perkins 101 2016 cte interns. phouang hamilton office of superintendent of public instruction career...

PERKINS 1012016 CTE Interns

PHOUANG HAMILTON

Office of Superintendent of Public InstructionCareer and Technical [email protected]

360-725-6245

Jill Pilbro, Office AssistantCareer and Technical Education

[email protected]

Monica Trabue, Office AssistantCareer and Technical Education

[email protected]

mailto:[email protected]



DISCLAIMER

The opinions and guidance expressed in this training/workshop is for educational and information purposes only. I use reasonable efforts to insure that information provided herein is accurate and is the most current information available at the time of training. However, districts are urged to contact the CTE program office directly via email to verify its accuracy prior to making costly programmatic decisions.

PERKINS IV

• There has been some type of CTE/Vocational program funded since 1917 (Smith Hughes Vocational Act)

• In terms of raw dollars, Perkins is not a major educational grant (WA – 20.6M)

• Perkins, the largest grant targeted at secondary education

PERKINS 101

• Perkins is “split funded” between the secondary (high schools) and the postsecondary (community colleges) programs

• The average split nationally is 59.24% secondary and 38.89% postsecondary

• The splits are determined by each state• WA –

• 56% Postsecondary

• 44% Secondary

PERKINS – In Trouble?

The President’s Administration has agreed to the:• Elimination of Tech Prep (Title II of Perkins)

• Continual reduction in Perkins funds to States

Continual funding cuts to States and Locals will require everyone to plan on the conservative side

• THE BASICS

PERKINS

• YOUR LIBRARY

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The Bible

How does Perkins fit in CTE programs?

• It’s a Federal formula program meant to improve and enhance existing CTE programs

• The Perkins act was originally authorized in 1984; the most recent authorization is Perkins IV in 2006

• District funding allocations are based on Federal census and poverty data

• Perkins is federal money – The state (OSPI) and local grantees (districts) must follow the Education Department General Administrative Regulations

PERKINS 101

• State Allocations Are Census Based

• In-State Allocation – Secondary• District census data

• 70% based on school aged kids 5-17 census count at or below poverty guidelines

• 30% total district census data(Section 131 (a)(b))

PERKINS 101

GETTING STARTED

LEAs – Your District’s Perkins 5-Year Application Plan(iGrants form package 214, 215, or 274)

Pitfalls – • Don’t just write “something” to get the money• Local applications –

• Recipients, follow it or amend it

• Check your progress and budget at least mid-grant and 90 days before your end date

PERKINS 101

DISTRICT PERKINS APPLICATION PLAN -

• The law is just the minimum requirements

• States can add more requirements, set parameters, restrictions, etc..

• Prioritize uses of funds

• Connect accountability to uses of funds

PERKINS 101

PRIVATE SCHOOL PARTICIPATION -

• Secondary students attending nonprofit private schools can participate in public CTE programs

• Consultation with nonprofit private schools regarding the private school participation is a must

PERKINS 101NOT AN ENTITLEMENT GRANT –

• You have to have one or more programs of sufficient size, scope and quality to warrant the receipt of grant funds

• If your allocation is $15k or less, locals will need to either – • Request and receive a waiver (page 3 of the local Perkins

application plan)Or• Enter into a consortium agreement with another district(s) (form

package 214)

Waivers – Locals need to be able to justify the waiver

PERKINS IV

Waivers – Districts need to be able to justify the waiver• The district has a viable program, and

• Districts are not able to enter into a consortium due to:

• Rural isolation

• No one within a reasonable distance wishes to enter into a consortium

(Section 131 (c) (1-2): Section 132(a)(3-4): Section 132 (C): Section 132 (C)(2))

PERKINS 101LEARN THE TIMELINE

• States – Without an approved State Plan or a Plan judged to be in a “substantially approvable form” a state may not obligate Perkins funds

• Recipients – Are in the “same boat” – they can’t obligate their new grant funds until their application is “substantially approvable”…

EDGAR 34 CFR §76.703(d)EDGAR 34 CFR §76.708(a)

Example – A recipient’s new fiscal year begins July 1st. On July 6th, in anticipation of school starting, the district buys some badly needed CTE equipment . Their application for the new school year is substantially approved two days later on July 8th. This district may not use Perkins funds to pay for this equipment – even if the delay is the state’s fault.

PERKINS 101

PERKINS 101

Your district’s Perkins application is approved – you’re ready to go and spend your money! What can I spend $$$ on?

Follow your approved Perkins 5-Year Application Plan

PERKINS 101GENERAL TEST OF ALLOWABILITY

• Fits with your application

• Allowable per the appropriate OMB Circular

• Reasonable and Necessary

• Allocable

• Consistent with your district’s policies

• Not charged elsewhere

• Adequately Documented When in doubt, contact the CTE program office at OSPI

PERKINS 101SALARIES• Yes – You must do “time-and-effort” (T&E) reporting• Employee works full time on Perkins you –

• Must certify the employee at least annually• T&E records must be signed by the employee or a supervisor with first

hand knowledge• Multiple cost objectives require regular Personnel Activity

Reports (PARs)• The cost has to be “allocable” to your Perkins grant• After-the-fact reporting• Signed by employee• Coincide with pay periods; at least monthly

OSPI Bulletin #051-11Secondary, SEAs, Governments, BIE – OMB Circular A87 Appendix B.8.h.

The most common problems, goofs!

PERKINS

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A COMMON PROBLEM

FAILURE TO FOLLOW YOUR DISTRICT’S APPROVED APPLICATION PLAN

YOUR APPLICATION

OUR APPLICATION WAS APPROVED – WE’RE GETTING THE MONEY – “LIFE IS GOOD” & I AM DONE!

• Review it at least at the 6 and 9 month points.• Follow it, or • AMEND IT• The OMB Circular A133 CTE Supplement – 4-84.048 (15 pgs.)

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COMMON PROBLEMSPROCUREMENT –

If your procurement shop or business office are not known for their attention to details - Cover your “butt”

• If you have to, keep your own set of documents• Purchase orders• Receiving documents• A mini-inventory, with item location info

• Keep it current• You need to put special procedures in place for items that cost less than $5K but are high-theft

items• Do your approved purchases agree with your approved application?• Does your annual fiscal completion report reconcile to your actual purchases?

PERFORMANCE INDICATORS

PERKINS ACCOUNTABILITY

PERKINS ACCOUNTABILITY

Purpose of Section 113 is to set out the Act’s accountability requirements and core indicators for performance at the secondary and postsecondary levels for all CTE students.

A. Sub-sections in Section 113 identify the (a) purpose, (b) state performance measures and (c) reporting.

B. Sub-section 2 Indicators of Performance identifies WHAT indicators you are being held accountable for.

PERKINS ACCOUNTABILITYSecondary Postsecondary

1S1: Academic Attainment | Reading/ Language Arts 1P1: Technical Skill Attainment

1S2: Academic Attainment | Mathematics

2P1: Credential, Certificate, or Diploma

2S1: Technical Skill Attainment 3P1: Student Retention or Transfer

3S1: Secondary School Completion 4P1: Student Placement

4S1: Student Graduation Rates 5P1: Nontraditional Participation

5S1: Secondary Placement 5P2: Nontraditional Completion

6S1: Nontraditional Participation

6S2: Nontraditional CompletionSection 113 Core Indicators of Performance

PERKINS ACCOUNTABILITYSACTIONS ARE REAL!!

Possible Sanctions if States:• Fail to implement an improvement plan, OR• Fail to show performance improvement once an improvement plan is in

place, OR• Fail to meet 90% of the same performance indicator for 3 consecutive

years

• District sanction language mirrors that of the State• State Education Agency can withhold some or all of the entire

local grant allocation

DATA SYSTEMS AND REPORTS


• What is CEDARS?

• What are Student Information Systems (SIS)?

• What are the Adjust Graduation Cohort Report (formerly known as the P210) and the Annual CTE Student Enrollment File (formerly known as the P210Voc Report)?

• What is Data Matching?

• Why is it important for us to submit these reports?

• What are the repercussions if we do not comply with reporting requirements?


The Comprehensive Education Data and Research System (CEDARS)

• Districts submit individual student, teacher, and course information on a frequent bases

• Data elements for Perkins requirements are pulled from CEDARS

• Districts verify and certify all data submitted for the CTE student enrolled for the reported year


Where does the student data come from?

• Annual CTE Student Enrollment File – a summary of all students served in any CTE courses in grades 7-12 in CEDARS for the current reporting

• Perkins federal reporting only includes students in grades 9-12

• Collection period: September 2014 through September 2015

How do we identify CTE Concentrators?

• Districts do not identify or report concentrators to OSPI. A concentrators is a secondary student who has enrolled in 2 or more CTE courses above the exploratory level in a single cluster.

Note: Concentrators are determined by reviewing a students entire high school enrollment history


CEDARS Outcomes

• CEDARS has reduced the redundancy in reporting from districts

• Allow OSPI to generate and consolidate reports for district viewing

• CEDARS reports are used for federal, state, and local use to determine funding of certain programs

CEDARS Data FilesLocation File

Student Demographics Student Enrollment Information Course Catalog Student Schedules* Grade History

D–Course Catalog

H-Grade History

E-Student Schedules

C–School Student File (enrollment)

B–District Student File

(demographics)

A–Location File

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CIP CODEState

Course Code

TEACHER CERTIFICATION

V-CODE COURSE NAME

010504 18102 V010000 Dog/Pet/Animal Grooming

010507 18104 V010000 Equestrian/Equine Studies

190706 19052, 22204 V200002 Child Development/Parenting

State Course Codes… mapped to CIP Codes

Grade History File data elements• Element H04 – State Student ID (SSID)

• Element H05 – Location ID

• Element H06 – Staff ID

• Element H07 – Course ID

• Element H08 – Course Title

• Element H09 – Grade Level Code

• Element H10 – Letter Grade

• Element H11 – Credits Attempted

• Element H12 – Credits Earned

CEDARS Grade History File

Grade History File data elements, cont’d• Element H13 – Course Designation Code

• Element H16 – (AP) and (IB) Code

• Element H17 – (CIP) Code Number

• Element H18 – Term End Date

• Element H19 – Term


CTE Grade History File data elements –• Element H20 – Is the Student a Career and Technical Education

(CTE) Program Completer?

• Element H21 – Did Student Receive a State or Nationally Recognized Industry Certification?

• Element H22 – Is Career and Technical Education (CTE) Direct Transcription Available?

• Element H23 – Is Tech Prep Completer?

• Element H24 – Did the Student Take or Pass a State or Nationally Recognized Assessment of Technical Skills and Knowledge?


WORK CLOSELY WITH YOUR CTE TEACHERS AND CEDARS

ADMINISTRATORS

CTE DATA AND REPORTS

ALLOWABLE/UNALLOWABLE USES OF PERKINS FUNDS

• EDGAR (34 CFR §80.1) defines equipment as personal property that costs $5,000 or more – The issue has more to do with a state’s inventory requirements (and the associated costs) than the purchase price

• The OIG (Office of Inspector General) has been issuing findings relative to items of equipment that are considered “attractive theft” items – cell phones, digital cameras, flat screen monitors, etc. that cost a lot less than $5,000

• When is something a supply and not equipment?

• Use a “reasonable person approach” – Does it have a useful life of a year or more, would you throw it away or repair it, does your own district’s criteria treat it as a supply or equipment? (see handout on Criteria for Distinguishing Non-capitalized Items from Capital Outlay – blue handout)

EQUIPMENT

PERKINS

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• Get it written into your approved application

• Items like your CTE computer lab

• Specialized workstations

• The cost of connecting equipment

• Etc.

• Avoid paying for stuff your district typically supplies to all your district’s educational programs – desks, chairs, PCs

• USE NON-PERKINS FUNDING WHERE POSSIBLE

• Trade Perkins-funded CTE costs for those CTE costs funded with non-federal $$$

• Pursue donated equipment where possible

EQUIPMENT CONT.

PERKINS

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Little guidance – the Feds typically refer you back to 34 CFR §403.71(c) – The last regulatory guidance for Perkins, under Perkins I

• Allowed – Instructional related costs (very narrow)

• Disallowed – All the fun stuff…

CAREER AND TECHNICAL STUDENT ORGANIZATIONS

CTSO

States – Section 124(c)(4)Local Recipients – Section 135(c)(5)

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(i) Lodging, feeding, conveying, or furnishing transportation to conventions or other forms of social assemblage;

(ii) Purchase of supplies, jackets, and other effects for students' personal ownership;

(iii) Cost of non-instructional activities such as athletic, social, or recreational events;

(iv) Printing and disseminating non-instructional newsletters;

(v) Purchase of awards for recognition of students, advisors, and other individuals; or

(vi) Payment of membership dues;

(d) Leadership and instructional programs in technology education; and

(e) Data collection.

(3) The support of vocational student organizations may not include—

My guess, they mean, non-instructional, out-of-the-classroom-type activities that don’t meet the conditions of 34 CFR § 403.71(c)(2)(iv) & – “all students…”

34 CFR §403.71(C)

PERKINS

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PERKINSAllowable Costs

• Reasonable and Necessary;

• Allocable to the Federal Award;

• Legal Under State and Local Law;

• Properly Documented;

• Consistent with the Provisions of the Grant Program; and

• Not used for cost sharing or matching any other grant agreement.

OMB Circular A-87See Handout Appendix B

• “NO”

• Unless it is related to –

• Approved travel (subject to your state’s per diem guidelines)

• Included in your approved registration

• Not considered entertainment

• Included as part of an approved conference or meeting (attending or sponsoring)

• A consumable training supply (culinary arts)

• Alcohol never allowed

Read Goods or services for personal use – A87 Attachment B.20 & A21 Section J. 22.

FOOD & BEVERAGES PERKINS

OMB A87 B.3; OMB A21 J.3OMB A87 B.14; OMB A21 J.17OMB A87 B.27; OMB J.32OMB A87 B.43; OMB J.5346

• Travel is allowable when it supports your approved grant or plan

• Meals, lodging, all the usual stuff is allowable, when approved

• Should be reasonable

• DOES NOT INCLUDE ENTERTAINMENT COST

What about those conferences where entertainment is included in the registration fee?

• It’s your state’s call…

If the cost is separate and identifiable and the employee wants to participate they must cover the cost out of their own pocket

OMB A87 Attachment B.43 or OMB A21 Section J.53

TRAVEL FOOD & BEVERAGES

PERKINS

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OMB A87 B.27 (Comparable language in OMB A21 J.32)

“Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental facilities, speaker’s fees, and other items incidental to such meetings or conferences. See OMB A87 B.14; OMB A21 J.17, “Entertainment Costs”.

• Must be reasonable

• Must be able to stand the, “Would you like to see this on the front page of your local paper?” test

• Does NOT include internal staff meetings

MEETINGS & CONFERENCES/FOOD & BEVERAGES

PERKINS

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• Memberships for a district is OK . For example the cost would be OK for your district CTE Director’s position, regardless of who the individual is – but not for the individual who is the CTE Director

• Must be “allocable” to your Perkins project or plan

• Use the “reasonable person” approach

• It is recommended that you utilize your procurement system procedures if you are looking at a -

• Significant cost

• Sole source provider (speakers, intellectual property, copyrighted, etc.)

MEMBERSHIPS, SUBCRIPTIONS & PROFESSIONAL ACTIVITY COSTS

PERKINS

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• Awards or Gifts -Typically Not Allowed

• However you can purchase nice frames through your approved local office supply contract, print out a nice certificate on your color laser printer and hand the result to folks…

• Hand out donated items from your state’s Chamber of Commerce, local industry groups, etc.

AWARDS

PERKINS

OMB A87 B.1.f(3); OMB A21 J.1.f(3)OMB A87 B.20; OMB A21 J.22

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• Alcohol

• Entertainment expense

• Awards (gifts)

• Promotional items (freebies)

• Promotional advertising

NOT ALLOWED

PERKINS

• OMB A87 B.3; OMB A21 J.3• OMB A87 B.14; OMB A21 J.17• OMB A87 B.20; OMB A21 J.22• OMB A87 B.1.f.(3); OMB A21 J.1.f(3)• OMB A87 B.1.f(4); OMB A21 J.1.f(4)

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CONSOLIDATED PROGRAM REVIEW (CPR)


• Monitor multiple federally funded programs under the Elementary and Secondary Education Act (ESEA)

• Fulfills OSPI’s compliance monitoring requirements under Federal regulations (2 CFR 200)

• The CPR process consists of an OSPI team reviewing school districts federal and selected state programs

• The monitoring activities are designed to focus on the results of the district’s efforts to implement critical requirements of the ESEA using available resources and flexibility provisions

District Contacts

CPR Contact

• Responsible for coordinating the review for all monitored federal and state programs.

• All future communication will be sent to this individual and the district superintendent.

• Provide name, title, phone number and email address.

• Fiscal Contact

• Point of contact for fiscal cross‐cutting portion of review.

• Provide name, title, phone number and email address.


Title I, A Title IV, B –Rural Education

LAP (Learning Assistance Program) Title X –McKinney-Vento (Homeless)

Title I, C –Migrant Ed Highly Capable

Title I, D –Neglected and Delinquent Perkins / CTE

Title I, G –AP (Advanced Placement) Private Schools

Title II, A –Highly Qualified Civil Rights

TBIP (Transitional Bilingual Instructional Program / Title III

Fiscal

Gun-Free Schools Act OSSS (Office of Student and School Success)


CPR Review Timeline

2015-16:Districts in ESDs 121 and 1712016-17:Districts in ESDs 105, 112, and 1132017-18:Districts in ESDs 105, 112, and 113

2018-19: Districts in ESDs 123 and 189 The “BIG 4” Districts

• Reviewed annually.

• Due to the size and amount of federal funds managed, these districts pose a potentially higher risk for noncompliance.

• Generally two day visits.

Other LEAs Reviewed

We are moving to a process that reviews other Local Education Agencies (LEA)s that receive funds from OSPI as the State Education Agency (SEA) and provide services.

This year as part of CPR, we are reviewing:• 3 Tribal Compact Schools

• 2 ESDs

• 1 Charter School

CPR 2015-161-Day Sample Agenda

8:30-9:30 a.m.

Entrance Meeting:Introductions and Overview of CPR ProcessDiscussion about Program Practices with OSPI and District Staff

9:30-11:30 a.m.

Discussion with District Program StaffBuilding visits

11:30-12:30 p.m.

Lunch

12:30-3:00 p.m.

Continuation of Building VisitsContinuation of Discussion with District Program Staff

3:00-4:00 p.m.

CPR Team Preliminary Report Preparation(OSPI team will be at the district office to prepare for the exit interview)

4:00-4:30 p.m.

Exit Meeting and Closing Observations

Day 1 CPR team members continue with review and end day around 4:00-4:30pm

Day 28:30-3:00 p.m.

Continuation of Building VisitsContinuation of Discussion with District Program Staff

3:00-4:00 p.m.

CPR Team Preliminary Report Preparation(OSPI team will be at the district office to prepare for the exit interview)

4:00-4:30 p.m.

Exit Meeting and Closing Observations

CPR 2015-162-Day Sample Agenda

Digital Checklist

• OSPI will use Program Monitor, a web application in the Education Data System (EDS), for the management of review content and as a replacement of the paper checklists used in the past.

• Districts upload all documentation for review to the online Program Monitor tool beginning 12 weeks (and no later than 6 weeks) prior to the review start date.

• We do not accept emails or paper copies of documentation.

• Access Program Monitor here: https://eds.ospi.k12.wa.us/ProgramMonitor/

https://eds.ospi.k12.wa.us/ProgramMonitor/



Uploading and Formatting

CPR - Follow‐Up Process


CPR TEAM LEAD CONTACT INFORMATION

Anne Renschler, Program SupervisorConsolidated Program [email protected]

Sylvia Reyna, Program SupervisorMigrant [email protected]

Timothy McNeely, Program SupervisorConsolidated Program Review and Rural Education [email protected]




PERKINS 101 TAKE WAYS

• Learn the timeline

• Understand the performance indicators

• Understand fiscal responsibilities

• Establish a local team; internal and external

• Seek and participate in technical assistance provided by State staff

• Organize electronic/paper files

• Monitor and adjust

CTE PROGRAM OFFICE CONTACT INFO

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Ken Emmil, Assistant SuperintendentCareer and College [email protected]

Vacant, DirectorCareer and Technical [email protected]

Marianna Goheen, Program SupervisorHealth [email protected]

Rebecca Wallace, Program SupervisorAgriculture [email protected]

Phouang Hamilton, Program SupervisorGrants and Innovative [email protected]

Denise Mileson, Program SpecialistGRADS [email protected]

Mary Nagel, Program SupervisorFamily and Consumer [email protected]

Lance Wrzesinski, Program SupervisorBusiness and [email protected]

Deifi Stolz, Program SupervisorMethods of [email protected]

Denny Wallace, Program SupervisorSkills and Technical [email protected]

Mary Kanikeberg, Program SupervisorJobs for Washington’s [email protected]

Clarence Dancer, Program [email protected] 360-725-4467Diane Gard, Executive Assistant | [email protected]

Monica Trabue, Secretary| [email protected] Jill Pilbro, Secretary | [email protected]
















perkins 101 2016 cte interns. phouang hamilton office of superintendent of public instruction career...

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