USBE: LEAs must adopt written, board‑approved time‑and‑effort policies and document staff qualifications

Jacob (Jake), a USBE special education fiscal monitor, told attendees that LEAs are required to have a written, board‑approved time‑and‑effort policy and that the policy must be publicly posted to the LEA website under Utah State Board of Education rule R277‑113.

Jake walked through 2 CFR §200.303 and its six requirements for time‑and‑effort systems: (1) be supported by a system of internal control providing reasonable assurance of accurate, allowable and properly allocated charges; (2) be incorporated into the LEA’s official records; (3) reasonably reflect total activity for which the employee is compensated; (4) encompass federally assisted and all other activities on an integrated basis; (5) comply with the LEA’s established accounting policies and practices; and (6) support distribution of salary/wages among activities when employees work on multiple awards or activities.

He used the Park City School District policy as a practical example of an effective LEA policy that describes when semiannual certifications are appropriate and when personnel activity reports (PARs) are required for staff with multiple cost objectives. Jake warned against copy‑pasting the federal regulation as an LEA policy and against referencing outdated OMB Circular A‑87.

“USBE rule R277‑113 requires LEAs to have a written board‑approved time and effort policy, and it must be publicly posted to your website,” Jake said. He encouraged LEAs to write a manual‑style policy describing step‑by‑step procedures, align the written policy with actual practice, review it regularly, and reach out to USBE staff for technical assistance.

Matthew Nye followed with a short summary of staff qualifications, noting monitors will check licenses, license areas and endorsements for educators and review paraeducator training and supervision documentation when paraeducators provide IDEA services.

Jake and the team left contact details for follow‑up assistance and said slide materials including example policies would be shared with attendees.