10d. Supplemental Documentation of Staff Activities
For financial monitoring purposes, documentation of the time spent and the activity performed is essential. If there is no record to support the staff time spent and its relationship to the approved grant activities, it is as though it did not happen and those staff costs cannot be paid with HUD funds.
All staff time charged to HUD must meet basic HUD program requirements and carry out a specific activity approved in the HUD contract. For instance, for costs to be ‘allowable’ expenditures, the time that staff spends delivering services to those clients – and only those clients – can be charged to the grant. This demonstrates that the costs are “allocable” costs.
Recording hours, however, is not sufficient in and of itself. An adequate time and activity system will have additional documentation that explains how the staff person spent the time on eligible clients and activities.
Following are two examples: use of Case Notes or an Activities Log:
- Case notes: MH Service Coordinators should keep case notes about the issues and topics that were addressed in their sessions with residents and have a justification for the frequency or infrequency of meetings.
- For instance, one client may have a steady job, be successfully managing their rent and other responsibilities, and have a stable coping strategy and family support. Such a client might require assistance only infrequently.
- Another resident may have more significant obstacles to housing stability or be going through a crisis. This client might require daily contact during the difficult period.
- Activities log: Other on-site staff, such as maintenance personnel, might keep a time log and file by housing unit. The log would document the time and activities spent on HUD-funded units and the file would contain forms like maintenance request forms and completed work orders, with completion dates and total hours expended in solving that unit’s particular issues.
- Documenting landlord outreach efforts: A key constraint in operating scattered-site housing programs, such as PRA, is identifying potential landlords, property management firms and individual units. State or sub-recipient entity staff (and/or contractors) will typically spend time researching and reaching out in developing leasing options. Similar to the MH Service Coordinators, outreach activities should be documented, including specific costs and hours, for inclusion in the Administrative Cost line item in the PRA budget.
Together these primary and supplemental documents are used to verify grantees’ and sub-recipients’ efforts to ensure that residents receive appropriate services as well as the work conducted on-site on behalf of eligible residents. This documentation is the foundation for the timesheet submitted and approved to charge time to HUD or other funding sources. This type of supporting documentation should also be available to respond to monitoring reviews or the test of transactions in an audit.