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Pre-Award Risk-Based Assessment
Tawanna Fields-Mphande October 14,2016
Overview
• Pre-Award Risk-Based Assessment Process
• Risk-Based Assessment Timeline
• Agency-Wide Compliance & Monitoring
Updates
• Resources
Risk-Based Assessment
The Law
• The Uniform Guidance (Super Circular)
requires all Pass-Through entity to conduct a
risk-based assessment prior to making
awards. (OMNI Federal Circular §200.331)
• To comply with this requirement, the Office of
Career Technical Education will conduct an
annual risk assessment of all Perkins
recipients.
Required Monitoring Activities
Framework for evaluating risks before applicant
receives funding:
• Financial stability
• History of performance
• Reports from single-audit findings
• Applicant’s ability to effectively implement
statutory, regulatory or other requirements
Risk-Based Assessment
The risk-based assessment process is
designed to conduct a more thorough review
for Perkins recipients with higher risk factors.
The risk-based assessment review identifies
potential problems that could lead to risks in
the accountability, fiscal accounting and grant
operations.
Purpose and Intent
Provide preventative assistance before
mistakes are made
Increase efficient use of resources &
transparency
Reduce, waste, fraud & abuse
Ensure that subrecipients use federal funds
for the intended purpose
Criteria Selection Process
Criteria Selection Process
Just kidding!
Criteria Selection Process
Risk-based assessment criteria used to
determine risk for FY17 districts (2016-2017
school year):
• Previously non-compliant;
• Failure to meet accountability measures;
• New career-technical education personnel;
• Failure to meet required deadlines; and
• Single Audit Findings.
Pre-Award Risk-Based
Assessment Tool
Assessment Tool
High
Medium
Low
Based on the results of the risk-based assessment tool, all districts will be categorized as high, medium or low risk.
Risk-Based Assessment Tool
Assessment Scores
0 to 1 points low risk
2 to 3 points medium risk
4 to 7 points high risk
Risk LevelsRisk Level Monitoring Guidelines Risk Levels
High(4-7)
Required to submit detailed financial reports such as general ledgers, supporting documentation and performance reports. On-site monitoring will be at the discretion of the education program specialist.
Medium(2-3)
Required to receive additional targeted assistance. Required attendance at trainings/conferences. Follow-up with district via phone audit review.
Low(0-1)
No known programmatic, financial instability or significant audit findings. No significant program changes. The district shall receive technical assistance upon request.
FY18 Pre-Award Risk Assessment Timeline
May 2017
High-Risk
Districts Notified
April 2017
Pre-Award Risk
Assessment
June 2017
Monitoring
Guidelines
implemented
July 2017
Funds allocated to
field
Note: The timeline is contingent on the availability of data.
Agency-Wide Updates
Pre-Award Risk-Assessment
Agency-Wide Process1
Agency-Wide Process
• All federal programs are required to
implement the risk-assessment process.
• Each departments process is unique to their
grant.
Program Monitoring
Agency-Wide Process2
Monitoring • Working collaboratively to reduce our foot-
print in the field.
• In FY16:
– There were a total of 112
districts/organizations with overlap
–Team approach – 107 onsite/desk review
and 5 with desk review only overlap
Compliance Dashboard3
New Compliance Dashboard
In Summary
• A high-risk assessment score should
NEVER be interpreted as a negative
reflection.
• Technical assistance will be provided
• FY2017 districts were notified in August,
2016
• Notification of high-risk will be sent via the
CCIP and email to the Superintendent
• Compliance dashboard coming soon!
Resources
Scheduled to be Monitored
Additional Resources• Carl D. Perkins Career and Technical Education Act of 2006
http://www.fldoe.org/workforce/perkins/pdf/Perkins_IV_text.pdf
• U.S. Office of Management and Budget (OMB) Circulars
http://www.whitehouse.gov/omb/circulars/
• Education Department General Administrative Requirements
(EDGAR)
• http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
Resources• Subpart A – Acronyms & Definitions (§200.0 -§200.99)
• Subpart B – General Provisions (§200.100 - §200.113)
• Subpart C – Pre-Federal Award Requirements and
Contents
• of Federal Awards (§200.200 - §200.211)
• Subpart D – Post-Federal Award Requirements
Standards for
• Financial and Program Management (§200.300 -
§200.345)
• Subpart E – Cost Principles (§200.400 - §200.475)
• Subpart F – Audit Requirements (§200.500 - §200.521
Miguel Ruiz
education.ohio.gov
Social Media
@OHEducation
@OHEducationSupt
OhioFamiliesAndEducation
OhioEdDept