2012 Fiscal Responsibility Title III Webinar Stephanie English, Chief Monitoring & Compliance Section School Business Division 919-807-3686 firstname.lastname@example.org ESL/Title III Consultants Glenda Harrell Joanne Marino Ivanna Mann Thrower email@example.com@firstname.lastname@example.org
Monitoring Indicators -- Fiduciary Items Included: Student count documentation Budget, including Administrative costs Implementation of Activities Documentation of expenditures for equipment, personnel, contracted services Supplement/Supplant (basic services as well as assessments)
3.1 Student Count • Does the LEA have documentation of the count of LEP Students? • Explanation of the headcount procedures
Budget Issues • Administrative Cost Limitation • 2% of current year allotment • Purpose code 6200 • Indirect cost (8100-104-392) • When is a budget amendment required? When total of overspent lines is more than 10% of approved budget • Monitored via Budget vs. Expenditures printout
Implementation of Activities • Evidence that the LEA is implementing required activities. • Evidence that the LEA is implementing activities that are supplemental (budget reports, record of expenditures)
3.2 Title III expenditures / equipment • How do Title III expenditures meet federal fiscal requirements? • How does equipment benefit the Title III program?
Equipment Documentation • Governed by EDGAR 80.32 • Tagging and tracking of non-consumable items with a useful life greater than one year • Monitored via list of “federal” equipment • Physical inventory at least once every two years; evidence required • Follow DPI’s Federal Equipment Disposition process when removing items from inventory; keep approval letters on file. (Form on web at http://www.ncpublicschools.org/fbs/finance/federal/under “Compliance Resources, Monitoring.”)
Personnel Documentation • Also known as “Time & Effort” documentation • For employees paid with federal funds, including tutors (but not subs) • Semi-annual certifications for individuals who work only on Title III activities • Personnel Activity Reports (PARs) for individuals who work on Title III and something else
Time & Effort – additional information • Additional training info on web at http://www.ncpublicschools.org/fbs/conferences/presentations/ ; see “Documenting Time & Effort” under Federal Information. • Your finance staff is your first line of defense – all federal programs must document time and effort. • Compliance monitored by matching time & effort documentation to payroll printouts. • Quarterly reconciliation of PAR data to payroll expense (typically the responsibility of finance staff).
Invoices for Contracted Services • Object code 311 • Invoices must be specific – who, what, when, where
Additional documentation • Internal Controls – LEA’s policies/procedures for purchasing/procurement, fixed assets, etc. • Responsibility of finance office; Title III staff should also be aware of the existence of these policies.
Procurement – one additional note • Suspension/Debarment • Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. • Debarred Vendors list – State and Federal can be found at http://www.doa.state.nc.us/pandc/
3.3 Supplement, Not Supplant • What is the basic instructional program/service provided to all students (e.g., to meet Lau requirements)? How are Title III funds providing activities/services that are supplemental? • What funds is the LEA using to provide the basic language instruction educational program for LEP students? • How has the LEA demonstrated that services provided with Title III funds are in addition to services that students would otherwise receive from State, local or other Federal funds?
Supplement, Not Supplant • What services is the LEA required by other Federal, State, local laws or regulations to provide? • How has the LEA demonstrated that it is not using Title III funds to provide services that it is required to make available under State or local laws or other Federal laws? • How has the LEA demonstrated that it is not using Title III funds to provide services that it provided in the prior year with State, local or other Federal funds?
3.3A Supplement, Not Supplant Use of Funds to Administer ELP Assessments • What funds other than Title III has the LEA used to identify LEP students who may need language services, including the development of ELP screening or placement assessments? • What funds other than Title III does the LEA use to pay for the costs of administration, scoring or reporting of ELP assessment, and materials or equipment related to the administration of annual ELP assessments?
Supplement, Not Supplant Screening and Placement Assessments for LEP Students [W-APT] • What funds other than Title III does an LEA use to develop and administer assessments to identify LEP students and place them in basic language programs?
Resources Federal information: OMB Circulars, EDGAR http://www.ncpublicschools.org/fbs/finance/federal/ Other: • Debarred Vendors list –http://www.doa.state.nc.us/pandc/
Contacts Stephanie English, Chief Monitoring & Compliance Section 919-807-3686 email@example.com ESL/Title III Consultants Glenda Harrell Joanne Marino Ivanna Mann Thrower firstname.lastname@example.org@email@example.com 919-807-3866 919-807-3861 919-807-3860