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Introduction to IDEA Part B Fiscal Accountability Plan
L t WLester Wyer Funding and Accountability Coordinator
Federal Requirement for Fiscal Monitoring
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Introduction to IDEA Part B Fiscal Accountability Plan
Federal Requirement for Fiscal Monitoring
The Idaho State Department of Education is the prime recipient of IDEA Part Bgrant awards under both the Special Education - Grants to States Program andth S i l Ed ti P h l G t Pthe Special Education - Preschool Grants Program.
Administrative responsibility:
General supervision requirements of IDEA
Fiscal monitoring required by both IDEA law and regulations and variety
of federal statutes and regulations.
Regulations
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Introduction to IDEA Part B Fiscal Accountability Plan
Regulations
34 CFR Part 80 – Uniform Administrative Requirements for Grants and C ti A t t St t d L l G t (thi i th U SCooperative Agreements to State and Local Governments (this is the U.S. Department of Education’s codification of the Grants Management Common Rule)
Office of Management and Budget (OMB) Circular A-87 – Cost Principles for State, Local, and Indian Tribal Governments
OMB Circular A – 133 – Audits of States, Local Governments, and Non-Profit Organizations
34 CFR Part 76 – State –Administered Programs g
Introduction to IDEA Part B Fiscal Accountability Plan
Requirement to Monitor
Even though federal law makes it clear that comprehensive monitoring(including fiscal) must be done by grantees, federal statutes and regulations
f i l l b t th l h thi h ld l kare fairly general about the rules on how this should look.
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Introduction to IDEA Part B Fiscal Accountability Plan
Requirement to Monitor
34 CFR Part 80 – Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments
§80.40 - Monitoring and reporting program performance.
(a) Monitoring by grantees. Grantees are responsible for managing the day-to-day operations of grant and subgrant supported activities. Grantees mustmonitor grant and subgrant supported activities to assure compliance withapplicable Federal requirements and that performance goals are being achieved.Grantee monitoring must cover each program, function or activity.
Introduction to IDEA Part B Fiscal Accountability Plan
Requirement to Monitor
IDEA Monitoring Requirement
34 CFR §300.149 SEA responsibility for general supervision.(a) The SEA is responsible for ensuring--(1) That the requirements of this part are carried out…
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Introduction to IDEA Part B Fiscal Accountability Plan
Requirement to Monitor
OMB Circular A-133
§ .400 Responsibilities.§___.400 Responsibilities.
(d) Pass-through entity responsibilities. A pass-through entity shall perform the following for the Federal awards it makes:
(2) Advise subrecipients of requirements imposed on them by Federal laws, regulations, and the provisions of contracts or grant agreements as well as any supplemental requirements imposed by the pass-through entity.
(3) Monitor the activities of subrecipients as necessary to ensure that Federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved.
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan
The SDE’s recent OSEP verification visit and their review of our fiscalaccountability system, served to give shape to the policies and procedures of
fi l t bilit d it i lour fiscal accountability and monitoring plan.
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan
Components of the Fiscal Monitoring Plan IDEA Part B and Preschool Application
Statement of Assurances
Monitoring Cycle
Risk Assessment
Document Reviews
Site Visits
Limited Scope Audits
State Audits and IFARMS annual report
A-133 Single Auditsg
Fiscal Accountability Checklist (self-assessment tool)
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
IDEA Part B and Preschool Application
This is the SDE’s mechanism for initially determining fiscal eligibility for IDEA funds.
Includes the Statement of Assurances
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Monitoring Cycle
The Special Education Division has an established five-year monitoring cycle.Following the format of the cycle, different components of fiscal monitoring planwill be implemented according to which year of the cycle a particular LEA is in.As mentioned above, districts and LEAs in Year 1 of the cycle will be required torespond to each of the applicable items on the Fiscal Accountability Checklist.
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Monitoring Cycle (continued)
Year 2: Selective review of written policies and procedures required by Fiscal Monitoring ChecklistMonitoring Checklist.
Year 3: Selective documents review that may include any of the following:• Specific items of cost from submitted GRA reimbursement requests• Time and effort certifications; personnel activity reports.
Year 4: Selective site visits that may be focused on one or more of the fiscal accountability requirements of the fiscal monitoring plan.
Year 5: Selective review of state audits and A-133 audits.
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Risk Assessment
Risk is the identification of events or circumstances that could have a negativeimpact on, or indicate compromise in, an LEA’s ability to effectively administerthe fiscal requirements of federal grant programs. The SDE has established riskfactors and categories that may be used to determine if additional levels of fiscalmonitoring are indicated.
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Risk Assessment (continued)
History of Maintenance of Effort issues or failure
Evidence of financial instability
New administration, business manager
Failure to use IFARMS accounting system
History of late submission of required data or financial information (Part B application, IFARMS Annual Report)
Data quality in Part B application (narratives not adequate to demonstrate allowable excess costs)
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Risk Assessment (continued)
Audit findings
Inaccurate or unverifiable reporting of actual expenditures and carryover on previous year budgets
Program monitoring determinations other than “Meets Requirements”
Fiscal Accountability Checklist
Timely obligation and liquidation of funds
Accounting for Medicaid expenditures and reimbursements.
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Risk Assessment (continued)
These risk factors, taken by themselves, will generally not trigger additional fiscalmonitoring activities. However, multiple instances of these issues or ongoingissues that appear to be unresolved may place a LEA in a higher risk categorythat would indicate that additional monitoring is necessary.
LEAs that are determined to have factors that place them in a higher riskcategory, will be notified in writing. The notification will include the reasons for thedetermination, possible monitoring consequences, and the opportunity torespond with an explanation or plan for resolution of the issuesrespond with an explanation or plan for resolution of the issues.
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Document Review
See Monitoring Cycle
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Site Visits
See Monitoring Cycle
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Limited Scope Audits
Limited scope audits are defined as an agreed-upon procedures engagements conductedin accordance with the American Institute of Certified Public Accountants’ (AICPA’s)in accordance with the American Institute of Certified Public Accountants (AICPAs)generally accepted auditing standards (GAAS) and attestation standards, that are paid forand arranged by the SDE and address one or more of the following types of compliancerequirements:
Allowable costs/cost principles Maintenance of Effort Time and Effort Reporting Parentally-placed private school children – proportionate funding Charter school sub-allocations.
Typically, these types of monitoring activities will only be triggered by risk assessments thatplace an LEA in a high risk category.
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Audits of School Districts and LEAs as required by Idaho Code 33.701(b)
A-133 Audits
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist
In the first year of implementation of the new fiscal accountability plan, theFi l A bili Ch kli i i d f ll b i i f IDEA P BFiscal Accountability Checklist is required of all subrecipients of IDEA Part Bfunds. In subsequent years, it will be required of those districts and schools thatare in Year 1 of the monitoring cycle, as well new Charter LEAs during their first2 years of operation.
In general, this checklist is intended as a tool for self-assessment of theadequacy of the subrecipient’s fiscal systems. However, districts and LEAsdetermined to have 1 or more of the risk factors listed above may be required tosubmit responses to the Fiscal Accountability Checklistsubmit responses to the Fiscal Accountability Checklist.
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
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Introduction to IDEA Part B Fiscal Accountability Plan
Fiscal Accountability Monitoring Plan Components
Fiscal Accountability Checklist Entries (continued)
Introduction to IDEA Part B Fiscal Accountability Plan
Contact
Lester WyerFunding and Accountability CoordinatorIdaho State Department of EducationDivision of Federal ProgramsSpecial [email protected]