Update on Categorical Program Monitoring

1. Update on Categorical Program Monitoring Accountability Leadership Institute for English Learner, Immigrant and Migrant StudentsHyatt Regency, Burlingame, CADecember 8, 2009Héctor Rico, DirectorCategorical Compliance DivisionPatrick McMenamin, AdministratorCategorical Program Monitoring OfficeKevin W. Chan, DirectorAudits and Investigations Division Sylvie Hale, Director, WestEd Interactive

2. A Few Facts • Non-mandated on-site reviews suspended for one year from February 2009http://www.cde.ca.gov/ta/cr/cc/onsitecpmhalt.asp • LEAs continue to be responsible for maintaining compliant programs • Uniform Complaint Procedures continue • Online CPM resources (update in progress) http://www.channelservernetwork.com/ • Categorical flexibility provisions affected only some programshttp://www.cde.ca.gov/nr/el/le/09ltr0225bdgt.asp • Monitoring” and follow-up monitoring continue

3. Risk Analysis-Based Monitoring • At least ten (from Cycle C) on-site reviews to be conducted early 2010, based on risk analysis • Risk analysis will help determine which LEAs receive on-site reviews • status with Title I-III accountability systems • Categorical funds carryover percentage • Categorical funds (including ARRA) per pupil allocation

4. Risk Analysis-Based Monitoring • Programs and funds of focus for early 2010 reviews: • Title I: Parts A (Basic/CE/PI) , C (Migrant), D (NorD) • English Learners (including Title III) • Title II • Title X (Homeless) • EIA (SCE&LEP), ARRA (Title I, Homeless, SFSF) • Other than these key points, will be similar to previous CPM process

5. Previous CPM Process • One-quarter of LEAs reviewed each year within a four year cycle • All compliance items (for programs selected) reviewed during on-site review • On-line (CAIS) piloted in regions 4 and 10 (NC findings not issued based only on on-line review) • Student achievement data reviewed for every LEA in cycle • Several factors (e.g. API, PI status, non-compliance history) used for on-site selection

6. CPM Redesign In Progress • If you wish to provide us with suggestions, recommendations, things to consider, etc., please jot them down and leave with us before the end of today’s session or e-mail them to cpmredesign@cde.ca.gov • There will be additional opportunities for input after today.

7. CPM Redesign In Progress • The use of CAIS will be expanded • CAIS allows LEAs to demonstrate compliance with select program requirements every year • Risk assessment will help determine which LEAs receive on-site reviews • status with Title I-III accountability systems • Categorical funds (including AARA) carryover percentages • Categorical funds (including AARA) per pupil allocations • Total entitlements, Audit findings, Others?

8. CPM Redesign In Progress • Compliance findings will be based on: • Review of e-documents • On-site reviews • Combination of e-documents and on-site reviews • Increased emphasis on fiscal components

9. Timelines • Pilot of redesigned CPM process to be implemented Spring 2010 (LEAs to be selected from Cycle D) • Full implementation of redesigned CPM process planned for 2010-2011 school year • Further redesign information and input gathering forums in January 2010

10. Fiscal Monitoring • Fiscal monitoring is not an “Audit.” It is an extension of CDE’s CPM process. • The objective of fiscal monitoring is to ensure that public funds are being appropriately expended and utilized in accordance with applicable state and federal program regulations.

11. Why Fiscal Monitoring? • Federal agencies require CDE to monitor sub-recipients use of program funds. • Unprecedented high level of accountability due to funding through the American Recovery and Reinvestment Act (ARRA).

12. Fiscal Monitoring Process • Processes under development. • Coordinated with CPM. • Utilize the California Accountability and Improvement System (CAIS) as much as possible. • The fiscal monitoring process involves either a desk or on-site review process.

13. Desk Review Process • No on-site review. • Staff review accounting records and supporting documentation utilizing CAIS or other electronic means where possible. • Staff summarize identified findings, provide technical assistance and recommendations to LEAs. • LEAs will be responsible for implementing corrective action. • Staff will follow-up on LEA’s corrective action.

14. On-Site Review Process Staff may visit LEAs to: • Meet with LEA staff to discuss and assess expenditure and cost allocation methodologies. • Review LEA’s internal controls and accounting records. • Staff summarize identified findings, provide technical assistance and recommendations to LEAs. • LEAs will be responsible for implementing corrective action. • Staff will follow-up on LEA’s corrective action.

15. Fiscal Components • Internal Controls • Allowable Costs • Timekeeping Requirements • Supplement Not Supplant • Direct Service Requirements • Cash Management 15

16. CA Accountability & Improvement System (CAIS) • Developed in collaboration with the CACC at WestEd • On-line system: • Storage and retrieval of LEA documents • Compliance management tool • Communication tool • Supports an LEA’s ongoing monitoring of programs

17. CA Accountability & Improvement System (CAIS) • Capacity to link to other (non-CPM) accountability systems at the CDE • Encourages a common approach across programs and CDE • Engages stakeholders and fosters collaboration • Reduces duplication and redundancy

18. CA Accountability & Improvement System (CAIS) Saves resources, time and money Improves communication and information management Provides consistent structure and processes Offers opportunity for targeted technical assistance

19. CA Accountability & Improvement System (CAIS) • Pilot Results: • 100+ LEAs trained • 4 of 45 LEAs monitored last year piloted CAIS • Some LEAs used CAIS even after suspension • LEAs report ability to manage ongoing compliance, ease of information management • State staff report greater efficiency • All LEAs will eventually participate

20. Feedback on CAIS Improved coordination and communication with State as well as between State and LEA. Improved service delivery and support to LEAs. Improved reach and efficiency of compliance monitoring processes. Increased ability to identify needs, target resources and monitor use of funds for improvement. Findings from Preliminary Internal Evaluation Report, 2009

21. CAIS Presentation Here

22. For More Information CPM Office Telephone: 916-319-0935 http://www.cde.ca.gov/ta/cr/cc/ Audits and Investigations Division Telephone: 916-322-2288 ARRA website www.cde.ca.gov/ar/ 22