Do subrecipients need to keep separate cost centers (or coding) for ESG funds? Do timesheets need to be broken down by actual time worked and charged accordingly (rather than by percent)?

Date Published: December 2013

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Actual time must be charged to federal grants. The exact methodology for tracking the time that staff worked on federal grants and on components within a federal grant is at the discretion of the recipient. However, recipients and subrecipients must be able to justify and document the methodology used, and it must be reasonable and well-documented. The OMB Circulars do not require that recipients track actual time by ESG component, but there must be a methodology in place to estimate time allocated to components because of the statutory caps in place on the Street Outreach and Emergency Shelter components, and Administration activities. While actual time is preferred, any estimates must be a realistic reflection of actual time spent across ESG components.

Timesheets that capture actual time spent on specific programs are the most straightforward way to meet time reporting requirements. However, other approaches may be acceptable as long as they meet the guidelines established in Circular A-87 Appendix B(8)(H) for States or units of local government or Circular A-122 Appendix B(8)(m) for nonprofit organizations.

Tags: ESG Financial and Grants Management - Invoicing/processing payments