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

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