Marching Forward to Fiscal Accountability

1. Marching Forwardto Fiscal Accountability Exceptional Children Program Directors’ Leadership Institute Embassy Suites, Greensboro, NC March 13, 2013

2. EC DIRECTORS LEAD THE WAY! NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

3. EC Directors Lead The Way ... Information Communication Oversight Timely & Accurate Data NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

4. IDEA Fiscal Monitoring Tiers Audit Results On-Site Visit Preparation NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

5. Time & Effort Equipment Contracted Services Maintenance of Fiscal Effort Proportionate Share NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

6. 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

7. Time and Effort Reporting Single Cost Objective – Semi-Annual Certification (individual / blanket) Multiple Cost Objective – Personnel Activity Report (PAR) – Reconciliation Substitute System – State Approved NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

8. Cost Objective 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 costobjectives- employee works on more than one type of activity. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

9. Semi-Annual Certification Certification that an employee worked solely on a single federal cost objective for the period covered by the certification. Completed at least semi- annually. Semi-Annual NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

10. Semi-Annual Certification INDIVIDUAL: Signed by employee or supervisor who has first-hand knowledge of the work performed. BLANKET: Supervisor with first- hand knowledge of the work done certifies all federally-funded employees in the school, by the individual program. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

11. 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

12. Personnel Activity Report (PAR) Documentation of a distribution of the salaries or wages of an employee who works on multiple cost objectives. PAR NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

13. PAR Requirements 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

14. PAR Form Required Components 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 %. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

15. PAR – Reconciliation 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 comparisons show differences between budgeted and actual costs charged to the federal program are less than 10%. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

16. PAR – Audit Findings Incomplete effort statement. No monthly % allocation calculation. No reconciliation evidence. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

17. PAR – Substitute Systems 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

18. ??? Semi Annual PAR NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

19. 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. SEMI-ANNUAL 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? NO NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

20. 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 NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

21. 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 NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

22. EQUIPMENT Internal Controls (Policies and Procedures) Identification (Tag & Track) Inventory (at least every two years) NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

23. Equipment– Internal Controls Compliance with policies/procedures “Significant technological items” – Non-consumable, Useable life > a year, and Can be converted to personal use. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

24. Description Serial number / other ID number Source Title holder Cost Percentage of federal participation in cost Location Use, condition, disposition Acquisition cost Equipment – Identification NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

25. Equipment – Inventory Physical inventory at least every two years. Reconciliation with property records. Submission of Equipment Disposition Request Form. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

26. Equipment – Audit Findings Incomplete policies/procedures (purchasing, physical inventory, federal funds use/nonuse) Incomplete management records (identification, physical inventory) NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

27. CONTRACTED SERVICES WHO? WHAT? WHEN? WHERE? NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

28. Contracts Invoices for contracted services must be supported by a valid contract. Expenditures from contract codes (i.e. 311, 317, 318, 331, 344) MUST have a contract. Check the Debarment & Suspension list of vendors before contracting. Review and approve all special education services contracts and invoices. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

29. 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? NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

30. Maintenance of Fiscal Effort (MOE) 4 ways to march into maintaining effort… State & Local Total Expenditures Local Expenditures Only State & Local Total Per Child Expenditures Local Expenditures Per Child Only NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

31. MOE Exception §300.204 Voluntary 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). NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

32. 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

33. MOE - Audit Findings Completion 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

34. Proportionate Share Plan Spend Track PRC 060 NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

35. Proportionate Share – Eligible Parentally-Placed Private School Children Consultation (annual / ongoing). Child Count (annual / October 1 – December 1). Calculation (allotment÷eligible public+private school children=per child amounteligible private school children=total proportionate share). Carryover funds provision. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

36. Proportionate Share – Audit Findings No evidence of PRC 060 expenditure. No evidence of expenditure tracking system. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

37. Proportionate Share Personnel providing services under the proportionate share requirement and general special education must complete a PAR for Time & Effort Documentation. TRUE FALSE NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

38. Coordinated Early Intervening Services (CEIS) Aim High! NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

39. CEIS Requirements 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

40. CEIS Funds 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. NCDPI/ECD_Directors'Institute2013_FiscalMonitoringVH

41. ONE BAND, ONE SOUND