1. Exceptional Children Division Special Programs & Data Section
IDEA Grant Application and Fiscal Accountability Orientation for New Charter School Leaders June 12, 2018
Exceptional Children Division
Special Programs & Data Section
Presentation by:
Dr. Ronda Sortino
IDEA Consultant and Fiscal Monitor

2. Exploring the EC Fiscal Monitoring Webpage

3. Exploring the EC Grant Management System

4. IDEA Fiscal Monitoring Tiers
Budget vs. Expenditures
Exceeds 10%
Desk Reviews
Five year cycle
Site Visits
Risk-based criteria
Tier I
Tier II
Tier III

5. Charter School Roles and Responsibilities
Assure sound financial management
Assure compliance with IDEA, fiscally and in programming
Maintain accurate and compliant records
Provide timely and accurate data

6. Compliance with IDEA

7. Time and Effort
All employees who are paid from federal funds – whether in whole or in part – must document their time and effort.
Time and Effort documentation serves as a “receipt” for payroll expenditures.
There are two types of Time and Effort documentation:
Semi-Annual Certification
Personnel Activity Report

8. Time and Effort Tidbits
Handwritten Information
Dates:
Must be after-the-fact (after the certification periods or other dates on the forms indicating periods of work performed)
Must coincide with one or more pay periods
Actual date signed
Signatures:
Must be legible
Printed name
No stamped signatures
No computer generated signatures/dates
Must have policies/procedures in writing.

9. Types of Time and Effort
Semi-Annual Certification
Personnel Activity Report (PAR)
Single Cost Objective
Completed semi-annually
Individual or blanket documentation
Multiple Cost Objective
Completed monthly
Reconciled quarterly with payroll

10. Semi-Annual Certification
Single Cost Objective
These employees must have semi-annual certifications certifying that they worked solely (100%) on the program in which they are being compensated.
Determined by the employee’s activities, not solely by the employee’s funding source.

11. Semi-Annual Certifications
Individual – Signed by the employee or supervisor who has first-hand knowledge of the work performed.
Blanket – Supervisor with first-hand knowledge of the work done certifies all federally funded employees in the school, by the individual program.
Certification Periods – January 1 through June 30; July 1 through December 31

13. Personnel Activity Report (PAR)
Multiple Cost Objective
These employees are paid from more than one federal grant or by a federal grant and a non-federal reward
Like the single cost objective employees, it is not always possible to tell by looking at funding whether an employee is a multiple cost objective employee
Determined by the employee’s activities, not solely by the employee’s funding source(s)

14. Personnel Activity Report (PAR)
Documentation of a distribution of salaries or wages of an employee who works on multiple cost objectives
Must complete and maintain support and/or documentation for the PAR forms
Must account for the total activity for which each employee is compensated
Must be signed by the employee
Must conduct comparisons of actual costs (based on reported PARs) to budgeted distributions at least quarterly

15. PAR Reconciliation
Reconciliation is simply conducting comparisons of actual costs (based on reported PARs) to budgeted distributions at least quarterly
Annual adjustments may be made if the quarterly comparisons show that the differences between budgeted and actual costs charged to the Federal program are less than 10%
If the quarterly comparisons show that the differences between budgeted and actual costs charged to the Federal program are 10% or more, then an adjustment must be made immediately

16. Personnel Activity Report (PAR)
REQUIREMENTS:
An effort statement that accounts for 100% of the employee’s effort
The exact number of hours worked
The exact time worked on all cost objectives
The specific cost objective (not just “federal”)

17. Sample PAR

18. Semi-Annual Certification or PAR?
Scenario #1: An elementary special education teacher is paid 50% from PRC 060 (federal) and 50% from PRC 036 (state). Semi-Annual because there is one cost objective and only one activity. Would it make any difference if the special education teacher worked part of the day in an elementary school and part of the day in a middle school? No.

19. Semi-Annual Certification or PAR?
Scenario #2: An EC/Title 1 Coordinator is paid 60% with federal PRC 060 funds and 40% with federal Title 1 funds. PAR because of multiple cost objectives- one for SWD (PRC 060) and one for students without disabilities (PRC 050).

20. Semi-Annual Certification or PAR?
Scenario #3: A Charter School resource teacher is paid from Fund 1 PRC 036 for direct services to SWDs four days/week and paid from Fund 3 PRC 060 one day/week as compliance/testing specialist for record reviews and testing SWDs. Semi-Annual because there is one cost objective. PRCs 036 and 060 both allow that activity for SWDs.

21. Semi-Annual Certification or PARs?
Scenario #4: A high school EC teacher is paid from PRC 060 for direct services to SWDs for two class periods/day. This teacher also teaches two regular ed classes of U.S. History each day. PAR because there are multiple cost objectives and activities. Can this teacher be paid 100% from PRC 060? No. Why?

22. Equipment

23. Equipment Tidbits Importance of Internal Controls
Policies and Procedures
Identification
Tag and Track
Inventory
At least once every two years

24. Equipment Identification
Date Purchased
Serial Number
Item Description
Vendor
Title Holder (who has the equipment in their possession)
Cost
PRC #
Percent Federal Participation
Location
Condition
Disposition Date (if applicable)

25. Contract Services

26. Who? What? When? Where?

27. Contracts and Invoices
Invoices for contracted services must be supported by a valid contract
Expenditures from contract codes (i.e. 311, 317, 318, 331, 344) must have a supporting contract
Check the Debarment & Suspension list of vendors before entering into a contract

28. Contracts and Invoices
Review and approve all special education services, contracts, and invoices
Charters must include the state language required for indebtedness in each of their contracts

29. Maintenance of Fiscal Effort

30. Purpose of MOE Purpose of LEA MOE Parallel Requirement of State MFS
Help ensure FAPE
Ensure sufficient funds to serve students with disabilities
MOE examines state and local dollars
Parallel Requirement of State MFS
Provide steady source of available funds for LEAs to provide FAPE

31. What is MOE?
LEAs must expend at least as much as they did the previous year on the education of students with disabilities
Two standards
Compliance: Must expend at least as much as they expended in previous year (comparison year)
Eligibility: Must budget at least as much as they expended in the last year for which information was available

32. Determining MOE Four methods are: local funds only;
the combination of state and local funds;
local funds only on a per capita basis; or
the combination of state and local funds on a per capita basis

33. Exceptions & Adjustments
Under IDEA, two categories allowing reduction of level of effort required to meet MOE:
Exceptions (§ )
Adjustments (§ )
Under both, reduced level retained moving forward

34. Consequences for NOT Meeting MOE
If LEA fails to meet MOE, SEA must repay federal government out of non-federal funds
May require repayment from LEA out of non-federal funds

35. Amount to be Repaid
…an amount equal to the amount by which the LEA failed to maintain its level of expenditures in accordance with paragraph (b) of this section in that fiscal year, or the amount of the LEA’s Part B sub grant in that fiscal year, whichever is lower. 34 CFR § (d)

36. Timely and Accurate

37. Meeting Deadlines These and any other deadlines established by NCDPI.
IDEA Part B 611 Grant
Due in late May
IDEA Part B 619 Grant
PRC 060 Budget
Due in late May with the 611 grant
PRC 070 Budget
PRC 049 Budget
Due in late May with the 619 grant

38. Meeting Deadlines Maintenance of Fiscal Effort Budget vs Expenditures
Due September 30
Budget vs Expenditures
December and April
IDEA Desk Reviews
Due October 15
IDEA Site Reviews
Run January through April

39. Meeting Deadlines Child Count Transfer System
Window opens for a limited time at the beginning of each school year
Combined Expenditure Report
Due mid-year (January/February)
Due again at the end-of-year (July 15)
Special Funding (114)
Due in late June

40. Meeting Deadlines Federal Child Count State Child Count
December 1
State Child Count
April 1
LEA- Self Assessment
Due each spring

41. Roles & Responsibilities of Special Programs & Data
IDEA Fiscal Monitoring
IDEA Grant Applications
Special Funding Applications
Technical Assistance
Training
Support

42. Federal Funding Sources Monitored by SPD
PRC 049 PRC 060 PRC 070 PRC 082 PRC 114 PRC 118 PRC 119

43. Questions & Comments

44. Exceptional Children Division Special Projects and Data Grant and Fiscal Team Contact Information
Section Chief
Kevin Allen
Phone:
IDEA Consultant
Districts 1, 2 and 4
Dr. Ronda Sortino
Phone:
IDEA Consultant
Districts 3 and 5
Valencia Davis
Phone:
IDEA Consultant
Districts 6, 7 and 8
Keashia Walker
Phone: