The Florida Department of Education (FDOE) will begin on July 1, 1996, using the following system for the allocation of salaries and wages that are charged to Federal awards or are used as part of cost sharing requirements according to actual time spent on Federal awards. The purpose of this time distribution system is to accurately and efficiently charge Federal grants according to FDOE employees' actual time spent working on those programs. This system is in compliance with the May 17, 1995, Office of Management and Budget Circular A-87, at attachment B, section 11.h.(6)(c). The system will operate on the general premise that there is an even workload for employees's salaries to accounts, and if necessary, adjust those estimates based on actual time records from specified months.

1) Personnel Activity Reports, as described in paragraph 5, for each participating employee [ Participating employees include those who split their time between State and Federal programs, between Federal programs or between cost objectives. Those employees working 100% on one Federal grant program or cost objective must complete at least semi-annual certifications that they work solely on a single Federal grant award as required by OMB Circular A-87, at Attachment B, section 11.h(3), but are not required to keep actual time records. Those employees working 100% under a consolidation of administrative funds in accordance with section 14201 of Title XIV of the Elementary and Secondary Education Act must also complete semi-annual certifications. These certifications will require an employee to provide accurate and complete information that is signed by the employee or employee's supervisor with first-hand knowledge of his or her work. If the employee works on other programs in addition to those programs covered by consolidation of administrative funds (covered programs), actual time distribution records must be kept, but those covered programs could be considered one cost objective.] will be kept by FDOE for the full month of September to account for 100% of the activity for which these employees are compensated. The Personnel Activity Reports for September will serve as the basis for adjusting the previously estimated employee salary and fringe benefits for July, August, and September and making estimated budget allocations for October, November, December, and January. The estimates used for the July through September quarter for the first year (1996-1997) will be based on the best actual information available to Florida.

2) In January, FDOE will repeat the actual record keeping procedure using the Personnel Activity Report form described in paragraph 5. The January Personnel Activity Reports will be used for adjusting previously estimated employee salary and fringe benefits for October, November, December, and January and making estimated budget allocations for February, March, April and May.

3) In May, FDOE will repeat the actual record keeping procedure using the Personnel Activity Report form described in paragraph 5. The May Personnel Activity Reports will be used for adjusting previously estimated employee salary and benefits for February, March, April, and May, for making final allocations for June, and for making estimated budget allocations for July, August and September of the following fiscal year (or for estimates for July through January of the following year if FDOE qualifies under paragraph 4). [ If there are major changes in programs, changes in employee program responsibilities, reorganizations, rescinded programs, etc. there will be adjustments made at the time of the change.]

4) If the average level of differences between the actual time records and the initially estimated time in September, January and May are less than 10%, [ The average level of differences is the composite of the differences for the various employees for each of these reporting months. The average difference for each employee for each month is computed by averaging the percentage deviations for each cost objective. Therefore, if an employee's estimated time among four cost objectives was 2.5% for each objective, and the actual time was 20% for objective A, 30% for objective B, 35% for objective C, and 15% for objective D, the overall percentage deviation (average level of difference) for this employee would be 7.5% (5% deviations for objectives A and B and 10% deviations for objectives C and D (for a total of 30%) divided by 4). For the purposes of computing the 10% variance (the average level of difference), employees working 100% on one Federal program or cost objective will be excluded.] Personnel Activity Reports will be completed with actual time only for January and May of the following year. The results of those Reports will be used for the distribution of salary and wages for the fiscal year in progress which runs from July 1 through June 30. The FDOE will make adjustments for the fiscal year based on the January and May actual data, and may make those adjustments once in June. The January data will be used to adjust the estimates for the preceding months of July through January, and for making estimated budget allocations for February through June. After the first year that the system is in place, Personnel Activity Reports will be kept in only those two months as long as the average level of differences between actual and estimated time is less that 10%. If the average level of differences for any year is greater than 10%, FDOE will keep actual time records as set forth in paragraphs 1-3 the following year.

5) The purpose of the Personnel Activity Report is twofold: (1) to serve as an adjustment for prior months' estimated time distributions; and (2) to provide new time estimates for the next reporting period. The Personnel Activity Report form will include the time period reported, the position number reported and the name of the employee currently holding that position. The employee will record on the form his or her actual attendance and time spent n each cost objective for each day. At the end of each week, the employee's supervisor with first-hand knowledge of that employee's work will initial the form to indicate his or her review and approval. At the end of the month, the employee will sign the form to certify it is an accurate representation of the employee's time distribution.

6) The Personnel Activity Reports will be supported by a position description of the staff member's responsibilities. The position description will specify the relevant program for each listed cost objective and the percentage of time to be devoted to each cost objective. Position descriptions will not break out percentages for individual activities within one grant objective. Annual employee evaluations will be performed in order to ensure that the activities anticipated to be carried out pursuant to the position description are carried out in an effective manner.

7) The supervisor will refer the Reports to the Deputy Commissioner or his or her designee who will be primarily responsible for determining whether or not the employee's reported time and effort deviated from the salary paid. The Deputy Commissioners' staff will ensure that the Report is used to make the required adjustments. The signed Personnel Activity Report will be kept by the Deputy commissioner or his or her designee for the official file. The employee and appropriate supervisor will maintain copies. The system will ensure that employees are properly paid based on their time and effort reports and that adjustments will be made if the payroll allocation is not consistent with the results of the Personnel Activity Report analysis. FDOE will generate a Summary of Position Funding which demonstrates the fund source and amount for each employee position for this purpose.

8) If an employee is on leave during an insignificant portion of a Personnel Activity Report month, the reported portion will be used as the basis for that employee's time distribution for the full month. If an employee is on leave for a significant portion of the month (more than two weeks), or the entire month, the most recently available reported month will be used as the basis for the employee's time and effort distribution. If the employee's responsibilities have changed significantly since the last reported month, the employee will complete a Personnel Activity Report for the month following his or her return.

9) The Personnel Activity Report will indicate the time that the supervisors spend exclusively on supervisory functions, which will be allocated based on the time allocations in the Personnel Activity Reports of the supervised employees. Time and effort allocation for supervisors will be based on actual time and effort of their activities to the extent they perform other than supervisory functions.

10) The Divisions that use a "team approach" to responsibilities will allocate time and effort for team employees based on a cost allocation method that is submitted to the U.S. Department of Education's Office of Chief Financial Officer (OCFO) by June 1, 1996, as long as the cost allocation system is not disapproved by the OCFO. This "team approach" affects employees in the Vocational Education Division who have responsibilities for each of the programs that division administers including each element of the Carl D. Perkins Vocational and Applied Technology Education Act, the Adult Education Act, section 123 of the Job Training Partnership Act, and State vocational education programs.

11) Time and effort allocation for clerical employees who provide support for personnel working on many grant objectives will be allocated based on the percentage of reported time and effort for the employees for whom they work.

12) The salaries of employees working in the Accounting, Personnel, Support Services and Data Center divisions will be allocated to appropriate grant objectives based on FDOE's approved indirect cost rate.

Any employee whose salary is accounted for in this manner and who works on only a single indirect cost activity will have a code entered into the system denoting his or her division in the FDOE, and will not be required to submit time and effort reports. Those employees, however, working on indirect cost activities with different allocation bases will be required to keep actual time distribution records.

13) FDOE will develop written policies and procedures for both supervisors and employees whose time and effort is recorded under this system. Prior to July 1, 1996, start date for this new system, FDOE will provide training to supervisors and employees regarding the proper use and importance of the time and effort system.

Dated: May 1, 1996