After School Program Administration

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1 INTRODUCTION After School Program Administration Standards address several areas relevant to effective program management and administration, including leadership; oversight; ethical practice; financial management; risk prevention and management; and continuous quality improvement. Implementing these standards supports a program's ability to provide quality programming for children and youth. Note: When another person, department, or entity (e.g., a school district) is responsible for implementing some of the practices addressed in these standards, the program should be prepared to provide evidence that this is the case. For example, if the school principal or superintendent is responsible for the quarterly risk review addressed in ASP-AM 6.02, the program should provide documentation to demonstrate this. If the program implements policies or procedures (e.g., conflict of interest policies and procedures) that have been developed and adopted by another body (e.g., the school board, or the governing body of the organization of which the program is a part), the program does not need to develop its own separate policies and procedures. Instead, it should provide evidence of the policies and procedures it has been given to enforce. When Standards Interpretations include lists of examples, every example will not necessarily be relevant and appropriate for every program. Rather, the examples are intended to provide guidance about factors and issues to consider when implementing the standard. For more information about the structure and features of the standards, and requesting an NA when a standard is not applicable, please see the After School Guidelines. For more information about the evidence needed to demonstrate standards implementation, please see the Table of Evidence. Table of Evidence Self-Study Evidence - Describe how the program assures that it remains abreast of changing legal and regulatory requirements. - Identify a part of your long term plan that has been: a. the most difficult to advance, and indicate the reason(s) why; and b. the least difficult to advance, and indicate the reason(s) why. - Describe how your program works with the person or entity responsible for providing oversight to strengthen the program and its capacity to meet its mission. - Describe activities that create an open and transparent system of accountability in your program. Provide specific examples of how you Page 1

2 provide access to information about the program and its finances to your stakeholders and the public. - Cite two examples of activities or decisions that your program has made that demonstrate implementation of the conflict of interest policy. - Describe the overall health of your program's finances. Include a description of significant factors that may have impacted your program's finances (e.g., enhanced or reduced program-specific funding streams, successful fundraising activities, new foundation support, state budget cuts, etc.), and any actions taken to enhance financial viability. - How does your program assure that its financial management systems are in accordance with Generally Accepted Accounting Principles? - Describe your program's overall approach to risk prevention and management. How are risks identified? How are identified risks brought to the attention of management? Which types of risks are brought to the attention of the person or entity responsible for providing oversight? - Describe 2-3 examples of your program's response to identified risks. Please describe the steps, the decision-making process, and actions taken to bring the issue to resolution. - Describe how regular safety inspections and maintenance reports are incorporated into your program's risk prevention and management reviews and how the results of these reports are integrated into quality improvement activities. - Describe your program's systems for maintaining information. Which systems, if any, are computerized and which are not (e.g., the financial management system, human resources)? - Explain how your program creates a culture that promotes excellence and continual improvement, and focuses on promoting satisfaction and positive outcomes. - Who is involved in deciding what goals and outcomes will be measured, and what the indicators will be? How would your program describe its progress/status with implementing outcomes measures? - How does the program know if the information it collects - the basis for data that is analyzed - is valid, reliable and relevant? Cite an example of data the program knows is valid and reliable for at least two of the following: a. program operations; b. the quality of programming and services provided; c. program results; and/or d. satisfaction and outcomes of children, youth, and families. - Cite 2-3 examples of improvement efforts that have occurred in response to data/information generated by your continuous quality improvement efforts. - Provide any additional information that would increase the Endorsers' Page 2

3 understanding of how your program operates relative to these standards. On-Site Evidence No On-Site Evidence On-Site Activities No On-Site Activities Page 3

4 ASP-AM 1: Legal and Regulatory Authorization and Compliance The program complies with applicable laws and regulations. Table of Evidence Self-Study Evidence - A list of licenses applicable to the program, including the oversight bodies that issue and monitor them - A letter signed by Program Administrator and the person or entity responsible for oversight, certifying that the program is in compliance with license requirements and meets applicable laws, regulations, guidelines, and codes - Provide a description of the system used by the program to ensure compliance with applicable licenses, laws, regulations, guidelines, and codes. - Bylaws/charter/articles of incorporation, or other documentation showing the program operates as (or as part of) a legal entity On-Site Evidence - Relevant licenses or documentation of exemption/non-applicability - Certificate of Occupancy - Documentation of compliance with applicable laws, regulations, guidelines, and codes - Reports from licensing/regulatory review, as applicable On-Site Activities - Interview: a. Program Administrator b. Site Director (FP) ASP-AM 1.01 The program possesses relevant licenses, if applicable, and displays documents in an area visible to the public. Interpretation: Requirements related to licensure may vary from state to state and by program type. Note: If the program is exempt from licensing, it should requst an "NA" from Page 4

5 COA. (FP) ASP-AM 1.02 The program meets applicable laws, regulations, guidelines, and codes, including those related to health and safety. Related: ASP-HR 5.01, ASP-PS Interpretation: The program is expected to be familiar and comply with all applicable federal, state, and local requirements. When codes differ, for example state and local codes, the stricter code applies. If necessary, the program should consult legal counsel to provide necessary information and guidance. The program should have current documentation (e.g., inspection reports) showing that it has met applicable state and/or local health and safety codes, regulations, and guidelines. For example, the program should be prepared to provide proof that it has passed health, building, and fire inspections. In order to be sure that applicable codes, regulations, and guidelines are met, some programs may choose to arrange for their own inspection of the program space by a qualified person, or develop plans that document their efforts to remain in compliance. (FP) ASP-AM 1.03 The program operates as, or as part of, a legally-authorized entity. Interpretation: The program may be, or be part of: a. a public agency, such as a school or the military; b. a nonprofit with a governing body incorporated or authorized to conduct business in the state where it operates or is headquartered and has a duly promulgated charter, constitution, and/or bylaws; c. a nonprofit organized as an identified sub-unit of a religious body that has legal status or is an identified sub-unit of another legal entity recognized under state law; d. a corporation sole; or e. a for-profit organized as a corporation, partnership, sole proprietorship, limited liability company, or association with a duly promulgated charter and other appropriate governing documents. Page 5

6 ASP-AM 2: Program Planning, Guidance, and Oversight Program personnel manage program planning, and collaborate with parties that provide oversight and guidance. Related: ASP-PS 1 Table of Evidence Self-Study Evidence - Long term plan - Contact information for person (or members of entity) responsible for oversight - List of advisory group or governing body members, with contact information On-Site Evidence - Long term planning process - Documentation of collaboration with person (or members of entity) responsible for oversight - Meeting minutes of advisory group or governing body On-Site Activities - Interview: a. Program Administrator b. Site Director c. Program Personnel d. Person (or representative of entity) responsible for oversight e. Member of advisory group or governing body ASP-AM 2.01 Long-term program planning involves relevant personnel and other stakeholders, including children and youth and their families, and includes: a. envisioning and setting the program's direction; b. reviewing the program's mission, values, and mandates; c. identifying and assessing strengths, weaknesses, challenges, and critical issues; d. establishing goals and objectives that flow from the program's mission and responsibilities; and e. devising strategies for meeting identified goals. Page 6

7 Interpretation: Timeframes for long-term planning may vary from program to program, but should be logical. For example, some programs may make plans annually, or for the school year. At some programs it may also be necessary and appropriate to involve the person or entity providing oversight, or the group providing guidance, in long-term program planning. Note: This standard is about planning for the program's overall direction, rather than planning for daily activities and events. Planning for the latter should be based on and connected to the program's overall plan and direction, and is addressed more specifically in ASP-HR 5.04 and the Note to ASP-PS 5. Long-term program planning should also be connected to continuous quality improvement efforts addressed in ASP-AM 9. ASP-AM 2.02 Program personnel work with, and provide reports or updates to, the person or entity responsible for providing oversight. Interpretation: The person or entity responsible for providing oversight will vary depending on the type of program. For example, while some programs may report to a governing body, others may be responsible to another type of review board (e.g., a military review board), or to an individual (e.g., a principal or superintendent). The program should be prepared to explain how the person or entity responsible for providing oversight and guidance supports the achievement of the program's mission and goals. Examples of what the person or entity providing oversight may be responsible for include, but are not limited to: a. reviewing the development and implementation of the long-term plan; b. reviewing risk identification and management processes; c. providing financial oversight; d. anticipating the need for and developing resources; e. reviewing achievement of the program's objectives; f. enhancing and promoting community-program relationships; g. appointing, collaborating with, and evaluating the program administrator or director; and h. developing and adopting policy. NA The program is a privately-held and owner-operated for-profit, and is not responsible to another person or entity. ASP-AM 2.03 The program receives guidance from a group that: Page 7

8 a. includes relevant stakeholders, such as parents, community representatives, or others with an interest in the program and its mission; b. receives support and information from the program; and c. provides feedback about programming, outcomes, and the community's perception of the program. Related: ASP-PS 10, ASP-PS 10.02, ASP-PS 11 Interpretation: The group that provides guidance may vary depending on the type of program. For example, while some programs may have a governing body that includes parents, others may have a parent or community advisory group. In order for the group to function well the program should establish clear and transparent recruitment and selection guidelines; have reasonable expectations about what the group can accomplish within the parameters of its mission and available resources; and actively consider and respond to the group's input, feedback, and recommendations. Page 8

9 ASP-AM 3: Ethical Practices The program earns and sustains the public's trust through honest, truthful, and responsible conduct, transactions, partnerships, and relationships. Table of Evidence Self-Study Evidence - Program brochures/literature - Mission statement - Annual report or other publicly available documents - Policies and procedures for all fundraising practices - Conflict of interest policies and procedures On-Site Evidence - Policies and procedures governing the confidentiality of donors - Financial statements/reports - Contracts/agreements, if applicable On-Site Activities - Interview: a. Program Administrator b. Site Director c. Program Personnel ASP-AM 3.01 The program promotes open, transparent, and ethical operations by: a. providing the public with access to clear, timely, and accurate information about the program's activities and finances; and b. accurately conveying its mission in all communications that contain such a representation (e.g., in flyers distributed to community members, or in applications for funding). Related: ASP-PS Interpretation: Donors, volunteers, public officials, and family members of program participants are among those for whom access to information should be assured. When the program is a not-for-profit, the federal Form 990 filing may be used as a source of information. COA recognizes that for-profit programs Page 9

10 are not required to disclose financial information to the public. ASP-AM 3.02 A program that raises funds by individual solicitation from the general public: a. accurately describes the purpose for which solicitations are being made; b. spends funds for the purposes they were solicited, with the exception of reasonable costs for administration of the fundraising program; c. maintains accounting segregation for restricted funds; and d. respects donor confidentiality requests. Interpretation: This standard is applicable to programs that solicit or receive money from private individuals through capital campaigns, contribution plans, and United Way appeals, as well as through smaller-scale fundraisers (e.g., used toy or clothing sales, bake sales). This standard is not applicable to private or public grants and contracts. Regarding element (d) of the standard, the program should protect the confidentiality of donors who request anonymity by ensuring that such donors' names are not published or listed in newsletters, articles, annual reports, or other publicly available documents. NA The program does not conduct fundraising. ASP-AM 3.03 Conflict of interest policies and procedures ensure that contracts and business arrangements serve the program's and program participants' best interests, not private interests. ASP-AM 3.04 Conflict of interest policies and procedures ensure that personnel, members of the entity providing oversight, members of the group providing guidance, and community partners who have a financial interest in the program's operations, assets, business transactions, or leases: a. disclose this information; and b. do not participate in any discussion or vote taken with respect to such interests. Page 10

11 Note: Element (b) does not apply to owners in private, for-profits. ASP-AM 3.05 Personnel know and follow an appropriate code of ethics in making decisions and fulfilling their professional responsibilities. Research Note: The National AfterSchool Association (NAA) developed a Code of Ethics that outlines the ethical responsibilities after school professionals have towards children, families, and communities. For more information about accessing the NAA Code of Ethics, please see the ASP-AM Reference List. Page 11

12 ASP-AM 4: Research Protections A program that participates in or permits research involving children and youth or their families: a. ensures that all research is conducted in accordance with applicable legal requirements; b. has a mechanism to review and approve or deny research proposals; c. establishes that children and youth and their parents or legal guardians have the right to refuse to participate without penalty; d. informs children and youth and their parents or legal guardians about the nature and purpose of the research, and any possible risks or discomfort; e. obtains consent forms signed by research participants and their parents or legal guardians; and f. guarantees protection of research participants' identity and confidentiality. NA The program does not participate in or permit research involving children and youth or their families. Table of Evidence Self-Study Evidence - Human subject research policy and procedures On-Site Evidence - Informed consent forms for research activities - Mechanism to review research proposals On-Site Activities - Interview: a. Program Administrator b. Site Director Page 12

13 ASP-AM 5: Financial Planning and Management Positive financial outcomes are achieved through sound financial planning, management, and oversight. Table of Evidence Self-Study Evidence - Program budget for the current fiscal year - Budget planning procedures/process - Internal financial control procedures - Audit and management letter, if applicable On-Site Evidence - Documents and reports that demonstrate budget planning - Financial records - Analysis of financial performance On-Site Activities - Interview: a. Program Administrator b. Site Director ASP-AM 5.01 An annual operating budget: a. supports the program's mission and goals; b. serves as a plan for managing the program's financial resources; and c. includes a statement of income and expenditures. Interpretation: For example, it may be appropriate for the financial plan to include budgets for payroll, staff development, activities, materials, supplies, equipment, and food. ASP-AM 5.02 The program implements a financial record keeping system for revenues and expenses, and records are kept up-to-date and balanced monthly. Interpretation: Accounting practices and procedures should address cash, Page 13

14 checks, and any other accounts, and should call for prompt, accurate, and complete recording of revenues and expenses; timely payment of financial obligations; and disbursement and receipt of monies. Examples of ways programs may demonstrate that records are kept up to date include: reconciling the bank statement and subsidiary records to the general ledger; posting cash receipts and disbursements in a timely manner; updating the general ledger on a monthly basis; and having the bank reconciliation reviewed by at least two personnel, one of whom is not involved in maintaining the accounting records. ASP-AM 5.03 The program regularly evaluates its financial status. Interpretation: Examples of relevant factors to consider during the evaluation of financial status include: financial capacities and resources (including assets and revenues); resources needed to operate the program; financial risks and anticipated problems; and financial planning and funding alternatives. ASP-AM 5.04 The program establishes an internal financial control system that includes mechanisms for: a. review and approval by management and entities responsible for oversight; b. management or review by more than one person, when possible; c. assurance that management directives are carried out; d. prevention of error, mismanagement, or fraud; e. safeguarding and verification of assets; and f. segregation of duties to the extent possible. Interpretation: In the case of privately-held and owner-operated for-profits, the program's owners will be responsible for the review and approval referenced in element (a) of the standard. Page 14

15 ASP-AM 6: Risk Management and Review The program identifies and reduces potential loss and liability. Note: Many of the activities and practices addressed elsewhere in the standards, from file maintenance to emergency response preparedness, also contribute to effective risk prevention and management. Table of Evidence Self-Study Evidence - Risk prevention and management plan and/or procedures - Procedures for quarterly review of incidents, accidents, and grievances - Reports of incidents, accidents, and grievances (for the previous two quarters) - List of insurance policies with descriptions, amounts, and dates of coverage On-Site Evidence - Documentation of risk reviews, including risk management reports that include analyses and improvement action plans, as applicable - Current insurance policies - Documentation that the program: (1) provides a written description to personnel regarding its insurance types and coverage amounts, and (2) assumes legal assistance costs if applicable On-Site Activities - Interview: a. Program Administrator b. Site Director (FP) ASP-AM 6.01 At least annually, the program identifies potential operational risks and specifies ways to reduce or eliminate risks. Interpretation: If the program develops a risk management plan, the plan should be reviewed annually and updated as necessary. Examples of relevant areas to consider when reviewing risks may include: compliance with legal requirements, including licensing and mandatory reporting laws, fiscal accountability, and governance; insurance and liability issues; health and safety, including use of facilities; contracting practices and compliance; Page 15

16 staff training regarding areas of risk; volunteer roles and oversight; research involving program participants and other clients' rights issues; security of information, including client confidentiality; financial risk; fundraising; conflict of interest; employment practices; and interagency collaborations. (FP) ASP-AM 6.02 The program documents and conducts a quarterly review of incidents, accidents, and grievances related to: a. serious illnesses and injuries; b. facility safety; c. administering or storing medications; d. situations where a person was determined to be a danger to himself/herself or others; and e. activities or other practices that involve risk. (FP) ASP-AM 6.03 The program is adequately insured, and possesses a copy of its insurance coverage certificate. Interpretation: Examples of relevant types of insurance may include: general liability; automobile liability; workers' compensation; disability; fire and theft; medical; indemnification; professional liability; officer's or director's liability; property and casualty; malpractice; and bonding or other forms of employee theft insurance for those who sign checks, handle cash or contributions, or manage funds. Page 16

17 ASP-AM 7: Security of Information The program protects confidential and other sensitive information from theft, unauthorized use, damage, or destruction by: a. limiting access to authorized personnel on a need-to-know basis; b. maintaining paper records in a secure location; c. using firewalls, anti-virus and related software, and other appropriate safeguards; and d. backing up electronic data, with copies maintained off premises when possible. Interpretation: This standard addresses the security of all types of records, including files of children and youth and administrative, financial, and personnel records. The program should develop a system for storing files and records that best fits its needs and circumstances, and should implement the elements of the standard as appropriate to those needs and circumstances. For example, a program that does not maintain electronic data will not implement element (d) of the standard. Examples of ways to demonstrate that paper records are stored in a secure location include: locked file cabinets; a locked file room with limited access or a gatekeeper system whereby one person or a few people can unlock the file storage area or access the files themselves; or a system using a keypad or keys where only authorized individuals are given the keypad code or copies of the keys. Programs may also consider storing files above the ground floor if the program is located in an area prone to flooding, and using fireproof file cabinets, metal file cabinets, or sprinkler systems to protect against fire. Table of Evidence Self-Study Evidence - Information management procedures and guidelines On-Site Evidence No On-Site Evidence On-Site Activities - Interview: a. Program Administrator b. Site Director - Review system for maintaining and storing files and records Page 17

18 ASP-AM 8: Files of Children and Youth Files of children and youth contain accurate and sufficient information, and are properly maintained. Related: ASP-PS 2.03 Interpretation: In addition to supporting program operations, files are an important risk management tool. Well-maintained files can help shield the program from allegations of misconduct and negligence, while poorly-maintained files and improper documentation are a known liability. Table of Evidence Self-Study Evidence - Procedures for maintaining files - Policies and procedures for accessing files On-Site Evidence No On-Site Evidence On-Site Activities - Interview: a. Program Administrator b. Site Director c. Program Personnel - Review files of children and youth ASP-AM 8.01 The program maintains files for all children and youth. (FP) ASP-AM 8.02 Files of children and youth comply with all legal requirements and contain essential information, including: a. registration forms; b. emergency contact information; c. evidence of communication with parents or other family members; d. information about special needs, including medical needs, if applicable; e. copies of all signed permission or consent forms, including medication Page 18

19 permission forms and authorizations for pick up, if applicable; and f. accident report forms, if applicable. Related: ASP-PS 8.02 ASP-AM 8.03 Files of children and youth are maintained by authorized personnel and are: a. specific, factual, relevant, and legible; b. kept up to date; and c. signed and dated by personnel, where appropriate. Interpretation: Files and signatures can be paper, electronic, or a combination of paper and electronic. ASP-AM 8.04 Files of children and youth are maintained and disposed of in a manner that protects privacy and confidentiality. ASP-AM 8.05 Access to confidential files meets legal requirements, and is limited to: a. children and youth and/or, as appropriate, their parents or legal guardians or designated legal representatives; b. personnel authorized to access specific information on a "need-to-know" basis; c. auditors, contractors, and licensing or accrediting personnel, consistent with the program's confidentiality policy; and d. others who are permitted access, as applicable. Page 19

20 ASP-AM 9: Continuous Quality Improvement The program develops and implements a system for promoting continuous quality improvement. Related: ASP-PS 1 Interpretation: Continuous quality improvement is relevant to both how the program is run, and the outcomes the program promotes. Accordingly, it may be relevant to measure desired goals and outcomes in both domains, from staff preparedness and activity quality, to the personal development and academic progress of children and youth. Note: The process of implementing COA's After School Standards is one way of demonstrating that a program is working on continuous quality improvement. Table of Evidence Self-Study Evidence - Program goals and desired outcomes, along with a plan or description that addresses how the program plans to achieve these goals and promote these outcomes - Stakeholder survey instruments - Aggregate analyses of results - Improvement plans, if applicable - Long term plan - Detailed description or plan that outlines the program's CQI system/process On-Site Evidence No On-Site Evidence On-Site Activities - Interview: a. Program Administrator b. Site Director c. Program Personnel d. Children, youth, families, and other stakeholders ASP-AM 9.01 The program creates a culture that promotes excellence and continual Page 20

21 improvement, and focuses on promoting satisfaction and positive outcomes. ASP-AM 9.02 The program sets forth desired goals and outcomes that are aligned with its mission and merit ongoing monitoring. Note: As referenced in ASP-AM 2.01, the program should work with relevant stakeholders to establish desired goals as part of its long-term program planning efforts. ASP-AM 9.03 The program works with key stakeholders, including personnel, children and youth, families, and the community, to collect and analyze data relevant to desired goals and outcomes. Note: COA expects programs to use instruments that reflect their desired goals and outcomes. A program may choose to create its own instrument, or use an already-existing one. Administering the Questionnaires included in the After School Guidelines can also help programs to gather and analyze relevant data. ASP-AM 9.04 The program communicates findings and recommendations to key audiences and stakeholders, and makes any needed improvements. Interpretation: In some cases, the program may find it necessary and appropriate to develop and implement an improvement plan that includes goals, action steps, timetables, and resources (e.g., if findings indicate that personnel need more training). In other cases a plan may not be necessary (e.g., if findings indicate that children and youth would like to have apples at snack time instead of oranges, the program may simply choose to purchase apples instead of making a formal plan). Page 21

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