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According to the California School Accounting Manual ("CSAM"), "Documentation of salaries and wages is often necessary to support charges to specific funding sources (resources), instructional settings (goals), and activities (functions).

Also, the Code of Federal Regulations ("CFR") requires that documentation for personnel expenses charged directly or indirectly against federally-sponsored projects be supported by a system of internal controls which provide reasonable assurance that the charges are accurate, reasonable, necessary and allowable in accordance with applicable program requirements. 

References

CSAM Procedure 905 - Documenting Salaries and Wages
2 CFR Part 200.430(i)
Time Accounting Video

Scenario

An employee is split-coded between state special education funds in SACS resource 65400 and Federal IDEA funds in SACS 3310. The services provided, and the populations served, are eligible and allowable under both resources.

Question

Does this employee complete a semi-annual time sheet or a monthly personnel activity report? 

Review

Both 6500 and 3310 are special education resources: Resource 6500 can be used to provided IEP-based special education and related services to students in grades pre-K through 12. Resource 3310 can be used for the excess costs of providing special education and related services to students with disabilities in order to benefit from a public education, and in grades K through 12, ages 5 through 21. 

To understand the nuance of excess costs, the example of an iPad may help. If an agency purchased an iPad because the student's IPE required such a device, then the purchase may be an allowable expenditure for either resource 6500 or 3310. However, if an agency provided iPads to all students (both general education and special education), then the purchase would not be allowable for 3310 (as it is no longer an excess cost). 

Regarding time accounting, CSAM page 905-3 provides an example of homogenous funding sources such as a special education instructional aide who is funded by a mixture of federal and/or state awards, where the services provided and the populations served are eligible and allowable under any of the awards. CSAM includes a disclaimer, however. 

To summarize, the LEA will need to consider the benefits and risks of using either a semi-annual or a personnel activity report. If the LEA determines that a semi-annual is appropriate, the LEA should prepare for an audit question regarding the combination of both resources.