Only the share of time spent on PASRR-related activities can be claimed at the enhanced 75% match. For example, let’s say a State Medicaid Agency (SMA) staff person spends half of her time on activities related to nursing facility level of care, thirty percent of her time on activities related to PASRR, and 20% of her time on activities related to a housing program funded with state-only dollars. Fifty percent of this employee’s time (i.e. that devoted to NF LOC activities) would be claimable at the standard 50% administrative match. Thirty percent of her time (i.e. the time she spends on activities related to PASRR) would be reimbursed at the enhanced 75% match. The final 20% of her time would not receive any FFP.
The Medicaid agency should collect a solid base of evidence to support the state's claim for the enhanced 75% match. Where employees work on multiple activities or cost objectives as described above, a distribution of their wages must be supported by personnel activity reports (PAR) or equivalent documentation. A PAR is a timesheet or log maintained by the employee which accounts for 100% of their time. The objective is to identify effort spent on multiple activities or programs. According to OMB Circular A-87 Attachment B, Item 8, Section H, Subsection 5 (attached below), personnel activity reports or equivalent documentation must meet the following standards:
a) They must reflect an after-the-fact distribution of the actual activity of each employee;
b) They must account for the total activity for which each employee is compensated;
c) They must be prepared at least monthly and must coincide with one or more pay periods; and
d) They must be signed by the employee.
Also according to OMB Circular A-87, states cannot use budget estimates or proposed distributions of staff effort before the activities are actually performed. However, these estimates may be used for interim accounting purposes, provided that:
a) The governmental unit's system for establishing the estimates produces reasonable approximations of the activity actually performed;
b) The budget estimates or other distribution percentages are revised at least quarterly, if necessary, to reflect changed circumstances; and
c) If the quarterly comparisons show differences between budgeted and actual costs that are less than 10%, costs charged to federal awards can be adjusted accordingly on an annual basis.
Additional information can be found in the OMB Circular A-87 Implementation Guide (see attached below).