21 st Century Community Learning Centers

1. 21st Century Community Learning Centers New Grantee Orientation

2. Our objectives for this training • Explain the culture of ADE 21st CCLC support and monitoring • Provide an overview of how to get started in implementing the grant CT

3. Agenda • Welcome & Introductions • Vision Team Table Facilitators • Fiscal & Programmatic Accountability • Meeting 21st CCLC Grant Requirements • Program Implementation • …but first, let’s address the elephant in the room CT

4. Elephant in the Room • Cycle XI Drawdowns: October / November • Enhanced Summer Program • Contract with an entity that offers exceptional youth programming • Offer STEM programming • Offer Technology Based Programming • Involve the program in Youth Quality Program Intervention (assessment tool / training offered by ADE) • Involve the program in Family Engagement Intervention (training to be offered by Dr. Maria Paredes through ADE) • Send a team to a professional development opportunity especially those facilitated by the ADE 21st CCLC Team CT

5. Introductions at your tables • Name • Where your from • Title / role • Level of experience with 21st CCLC Example: First year grantee or Fifth year grantee but new to the program CT

6. Fiscal & Programmatic Accountability Every dollar of 21st CCLC funds must be spent to forward the GOALS and OBJECTIVES of the grant and the school improvement plan. AY & PS

7. Fiscal & Programmatic Accountability Special Guests from the Arizona Department of Education: Gary R. Holland, MBA Audit Manager and C. Todd Mason Grants Manager AY & PS

8. Surviving ADE Fiscal Monitoring & Time and Effort Compliance Gary Holland Arizona Department of Education September 24, 2012

9. Presentation Focus on: • Fiscal Monitoring • Time & Effort • Potential Consequences of Non-Compliance

10. Grant Sub-recipient Duties Receiving Federal Grant Monies Entails both Programmatic and Financial Duties Including Proper Programming and Expenditure of Monies, Goals Achievement and the RelatedReporting

11. Monitoring During the course of the grant period, LEA’s are required to be monitored by ADE You are monitored by several entities to ensure that the grant is properly executed and achieves the goals set forth

12. Definition of Monitoring A process whereby the programmatic and business management performance aspects of a grant are reviewed by collecting and assessing information from reports, audits, site visits, and other sources

13. Why Compliance is Important • Ensure money is spent properly to achieve program goals • Program goals are to help kids and families • Non-compliance could result in “paying back” grant with M&O monies, suspension, and/or termination of grant • Losing future grants • Going to jail for fraud/illegal activities

14. What is Monitored? • Grant Expenditures • Time and Effort reporting • Fixed Assets • ADE Grants Management • American Recovery and Reinvestment Act (ARRA) IDEA Part B

15. Monitoring Expenses Check financial reports for: • Unallowable costs • Late cost transfers (expenses that are posted significantly later than incurred) • Budget deviations • Journal entries near end of funding period • Excessive or unreasonable expenses

16. Excessive Expenditures • All travel expenses must adhere to agency or state travel policies • Reasonable, NOT Excessive • Able to show clear link and benefit to program • Remember all expenses must receive prior approval from ADE

17. Fixed Assets All assets must be tracked and safeguarded Complete Fixed Asset report • Property Identification tag • Asset description • Purchase Date • Cost • Location

18. Time and Effort Reporting Missing Time and Effort report documentation is one of the most frequent and costly audit findings in the state All Federal Funds being used for Payroll expenses MUST have Time and Effort regardless of amount

19. Time and Effort Reporting OMB A-87 Time and Effort Reporting for Employees who are paid 100% from a SINGLE cost objective: An employee whose salary is paid in whole from one federal source must certify, on a semi-annual basis, that they “worked solely on that program (single cost objective) for the period covered by the certification” • The certification must be signed and dated by the employeeand may be signed by a knowledgeable SUPERVISOR

20. Time and Effort Reporting OMB A-87 Time and Effort Reporting for Employees who are paid from Multiple Cost Objectives: An employeewho works on more than one federal program, or on a combination of a federal programs and a non-federal program, mustmaintain personnel activity reports that accurately declare the amount of time the employee spends performing the federal work activity any other duties

21. Time and Effort Reporting OMB A-87 Time and Effort Reporting for Employees who are paid from Multiple Cost Objectives: • Report must reflect an “AFTER-THE-FACT” distribution of actual activities performed • Account for TOTAL activity for which employee is compensated • Must be completed at LEAST MONTHLY • Be signed and dated by the EMPLOYEE and may be signed by a knowledgeable SUPERVISOR

22. Time and Effort Reporting OMB A-87 What Type of Reporting is Needed: • Single cost objective →Semi annual certification • Multiple cost objectives →Monthly time reports or Personnel Activity Reports (PARs) ** Reminder - OMB A-87 applies to Districts only

23. Time and Effort Reporting OMB A-122 Non-Profit Organizations are required to maintain monthly Personnel Activity Report (Time and Effort) that accurately declare the amount of time the employee spends performing the federal work activity and any other duties • Report must reflect an “AFTER-THE-FACT” distribution of actual activities performed • Account for TOTAL activity for which employee is compensated • Must by completed at LEAST MONTHLY • Be signed and dated by the EMPLOYEEand may be signed by a knowledgeable SUPERVISOR

24. Time and Effort Reporting OMB A-122 What Type of Reporting is Needed: Monthly time reports or Personnel Activity Reports (PARs) Non-Profit organizations are required to maintain monthly personnel activity reports ** Reminder - OMB A-122 applies to Charters only

25. Time and Effort Reporting Common Missed Steps • No Time and Effort System at all • Staff failing to date the form after the effort has been completed • Stipends • Supplemental pay • Substitutes • Training/Professional Development • ESY (Extended School Year)

26. Additional Reference

27. Monitoring Findings Common Findings: Non-compliance with financial requirements of federal program • Inaccurate Fixed Asset/Inventory System Report • Purchasing Capital Assets that were not previously approved • Excessive or Unallowable Travel Expenses • Lack of adequate Time and Effort Reporting

28. Why Compliance is Important • Ensure money is spent properly to achieve program goals • Program goals are to help kids and families • Non-compliance could result in “paying back” grant with M&O monies, suspension, and/or termination of grant • Losing future grants • Going to jail for fraud/illegal activities

29. The Impact of Non-Compliance with Federal Requirements

30. The Impact of Non-Compliance with Federal Requirements

31. The Impact of Non-Compliance with Federal Requirements in AZ 2011/2012 Questionable Cost School/Charter: Questionable Cost: District A $ 222,396 Charter A $ 5,137 District B $ 29,546 District C $ 168,104 District D $ 7,833 District E $ 254,953 Charter B $ 46,600 School/Charter: Questionable Cost: District F $2,286,854 Charter C $ 41,166 District G $ 28,285 District H $ 178,540 District I $ 149,751 District J $ 102,959

32. Investigative Entities Depending on the finding the following may be involved: • Local Law Enforcement • Attorney General • Auditor General • Federal Dept of Ed Inspector General (OIG)

33. Investigation Examples Arizona Attorney General – School X • School X should use effective internal controls to demonstrate responsible stewardship for the tax dollars it receives • School X failed to comply with the USFR. AG noted certain deficiencies in controls to ensure its responsibility to establish and maintain adequate financial stewardship and to comply with the USFR

34. Investigation Examples Auditor General – School Y • Allegations of financial misconductby their former business manager • Internal controls over the disbursement process were inadequate • Specifically, check preparing, check signing, and recordkeeping duties were not properly segregated; supporting documents were not required to process transactions; and authorization controls were circumvented

35. Investigation Examples • Federal Inspector General – School Z School Z draw of grant funds on June 8, 2004 exceeded its immediate needs and, previous to that date, the District had made other excessive draws of grant funds

36. Questions, Concerns – PLEASE ASK: • ADE Federal Program Contact • ADE Grants Management • LEA Business and Grants Managers • LEA External Auditors • Gary Holland, M.B.A. • ADE Audit Unit (602)364-3518 gary.holland@azed.gov

37. Resources • OMB Source documents • www.whitehouse.gov/omb/circulars • Cost Principles – A-87 and A-122 • Audit Requirements – A-133 • Grants Management Common Rule • Code of Federal Regulations • Organized by Department • Education is 34 CFR 80 • ADE • www.ade.state.az.us • Review grant agreements

38. Fiscal Compliance for Recipients of 21st CCLC Funding • ADE is the pass-through agency for the 21st CCLC grant (Feds to State to LEA) • Sub-grant recipients (grantees) must comply with State and Federal guidelines for fiscal management, reporting and expenditures AY & PS

39. Fiscal Compliance • Grantees must comply with the signed General Statement of Assurance that is submitted yearly to the ADE (changes during the year need to be reported immediately) • Grantees are required to follow the ADE Business Rules • The same Federal/State Rules and Regulations apply for any contracted services hired with grant funding AY & PS

40. Fiscal Compliance • Cash management reporting and completion reports are areas of continuing concern for the ADE • Draw down based on 30 day projected need • District may not accumulate excess cash • ADE may request that excess cash be remitted back • Improper monthly cash management reporting will jeopardize reimbursement and continuation of funding AY & PS

41. Fiscal Compliance • Grantees are responsible for using grant monies as approved in their original awarded application and to implement what is WRITTEN in the awarded grant. Expenses must be in approved budget. • Sites that fail to serve the targeted number of students on their campus may be subject to a 25% reduction in funding. AY & PS

42. Fiscal Compliance • Supplement NOT supplant (define) • Programs must be equally accessible- if charge a fee must be nominal and used for a specific grant activity • Charging fees for sustainability is NOT allowed AY & PS

43. Fiscal Compliance • Burn Rate of Budget • Are expenses proportionate with programming? • Basic Guidelines • Ask yourself, is the purchase… • Necessary? • Reasonable? • Allocable? • Non-Regulatory Guidelines: • See page 26 section G. Local use of Funds. AY & PS

44. Business Rules • Guidelines • Applications • Indirect Cost Rate • Amendments (Programmatic / Fiscal) • Cash Management (Federal Projects) • Completion Reports AY & PS

45. Business Rules • Return of Funds • Carryover of Funds - NO CARRY OVER • Interest • Audit of Federal Programs • Compliance Checklist AY & PS

46. Fiscal Monitoring • A minimum of one on-site visit to fiscal agent per year • Fiscal monitoring visits may be unannounced • Request for Documentation (Fiscal Record Keeping Tabs i.e. T/E logs) • Non-Compliance Report/ Corrective Action Plan • Reduction of Funding Notice AY & PS

47. Record Keeping • ALL expenditures MUST be approved in awarded grant budget PRIOR to incurring expense • Record keeping should be kept current, follow approved budget and be available for review at any time • 21st CCLC Site Coordinator should keep track of ALL expenditures charged to grant, by budget line with current balance monthly (Excel sheet) AY & PS

48. Vision Team Processing Questions • What is clear or confusing regarding the fiscal requirements of the grant? • What strategy of fiscal and programmatic management do you already have in place? • What are some of the important decisions you will have to make regarding fiscal and programmatic management? • How do model sites handle the fiscal and programmatic management challenges and celebrations? VT Facilitators

49. Meeting 21st CCLC Grant Requirements “Why are after-school programs so important? Because children’s minds don’t close down at 3:00 p.m., and neither should their schools.” Richard W. Riley, Former U.S. Secretary of Education October 2000 MLN

50. Grant is the Blueprint • Know and understand grant objectives • Implement what is in YOUR proposal • Evaluate program to assess progress towards achieving goal of meeting grant objectives MLN