Policies and Procedures Manual Version 1.1 Published September 11, 2013
Policies and Procedures Manual Version 1.1 Published September 11, 2013 GEAR UP Iowa Policy and Procedures Manual Overview Funded by a $16.8 million Federal grant, GEAR UP Iowa (Gaining Early Awareness and Readiness for Undergraduate Programs) is charged with significantly increasing the number of students who are prepared to enter and succeed in postsecondary education. The Iowa College Student Aid Commission administers GEAR UP Iowa in partnership with the Iowa Department of Education and other state agencies; local school districts; postsecondary educational institutions; and community organizations, businesses, and industries. Serving Students and their Families GEAR UP Iowa works to create a "college-going culture" through statewide and school-based services to a cohort of approximately 7,000 high school students and their families who began 7th grade in the fall of 2008 or 8th grade in the fall of 2009 in 18 communities across Iowa. Those communities are: Cedar Rapids Keokuk Clinton Lineville-Clio Columbus Junction Marshalltown Council Bluffs Ottumwa Davenport Perry Denison Sioux City Des Moines Storm Lake Diagonal Walnut Grand Junction Waterloo GEAR UP Iowa Policy and Procedures Manual Scholarship Opportunities Unique to the GEAR UP Iowa state grant is a $16.8 million scholarship fund for use toward postsecondary education that will be available to the entire cohort upon graduation from high school in 2014. GEAR UP Iowa offers further scholarship opportunities through our college partners and the Iowa Treasurer's Office to assist our students and families in financing their postsecondary education goals. Creating a "College-Going Culture" GEAR UP Iowa's three-pronged approach to the creation of a "college-going culture" in Iowa funds initiatives designed to strengthen academic achievement, increase academic aspirations, and raise college awareness. The program encourages young people to have high expectations, study hard, and pursue success in college. Services to GEAR UP Iowa schools, students, and their families include: Professional development opportunities for teachers, counselors, administrators, and school staff Supplemental academic offerings including after-school, weekend, and summer academic programs Academic mentoring and tutoring student, family, and community outreach programs College visits and tours for students and their families Job shadowing, career fairs, and internships scholarships, financial awards, and reduced tuition Financial literacy education for students and families Student, family, and community educational programs about the college search, application, and enrollment process College / career counseling, SAT / ACT preparation, and college application services through www.ihaveaplaiowa.gov GEAR UP Iowa Policy and Procedures Manual The success of GEAR UP Iowa relies on a partnered network of community and government organizations, high schools, colleges, universities, individual community members, and families who believe that "with the right approach, postsecondary education is possible for all Iowans." For more information regarding GEAR UP Iowa, please contact: John Gilman Project Coordinator 515-725-3440 [email protected] Chol Chagai Training Specialist 515-657-3773 [email protected] Erma Mujic Training Specialist 515-883-0313 [email protected] Cara Graziano Training Specialist 515-577-3049 [email protected] Timothy Henriksen Training Specialist 515-577-5738 [email protected] Nancy Ankeny Education Consultant 515-725-0436 [email protected] GEAR UP Iowa Policy and Procedures Manual GEAR UP Iowa Goals and Objectives: Goal 1.0: STUDENT ACHIEVEMENT: Significantly increase the number of minority and low incomes students in GEAR UP partner schools who graduate from high school prepared to enter and succeed in postsecondary education. Goal 1 Objectives 1.1 Increase the number of students in GEAR UP partner middle and high schools who identify postsecondary education as a goal. (Goal is to increase by 10% each year to reach a target goal of 90% by the twelfth grade) 1.2 Ninety percent of GEAR UP students will earn sufficient credits to advance to the next grade level each year and remain on track for graduation. 1.3 Increase the number of students who successfully complete Algebra I. 1.4 GEAR UP students will demonstrate knowledge of high school graduation and college admittance requirements as demonstrated by course selection and graduation plans. 1.5 STUDENT ENGAGEMENT. Increase GEAR UP student engagement as measured by increased attendance and decreased discipline referrals. 1.6 The number of Advanced Placement and/or dual credit courses completed by GEAR UP students will increase by 10% each year in year V and VI. Goal 2.0: Redesign Middle and High School Programs: Support GEAR UP partner middle and high schools in redesigning educational programs to ensure low-income and minority students master a rigorous college-preparation curriculum and graduate from high school. Goal 2 Objectives 2.1 EARLY IDENTIFICATION AND INTERVENTION. Establish a school-wide system for early identification and intervention for at-risk, struggling and special education students as measured by the reduction of the number of D’s and F’s in each semester. 2.2 Implement the Iowa Core Curriculum to increase the rigor and relevance of the high school program as measured by course syllabi and master schedules. 2.3 EXTENDED LEARNING OPPORTUNITIES. Increase extended learning for students in order for them to master a rigorous curriculum. GEAR UP Iowa Policy and Procedures Manual 2.4 PERSONALIZATION STRATEGIES. Increase the personalization of the school learning environment and instructional practices, and increase flexibility in providing rigorous and relevant learning experiences. 2.5 PROFESSIONAL DEVELOPMENT Based on the needs identified by the staff and data at each partner school, facilitate professional development in areas of: Instructional Strategies for improving learning for all students, Differentiation and Universal Design, Assessment, Social-Emotional-Affective/Learning Supports, Data Analysis and other. Goal 3.0: Student and Family Support: Foster a statewide “college going culture” among low-income, minority, and first-generation college-attending students and families to increase their knowledge of post-secondary options, preparation, and financing. Goal 3 Objectives: 3.1 FINANCIAL LITERACY AND PLANNING. Increase the level of outreach services to low-income students and families for financial literacy, financial planning, and securing financial aid. 3.2 Collaborate with schools and partner agencies to develop strategies to increase parent/family involvement in their child’s education and support their goals for higher education. 3.3 Ensure that 100 percent of the students in the grant cohort receive information about the academic preparation needed in middle school and high school to be prepared for college, and to understand the real costs of college and the availability of financial aid. GEAR UP Iowa Policy and Procedures Manual Introduction The federal government provides billions of dollars in grants to over 30,000 organizations annually. This investment of taxpayer dollars means that the federal government must set up strong controls over grant projects to ensure the proper use of public funds. It can be complicated and does take time to learn. Your knowledge will grow with experience and training. There may also be experts in your school district to help you. When Congress created the GEAR UP program, they wanted to create partnerships that would sustain themselves. The result is the dollar-for-dollar match requirement. The total project cost is shared between federal and non-federal sources. GEAR UP programs need to collect and accurately document in-kind contributions of goods and services. Such match helps ensure that local partnerships are created and that GEAR UP grant resources are being directed to communities. Regulations The federal policies that govern GEAR UP are diverse and sometimes confusing. You may find inconsistencies that come from government and agency policies trying to accommodate many unique grant programs. In GEAR UP, you are subject to a number of regulatory sources. When you come across conflicts or inconsistencies between the sources, generally you should begin with the GEAR UP statute, and then move down the hierarchy for answers. The following list provides a brief description of each of the major policy sources. Statute. A statute is the federal law that authorizes or governs a program. In the case of GEAR UP, the term statute refers to the program legislation found in Title IV of the 1998 Amendments to the Higher Education Act (HEA) of 1965 [P.L. 105-244]. The statute sits at the top of the hierarchy but affords the Secretary of Education the authority to set program-specific policies, which are commonly known as “program regulations.” The statute only broadly defines how the program should operate. Program Regulations. Program regulations provide additional guidance when the statute is silent or vague on an issue. They provide details that govern the application competition, dictate how programs will be implemented, and other administrative details. There are two types of regulations that you should become familiar with: EDGAR, OMB Circulars, and GEAR UP program regulations. EDGAR. The Education Department General Administrative Regulations (EDGAR) set broad administrative policies that impact nearly all grant programs funded at the USDOE. The regulations are published in Title 34 of the Code of Federal Regulations (CFR). The pertinent sections of EDGAR to your grant administration are 34 CFR parts 74, 75, 77, 79, 80, 81, 82, 84, 85, 86, 97, 98, and 99. http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html GEAR UP program regulations. Whereas EDGAR sets broad agency-wide policies, the GEAR UP program regulations address the very unique administrative matters associated with GEAR UP. GEAR UP program GEAR UP Iowa Policy and Procedures Manual regulations are published in 34 CFR parts 694. http://www.ed.gov/policy/highered/leg/hea98/sec403.html OMB Circulars The circulars are developed by the Office of Management and Budget (OMB) and provide 26 federal agencies with instructions and guidance on a wide variety of administrative issues of interest to the executive branch. As guidance documents, they tend to be revised every few years. The OMB Circulars will affect your day-to-day decision-making because EDGAR cites specific OMB Circulars as regulation. Thus, much of the discussions in the grant administration world will revolve around the circulars, as they define cost principles, administrative requirements, and audits. Common circulars are organized by their purpose and audience, and are addressed by their circular number (e.g. OMB A-21). Cost Principles A-21, Educational Institutions. A-87, State, Local Governments and Indian Tribe Governments (Includes School Districts). A-122, Non-Profit Organizations. Administrative Requirements A-102, State and Local Governments. A-110, Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations. Audit Requirements A-133, States, Local Governments, and Non-Profit Organizations. Additional Resources: OMB Circulars can be found at: www.whitehouse.gov/omb/circulars/ In addition to understanding federal requirements, you are expected to follow the policies of the fiscal agent of the grant—the Iowa College Student Aid Commission. As an agency of the State of Iowa, the commission has additional policies it must follow to comply with state and federal law. It is important to rely on GEAR UP Iowa staff when the federal regulations aren’t clear on an issue. You also must follow GEAR UP Iowa reporting guidelines and budget categories. Time and Effort Develop a process for collecting time and effort sheets regularly and accurately. Federal regulations require that every GEAR UP staff whose salary is supported in full or in part need to document the time, effort and activities during any given pay period. When you use in-kind personnel contributions as match, they have to fulfill the same reporting obligations as if they were receiving federal funds. Allowable Costs Sound fiscal GEAR UP administration begins with understanding what types of expenses can be paid for with federal funds. Allowable costs are those expenses that are specifically permitted (or not explicitly prohibited) by the laws, regulations, principles and standards issued by the GEAR UP Iowa Policy and Procedures Manual USDOE and other authoritative sources. To help you decide if costs are allowable or not, ask these questions: Is the expense: Allowable and necessary to implement the program. Reasonable. Allocable to program objectives. Compliant with the program’s federal administrative regulations. Supplement but not Supplant GEAR UP regulations require that GEAR UP funds supplement-not-supplant. GEAR UP funds are intended to build the capacity of school districts to create a college going culture. Therefore, GEAR UP funding may be used to enhance what is already in place or to create new activities. GEAR UP funds cannot be used to replace other federal, state, or local funding. Below are some examples: For the last five years, your school has paid for a career exploration software license. This year, the school needs new PE equipment so you have been asked to pay for the software license with GEAR UP funds to free up funding for PE equipment. This is supplanting - and is not allowed. For the last several years, your school has annually purchased $500 of new library books. This year you have been asked to use GEAR UP funds to pay for the books. This is supplanting - and is not allowed. For the last two years, your school has been unable to purchase any curriculum enhancement materials for math classes, including an essential software package, because of budget cuts. You have been asked to purchase this software with GEAR UP funds this year. This is not supplanting - and is allowed - because without GEAR UP funding, your school would not be able to make this purchase. GEAR UP Iowa Policy and Procedures Manual The GEAR UP Iowa Model GEAR UP funds may be used to pay for activities that support the GEAR UP Iowa Goals and Objectives, as outlined in each school’s approved GEAR UP Iowa Implementation Plan and its included statement of assurances from individual school district and building officials. When planning for activities and expenditures, schools must follow the guidelines below: Funds may be used to support activities for all students in the GEAR UP Iowa Cohort Class of 2014. If you opt to include additional students in any GEAR UP sponsored activities, costs should be covered proportionately from other funds. Common GEAR UP Costs (Sources: GEAR UP Statute, EDGAR, OMB Circular A-21, OMB Circular A-87) The following list may help you determine whether your program expenses are allowable or not. It includes costs that are commonly incurred in GEAR UP, or are the subject of frequent questions or discussions about their permissibility. Advertising and public relations costs: Generally unallowable The OMB cost principles define advertising costs as the expenses associated with the costs of advertising media (magazines, newspapers, radio and television, direct mail, exhibits, electronic or computer communication) and associated administrative costs. For GEAR UP, reasonable advertising costs are allowable when: 1. Recruiting and advertising for vacant GEAR UP staff positions in a manner that is acceptable and standard for the hiring entity. The term public relations is defined as activities dedicated to maintaining the image of the institution/governmental agency or maintaining or promoting understanding and favorable relations with the community or public at large or any segment of the public. For GEAR UP, public relations costs are potentially allowable when: 1. The activity is part of your approved application. 2. You are communicating with the public and press pertaining to specific activities or accomplishments which result from your grant performance (these costs are considered necessary as part of the outreach effort for the sponsored agreement). 3. You are conducting general liaison with news media and government public relations officers, to the extent that such activities are limited to communication and liaison necessary to keep the public informed on matters of public concern. Advisory Councils: allowable Costs incurred by advisory councils or committees are allowable as a direct cost when authorized by the awarding agency, or as an indirect cost where allocable to the GEAR UP award. Alcoholic beverages: unallowable GEAR UP Iowa Policy and Procedures Manual Commencement and convocation costs: unallowable For education institutions, costs associated with commencement and convocations are disallowed, but costs associated with GEAR UP activities that take place during commencement events may be allowable under student activity costs if approved as part of a GEAR UP Iowa Implementation Plan. Communication costs: allowable Costs incurred for telephone services, local and long distance telephone calls, telegrams, postage, messenger, electronic or computer transmittal services and the like are allowable. However, you will need to check if these expenses are captured in your indirect costs. Compensation (Salaries, Wages & Fringe Benefits): allowable Personnel costs such as salaries, wages and fringe benefits are allowable to the extent that the total compensation to individual employees conforms to the established policies of the institution, consistently applied, and provided that the charges for work performed directly on sponsored agreements. Fringe benefits costs should be in line with institutional policies regarding: annual leave, sick leave, military leave, and employer contributions or expenses for social security, employee insurance, workmen's compensation insurance, and tuition or remission of tuition for individual employees. Consultants & Contracts: allowable EDGAR states that costs associated with consultants are allowable if there is a need in the project for the services and the grantee cannot meet that need by using an employee rather than a consultant. Providing donations and contributions: unallowable Contributions or donations (including cash, property, and services) are unallowable costs. Entertainment costs: unallowable Costs of entertainment, including amusement, diversion, and social activities and any costs directly associated with such activities (such as tickets to shows or sports events, recreational activities such as swimming, meals, lodging, rentals, transportation, and gratuities) are unallowable. Be sure to distinguish these unallowable expenses from similarly worded and allowable student activities, meetings and conferences that are approved as part of an Implementation Plan. Equipment: allowable Equipment means an article of nonexpendable, tangible personal property having a useful life of more than one year and for GEAR UP accounting purposes, has a per-unit cost equal to or greater than $5000. The title (documented ownership) of the equipment vests in the grantee or school district and may be used for other projects as long as that use does not interfere with the terms describing justification of the expense in an approved GEAR UP Iowa Implementation Plan. GEAR UP Iowa Policy and Procedures Manual Fines and penalties: unallowable, with exceptions Costs resulting from violations or failure of the fiscal agent to comply with, federal, state, and local or foreign laws and regulations are unallowable, except when incurred as a result of compliance with specific provisions of the sponsored agreement, or instructions in writing from the authorized official of the sponsoring agency authorizing in advance of such payments. Late fees, including late fees for registrations, and interest charges on credit cards are unallowable. Student fines are also unallowable. Fund raising: unallowable Organized fund raising is not allowed. Goods or services for personal use: unallowable Costs of goods or services for personal use of the governmental unit's employees are unallowable regardless of whether the cost is reported as taxable income to the employees. Lobbying: generally unallowable, with exceptions Federal funds cannot be used to: Influence the outcome of referendum, initiative, or similar procedure, through in-kind or cash contributions, endorsements, publicity, or similar activity. Support a political party, campaign, political action committee. Influence the introduction, enactment or modification of state or federal legislation through direct or grassroots lobbying. However there are a few exceptions, including: Technical and factual presentations on topics directly related to the performance of a grant, contract, or other agreement. Efforts to influence state legislation in order to directly reduce the cost, or to avoid material impairment of the institution's authority to perform the grant, contract, or other agreement. Any activity specifically authorized by statute to be undertaken with funds from the grant, contract, or other agreement. Memberships, subscriptions and professional activity costs: allowable, with exceptions Costs associated with memberships in business, technical, and professional organizations are allowable. In addition, subscriptions to business, professional, and technical periodicals are allowable. Please note that the circulars make the following exceptions: State entities can use federal funds for membership in civic, community, and social organizations which are allowable as a direct cost with the approval of the USDOE. State entities cannot use federal funds for membership in organizations substantially engaged in lobbying. Meetings and Conferences: allowable Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental of facilities, speakers' fees, and other items incidental to such meetings or conferences. Be aware of restrictions pertaining to entertainment costs. GEAR UP Iowa Policy and Procedures Manual Publications and printing: allowable Publication costs—including the costs of printing, distribution, promotion, mailing, and general handling—are allowable federal costs if they are allocable to project objectives. If not, any publications or printing should be paid for by institutional or indirect funds. Rental cost of buildings and equipment: allowable With stipulations, rental costs are allowable to the extent that the rates are reasonable in light of such factors as: (1) rental costs of comparable property, if any; (2) market conditions in the area; (3) alternatives available; and, (4) the type, life expectancy, condition, and value of the property leased. Rental arrangements should be reviewed periodically to determine if circumstances have changed and other options are available. Severance pay: allowable Costs of severance pay, for personnel whose services have been terminated are allowable only to the extent that such payments are required by law, by employer-employee agreement, by established policy that constitutes in effect an implied agreement on the institution's part, or by circumstances of the particular employment. Student activity costs: generally unallowable, with exceptions Costs incurred for intramural activities, student publications, student clubs, and other student activities, are unallowable. Supplies: allowable Costs incurred for supplies to carry out the grant are allowable. Supplies have a per-unit cost of less than $5,000. Travel costs: allowable Travel costs are the expenses for transportation, lodging, subsistence, and related items incurred by employees who are in travel status on official business of the institution. Travel outside of the United States requires prior approval. Travel costs also may be incurred in relation to local events for students, parents or professionals participating in programs authorized by the GEAR UP statute. Travel costs are only allowable if they abide by published Sate of Iowa and / or school district travel policies and procedures. NOTE: Just because a cost is interpreted as being allowable under the OMB cost principles, it is not guaranteed that you will be able to make that expenditure. The GEAR UP Iowa Project Coordinator in consultation with the Project Director and the Iowa College Student Aid Commission CFO will make final determination of whether or not an allowable cost is acceptable. This may happen when, for example, a cost identified as allowable under the circular may be disallowed in program regulations or statute, or fail to pass the USDOE’s judgment that it is justified, allowable, or reasonable. GEAR UP Iowa Policy and Procedures Manual Allowable Incentives Description Clothing items w/ GEAR UP or college message. Any printing/setup charges must be included. Pencils/Pens Magnets Stickers Flash Drives Amount Up to $20 each – SEE NOTES BELOW Up to $1 each Up to $2 each Up to $.50 each Up to $10 each Purpose Students, staff, chaperones to wear on field trips, school events, special programs, community service and other events to promote GEAR UP, teamwork, and safety (on field trips) Student reward or incentive Student reward or incentive Student reward or incentive Student reward or incentive NOTES: 1. The reward/incentive budget shall be no more than 2% of an individual school’s allocated GEAR UP Iowa funding each program year (July 1 – June 30). 2. iTunes or similar items are considered entertainment and are not an allowable expenditure. Allowable Food and Beverage Expenses Food and beverages may be offered to participants only in conjunction with GEAR UP Iowa training, workshops, and structured activities where the participants are receiving GEAR UP Iowa information. GEAR UP Iowa funds CAN NOT be used to purchase food for students attending events on their middle or high school campus during the school day if regular school breakfast and/or lunch meals are being served. Use the following guidelines when planning to provide food for a GEAR UP Iowa event. Description Drawing Item: Grocery Store gift card OR Gas Gift Card OR Restaurant Gift Card OR Food Gift Basket Meals Meals Healthy and nutritious snacks (e.g. granola bars, string cheese, fruit, popcorn, trail mix, pretzels, crackers, milk, juice, yogurt, bagels, muffins) Coffee and light refreshments (e.g. fruit, bagels, donuts, muffins, cookies, or crackers and cheese) Amount One item per meeting valued at up to $25 Purpose Attendance Incentive for Parent / family Meetings Up to $8 per student, parent, or staff Up to $8 per student per meal Note: We will pay up to $10 for meals at college campus cafeterias when there is no lower option. Up to $1 per day per student Family/Parent Night Event Up to $5 per person per event Advisory meetings, volunteer meetings, chaperone meetings Field trips, college visits or test taking Field trips, college visits, after school programs GEAR UP Iowa Policy and Procedures Manual Student Classes, Camps, College Credit GEAR UP allows expenses related to dual credit options, credit recovery, student camps and placement tests. Use the following guidelines when planning for these expenses. Description Dual Credit College classes, online classes for credit retrieval, AP tests, Running Start books, College in the High School costs or similar expenses. Individual student camps, on a college campus. SAT or ACT tests College Placement Tests (ASSET, Compass, etc.) Amount Allowable Purpose Activities associated with academic college credit Request Pre-Approval Academic support or enrichment Pre-College Tests Published amount and allowable only if student is not eligible for a waiver. As of September 11, 2013 all GEAR UP Iowa cohort students are eligible for a fee waiver to take the ACT exam (up to two attempts per student). Fee waiver forms are available in school counseling offices. Published amount when no waiver is available. Placement Tests. GEAR UP Iowa Policy and Procedures Manual Instructions for Reimbursement Summary There are two parts required each month in order for your district to be reimbursed for expenditures: the GEAR UP Iowa Reimbursement Request Form and all required backup documentation. 1. Complete and submit a GEAR UP Iowa Reimbursement Request Form and all required backup documentation by the 25th of each month for the preceding month’s expenditures. 2. Each Reimbursement Request Form may only include expenses for one calendar month (do not mix months). 3. Include copies of receipts, invoices, and source documentation for each expenditure. Copies of original detailed invoices or receipts must be provided for all goods and services purchased with GEAR UP Iowa funds. GEAR UP Iowa cannot accept credit card receipts that do not show what was purchased, and cannot accept credit card statements as documentation. Mail, fax, or email invoice vouchers requesting reimbursements to: John Gilman GEAR UP Program Coordinator Iowa College Student Aid Commission 430 East Grand, FL 3rd Des Moines, IA 50319 (515) 725-3401 – FAX [email protected] Questions? Contact John Gilman at (877) 272-4456 or via email at the above address. Records Retention Requirement: Each building or district business office must retain itemized records of all GEAR UP Iowa expenditures for six years after final contract payment is remitted. The records may be subject to program review or audit. GEAR UP Iowa Policy and Procedures Manual STEP 1: COMPLETE THE GEAR UP IOWA REIMBURSEMENT REQUEST FORM AND COLLECT BACK UP DOCUMENTATION EXPENDITURE DETAIL CATEGORIES: When preparing the Expenditure Detail Form, please adhere to the following guidelines for categorizing all expenditures. The list also includes the backup documentation required to be submitted with the Reimbursement Request form to ensure reimbursement to the district. Direct Costs 1. Salaries, Wages, and Benefits a. Salaries or wages for staff for the period being reported / requested. b. Costs for mandatory employer deductions. c. Backup Documentation Required: Include a payroll report with detailed compensation and benefits information for GEAR UP Iowa - paid staff. Sort the report by payee. 2. Staff Travel and Professional Development a. Reimbursements for staff travel paid for GEAR UP Iowa sponsored events. b. Reimbursement for approved professional development travel expenses, registration, and other fees. c. Travel expenses will be paid in accordance with district policies. Costs may not exceed district or state per diem rates for mileage, lodging, and meals. d. Backup Documentation Required: District Travel Voucher completed by the employee and all detailed receipts or invoices. 3. Goods and Services a. Cost of consumable supplies, including office supplies, photocopies, postage, and other materials required and necessary for GEAR UP Iowa initiatives. b. Cost of instructional materials, guest speakers, meals/refreshments, and other related items as allowed by GEAR UP Iowa to ensure that students meet the GEAR UP Iowa goals and objectives. c. Costs for standardized tests when students do not qualify for waivers. d. Costs for college visits, job shadows, and educational field trips, including meals for participants (approximately $8 per participant per meal), and fees for related educational activities. All trips must be pre-approved. e. Entertainment expenses are NOT allowable. f. Backup Documentation Required: Detailed receipts or invoices for all items that clearly show what was purchased, the date, and the amount. Credit card receipts or statements will not be accepted. 4. Student Transportation a. Costs for district vehicles, including driver time, for GEAR UP events. b. Reimbursement rate is currently $.51 per mile for district or privately owned cars. c. Reimbursement rate is per established district rates for other vehicles, including SUVs and buses. District must provide verification of rates to the GEAR UP Iowa Project Coordinator to charge more than $.51 per mile. d. Backup Documentation Required: District transportation log, transportation invoice, or similar item. GEAR UP Iowa Policy and Procedures Manual NOTES: 1. Internet Purchases a. When purchasing and/or paying for items online, it can be particularly challenging to get the correct backup documentation. It is important that you print the final invoice of your purchase showing what was purchased, the date the item was purchased, and the detailed costs. Order confirmations, order summaries, etc. are not invoices and will not be accepted as backup documentation. 2. Pre-Payment a. Per State of Iowa regulations, GEAR UP Iowa will not reimburse for items that have not been received by the school district. You must have received all goods and services prior to submitting for reimbursement. 3. Credit Card Statements and Receipts a. All purchases require a detailed receipt as backup, therefore the summary receipt that is given when you make a credit card receipt, nor the credit card statement are accepted as backup. STEP 2: Mail, fax, or email invoice vouchers requesting reimbursements to: John Gilman GEAR UP Program Coordinator Iowa College Student Aid Commission 430 East Grand, FL 3rd Des Moines, IA 50319 (515) 725-3401 – FAX [email protected] GEAR UP Iowa Policy and Procedures Manual STUDENT MEAL ALLOWANCE FORM Directions: Use this form to document student meal allowance distribution for field trips. This would apply only when you are giving students a set allowance for each meal. It does not apply when you are purchasing a group meal and paying one bill. Have students initial for each meal allowance received. Note: Chaperones receiving the meal allowance may also sign this form as acceptable backup documentation. Date(s) of Trip:_______________ Destination:___________________________________________________________________ Chaperone(s):_________________________________________________________________ Student Name Total: Grade Level Breakfast Amount: Date: Lunch Amount: Date: Dinner Amount Date: Snack: Amount: Date: GEAR UP Iowa Policy and Procedures Manual General Information: In order to ensure smooth processing and reimbursement of GEAR UP related travel expenses, there are two important considerations: 1. District employees must follow the district’s rules and policies regarding travel allowances and reimbursement requirements. 2. GEAR UP Iowa can only reimburse for travel expenses (of any kind) up to the maximum allowed amount set by State and Federal law / regulations governing travel. All district employees need to claim travel expenses in the manner that their district requires while still providing GEAR UP Iowa with the necessary travel expense documentation required by the program for reimbursement. GEAR UP Iowa does not reimburse for travel directly. Staff will submit a travel voucher and documentation to their school district to be reimbursed for travel expenses. The school district then submits a monthly Reimbursement Request Form requesting reimbursement of these expenses, just like any other GEAR UP Iowa expenditure. Following the guidelines below will ensure that your district is reimbursed for all approved GEAR UP Iowa related travel expenses. Meals: 1. GEAR UP Iowa can only reimburse for the cost of meals up to the maximum allowed “state or district meal per diem rates”. 2. Meals are only reimbursable if the staff member is in travel status. This includes overnight travel, or going on field trips with students/families. 3. Receipts for meals: a. If you claim per diem (state or district allowance) a meal receipt is not required – UNLESS required by your district. b. If your district reimburses you based on the actual cost of the meal, not to exceed the state’s per diem, then GEAR UP Iowa requires a copy of your receipts. c. Staff will not be reimbursed for meals if the meal was provided at the event. 4. Also remember: a. Alcoholic beverages will not be reimbursed. b. If submitting meal receipts: If you are paying for your meal and another person’s you must get separate receipts showing only your meal cost. c. GEAR UP Iowa will only pay for the approved traveling staff member’s meal expenses even if combined meal costs for one approved traveler plus companion(s) does not exceed the allowed maximum amount. d. GEAR UP Iowa requires that all meal receipts be detailed – credit card receipts are not detailed and therefore are not an acceptable form of documentation. Receipts must show what was purchased. e. The state allowed per diem amount per meal includes taxes and tip so travelers will not be reimbursed if these items exceed the allowed per diem. GEAR UP Iowa Policy and Procedures Manual Mileage: 1. GEAR UP Iowa can reimburse for use of a personal vehicle up to the allowed maximum amount set by OMB which is currently $.51/mile. If the per mile amount increases GEAR UP Iowa staff will notify school districts. 2. Carpooling: If staff members are carpooling only one staff member can claim mileage for the duration of the trip. GEAR UP Iowa encourages carpooling to maximize resources. 3. GEAR UP Iowa can reimburse for use of a district car up to the allowed maximum amount set by OFM which is currently $.51/mile. 4. GEAR UP Iowa can reimburse for the use of other district vehicles (SUV, van, bus) up to the allowed maximum amount set the by the school district, but will need written verification of the cost per mile being claimed from the district. 5. Driver Cost: When a district vehicle such as a bus is being used for transportation GEAR UP Iowa will reimburse for driver time, benefits, and mileage, but will need written verification of these expenses, such as a transportation log or invoice. 6. Tolls: GEAR UP Iowa will reimburse for bridge and ferry tolls but will require a detailed receipt. 7. Rental Car: GEAR UP Iowa will not reimburse for the use of rental cars except in rare cases. All rental cars must be pre-approved – prior to funds being spent. Lodging: 1. GEAR UP Iowa can reimburse for lodging up to the maximum allowed amount set by the State of Iowa or local district travel regulations. 2. Taxes and fees associated are not included in State of Iowa lodging rates, and therefore are reimbursed in addition to the room rate. 3. Internet: Must receive pre-approval from GEAR UP Iowa. Typically, internet access will be approved if necessary for administrators, but not for other staff. 4. If lodging is required that exceeds State of Iowa and / or district allowed loding amount then pre-approval must first be obtained from GEAR UP Iowa. For example, a. If a conference is being held at a hotel that charges over per diem, the costs may be reimbursed to the district only if pre-approval is given. This may be allowed when the cost of staying at a separate venue requires additional transportation expenses that would result in higher costs than staying at the conference venue. b. A detailed invoice is required for all lodging expenses (shows cost of room, fees, taxes, etc.). Parking: 1. If parking at a hotel event, parking included on the lodging receipt will be reimbursed. 2. GEAR UP Iowa will reimburse for other parking, but a detailed parking receipt is required. 3. GEAR UP Iowa will not reimburse for valet parking. If you opt to use valet parking, only the standard rate will be reimbursed. GEAR UP Iowa Policy and Procedures Manual Airfare: 1. Staff may travel by air (economy class), but a detailed receipt showing all costs is required for reimbursement from GEAR UP Iowa. Use caution when making online reservations. If you do book online, be sure you print the actual receipt – and not the confirmation. 2. Baggage: GEAR UP Iowa will reimburse for up to one checked bag. A detailed receipt showing this expense is required. Advance Travel: 1. GEAR UP Iowa cannot reimburse districts for advance travel. Because travel advances are estimates of travel expenses GEAR UP Iowa cannot accept these forms for reimbursement. 2. GEAR UP Iowa cannot reimburse a school district more than what a school district reimbursed its employee for. 3. School districts must request reimbursement from GEAR UP Iowa only after reimbursement to the employee has been completed. Travel Expense Voucher: 1. GEAR UP Iowa accepts school district travel vouchers, with receipts, as backup. 2. Staff must complete the travel expense voucher completely - providing as much detail as the expense voucher requests. This includes the purpose of the trip, the location, and the dates of travel. 3. The following items must also be included: a. Mileage: How many miles total are being claimed from destination to destination? b. Meals: How much money total is being claimed for breakfast, lunch, dinner on each travel day(s)? i. If neither the school district nor State of Iowa per diem is being claimed then detailed receipts must be submitted as backup. c. Lodging: How much money total for each night is being claimed for lodging? i. A detailed invoice of lodging expenses is always required for reimbursement from GEAR UP Iowa. d. Misc Expenses (tolls, parking, baggage, etc.): Detailed receipts must be provided. The Best Way to Show What/Who Was Paid: 1. Provide copies of all detailed receipts/invoices for travel expenses being requested for reimbursement. a. Copies of credit card receipts or bank statements are not considered appropriate backup. 2. Provide copies of completed travel expense vouchers. 3. Provide a copy of the transaction recap showing only what/who was paid with GEAR UP Iowa funding. GEAR UP Iowa Policy and Procedures Manual When traveling for GEAR UP Iowa events: Prior to each GEAR UP Iowa sponsored professional development event, GEAR UP Iowa will send you the information you need related to travel arrangements, including lodging reservation information, meals, and any other guidance to ensure that you are prepared for your trip. Watch for these emails. Questions? If you have questions about a specific GEAR UP Iowa event or about the travel reimbursement process, please contact John Gilman at [email protected] . GEAR UP Iowa Policy and Procedures Manual UNDERSTANDING GEAR UP MATCH REQUIREMENTS Understanding Match GEAR UP grants require a dollar-for-dollar match, meaning that for every dollar of federal grant money spent on the project, the grantee must find an equal dollar amount of match in the form of state, local, or donated funds. It is the grantee’s job to generate and document this match with the same care and attention to accuracy, accountability, and timeliness as documenting the use of federal grant funds. If a grantee does not meet the match requirement, they could have their federal funds reduced, or their award could be terminated. For every dollar GEAR UP spends of the federal allotment, we need to contribute an equal state share. If we cannot identify sufficient matching funds to meet the program goals, we have to reduce our program expenditures by an equal amount. If the non-federal share (in-kind) is not met, we may have to cut back on the program. Thus, meeting the in-kind match is critical to the success of GEAR UP. In year four, 2011 – 2012 of the grant, school districts are responsible to collect 60% match unless the district has filed documents agreeing to utilize Microsoft Settlement funding for through Spring of 2014 as the district’s contribution toward GEAR UP Iowa’s match requirement. Definition of Match “Match” is a general term that refers to items donated to the project, regardless of who paid for them. In the case of GEAR UP grants, it means the non-federal share of program costs. If your organization purchased the goods or services but did not request reimbursement from the grant, then the generic term “match” applies. If another person or organization donated the goods or services, then both the generic term “match” and the more specific term “in-kind” apply. Definition of In-Kind "In-Kind" refers to non-cash contributions of goods or services made by third party individuals or organizations to GEAR UP Projects. Examples of in-kind include work done by unpaid volunteers in support of GEAR UP, fee waivers, and donations of supplies, facilities, or equipment. Qualifying in-kind contributions must be necessary to accomplish program activities, verifiable, and only allowable if the grantee could legitimately pay for them. In-kind match follows the same rules as the money you spend on GEAR UP. Your in-kind match must be allocable, allowable, and reasonable. The school district’s 60% match requirement must be met during the Implementation Plan period. You cannot “catch up” later. Match can be audited at anytime, just the same as any other expenditure in your approved GEAR UP Iowa Implementation Plan. GEAR UP Iowa Policy and Procedures Manual How to Meet the Required Match Collecting and documenting match on an ongoing basis is wise, efficient, and much less stressful than attempting to catch up or go back and document it. When collected as part of the day-today program, it is easier to record accurately and monitor regularly. Breaking down a grant’s match requirement on a monthly or quarterly basis makes it manageable and attainable. Grantees may choose to assign a staff person or team to coordinate the match. School staff must receive match allowability and documentation training to be eligible to document time as in-kind match. Some find it helpful to create match binders or folders for staff to keep with them as they do their GEAR UP work. Having the information and forms on hand makes it easier to collect match documentation as it occurs. A sample training outline is provided in this section. It includes the items that should be covered in the staff match training. Note that the match forms for staff time include a check box to verify the staff person has received this training. When considering whether or not goods or services qualify as allowed match, refer to the Common GEAR UP Costs section in Section 3: Expenditure & Reimbursement Procedures. If it is an allowable expenditure, it is also an allowable match item. Generally, to determine if a good or service qualifies as match, you should ask yourself, 1. When considering match, could I pay for this (item or service) using federal GEAR UP funds? 2. Is it legal and ethical? 3. Does it pass the “headline test”? Remember that if a cost is unallowable, it is not allowable match. Other federal funds. Match cannot be claimed from other sources/programs that are federally funded. In other words, if you receive other federal grants, it cannot be used as match to the GEAR UP Iowa program. Match can be counted only once. If you have one or more federal grants, you can only count a match contribution once. Additionally, if you partner with another federal program, and provide goods or services jointly, and both programs are collecting match, you must determine which programs gets the match – you may split it out and share it, or one program may use it. If you have more than one grant that requires match, you cannot move match from one project to another. Each must be documented separately and the match must be used for the grant to which it was contributed. GEAR UP Iowa Policy and Procedures Manual Donations may be counted as match, but discounts cannot. Discounts cannot be counted towards match. For example, if you order pizza for a parent meeting and the pizza restaurant gives you the pizzas at 25% off, you cannot count the 25% discount as match. However, if you purchase six pizzas and they give you two free, you can count the two free pizzas’ value as match. Volunteer services. These need to be valued at what you would pay for the service not at the individuals’ wages. When documenting a person’s service, it should be valued at the rate of what someone would ordinarily be paid to do the work rather than the contributor’s actual paid wage. If the organization has no one doing similar work, then the value needs to be consistent with what is paid for that type of work in the local area. You can also go to this website to find the volunteer rate for Iowa: http://www.independentsector.org/volunteer_time . The current rate is $21.62 per hour (fall 2011). Keep supporting documentation on how the rate was determined. Teacher and school staff time. Teacher and other school staff time may be counted as in-kind match IF it meets these criteria: 1. The in-kind match time must support the goals and objectives of GEAR UP Iowa and be in addition to the general tasks expected of a teacher or school staff. For example: a. If a staff member chaperones a GEAR UP Iowa field trip, the total time on the field trip can count as match. b. If a teacher is teaching a curriculum required by GEAR UP Iowa, the total time spent preparing and teaching the curriculum can be counted as match. c. If a teacher or staff volunteers time beyond their regular contract day to participate in a GEAR UP Iowa sponsored activity, that time can be counted as match. 2. If teachers have non-GEAR UP Iowa cohort students in their class, and are providing a GEAR UP Iowa specific activity during class time, they must prorate their time based on the number of GEAR UP Iowa students in their class. a. Example of teacher prorated time: i. Class: 24 total students. ii. 18 of the 24 students are GEAR UP Iowa cohort students or 75%. iii. 75% of the teacher’s time spent planning activities specifically for GEAR UP Iowa cohort students and activities that are different than activities done before the GEAR UP Iowa program may be counted as match. 3. All paid school district teachers and staff must use the “Teacher / Counselor / Staff InKind Match” form available online at: http://www.gearupiowa.gov/Collection/pdf/InkindActivitiesForm.pdf to document their time as match. GEAR UP Iowa Policy and Procedures Manual School district physical space and equipment. Use depreciation and cost allowance to value space and equipment. Please see a copy of the Depreciation and Cost Allowance section from OMB Circular A-87. A description of depreciation is also included. Rate sheet. When documenting volunteer time, spaces, and services, develop a rate sheet to document how you determined the value. Many schools and organizations already have established rates. Sometimes you may need to do some research to find out the fair market value in your area. Submit your rate sheet at the beginning of each grant year to the GEAR UP Iowa office along with that year’s GEAR UP Iowa Implementation Plan. GEAR UP Iowa Policy and Procedures Manual MONTHLY MATCH SUMMARY FORM Directions: Complete this form each month and submit with your school district’s Reimbursement Request Form. For each donor listed, a copy of the “Contribution of Goods and Services Statement” or “Teacher / Counselor / Staff In-Kind Match form” must be attached and submitted. Schools should retain the originals of all forms. GEAR UP School District Name: _______________________________________________________________ Month and Year: ____________________________________________________________________________ DATE CONTRIBUTOR LIST EACH CONTRIBUTOR’S NAME HERE TOTAL $ AMOUNT LIST THE TOTAL FROM EACH FORM ATTACHED. GEAR UP Iowa Policy and Procedures Manual MATCH CONTRIBUTION OF GOODS AND SERVICES STATEMENT Directions: When you receive an in-kind donation of goods or services, this form must be completed and signed by the donor. The information must be included in the Summary Match Form and submitted with the monthly A19 Request for Reimbursement. School District: _____________________________________ Date: ____________________ Contributor's Name or Organization: ____________________________________________ Address: ____________________________________________________________________ ____________________________________________________________________________ Phone Number: (_____) ______________ Fax Number: (_____) ______________ DATE Detailed Description of Goods or Services Contributed Total miles driven: Number of Hours (if applicable) Hourly Rate for Service Value State mileage rate: TOTAL $ The information provided on this form is an accurate estimate of the goods and/or services I have provided to the GEAR UP Program. Contributor's Signature: ____________________________________ Date: ______________ I hereby certify, UNDER PENALTY OF PERJURY under the laws of the State of Iowa, that the foregoing is true and correct. School District’s Signature: ___________________________________Date: ______________ GEAR UP Iowa Policy and Procedures Manual IN-KIND CONTRIBUTION OF TEACHER OR SCHOOL STAFF TIME AND EFFORT REPORT Directions: This form must be completed and signed monthly by each school district staff member who contributes time to the GEAR UP project. Refer to the guidelines in Section 4: InKind Match Documentation and Reporting for qualifying activities. Teacher/School Staff Name: ____________________________________________________ School and School District Names: ____________________________ Date: ____________ Code DATE (see table below) Detailed Description of Services Contributed to GEAR UP donated with unpaid volunteer hours or that are specific GEAR UP services. Number of Hours Hourly Rate for Service Value TOTAL $ The information provided on this form is an accurate estimate of the services I have provided to the GEAR UP Program. I hereby certify, UNDER PENALTY OF PERJURY under the laws of the State of Washington, that this information is true and correct. Contributor's Signature: _____________________________________ Date: ______________ Project Contractor's Signature: _________________________________ Date: ____________ Code # 1 2 3 4 5 6 7 Activities Prepared class activity to inform or help students learn about college opportunities. Prepared class activity to help underachieving students and/or promote rigor. Prepared class activity to learn about career opportunities Planned and/or participated in a GEAR UP sponsored event or meeting. Professional Development which would benefit GEAR UP students. Tutored or mentored GEAR UP students. Other: Specific details – attach additional sheets of paper if necessary GEAR UP Iowa Policy and Procedures Manual DEPRECIATION AND USE ALLOWANCES (Source: OMB Circular A-87). 1. Depreciation and use allowances are means of allocating the cost of fixed assets to periods benefiting from asset use. Compensation for the use of fixed assets on hand may be made through depreciation or use allowances. A combination of the two methods may not be used in connection with a single class of fixed assets (e.g., buildings, office equipment, computer equipment, etc.) except as provided for in subsection g. Except for enterprise funds and internal service funds that are included as part of a State/local cost allocation plan, classes of assets shall be determined on the same basis used for the government-wide financial statements. 2. The computation of depreciation or use allowances shall be based on the acquisition cost of the assets involved. Where actual cost records have not been maintained, a reasonable estimate of the original acquisition cost may be used. The value of an asset donated to the governmental unit by an unrelated third party shall be its fair market value at the time of donation. Governmental or quasi-governmental organizations located within the same State shall not be considered unrelated third parties for this purpose. 3. The computation of depreciation or use allowances will exclude: a. The cost of land; b. Any portion of the cost of buildings and equipment borne by or donated by the Federal Government irrespective of where title was originally vested or where it presently resides; and c. Any portion of the cost of buildings and equipment contributed by or for the governmental unit, or a related donor organization, in satisfaction of a matching requirement. 4. Where the depreciation method is followed, the period of useful service (useful life) established in each case for usable capital assets must take into consideration such factors as type of construction, nature of the equipment used, historical usage patterns, technological developments, and the renewal and replacement policies of the governmental unit followed for the individual items or classes of assets involved. In the absence of clear evidence indicating that the expected consumption of the asset will be significantly greater in the early portions than in the later portions of its useful life, the straight line method of depreciation shall be used. Depreciation methods once used shall not be changed unless approved by the Federal cognizant or awarding agency. When the depreciation method is introduced for application to an asset previously subject to a use allowance, the annual depreciation charge thereon may not exceed the amount that would have resulted had the depreciation method been in effect from the date of acquisition of the asset. The combination of use allowances and depreciation applicable to the asset shall not exceed the total acquisition cost of the asset or fair market value at the time of donation. 5. When the depreciation method is used for buildings, a building's shell may be segregated from the major component of the building (e.g., plumbing system, heating, and air conditioning system, etc.) and each major component depreciated over its estimated useful life, or the entire building (i.e., the shell and all components) may be treated as a single asset and depreciated over a single useful life. GEAR UP Iowa Policy and Procedures Manual 6. Where the use allowance method is followed, the use allowance for buildings and improvements (including land improvements, such as paved parking areas, fences, and sidewalks) will be computed at an annual rate not exceeding two percent of acquisition costs. The use allowance for equipment will be computed at an annual rate not exceeding 6 2/3 percent of acquisition cost. When the use allowance method is used for buildings, the entire building must be treated as a single asset; the building's components (e.g., plumbing system, heating and air condition, etc.) cannot be segregated from the building's shell. The two percent limitation, however, need not be applied to equipment which is merely attached or fastened to the building but not permanently fixed to it and which is used as furnishings or decorations or for specialized purposes (e.g., dentist chairs and dental treatment units, counters, laboratory benches bolted to the floor, dishwashers, modular furniture, carpeting, etc.). Such equipment will be considered as not being permanently fixed to the building if it can be removed without the destruction of, or need for costly or extensive alterations or repairs, to the building or the equipment. Equipment that meets these criteria will be subject to the 6 2/3 percent equipment use allowance limitation. 7. A reasonable use allowance may be negotiated for any assets that are considered to be fully depreciated, after taking into consideration the amount of depreciation previously charged to the government, the estimated useful life remaining at the time of negotiation, the effect of any increased maintenance charges, decreased efficiency due to age, and any other factors pertinent to the utilization of the asset for the purpose contemplated. 8. Charges for use allowances or depreciation must be supported by adequate property records. Physical inventories must be taken at least once every two years (a statistical sampling approach is acceptable) to ensure that assets exist, and are in use. Governmental units will manage equipment in accordance with State laws and procedures. When the depreciation method is followed, depreciation records indicating the amount of depreciation taken each period must also be maintained. GEAR UP Iowa Policy and Procedures Manual GEAR UP Match Training Suggested Outline 1. Definition of Match a. Items donated to the project (school districts share of the program costs) 2. Definition of In-kind a. Non-cash contributions of goods or services made by third party individuals or organizations i. Examples include work by unpaid volunteers, waivers, donations of supplies, facilities or equipment. b. In-kind contributions are: i. Necessary to accomplish program activities ii. Are verifiable iii. Are allowable if the grantee could legitimately pay for them 3. GEAR UP Match Requirement a. GEAR UP grants require a $.66 match for each $1 of grant funding. The school’s 2010-11 GEAR UP Iowa allocation is $__________ and requires a match of $______________. 4. Match Qualifications a. Ask yourself “Is the good or service an allowable expense that could be purchased using federal funds?” b. Match needs to be reasonable, necessary, well documented, and consistent. c. Details need to be specific and clear. d. Generally, the same requirements apply to the cash/in-kind match as they do to the expenditures e. Match must be met in the year of the grant budget. You cannot play “catch up”. f. The expense must be: i. Necessary to implement the program ii. Reasonable, in that a prudent person would determine that the cost is appropriate iii. Allocable to the objectives of the award iv. Compliant with the federal administrative regulations that govern the program g. Match cannot be claimed from other sources/programs that are federally funded. h. Match can only be counted once i. Discounts cannot be counted as match 5. Volunteer Services a. Should be valued at what you would pay for the service, not the individuals’ wages. b. Supporting documentation on how the rate was determined must be kept GEAR UP Iowa Policy and Procedures Manual 6. Teacher Time a. All time devoted to GEAR UP specific activities can be counted as match at the same rate that person is normally paid, including benefits, if they are doing work similar to their regular duties. b. All teacher time must support the goals and objectives of the program and be in addition to the general tasks expected of a teacher. 7. Other School Staff Time a. All time devoted to GEAR UP specific activities can be counted as match at the same rate that person is normally paid, including benefits, if they are doing work similar to their regular duties. b. All staff time must support the goals and objectives of the program and be in addition to the general tasks expected of a teacher. c. If staff are participating in activities directly related to GEAR UP during regular school hours for which they are being paid, this may count as match as long as they are activities they would not normally be doing if the GEAR UP program were not in place. 8. On one day field trips, all time spent with students can be counted as match. a. On overnight field trips, all time spent supervising students can be counted as match. GEAR UP will assume 8 hours of sleep per chaperone, which cannot be included in the total hours
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