Career Education Finance Update MCCTA Spring Conference February 2015

OMB Uniform Grant Guidance 2 Effective July 1, 2015, all Federal Perkins CTE expenditures will be governed by the new OMB Uniform Grant Guidance. These changes will result in a complete rewrite of EDGAR and the OMB Circulars. The changes will alter the landscape on financial management systems, inventory controls, procurement, and accountability. Focus will be on PERFORMANCE. Must have written policies and procedures (internal controls, cash management, procurement, travel).

Federal Grants Management Workshops 3 March 17, 2015 – St. Louis March 18, 2015 – Kansas City Michael Brustein, a founding partner of the law firm of Brustein & Manasevit, and national expert of the Federal cost, administrative, and audit principles, will present at each workshop. There will be an informal Q&A session in the afternoon of each workshop for the Career Education administrators regarding the information presented by Michael Brustein.

Perkins Monitoring Findings 4 Accounting records don’t agree with payment requests or FERs Funds obligated and expended outside of the period of availability Funds used for unallowable costs Time and effort reporting issues Inadequate stipend/extra-duty pay documentation Equipment inventory issues Inadequate physical inventory documentation Consortium agreement issues

ePeGs—Perkins Budgets 5 Budget revisions—the deadline to submit a budget revision is April 30. Budgets are estimates—do not have to agree exactly to how funds are spent. Review budget and actual expenditures monthly or at least quarterly—must ensure good fiscal management. Some budget revisions are not necessary—10% variance. Must have funds budgeted in a cell to report an expenditure.

Tiered Monitoring 6 Desk Monitoring—review of Perkins Finance Self- Assessment. For FY2015, this was required for Cohort 1, and the due date was January 31, Access Perkins Finance Self-Assessment through Web Applications—Tiered Monitoring. Responses to the self-assessment should be related to the previous year. Perkins Finance Self-Assessment will be used to identify any LEAs not complying with requirements.

Tiered Monitoring 7 On-Site Monitoring—review of financial records using the Perkins Finance Worksheet. For FY2015, the on-site reviews were conducted for Cohort 3. LEAs receiving an on-site monitoring were determined by reviewing the Perkins Finance Self-Assessments and using a risk-based calculation. Perkins Finance Report and LEA Corrective Action Plan (CAP) will be completed in the Tiered Monitoring System. Access On-Site Monitoring through Web Applications— Tiered Monitoring.

PS Institutions—Single Audit Report 8 LEAs that expend $750,000 or more in Federal funds during a fiscal year must have a single audit conducted. NEW PROCESS—Single Audit reports for PS Institutions must be uploaded into the Tiered Monitoring system (same requirement for school districts and charter schools). LEAs must complete the information regarding the CPA Firm and Auditor in order to upload the Single Audit report. The due date this fiscal year was December 31, However, next fiscal year, our Office will push this due date back to probably January 31.

FY2016 Perkins Changes 9 Our Office has provided recommendations instead of mandatory requirements related to equipment and instructional furniture. This guidance is effective July 1, Equipment: Our Office recommends that all equipment items purchased with Perkins grant funds be received, installed, and available for student instruction by December 31 of each year. However, if the LEA does not meet this deadline, then a justification statement(s) should be written and kept locally as documentation to support the exception to this date. Rationale: It is the expectation of this Office that equipment items are purchased early in the school year so the students can use them and benefit from their instruction. Students should have ready access to up-to-date equipment that enables improved instruction. The justification statement(s) should address these areas and also explain why the deadline was not met.

FY2016 Perkins Changes (cont.) 10 Instructional furniture: Our Office recommends that LEAs not use Perkins grant funds to purchase instructional furniture. However, if the LEA determines there is a need for this type of item, then a justification statement(s) should be written and kept locally as documentation to support the purchase. Rationale: The Perkins Act states that the funds must be used to improve the career and technical education programs. In addition, items purchased with Perkins funds should strengthen and support academic and technical skill achievement. Ultimately, the purpose of the Perkins program should be to develop more fully the academic and career and technical skills of students enrolled in CTE. The justification statement(s) should address these areas and also explain why Perkins grant funds were needed to support this type of cost.

FY2016 Perkins Grant 11 It appears there will be a small decrease in the Perkins funding for next fiscal year. The estimated grant amount for Missouri is $21,416,247 (about a $5,000 decrease from the current year). The impact on local allocations is unknown at this time. Change in census data State level administration funds—our Office may have carryover funds to include in the formula allocation amount

Distribution of Perkins Postsecondary Funds 12 The Perkins Act distributes postsecondary funds based on the number of career education students who are Pell Grant recipients and/or receive assistance from the Bureau of Indian Affairs. Administrative Memo will be sent in mid March, and LEAs will have until mid to late April to review and update any of the data elements used in the formula. Data must be submitted through MOSIS. Please review data for completeness and accuracy. Questions on data, please contact Mike Griggs or Connie O’Brien in the Office of Data Systems Management.

Effectiveness Index Formula 13 Effectiveness Index Formula (EIF) is an incentive-based funding system comprised of two components: placement and enrollment. Administrative Memo will be sent in mid March, and LEAs will have until mid to late April to review and update any of the data elements used in the formula. The formula uses placement data to calculate 90% of the EIF allocation and enrollment data for the remaining 10%. Data must be submitted through MOSIS. Please review data for completeness and accuracy. Questions on data, please contact Mike Griggs or Connie O’Brien in the Office of Data Systems Management.

Secondary Salary Reimbursement 14 LEAs receive the maximum approved salary reimbursement amount that was established in FY2002. This amount was based on the number of approved CTE programs and the number of CTE instructors, counselors, and administrators at that time. This process will remain the same for FY2015. The only difference for this fiscal year is that the maximum approved salary reimbursement amount will be paid in two payments. Half of the amount was paid in December, and the remaining half will be paid in the May or June school payment.

Adult/Postsecondary Salary Reimbursement 15 The Department uses an Adult/Postsecondary Reporting System to determine the salary reimbursement for adult and postsecondary programs. Data must be submitted through MOSIS. System is now open and LEAs have until March 31, 2015 to submit the data. Please review data for completeness and accuracy. Questions on data, please contact Mike Griggs or Connie O’Brien in the Office of Data Systems Management.

Contact Info Phone: The Department of Elementary and Secondary Education does not discriminate on the basis of race, color, religion, gender, national origin, age, or disability in its programs and activities. Inquiries related to Department programs and to the location of services, activities, and facilities that are accessible by persons with disabilities may be directed to the Jefferson State Office Building, Office of the General Counsel, Coordinator – Civil Rights Compliance (Title VI/Title IX/504/ADA/Age Act), 6th Floor, 205 Jefferson Street, P.O. Box 480, Jefferson City, MO ; telephone number or TTY ;