Office of Origin: Finance
Responsibility: Chief Financial Officer
Original Date Adopted: 4-15-25
Dates Reviewed: 4-15-25
Last Date Board Approved: 4-15-25

This policy requires accurate tracking and reporting of time and effort (T&E) for employees of Lake Michigan College (College) working on federally funded grants. It applies to all employees whose work is funded by federal grants and is designed to comply with federal regulations (see appendices for more information).

Responsibilities

Employees must:

• Use the approved T&E report template provided by the college.
• Accurately complete T&E reports on a biweekly basis and submit to supervisor.
• Maintain supporting documentation of hours worked and tasks completed related to grant projects.

Supervisors must:

• Review and approve submitted T&E reports for accuracy and completeness within 7 calendar days of end of biweekly pay period and submit to Finance.

Compliance and Consequences:

Non-compliance with this policy may result in disciplinary action, which may include, but is not limited to, retraining, reprimand, or other measures. It is essential that all reports are truthful and reflect actual work performed.

Training and Support:

All employees involved in federally funded projects will receive training on T&E reporting procedures.

References: Appendix A
Appendix B
Grants & Grant Manager Responsibilities policy

Appendix A: 2 CFR Part 200 Requirements for T&E Reporting

Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200) establishes the standards for managing federal awards, including specific requirements for T&E reporting.

Key Provisions

• Accurate Documentation: Recipients must maintain accurate records of time worked by employees on federally funded projects, including hours worked and the nature of the work performed.
• Standards for T&E Reporting: Documentation must demonstrate appropriate allocation of time between federally and non-federally funded activities. T&E reports should be consistent with an organization’s accounting practices.
• Types of Reporting:

1. Personnel Activity Reports (PARs): Recommended to reflect the distribution of time spent on various activities. (These are what the College calls T&E Reports.)
2. Reports should be prepared at least monthly and reviewed and approved by a supervisor or designated official. (The College elects to have these completed biweekly, on a payroll pay period basis.)
3. Reports must include signatures of both the employee and the supervising official to confirm accuracy.

• Retention of Records: Recipients must retain T&E documentation for at least 3 years after the final expenditure report is submitted.
• Auditing and Compliance: Federal awards are subject to audit; auditors will review T&E reporting to ensure compliance.

Appendix B: OMB Circular A-21 Requirements for T&E Reporting

Office of Management & Budget Circular A-21: Cost Principles for Educational Institutions (OMB Circular A-21) establishes principles for determining allowable costs for federal awards to educational institutions, including requirements related to T&E reporting.

Key Provisions:

• Allowable Costs: Salaries and wages are allowable costs to the extent that they are reasonable and allocable to the project.
• Documentation Requirements: Institutions must maintain adequate documentation to support costs charged to federal awards, including personnel costs.
• Allocation of Salaries: Costs of salaries and wages must be allocated to federal awards based on the actual work performed.
• Time Distribution: Personnel costs can only be charged to federal awards if based on the actual distribution of time worked.
• Periodic Certifications: Institutions should have a method to regularly certify the accuracy of time worked on federal projects.