Q: How do you differentiate direct time for an Executive Director from indirect time?
A: The Executive Director can track direct and indirect time on a Personal Activity Report. Direct time in specific cost objectives can be listed separately under each of those, and then indirect time can be an additional category.
Q: Our State is under the belief that Executive Directors should track their time by Cost Fund rather than be indirect – they believe this is driven by the federal guidelines. Your interpretation?
A: The State can add on requirements as the DSE overseeing the Part B subcontractees, and may have the same oversight with Part C recipients, so if they require this differentiation, you will need to comply. Our read, though, is that the Uniform Guidance encourages calling the Executive Director’s time indirect, along with the time of other staff that provide benefit to all of your cost objectives. While this will give you a higher indirect rate, it also greatly simplifies record keeping for those individuals.
Q: Our state requires the PAR for staff be broken down by each activity (i.e. outreach, core service) and this all activities must match the time sheet. What do you suggest for this type of documentation?
A: Again, the state has the right to add on requirements, so you will likely have to comply. We would advocate, though, that it is not required that the PAR contain that level of detail regarding how time is spent. The requirement is simply to record which cost objective you were working for, not precisely what you were doing. That more complete record is usually kept in the consumer service record or the database where you describe services provided, not in the PAR.
Q: When more than one program benefits equally by the work done, and it is not possible to separate it by time, how do you allocate the PAR (i.e. staff training).
A: Some CILs have a column for staff development, since the regulations require a staff development plan, so this can be seen as a separate cost objective. Others record this time in the indirect column. Either is acceptable.
Q: Do PARs need to be signed? Do these have to be printed, signed and filed or can electronic signatures be used?
A: The requirement for signatures in federal law is that either the employee or a supervisor with personal knowledge of the time must sign. Some CILs require both, but that is not necessary. Electronic signatures can be used if they are properly protected i.e. no one else can sign your document electronically. When in doubt, keep the hard copy with an ink signature.
Q: As the director I have a very difficult time getting a board member (even board chair) to sign PARs as well. All other staff have both signatures, but as ED I do not. Is this okay? We had a consultant recommendation to have this board signature but I don’t know if we need it.
A: Again the requirement is that the individual OR a supervisor with personal knowledge of the work schedule sign. It is doubtful your board chair has personal knowledge of your schedule. Your policies can reflect that only one signature is required.
Q: We are still a little fuzzy on PARs vs. time sheets. Should “indirect” staff also keep log notes along with their time sheets?
A: A PAR allocates an individual’s time across cost objectives. A time sheet records time for payroll. Some organizations blend the two documents to reduce paperwork, but they don’t have to be one document, and can be separated if the organization wishes to do that.
Q: Do you interpret guidelines for PARs to mandate that staff charged to grants type up notes to cover their “general/admin” time? Our state wants to see log notes that cover every minute of the day, which means that staff write log notes to cover bathroom time etc. They do this by totaling Direct Service time for their day. Any leftover work hours are entered under a “general activity” note. Is this really necessary for compliance? Can the state require this of us?
A: This is not necessary for compliance, but the state can require it of you.
For more information from this workshop, go to the page for the workshop. As they are available, the captioned videos, PowerPoint Presentations and transcripts will be posted there. The sample financial policies and procedures are already available.