Overview of the Monitoring Process SASA OSEP. Preparing for a Monitoring Visit Common Findings. Jennifer S. Mauskapf, Esq.

Transcription

1 Jennifer S. Mauskapf, Esq. Spring Forum Overview of the Monitoring Process SASA OSEP Preparing for a Monitoring Visit Common Findings 2 3 1

2 New to : ESEA Flexibility Monitoring SASA Monitoring for Select Non Flex States: Title I, Part A Title I, Part D (Neglected, Delinquent, or At Risk) Title X, Part C (McKinney Vento Act/Homeless Program) Title III, Part A 4 SEA has not been monitored since the or monitoring cycle Review of Audits and Previous Monitoring Findings Staff Leadership Turnover or New Staff 5 Pre site document reviews SEA and LEA website reviews Previous corrective actions Combination of program specific Desk Teleconference / Videoconference Web based conference On site monitoring review of indicators 6 2

3 Continuous Improvement Visits name=osep+continuous+improvement+visits Results Component Stakeholder Input Process Verification Component r_name=creags +Part+B Determinations. State Performance Plan (SPP) / Annual Performance Report (APR) Review 7 Desk monitoring of each State State contact gathers and analyzes data and information Information collected primarily through Webbased searches and document analysis Specific documentation requested from SEA Selection of LEAs Receipt of Agenda and List of ED Participants 8 HOW LONG? Typically one full week WHAT WILL ED BE DOING DURING THE VISIT? Review documentation not available prior to the trip Interview SEA and LEA staff, principals, teachers, parents, and other stakeholders Exit Conference 9 3

4 DRAFT comprehensive monitoring report issued To be issued within 35 business days of the on site visit SEA has 5 business days to review and provide technical edits and corrections FINAL report issued SEA Response SEA has 30 business days to respond to any required actions SASA sends a letter approving proposed actions or requiring revision/further action May require close collaboration (e.g., CAPs) and/or follow up visits Significant compliance findings can lead to special conditions 10 Preparation is the Key! 11 Meet with Key Personnel All about Communication! Discuss program and areas that will be reviewed 12 4

5 1 Main Visit Contact Schedule meetings Ensure lead personnel schedules clear Organize travel requests / information (as requested by SASA) Schedule visits to schools (as requested by SASA) Schedule conference calls with SASA prior to visit 13 A representative should be appointed as lead interviewer for each program (and topic) as appropriate Title I, Part A Title I, Part D Neglected, Delinquent or At Risk Title X, C McKinney Vento Title III, Part A SIG IDEA Results These representatives must know who should be present for each indicator and where all documentation is located! 14 Want meeting place separate from main offices so that all parties can remain focused Don t completely isolate All personnel should have cleared scheduled and be ready to participate as necessary Organized by the applicable lead contact 15 5

6 Complete the Actual Monitoring Document the Monitors will be using! Put your best foot forward Narrative Form How? Answer the Question Being Asked! Respond to correct fiscal year! Include Specific Citations as appropriate. 16 OSEP: Critical Elements Analysis Guide (CrEAG) Part B Gen. Supervision Fiscal Systems SASA Monitoring Plan for Formula Grant Programs SIG: Application Process, Implementation, Fiscal, Technical Assistance, Monitoring, Data Collection Title I Team Title I A Fiduciary Title I D McKinney Vento Title III A: Monitoring of Subgrantees; Standards, Assessments & Accountability, Instructional Support, Fiduciary 17 OSEP s CrEAG Format 18 6

7 SIG Format Title I & Title III Team Format 19 Corresponding Binders Tabbed! Organized! Complete Examples! Connect the Dots! Copies for yourself Include any additional documents given to SASA during the visit 20 Practice Makes Perfect! (sort of) Take the monitoring instrument and review the current system in place Interview selected personnel ( test ) CONDUCT PRIOR TO VISIT Chance to change systems as needed! Chance to create corrective action plans and begin implementation as needed! 21 7

8 Be prepared to address any corrective action plan already created or implemented. If no corrective action plan then attempt to create a plan prior to SASA s arrival. 22 Review old monitoring reports Special Conditions State Plans Did you complete everything you said you would? Review audits Including A 133 Single Audit 23 Title I & Title III Reports ( ): s12/index.html SIG Reports: OSEP Continuous Improvement Letters: ate.html Review reports to identify focus areas, trends in findings. 24 8

9 25 Conflicting policies Out of date policies Non existent policies If you have to explain how something is done without being able to point to a clear and current written policy or procedure, you probably have some work to do!!! 26 Timeliness Required Items Public Reporting Examples: Title I A: Annual LEA Report Card, HQT Status Letter, School Improvement Status, SES and Choice Notice Title III: Student Identification, AMAO Determination IDEA: Procedural Safeguards, Stakeholder Input for SPP/APR 27 9

10 Timely review and approval of LEA applications Timely allocation of subgrants Period of availability of funds to LEAs Process for Reallocating Funds Timely Obligation and Liquidation 28 Ensuring Funds are Used for Allowable Uses Consistent with Federal Cost Principles? Consistent with EDGAR? Consistent with program specific rules? How does SEA/LEA ensure and document allowability? Program specific Fiscal Rules MOE Supplement not Supplant Caps 29 Procurement Property / Inventory Management Time Distribution 30 10

11 Section of EDGAR All procurement transactions must be conducted with full and open competition Conflict of Interest: Must have written code of conduct for all employees engaged in contract award and administration Must have protest procedures to handle disputes Follow Procurement Rules!!! 31 Determining between equipment and supply Determining level of control over item Tracking non equipment items 32 Section of EDGAR Must have adequate controls in place to account for: Location of equipment Custody of equipment Security of equipment Property records Description, serial number or other ID, title information, acquisition date, cost, percent of federal participation, location, use and condition, and disposition (if applicable) Physical inventory Must be performed at least every 2 years Control system to prevent loss, damage and theft All incidents must be investigated 33 11

12 Must protect against unauthorized use May use for other projects as long as use is incidental and does not interfere with authorized use When property is no longer needed, must follow disposition rules: Transfer to another federal program Over $5,000 Keep or sell, but must pay a share based on the percentage of federal ED participation at initial acquisition Under $5,000 May keep, sell, or dispose of it with no obligation to ED 34 Section of EDGAR Supplies are everything else Do not cost much money Used fairly quickly Examples: pens, paper, toner, laptops EDGAR does not set out any specific tracking requirements As a practical matter, ED expects subgrantees to track all property purchased with federal funds, in order to prove there has been an allocable benefit to the federal program 35 Selected Items of Cost: Salaries and Wages Allowable if proper time distribution records Time Distribution Records must be maintained for all employees whose salaries are: Paid in whole or in part with federal funds Used to meet a match/cost share requirement 36 12

13 Proper Identification of Cost Objective(s) Completion of Required Documentation PAR vs. Semi annual Certification Correct Signatory? Correct Time Period? Time reported add up to 100% time worked? Signed after the fact? Quarterly Reconciliations 37 Timely and Meaningful Consultation LEA Maintaining Control Program Funds no reimbursement! Property tags, inventory Evaluation of Services Identification of Eligible Students Administration Costs NOT Charged Against Equitable Services Set Aside 38 Comprehensive Monitoring Protocol Follow up procedures to ensure corrective actions taken to address compliance issues Linking Monitoring Findings with Technical Assistance 39 13

14 ESEA Flexibility Monitoring flexibility/monitoring/index.html SASA Monitoring Indicators ( ) Title I & Title III Reports ( ): NASTID Presentation on SASA Monitoring for _overview_sasa_moni.pdf Office of School Turnaround SIG Monitoring SIG Monitoring Plan pdf SIG Reports: 40 Continuous Improvement Visit Page folder_name=osep+continuous+improvement+visits OSEP Continuous Improvement Letters: html Part B SPP and APR Determination Letters: ml

15 Disclaimer This presentation is intended solely to provide general information and does not constitute legal advice. Attendance at the presentation or later review of these printed materials does not create an attorney client relationship with. You should not take any action based upon any information in this presentation without first consulting legal counsel familiar with your particular circumstances