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Speed Bumps on the Fiduciary Road

Speed Bumps on the Fiduciary Road. Title I Administrative Meeting Timonium Maryland April 14, 2010 Cvieta Jovanovich. Purpose of Speed Bumps. Caution. Focus. Keep Honest. Safety. Watch. Monitor. Warning. “Spend funds quickly. . . .”. Save and create jobs

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Speed Bumps on the Fiduciary Road

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  1. Speed Bumps on the Fiduciary Road Title I Administrative Meeting Timonium Maryland April 14, 2010 Cvieta Jovanovich

  2. Purpose of Speed Bumps Caution Focus Keep Honest Safety Watch Monitor Warning

  3. “Spend funds quickly. . . .” • Save and create jobs • Improve student achievement through school improvement and reform

  4. But ensure: Transparency Reporting Accountability Including Title I Part A Invest ARRA funds thoughtfully . . .

  5. Where are Title I “speed bumps” located? • Title I Law – ESEA • Regulations – 34CFR Part 200 • Education Department General Administrative Regulations (EDGAR) • OMB Circular A-87 – Cost Principles • OMB Circular A-133 – Audit Requirements • A-133 Compliance Supplement • Non regulatory guidance • Letters and press releases issued by ED

  6. Requirements • Maintenance of Effort • Comparability • Supplement Not Supplant

  7. Federal Cost Principles • Necessary • Reasonable • Allocable • Legal ???

  8. Bumps Missed or Forgotten?? Spend down of funds! • Parent Involvement • Services to Private School Students • Required Reservations ( homeless, professional development, N/D) • School Level Allocations • ARRA Funds (late allocating to schools)

  9. More Missed! • Supplement/ Supplant – Time and Effort • Carryover – First in First Out • Audits – Same Findings • Equipment/Inventory – Missing Written Process or Not Implemented

  10. How to Safely Travel the Fiduciary Road • Training • Increase Knowledge of the Requirements within the LEA (central office and schools) • Monitor • Ask for Technical Assistance

  11. Questions

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