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Procedures for A-21 Certification

Time and Attendance Certification Report for Restricted Fund Personnel

 

As a recipient of federal funds the College must comply with the Office of Management and Budget Cost Principles for Educational Institutions (OMB-Circular A-21) which provides specific guidance for an institution’s documentation requirements for charging eligible salary and wage expenditures to federal award programs. The requirements in OMB-Circular A-21 state that where employees work on federal award program(s), charges for each respective employee’s salary and wages will be supported by periodic certifications stating that the respective employee worked on the federal award program(s) for the period covered by the certification. For those employees who work solely on a federal award program a "Time and Attendance Certification Report for Restricted Fund Personnel" form is to be prepared monthly. For those employees who work partially on a federal award program or on multiple federal award programs, a "Time and Attendance Certification Report for Restricted Fund Personnel" form must be prepared monthly. The "Time and Attendance Certification Report for Restricted Fund Personnel" form is designed to accurately reflect the actual time expended by each employee during a given pay period. For employees on monthly salary, the form should reflect the actual effort expended for the month. For employees on a bi-weekly or an hourly wage, the form should reflect the actual effort of the employee based on the related pay period.

When the form has been completed by the employee working on the federal grant program, it must be signed by that employee and responsible official having first-hand knowledge of work performed by the employee. Department secretaries do not qualify as responsible officials having first-hand knowledge of work performed. If the Project Director is signing the form as the employee performing the work, the form must also be signed by a College Officer/Dean/Director/ or Department Chair. If the form is being signed by another employee working on a federal grant award program and this employee is not the Project Director, then the form must also be signed by the Project Director. It is the responsibility of the Project Director to ensure that the level of effort is being met for all employees working on the project.

The Project Director will forward all signed certification forms and a copy of time sheets to General Accounting for the Attention of Fiscal Services Specialist. Although the Fiscal Services Specialist will report based on the certification, they should review certification for consistency with approved budget. If the form is consistent with approved budget, a copy of the signed form should be placed in the project folder in General Accounting. If there are concerns noted in General Accounting with regards to form, the Fiscal Services Specialist will notify the Project Director, who has the ultimate responsibility to ensure the level of effort is being met for all employees working on the federal grant program. The Director of Development will also be notified of concerns. The accuracy of information on the "Time and Attendance Certification Report for Restricted Fund Personnel" form is critical with respect to the College‘s compliance with OMB-Circular A-21.

The Office of Development will disseminate the "Time and Attendance Certification Report for Restricted Fund Personnel" form and procedures to all current/future employees working on federal grant programs. The Office of Development will provide Project Directors of federal grant programs with information on OMB–Circular A-21. During project orientation meetings conducted by the Director of Development, Project Directors of federal grant programs will be informed of their responsibilities with respect to Circular A-21 requirements.

Copies of the "Time And Attendance Certification Report For Restricted Fund Personnel" may be obtained from the office of Development located at the Joseph P. Cosand center, Room 619, 300 s. Broadway, St. Louis, MO 63102.