NGMA Connect

Week at a Glance

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Acknowleding Our CGMS Holders

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DOT Launches New ROUTES Initiative To Improve Rural Transportation

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Nominate Your Peers for the 2020 Annual Awards!

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Week at a Glance

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Last Chance to Participate in the Annual Grants Management Survey!

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Get Ahead With GMBoK Training

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A Week at a Glance

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Getting it Right – Federal Grant Time and Effort Reporting

Guest Post by NGMA's CAPP Partner Association Management 

Five years after full implementation of Code of Federal Regulations (CFR), Title 2: Grants and Agreements, Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, commonly referred to as Uniform Guidance (2 CFR § 200), time and effort reporting, or Compensation – personal services (2 CFR § 200.430) is still a compliance risk for non-Federal entities.

Many award recipients and subrecipients have personnel-heavy projects. During the public comment periods that preceded full implementation of the Uniform Guidance, respondent comments focused on the restrictive nature of time and effort reporting guidance in previous Office of Management and Budget (OMB) circulars.

In response, OMB and the Council on Financial Assistance Reform (COFAR), (which has since been replaced by the Chief Financial Officers (CFO) Council) built more flexibility into the new guidance. Unfortunately, this resulted in some confusion about what is now required and what will survive audit muster.

  • Future revisions of the Uniform Guidance should provide more clarity. In the meantime, there are some key takeaways that all non-Federal entities should address in their organizations. Federal and pass-through agencies can also use these points to monitor the time and effort reporting of their recipients and subrecipients effectively.   
Reporting Requirements
  • Compensation must be reasonable and in line with work on similar activities performed by the non-Federal entity; if no comparable activities exist at the non-Federal entity, compensation is considered reasonable if comparable to that paid for similar work in the applicable labor market
  • Compensation ceilings may apply for certain employees according to 10 U.S.C. 2324(e)(1)(P), and 41 U.S.C. 1127 and 4304(a)(16) or established statutory ceilings
  • Non-Federal entities must have written policies surrounding time and effort reporting that are consistently applied to both Federal and non-Federal activities
  • Non-Federal entity policies and procedures for matching funds must align with policies and procedures for Federal funds
  • Restrictions on professional activities outside of the non-Federal entity must follow 2 CFR § 200.430(c):
    • Time and effort must be aligned to a particular cost objective, and accurately charged; some flexibility is afforded to institutions of higher education (2 CFR § 200.430(i)(1)(x))
  • The actual percentage of employees’ time must be recorded and documented per funding source
    • Not by estimates or budgets
    • Total must not exceed 100%
    • Documentation must be maintained to support allocations
These key takeaways are not all-inclusive. While the grants community waits for revised OMB guidance, we encourage you to read 2 CFR § 200.430.

Best Practices
Your time and effort tracking and reporting system must be supported by a strong system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The following best practices may help your organization maintain compliance with enough flexibility to meet your performance goals and objectives.
  • Supervision – Responsibilities of personnel designated to supervise time and effort reporting should include:
    • Certifying that time and effort recorded is accurate and allowable and submitted in a timely fashion
    • Confirming proper alignment with cost objectives
    • Preventing resources from being exhausted prior to the end of the funding period
    • Ensuring certification does not take place before the end of the specified period
  • Internal Control – Incorporate policies and procedures that include methodologies and tools for measuring, documenting, and reporting time and effort expended on Federal awards
  • Communication – A robust, compliant system should include organizational charts delineating responsible personnel, as well as process flows and job aids to communicate the system effectively to staff, leadership, and auditors
Finally, no grants management system, including time and effort reporting, is complete without staff training. By guiding your staff through the haze of compliance, and providing complete information, your team will have more time to direct their energies to meet the mission, and you will have less stressful monitoring visits and audits.

In addition to her role as an instructor for Management Concepts, Mary Jean White is a consultant for public sector, non-profit, and commercial clients. She is a recognized Subject Matter Expert in grants, including Uniform Administrative Requirements (2 CFR § 200), program management, strategic planning as well as Federal, state, and local procurement and compliance, including the Federal Acquisition Regulation (FAR, 48 CFR 31.2). She holds a Bachelor of Urban Planning degree from Florida Atlantic University and is a Certified Grants Management Specialist through the National Grants Management Association.

Congratulations to the Newest CGMS Holders

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5 Reasons to Join Your Professional Grants Management Association – NGMA!

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Let's Get Engaged!




Today, it is so easy to “engage” our friends and family with so many social venues at our fingertips. It is just as IMPORTANT to stay connected and interact with your peers in the grants industry. The NGMA Network, our social community is an easy way to connect and “engage” with other grant professionals like yourself!  There are many different social community pages available to ask work-related questions, share your ideas as well as find mentors or “study buddies” to help you with obtaining your CGMS credential.

One of the main reasons to use the NGMA Network is to gain knowledge. Knowledge is POWER! Joining our social community could not only improve your professional development but someone else could benefit from you! It is a chance to surround yourself with the support you may need and create networks that can prove valuable to your success as a grant professional.

We all know that work can be hectic and present daily challenges but just take a moment and ENGAGE!  Visit NGMA Network because you may be presently surprised how helpful your peers can be...  And don’t forget to upload your profile picture because we all want to see that beautiful smile!


Bo Inscho, Member Engagement Manager


Join an NGMA Member Committee Today!

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