Eligible Expense

Question:

For a worker simply checking a client into the shelter and/or verifying their Emergency Solutions Grant (ESG)eligibility, is this allowable under Operations Component? If so, how should it be categorized? Please note, this is NOT a case manager that would be working with them under essential services. In addition, any staff person who is responsible for the day to day operations or oversight of the day to day running of the shelter, how should this be billed?

Answer:

Costs directly related to carrying out activities eligible under an ESG component are eligible costs under that component (see 24 CFR § 576.100(d)). For the salaries and related costs (including fringe benefits such as holiday, vacation, sick leave) of staff that are not fully dedicated to a particular component, costs should be reimbursed in proportion to the actual hours worked on each ESG component.

When reporting in the CAPER, a recipient and its subrecipient must track costs allocated under the emergency shelter component by activity (i.e. renovation/rehab, essential services, and operations). The activities of a worker  who conducts intake activities such as checking a client into the shelter and/or verifying their ESG eligibility would fall under essential services rather than shelter operations. This will be the case regardless of whether the staff person who conducts the intake is a case manager or some other type of staff.

In terms of how to track staff time, the exact methodology for tracking the time that staff worked on federal grants and on components and activities within a federal grant is at the discretion of the recipient. However, actual time must be charged to federal grants and recipients and subrecipients must be able to justify and document the methodology used, and it must be reasonable and well-documented. The OMB Circulars do not require that recipients track actual time by ESG component and activity, but there must be a methodology in place to estimate time allocated to components because of the statutory caps in place on street outreach and emergency shelter, and administration. Additionally, because of the CAPER reporting requirements, there must be a methodology in place to estimate time allocated to activities within a component. While actual time is preferred, any estimates must be a realistic reflection of actual time spent across ESG components and activities.  Timesheets that capture actual time spent on specific programs are the most straightforward way to meet time reporting requirements. However, other approaches may be acceptable as long as they meet the guidelines established in Circular A-87 Appendix B(8)(H) for States or units of local government or Circular A-122 Appendix B(8)(m) for nonprofit organizations.