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IM/W-2 100% Time Reporting

Applicability of 100% Time Reporting in the IM and/or W-2 Functional Area

There are job functions at the local level that cross the lines of administration, contract and/or program management, and supervision. “Supervision” typically involves the oversight, training, program monitoring, and personnel functions related to line staff workers. If IM/W-2 supervisors also provide program management on a non-routine basis, it is likely that their work effort is representative of the direct worker effort distribution shown in the RMS statistics. Generally speaking, supervisory staff working in these capacities do not participate in RMS, but their time is allocated to benefiting programs based on RMS data.

When job functions relate more to contract or program administration/management, the RMS statistics may not reflect the same distribution to programs as the time spent by program/contract managers whose focus relates more to budgeting and contract management. Individuals in this category spend a significant amount of time on activities that do not relate to supervision of line staff and have very minimal client contact.

To the extent that supervision is a significant part of an individual’s job, there is no need for the supervisor to keep 100% time reporting records. If, however, program or contract management time diverges significantly from the RMS statistics, 100% time reporting is required to accurately allocate costs to the benefiting programs. The most common example of this divergent activity can be found in supervisors who devote part of their time to program or contract management. They may, for example, supervise line staff and also be required to procure and manage subcontracts, develop program budgets, and/or monitor department or division expenses on a regular and routine basis.

Brief Definitions of Administration, Management, and Supervision

Agency Administrator

In most agencies, the director/administrator is responsible for the entire agency and should be included in the AMSO cost pool and is not subject to 100% time reporting.
 

Administrator/Program Manager

Handles IM/W-2 functional area program planning, budget development, procurement, oversight of supervisory staff but not line staff, reporting to public boards and committees, contract management, etc., with no client contact.  Each program manager should keep 100% time reporting records so costs can be direct charged to the benefiting programs.

Supervisor/Manager

Performs some or all of the functions above or may have unique or additional duties such as contract management and monitoring that occupy a significant amount of time that does not notably coincide with the RMS distribution of allocable costs. Program management is a regular and routine part of the job function, with minimal client contact. Supervisors whose time is not in the same distribution as the RMS statistics are required to do 100% time reporting.
 

Supervisor

Responsible for training, assistance with policy interpretation and individual case applicability, monitoring of CARES caseload data, alerts, etc., facilitation of unit meetings and personnel and disciplinary functions related to line staff. Often involves high levels of client contact. IM/W-2 supervisors are not required to keep 100% time reporting records.

Instructions

1. If your county has a program manager that does not supervise line staff, 100% time reporting is required if the benefiting programs are not in proportion with the RMS statistics.
   
   
2. Determine if IM/W-2 supervisors provide program or contract administration/management functions on a regular and routine basis. If they do and the estimated distribution of their work effort does not correlate to the RMS statistics, these individuals are subject to 100% time reporting.
   
   
3. All counties who have supervisors required to keep 100% time reporting records in accordance with these guidelines must send an email to becky.craig@dwd.state.wi.us indicating the names of supervisory staff who will be doing 100% time reporting.
   
   
4. At the end of each month, a copy of all time records must be submitted to the following address:
   
   Becky Craig
   DWD Finance/Financial Policy, Monitoring & Review Section
   PO Box 7946
   Madison, WI 53707-7946
   
   
5. Failure to submit proper documentation may result in disallowed expenditures.

Requirements

1. The requirements of OMB Circular A-87 state that personnel activity reports for 100% time reporting must meet the following standards:
   
   • Time reports must reflect an after-the-fact determination of your actual activity,
   • Time reports must account for the total activity for which employees are compensated,
   • Time reports must be at least monthly and must coincide with one or more pay periods,
   • Time reports must be signed by the employee.
      
2. Time coded to supervision must be included in the IM/W-2 shared cost pool for distribution to the benefiting program.
   
   
3. Record vacation, other leave, holidays, sick time, and breaks/lunch to one category and allocate these costs to the benefiting programs and the IM/W-2 cost pool based on the proportion of the individual’s time charged to supervision and the various program categories.
   
   
4. For these staff that may also be doing administration functions for the entire agency, record this time as AMSO and report related costs the AMSO cost pool.
   
   
5. Time reporting information must be retained for audit purposes in accordance with state and federal regulations.
   
   
6. Agencies are expected to comply with OMB Circular A-87 and these guidelines. Agencies are encouraged to utilize their current effort reporting systems to implement the 100% time reporting for these specific individuals.
   
   
7. Counties can use their own coding numbers/accounting system as long as the 100% time reporting system accounts for all activity. It is extremely important that all activity is accounted for and that any programmatic activity is coded to the program level, not just to the contract level.

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