Financial and Programmatic Monitoring ESEA/Act 807 ACSIP

1. Financial and Programmatic MonitoringESEA/Act 807ACSIP Arkansas Department of Education Division of Public School Accountability

2. Federal & State Monitoring Unit John Hoy, Assistant Commissioner Willie Morris, Director Wes Whitley, Coordinator Barbara Means, Monitor Charles Nowak, Monitor Wendy Reed, Monitor

3. Act 807 State of Arkansas 86th General Assembly Regular Session, 2007 2.0 Purpose: • 2.01 - To expand monitoring and implementation of school improvement plans (i.e., ACSIP) by the Department of Education • 2.02 - To monitor the use of “Instructional Facilitators” • 2.03 - To ensure statutory compliance • 2.04 - To provide technical assistance

4. Purpose of Monitoring –The Department will periodically monitor each LEA (district) and selected schools to determine if the district is in compliance regarding the implementation of ACSIP. A team of monitors shall conduct a site visit to: • Determine whether the evaluation conducted by the public school/LEA was conducted properly; • Assess the areas in which the school or LEA needs to revise its plan; • Review the school/LEA’s performance during the preceding two years, including the documented academic performance of its students; • Review the use of public school funding under the Public School Funding Act of 2003, Ark. Code 6-20-2301 et. Seq. (i.e., Categorical Funding).

5. Monitoring Cycle 6 year cycle 45Districts Scheduled 2013-2014 School Year (Oct – May)

6. Prior to On-site Visit - • The LEA will receive the following: • An e-mail/phone call announcing the visit • Registered Letter of Notification – This letter will include a list of schools that will be monitored • Monitoring Guide (checklist) and Protocol • Confirmation of dates and schedule of events • The LEA (Superintendent or designee) will ensure that all documentation is organized, readily available, aligned to the monitoring guide and consistent by section and subsection. • Contact us if you have any questions or concerns.

7. Visit • Start Time 9:00 a.m. • Visit conducted at central office • All documentation (school/district) will be examined at the central office • Monitors will interview LEA staff and review evidence to verify Federal/State compliance • Staff to have at meeting: • Federal Program Coordinator • Principal or designee of selected schools (found in the Notification Letter) • Parent Involvement Coordinator • Homeless Liaison • ALE-ELL Coordinator • Neglected Part A Program Coordinator • Other Relevant Staff • School visits conducted (as applicable)

8. Exit Conference with LEA • An informal meeting with LEA designees will be held to summarize: • Monitoring activities • Potential findings • Recommendations • Timelines for developing the monitoring report

9. Post-visit Protocol • Written Preliminary Monitoring Report • 20 Days (from the date of the Exit Conference) • LEA Response • 30 Days (from receipt of SEA Preliminary Report) • Final Report from ADE • 60 Days (from the date of the Exit Conference)

10. Programs To Be Monitored - • Alternative Learning Environments (ALE) • National School Lunch Act (NSLA) • English Language Learners (ELL) • Professional Development (PD) • Title I • Title IIA • Title III • Title VI (State & Federal) • Title X State Programs Federal Programs

11. Financial and Programmatic Monitoring Guide - Legal Requirement(s) (Rules, Laws and Statutes)

12. Financial and Programmatic Monitoring Guide (cont.) - Compliance Indicator(s) (The answers to these questions will determine the level of compliance)

13. Financial and Programmatic Monitoring Guide (cont.) - Monitoring Guide Key Implemented (I) – Compliance with all indicators Implementation in Progress (IP) – Scholastic Audit and New Interventions/Actions Partially Implemented (PI) – Recommendations Not Implemented (NI) – Findings Not Applicable (NA)

14. Financial and Programmatic Monitoring Guide (cont.) - Potential Evidence (Documentation of the Compliance Indicators)

15. Financial and Programmatic Monitoring Guide (cont.) - The Financial and Programmatic Monitoring GuideSection Titles and Numbers

16. Financial and Programmatic Monitoring Guide (cont.) - District and/or School (where the record keeping should originate)

17. Common Findings and examples- • Supplement vs. Supplant • CSR • Incomplete Planning Meeting Evidence • It is recommended that all meetings should be accompanied with agendas, sign-in sheets denoting names and positions, and minutes for each meeting. In addition, meeting agendas in which federal programs planning is conducted must be unique to the entitlement. Meeting agendas which only describe ACSIP as the topic, fail to meet the requirements necessary for specific planning requirements of entitlement law. Meetings should reflect that topics such as Title I Schoolwide, data, program research etc. are being discussed. • Adequate evidence that parents have been involved in entitlement program planning • All required planning meetings involving parent participation should be accompanied with sign-in sheets denoting the parent names. It is a requirement of federal funds grantees that parents participate in all stages of program planning and that documentation is archived by the LEA to support parent involvement.

18. COMMON FINDINGS and examples CONT’D • Homeless list • FINDING (NI): A review of LEA records indicated that the LEA had no policy, procedures, or guidelines for identifying, enrolling, and addressing the educational needs of homeless children and youth. It is noted that the LEA had made a fund reservation of Title I, Part A funds for Homeless. CORRECTIVE ACTION: The LEA must remit to the Office of Federal and State Monitoring copies of procedures and guidelines for identifying and enrolling homeless children. These policies must provide assurance that homeless children have access to activities and programs that address their educational needs and do not inhibit comparable services to students so identified. • ADE Schoolwide approval letters • FINDING: On the day of the visit, the LEA was cited with a finding of partially implemented (PI) for Section II-1. During a review of the LEA’s documentation, it was discovered that the district did not have a Schoolwide approval letter from the ADE. Currently the LEA is operating Title I Schoolwide Projects at both of its campuses. CORRECTIVE ACTION: The LEA must contact the Federal Programs Unit of the ADE and secure the necessary approval letter for the operation of a Title I Schoolwide Project. Once this authorization letter has been received, a copy of it must be forwarded to the Federal and State Monitoring Unit. This authorization will verify that the Federal Programs Unit of the ADE has reviewed all relevant requirements pertaining to the LEA’s status as a Title I schoolwide and will satisfy aforementioned area of non-compliance.

19. COMMON FINDINGS and examples CONT’D • Excessive district fund reservations • The district ACSIP as written gives the false appearance of reservation of funds at the district level. The district is advised to allocate all supplemental funds to schools and only place in the district ACSIP an amount that is reasonable and necessary to administer the program. • Incomplete equitable services documentation • The District has made contact with four Private Schools to notify each of the rights of students and teachers to benefit from federal entitlement funds; however, the contact was not timely. Each of the four private schools was contacted by certified mail on August 23, 2011. Private schools choosing to participate were therefore unable to complete the consultations necessary to begin an educational program in a timely fashion. The LEA was counseled regarding the timeliness of their responsibility in contacting private schools and will ensure that in the future the notices to private schools will be conducted each spring in order that sufficient time will exist to adequately consult and plan for programming.

20. COMMON FINDINGS and examples CONT’D • School level compliance review • Unallowable expenditures (peer review) • It is recommended that the district establish (or re-visit) a systematic internal control process for allowable costs and programmatic restrictions for entitlement funds. As the grant recipient, it is the district’s responsibility to review all entitlement expenditures for allowable uses prior to submission of the ACSIP to the SEA. • A review of Title I expenditures in the district plan revealed unallowable expenditures for administrative conferences. The district was advised to reimburse Title I for the amount of these conferences, and pay for those conferences with an allowable funding source. • The LEA must continue to review actions in the ACSIP that contain NSLA funds. NSLA funds are restricted use funds and all expenditures are subject to the restrictions found in the Rules for Special Use Funding (revised June 2011). • During the on-site review of the Expenditure Audit Trail for Title I Funds it was observed that Title I funds had been used to reimburse expenditures for Quiz Bowl activities. The LEA was informed at that time that the use of Title I funds for this activity is not allowable.

21. Closing - • The six-year monitoring list was modified to make sure that no district would have a Standards Monitoring and a Federal/State Monitoring within the same school year. • The items listed below were revised and released in a Commissioner’s Memo and are posted on the ADE website: • Six-Year Monitoring Schedule • 2013-2014 Monitoring Schedule • 2013-2014 Monitoring Protocol • 2013-2014 Monitoring Guide • 2013-2014 Training PowerPoint • 2013-2014 Training Schedule • 2013-2014 Training Agenda

22. Contact Information - • Willie Morris (501)682-4472 • Willie.Morris@arkansas.gov • Wes Whitley (501)682-4389 • Wes.Whitley@arkansas.gov • Charles Nowak (501)682-5295 • Charles.Nowak@arkansas.gov • Barbara Means (501)682-2259 • Barbara.Means@arkansas.gov • Wendy Reed (501)682-1188 • Wendy.Reed@arkansas.gov

23. Resource Information Please see the new Arkansas Dept. of Ed Website for additional information. Use the following links: ADE Divisions Public School Accountability Federal/State Monitoring