financial and programmatic monitoring esea/act 807 acsip

FINANCIAL AND PROGRAMMATIC MONITORINGESEA/ACT 807

ACSIPArkansas Department of Education

Division of Public School Accountability

FEDERAL & STATE MONITORING UNIT

John Hoy, Assistant CommissionerWillie Morris, Director

Wes Whitley, CoordinatorBarbara Means, MonitorCharles Nowak, MonitorWendy Reed, Monitor

ACT 807 STATE OF ARKANSAS

86TH GENERAL ASSEMBLY REGULAR SESSION, 2007

2.0 Purpose:

2.01 - To expand monitoring and implementation of school improvement plans (i.e., ACSIP) by the Department of Education

2.02 - To monitor the use of “Instructional Facilitators” 2.03 - To ensure statutory compliance 2.04 - To provide technical assistance

PURPOSE OF MONITORING –THE DEPARTMENT WILL PERIODICALLY MONITOR EACH LEA (DISTRICT) AND SELECTED SCHOOLS TO DETERMINE IF THE DISTRICT IS IN COMPLIANCE REGARDING THE IMPLEMENTATION OF ACSIP. A TEAM OF MONITORS SHALL CONDUCT A SITE VISIT TO: Determine whether the evaluation conducted by the

public school/LEA was conducted properly; Assess the areas in which the school or LEA needs to

revise its plan; Review the school/LEA’s performance during the

preceding two years, including the documented academic performance of its students;

Review the use of public school funding under the Public School Funding Act of 2003, Ark. Code 6-20-2301 et. Seq. (i.e., Categorical Funding).

MONITORING CYCLE

6 year cycle

45 Districts Scheduled2013-2014 School Year (Oct –

May)

PRIOR TO ON-SITE VISIT - The LEA will receive the following:

An e-mail/phone call announcing the visit Registered Letter of Notification – This letter will

include a list of schools that will be monitored Monitoring Guide (checklist) and Protocol Confirmation of dates and schedule of events

The LEA (Superintendent or designee) will ensure that all documentation is organized, readily available, aligned to the monitoring guide and consistent by section and subsection.

Contact us if you have any questions or concerns.

VISIT Start Time 9:00 a.m. Visit conducted at central office All documentation (school/district) will be examined at the

central office Monitors will interview LEA staff and review evidence to verify

Federal/State compliance Staff to have at meeting:

Federal Program Coordinator Principal or designee of selected schools (found in the Notification

Letter) Parent Involvement Coordinator Homeless Liaison ALE-ELL Coordinator Neglected Part A Program Coordinator Other Relevant Staff

School visits conducted (as applicable)

EXIT CONFERENCE WITH LEA An informal meeting with LEA designees

will be held to summarize:Monitoring activitiesPotential findingsRecommendationsTimelines for developing the monitoring

report

POST-VISIT PROTOCOL Written Preliminary Monitoring Report

20 Days (from the date of the Exit Conference)

LEA Response 30 Days (from receipt of SEA Preliminary

Report)

Final Report from ADE 60 Days (from the date of the Exit Conference)

PROGRAMS TO BE MONITORED - State Programs

Federal Programs

Alternative Learning Environments (ALE)

National School Lunch Act (NSLA)

English Language Learners (ELL)

Professional Development (PD)

Title I Title IIA Title III Title VI (State &

Federal) Title X

FINANCIAL AND PROGRAMMATIC MONITORING GUIDE -

SECTION I: PROGRAM PLAN AND EVALUATION

Legal requirement(s) Compliance indicator(s) Samples of potential evidence

I-1D

The local education agency (LEA) has approved a comprehensive school improvement plan, which includes appropriate program goals, evaluations, budgets and assurances. The LEA ensures that all required parties are consulted in the planning, development, and implementation of the programs and activities as indicated in the ACSIP. §1112(d)(1), §3113(b),§4115(A)(1), §5133(b)(1)Edgar 80.42(a) ), §2122(b), §3113(b),§4115(A), §5133(b)

1. Does the evidence verify that the LEA utilized a planning team of stakeholders in the development of the Arkansas Comprehensive School Improvement Plan (ACSIP)?

Minutes, Sign-in sheets (including position/title), Agendas

Documentation of Board

approval (Board minutes and signed statement of assurance)

I IP PI NI NA

Legal Requirement(s)(Rules, Laws and Statutes)

FINANCIAL AND PROGRAMMATIC MONITORING GUIDE (CONT.) -



I-1D






I IP PI NI NA

Compliance Indicator(s)

(The answers to these questions will determine the level of compliance)




I-1D






I IP PI NI NA

Monitoring Guide KeyImplemented (I) – Compliance with all indicatorsImplementation in Progress (IP) – Scholastic Audit and New Interventions/ActionsPartially Implemented (PI) – RecommendationsNot Implemented (NI) – FindingsNot Applicable (NA)




I-1D






I IP PI NI NA

Potential Evidence(Documentation of the Compliance

Indicators)




I-1D






I IP PI NI NA

The Financial and Programmatic Monitoring

Guide Section Titles and Numbers




I-1D






I IP PI NI NA

District and/or School(where the record keeping should

originate)

COMMON FINDINGS AND EXAMPLES- Supplement vs. Supplant CSR Incomplete Planning Meeting Evidence

It is recommended that all meetings should be accompanied with agendas, sign-in sheets denoting names and positions, and minutes for each meeting. In addition, meeting agendas in which federal programs planning is conducted must be unique to the entitlement. Meeting agendas which only describe ACSIP as the topic, fail to meet the requirements necessary for specific planning requirements of entitlement law. Meetings should reflect that topics such as Title I Schoolwide, data, program research etc. are being discussed.

Adequate evidence that parents have been involved in entitlement program planning All required planning meetings involving parent participation should be accompanied with

sign-in sheets denoting the parent names. It is a requirement of federal funds grantees that parents participate in all stages of program planning and that documentation is archived by the LEA to support parent involvement.

COMMON FINDINGS AND EXAMPLES CONT’D Homeless list

FINDING (NI): A review of LEA records indicated that the LEA had no policy, procedures, or guidelines for identifying, enrolling, and addressing the educational needs of homeless children and youth. It is noted that the LEA had made a fund reservation of Title I, Part A funds for Homeless. CORRECTIVE ACTION: The LEA must remit to the Office of Federal and State Monitoring copies of procedures and guidelines for identifying and enrolling homeless children. These policies must provide assurance that homeless children have access to activities and programs that address their educational needs and do not inhibit comparable services to students so identified.

ADE Schoolwide approval letters FINDING: On the day of the visit, the LEA was cited with a finding of partially implemented (PI)

for Section II-1. During a review of the LEA’s documentation, it was discovered that the district did not have a Schoolwide approval letter from the ADE. Currently the LEA is operating Title I Schoolwide Projects at both of its campuses. CORRECTIVE ACTION: The LEA must contact the Federal Programs Unit of the ADE and secure the necessary approval letter for the operation of a Title I Schoolwide Project. Once this authorization letter has been received, a copy of it must be forwarded to the Federal and State Monitoring Unit. This authorization will verify that the Federal Programs Unit of the ADE has reviewed all relevant requirements pertaining to the LEA’s status as a Title I schoolwide and will satisfy aforementioned area of non-compliance.

COMMON FINDINGS AND EXAMPLES CONT’D Excessive district fund reservations

The district ACSIP as written gives the false appearance of reservation of funds at the district level. The district is advised to allocate all supplemental funds to schools and only place in the district ACSIP an amount that is reasonable and necessary to administer the program.

Incomplete equitable services documentation The District has made contact with four Private Schools to notify each of the rights of

students and teachers to benefit from federal entitlement funds; however, the contact was not timely. Each of the four private schools was contacted by certified mail on August 23, 2011. Private schools choosing to participate were therefore unable to complete the consultations necessary to begin an educational program in a timely fashion. The LEA was counseled regarding the timeliness of their responsibility in contacting private schools and will ensure that in the future the notices to private schools will be conducted each spring in order that sufficient time will exist to adequately consult and plan for programming.

COMMON FINDINGS AND EXAMPLES CONT’D School level compliance review Unallowable expenditures (peer review)

It is recommended that the district establish (or re-visit) a systematic internal control process for allowable costs and programmatic restrictions for entitlement funds. As the grant recipient, it is the district’s responsibility to review all entitlement expenditures for allowable uses prior to submission of the ACSIP to the SEA.

A review of Title I expenditures in the district plan revealed unallowable expenditures for administrative conferences. The district was advised to reimburse Title I for the amount of these conferences, and pay for those conferences with an allowable funding source.

The LEA must continue to review actions in the ACSIP that contain NSLA funds. NSLA funds are restricted use funds and all expenditures are subject to the restrictions found in the Rules for Special Use Funding (revised June 2011).

During the on-site review of the Expenditure Audit Trail for Title I Funds it was observed that Title I funds had been used to reimburse expenditures for Quiz Bowl activities. The LEA was informed at that time that the use of Title I funds for this activity is not allowable.

CLOSING - The six-year monitoring list was modified to make sure that no

district would have a Standards Monitoring and a Federal/State Monitoring within the same school year.

The items listed below were revised and released in a Commissioner’s Memo and are posted on the ADE website:

Six-Year Monitoring Schedule 2013-2014 Monitoring Schedule 2013-2014 Monitoring Protocol 2013-2014 Monitoring Guide 2013-2014 Training PowerPoint 2013-2014 Training Schedule 2013-2014 Training Agenda

CONTACT INFORMATION - Willie Morris (501)682-4472

[email protected] Wes Whitley (501)682-4389

[email protected] Charles Nowak (501)682-5295

[email protected] Barbara Means (501)682-2259

[email protected] Wendy Reed (501)682-1188

[email protected]

RESOURCE INFORMATION

Please see the new Arkansas Dept. of Ed Website for additional information.

Use the following links:

ADE DivisionsPublic School Accountability

Federal/State Monitoring

financial and programmatic monitoring esea/act 807 acsip

Documents

school year

public school funding

use of public school

lea district

monitoring cycle6 year

lea staff

lea designees

acsip financial