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 Survey Form

TEA has developed a new, streamlined form process for LEAs to submit management certification forms for approval. LEAs now follow this link to access and complete the certification form

LEAs must submit a new management certification form to TEA and may do so throughout the year, in accordance with the following submission requirements:

  • If a management certification form is submitted by or before December 1st, approval will be retroactive to July 1st of the same year. Approval will remain in effect for 2 years, to June 30th.
  • If a management certification form is submitted after December 1st, approval will be effective on the date of submission, and will remain in effect for 2 years.

A new request for approval will be required on or before the expiration date, to avoid a lapse in approval.

A list of approved LEAs will be posted, updated, and maintained in the List of Approved LEAs section below to include approval expiration date.

Please allow up to 5 business days from the date of submission for LEA approval to be completed and appear on this list.

List of Approved LEAs

Once LEAs begin submitting management certification forms, the list of approved LEAs will be linked below. If your LEA is still not listed, email the department at grantsupport@tea.texas.gov.

List of LEAs approved for school year, sorted alphabetically by LEA name:

Employee Requirements 

Employees must meet eligibility requirements and must complete and submit an employee schedule and certification.

Employee Eligibility  

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 (also in accessible PDF format). 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.

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.

Additional Information 

Refer to this substitute system FAQ for answers to common questions.