UGG Debriefing &Comparability Summary

2015 ESEA Directors Institute

August 2015

Consolidated Planning & Monitoring

Eve CarneyExecutive Director

Janine WhitedDirector of Project Management

Eve.Carney@tn.govJanine.Whited@tn.gov

Uniform Grants Guidance

UGG Debriefing

Uniform Grants Guidance: Rationale

• Simplicity

• Consistency

• Obama Executive Order on Regulatory Review– Increase Efficiency– Strengthen Oversight

Most Significant General Changes

• Auditors (A-133 + federal OIG) and Monitors (federal and State Pass-Through) must look more to “outcomes” than to “process”

• The Omni Circular has a MAJOR emphasis on “strengthening accountability” by improving policies that protect against waste, fraud and abuse Required written policies/procedures

Allowability – Cost Principles and

Items of Cost

Cost Principles: Factors Affecting Allowability

• §200.403All Costs Must Be:

1. Necessary, Reasonable, and Allocable2. In conformance with federal law and grant terms3. Consistent with state and local policies 4. Consistently treated5. In accordance with Generally Accepted Accounting

Principles (GAAP)6. Not included as match7. Net of applicable credits 8. Adequately documented

Selected Items of Cost – Conferences

• §200.432 (Updated)

Allowable conference costs include rental of facilities, costs of meals and refreshments, transportation, unless restricted by the federal award

New: Costs related to identifying, but not providing, locally available dependent-care resources

New: But 200.474 “travel” allows costs for “above and beyond regular dependent care”

Conference hosts must exercise discretion in ensuring costs are appropriate, necessary, and managed in manner than minimizes costs to federal award

Selected Items of Cost – Travel

• §200.474 (Changed)

Travel costs may be charged on actual, per diem, or mileage basis

Travel charges must be consistent with entity’s written travel reimbursement policies

Grantee must retain documentation that participation of individual in conference is necessary for the project

Travel costs must be reasonable and consistent with written travel policy / or follow GSA 48 CFR 31.205-46(a)

Time and Effort

Participants

• All employees paid in part or in full with federal funds

• Some employees paid with non-federal funds (state match)

• Part-time employees

• NOT contractors

Part 200.28 Cost Objective – Defined

What is a cost objective?

• Program, function, activity, award, organizational subdivision, contract, or work unit for which cost data are desired and for which provision is made to accumulate and measure the cost of processes, products, jobs, capital projects, etc.

What aren’t cost objectives?• Federal Programs• Title I, Part A• Doing my job• ESEA• Working on initiatives and

programs that benefit Students with Disabilities

• Director of Federal Programs• IDEA• Educating children in

classrooms

Multiple Cost Objectives

Multiple Cost Objectives §200.430(vii) include working on

More than one federal award A federal award and a non-federal award An indirect cost activity and a direct cost activity Two or more indirect activities that are allocated using

different allocation bases An unallowable activity and a direct or indirect cost activity

A-87 Standards – Current Rule

• Semi-Annual Certifications

If an employee works on a single cost objective: After the fact Account for the total

activity Signed by employee or

supervisor Every six months (at

least twice a year)

• Personnel Activity Report (PAR)

If an employee works on multiple cost objectives: After the fact Account for total activity Signed by employee Prepared at least monthly

and coincide with one or more pay periods

2 CFR Part 200 Standards – New Rule

• Charges for salaries must be based on records that accurately reflect the work performed

1. Must be supported by a system of internal controls which provides reasonable assurance charges are accurate, allowable, and properly allocated

2. Be incorporated into official records3. Reasonably reflect total activity for which employee is

compensated and not exceed 100%4. Encompass all activities (federal and non-federal)5. Comply with established accounting polices and practices6. Support distribution among specific activities or cost

objectives

New Rule – Compliance

• If records meet the standards: the non-federal entity will NOT be required to provide additional support or documentation for the work performed 200.430(i)(2)

• BUT, if “records” of grantee do not meet new standards, ED may require PARs 200.430(i)(8) PARs are not defined Questioned costs must be repaid using state/local funds

• Recommend maintaining current system of documenting personnel expenses until these new standards have been audited

Budget Estimates and Percentages in Documenting Personnel Activities / Reconciliation• Budget estimates alone do not qualify as support for charges to

federal awards §200.430(i)(1)(viii)

• May be used for interim accounting purposes if: Produces reasonable approximations Significant changes to the corresponding work activity are identified

in a timely manner

• NEW: Percentages may be used for distribution of total activities §200.430(i)(1)(ix)

• NEW: All necessary adjustments must be made such that the final amount charged to the federal award is accurate, allowable, and properly allocated §200.430(i)(1)(viii)(C)

• Annually, reconciliation assures allocability – charging the federal award only for the benefit received.

De Minimis Benefit

• Limited work on another cost objective does not need to be captured in time and effort records.

• Employees may work 5% or less on another cost objective.

• The worked performed on these limited duties cannot deprive a benefit from the intended beneficiaries.

• EXAMPLE: A teacher works on a single cost objective but also has limited other responsibilities, such as cafeteria or bus duties. – As long as these additional responsibilities do not exceed 5%

over a twelve-month period, then the teacher can still complete a semi-annual certification (single cost objective)

Financial Management Controls:

Key Components

Internal Controls

• §200.303 – Internal Controls must ensure compliance with federal statutes, regulations, and terms of the award.

• Entities must: Evaluate and monitor compliance Take prompt action when instances of non-compliance are

identified; and Safeguard protected personally identifiable information

(PII)

• Effective control over and accountability for:1. All funds2. Property3. Other assets

NEW: Written Cash Management Procedures

• Written Procedures required to implement the requirements of 200.305

• Written procedures must include a description of the method the district uses (Tennessee is a reimbursement state)

• Must minimize time elapsing between reimbursement request and disbursement to comply with Cash Management Improvement Act (CMIA)

New: Written Allowability Procedures

• Written procedures required for determining allowability of costs in accordance with Subpart E – Cost Principles

• Procedures can not simply restate the Uniform Guidance Subpart E

• Should explain the process used throughout the grant development and budget process

• Someone familiar with the program requirements should be involved with the allowability determinations, and the written procedures should include this (position, not name of employee)

Financial Management Controls:

Procurement

Open Competition

• §200.319

• All procurement transactions must be conducted with full and open competition (in Tennessee over 10,000)

• T.C.A. states that the threshold of $10,000 or more for purchases. – Cumulative purposes anticipated to exceed $10,000 must be

competitively bid

• To eliminate unfair advantage, contractors that develop or draft specifications, requirements, statement of work, and invitations for bids or RFPs must be excluded from competing for such procurements

Conflict of Interest

• §200.112

• Must maintain written standard of conduct, including conflict of interest policy

• A conflict of interest arises when any of the following has a financial or other interest in the firm selected for award:

– Employee, officer, or agent– Any member of that person’s immediate family– That person’s partner– An organization which employs, or is about to employ, any of

the above or has a financial interest in the firm selected for award

Conflict of Interest

• §200.112

• NEW: All non-federal entities must establish conflict of interest policies, and disclose in writing any potential conflict to federal awarding agency in accordance with applicable federal awarding agency policy

Cost/Price Analysis

• §200.323

• Must perform a cost or price analysis in connection with every procurement action, including contract modifications

• NEW: Only required for costs in excess of the simplified acquisition threshold ($150,000)– Cost analysis generally means evaluating the separate cost

elements that make up the total price (including profit)– Price analysis generally means evaluating the total price– However, TN has a lower limit of $10,000

Vendor Selection Process

• §200.320

• Methods of procurement:

1. NEW: Micro-purchase2. Small purchase procedures – N/A to Tennessee3. Competitive sealed bids4. Competitive proposals5. Non-competitive proposals

Vendor Selection Process: 1) Micro-Purchase

• §300.320(a)

• NEW: Acquisition of supplies and services under $3,000 or less

• May be awarded without soliciting competitive quotations if nonfederal entity considers the cost reasonable

• To the extent practicable must distribute micro-purchases equitably among qualified suppliers

Vendor Selection Process: 2) Small Purchase Procedures – N/A to TN

• Good or service that costs $100,000 or less (NEW: $150,000 under 200.88)

TN has a lower threshold, $10,000; therefore this procurement method is Not Applicable

• Must obtain price or rate quotes from an adequate number of qualified sources

• “Relatively simply and informal”

Vendor Selection Process: 3) Noncompetitive Proposals

• Appropriate only when:– The good or services is available only from a single source

(sole source)– There is a public emergency– The awarding agency authorizes– NEW: awarding agency or pass-through must expressly

authorize noncompetitive proposals in response to written requires from nonfederal entity - 200.320(f)(3)

– After soliciting a number of sources, competition is deemed inadequate

• Cannot contract with vendor who has been suspended or debarred: http://www.sam.gov

Contract Administration

• §200.318

• Revised: Nonfederal entities, such as TDOE, must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of the contract

– Contractors bound by terms of contract

– Important to include appropriate terms and conditions

– Manage for performance

Use and Disposition of Grant-Acquired Equipment

• §200.313

• Clarification: shared use is allowed if such use will not “interfere”: 1st preference – other projects supported by the federal

awarding agency 2nd preference – project funded by other federal agencies 3rd preference – use for non federally funded programs

• When property no longer needed, must follow disposition rules: Transfer to another federal program Over $5,000 – pay federal share Under $5,000 – no accountability

Requirements of the Pass-Through Entity

Federal awarding agency review of risk posed by applicants

• §200.205

• NEW: ED and “Pass-Through” must have in place a framework for evaluating risks before applicant receives funding

1. Financial Stability2. Quality of Management System3. History of Performance4. Audit Reports5. Applicant’s Ability to Effectively Implement Program

Federal awarding agency review of risk posed by applicants

• §200.205

• ED or “Pass Through” May Impose “additional federal award conditions”:

Require reimbursement; Withhold funds until evidence of acceptable performance; More detailed reporting; Additional monitoring; Require grantee to obtain technical or management

assistance; or Establish additional prior approvals

Monitoring and reporting program performance

• §200.328

• NEW: Monitoring by the “Pass Through”

• Monitor to assure compliance with applicable federal requirements and performance expectations are achieved

• Must cover each program, function or activity (see also 200.331)

• Must submit “performance reports” at least annually

Resources

• Uniform Grants Guidance: http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/2013-30465.pdf

• COFAR: https://cfo.gov/cofar/

• OCFO Time and Effort Guidance: http://www2.ed.gov/policy/fund/guid/gposbul/time-and-effort-reporting.html

Resources

• 2 CFR 200: http://www.ecfr.gov/cgi-bin/text-idx?SID=6214841a79953f26c5c230d72d6b70a1&tpl=/ecfrbrowse/Title02/2cfr200_main_02.tpl

– FAQs: http://www2.ed.gov/policy/fund/guid/uniform-guidance/faqed.pdf

• EDGAR: http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html– Title 34, Code of Federal Regulations (CFR), Parts 75-79, 81 to

86 and 97-99. For awards made prior to 12/26/2014, EDGAR Parts 74 and 80 still apply.

– For awards made on or after 12/26/2014, 2 CFR Part 200, which includes the substance formerly in parts 74 and 80, applies.

Resources

• ePlan: https://eplan.tn.gov/ Uniform Grants Guidance Training Videos:

https://onedrive.live.com/?cid=4e040e5a9ca9cbb4&id=4E040E5A9CA9CBB4!121&Bsrc=Share&Bpub=SDX.SkyDrive&sc=Photos&authkey=!AmuTdskCXMWsAvc

NOTE: The videos are not to be used for any other purpose nor shared with anyone outside of the department or LEA.

Comparability Summary:

Clarifications

Basic Premise of Comparability

The basic premise of comparability is to ensure the LEA can demonstrate that state and local funds used to provide services at Title I schools are at least

comparable to the services at non-Title I schools.

Comparable State & Local Funds withSupplemental Title I Funds

SUPPLEMENTAL Title I Fundsare Like the Cherry On Top of State & Local

Funds

Title I Title I Title I

Non-Title Non-Title Non-Title

Basic Premise of Comparability

• Remember, the basic premise of comparability is to ensure the LEA can demonstrate that state and local funds used to provide services at Title I schools are at least comparable to the services at non-Title I schools.

• For this reason, the grade span groupings used for comparing schools to demonstrate comparability are very important.

• Grade span groupings must match the basic organization of schools in the LEA.

Grade Span Grouping

• Defined grade span groupings for comparability must take into consideration which grades the LEA serves with Title I funds.

• For instance, if the Title I schools in the LEA serve only grades K-8, but not grades 9-12, the comparability calculations only need to include the Title I and/or non-Title I elementary and middle schools, but not the non-Title I high schools.

• However, if a school crosses multiple grade span groupings where any grades in the LEA are served with Title I funds, it must be included in one of the grade span groupings of the basic organizations of the LEA.

Grade Span Grouping

• If the LEA has multiple schools serving grades that cross more than one of the basic grade span grouping configurations, and at least one of those schools is a Title I school, those schools may be compared as a separate grade span grouping.

• For example, if the LEA's basic organization primarily includes schools serving grades K-5, 6-8, and 9-12, the LEA would have three grade span groupings.

• Additionally, if the LEA also has two schools serving K-8, and at least one of those schools is a Title I school, the LEA would have four grade span groupings – the fourth being K-8.

Schools Crossing Grade Span Groupings• No school may be excluded from comparability simply

because it crosses multiple grade span groupings.

• For instance, if the LEA's basic organization primarily includes schools serving K-5, 6-8, and 9-12, the LEA would have three grade span groupings.

• If the LEA also has only one K-6 school, the school could be included in the K-5 grade span grouping but K-6 could not be identified as a separate grade span grouping.

• Likewise, if the LEA has two K-8 schools, but both are non-Title I schools, the LEA would still have only three grade span groupings for comparability because at least one of those K-8 schools is not a Title I school.

Options for Schools Crossing Grade Span Groupings

• If a school serves grades that cross more than one grade span grouping, the LEA has the following options for including the school in comparability determinations:

– OPTION 1: Include a school in the grade span grouping with which the school has the most grades in common:• A K-6 school could be compared within the K-5 grade span

grouping. • A K-8 school could be compared within the K-5 grade span

grouping.• A 6-12 school could be compared within the 9-12 grade span

grouping.• A K-12 school could be compared within the K-5 grade span

grouping.

Options for Schools Crossing Grade Span Groupings

– OPTION 2: Divide the grades the school serves by the grade span groupings. Then include the school in each grade span grouping it crosses based on the grades:• A K-6 school could be compared within both the K-5 and 6-8

grade span groupings. – Grades K-5 would be compared within the K-5 grade span grouping.– Grade 6 would be compared within the 6-8 grade span grouping.

• A K-8 school could be compared within both the K-5 and 6-8 grade span groupings.

• A 6-12 school could be compared within both the 6-8 and 9-12 grade span groupings.

• A K-12 school could be compared within the K-5, 6-8, and 9-12 grade span groupings.

Options for Schools Crossing Grade Span Groupings

– OPTION 3: If the LEA has multiple schools serving grades that cross more than one grade span grouping, and at least one of those schools is a Title I school, those schools may be compared as a separate grade span grouping.

If all schools that serve grades crossing more than one grade span grouping are non-Title I schools, option one or two must be used.

Option three may not be used to exclude non-Title I schools from comparability determinations.

Options for Schools Crossing Grade Span Groupings

– OPTION 3: (cont.)Example for comparing multiple schools as a separate grade span grouping:• If the LEA has multiple K-8 schools, and at least one of those

schools is a Title I school, the schools may be compared within a separate K-8 grade span grouping.

• If none of the schools are Title I, option one or two must be used and the schools may not be compared as a separate grade span grouping.

Grade Span Grouping Examples

• EXAMPLE 1:– All schools in the LEA are Title I schools.– The LEA has three K-5 schools, two 6-8 schools, and one 9-12

school, but also has one K-6 and one K-8 school.– Because the LEA has only one K-6 and one K-8 school, those

schools cannot be separate grade span groupings, but must be compared within one of the three basic grade span groupings.

Example 1:– K-5– 6-8– 9-12

Example 2:– K-5– 6-8– K-8– 9-12

Example 3:– K-6– 7-8– 9-12

OR MAYBE

OR MAYBE

Grade Span Grouping Examples

• EXAMPLE 2:– The LEA serves both Title I and non-Title I schools. – The K-5 and 6-8 schools are all served by Title I and one of

two K-8 schools is served by Title I. There are two 9-12 non-Title I schools.

– Because the LEA has multiple K-8 schools, and at least one of those schools is a Title I school, those schools may be compared as a separate K-8 grade span grouping.

– Because none of the Title I schools in the LEA serve any grades 9-12, the high schools may be excluded from the calculations.

Example 1:– K-5– 6-8– 9-12

Example 2:– K-5– 6-8– K-8– 9-12

Example 3:– K-6– 7-8– 9-12

OR MAYBE

OR MAYBE

Grade Span Grouping Examples

• EXAMPLE 3:– The LEA serves both Title I and non-Title I schools. – The LEA has four K-6 schools, three 7-8 schools, and two 9-12

schools, but also has one K-8 school and one 6-12 Title I school.

– Because the LEA has only one K-8 and one 6-12 school, those schools cannot be separate grade span groupings, but must be compared within one of the three basic grade span groupings.

Example 1:– K-5– 6-8– 9-12

Example 2:– K-5– 6-8– K-8– 9-12

Example 3:– K-6– 7-8– 9-12

OR MAYBE

OR MAYBE

Excluding Support Staff

• If the LEA opts to exclude other personnel directly supporting instruction from comparability determinations, the exclusion must be consistent for all schools in the LEA.

• Form III has been updated to provide a space for the LEA to indicate its intent to exclude all personnel directly supporting instruction from comparability.

• The LEA must still submit Form III and note "EXCLUDED" in the space provided.

Schools are Not Comparable

• If the LEA is unable to demonstrate comparability by the October 31 deadline, the LEA must still upload all required forms by October 31 and a letter stating that the LEA was not able to demonstrate comparability and understands it must make necessary adjustments within the same school year.

• If adjustments are required to demonstrate comparability, all new comparability forms and a letter stating what adjustments were made must be uploaded to ePlan no later than December 1 of the same school year.

Uploading Files to ePlan

• Forms I – IV are Excel files which must be completed and uploaded to the ePlan LEA Document Library / 2016 / Comparability folder.

• Please do not print and scan Excel files. If Excel files are printed and scanned, the LEA will be requested to upload the completed Excel files.

• Only Form V is to be printed, signed and scanned before it is uploaded to the ePlan LEA Document Library / 2016 / Comparability folder.

Alternative Methods Documented

• The standard method for demonstrating comparability is based on student/instructional staff ratio comparisons.

• Any method approved must be one that does not compromise the intent of the law for demonstrating comparability. The October 31 deadline applies to all alternative methods.

– Alternative 1: Per Pupil Budgeted Instructional Expenditures– Alternative 2: Student / Instructional Staff Salary Ratios– Alternative 3: Large and Small Schools– Alternative 4: High and Low Poverty

• For assistance with alternatives, please contact CPM.

Alternative Methods Documented

• An alternative method may be considered with prior approval by TDOE.

– Alternatives 1 & 2: Request for approval must be received by TDOE no later than October 15.

– Alternatives 3 & 4: When requesting approval to use this alternative, the LEA must first submit all completed Forms I – V showing the results of the standard method. Request for approval must be received by TDOE no later than October 15.

Comparability Support

CPM Comparability Support

• CPM Regional Consultants – Map of District Assignments1) Corey Currie

Corey.Currie@tn.gov(731) 234-5417

2) Janet (Michelle) MansfieldJanet.Mansfield@tn.gov(731) 225-3627

3) Bridgett CarwileBridgett.Carwile@tn.gov(615) 626-3466

4) Courtney WoodsCourtney.Woods@tn.gov(615) 864-5471

5) Deborah ThompsonDeborah.Thompson@tn.gov(615) 864-5162

6) Jacki WolfeJacki.Wolfe@tn.gov(423) 262-3296

CPM & Finance Regional Consultant District Map

LAKE

OBION WEAKLEY

DYER GIBSON

LAUDERDALE

HAYWOOD

FAYETTE

CROCKETT

BENTON

SHELBY

TIPTON

HENRY

CARROLL HUMPHREYS

HENDERSONMADISON

HARDEMAN McNAIRY HARDIN

HOUSTON

STEWARTROBERTSON

MONTGOMERY

DICKSON

CHEA

THAM

PERRY

HICKMANWILLIAMSON

DAVIDSON

MAURY

LEWIS

WAYNE LAWRENCE

MARSH

AL

L

GILES

SUMNERMACO

NTROUSDA

LE

WILSON

RUTHERFOR

D

BEDFORD

LINCOLN

SMITH

DEKALB

WHITE

PUTNAM

JACKSON

CLAY

CANNON

COFFEE

FRANKLIN

MO

OR

E

PICKETT

OVERTON

FENTRESS

CUMBERLAND

BLEDSO

E

WARREN

VAN

BUREN

GRUNDY

SEQUATCH

IE

MARION

SCOTT

MORGAN

CAMPBELL

ROANE

LOUDON

RHEA

HAMILTO

N BRADLE

Y

McMINN

POLK

MEI

GS

MONROE

BLOUNT

SEVIER

KNOXANDERSO

N

CLAIBORNE

GRAING

ER

JEFFERSON

HANCOC

K HAWKINS

SULLIVAN

JOHNSO

NCARTE

R

UNICOIHAMBLE

NGREENE

COCKE

WASHIN

GTO

NUNIO

N

Corey Currie, CPMCindy Smith, Fiscal

Michelle Mansfield, CPMBrad Davis, Fiscal

Bridgett Carwile, CPMRob Mynhier, Fiscal

Courtney Woods, CPMBrian Runion, Fiscal

Deborah Thompson, CPMDustin Winstead, Fiscal

Jacki Wolfe, CPMJackie Broyles, Fiscal

120 Chester200 Decatur240 Fayette350 Hardeman360 Hardin380 Haywood390 Henderson

391 Lexington (PK-8)

490 Lauderdale550 McNairy570 Madison 680 Perry792 Shelby

793 Arlington796 Germantown794 Bartlett798 Millington795 Collierville797 Lakeland

840 Tipton

960 West TN School for Deaf

030 Benton090 Carroll

092 Hollow Rock- Bruceton

093 Huntingdon094 McKenzie 095 South Carroll097 West Carroll

170 Crockett171 Alamo (PK-6)

172 Bells (PK-5)

230 Dyer231 Dyersburg City

275 Gibson271 Humboldt City272 Milan SSD273 Trenton274 Bradford SSD

400 Henry401 Paris SSD (K-8)

420 Houston430 Humphreys480 Lake660 Obion

661 Union City810 Stewart920 Weakley

985 ASD

110 Cheatham140 Clay180 Cumberland190 Davidson 210 DeKalb220 Dickson250 Fentress440 Jackson560 Macon630 Montgomery670 Overton 690 Pickett710 Putnam740 Robertson800 Smith830 Sumner850 Trousdale930 White950 Wilson

951 Lebanon SSD (PK-8)

 

970 Dept of Children’s Serv.971 Dept of Corrections963 TN School for the Blind961 York Institute (9-12)

020 Bedford040 Bledsoe080 Cannon160 Coffee

161 Manchester (PK-8)

162 Tullahoma260 Franklin280 Giles310 Grundy410 Hickman500 Lawrence 510 Lewis520 Lincoln

521 Fayetteville 580 Marion

581 Richard City 590 Marshall600 Maury640 Moore750 Rutherford

751 Murfreesboro (PK-6)

770 Sequatchie880 Van Buren890 Warren910 Wayne940 Williamson 941 Franklin SSD (PK-8)

010 Anderson 011 Clinton (PK-6)

012 Oak Ridge

050 Blount 051 Alcoa City 052 Maryville 060 Bradley

061 Cleveland070 Campbell330 Hamilton530 Loudon

531 Lenoir City

540 McMinn541

Athens City (PK-9)

542 Etowah City (K-8)

610 Meigs620 Monroe

621 Sweetwater (PK-8)

650 Morgan700 Polk720 Rhea

721 Dayton City (PK-8)

730 Roane760 Scott

761 Onieda

100 Carter 101 Elizabethton

130 Claiborne150 Cocke

151 Newport City (K-8)

290 Grainger300 Greene

301 Greeneville

320 Hamblen340 Hancock370 Hawkins

371 Rogersville (K-8)

450 Jefferson460 Johnson County470 Knox

780 Sevier 820 Sullivan

821 Bristol 822 Kingsport

860 Unicoi Co870 Union Co900 Washington 901 Johnson City

964 East TN School for Deaf

Central Time Zone Eastern Time Zone

Revised 8/17/2015

CHESTER DEC

ATU

R

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NOTICE: This agency is a recipient of taxpayer funding. If you observe an agency director or employee engaging in any

activity which you consider to be illegal, improper or wasteful, please call the state Comptroller’s toll-free Hotline:

1-800-232-5454

Notifications can also be submitted electronically at:

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