Technical Assistance Compliance Financial Report Internal Controls New CATE Administrators Training Presenters: Melissa Benton & Abby Lawson October 21, 2015 New CATE Administrators Training Presenters: Melissa Benton & Abby Lawson October 21, 2015

LOCAL PLAN FISCAL MONITORING Single Audit Act, 1996 Amendments, 31 U.S.C. section 7502(f)(2)(B) states: “…each pass-through entity shall…monitor the subrecipients’ use of Federal awards through site visits, limited scope audits, or other means…”

The General Education Provisions Act (GEPA) Single State Application, 20 U.S.C. section 1232d states that - “…State will adopt and use proper methods of administering each applicable program, including - (a) monitoring of agencies, institutions, and organizations responsible for carrying our each program…, (b) providing technical assistance, where necessary, to such agencies, institutions, and organizations…, (c) encouraging the adoption of promising or innovative education techniques by such agencies, institutions, and organizations…, (d) the dissemination throughout the State of information on program requirements and successful practices…”

Major paradigm shift in compliance, internal control, and fiscal management Will require changes in the status quo of the operations and management of all entities, including state and local governments.

What is 2 CFR Part 200? New regulations for federal grants Released 12/26/13 by the Office of Management and Budget (OMB) Implemented 12/26/2014 Incorporates uniform grant guidance, cost principles, and audit regulations into one set of regulations.

New Regulations Require Pre‐Award Risk Assessment Federal agencies to be held responsible for the funding decisions of their grantees and all Pass‐through entities to be held responsible for their subgrantees

Pre-Award Risk Assessment The agency is using a risk‐based approach on all funding awards based on: Financial stability Quality of management systems and ability to meet management standards History of performance Reports and findings from monitoring visits Applicant’s ability to effectively implement statutory, regulatory, other requirements

Part of Larger Changes The Uniform Grant Guidance is a part of the continued improvements in Federal Funding Accountability & Transparency Act

New Regulations Require Internal Controls

Internal Controls 101 Internal control is a process controlled by management that make it possible for the agency to successfully achieve its goals and objectives.

Why are Internal Controls Important? Internal controls are designed to provide reasonable assurance regarding the achievement of objectives in the following categories: Effectiveness and Efficiency of Operations Reliability of Financial Reporting Compliance with Laws and Regulations

2 CFR Part The report is true, complete and accurate and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the federal award, and the official is aware that any false, fictitious, or fraudulent information or the omission of any material fact, may subject them to criminal, civil or administrative penalties for fraud, false statements, false claims, or otherwise.

Local Plan Process Reporting of Expenditures Use of Funds Salaries funded in LEA Local Plan Equipment Progress Report Advisory Council & Committees Program of Study Special Populations Data Local Improvement Plan What are we monitoring? What are we monitoring? LEA Local Plan

OCTE’s Actions By submitting this report through the CATE system….

Evidence Evidence to support compliance of expenditures for funding streams to include : 1) Detailed Budget Expenditure Report 2)Details of Expenditures by Fund Report 3)Employee by Account Number Report Consortium Agreement Form (if funds are transferred to another LEA or multi-district career center) Amendments to your Local Plan should be submitted in a timely manner Revenue CodeSubfundDescription Career and Technology Education Equipment (EIA Equipment) Work-Based Learning EEDA Career Specialists Perkins Aid, Title I

Budgeting & Expenditure, Use of Funds

PERKINS FUNDS Fund 207 Approved CATE Course, with a four-digit Course Code, and taught by a certified instructor Course with SBA number assigned—Innovative Application submitted and approved; taught by certified instructor An inventory must be conducted on an annual basis and maintained for all equipment/supplies purchased with Perkins funds Follow the OCTE’s guidelines for disposing of equipment purchased with Perkins funds

Fund 207 Perkins Federal Federal Funds “Do Not” Carryover

State EIA Equipment Funds (Fund 325) CATE Course must be approved, with a four-digit Course Code, offered at the high school/career center level as part of a completer program, and taught by a certified instructor Items purchased must be tangible, non-expendable items with useful life of more than one year and an acquisition cost of $100 or more per item “Big-Ticket” Items Funds may carry-over for 1 year

Fund 325 State EIA Equipment State Funds Carryover 1 Year

Work-Based Learning Funds (Fund 392) Job Description submitted should include the % of time allocated to duties specified for which funding is requested Activities must support Work-Based Learning Activities funded are compared to the number of WBL experiences reported in Power School

Fund 392 Work-Based Learning State Funds Carryover 1 Year

Salaries Job description submitted with current Local Plan should have percentages by each assigned job duty Job description should match the FTE assigned to the funded role ( Evidence of compliance= Employee by Account finance report) Employee Time Certification Employee Time Certification is required if FTE is 100% funded with CATE awarded allocations Personnel Activity Report (PAR) Personnel Activity Report (PAR) is required if FTE is partially funded by CATE allocation and numerous cost objectives

Progress Report July 15 th deadline Who completes it? How is the progress report information shared and input received?

Advisory Council & Committees LEA has established Advisory Council and/or Committee(s) Membership Profile: Member’s name, address, place of employment, and position are on file with school district Process in recruitment of new members Are you documenting attendance, agenda, and minutes at each scheduled meeting? **Membership Profile and Meeting Minutes will be requested to serve as evidence of compliance during your desk audit review*

Program of Study LEA offers at least 4 units under the secondary CATE program identified for the POS in current approved Local Plan - Master schedules for applicable schools will be requested during desk audit review and on-site monitoring visit Agreement between LEA and post-secondary institution - Do you have an articulation agreement in place? ****Is it up to date and on file for review? Evidence of career guidance and work-based learning opportunities Evidence of providing a seamless transition for student participation in CATE offerings Does your Local Advisory Council meeting minutes reflect post- secondary curriculum alignment?

Special Populations  Individuals with disabilities  Individuals from economically disadvantaged families, including foster children  Individuals preparing for nontraditional training/employment  Single parent, including single pregnant women  Displaced homemaker  Individuals with other barriers to educational achievement, including individuals with limited English proficiency Evidence indicating needs of Special Population students are assessed with respect to their enrollment and participation in CATE program

Data Reporting DATA IS IMPORTANT FOR : DATA IS IMPORTANT FOR :  Accountability Perkins IV (Federal) School Report Cards (State)  Placement  Allocation of Funds  Enrollments  Planning

Local Program Improvement (ALL OR A PORTION)  FEDERAL FUNDS (ALL OR A PORTION) CAN BE WITHHELD FROM AN LEA FOR FAILURE TO:  Implement an improvement plan;  Failure to make any improvement in meeting any of the local adjusted levels of performance within the first program year of implementation of its improvement plan; or  Failure to meet at least 90% of an agreed upon local adjusted level of performance for the same core indicator of performance for 3 consecutive years

2015 CATE Monitoring Tips Moving Forward: LEAS/Career Centers will have to “pay back” to the SCDE any funds that were spent for items not approved in Local Plan LEAS/Career Centers will be chosen based on the risk analysis done by the SCDE Audit Office Make sure to purchase only items listed in the Local Plan

2015 CATE Monitoring Tips Moving Forward: Keep a detailed equipment inventory based on CATE Equipment Guidelines and column headings Remember, State WBL Funds (392) and EIA Funds (325) can only roll over for 1 year

Helpful Tools Electronic Code of Federal Regulations COFAR 2 C.F.R 200: Uniform Guidance Melissa BentonAbby Lawson (803) (803)

Thank YOU! In order to help students reach their goals, In order to help students reach their goals, we look forward to helping you!