Transcript Document

Fiscal Responsibility Webinar
Title III
Stephanie English, Chief
Monitoring & Compliance Section
School Business Division
919-807-3686
[email protected]
ESL/Title III Consultants
Glenda Harrell
Joanne Marino
Ivanna Mann Thrower
[email protected]
[email protected]
[email protected]
Monitoring Indicators -- Fiduciary
Items Included:
 Student count documentation
 Budget, including Administrative costs
 Implementation of Activities
 Documentation of expenditures for
equipment, personnel, contracted services
 Supplement/Supplant (basic services
as well as assessments)
1.3: Annual Measurable
Achievement Objectives (AMAOs).
Guiding
Questions
Acceptable LEA
Evidence
Compliance
Indicator(s)
Rating
•Has the LEA met all three
AMAOs?
•Has the LEA followed its
improvement plan related
to two-year /or four-year
accountability provisions?
•LEA notification letters to
parents regarding LEA has
not met AMAOs, if
applicable.
Possible Documentation:
State content
assessments data
Documentation of
testing accommodations
Agendas from teacher
meetings where AMAOs
and related issues are
discussed
Rating:______
For a rating of ‘2’, list the
change(s) suggested to be
implemented.
For a rating of ‘1’, list the
action(s) required to be
taken to meet compliance
requirements.
3.1 Student Count
• Does the LEA have documentation of the count
of LEP Students?
– Explanation of the headcount procedures
Budget Issues
• Administrative Cost limitation
– 2% of current year allotment
– Purpose code 6200
– Indirect cost (8100-104-399)
• When is a budget amendment required?
When total of overspent lines is more
than 10% of approved budget
• Monitored via Budget vs. Expenditures
printout
Implementation of Activities
• Evidence that the LEA is implementing
required activities.
• Evidence that the LEA is implementing
activities that are supplemental (budget
reports, record of expenditures)
Questions
3.2 Title III expenditures /
equipment
• How do Title III expenditures meet federal
fiscal requirements?
• How does equipment benefit the Title III
program?
Equipment Documentation
• Governed by EDGAR 80.32
• Tagging and tracking of non-consumable items with a
useful life greater than one year
• Monitored via list of “federal” equipment
• Physical inventory at least once every two years;
evidence required
• Follow DPI’s Federal Equipment Disposition process
when removing items from inventory; keep approval
letters on file. (Form on web at
http://www.ncpublicschools.org/fbs/finance/federal/
under “Additional Information.”)
Personnel Documentation
• Also known as “Time & Effort”
documentation
• For employees paid with federal funds,
including tutors (but not subs)
• Semi-annual certifications for individuals
who work only on Title III activities
• Personnel Activity Reports (PARs) for
individuals who work on Title III and
something else
Time & Effort – additional
information
• Additional training info on web at
http://www.ncpublicschools.org/fbs/conferences/p
resentations/ ; see “Documenting Time & Effort”
under FBS Summer Conference 2008.
• Your finance staff is your first line of defense – all
federal programs must document time and effort.
• Compliance monitored by matching time & effort
documentation to payroll printouts.
• Quarterly reconciliation of PAR data to payroll
expense (typically the responsibility of finance
staff.
Invoices for Contracted Services
• Object code 311
• Invoices must be specific – who, what,
when, where, why
Additional documentation
• Internal Controls – LEA’s
policies/procedures for
purchasing/procurement, fixed assets, etc.
• Responsibility of finance office; Title III
staff should also be aware of the existence
of these policies.
Procurement – one additional note
• Suspension/Debarment
– Non-Federal entities are prohibited from
contracting with or making subawards
under covered transactions to parties that
are suspended or debarred or whose
principals are suspended or debarred.
• Debarred Vendors list – State and Federal
can be found at
http://www.doa.state.nc.us/pandc/
Questions
3.3 Supplement, Not Supplant
• What is the basic instructional program/service
provided to all students (e.g., to meet Lau
requirements)? How are Title III funds providing
activities/services that are supplemental?
• What funds is the LEA using to provide the basic
language instruction educational program for
LEP students?
• How has the LEA demonstrated that services
provided with Title III funds are in addition to
services that students would otherwise receive
from State, local or other Federal funds?
Supplement, Not Supplant
• What services is the LEA required by other
Federal, State, local laws or regulations to
provide?
• How has the LEA demonstrated that it is not
using Title III funds to provide services that it is
required to make available under State or local
laws or other Federal laws?
• How has the LEA demonstrated that it is not
using Title III funds to provide services that it
provided in the prior year with State, local or
other Federal funds?
3.3A Supplement, Not Supplant
Use of Funds to Administer ELP Assessments
• What funds other than Title III has the LEA used
to identify LEP students who may need
language services, including the development
of ELP screening or placement assessments?
• What funds other than Title III does the LEA use
to pay for the costs of administration, scoring or
reporting of ELP assessment, and materials or
equipment related to the administration of
annual ELP assessments?
Supplement, Not Supplant
Screening and Placement Assessments for LEP
Students [W-APT]
• What funds other than Title III does an LEA use
to develop and administer assessments to
identify LEP students and place them in basic
language programs?
Questions
Resources
Federal information:
OMB Circulars, EDGAR
http://www.ncpublicschools.org/fbs/finance
/federal/
Other:
• Debarred Vendors list –
http://www.doa.state.nc.us/pandc/
Contacts
Stephanie English, Chief
Monitoring & Compliance Section
919-807-3686
[email protected]
ESL/Title III Consultants
Glenda Harrell
Joanne Marino
Ivanna Mann Thrower
[email protected] [email protected] [email protected]
919-807-3866
919-807-3861
919-807-3860