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					Florida Department of Education




    Helping Every Child Get Ahead
Martha K. Asbury, Assistant Deputy Commissioner
       Race to the Top: Amendments

• System will be open today for amendments
• Three types of required amendments:
  – Scopes of Work (detailed information for year 2
    starting on July 1, 2011)
  – Add additional funds available from districts
    choosing not to participate)
  – Budget (roll forward unspent funds from prior
    quarters and align budget with scopes of work
    changes)


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       Race to the Top: Amendments

Changes to the Process:
• Will allow two amendments per quarter (one
  for scopes of work and budget early in the
  quarter and one for budget only prior to the
  end of the quarter)
• Request to amend is simplified (contact
  information and type of amendment only with
  automatic approval)


                                             3
       Race to the Top: Amendments

Changes to the Process:
• Amendment must include
  justification/rationale for the proposed
  revisions (instead of including this with the
  request to amend)
• Unspent funds from current quarter will
  automatically be made available at the
  beginning of the next quarter


                                                  4
      Race to the Top: Amendments

Timelines for This Quarter:
• May 9 – 27: Submission of Request to Amend
  and Amendments (Scope of Work and Budget)
• June 27 – July 1: Submission of Budget Only
  Amendments
Detailed Scope of Work Information for Year 2
• Identification of Key Personnel
• Deliverables and Supporting Activities with
 Timelines


                                            5
       Race to the Top: Amendments


• Timelines for Future Quarters
  – Beginning of each quarter: Unspent funds from
    previous quarter become available
  – Beginning of each quarter – after quarterly
    reporting closes: System open for Scope of Work
    and Budget amendments
  – Last week of each quarter: System open for minor
    budget amendments only (those not requiring
    prior approval)

                                                   6
         Race to the Top: Monitoring
• General ARRA Monitoring:
  – Review and approval of budgets and budget
    amendments
  – Quarterly review and analysis of quarterly reports
  – Periodic reconciliations among various reporting
    system
  – Review and resolution of A-133 audit findings
• Strategies Specific to Race to the Top:
  – Quarterly assessment of Scope of Work
    implementation and budget status
  – Review and approval of deliverables

                                                         7
         Race to the Top: Monitoring

• Strategies Specific to Race to the Top
  – Quarterly assessment of Scope of Work
    implementation and budget status
  – Review and approval of deliverables
  – Review of LEA status in implementing selected
    portions of the SOW, for example:
     • Struggling schools (REDs monitor LEA progress)
     • Computer-based testing readiness
     • Charter school implementation
     • Assess compliance with minimum standards for
       local instructional improvement systems

                                                    8
         Race to the Top: Monitoring
• Review of Performance Data
• Annual Progress Reporting
• Monitoring of Other Federal Programs – Assess
  impact of RTTT
• Risk-Based Monitoring – identification of risk
  can lead to additional interventions:
  – Expansion of monitoring
  – Provision of more intensive technical assistance
  – Restrictions on expenditure of funds
  – Required implementation of corrective action plan
    and/or revisions to the budget/Scope of Work

                                                        9
       Close-out of Other ARRA Programs

Targeted Programs (Title I, IDEA, Homeless,
Technology)
• September 30 – Last day to obligate funds
• November 20 – Last day to liquidate
  obligations and report expenditures
       WARNING: THERE CAN BE NO
     EXTENSIONS! UNSPENT FUNDS WILL
                 REVERT!

                                              10
     Close-out of Other ARRA Programs


State Fiscal Stabilization Funds
• June 30 – Last day to obligate funds
• July 20 – Last day to liquidate obligations and
  report expenditures
        WARNING: THERE CAN BE NO
      EXTENSIONS! UNSPENT FUNDS WILL
                  REVERT!

                                                    11
          ARRA Quarterly Reporting

• Will likely continue through December 31,
  2011 for ALL programs (to ensure that all
  expenditures are properly reported)
• After that, only RTTT and SIG will continue
• Infrastructure expenditures are discouraged
  because of additional requirements
• Vendor expenditures cause the most frequent
  errors (be sure the reports are cumulative)

                                            12
             Maintenance of Effort

Maintenance of Effort (MOE) = level of non-
federal support for specific programs cannot be
reduced from year to year
• Expenditures of non-federal funds for the
  fiscal year must equal or exceed expenditures
  from the 2nd preceding year
• Example: Expenditures of non-federal funds
  for k-12 students in 2009-10 must equal or
  exceed expenditures in 2008-09.

                                                  13
              Maintenance of Effort

• Calculated as either
  – Per student
  – In the aggregate
• Use the calculation most advantageous to the
  district
• Calculated by DOE using cost reports
• If it appears that district did not meet MOE,
  district will be asked to provide additional
  documentation

                                                  14
               Calculation of MOE


• Use the total amount of state and local funds
  expended for two consecutive fiscal years
• Less any federal funds
• Deduct Community Services, Capital Outlay,
  Debt Services, and any non-recurring
  Incentive or Bonus Programs



                                                  15
                Maintenance of Effort

• Problem: compliance with MOE requirements
  cannot be determined until after it is too late
  to make changes
• Partial Solution: be knowledgeable about
  levels of effort for current and preceding
  years:
  – Take MOE into account during budget process
  – Monitor expenditure rates throughout the fiscal year



                                                           16
         Maintenance of Effort – Title I


• Measured at the 90% level
• Title I calculation generally applies to all other
  NCLB programs
• Waiver is available – DOE will apply for the
  waiver on behalf of the district




                                                   17
              Maintenance of Effort


• Good News
  – Certain State Fiscal Stabilization Fund
    expenditures may be used as non-federal
    expenditures for 2009-10 and 2010-11
  – Should assist districts in meeting the MOE
    requirements for those years
• Bad News
  – Existing thresholds will carry over into 2011-12


                                                       18
            Monitoring vs. Auditing


• Monitoring generally conducted by staff with
  a program emphasis
• Goal is program improvement and compliance
  (bringing subrecipients into compliance rather
  than punitive)
• Monitoring identifies areas which may require
  further examination


                                               19
           Monitoring vs. Auditing

• Auditing conducted by audit professionals
  (CPAs or persons with accounting and
  specialized audit training)
• Audits must comply with strict standards
  established by law
• Audits must be consistent with the
  “Compliance Supplement” published by USED
  every year

                                          20
            Monitoring vs. Auditing

• Both auditing and monitoring are required by
  federal law and regulations
• FDOE is responsible for conducting monitoring
  AND resolving audit findings
• Office of Audit Resolution and Monitoring
  (Director: Alricky Smith) within Division of
  Finance and Operations is responsible for
  audit resolution and monitoring oversight


                                              21
            Monitoring vs. Auditing

Process for Audit Resolution
• FDOE receives audit report and sends letter to
  district requesting information
• District responds (sometimes extensive
  interaction between district and FDOE)
• FDOE issues a “management decision”
• Repayment/restoration of funds is always a
  last resort when no other “fix” is possible

                                               22
             Monitoring vs. Auditing
• With respect to monitoring, generally looking
  at improvements going forward rather than
  correction of prior mistakes
• If there is indication of fiscal non-compliance,
  FDOE staff auditors will examine the
  documentation to determine appropriate
  remedies
• “Fiscal Adjustments” are NOT always identical
  to repayment/restoration of funds

                                                     23
             Monitoring vs. Auditing
• In both instances the intent is to ensure that
  the federal program is “whole.”
• Goal is to ensure that the federal funds
  benefit the program as intended – fund
  adjustments are made only when
  circumstances require them in order for the
  federal program (i.e., eligible students) to
  “benefit” in accordance with the program
  requirements

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                         Thank You!

Questions may be addressed to:

  Alricky Smith, Director, Audit Resolution and Monitoring
    Alricky.Smith@fldoe.org; 850/245-9875
  David Guido, Chief, Bureau of Contracts, Grants, and
    Procurement
    David.Guido@fldoe.org; 850/245-0735
  Martha K. Asbury, Assistant Deputy Commissioner, Finance
    and Operations Martha.Asbury@fldoe.org; 850/245-0420




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