marching forward to fiscal accountability exceptional children program directors’ leadership...

Marching Forwardto

Fiscal Accountability

Exceptional Children Program Directors’ Leadership Institute

Embassy Suites, Greensboro, NC March 13, 2013

EC DIRECTORS LEAD THE WAY!

2NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

EC Directors Lead The Way ...

Information

Communication

Oversight

Timely & Accurate Data


IDEA Fiscal Monitoring

Tiers

Audit Results

On-Site Visit Preparation


Time & Effort

Maintenance of Fiscal Effort

ContractedServices

Equipment

Proportionate Share


Time and Effort Documentation

All employees who are paid

from federal funds, or

whose salaries are used to

match federal funds, must

document their time and effort.

Time and effort documentation

serves as a “receipt” for payroll

expenditures.6NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

Single Cost Objective – Semi-Annual Certification (individual / blanket)

Multiple Cost Objective

– Personnel Activity Report (PAR)

– Reconciliation

Substitute System

– State Approved

Time and Effort Reporting


It’s a federal term that refers to a function, organizational subdivision, contract, grant, or other activity for which cost data are needed and for which costs are incurred.

Single federal cost objective-100% of your employee’s time is spent on specific activities allowed in the grant.

Multiple federal cost objectives- employee works on more than one type of activity.

Cost Objective


Certification that anemployee worked solely ona single federal cost objective for the period covered by the certification.Completed at least semi-annually.

Semi-Annual Certification

Semi-Annual


INDIVIDUAL: Signed by employeeor supervisor who has first-hand knowledge of the work performed.

BLANKET: Supervisor with first-hand knowledge of the work done certifies all federally-fundedemployees in the school, by theindividual program.

Semi-Annual Certification


Semi-Annual Certification – Audit Findings

Statements did not include language - “IDEA Activities”.

Signatures dated before ending period.

Period and signature not included on blanket certifications with multiple employee lists.


Documentation of a

distribution of the

salaries or wages of an

employee who works

on multiple cost

objectives.

Personnel Activity Report (PAR)

PAR


Reflect an after-the-fact distribution of the actual activity;

Account for the total activity for which employee is compensated;

Prepared at least monthly and coincide with 1 or more pay periods;

Maintained support documentation;and

Signed by the employee.

PAR Requirements


Effort statement that accounts for 100%of employee’s effort;

Specific cost objective (not just “federal”);

Number of hours worked (no “X” entries);

Time worked on ALL cost objectives; and

Weekly and monthly allocation %.

PAR Form Required Components


Comparisons: Actual costs (based on monthly PAR reports) to budgeted distributions at least quarterly.

Adjustments:

Immediately, if quarterly comparisons show differences between budgeted and actual costs charged to federal program are 10% or more. Annually, if quarterly comparisonsshow differences between budgetedand actual costs charged to thefederal program are less than 10%.

PAR – Reconciliation


PAR – Audit Findings

Incomplete effort statement.

No monthly % allocation calculation.

No reconciliation evidence.


Plan approved by DPI that specifies the months that PAR forms will be completed;

The next year’s number of reporting months is recalculated annually;

Comparisons must be conducted each time an employee completes a PAR (2 or 3 times a yr.);

The adjustment must be conducted immediately, regardless of the difference (+/− 10%); and

Handbook must be maintained and updated.

PAR – Substitute Systems


???

Semi Annual

PAR


Semi-Annual Certification or PAR???Question 1: An elementary special education teacher is paid 50% from federal PRC 60 and 50% from state PRC 32.

Would it make any difference if the special education teacher worked part of the day in an elementary school and part of the day in a middle School?


SEMI-ANNUAL

NO

Semi-Annual Certification or PAR???

Question 2: EC/Title I Director is paid 60% with federal PRC 60 funds and 40% with federal Title I funds.


PAR

Semi-Annual Certification or PAR???

Question 3: A preschool teacher has 12 students in her class-4 funded with special education federal PRC 49 funds, 4 funded with federal Title I funds and 4 funded with state More At 4 funds.


SEMI-ANNUAL

Internal Controls (Policies and Procedures)

Identification (Tag & Track)

Inventory (at least every two years)

EQUIPMENT


Equipment – Internal Controls

Compliance with policies/procedures

“Significant technological items” – Non-consumable, Useable life > a year, and Can be converted to personal use.


Description

Serial number / other ID number

Source

Title holder

Cost

Percentage of federal participation in cost

Location

Use, condition, disposition Acquisition cost

Equipment – Identification


Equipment – Inventory

Physical inventory at least every two years.

Reconciliation with property records.

Submission of Equipment Disposition Request Form.


Equipment – Audit Findings

Incomplete policies/procedures (purchasing, physical inventory, federal funds use/nonuse)

Incomplete management records(identification, physical inventory)


WHO?WHAT? WHEN? WHERE?

CONTRACTED SERVICES


Contracts

Invoices for contracted services must besupported by a valid contract.

Expenditures from contract codes (i.e. 311,317, 318, 331, 344) MUST have a contract.

Check the Debarment & Suspension list ofvendors before contracting.

Review and approve all special education services contracts and invoices.


Would you blow the whistle on this contract?

− Merry Marching School District (MMSD) has purchased services from Stepping Related Services (SRS) for the 2012-13 school year.

− In your packet you will find a contract between MMSD and SRS, and an invoice from MMSD for the month of August.

What corrections would you require before you would approve this invoice for payment?


Maintenance of Fiscal Effort (MOE)

4 ways to march into maintaining effort…

State & Local Total Expenditures

Local Expenditures Only

State & Local Total Per Child ExpendituresLocal Expenditures Per Child Only


MOE Exception §300.204Voluntary departure of special education/related service personnel, retirement/otherwise/just cause;

Decrease in enrollment of SWDs;

Termination of costly expenditures for long-term purchases, such as acquisition of equipment or construction of school facilities;

Termination of an exceptionally costly obligation to a particular SWD because child has left jurisdiction, aged out, or no longer needs special education; and/or

Assumption of cost by SEA high cost fund (PRC 114).


MOE Adjustment In Certain Fiscal Years §300.205

Increase in IDEA 611 funds since prior fiscal year;

”Meets Requirements” under IDEA (determinations);

No action taken against LEA by SEA under IDEA;

FAPE responsibility not taken away by SEA;

Not identified w/significant disproportionality; AND

Amount of funds intended for CEIS permissive use is counted toward maximum amount of expenditures LEA may reduce.


MOE - Audit FindingsCompletion of incorrect calculation form.

Justification form not submitted for reduction.

Inappropriate recording of federal expenditures.

Budgeted/encumbered entries on calculation form and not year-to-date expenditures.

Discrepancies between calculation form and expenditure reports.

Unidentifiable expenditures for transportation calculation. 33

NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

Proportionate Share

Spend

PRC 060

TrackPlan


Consultation (annual / ongoing).

Child Count (annual / October 1 – December 1).

Calculation (allotment÷eligible public+private school children=per child amounteligible private school children=total proportionate share).

Carryover funds provision.

Proportionate Share – Eligible Parentally-Placed Private School Children


Proportionate Share – Audit Findings

No evidence of PRC 060 expenditure.

No evidence of expenditure tracking system.


Personnel providing services under the proportionate share requirement and general special education must complete a PAR for Time & Effort Documentation.

TRUE

Proportionate Share

FALSE


Coordinated Early Intervening Services (CEIS) Aim High!


Provision for students K-12 (particularly K-3) not identified as SWDs, but need academic and behavioral support to succeed in general education.

Mandatory for LEAs identified with significant disproportionality based on race and ethnicity of SWDs with respect to identification, including specific disability categories, placement in particular educational settings, and incidence, duration and type of disciplinary actions.

LEAs must report the number of children who received CEIS, and the number of those children who subsequently received special education and related services during the two years after receipt of CEIS.

CEIS Requirements


Permissive use – up to 15% of total IDEA Part B funds (611+619).

Mandatory use – 15% of total IDEA Part B funds (611+619).

Funds transfer from PRC 060 to PRC 070.

Allowable use of funds for targeted CEIS students include personnel, contracted services and equipment.

CEIS Funds


ONE BAND, ONE SOUND

marching forward to fiscal accountability exceptional children program directors’ leadership...

Documents

fiscalmonitoringvh slide

effort documentation

single federal cost

single cost objective

employees time

multiple cost objectives

effort reporting

effort statement