If my institution/agency decided to use ARRA funds for salaries, are employees required to fill out time and effort reports?
USDE guidance issued December 24,2009, (see link on THECB ARRA webpage) states that SFSFs (which include GSFs) can be used by IHEs to pay general expenditures, operating expenses, and E&G salaries without maintaining specific, separate time and effort distribution records that apply to individuals whose salaries are supported with SFSFs . The OMB Circulars that apply cost principals, such as OMB A-21 and A-87, do not fully apply to SFSFs. Expenditures must still be “reasonable and necessary”, and consistent with applicable state and local requirements. Entities must maintain documentation for SFSFs to support Time & Effort (T&E) in the same manner that supports similar duties for individuals paid with state or local funds. An individual paid salary with both SFSFs and state funds is not required to maintain records documenting the amount of time spent on SFSF activities because there are no specific “SFSF activities”. Recipients of SFSFs must maintain records that separately track and
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