proportion of the benefit received okay thank you right and our second question would laptop carts be classified as furniture or equipment great question so laptop carts are we considered it's equipment but it's under if it is under 5000 it will be allowable if it was a need for it because it's really part of your laptop equipment or devices if it's under 5000 dollars per unit and it's pass all those requirements then that should be allowable even though it's equipment but again remember the equipment that is not allowable is with a per unit of 5000 dollars and more one thing to keep in mind on equipment a lot of the times the value is close to 5000 dollars please keep in mind that equipment the total 5000 dollars on equipment includes taxes and if that device requires installation delivery delivery cost all that is included on the total cost it's not just the net cost it's the total cost of the device taxes delivery cost and if it includes installation cost great now that's it for our current round of questions thank you great question thank you Jim okay time and effort reporting this is by far the biggest area that we'll be covering today and you'll see a lot of information but at the end of the day it's I hope I provide the tools for you to comply with this requirement and time and effort reporting time and effort is only one of those items on the 56 selected items of cost so it's it's basically directly related to compensation for personal services so there's a lot of requirements on this and I suspect because this is the biggest expense for adult education agencies and typically can account up to 90% of the total grant so bottom line is that if your agency use Afla funds for compensations of personal services to pay salaries and benefits then time and effort records are such as semi-certification personal activity reports time sheet whatever you use to document the time so time and effort records are required so what is required the requirements said that any employee full-time part-time substitute early pay with federal funds must maintain documentation showing that their time is allocable again that are locability in proportion allocable to a federal program so in other words a cost must be allocated or charged to a federal program in accordance to the benefits received again this basic example that if we if an agency if a teacher is paid 50% with Afla funds let's say resource cost $39.05 providing adult basic education and 50% with K resource cost $60.391 the time and effort documentation whether it's a semi-certification personal activity report time sheet whatever the agency uses must demonstrate that at least 50% of the time of the teacher's time was providing Afla ground related activities under the resource cost $39.05 so allocability I'm going to interrupt just for a second because there's a lot of questions and whistles are going off right now because of the alert so they're doing it across the United States so we got it a little early here you might not have gotten it yet where you're in California but I'm just making sure we have a little space here so people can turn off it and turn it off let me know when we're ready to continue I think we're good let's go I hope we're all good now the only thing I wanted to mention on allocation or allocability the easiest way to demonstrate that is to have the employees include the time and effort again in your personal activity report or part they should clearly state the activity and the actual time the employee is working benefiting the programs whether it's Afla or the other resources the employee is compensated for and we'll cover some forms that have space to document the activity and the time so in a coming slides we'll have examples that will help us or hopefully help you understand the requirements better this is the standards for documentation for time and effort the information is on three slides this is the first one included on the on the standards for documentation that we mentioned on the prior slide so again whether you use a minor certification parse time sheet this is the requirement so for this section of 2CFR200 430I1 the documentation must be based on records that accurately reflect the work performed the records must be supported by a system of internal controls which provide reasonable assurance that the charges are accurate allowable and properly allocated so a strong internal control ensure reliability and accuracy for example very viable documentation such as review and approval of supervisors signature for employees having first hand knowledge of the services the employee provide backup documentation such as duty statements class sketches and so again I included not with leading questions so hopefully this will help you when you go back and find if you responsible for this area then you can determine whether you have these systems in place or the requirements in place but if not it will help you identify who or what unit is doing this work the second requirement is that the records must be incorporated into the official records of the agency so basically on this case time and effort records should be incorporated with your payroll records and your time accounting records this is the second slide of three that includes the standards for documentation and so what the requirement says is that the records must reasonably reflect the total activity for which the employee is compensated so again if the employee is funded with more than one funding source the time and effort record must reflect 100% of the activity we sometimes when we do our reviews we see time and effort records some agencies maintain and the form has the elements that it only includes the portion that relates to the federal award so again it must include 100% activities the employee perform under the AFLA if they're the same as they do with CAPE they will still have to display those from CAPE if they're funded with all their funding sources it has to include all 100% of the activity the second one the next one is that the records must encompass all activities federal and non-federal so basically these two requirements go hand in hand and a leading question is do the time and effort records include all activities federal and non-federal reflecting again 100% of the position and we'll look at some forms that will help us understand the requirements this is the third slide that includes the standards for documentation and so the requirement is that records must comply with the agency established accounting policies and practices so in this case does your time and effort records align with your policies and procedures and we'll go over more policies and procedures but in instance what the policies and procedures say is what is taking place the next one is that the records must support the distribution among specific activities of cost objectives cost objectives is definitely something that we'll cover because it's important and we'll see more details on slides so cost objective is mentioned here on the federal requirement but pretty much what it is is cost objectives are the activities the employee perform and again the easiest way to have the employee describe or identify the cost objective is to include those or to identify or write those on the time and effort record for example a cost objective can be ESL instruction AB instruction administration professional development CASAS intake CASAS assessment so all those are different cost objectives or activities another requirement is that budget estimates these are estimates determined before the services are performed alone do not qualify as support for charges to federal awards so this is one of the most common reasons of non-compliance a lot of the times we receive documentation that reflects the funding and it's great to see how the person expanded but it does that is not the time and effort remember the effort is the effort that the employee perform services to the program so budget estimates again are not a valid evidence for time and effort documentation so what will happen when we receive those documents then we'll have to ask for more documentation so what do the person do then we might interview the employee then we will request payroll records class schedules to justify the charges to the program and the non-compliance still will be that the agency have to correct have a corrective action to train employees to develop those policies and procedures if not develop that the time spent on the program should be based reasonable based on the actual time the employee spend serving those programs again as mentioned cost objective this is one of the standards of documentation is that the records must support the distribution among specific activities of cost objectives so on the regulation cost objective is defined as a function activities mandated set of size mandatory minimums like for example with AFLA there is a requirement you can spend up to 5% for administrative cost so that's what makes administrative cost a cost objective I like the definition on the California school accounting menu they define in practical terms that a cost objective is a set of work activities allowable under the terms and conditions of a particular funding source for example on the resource code 30905 we have different cost objectives we have ESO instruction AVE instruction CASAS testing administrative cost so again this resource code 30905 39113 we have the high school secondary education or high school diploma, GED instruction that's pretty much the cost objective of those activities of a particular funding source when administrators again with collaboration with your program and fiscal staff you're planning and determining or verifying what type of documentation this employee should maintain something to keep in mind that the most significant factor is not the number of funding sources the employee is paid is rather the activity or activities being performed by the employee so it will go to what type when we want to determine what type of documentation certain employee should be maintaining the type of documentation will depend on whether the employee works on a single cost objective or activity or multiple cost objectives and again the regulation a single cost objective is a function activity and so on or when both the services being performed and the population being served is allowable and eligible under any of the program supporting the cost objective and we have a couple of examples that these are the typical ones with the Afla funds so a very basic one is when we have an employee solely providing ESO instruction on the resource code 30905 and he's paid 100% with Afla funds that's a single cost objective or single activity an example two when employee is paid with more than one funding source so we have an employee who solely again provides ESO instruction basically the employee is doing the same function as on the example one but in this case the employee is paid 50% with Afla and 50% with Cape on this case still the employee works on a single cost objective because the services being performed and the population being served English language learners are allowable and eligible under Cape and Afla supporting the ESO instruction cost objective of activity so again the factor is what the employee do compared to how is the employee being paid and we have that lead us to a semi-annual certification or periodic certification which is a form agencies often use to comply with the federal regulations for those employees who work on a single cost objective so these are the elements that a semi-annual certification will include to meet the federal requirements it will be it will reflect an updated file record covering the entire period of the certification identifies again the cost objective or activity resource code percentage of actual time hours time spending for the period of the certification accounts for the total activity for which the employee is compensated that means federal and non-feral any sign and dated by the employee or supervisor agencies might require both signatures that's a really good internal controls showing that the employee sign and this supervisor review and approve that time and effort documentation there is a sample certification semi-annual certification on the California school accounting manual and this link will take you to that but if not it's on page 905 19 I like to mention that the semi-annual certification or periodic certifications forms our suggestions the agencies might use different certifications that as long as it meets the federal requirements we talk about on those three slides and the one prior to that so again if the agency use a different type of form of certification for employees who work on a single cost objective make sure it includes these elements and I hope you can see this you can probably zoom on the powerpoint but this template of form is basic and it's typically again for someone who works on a single cost objective or activity and is paid with only one funding source if you utilize correctly this sample template includes all the elements and information the agency will need to help the agency meet the federal regulations for example if you have an instructional aid who works 100% supporting let's say you adult secondary education instruction and is paid solely with resource code 3913 then these forms will be adequate I like to mention something important employee training is very important even with these simple forms because employee will need to understand that what they sign in is based on their position and they certifying that that's what they did they provide adult secondary education instruction and this is on this case a minor certification that is covering typically from July 1st to December 31st and then is signed after December 31st a testing or certifying that in fact that's what they did during those six months this is the the template example to our second example on this slide which is for someone who still work on a single cost objective but is paid with more than one funding source again if you utilize correctly this template includes the information to help the agency meet their requirements continuing with time the type of documentation again when you're making that determination how do we what the documentation this employees should maintain and again the type of documentation will depend on whether the employee works on a single cost objective or multiple cost objective we have the multiple cost objective is basically when an employee works on more than one federal work a federal and non-federal work function and the activities performed are not considered a single cost objective so a two examples on this case we have an employee who is funded 25 with AFLA resource code 3926 25 with Perkins so that at that point we know it's two different federal programs so that employee works on a multiple cost objective so that employee will maintain the documentation the agency uses for individuals or for employees who work on a multiple cost objective the sample the sample two is if an employee provides AFLA instruction and administration services which includes professional development and he's paid 100% with AFLA funds the employee is considered to work on multiple cost objective as instruction and administration activities are two separate functions of cost objectives within the AFLA grant so even though it's 100% paid with AFLA the employee works on two cost objectives so the information should be maintained for each of those activities and again the most important factor is what the functions employee do rather than the how they are paid parts of equivalent so this are typically the adequate for employees who work on multiple cost objectives who usually have a variation of activities support various programs and we typically refer this as a par timesheet or time log and the elements for this certification is that this is after the fire record after the employee performed the activity reflecting the actual time work not budgeted estimates on each cost objective of activity under each resource code prepare at least monthly or a substitute system includes all activities for which the employee is compensated 100% federal and non-federal again signing date by the employee or supervisor agency might require both this is a strong internal control again and I'm also including a link to a sample form on the California school accounting manual so that form is basic but it's include the elements to meet the requirements the federal requirements again if the agency use any other type of documentation for employees who work on multiple cost objectives please ensure that includes at a minimum these elements and most importantly that they meet the requirements on the slides that we discuss the standards this is a sample form for those who work on multiple cost objectives and their time is fairly predictable again training is important so they understand that they need to document 100% so on this case this will be adequate for someone who for example a teacher who teaches adult basic education and also teaches ESL or the literacy part under resource code 3926 so 3926 3905 they are different requirements for those funds so by itself are two different cost objectives and if an employee is paid with 3926 and 3905 in CAPE and other programs then automatically the employee is working on a multiple cost objective again because the requirements for 3905 3913 and 3926 are different so it's different sources of funds with different eligibility this is another form for employees who work on multiple cost objectives and again if utilized correctly these form include the elements and information to help the agency meet the time and effort requirements who work on multiple cost objectives this form is fairly simple and I really like this form because it includes a clear area for funding source activity and the time the employee spent serving that activity and that funding source again these are just samples if you use any other form or certification make sure you include the elements on these forms and again employee training is very important because often we see the certifications but they not completed correctly sometimes on the activity they just listed adult education which is not very helpful because we don't know what they did on adult education sometimes it has just the resource code and not the activity but again with the resource code we don't know what the activity was so we cannot verify if that activity is allowable or not allowable so employee training is very important that these forms are completed correctly and are reviewed and approved within reasonable time because if the form is monthly you should be in and completing these forms right after the end of the of the month and it will have to show that it was reviewed and approved or it was signed some type of assurance that is reasonably close to the month that is reported real quick the other part that is required for time and effort is policies and procedures and so this the federal allocation guide indicates that these are essential to implement an effective time and effort reporting system then the process should be in sufficient detail to understand how the systems will operate from when the time is work and when the time is recorded on the accounting records charged to the federal award so some of the comments non-compliance that we notice is that sometimes agencies don't have policies and procedures updated or nonexistent so if that is the case definitely you will start as soon as you can and then reach out to your CD consultant if you need any assistance and agency written policies and procedures are to be established and implemented for documenting time and effort of employees that work on federal programs some of the elements that might be included on those policies and procedures one key requirement or something really important is that the policies and procedures must include the elements to meet the federal compliance and also ensure that what is reflected on your policies and procedures is actually taking place so your time and effort records should be aligned to your policies and procedures if you say that you maintaining personal activity reports then you really maintaining personal activity reports and they should include things such as what forms are they used who must complete the forms, the due dates where and when the forms are submitted approval reconciliation process, employee training and sample forms in the appendix so when you have a review this is one of the first areas that we review to understand your system and so when we review the policies and procedures expectation as that that's what's happening on actually happening with your time and effort documentation and a couple of questions to help us understand the single versus multiple cost objective on this question is we have a director of adult education who provides administrative services for AFLA and also we are title one Perkins so on this case once we see more than one federal award one federal program automatically is that the person works on a multiple cost objective single or multiple cost objective here we have an instructional aid who provides instruction support for ABE students who are allowable under CAPE and AFLA in addition the aid provides CASA's pre-test post-test and to these students the aid salary benefits and benefits are paid 60% with CAPE and 40% with AFLA Resource Code 30905 so on this case the answer is ABE based on that the services being performed ABE instruction and CASA's pre-test post-test and the population being served ABE students are allowable and eligible under CAPE and AFLA so on this case the employee will complete time and effort documentation the agency uses for employees who work on a single cost objective and this is the last one we have a school principal principal who provides support to all adult education programs and again we will need to know the functions of the services that the employee performs to make a determination so on this case it will not be sufficient information to determine cost objective we will need to know what kind of support the principal does for this and what kind of programs support okay and that's it for time and effort we're almost done James do we have questions for time and effort yes we have several so I'll get right to it first one do you need time and effort reports for all adult ed staff even if they are not paid with AFLA funds are only those that are paid with AFLA funds for example the agency pays some of their teachers with AFLA but not all okay the it will be the short answer is yes and let me say for federal for employees who are paid with AFLA funds it's absolutely yes for employees who are paid with restrictive funds for example Cape is also yes the agency should follow the federal rules for those employees who are paid with restrictive programs on the California school accounting there is an alternative to use for those who are paid with restrictive programs but the general rule is that they should be using the the systems of the time and effort process that they use for federal but I'm not sure what the details are for those who are paid with K-fans for the alternative because there's an alternative that they can use but the expectation is that they use the federal requirements great and the next one I think this question was asked before you provided examples of the PARS and the semi annual certification but it says might you have a sample document to look at for time and effort so the person who sent that question in if what Arturo provided isn't what you're looking for then let us know thank you and then is 50-50 allowable even if prior to receiving Viola grants the teacher was paid 100% with Cape okay great question so again the employee it really have to consider if there's a change on the activities for example if the employee was 100% with Cape and it was just providing ESL and now you want to pay that employee with 50% K-50% afla it has to be some change on the position for example now the teacher instead of just doing ESL the teacher is also providing tutoring services is providing additional support to students that are not part of the same position so it really depends on the services and not so much because what we use is we use as a first question is how this employee was paid on the prior year but then it might be different reasons it might be because the employee got promoted because now the employee is teaching different subjects so on this case it's possible but it will the first consideration is what's the difference from last year because when there's a budget shift it has to be a difference it has to be because there are additional functions that are supplemental that might justify the charge of the shift on funding great and this person I think just had an example that they wanted a little clarity on it says if you have an IET teacher teaching part CTE and part ESL they can only be funded in part correct yes that is the and I'm going to assume the IET, the CTE is for the resource code 3926 again those funds are intended to support English language learners with the literacy and the co-ops part so on that case definitely the CTE part has to be paid especially with non-AVLA Title I usually can support the training piece okay great and then are CASAS testing and admin tasks considered different cost objectives yes CASAS testing is direct services to everything that is direct to students it's part of the 95% of the ground which is the activities the administration is a different cost objective because there is that 5% that it needs to be identified so that is why it's two different cost objectives okay great and then we're just going to see are there any risks exactly what activity are cost objective terms to use we don't really have a specific document that shows the cost objectives but that's really interesting that maybe we will put something in place but in a way to think about cost objective is really the activities the employee perform and the easiest way is to think on resource code 3905 is ESL ESL includes instruction administration assessment testing and data reporting so data reporting like for example those data managers that's administrating the grant so that is administration CASAS testing student intakes orientation those are services directly to students so that is not administration cost anything that doesn't have to deal with the ministry of the grant is direct cost and a cost objective again there's no right wrong but it should be sufficient to identify the activity the employee is doing okay if reassigning an IA in a high school program who is paid by general funds to conducting an AFLA activities such as CASAS assessments would it be allowable to switch to AFLA funds I'm sorry what is I think what they're asking I think we have a classified person our teacher it's an IA and there's a lot of acronyms in a high school program so the person is they are being paid in general funds but then I guess as part of their tasks they're conducting and AFLA activities such as CASAS assessments would that portion I think they're asking would that portion of their job be allowable to switch are to be covered by AFLA funds yeah I think the keyword there is reassigning and again it's really not the person it's what the person is doing again if it was paid with CAPE doing something related to CAPE but now it's going to be reassigned to AFLA activities and if there is a need and they comply with the rules and regulations that should be okay right and our last one helps with watching adults with kids be considered in AFLA supplements watching so like I think the students kids child care yeah I will so basically if you definitely that seems like that might be allowable because if I would say what I think is confusing or at least interesting is the instructor watching kids so adults with kids so for child child care it's it might be because if they to attend those AFLA programs they would not be able to pay with K funds for child care but with AFLA funds they would not be able to pay for child care costs whether it's a instructor or someone who's going to watch that's definitely a supplemental because it wouldn't be I guess the easiest way to put it it wouldn't be possible without the AFLA funds and that's the whole purpose to use AFLA funds for those type of services for services okay great that's it for the questions okay and again we just have these are these will go in a couple of minutes so this is the the matching requirement is that the 25% annual that all grantees must provide in non-federal funds and this is typically the those of you who are continuing so on the next slide I'm going to show you an example these are reported on the ECR again the non federal funds contribution can be on cash in kind or stay in local stay in local funds so I just want to mention a key requirement on the matching contribution is that they are subject to the same rules and regulations the AFLA funds are subject so it has to be allowable under the grant in order to be for the agency to claim or to report as a matching contribution so this is the agency reported the the non-federal contribution on the expenditure current report this is an example of while new grantees will see and it's just divided on three sections the state general fund is typically your cave expenditures related to AFLA activities all the non-federal funding that is very rare I mean it's often that we see those mainly because the contribution really are things such as cash or designated foundation local grants assigned for AFLA programs in-kind funding is the other section and in-kind funding is as typical as that is your classroom space volunteering time buildings donated property and so on and that's if there's any questions on matching Jim so far nothing's appearing we can give folks maybe a second or two but it's yeah I guess you covered everything for that section so great okay and if there's no questions right on time thank you so much again for attending and we know this can be complex but again keep this PowerPoint reach out to your CDE consultant reach out to me if there's anything we can assist and if you have additional questions you can send those to me or to your consultant or to the CDE adult education office so the information is on this slide and again I want to thank you one last time