Equivalent Documentation for Multifunded Employees

This management bulletin provides guidance to school food authorities (SFA) about federal and state requirements pertaining to equivalent documentation of employee time and effort for multifunded employees. It is intended to build on currently published time accounting policies and procedures. For general information on documenting employee time and effort, SFAs should refer to the California Department of Education (CDE) Management Bulletin SNP-06-2014: Documenting Employee Time and Effort in Federal School Nutrition Programs web page at https://www.cde.ca.gov/ls/nu/sn/mbsnp062014.asp. Additional information is available on the U.S. Department of Agriculture (USDA) Policy Memorandum SP 60-2016: Indirect Cost Guidance, on the USDA School Meals Policy web page at http://www.fns.usda.gov/school-meals/policy.

Note: The CDE Cafeteria Fund Frequently Asked Questions: Documenting Employee Time web page at https://www.cde.ca.gov/ls/nu/sn/cafefundguide.asp#timeandeffort provides some time and effort documentation information for the Fresh Fruit and Vegetable Program.

Background

Title 2, Code of Federal Regulations (2 CFR), Section 200.430, Standards for Documentation of Personnel Expenses; Management Bulletin SNP-06-2014; and the California School Accounting Manual (CSAM) Procedure 905 (available on the CDE Definitions, Instructions, and Procedures web page at http://www.cde.ca.gov/f g/ac/sa/ require employees who are paid with federal funds to accurately document their time and effort within the federal program. The federally funded portion of the employee salary must reflect the actual time and effort the individual has put forth for each funding source for which the employee has completed work.

The purpose of documenting time and effort is to ensure that SFAs use federal funds to compensate an employee only for time spent on work activities allowable under the terms and conditions of the federal funding source. The level of time and effort documentation needed is predominantly determined by whether an employee works on a single-cost objective or on multiple-cost objectives.

While time and effort documentation for single-funded employees may include only a periodic (semiannual) certification, multifunded personnel must keep personnel activity reports (PAR) or equivalent documentation which, at the minimum, meets the criteria contained within a PAR. Examples of multifunded employees that need to complete a PAR or equivalent documentation include staff working on multiple-cost objectives where their time and effort must be indicated separately between federal programs such as the National School Lunch Program (NSLP) and the Child and Adult Care Food Program (CACFP). Furthermore, those employees that charge their salary or wage to a combination of at least one federal funding source and state or local funding sources must complete a PAR or equivalent documentation.

Time and Effort Documentation for Multifunded Personnel

Federal regulations require SFAs to maintain auditable time and effort documentation that accurately reflects the compensated time for federally funded employees. Such documentation must reflect an after-the-fact distribution of the employee’s actual activity. Budget estimates or other time distribution percentages determined before the services are performed, unless preapproved by a cognizant agency, are not permitted. Time and effort must be documented for any staff charging their salary or wage directly to either a federal award, multiple federal awards, or any combination of a federal award and state or local funding sources. Total activity means that the time and effort documentation must document all the activities that were performed by employees within the pay period.

Per 2 CFR, Section 200.430, and the CSAM Procedure 905: Documenting Salaries and Wages, employees who are charging their time and effort to multiple funding sources (e.g., the NSLP and other federally funded programs such as the CACFP), must separate time and effort costs between each Child Nutrition Program (CNP). These employees are required to demonstrate on their PAR or equivalent documentation how their work benefited the nonprofit school food service and, at the very least, provide a list of activities that they performed for the nonprofit school food service. A PAR must:

• Reflect an after-the-fact distribution of the actual activity of each employee working on a multiple-cost objective (not budgeted hours)
  
  
• Account for each activity for which the employee is compensated
  
  
• Be prepared at least monthly and coincide with one or more pay periods
  
  
• Be signed and dated by the employee after the work has been performed
  
  

Equivalent Documentation

SFAs that have multifunded staff may use an equivalent time and effort documentation as an alternative to a PAR. Each multifunded employee working for the nonprofit school food service must use a PAR or equivalent time and effort documentation. The table below lists the equivalent documentation requirements:

The job description or duty statement must contain activities allowable under the terms and conditions of the federal funding source (for CNP). The SFA needs to allocate benefits according to the percentage of time worked for each time period.

Using the equivalent documentation, the CDE reviewers will be able to confirm if the time and effort accounting for multifunded personnel is allowable under the federal award. For example, if a district did not maintain a custodian’s time and effort charges using a PAR, the district would be required to submit the custodian’s job description to the CDE. If the job description includes cleaning instructional space, this would not qualify as equivalent documentation as it includes an activity that is unallowable under the federal award.

Contact Information

If you have questions regarding this subject, please contact the Resource Management Unit by email at snpcafefundquestions@cde.ca.gov.

If you have any specific questions about meeting time and effort documentation requirements for the CACFP or Summer Food Service Program (SFSP), please contact your Program Specialist.

• CACFP: The CACFP Specialist list is available in the Download Forms section of the Child Nutrition Information and Payment System (CNIPS), Form ID Caseload. You can also contact the CACFP Office Technician (OT) by phone at 916-327-2991 or 800-952-5609, Option 3. [Note: The preceding information is no longer correct. The CACFP moved to the California Department of Social Services (CDSS). Information may be found on the CDSS website at https://www.cdss.ca.gov/cacfp.]
  
  
• SFSP: The Summer Meals Unit (SMU) Specialist list is available in the CNIPS Download Forms section, Form ID Caseload. You can also contact the SMU OT by email at SFSP@cde.ca.gov.