Title I, Part A District Coordinator Webinar

August 22, 2019

Logistics

To submit a question during the call, send

an email to tara.rodriguez@education.ky.gov

Questions will be answered during the

presentation if possible.

The webinar will be recorded and posted on

the Title I Documents and Resources

webpage.

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Review of July Webinar Topics

Supplement not supplant informational

document

Supplement not supplant requirements

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Agenda

Internal Controls

Updates to Title I Monitoring Indicators

Resource: Online grants training courses

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Internal Controls 2 C.F.R. 200.303 Internal Controls. The non-federal entity must:

● Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.

● Comply with Federal statutes, regulations, and the terms and conditions of the Federal awards.

● Evaluate and monitor the non-Federal entity’s compliance with statutes, regulations and the terms and conditions of Federal awards.

● Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings.

● Take reasonable measures to safeguard protected personally identifiable information and other information the Federal awarding agency or pass-through entity designates as sensitive.

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Internal Control Internal Control—a process that gives reasonable

assurance that the organization will achieve its objectives through

● Effective and efficient operations

● Reliable reporting

● Compliance with applicable laws and regulations

What is an Internal Control System? A continuous built-in component of operations, effected by people, that provides reasonable assurance, not absolute assurance that an entity’s objectives will be achieved. Sources: U.S. Department of Education: “Internal Controls Technical Assistance Presentation” on the Risk Management Tools web page, and “PowerPoint Slides from the Webcast” presentation on the Internal Controls web page

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Internal Controls and Accountability

The elevated role of internal control:

● Creates a transparent system of accountability

for decision making around federal funds.

● This system of accountability applies equally to

Federal Agencies, grantees, and sub-recipients.

While internal controls are not new to the

financial world, they may be new to folks

working on program implementation.Source: U.S. Department of Education: “PowerPoint Slides from the Webcast”

presentation on the Internal Controls web page7

Five Components of Internal Controls

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Definitions of the five components of internal controls

Those processes by which you assure objectives are achieved efficiently, effectively, and with reliable, compliant reporting:

● A Control Environment that sets the tone for the organization.

● A Risk Assessment process that involves the identification and analysis of relevant risks.

● Control Activities that include the policies and procedures that help ensure management directives are carried out and documented.

● Information and Communication systems or processes that support the exchange of information.

● Monitoring processes used to assess the quality of internal control performance over time.

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The third component of internal controls: Control Activities

Control Activities: actions management

establishes through policies and procedures

to achieve objectives and respond to risks in

the internal control system, which includes

the agency’s information system.

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Third Component: Control Activities (Cont.)

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Control Activities are the heart of the internal control

system.

Understanding the types of internal control activities

• Preventive—these controls help management to avoid

problems before they occur. Prevent the occurrence of negative

events.

• Detective—these controls help to uncover issues after they’ve

occurred. Identify the occurrence of a negative event.

• Corrective—these controls detect if risk is present, and then

elicits a response and/or corrective action.

Examples of Control Activities

• Approvals and authorizations (Preventive)

• Reconciliations (Detective)

• Independent Reviews (Detective)

• Segregation of Duties (Preventive)

• Training (Preventive)

• Corrective Action Plan (Corrective)

• Monitoring (Corrective)

• Update/Implement standard operating procedures (Corrective and/or Preventive)

• Asset Security (Preventive)12

What does this mean for Title I/federal programs?

Required to have internal controls in place

Implications for monitoring

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Title I Monitoring Overview

Checklist updates

Monitoring information

Timelines

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Monitoring Checklists

Checklist Format Change

● The content within each checklist has not

changed. We reformatted each checklist,

updated citations for each indicator and

provided a list of required documentation we

need in order to review each indicator.

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Checklist Sample

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Monitoring Checklists

Program Tool

● We suggest utilizing these checklists as a tool

for organizing documentation and overseeing

your program. It provides a list of things

applicable to your Title I program at both the

district and school level. We include Best

Practices within each section that will provide

some additional guidance for your Title I

programs.17

Best Practices Sample

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Monitoring Checklists

Distance Monitoring Changes

● The distance monitoring checklist and process

have undergone the most noticeable change.

We are narrowing the scope and focus of the

distance monitoring requirements. The

required documentation is more fiscal in

nature.

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Monitoring Checklists

The updated checklists for Distance,

Consolidated (on-site) District, Schoolwide

Program and Targeted Assistance Programs

are still in draft form.

The updated checklists for 2019-20 will be

located on the Title I, Part A Documents and

Resources Page.

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Tentative Monitoring Timelines

August and September

● Programs are entering data in Risk Assessments

October

● Districts will be notified if chosen for either Distance or Consolidated visit.

● Skype calls will be provided for districts chosen for either type of monitoring

● Districts participating in Distance monitoring will upload required documentation.

November

● Title I Distance monitoring documentation will be reviewed and reports will be provided to districts.

● Finalized schedules for Consolidated Monitoring will be provided to chosen districts.

January through May

● Districts chosen for Consolidated Monitoring will receive visits21

Questions?

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Professional learning opportunities

There will be one more KDE session for new

coordinators on the fundamentals of Title I

● September 12 at the 300 Sower Building in

Frankfort, from 9:00 a.m. to 4:00 p.m.

● New Coordinator Training Registration Link

Online courses

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Online courses through ED

U.S. Department of Education online grants training courses. Courses are 45 minutes to 1 hour

● Cash management

● Discretionary grants Administration

● Formula grants administration

● Indirect costs

● Internal controls

● Procurement

● Property management

● Travel

● Subrecipient monitoring

● Allowable activities 24

Example: The Allowable Costs online course

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Project 310D

Reminder: spend down any remaining

funds from Project 310D

●All funds must be spent or

encumbered by September 30, 2019

and the final Federal Cash Request

must be submitted by December 6,

2019. 26

New Title I consultant

Welcome to Emily Meade

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Resources

U.S. Department of Education Risk

Management Tools web page

U.S. Department of Education Internal Controls

web page

U.S. Department of Education online grants

training courses

Supplement Not Supplant Informational

Document from U.S. Department of Education28