OMB Circular A-122: Is the Application to AmeriCorps Fact or Fiction?

Deep inside OMB Circular A-122 (from Attachment B, Section 8(m)(2)(a) lies a little piece of text that reads:

(a) The reports must reflect an after-the-fact determination of the actual activity of each employee. Budget estimates (i.e., estimates determined before the services are performed) do not qualify as support for charges to awards.

Depending on how you read this, you might walk away feeling that AmeriCorps member timesheets must never be submitted ahead of the last day of a given pay period.

After conducting research with an amazingly helpful Senior Grants Officer at CNCS, we’ve finally gotten to the bottom of the issue.  The details are below, and the punch line is in bold towards the bottom of this post.  The first bullet deals with what you should do if you live in “the ideal world”.  The second bullet is for those of us who live around the corner from that world.

  1. In the ideal world, AmeriCorps members would never submit timesheets before the last day of a pay period (CNCS likes to use the acronym PP for this, so we’ll run with it).A policy requiring only post-service submission will still permit the member to be paid her stipend on time because the stipend only requires that one hour of service occur during a stipend pay period.  If a given member didn’t serve at all during a PP, the supervisor needs to inform payroll not to issue a stipend for that period of time.  (This might become a tricky process if you’re with a large National Direct and payroll is run from your national office, but we don’t go down that path in this post.  Feel free to reach out to us if you’d like to run through the possible hiccups of that scenario as it relates to this policy.)(As a reminder, there is absolutely no negative impact if the timesheets or timecards for service are completed on the very last day of a payment period.)
  2. Now, if you don’t live in the ideal world, here’s the guidance we received from CNCS:It’s okay for members to submit sheets before the last day of a PP (hooray!), but if they do this, you’re signing up your site supervisors for a potentially-frustrating experience.
    • After the member finishes serving on the last day of a pay period, the supervisor needs to return to the sheet and certify that the hours are correct.  So, if you accept timesheets early, you may be setting yourself up to prove that supervisors looked at the sheets twice.To quote the guidance we received from CNCS on this: “Naturally the grantee should be making sure supervisors follow this policy [of checking the sheets twice], and one would expect to find some evidence of correction cards with more frequency than under a policy where the card is submitted after the close of the PP.”In other words, supervisors really shouldn’t sign sheets before a member stops serving on the last day of a PP.   If supervisors do sign sheets early, they must return to the sheet after the PP ends and do another lookover (with another signature).   AND….as compared to sheets that are submitted after the close of a PP, the Corporation expects there to be more corrections on sheets that are submitted early.  So in an extreme auditing example, you might get the question, “It looks like members submitted sheets early throughout the program year, but there aren’t many corrections on them.  How can that be?”

There Must Be A Better Way.
”There must be a better way.”  That’s what we started saying when we first learned of A-122.  As of this summer, there is a better way.  We recently created and rolled out a feature that makes it easy to live in a non-ideal world while also making sure that supervisors are treated humanely and are never put in a position where they’d need to review a sheet more than once.