Transcript TARGET Discovery Series: Discover How the Department of
AFP and Telework Program Review
Jeremy Buzzell and Robert Groenendaal
Requirements for Program Review The Handbook for the Discretionary Grant Process Section 5.3.2 Monitoring Policy It is ED’s policy to monitor active discretionary grants with a focus on technical assistance, continuous improvement, and attaining promised results. Monitoring a grantee shall continue for as long as ED retains a residual financial interest in the project, whether or not ED is providing active grant support.
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Requirements for Program Review Section 5.3.2 Monitoring Policy ED staff is to monitor each grantee to the extent appropriate so as to achieve expected results under approved performance measures, while assuring compliance with grant requirements. Existing requirements in EDGAR extend equally to all grantees and their partners.
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Requirements for Program Review Section 5.3.3 Monitoring Purpose Systematic and regular monitoring by ED staff of a grantee’s activities measures the project quality and progress, including strengths and weaknesses.
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Requirements for Program Review 1. A grantee’s project must: a) Conform to the grantee’s approved application and any approved revisions, as well as the effectiveness and quality of the project (Program Management); b) Progress against previously established performance measures (Performance Measurement); c) Adhere to laws, regulations, conditions of the grant, certifications and assurances (Compliance); and d) Manage Federal funds according to Federal cash management requirements, including expenditures of funds for authorized purposes (Fiscal Accountability).
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Requirements for Program Review • • • 2. Regular monitoring enables ED staff to provide customized technical assistance, appropriate feedback, and follow-up to help grantees to: Improve areas of need Identify project strengths Recognize significant achievements 6
Development of Program Review
• • • • • • • • Open forum in Denver Review of existing protocols ED training in auditing Developed proposals NATTAP Blog Teleconference of directors in September 2007 Refined proposals Internal review and approval of proposals 7
What we learned from the process . . .
• • • • • Proof of compliance should not be based on data alone.
Every grantee should be assessed the same way but can show compliance in its own way.
Grantees should not be compared to each other. Compliance should not be black or white.
Look for the positive as well as the negative.
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The result . . .
• Program Reviews allow for a holistic explanation of the program (through documents, data, and discussion).
• This explanation is done for peer reviewers and RSA.
• The peer reviewers and RSA answer a series of questions about the program to determine the extent of compliance.
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The effect . . .
• • • Pros Context is considered Focuses on what you can control • • • Appropriate to size and funding of program Cons Time-intensive (for all) Highly subjective Learning curve for RSA and grantees 10
Why this approach?
• • • • • • On-site reviews are not feasible.
RSA staff are limited and do not come from the field.
Data is not reliable.
Lack of basis for self-assessment.
Program continues to evolve.
One size fits all.
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Next Steps with Program Review
• • • • • • • Final drafts cleared by RSA.
Final drafts reviewed by Risk Management.
Official materials shared with AFP/Telework Programs.
Choose and notify first round of programs.
AFP/Telework Programs submit FY 2008 data.
Train third-party (peer) reviewers.
First peer review in January 2009.
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Role of Lead Agencies and Community Based Organizations in Program Reviews • • • • The LEAD AGENCY is being reviewed.
Participation from BOTH the Lead Agency and CBO is expected.
Participation of all personnel being paid using grant funds is required (see exception in the next bullet). Participation of the Certifying Representative is encouraged but not required.
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How are AFP/Telework Programs selected for review?
Random selection of an equal number of grantees in two categories: (1) Title III AFP/Telework grantees claimed by a Statewide AT Program as a state financing activity; OR (2) Title III AFP/Telework grantees not claimed by a Statewide AT Program as a state financing activity.
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How are AFP/Telework Programs selected for review?
• • Exceptions to random selection: • Recent major change in the AFP/Telework Program or State Plan for AT Recent major disaster RSA is concerned 15
How are AFP/Telework Programs selected for review?
• • 6 grantees per cycle (3 x 3) A “cycle” is a fiscal year (Oct. 1 to Sept. 30) • 9 weeks per grantee (some program reviews may overlap) • First year of program reviews: • Jan. 1 to Sept. 30 • Only 3-4 reviews 16
What happens when an AFP/Telework Program is selected?
• RSA notifies grantee in spring prior to next cycle.
• RSA and grantee negotiate 9-week window within next cycle.
• • RSA recruits third-party (peer) reviewers.
Grantee begins preparing for review.
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How does a grantee prepare for the review?
A review assesses two “Core Components” of grant implementation, each in a slightly different way.
• Core Component 1 – Program Management • Core Component 2 – Program Performance 18
Core Components of Program Review
Elements of Program Management • Fiscal Management • Contract Oversight • Personnel Management Elements of Program Performance • Emphasis and Expansion of Consumer Choice and Control • Timely and Equitable Access to Financial Assistance • Capacity to Continue on a Permanent Basis 19
Program Management
• • • The review of Program Management verifies that a grant is managed efficiently and appropriately in accordance with title III, the NFP, EDGAR, and OMB Circulars, as applicable. This includes: Fiscal Management Contract Oversight Personnel Management 20
Fiscal Management
EDGAR requirements: • Fiscal control and accounting procedures to insure proper disbursement of and accounting for Federal funds; controls and procedures adequate to establish that such funds have not been used in violation of applicable statutes. • Records that fully show the amount of funds under the grant, how the grantee uses the funds, the total cost of the project, the share of the cost provided by other sources, and other records to facilitate an effective audit.
• Audits in accordance with OMB A-133.
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Fiscal Management
Title III or NFP requirements: • Assurance that the grantee will provide the non-federal share of the cost of the program in cash, from state, local, or private sources.
• Assurance that the grant funds will be used to supplement and not supplant other federal, state, and local public funds.
• Assurance that the grant funds will be placed in a permanent separate account and identified and accounted for separately from any other fund.
• Assurance that the funds are administered, expended, and invested in accordance with title III or the NFP.
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How to prepare for a review of Fiscal Management
• • Submit to RSA: Expenditure report.
Proof of title III or NFP fiscal management assurances.
• Approved indirect cost rate agreement/cost allocation plan or questionnaire provided by RSA (applies to both Lead Agencies and Community Based Organizations.) • Copies of most recent audit reports or questionnaire provided by RSA (applies to both Lead Agencies and CBOs).
(In addition, RSA will look at ED 524Bs and GAPS records.) 23
Expenditure Report
• 1 for Lead Agency to administer the grant, 1 for CBO to implement the program.
• From the most recent federal fiscal year.
• There is no “format”, but RSA must be able to understand the reports.
• Show use of all federal and match funds as well as income from interest, investments, loan repayments, and other sources.
• Show use of funds used for administration of the program separately from the amount used for loans and other program purposes.
• Show the amount of funds used for indirect costs.
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Expenditure Report
• What RSA is looking for: • Existence, quality, and legitimacy of report Permanent separate account • Compliance with indirect cost limits 25
Proof of Fiscal Management Assurances What RSA is looking for: • The sources, amounts, and appropriateness of match provided for all grants for the AFP/Telework Program. • The Lead Agency’s and CBO’s internal controls that ensure all principal and interest from the permanent separate account (a) support only AFP/Telework activities and (b) supplement and do not supplant other federal, state, and local public funds expended to provide financial loans.
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Indirect Cost Rates
What RSA is looking for: • Existence of agreement • Appropriate kind of agreement • Handling of indirect costs between Lead Agency and CBO • Amount of indirect will be seen in expenditure reports 27
Audits
What RSA is looking for: •
An audit was done (if required)
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Findings of the audit
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Resolution of findings
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ED 524B Forms and GAPS Records What RSA is looking for: • Completeness and accuracy of financial reports 29
Contract Oversight
• • • EDGAR requires grantees to: Directly administer or supervise the administration of each project.
Have procedures for providing TA, evaluation and for performing other administrative responsibilities necessary to ensure compliance.
Monitor activities to assure compliance with applicable Federal requirements and that performance goals are being achieved.
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Contract Oversight
• • • Grantees are required to enter into a contract with a CBO or group of CBOs that has individuals with disabilities involved in the organizational decision-making to administer the AFP/Telework Program. The contract must: Include a provision requiring funds be administered consistent with title III or the NFP.
Include any provision the Secretary requires concerning oversight and evaluation of federal financial interests.
Require the CBO(s) enter into a contract with commercial lending institutions or organizations or state financing agencies.
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How to prepare for a review of Contract Oversight
Submit to RSA: • A dated copy of the grantee’s most recent contract with the CBO 32
How to prepare for a review of Contract Oversight
What RSA is looking for: • Appropriate oversight to protect Federal interests and ensure implementation • Relevant to title III or the NFP 33
Personnel Management
• • • • OMB Circulars: Compensation to personnel must be reasonable.
Charges to Federal awards for salaries and wages are based on documented payrolls. Charges for salaries and wages of employees who work solely on a single Federal award are supported by periodic certifications.
Charges for salaries and wages of employees who work on multiple activities are supported by personnel activity reports.
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How to prepare for a review of Personnel Management
Submit to RSA either: (A) Position descriptions of record for those being paid with grant funds and personnel activity reports for them; OR (B) Synopsis for key personnel describing his or her role and responsibilities associated with the grant.
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Personnel Management
What RSA is looking for: • Appropriate number of personnel • Appropriate time commitments of personnel • Appropriate duties for personnel 36
How to prepare for a review of Program Management
• • • • Submit all the previously described documents.
RSA reviews the documents.
RSA discusses the documents via conference call (the grantee is responsible for bringing together the appropriate parties).
RSA uses this information to answer questions about program management.
• Yes/no with explanation.
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Questions about Program Management 1. Has the grantee obtained its full matching funds from appropriate sources? If not, does the grantee have a plan for obtaining the remaining match funds? 2. Does the grantee account for grant funds accurately and completely in accordance with EDGAR? 3. Does the grantee use grant funds only for purposes under, and within the limitations of, title III or the NFP, as applicable?
4. Does the grantee comply with indirect cost requirements?
5. Does the grantee comply with audit requirements?
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Questions about Program Management 6. Does the grantee exercise appropriate fiscal and performance oversight of the AFP/Telework Program through its contract with the CBO? If not, does the Lead Agency have a plan for improving its oversight?
7. Is the contract structured to meet the requirements and intent of title III of the NFP, as applicable? If note does the Lead Agency have a plan for changing its contract to make it more consistent with title III or the NFP, as applicable?
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Questions about Program Management 8. Does the AFP/Telework Program have an appropriate number of staff to implement the grant? If not, does the Lead Agency have a plan for changing its contract to make it more consistent with title III or the NFP, as applicable?
9. Do the Lead Agency and CBO distribute the time of their personnel appropriately to implement the grant based on their responsibilities? If not, does the grantee have a plan to distribute time more appropriately?
10. Do the Lead Agency and CBO use grant funds to support only personnel with responsibilities germane to the grant?
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Assessing Compliance of Program Management
There is no overall rating of compliance.
For each element of Program Management, a grantee will receive 1 of 3 ratings: • Compliant • In Need of Improvement • Fails to Substantially Comply 41
Assessing Compliance of Program Management
The rating is based on how RSA answers the questions: • Initial question: Does the AFP/Telework Program have an appropriate number of staff to implement the grant? • Subquestion: If not, does the grantee have a plan for adjusting the number of staff? 42
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Assessing Compliance of Program Management
If the answer to the initial question is “Yes” – the grantee is rated as compliant.
If the answer to the initial question is “No” – the rating depends on the answer to the subquestion.
If the answer to the subquestion is “Yes” – the grantee is rated as in need of improvement.
If the answer to the subquestion is “No” – the grantee is rated as failing to substantially comply.
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Assessing Compliance of Program Management
Questions for which “needs improvement” doesn’t apply: • • • • • Does the grantee account for grant funds accurately and completely in accordance with EDGAR? Does the grantee use grant funds only for purposes under, and within the limitations of, title III or the NFP, as applicable?
Does the grantee comply with indirect cost requirements?
Does the grantee comply with audit requirements?
Does the grantee use grant funds to support only personnel with responsibilities germane to the grant? 44
Assessing Compliance of Program Management
The onus is on the grantee to present evidence/plan sufficient to get to a “yes” answer.
• RSA will ask questions or provide examples of sufficient evidence, if needed.
• Grantee likely will know their status before the conversation is over.
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Program Performance
The review of Program Performance assesses whether the AFP/Telework Program is implementing its grant in accordance with title III or the NFP, as applicable. This includes: • Extent to which the program emphasizes and expands consumer choice and control.
• Extent to which program provides timely and equitable access to financial assistance.
• Extent to which the program can continue on a permanent basis. 46
Third-Party Reviewers
• • Peer reviewers participate in the review of Program Performance: • 3 current or former program directors (or position with similar duties).
At least 1 with prior review experience on each team.
Trained, paid volunteers from a standing pool.
• No reviewers from NATTAP or NISAT.
• Participation is not anonymous, but conclusions are not attributed to individual reviewers.
Peer reviewers learn about the program through review of documents, looking at data, and discussion on teleconferences/webinars.
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How to prepare for a review of Program Performance
Submit to RSA: • • Narrative explaining how consumer choice and control is emphasized and expanded.
Copies of administrative policies and procedures manuals. • • Copies of lender agreement(s), investment plan, if applicable, and narrative or plan for sustainability. Reviewers already will have AFP/Telework Program data.
There is no prescribed format for these but must be accessible.
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How to prepare for a review of Program Performance
• • Develop teleconference/webinar presentations that serve as a virtual on-site visit to your program.
• Length, format, and content of presentation are up to the program.
• The “presenter” during a teleconference or webinar is up to the program. Need to be accessible.
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Emphasis and Expansion of Consumer Choice and Control
Title III or NFP requirements: • Assurance that, and information describing the manner in which, the grantee will expand and emphasize consumer choice and control. 50
How to prepare for a review of Consumer Choice and Control
Submit to RSA: • A narrative describing how individuals with disabilities are involved in organizational decision-making at all organizational levels to administer the loan program.
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How to prepare for a review of Consumer Choice and Control
What RSA is looking for: • Appropriate emphasis and expansion of involvement in organizational decision making by individuals with disabilities • The grantee should also be prepared to discuss consumer choice and control during webinars/teleconferences 52
Timely and Equitable Access to Financial Assistance
• Title III or NFP requirements: (1) (2) (3) Assurance that the grantee enter into a contract with a CBO that has policies and procedures to: Review and process requests for financial assistance in a timely manner.
Ensure equitable access to all consumers for which financing is requested through the program.
Ensure consumer-controlled oversight of the program. 53
How to prepare for a review of Timely and Equitable Access to Financial Assistance Submit to RSA: • A dated copy of its most recent revised and adopted AFP/Telework policies and procedures manual.
• A dated copy of its most recent revised and adopted lender agreement(s).
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How to prepare for a review of Timely and Equitable Access to Financial Assistance What RSA is looking for: • Appropriate access to financial assistance.
• The grantee should also be prepared to discuss how the program assures the review and process of financial loans in a timely manner and describe the flow of an application for an AFP/Telework loan during teleconferences or webinars. 55
Capacity to Continue on a Permanent Basis
• Title III or NFP requirements: (1) (2) (3) Assurance that the AFP/Telework Program will: Continue on a permanent basis.
Invest the funds within the permanent separate account in low-risk securities.
Administer the funds with prudence, discretion, and intelligence.
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How to prepare for a review of Capacity to Continue on a Permanent Basis Submit to RSA: • A dated copy of its investment plan, if applicable, or narrative describing how loan program funds are invested.
• A copy of its investment portfolio.
• A dated copy of the its plan for sustainability, if one has been developed, or narrative explaining how the program will continue on a permanent basis.
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Investment Plan
What RSA is looking for: • Appropriate investment of AFP/Telework Program funds in the permanent separate account.
• The grantee should also be prepared to discuss the implementation and regular revision of the AFP/Telework Program’s investment plan.
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Sustainability Plan
What RSA is looking for: • Appropriate implementation of strategies for sustaining the AFP/Telework Program.
• The grantee should also be prepared to discuss how the program is implementing a plan for sustainability during a webinar/teleconference.
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How to prepare for a review of Program Performance Based on documents, data, and discussion, third party reviewers respond to a series of questions: • Yes/no with explanation.
• Evidence can come from any source of the review.
• Getting a “yes” answer does not depend on an AFP/Telework Program having any particular • structure or type. A “no” answer does not automatically mean a grantee is out of compliance.
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Questions about Program Performance 1. Is there evidence that individuals with disabilities are involved in the administrative decision-making of the AFP/Telework Program?
a) If not, does the grantee provide justification for the current level of involvement of individuals with disabilities in the administrative decision-making of the loan program?
b) If not, does the grantee have a reasonable plan for improving the involvement of individuals with disabilities in the administrative decision-making of the loan program?
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Questions about Program Performance 2. Is there evidence that the AFP/Telework Program emphasizes and expands consumer choice and control? a) If not, does the grantee provide justification for why the current level of consumer choice and control is appropriate?
b) If not, does the grantee have a reasonable plan for improving its emphasis and expansion of consumer choice and control?
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Questions about Program Performance 3. Is there evidence that the policies and procedures of the AFP/Telework Program make it accessible to consumers regardless of type of disability, age, income level, type of AT device, equipment, or service for which financing is requested through the program? a) If not, does the grantee provide justification for why the program is not accessible to all individuals with disabilities in the State?
b) If not, does the grantee have a reasonable plan for improving the accessibility of the program?
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Questions about Program Performance 4. Is there evidence that the structure and practices of the AFP/Telework Program make it possible to meet the needs of individuals in most areas of the State? a) If not, does the grantee provide justification for why the areas reached in the State are sufficient?
b) If not, does the grantee have a reasonable plan for improving their ability to reach consumers in other areas of the State?
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Questions about Program Performance 5. Is the lender agreement structured to promote the goals of the AFP/Telework Program? a) If not, does the grantee provide justification for the structure of the current lender agreement?
b) If not, does the grantee have a reasonable plan for improving the lender agreement? 65
Questions about Program Performance 6. Does the AFP/Telework Program administer its funds with prudence, discretion, and intelligence? a) If not, does the grantee provide justification for why the program administers its funds in the current manner?
b) If not, does the grantee have a reasonable plan for improving the administration of program funds? 66
Questions about Program Performance 7. Does the AFP/Telework Program invest funds in low risk securities in which a regulated insurance company may invest under the law of the State? a) If not, does the grantee provide justification for why the program invests in the manner it currently does?
b) If not, does the grantee have a reasonable plan for investing program funds more appropriately? 67
Questions about Program Performance 8. Does the AFP/Telework Program have an investment plan that is implemented and revised regularly?
a) If not, does the grantee provide justification for why the program has not implemented an investment plan that is reviewed regularly?
b) If not, does the grantee have a reasonable plan for the implementation and regular revision of an investment plan? 68
Questions about Program Performance 9. Is the AFP/Telework Program implementing appropriate strategies for sustainability?
a) If not, does the grantee provide justification for why the program is not implementing appropriate strategies for sustainability?
b) If not, does the grantee have a plan for sustainability that could be implemented? 69
Assessing Compliance of Program Performance
There is no overall rating of compliance.
For each element of Program Performance, a grantee will receive 1 of 3 ratings: • Compliant • In Need of Improvement • Fails to Substantially Comply 70
Assessing Compliance of Program Performance
The rating is based on how peer reviewers answer the questions: • Initial question: Is there evidence that the structure and practices of the AFP/Telework Program makes it possible to meet the needs of individuals with disabilities in most areas of the State? • Subquestion 1: If not, does the grantee provide justification for why the areas reached by the program in the State currently are sufficient? • Subquestion 2: If not, does the grantee have a reasonable plan for improving the capacity of the program to reach individuals in more areas of the State? 71
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Assessing Compliance of Program Performance
If the answer to the initial question is “Yes” – the grantee is rated as compliant.
If the answer to the initial question is “No” – the rating depends on the answer to the subquestions.
If the answer to subquestion 1 is “Yes” – the grantee is rated as compliant.
If the answer to subquestion 1 is “No” – the the rating depends on the answer to subquestion 2.
If the answer to subquestion 2 is “Yes” – the grantee is rated as in need of improvement.
If the answer to subquestion 2 is “No” – the grantee is rated as failing to substantially comply.
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Assessing Compliance of Program Performance
The onus is on the grantee to present evidence/plan sufficient to get to a “yes” answer.
• RSA and third party reviewers will ask questions or provide examples of sufficient evidence if needed.
• Grantee likely will know their status before the conversation is over.
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Program Data
• AFP/Telework Program data will not determine compliance.
• Data will be discussed during a teleconference or webinar and reflected in the report: (1) Grantees strengths and areas in need of improvement when it comes to data; and (2) How the grantee is learning from and using its data.
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Program Data
Data collection infrastructure: • How the data is collected.
• How the data is checked.
• Strengths and areas in need of improvement.
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Program Data
• • • Understanding your data: How the nature of your state and structure of your program influence the data.
What your data tells you about the program and how it influences implementation.
Strengths and areas in need of improvement. 76
Assessing Compliance of Program Performance
• • • • • Activities of peer reviewers: Read documents.
Participate in teleconferences/webinars.
Complete review forms (answer questions).
Meet as a group with RSA to discuss results.
Finalize review forms and submit to RSA.
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Concluding the Program Review
• RSA compiles Program Management and Program Performance information into a comprehensive report.
• Review of both AFP and Telework grants, if applicable, are consolidated into one report summarizing findings, recommendations, and highlighting differences. • RSA shares report with grantee (on-site available).
• RSA finalizes and receives approval of report.
• Grantee may respond to report in writing.
• Report and response posted on ed.gov.
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Concluding the Program Review: Report Introduction Executive Summary Review of Program Management • • • Fiscal Management Contract Oversight Personnel Management Review of Program Performance • Emphasis and Expansion of Consumer Choice and Control • • Timely and Equitable Access to Financial Assistance Capacity to Continue on a Permanent Basis Data Conclusion Appendices 79
Outcomes of a Review
Compliant = No action necessary.
In Need of Improvement = AFP/Telework grantee implements its own plan for improvement.
Failure to Substantially Comply = • Prior to imposing sanctions, RSA and grantee will negotiate corrective action plan. • Possible referral for TA from NATTAP or NISAT.
• Failure to implement corrective action may result in sanctions. 80
Timeline
Pre-review Prior spring = Notify grantee Prior to review start = Agree on time for review, find reviewers, grantee prepares and submits documents, grantee prepares for teleconferences/webinars.
Review 2 weeks – Read documents, Program Management call with RSA 2 weeks – Teleconf./Webinars 2 weeks – Reviewers complete forms and meet with RSA 3 weeks – RSA develops draft report and shares with grantee Post-review Finalize report and share Grantee has two weeks to write response ED approval of report and posting on ed.gov
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Other Information
• Read the Program Review Manual.
• This is a work in progress.
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