Monitoring and Technical Assistance

1. Monitoring and Technical Assistance Pat Meyertholen and Lisa Gillette Annual Directors Meeting February 29, 2012

2. Objectives • Understand OME’s MEP monitoring process and procedures • Discuss MEP requirements as they relate to common findings • Gather ideas for addressing challenging monitoring findings

3. Overview FEDERAL Monitoring of SEAs • Why does OME conduct program reviews? • Who does OME review? • What topics are covered? • How does OME conduct monitoring? • What are the most common findings?

4. Why does OME conduct Reviews? Provide evidence of the State’s compliance with applicable statutes/regulations. Identify exemplary practices that can be used as a model for others. Determine where the State could benefit fromFederal technical assistance.

5. Who does OME review? The MEP is a STATE-operated and STATE-administered program. As such, OME reviews the SEA. LOAs are interviewed to observe the SEA’s administration of the program at the local level.

6. How does OME review and What topics does OME review? An onsite review is usually a comprehensive examination of several topic areas A desk or targeted review is usually based on a risk assessment, outstanding monitoring findings, and/or current/prior audit findings.

7. How does OME review and What topics does OME review? • Prior to a review, States must submit documents requested on the “Document Request List” (may be modified for targeted reviews) • SEA and LOA monitoring instruments provide a more detailed look at most review topics (may be modified for targeted reviews)

8. Risk Assessment Risk Indicators • Personnel (1 & 2) • Program Monitoring (3, 4, & 5) • Audit Findings (6) • Past Performance (7) • Current Performance (8) • Unexpended Balance (9) • Designated as “High Risk” by the Department (10)

9. Self-Guided Activity • Review the draft risk assessment • Think about how your State would score • What modifications/improvements could you make to change your score?

10. Frequent Monitoring Findings • Evaluation & Improvement • Parent Advisory Councils • Priority for Services • Fiscal Management • Subgrant Formula • Service Delivery Plan • Comprehensive Needs Assessment • ID&R - Quality Control • Subrecipient Monitoring • Child Eligibility/COE Documentation

11. Small Group Activity • Each group will receive a common monitoring finding • At your table, discuss the requirement and finding: • How does your State implement the requirement? • How would your State resolve the finding? • What challenges would your State face? • Report out to the large group: • Describe your tables ideas for resolving the finding • Describe the challenges that might arise

12. Program EvaluationRequirements • Section 1304(c)(5) - SEAs are required to determine the effectiveness of their programs and projects, where feasible, using the same approaches and standards that are used to assess the performance of students, schools, and LEAs under Title I, Part A. • 34 CFR 200.84 – SEAs must determine program effectiveness through a written evaluation that measures the implementation and results achieved by the program against the State’s performance targets, particularly for PFS students. • 34 CFR 200.85 - requires SEAs to use evaluation results at the State and local level for program improvement.

13. Program EvaluationCommon Findings • The SEA does not have a written evaluation that measures both program implementation and results. • The SEA’s evaluation does not examine the implementation and results of the program in relation to PFS kids.

14. Parent Advisory CouncilRequirements • Section 1304(c)(3) - SEAs and LOAs must consult with PACs in planning and operating the MEP for programs of one school year in duration. • All programs and projects must be carried out in a manner consistent with Section 1118, unless extraordinary circumstances exist.

15. Parent Advisory CouncilRequirements • All programs and projects must be carried in a format and language understandable to the parents. • 34 CFR 200.83 - SEAs must develop their comprehensive State plans (SDPs) in consultation with the State PAC if the program is one school year in duration. If less than one school year in duration, the SEA must consult with migrant parents.

16. Parent Advisory Council Common Findings • The SEA or LOA has not established a PAC • The SEA or LOA does not consult with the PAC about the comprehensive needs assessment, service delivery plan, or other activities related to program implementation • The SEA or LOA is not consulting with the PAC in a meaningful way.

17. Priority for Services Requirements • Section 1304(d) – Priority for services is given to children (1) who are failing or most at risk of failing to meet State standards AND(2) whose education has been interrupted during the regular school year.

18. Priority for ServicesCommon Findings • The SEA has not defined “failing or at risk of failing” or “interruption during the regular school year” • The SEA has not provided guidance/training to its LOAs defining PFS and identifying PFS children for services • The LOAs are not correctly identifying which migrant students have PFS • There is no evidence that PFS students are being served before non-PFS students or that those services are meaningful • The SEA is not monitoring LOAs on identifying and serving PFS students.

19. Fiscal ManagementRequirements • OMB Circular A-87, Attachment A – Cost Principles (2 CFR Part 225) – costs must be, among other things: necessary and reasonable, allocable to the MEP, consistent with policies and procedures that apply uniformly to both Federal and non-Federal funds, and permitted by the Circular’s “Selected Items of Cost”. • Sections 1120A and 1304(c)(2) – Federal funds shall be used only to supplement, and not supplant, the funds that would, in the absence of such Federal funds, be made available from non-Federal sources for the education of migratory children.

20. Fiscal ManagementRequirements • Section 1112(b)(1)(J) – Migrant children must be selected to receive Title I services on the same basis as other eligible children. • Section 1306(b)(2) - Funds shall be used to address the needs of migrant children that are not addressed by services available from other Federal or non-Federal programs.

21. Fiscal ManagementCommon Findings • Unallowable costs • MEP-funded staff are used to perform duties for Titles I and III • The amount of MEP funds contributing to a split-funded summer program is not in proportion w/ the number of migrant kids attending • Supplement, Not Supplant • MEP funds used to provide regular school day ESL classes to migrant students while local funded ESL teachers provides services to non-migrant kids

22. Fiscal ManagementCommon Findings • Using MEP funds to address needs that should be addressed by other Federal programs • MEP children are not afforded opportunities to participate in IA services in the same way as all children

23. Subgrant ProceduresRequirements • Section 1304(b)(5) – The State must describe in its State application how it will determine the amount of any subgrant it will award to local operating agencies, • In determining subgrant amounts, the State must take into account (1) the numbers of migratory children, (2) the needs of migratory children, (3) the requirement to serve PFS children first, and (4) the availability of other Federal, State, and local program funds.

24. Subgrant ProceduresCommon Findings • SEAs do not update their consolidated State applications when they make changes to their subgrant procedures. • SEAs do not take into account all four factors. • SEAs do not describe their procedures for all subgrants. Instead, they only describe procedures for direct services provided by LOAs.

25. Resources • Statute • Regulations • Guidance • Monitoring Instrument • Colleagues in your state • Colleagues from other states • OME Program Officer If you would like more information about MEP requirements, how to prepare for a monitoring visit, or how address specific monitoring findings, please look at or talk to the following: