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LOGIC: Logistics of Grants Internal Controls

LEAs (local educational agencies, which includes Independent School Districts and Open-Enrollment Charter Schools) must establish and maintain effective internal control over their federal grant awards. The internal controls should provide reasonable assurance that the LEA is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR §200.303

The purpose of the LOGIC webpage is to provide resources to assist LEAs with certain internal control processes.


EDGAR Express contains brief summaries of various EDGAR (Education Department General Administrative Regulations) topics. EDGAR contains cross-cutting requirements that are applicable to the administration of all federal education grants.
If your specific grant program is more restrictive than EDGAR, you must follow the most restrictive.

If state rules or local policies are more restrictive than EDGAR, you must follow the most restrictive.


Instead, viewers are encouraged to subscribe to TEA's Updates listserv for topic-specific subscriptions in order to be informed of various due dates and deadlines.
Additional TEA resources:
Please view TEA's Coronavirus (COVID-19) Support and Guidance webpage for the most up-to-date information and resources applicable to the coronavirus pandemic.
TEA posts Agency Calendars on it's "About TEA" webpage.
A State Funding Calendar is posted under "District & Charter Planning Tools" on TEA's State Funding webpage.


The Committee of Sponsoring Organizations of the Treadway Commission (COSO) provides frameworks and guidance on enterprise risk management, internal control and fraud deterrence.

2 CFR §200.303(a) includes COSO's "Internal Control Integrated Framework" as a suggested resource for internal control guidance.

Access the COSO "Guidance on Internal Control" webpage.

The U.S. Government Accountability Office (GAO) sets the standards for an effective internal control system for federal agencies in the Standards for Internal Control in the Federal Government, known as the "Green Book." 

The Green Book may also be adopted by state, local, and quasi-governmental entities as a framework for an internal control system.

2 CFR §200.303(a) includes GAO's "Standards for Internal Control in the Federal Government" as a suggested resource for internal control guidance.

Access the GAO "The Green Book" webpage.

The United States Department of Education (USDE) developed an Internal Controls Tool Kit that includes:

  • Use of Funds Guidance
  • Self-Assessment Checklists
  • Procurement Examples
  • Internal Control Glossary


Access the USDE "Internal Controls" webpage

Time and Effort (Time Distribution)

Time Distribution Records are applicable to any employee paid in full or in part with federal funds.

Compensation charges to federal awards must be reasonable, accurate, allowable, and properly allocated.

Federal regulations require time distribution documentation to ensure that charges to each federal program reflect an accurate account of the employee's time and effort devoted to that program.

LEAs must have adequate internal controls to ensure charges to the Federal awards are reasonable, accurate, allowable, and allocable. The Uniform Guidance 2 CFR Part 200 is less prescriptive regarding time distribution documentation than previous EDGAR (Education Department Regulations) requirements. 

As long as the LEA's internal controls and documentation meet the Standards for Documentation of Personnel Expenses illustrated in 2 CFR §200.430(i), the LEA has flexibility on how they comply with time distribution records.

Best practice is to follow the previous EDGAR documentation standards of 2 CFR §225 (OMB Circular A-87), with modifications. 

Sample forms for Single Cost Objective and Multiple Cost Objective employees are available below, as well as sample Extra Duty Pay Agreement form, Supplemental Pay Agreement form, job description guidelines and sample template.

ESC-20 Workshops 2020-2021

The fall 2020 grant management workshops will be held via ZOOM only.
Each participant must register in Connect20 first. Registered participants will then be provided the link to the ZOOM meeting.
Please do not share the ZOOM link with others because it is for your individual use only. The Connect20 registration is not a group registration. 
Thank you. We appreciate your interest in our sessions!



Within the LOGIC webpage are resources developed, adapted, or acquired by ESC-20 from public websites and other public sources readily available in the public domain. No copyright is claimed for those materials.

ESC-20 and its affiliates and suppliers disclaim any representations or warranties that use of the LOGIC resources will satisfy or ensure compliance with any legal obligations or laws or regulations. The disclaimer applies to, but is not limited to, the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), the Gramm-Leach-Bliley Act of 1999, the Sarbanes-Oxley Act of 2002, or other Federal or State statutes or regulations.

Use of the LOGIC resources are entirely at the LEA's risk and does not guarantee that the LEA will not have an audit finding or questioned costs.

To the maximum extent permitted by applicable law, ESC-20, its affiliates, and suppliers disclaim all warranties, expressed or implied, including any warranty that the LOGIC resources are fit for a particular purpose, title, merchantability, data loss, non-interference with or non-infringement of any intellectual property rights, or the accuracy, reliability, quality, or content in or linked to the LOGIC webpage.


Denise Dusek
Phone: (210) 370-5378
Fax: (210) 370-5755


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