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Monitoring Concerns . Presented By WVDE Federal Programs Staff June 15, 2011. 2010-2011 Findings. Title I LEA . Fiscal Issues. Fiscal Issues. 7.1 Expending funds for administrative costs that are reasonable and necessary 7.2 Supplement/Supplant 7.3 Indirect Cost
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Monitoring Concerns Presented By WVDE Federal Programs Staff June 15, 2011
2010-2011 Findings Title I LEA
Fiscal Issues • 7.1 Expending funds for administrative costs that are reasonable and necessary • 7.2 Supplement/Supplant • 7.3 Indirect Cost • 7.4 Records of program review (now 7.12) • 7.5,7.6,7.7 Equipment inventory • 7.9, 7.10 Time and Effort • 7.11 Written contracts
7.1 Expending funds for administrative costs that are reasonable and necessary • Ensure expenditures are reasonable and necessary for proper and efficient performance and administration of the federal program • Ensure expenditures are allowable expenditures according to OMB Circular A-87 • Approve all requisitions, purchase orders, and invoices for payment • Signature of the district Title I director • Incorporate this procedure as part of the written procurement procedures • Avoid the use “blanket” purchase orders –POs must include an itemization list of articles purchased
7.2 Supplement/Supplant • Be conscious of supplement/supplant issues • Purchase of materials and equipment • Teacher salaries • Title I funded staff members substituting for teachers • Title I teachers are used daily to cover teacher planning periods • Child nutrition program • Title I funds to support attendance at non-Title I conferences and trainings for principals
7.3 Indirect Cost • Use restricted indirect cost amount • Use appropriate fiscal year’s rate – year in which funds are expended • Ensure the amount withdrawn does not exceed the rate allowable for the amount of funding which has been expended
7.4 Records of program review (now 7.12) • Documentation of review of the Title I school programs • Evidence of an annual mock monitoring
7.5,7.6,7.7 Equipment inventory • Maintain an updated inventory list, including the following information: • description of the item; • serial number; • acquisition date; • funding source and the % of funding from each source; • purchase price; • location; and • condition • Conduct and document the date of a physical inventory at least once every two years
7.9, 7.10 Time and Effort • Maintain time and effort documentation • Monthly personnel activity reports-reconciled quarterly • Semi annual certification
7.11 Written contracts • Contracts are required for any supplemental work paid with Title I funds (e.g, consulting services, after school programs) • Required information not on contracts • Required signatures • Lack of invoices to accompany contracts
Highly Qualified Teachers • 2.1 Highly Qualified in Title I schools • 2.6 Utilizing 5% set aside for tuition reimbursement
Highly qualified teachers • Require principals to complete the “Principal’s Attestation Statement”, annually – LEA director should check for accuracy • Ensure the amount of time assigned for non instructional duties for Title I funded professionals and paraprofessionals is proportional to similar personnel at the same school • Ensure all teachers in schools supported with Title I funding, hired after the first day of school in 2002, are highly qualified at the time of hire
Parent Involvement • 4.2 Developing with and distributing to parents- a district parent involvement policy • 4.3 Training staff to work with parents-this must be completed at the LEA and also the school level
Parent Notifications • 5.1c Highly Qualified – parent letter • Provide to each individual parent timely notice that the parent’s child has been assigned, or has been taught for 4 or more consecutive weeks by a teacher who is not highly qualified
Private Schools • 6.1 Meaningful consultation with private school officials • 6.6 Complaint procedures distributed to the officials of the private school informing them of the right to complain if the LEA has not engaged in timely and meaningful consultation
School and LEA Improvement • 8.5 Using 10% set aside for PD in the school budget (now 8.6) • 8.7 Making SES available at least twice (now 8.8) Sept. & Jan. • 8.15 Spending 10% for PD for LEA on improvement (now 8.17)
Homeless Set-aside • 9.2a Administration of the homeless set aside
2010-2011 Findings Title II LEA
2010-2011 Findings RLIS LEA
Highly Qualified Teachers Title II
Highly Qualified Teachers 2.2 Reaching 100% HQT 2.3 Implementing an Effective HQT Plan
Reaching 100% HQTs • Requires an effective HQT plan • Requires tracking progress toward HQT status • Requires timely cleanup of HQT reports • Requires that the county and schools harvest positive culture and work environments
Implementing an Effective HQT Plan • Recruiting • Retention • Retraining • Must have a written plan • Must show evidence of communicating the plan • Tuition reimbursement policy included as one part of the overall plan
Professional Development Title II
Professional Development 3.1 Tracking high quality professional development for core subject area teachers • The issue is not tracking professional development • The challenge is being specific to NCLB definitions
High Quality Professional Development - NCLB Must be: • Based on scientific research • Based on the needs of the school district • Sustained and ongoing training(s) • Review collaboration is provided
Core Subject Areas - NCLB • English and reading or language arts • mathematics • science • foreign languages • civics and government, economics, history, geography • arts (including music, dance, theatre, art, etc.) • special education (because they teach core subject area information to students)
Parent Involvement Title II
Parent Involvement 4.1 Supporting a partnership between schools, parents, and the community. Soliciting feedback from parents. Issues: • Neglecting non-Title I schools • Not soliciting feedback from parents
Parent Involvement 4.3 Training teachers, service personnel, and principals on parental involvement Issues: • Need one definitive piece of high quality professional development for parental involvement • Need enough evidence to show that all groups of stakeholders were trained
Fiscal Issues Title II and RLIS
Fiscal Issues 7.1 Reasonable and necessary administrative cost • Limited to 5% or less for both Title II or RLIS programs 7.2 Supplement and not supplant • Spend Title II funds only on items required to hold the professional development session(s) • Limit CSR expenses to 50% of the total allocation • CSR student to teacher ratio • 10/1 ratio for students / teachers or aides in Kindergarten • 17 or less students per teacher in grades 1-3
Fiscal Issues 7.4 Keeping records necessary for fiscal audit and program evaluation Issues: • No evidence of a carryover waiver at over 15% • Coding errors (incorrect project function and object codes) • Professional Development listed in supplies code • Salaries and benefits listed in the wrong program function code • No record of transfers between projects
Fiscal Issues 7.8 Budget Transfers • Requests are required for all changes of 10% or more from the allocation as outlined in the online WVEIS budgets
2010-2011 Findings Title III LEA
Common Findings 2010-2011 • 2.8 Highly Qualified Teachers • ESL Endorsed Teachers need to work with LEP students (Direct instruction) • 5.2 Parent Notification Letter • Within 30 day timeline -Better communication to the principals/schools of the procedures to follow upon the arrival of an ESL student in the school – notification to central office to begin testing process • (2 weeks if a child enrolls after the beginning of school) • Including all components required by law • Put graduation time line in the parents notification letter (only for high school students)
Common Findings 2010-2011 • 6.1 Private School • Notify private schools that they can receive ESL services as well. Notification can be in the same letter as Title I letters to the private schools. • Timely and meaningful consultation • 14.2 (13. 2) High Quality programs (school visits) • Amount services • Linked to ELP/CSO standards (Content Based ESL) • Grade Placement • Special Education • Appropriate space
Remember… The West Virginia Department of Education (WVDE) monitoring process includes the following goals: • Provide an academic focus for program improvement; • Promote student achievement; and • Provide technical assistance to schools and districts in utilizing federal funding to impact instructional practice and increase student performance.