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Fiscal Responsibility Webinar Title III
Stephanie English, ChiefMonitoring & Compliance Section
School Business Division919-807-3686
ESL/Title III Consultants
Glenda Harrell Joanne Marino Ivanna Mann [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 dataDocumentation of testing accommodationsAgendas 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/presentations/ ; 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.
• Object code 311
• Invoices must be specific – who, what, when, where, why
Invoices for Contracted Services
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
ResourcesFederal 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, ChiefMonitoring & Compliance [email protected]
ESL/Title III Consultants
Glenda Harrell Joanne Marino Ivanna Mann [email protected] [email protected] [email protected]
919-807-3866 919-807-3861 919-807-3860
