I am interested in how other universities receiving funding under this
program have responded to the statement copied below.  Even if you are
not receiving such funding, I am interested in how you would respond.
This appears to me to be an overly prescriptive requirement on how we
meet our time and effort reporting obligations.  I would think that our
descriptions of these processes in our Disclosure Statements and/or
absence of effort reporting findings in our A-133 audit reports would be
sufficient (so far, these approaches have not been successful).  Am I
wrong to think that what is sufficient for one federal agency should be
sufficient for other federal agencies?  This is a note from a regional
office, but it is said to have originated from a ruling at the national
level.  I appreciate any input you may offer publicly or in private.

Thank you.

Mike

Michael J. Warnock, Director
Office of Sponsored Program Administration
310 Jesse Hall
University of Missouri
Columbia, MO  65211
voice 573 882-4329
fax 573 884-4078
xxxxxx@missouri.edu

-----Original Message-----
From: xxxxxx@FNS.USDA.GOV [mailto:xxxxxx@FNS.USDA.GOV]
Sent: Tuesday, April 15, 2003 4:32 PM
To: xxxxxx@LISTSERV.UNL.EDU
Subject: FSNE Time and Effort

FILE:  FS 10-6-2 GEN
_______________________

 The Mountain Plains Regional Office has received further
confirmation from the FNS National Office re: what will be accepted for
documentation of time and effort. A Policy Memo was issued to all States
on October 23, 2002 entitled, Use of Plan Confirmation for Time
Accounting in the FSP Nutrition Education Program. This Policy Memo
stated that FNS will accept the use of Plan Confirmation for documenting
time and effort for those colleges and universities that have an
approval from the Division of Cost Allocation.  Colleges and
universities that do not have such an approval must utilize weekly time
sheets for all staff devoting less than 100% of their time to the food
stamp nutrition education project. Exceptions to this policy are those
sub-grantees who have Federally approved Random Moment Time Studies or
Federally approved Rolling Weekly Time Sheets. The use of After-the-Fact
Activity Records is not an acceptable method of time and effort
documentation.

 Currently, no states in the Mountain Plains Region have approved
Plan Confirmation methodology nor do any states have either of the
Federally approved exceptions as identified above.  Therefore, Mountain
Plains is requesting that all State food stamp nutrition education
projects comply with FNS Policy and implement weekly time sheets
beginning May 1, 2003. Please verify back to the Regional Office that
such action has taken place. If there are questions or comments, Colleen
Bray can be contacted at (303) 844-0347 or by e-mail at
xxxxxx@fns.usda.gov.  Thank you.

Colleen R. Bray
Food and Nutrition Service
1244 Speer Blvd
Denver, CO  80204-3585
(303) 844-0347

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