Federal Programs Requirements

Allowability of Expenses

All costs charged to federal programs must be necessary, reasonable, and allocable for the performance or administration of the grant considering the amount of money spent and the needs of the program.

2 CFR § 200.403(a)

Time and Effort

Federal regulation requires that any salaries and benefits charged to federal awards must be based on documentation that reflects the actual time spent by the employee on activities being charged to those programs. Such documentation must be completed after-the-fact and will be completed in accordance with district procedure and UGG.

2 CFR § 200.430

Classified employees will use a digital time clock to record hours worked. Hours logged for each employee must be actual hours completed.

Certified employees will receive a Monthly Time & Effort Certification, generally sent on a quarterly basis, that certifies what portion of their work is allocated to the award. The form must document 100% of efforts by each employee, including those not allocated to the federal award. Those who work exclusively within a federal (or special education) award, will sign a semi-annual certification. 

All time and effort certification forms will also be signed by a supervisor (superintendent, principal, or special education director). 

Supplement not Supplant 

ESEA section 1118(b)(1) requires that an LEA use the Title I, Part A funds it receives from its SEA only to supplement funds that would, in the absence of Title I, Part A funds, be made available from State and local sources for the education of students participating in a Title I program. 

Maintenance of Effort

LEAs receiving Title I, Part A funds must comply with the annual Maintenance of Effort (MOE) requirement. In short, MOE requires districts to maintain a consistent floor of state and local funding for free public education from year-to-year. MOE applies to Title I, Part A; Title I, Part C—Migrant Education; Title I, Part D—Neglected and Delinquent; Title II—Effective Educators; Title III—English Language Acquisition; Title III—Immigrant; Title IV, Part B—21st Century Community Learning Centers; and Title VI—American Indian Education.

Maintenance of Effort can be satisfied by a LEA in one of the following two ways: 

1. By looking at the amount the LEA has expended in non-federal expenditures two years previously, taking 90% of that amount, the results must be greater than or equal to the amount spent in the previous year for the LEA to have no reduction in funds for the current year; or 
2. By looking at the amount the LEA has expended per pupil in non-federal expenditures two years previously, taking 90% of that amount, the results must be greater than or equal to the per pupil cost of the amount spent in the previous year for the LEA to have no reduction in funds for the current year.

Allowable reductions may be made for the following reasons:

1. The voluntary departure, by retirement or otherwise, or departure for just cause of service personnel 
2. A decrease in the enrollment of qualifying students 
3. The termination of costly expenditures for long-term purchases, such as the acquisition of equipment

USBE Title I Handbook

Asset Tracking

Assets purchased with federal grant or program funds must be tracked and tagged in accordance with federal requirements. The program associated with the capital asset purchased with federal funds must be identified in the capital asset records (i.e. Special Education, Food Service, etc.)  Capital assets shall be inventoried annually.

Sale/Disposal of Property

The sale and disposal of federal assets falls under the authority of the Business Administrator. No district employee shall transfer, sell, or trade any property owned by the district without written authorization from the Business Administrator.

Surplus property shall be offered to the general public through competitive sealed bids or public auction. An internet/online auction method is an acceptable method to conduct a public auction/sale. In circumstances where traditional methods of sale are inappropriate or disadvantageous to the district, the Business Administrator may authorize and employ alternative methods in accordance with general District disposition policies that provide greater advantage to the District. At a minimum, surplus property sales and/or auctions shall be advertised at least once in a local newspaper of general circulation and notice shall be posted on the District website. 

When no bids are received on an item for sale, the Business Administrator may determine the method of disposal of the item, provided it is in the best interest of the District.