10c. After-the-Fact Time and Activity Reporting
Accurate documentation of personnel costs is a key requirement that can be challenging. In order to comply with financial management requirements, grantees and sub-recipients should be able to document all staff time that is paid from the HUD grant. To document the division of costs between funding sources, staff is expected to record actual time spent on each HUD grant or non-HUD activity to provide the basis for how much of his or her salary (and related fringe benefit costs) will be allocated to the various funding sources.
According to OMB, time and activity records must be prepared at least monthly; but keeping records on a daily or weekly basis is much more practical and efficient. The recording may take place after the fact. Because it is difficult to reconstruct the time spent on activities with any degree of accuracy many days after the fact, it should occur as soon as possible, preferably the same day or first thing the next.
Optimally, the timekeeping procedures an organization implements require effective supervision by managers to ensure on a regular basis that employees are keeping records accurately. The most important tool in adequately documenting time is an adequate time and activity reporting system. This system must allow employees to log the time spent on different clients, activities, and grants, and provide a mechanism for employees to report all the time they spent working throughout that day. Grantees should assure that sub-recipients have such systems in place prior to subcontracting.