If your district or school uses federal funds to pay staff—even partially—time and effort documentation is not optional.
Time and Effort is one of the most frequently reviewed (and most misunderstood) compliance requirements in federally funded programs. While it can seem like just another piece of paperwork, these records are essential for protecting your district, showing that funds are used correctly, and demonstrating fiscal accountability.
Why Time and Effort Documentation Matters
Time and effort documentation is required under the Uniform Grant Guidance (2 CFR Part 200.430). Its purpose goes beyond compliance — it serves as an important financial safeguard for districts.
Proper documentation helps ensure that:
- Federal funds are used only for allowable, allocable, and reasonable costs
- Salary and benefits charged to grants are supported by actual work performed
- Districts are protected during audits, monitoring, and program reviews
- There is clear evidence that staff are working on the programs being charged
In short, time and effort records demonstrate that federal dollars are being used exactly as intended.
Who Must Complete Time and Effort or Certification
Time and effort documentation is required for:
- Employees paid in whole or in part with federal funds
- Employees whose time is used to meet a federal match or cost-share requirement
- Employees working on:
- One federal program
- Multiple federal programs
- Federal and non-federal cost objectives
Key takeaway: If federal funds touch a position in any way, time and effort documentation is required.
Single vs. Multiple Cost Objectives (The Big Question)
This is one of the most confusing — and most critical — parts of time and effort compliance.
What Must Be Included in Documentation
All time and effort documentation must:
- Reflect actual work performed
- Include all activities, not just federally funded duties
- Be incorporated into official payroll records
- Support the distribution of salary and benefits
- Be consistent with district accounting policies
- Be signed and dated
These elements are essential for audit and monitoring purposes.
Common Compliance Mistakes to Avoid
This is where many districts get tripped up. Some of the most common errors include:
❌ Using semi-annual certification for split-funded staff
❌ Signing certifications in advance
❌ Job descriptions that don’t match how the position is funded
❌ Missing signatures or dates
❌ Not retaining records for audit purposes
❌ Assuming Title I Schoolwide means no documentation is required (it is still required!)
Record Retention & Audit Readiness
Time and effort records must be retained in accordance with:
- Federal record retention requirements
- State and local record retention policies
To stay audit-ready, districts should ensure records are:
- Easy to access
- Consistent with payroll and accounting systems
- Reviewed regularly for accuracy and completeness
Good organization now prevents major headaches later.
Best Practices for Districts & Schools
Strong systems make compliance easier and more sustainable. Consider these best practices:
- Maintain up-to-date job descriptions
- Align payroll coding with actual employee duties
- Train principals and supervisors on requirements
- Use standardized district forms
- Conduct internal reviews mid-year
- Document changes in funding or job duties immediately
Proactive monitoring helps catch issues before they become findings.
Why This Matters for Federal Program Monitoring
Time and effort documentation is a frequent focus during TEA and federal monitoring. Errors can result in:
- Compliance findings
- Required repayment of funds
- Corrective action plans
Strong documentation systems reduce risk, support fiscal integrity, and help districts avoid costly surprises.
Making Time and Effort Work for You
Time and effort doesn’t have to be complicated—but it does have to be done correctly. The good news? With clear processes, ongoing training, and regular reviews, districts can turn one of the most misunderstood requirements into one of their strongest compliance areas.
Now is the time to review your current practices, confirm documentation is accurate, and fix small issues before they become bigger problems.
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