FY 2003 LEA FEDERAL COMPLIANCE OVERVIEW TITLE II-A PROGRAM CFDA 84.367

1. FY 2003 LEA FEDERAL COMPLIANCE OVERVIEWTITLE II-A PROGRAMCFDA# 84.367 PETER VIEN COORDINATOR FOR FEDERAL COMPLIANCE GA DEPT OF AUDITS & ACCOUNTS

2. FEDERAL PROGRAM REVIEW PROCESS GUIDELINES OMB CIRCULAR A-133 (SINGLE AUDIT ACT AMENDMENTS OF 1996) GAO STANDARDS (YELLOW BOOK) AICPA�S �AUDITS OF STATE AND LOCAL GOVERNMENTS���.SOP 98-3 OMB CIRCULAR A-133 COMPLIANCE SUPPLEMENT

3. FEDERAL PROGRAMS SELECTED FOR REVIEW CRITERIA CLASSIFY BY TOTAL EXPENDITURES TYPE A PROGRAM ( $300,000 OR 3% OF TOTAL EXPENDITURES ) TYPE B PROGRAM ( OTHER FEDERAL PROGRAMS WITH LESS THAN $300,000 or 3% OF TOTAL EXPENDITURES)

4. FEDERAL PROGRAMS SELECTED FOR REVIEW CRITERIA ASSESS RISK OF EACH FEDERAL PROGRAM� NEW PROGRAM CHANGE IN LEGISLATION/REGULATIONS, ETC OVERSIGHT EXERCISED BY FEDERAL AGENCIES/GDOE INHERENT RISK NOT RECENTLY AUDITED PRIOR AUDIT EXPERIENCE..FINDINGS!!

5. FEDERAL PROGRAMS SELECTED FOR REVIEW CRITERIA: IDENTIFY : ALL HIGH RISK TYPE A PROGRAMS ALL HIGH RISK TYPE B PROGRAMS SELECT: ALL HIGH RISK TYPE A PROGRAMS IF NEEDED�ADD ANY HIGH RISK TYPE B PROGRAMS TO MEET REQUIRED EXPENDITURE THRESHOLD

6. FEDERAL PROGRAMS SELECTED FOR REVIEW CRITERIA: THRESHOLD 50% OF TOTAL EXPENDITURES ..OR 25% OF TOTAL EXPENDITURES IF LEA HAD: UNQUALIFIED F/S OPINION NO MATERIAL WEAKNESSES IN F/S�S INTERNAL CONTROLS NO MATERIAL FEDERAL INTERNAL CONTROL/COMPLIANCE FINDINGS FOR THE PAST 2 YEARS

7. FEDERAL PROGRAM REVIEW PROCESS 14 COMPLIANCE REQUIREMENTS ACTIVITES ALLOWED/UNALLOWED ALLOWABLE COSTS/COST PRINCIPLES CASH MANAGEMENT DAVIS-BACON ACT ( N/A) ELIGIBILITY (N/A) EQUIPMENT/REAL PROP MANAGEMENT (N/A) MATCHING/LEVEL OF EFFORT/EARMARKING PERIOD OF AVAILABILITY

8. FEDERAL PROGRAM REVIEW PROCESS 14 COMPLIANCE REQUIREMENTS PROCUREMENT/SUSPENSION AND DEBARMENT PROGRAM INCOME (N/A) REAL PROPERTY /ACQUISITION /RELOCATION ASSISTANCE (N/A) REPORTING SUBRECIPIENT MONITORING SPECIAL TESTS AND PROVISIONS

9. FEDERAL PROGRAM REVIEW PROCESS INTERNAL CONTROLS ( 5 COMPONENTS) CONTROL ENVIRONMENT TONE OF ORGANIZATION INFLUENCING THE CONTROL CONSCIOUSNESS OF ITS PESONNEL ETHICS RESPONSIVENESS TO PRIOR FINDINGS/REMEDIES RESPONSIBILITIES DEFINED ADEQUATE TRAINING

10. FEDERAL PROGRAM REVIEW PROCESS INTERNAL CONTROLS RISK ASSESSMENT IDENTIFICATION & ANALYSIS OF RELEVANT RISKS TO ACHIEVE OBJECTIVES/BASIS FOR MANAGING RISKS PROGRAM MANAGERS HAVE IDENTIFIED KEY COMPLIANCE REQUIREMENTS IDENTIFIED RISKS OF NON-COMPLIANCE IDENTIFY/COMMUNICATE CHANGES EMPLOYEES GET REQUIRED SUPERVISION ARE IDENTIFIED IDENTIFIED COMPLEX OPERATIONS/PROJECTS/PROGRAMS AWARE OF MONITORING/REVIEWS/AUDITS/RELATED RISK OF NONCOMPLIANCE

11. FEDERAL PROGRAM REVIEW PROCESS INTERNAL CONTROLS CONTROL ACTIVITIES POLICIES/PROCEDURES THAT HELP MANAGEMENT�S DIRECTIVES TO BE ADEQUATELY CARRIED OUT OPERATING POLICIES/PROCEDURES CLEARLY WRITTEN/COMMUNICATED ADEQUATE SEGREGATION OF DUTIES PROPER EDIT CHECKS FOR COMPUTER CONTROLS PERSONNEL SUPERVISED..BASED ON LEVEL OF COMPETENCE/EXPERIENCE KNOWLEDGFEABLE/EXPERIENCED PERSONNEL DISCHARGES DUTIES GOVERNING BOARD MEETS/REVIEWS/ADDRESSES AND DISCUSSES MATERIAL ISSUES

12. FEDERAL PROGRAM REVIEW PROCESS INTERNAL CONTROLS INFORMATION AND COMMUNICATION IDENTIFIACTION/CAPTURE/EXCHANGE OF INFORMATION IN A FORM & TIMEFRAME THAT ENABLE PERSONNEL TO CARRY OUT THEIR RESPONSIBILITIES ADEQUATE SOURCE DOCUMENTATION KEPT RECORDS MAINTAINED FOR REQUIRED PERIODS TIMELY AND MEANINGFUL REPORTS ISSUED/REVIEWED AND APAROPRIATE ACTION TAKEN ACCURATE INFO IS ACCESSIBLE TO THOSE WHO NEED IT COMMUNICATION CHANNELS ESTABLISHED�STAFF MEETINGS/MEMOS/E-MAIL/ETC. EMPLOYEE�S DUTIES /RESPONSIBILITIES EFFECTIVELY COMMUNICATED PROPER COMMUNICATIONS W/SUBGRANTEES

13. FEDERAL PROGRAM REVIEW PROCESS INTERNAL CONTROLS MONITORING PROCESS THAT ASSESSES THE QUALITY OF INTERNAL CONTROL PERFORMANCE OVER TIME PERIODIC SITE VISITS INTERNAL QUALITY CONTROL REVIEWS PERFORMED ON-GOING MONITORING � INDEPENDENT RECONCILIATIONS/FEED BACK AT STAFF MEETINGS/ROTATING STAFF/SUPERVISORY REVIEWS OF REPORTS

14. FEDERAL PROGRAM REVIEW PROCESS INTERNAL CONTROLS ASSESSED THROUGH INTERNAL CONTROL QUESTIONNAIRE EACH APPLICABLE COMPLIANCE REQUIREMENT FOR TITLE II-A PROGRAM EACH OF THE 5 INTERNAL CONTROL COMPONENTS ADDRESSED

15. FEDERAL PROGRAM REVIEW PROCESS TITLE II-A PROGRAM COMPLIANCE REQUIREMENTS: ACTIVITIES ALLOWED/UNALLOWED PROFESSIONAL DEVELOPMENT .TEACHERS/ AS APPLICABLE PRINCIPALS/PARAPROFESSIONALS STRATEGIES FOR RECRUITING , HIRING & /RETAINING HIGH QUALITY TEACHERS/PRINCIPALS TEACHER ADVANCEMENT INITIATIVES FOR PROMOTING PROFESSIONAL GROWTH CAREER PATHS ESTABLISH PROGRAMS & ACTIVITIES FOR �EXEMPLARY TEACHERS� HIRE TEACHERS FOR CLASS SIZE REDUCTION

16. FEDERAL PROGRAM REVIEW PROCESS ALLOWABLE COSTS/COST PRINCIPLES Source: OMB Circular A-87, Cost Principles for State and Local Governments Costs�necessary, reasonable, allocable, and documented Direct Costs. identify with particular activity/function Typical costs include..personnel service costs, equipment, travel Review: personnel service expenses Non-personnel service costs Indirect Costs�incurred for a common purpose benefiting more than one objective Typical costs are; Utilities/procurement/human resource functions Review support of indirect cost rate/application of rate

17. FEDERAL PROGRAM REVIEW PROCESS CASH MANAGEMENT REQUEST/DRAWDOWN OF TITLE II-A FUNDS IN A MANNER TO ASSURE TIME/AMOUNT IS IN LINE WITH DISBURSEMENTS ANALYZE BALANCES/REQUESTS/DISBURSEMENTS

18. FEDERAL PROGRAM REVIEW PROCESS MATCHING, LEVEL OF EFFORT/EARMARKING Maintenance of Effort ( 90% rule) Non-federal expenditures for free education for FY 2002 no less than 90% of non-Federal expenses for FY 2001 Either in the aggregate or per student

19. FEDERAL PROGRAM REVIEW PROCESS MATCHING, LEVEL OF EFFORT/EARMARKING Supplement versus Supplant Were funds used for services: required by Federal, State or local law previously funded in PY from non-Federal funds for participating students. similar services provided from non-Federal sources for non-participating students Bottom line�will services be provided if Federal funds (Title II-A) not available!!!!

20. FEDERAL PROGRAM REVIEW PROCESS MATCHING, LEVEL OF EFFORT/EARMARKING Transferability Move funds to applicable federal fund Meets limitations.. Up to 50% of FY 2003 grant award Up to 30% of FY 2003 grant award. if LEA identified for school improvement Not allowable if funds designated for a school identified for corrective action

21. FEDERAL PROGRAM REVIEW PROCESS MATCHING, LEVEL OF EFFORT/EARMARKING Transferability Records should validate that LEA: Consulted w/private school staff/students Funds transferred based on priorities & after engaging w/ private school staff/students Modified federal plan to account for transfer Establish an effective date Notify GDOE ..30 days before effective date Significant change to plan..then revised plan provided to GDOE ..within 30 days after transfer

22. FEDERAL PROGRAM REVIEW PROCESS Period of Availability Funds expended in grant period Review expenditures at: beginning of and near end of grant period Review any transfer of funds

23. FEDERAL PROGRAM REVIEW PROCESS Procurement�Suspension/Debarment Requirements Review if material amount of funds expended to purchase/contract or provide funds to subrecipients Follow appropriate ( documented) procedures to obtain goods/services Are Contractors/Subgrantees certified �have not been suspended/debarred for violations

24. FEDERAL PROGRAM REVIEW PROCESS Reporting Accuracy and completeness of Title II-A Completion ( Financial) Report submitted to GDOE at end of FY Assess if it reconciles with accounting records As applicable..were transfer of funds properly reported on Completion Report

25. FEDERAL PROGRAM REVIEW PROCESS Subrecipient monitoring Review if: Grant awards contain appropriate terms/conditions Obtain appropriate audit reports/meet requirements Conduct appropriate monitoring Handles questioned costs/deficiencies adequately

26. FEDERAL PROGRAM REVIEW PROCESS Special Tests and Provisions Schoolwide Programs Review schoolwide Plan Includes Components: Needs Assessment of Entire School Conducted Comprehensive Plan Developed Annual evaluation/modify Plan Performed Schoolwide reform strategy for improvement student achievement Included Instruction by highly qualified professional staff Included Strategies to increase parental involvement Included Additional support to students experiencing difficulty Reflected Transition plan ..assist pre-school children in transition to schoolwide program ..Described

27. FEDERAL PROGRAM REVIEW PROCESS Special Tests and Provisions Schoolwide Programs Participating Federal Programs Fiscally Combined Reflected in a Budget!!! If Combined�Schoolwide Program Costs Lose Their Identity Schoolwide Program Costs Should Be Allocated to Each Participating Federal Program Prescribed by US Dept of Education In Proportion ..With Source of Revenue In line With OMB Circular A-87 Requirements Cost Allocation Plan should be developed, documented and maintained for audit

28. FEDERAL PROGRAM REVIEW PROCESS Special Tests and Provisions Schoolwide Programs Maintenance of Effort Review accounting records �to verify that non-Federal expenditures in support of those schools participating in schoolwide program was not reduced or less than non-Federal expenditures supporting non-schoolwide schools

29. FEDERAL PROGRAM REVIEW PROCESS Special Tests and Provisions Participation of Private School Educators Consult W/Private School Officials in Making Determinations About Educational Services Provided to Private School Teachers and Other Educational Personnel Look at Minutes of Meetings, Correspondence, etc...Conduct Interviews Review program expenditures & Other Records ..Planned Services were Provided for Private School educators�Equivalent to n Cost of Educational Services Provided to Public School Educators

30. FEDERAL PROGRAM REVIEW PROCESS Special Tests and Provisions ASSESSMENT OF NEED Review Documents for .. Conducted Required Needs Assessment for Professional Development and Hiring as Identified by Teachers and Schools Staff Included Title I, Part A Teachers�.From Target Assistance and/or Schoolwide Program Schools In the Needs Assessment Process

31. Single Audit Report QUICK SNAPSHOT OF AUDIT RESULTS See Section IV � FINDINGS AND QUESTIONED COSTS See Schedule of Schedule of Expenditures of Federal Awards INCLUDED IN EITHER: SCHEDULE �1�.. of non- GASB #34 Audit Reports SCHEDULE �2�.. of GASB#34 Audit Reports