I. Purpose: Explain the Process to Principals, Directors, Officers, and Grant Managers

BALTIMORE CITY PUBLIC SCHOOLS (CITY SCHOOLS)

DEPARTMENT: DEPARTMENT OF GRANTS ADMINISTRATION FINANCE SUBJECT: OMB 2CFR PART 225 COMPLIANCE (FORMERLY OMB A-87) FY 2014 (CERTIFICATION)

I. PURPOSE : Explain the process to Principals, Directors, Officers, and Grant Managers for completing certification affidavits for federal funded employees (full and /or partial) as required by the Office of Management and Budget (OMB).

II. GOVERNING POLICY/REGULATORY IMPLICATIONS :

A. Code of Maryland Regulations (COMAR) 13 A.02.01.02, Section 5-101, Education Article, Annotated Code of Maryland B. OMB Circulars A-133 and 2 CFR Part 225 (OMB A-87) – www.whitehouse.gov/omb/circulars .

III. IMPLEMENTATION GUIDELINES :

A. The Office of Management and Budget (OMB), a federal agency, issues standards to State and local governments receiving federal grant awards. As a condition of receiving the grants, including IDEA and Title I, school districts must comply with all OMB regulations. OMB 2 CFR Part 225 describes specific documentation requirements that when a salary is either fully or partially paid by a federal grant.

B. Employees Fully Funded by a Federal Grant

1. The OMB 2 CFR Part 225 guidance for employees fully funded by a federal grant states that the Salaries and wages of such employees will be supported by periodic certification that the employees worked solely on that program for the period covered by the certification.” OMB 2 CFR Part 225 further states that the certification will be “…prepared at least semi-annually and will be signed by the employee or supervisory official having first-hand knowledge of the work performed.”

C. Employees Partially Funded by a Federal Grant

1. Some employees’ salaries are paid by a combination of funding sources. For example, the salary of a full-time employee may be paid .5 by Title I and .5 by local dollars, In these instances, OMB 2 CFR Part 225 states “…that a distribution of the employee’s salary is supported by personnel activity reports or equivalent documentation.” Complying with this regulation requires that such employees keep Time and Effort logs.

CITY SCHOOLS- SYSTEM FORMAL NOTIFICATION FY 2014 PAGE 1 BALTIMORE CITY PUBLIC SCHOOLS (CITY SCHOOLS)

C. City Schools Requirements in Response to OMB 2 CFR Part 225

1. The standards noted above require that City Schools supervisory personnel complete certification affidavits for fully funded staff on a bi-annual basis. In addition, compliance with the OMB requirement will also require that staff oversee the maintenance of Time and Effort logs for partially grant-funded employees.

2. All principals, supervisors, and grant managers who currently employ federally- funded staff will receive specific directions on the maintenance of the required documentation. It is expected that all staff comply fully with the OMB requirement and with the procedures that City Schools’ Grants Administration Office has established.

INSTRUCTIONS

Principals and Grant Managers must complete an affidavit if they have federally-funded staff assigned to their Cost Center. Please see the directions below as they apply to your area of responsibility.

School Principals

The Employee Certification form will serve as the affidavit. The Employee Certification form lists only those staff members in your school who are paid from one of the many federal grants in the BCPS. The pre-printed form includes the staff member’s Job Title, Cost Code (funding source), and Full Time Equivalent (FTE).  Each principal must sign for receipt of the Employee Certification Form.  For each employee on the summary list, indicate by circling “Yes” if the employee is (a) working in your school and (b) performing the duties of the grant that is funding the person’s salary.  If either condition (a) or condition (b) is not true, then circle the “No” response for that particular employee. If you circle “No” for any employee, indicate the reason for the “No” by providing a response on the Additions/Corrections/ Deletions page.

If you have federally-funded employees in your school who do not appear on the pre-printed Employee Certification form, use the Reconciliation form:

 Add the employee’s name to the Corrections sheet.  If an employee is erroneously listed on your Cost Center summary as a federally-funded staff person, record the correct funding source for that employee on the Corrections sheet.  For split-funded employees complete the attached Time and Effort form that may be used. Maintain Time and Effort logs of split-funded employees effective the start date of the employee is assigned to the grant.  On a daily basis, the employee should record on The Time & Effort form the number of hours and a summary of grant related tasks performed.  Weekly, employees must sign, date and submit the Time and Effort form to the Principal and /or Grant Manager.

Grant Managers in Central Offices

OMB 2 CFR Part 225 verification requirements also apply to non school-based grant managers who oversee federal programs. Each grant manager must follow the same verification steps as outlined above for principals. Certify each employee on your pre-printed list as working on grant activities and salary paid using grant funds.

It is more likely that grant manager rosters include a higher number of partially-funded staff, which requires the maintenance of Time and Effort logs. Therefore, in addition to certifying that the employee is working on grant activities, the Grant Manager must also ensure that proper Time and Effort documentation is maintained by anyone who is not funded 100% by the federal grant. Submit copies of employees’ Time and Effort logs with the Employee Certification forms.

Certification Periods for FY2014 are:

First Certification covers the period of July through December 2013. Second Certification covers the period of January through June 2014.

◊ Second Certification Reports are due to Grants Administration by: Monday, June 30, 2014

CONTACT INFORMATION :

Name of Contact Person: Pauline D. Edwards, Director Grants Administration Phone Number: (410) 396-8940 Contact Email: [email protected]

Name of Contact Person: Ray Anuforo, Grants Management Administrator Grants Administration Phone Number: (410) 396-8909 Contact Email: [email protected]

CITY SCHOOLS- SYSTEM FORMAL NOTIFICATION FY 2014 PAGE 4 Baltimore City Public School System Reconciliation Form

Directions:

If there are any discrepancies on your Federally Funded Employee Certification report, please check the corresponding box below that best describes your situation. Attach this form with your employee certification form and return items to the appropriate supervisor as described on the set of directions by the deadline.

An error exists on my employee certification form. The following describes the situation:

 Missing the names of permanent federally funded employees.

 Missing the names of temporary federally funded employees.

 Employee listed has an incorrect costing string (fund number).

 Incorrect full time employee (FTE) status.

 Incorrect position title recorded for employee.

 Incorrect subject assignment recorded for employee.

 Other:______

 Please note any needed corrections on the reverse side of this page.

Name:______Date:______

CITY SCHOOLS- SYSTEM FORMAL NOTIFICATION FY 2014

Baltimore City Public School System Reconciliation Form

ADDITIONS/CORRECTIONS

Employee # Position # Employee Name Effective Date Job Title Cost Code FTE Area: Cost Center:

DELETIONS

Employee # Position # Employee Name Effective Date Job Title Cost Code FTE Area: Cost Center: 1.

Baltimore City Public School System Time and Effort Log (Instructions for all Federally-Funded Staff)

1. Complete all header information.

 Name of Grant

 Fund Number

 Week of

 School Number

2. Provide the total hours worked for each day of the week. For split-funded staff, only show the time devoted to grant related duties.

3. For each day worked, provide a brief summary of the service that was provided.

4. Sign and date the form. Ensure that the form is signed and dated by the supervisor. (Weekly signatures are recommended)

Baltimore City Public School System Time and Effort Log

Name of Grant:______Fund Number:______

Week of:______School Number:______

Monday Tuesday Wednesday Thursday Friday

Total Hours Total Hours Total Hours Total Hours Total Hours Worked:______Worked:______Worked:______Worked:______Worked:______

Summary of Service: Summary of Service: Summary of Service: Summary of Service: Summary of Service:

Employee’s Signature:______Date:______

Authorizing Supervisor:______Date:______

Baltimore City Public School System Time and Effort Log