Substitute System of Time and Effort Reporting
The federal time-and-effort reporting requirement comes from the US Department of Education’s (USDE's) Education Department General Administrative Regulations (EDGAR). EDGAR requires employees who work on multiple activities or cost objectives to document their time and effort in one of two ways:
- By meeting the characteristics in 2 CFR 200.430(i) or
- Through an approved "substitute system."
Completing, submitting, and maintaining monthly documentation can be cumbersome for employees and local educational agencies (LEAs). To reduce that burden, the USDE has approved a substitute system. Under the substitute system, employees may submit semiannual certifications instead of monthly PARs.
LEA Requirement: Management Certification
USDE requires you to submit a management certification form to TEA before your employees may participate in the substitute system.
You must submit a new management certification form for each school year. Even if you submitted a management certification form for a prior school year, you must submit a new form for this school year.
You may submit the management certification form throughout the year. The management certification form is only required to be submitted once per school year, regardless of when it is submitted. The time of submission determines when in the school year you may use the substitute system:
- Submit by September 15 to use the system in the fall, spring, and summer semesters of that school year.
- Submit by December 15 to use the system in the spring and summer semesters of that school year.
- Submit by May 15 to use the system in the summer semester of that school year.
Submit your signed, completed management certification to TEA by email (to firstname.lastname@example.org), fax (to 512-463-9176), or mail at the following address:
Texas Education Agency
Department of Contracts, Grants and Financial Administration
1701 North Congress Avenue
Austin, TX 78701
Employees must meet eligibility requirements and must complete and submit an employee schedule and certification.
An employee must meet all the following conditions to participate in the substitute system:
- The employee’s schedule must include multiple activities or cost objectives.
- The employee must work on a set schedule.
- The employee may not work on multiple activities or cost objectives at the exact same time.
Employee Schedule and Certification
USDE requires participating employees to complete an employee schedule and certification form. This form was developed by TEA. It includes all elements that TEA auditors will check. Refer to this sample schedule and certification to see how the form should be completed.
You may use the TEA form, or you may develop your own. If you develop your own form, ensure it includes all required elements. All your employees must use the same form.
You keep a copy of each participating employee’s schedule and certification; you do not submit these documents to TEA.
The employee schedule and certification are completed after the fact, to document time the employee has actually worked.
Your participating employees must complete the schedule and certification, if not waived by Ed-Flex, at least every six months.
To meet the requirement that the certification coincide with one or more pay periods, the certification must be signed immediately after the last pay period of the time span being certified (that is, the last pay period of the school semester or six-month period).
An employee must complete a new schedule and certification if his or her schedule changes by more than 10 percent.
List of Approved LEAs
Once LEAs begin submitting management certification forms, the list of approved LEAs will be linked below. Allow two weeks from the time you submit your form for your LEA to appear on this list. If your LEA is still not listed, email the department at email@example.com.
2019-2020 School Year List of Approved LEAs, sorted alphabetically by LEA
2018-2019 School Year List of Approved LEAs, sorted alphabetically by LEA
2017-2018 School Year List of Approved LEAs, sorted alphabetically by LEA
Single or Multiple Cost Objectives
The substitute system is for employees who work on more than one federal grant award. Those employees are said to be supported by multiple cost objectives.
Sometimes employees who work on a single federal grant award are paid out of multiple fund sources. As long as the employee can legitimately be paid out of a single fund source, he or she is supported by a single cost objective. Unless waived by Ed-Flex, those employees should always submit semiannual certifications.
Refer to this substitute system FAQ for answers to common questions.