#1New Jersey Department of Education Collaborative Monitoring Information Session Office of Fiscal and Data Services Office of Fiscal Accountability and Compliance JERSEY E OF NEW OF STATE O NEW SEAL OF THE STATE * GREAT THE DEPARTME BOSPERITY OF JERSEY DUCAT#2Goals for Today's Meeting • Review the Federal monitoring requirements • Provide an overview of the Risk Assessment Tool • Review the desk monitoring process • Review the "onsite” monitoring process ● Provide answers to any outstanding questions NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY EDUCATION 2#3* STATE O GREAT SEAL OF A THE DEPARTMENT N JERSEY STATE OF N JERSEY FEDUCA CATION Background The United States Department of Education (USED) makes subgrants available to the States pursuant to the Elementary and Secondary Education Act of 1965 (ESEA) as Reauthorized by the Every Student Succeeds Act (ESSA). The State Department of Education uses some of the money received from the USED for State set- aside activities. The majority is subgranted to Local Education Agencies (LEAs). Local Education Agencies, school districts, use the funds to implement programs to ensure the success of all students.#41 STATE O THE GREAT DEPARTMENT The NJDOE is a "pass-through" entity The United States Department of Education (USED) makes subgrants available to the States pursuant to the Elementary and Secondary Education Act of 1965 (ESEA) as Reauthorized by the Every Student Succeeds Act (ESSA). NEW JE THE STATE O E OF NE OF N JERSEY EDUCATION The State Department of Education uses some of the money received from the USED for State set- aside activities. The majority is subgranted to Local Education Agencies (LEAs). Local Education Agencies, school districts, use the funds to implement programs to ensure the success of all students.#5STATE O GREAT SEAL OF THE DEPARTMENT Uniform Grant Guidance Requirements for Pass-through Entities EW JERSEY STATE OF N JERSEY OF EDUCA CATION Evaluate each subrecipent's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as:#6Uniform Grant Guidance Requirements for Pass-through Entities Factors include: The subrecipent's prior experience with the same or similar subawards; The results of previous audits; Whether the subrecipient has new personnel or new or substantially changed systems; and The extent and results of Federal awarding agency monitoring. STATE O GREAT SEAL OF THE DEPARTMENT EW JERSEY STATE OF N JERSEY OF EDUCA CATION 6#7NJDOE Risk Assessment Tool-Overview Interdivisional team met to develop a new tool for the 2019-2020 monitoring cycle Team members included Title I, Title II, Title III, IDEA, OGM, Perkins Reviewed Federal guidance, regulations, available data to draft a new Risk Assessment Tool STATE O GREAT SEAL OF THE DEPARTMENT EW JERSEY STATE OF N JERSEY OF EDUCA CATION Z#8NJDOE Risk Assessment Tool-Overview Purpose Fulfill the legal requirement at 2 CFR § 200.331 Evaluate each LEA's risk of noncompliance with federal and state fiscal regulations and requirements NJDOE Support Tiers Intensive Targeted STATE O GREAT THE DEPARTMENT OF N STATE OF JERSE N JERSEY EDUCATION Determine the level of NJDOE support each LEA will receive Universal#9STATE O GREAT SEAL OF THE DEPARTMENT W JERSE N JERSEY OF EDUCA CATION NJDOE Risk Assessment Tool-Process 12 Risk Indicators 1 Aggregate Risk Score 2 Adjustments 9#10NJDOE Risk Assessment Tool-Risk Indicators ACADEMIC 1. ELA Proficiency Rate for Federal Accountability 2. Math Proficiency Rate for Federal Accountability 3. Four- and Five-Year ATE OF GREAT THE DEPARTMENT Graduation Rates N JERSEY STATE OF N JERSEY OF EDUCA CATION 4. Accuracy of NJ SMART Data Submissions 5. Percentage of Funds Drawn Down by June 30th 6. Frequency of Reimbursement Requests 7. Number of Application Revision Rounds FISCAL 8. Late Grant Application 9. Late Final Report Submission 10. Late Revision Submission 11. Total Amount of Federal Awards 12. Audit Findings 10#11* STATE O GREAT THE DEPARTMENT NJDOE Risk Assessment Tool-Example INDICATOR 12: AUDIT FINDINGS Category Description Risk Level 0 The LEA's Comprehensive Annual Financial Report (CAFR) noted no deficiencies and disclosed no instance of non-compliance 0 1 The LEA's CAFR contained between one and three deficiencies 2 The LEA's CAFR contained four or more deficiencies 3 The LEA's CAFR contained a qualified or modified opinion 5 7.5 10 Data Source: LEA FY 2019 CAFR, Special Audits Unit EW JERS JERSEY STATE OF N JERSEY OF EDUCA CATION#12NJDOE Risk Assessment Tool- Aggregate Risk Score * STATE O GREAT SEAL OF THE DEPARTMENT Risk Assessed Indicator Category Assessed Category Description 1 0 The LEA met the ELA proficiency rate target or goal 2 2 The LEA did not meet the math proficiency rate target Aggregate Risk Score = Total Assessed Risk Levels Total Possible Risk Levels EW JERSEY STATE OF N JERSEY OF EDUCA CATION Total Assessed Risk Levels: Total Possible Risk Levels: Aggregate Risk Score: Assessed Risk Level Highest Possible Risk Level 0 5 5 5 55 105 52.4% 12#13* STATE O GREAT SEAL OF THE DEPARTMENT NJDOE Risk Assessment Tool- Adjustment Variable • An LEA's Aggregate Risk Score determines its support tier placement. However, the NJDOE takes into consideration each LEA's past collaborative monitoring history and QSAC cohort to adjust an LEA's support tier placement, if necessary. ADJUSTMENTS In the last two years, did this LEA receive intensive support from the Department? Is this LEA in the current monitoring cycle for QSAC? W JERSEY STATE N JERSEY OF EDUCA CATION 13#14STATE O GREAT SEAL OF THE DEPARTMENT NJDOE Desk Monitoring Why conduct desk monitoring? . Meet the requirements of the Uniform Guidance Supplement the work being done by the onsite Monitoring Focus on data and support LEA performance Identify unique issues that require targeted support EW JERSEY STATE OF N JERSEY OF EDUCA CATION 14#15Desk Monitoring Timeline October-November Notify LEAS (ongoing) March - June Finalize reports Provide Technical Assistance 囚 t 100 November - April September Identify LEAS Conduct monitoring June - September Review and Close CAPS Conduct Risk Assessment#16STATE O GREAT SEAL OF THE DEPARTMENT NJDOE Desk Monitoring Overview What programs are being monitored? ● Title I, Part A, Title I Reallocated, Title I SIA, Title II-A, Title III, Title III Immigrant, IDEA, CARES Act ESSER Funds, Coronavirus Relief Funds • Non-Public funds for all the Grants are also included • Fiscal, program, and nonpublic questions • 20 LEAS EW JERSEY STATE OF N JERSEY OF EDUCA CATION 16#17STATE O GREAT THE DEPARTMENT NJDOE Desk Monitoring • Documents being Requested - Fiscal General Ledger/Budget Report to be followed up with sampling of purchases Time and Activity Reports for all staff charged to grants Inventory Logs for Equipment Cash Management Procedures and Draw Downs with supporting schedules IDEA has Excess Costs and MOE Requirements NEW THE W JERSEY STATE OF N JERSEY OF EDUCA CATION#18STATE O GREAT SEAL OF THE DEPARTMENT NJDOE Desk Monitoring Documents being Requested - Program Evidence of compliance with program requirements such as: • • Parent engagement letters Stakeholder meeting agendas District websites Transportation policies EW JERSEY STATE OF N JERSEY OF EDUCA CATION 18#19STATE O GREAT SEAL OF THE DEPARTMENT EW JERSEY STATE OF N JERSEY OF EDUCA CATION NJDOE Desk Monitoring • Districts will submit documents through Homeroom Naming convention will be provided by NJDOE 19#20STATE O GREAT SEAL OF THE DEPARTMENT NJDOE Desk Monitoring W JERSEY STATE OF N JERSEY OF EDUCA CATION Title I, Part A - Fiscal Rating Legal Authority Evidence Comments M PM NM NA 2 C.F.R. 200.403 Requirement A. Allowability 1. All costs must be necessary reasonable and allocable in accordance with regulations. a. The cost is aligned to an identified need from the LEA's need assessment. b. The cost is reasonable, i.e. the nature and amount of the cost does not exceed that which would be incurred by a prudent person under the circumstances. c. The cost is allocable to the program, i.e. the cost of the purchase benefits the program in proportion to the amount paid for the purchase. B. Cash Management/Reimbursement 1. LEA has written policies and procedures regarding reimbursement requests for Title I, A Programs. 2 C.F.R 200.302 LEA Grant Application Final Report Purchasing Samples Purchasing Samples District policies and procedures on cash management and reimbursement requests 20#21STATE O GREAT SEAL OF THE DEPARTMENT NJDOE Desk Monitoring EW JERSEY STATE OF N JERSEY OF EDUCA CATION Title III & III Immigrant - Program Requirement A. Entrance and Exiting from an ELL Program 1. The district will establish and implement standardized statewide entrance and exit procedures including a requirement that all students who may be English learners be assessed for such status within 30 days of enrollment in a school in the State. Legal Authority ESEA §3111(b)(2)(A) ESEA §3113 (b)(2) B. ELL Program Staff and Certification 1. All teachers of Bilingual Education classes shall hold a valid New Jersey instructional certificate with an endorsement for the appropriate grade level and/or content areas, as well as an endorsement in bilingual education, pursuant to N.J.S.A. 18A:6-38 et seq. and N.J.A.C. 6A:9B-10.5. C. Supportive Services 1. Students enrolled in Bilingual, ESL, and English language services programs shall have full access to (as feasible) supportive services such as counseling, tutoring, and career guidance. These services should be provided by bilingual personnel who are familiar with and knowledgeable of the unique needs and background of the ELLS and their parents. ESEA §3122(b)(5) Evidence List of WIDA Screener scores used in the identification of new entrants. The procedures followed to identify new entrants. The procedures for exiting an ELL program. List of staff members with Bilingual and ESL certification and endorsements; including instructional assignments. ESEA §3115(d)(1-8) Procedures for ELLs to participate in supportive services. Rating Comments M PM NM NA 21#22NJDOE Desk Monitoring CARES Act, ESSER Funds • LEAs may use funds for any activity authorized by: • ESEA • . IDEA The Adult Education and Family Literacy Act Perkins McKinney-Vento In addition to these broad uses, funds may be used for... NOTE: These fund are NOT subject to a supplement not supplant requirement. STATE SEAL OF GREAT SE NEW THE JERSEY STATE OF DEPARTMENT OF JERSEY EDUCATION#23NJDOE Desk Monitoring CARES Act, ESSER Funds Broad allowable uses in the legislation • Guidance issued by NJDOE on May 12, 2020 12 allowable use categories including but not limited to: • • • ● Technology Cleaning and sanitizing Professional development Mental health services • Activities to support remote learning. NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY EDUCATION#24Additional Desk Monitoring Fall of 2020-2021 • The OFDS is conducting a special desk monitoring which is separate from the regular monitoring of Federal funds. • This monitoring will cover the Coronavirus Relief Funds (CRF) allocated through School Finance in September 2020 and the CRF funds allocated to LEAs through the Digital Divide Grant. 56 LEAs have been identified for this special one-time desk monitoring. STATE SEAL OF GREAT SE NEW THE JERSEY STATE OF DEPARTMENT OF JERSEY EDUCATION 24#25STATE SEAL OF GREAT SE NJDOE Desk Monitoring Coronavirus Relief Funds (CRF) On August 26, 2020, Governor Phil Murphy announced an allocation of $100 million from the federal Coronavirus Relief Fund (CRF) to assist public school districts, charter schools, and renaissance school projects with defraying costs associated with reopening schools for the 2020-2021 school year in the wake of the COVID-19 pandemic. Allocations were made available through Homeroom on September 23, 2020. • LEA allocations ranged from $1,000 to over $4.6 million. The CRF grant funds must be used to address health and safety measures necessary to support reopening for in-person instruction and to support students during periods of remote learning. NEW THE JERSEY STATE OF (* DEPARTMENT OF JERSE UCATION#26Coronavirus Relief Funds - Digital Divide Grant . • In addition, the Administration redirected additional Coronavirus Relief Fund (CRF) funds to close any remaining academic achievement gaps and to fulfill the unmet digital device and internet connectivity needs of our approximate 1.4 million New Jersey students through the Digital Divide grant. Up to $44 million in CRF funds was made available for this purpose, with an additional $6 million available for nonpublic schools. • This funding will be disbursed to public school districts to purchase digital devices and internet connectivity for one-to-one student use based on need and the availability of philanthropic donations. NEW THE STATE JERSEY OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSE EDUCATION 26#27Overview of the CRF Desk Monitoring Process • Documents will be exchanged via email. Initial email from OFDS will contain a copy of the monitoring protocol. Staff from OFDS will follow-up with the district regarding needed documents. • Note the truncated timelines due to the nature of the CRF. • Funds must be encumbered or expended no later than December 30, 2020. NEW THE JERS STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY EDUCATION 27#28STATE SEAL OF GREAT SE CRF Desk Monitoring LEA Selection Process . Entire population of LEAs was divided into tiers based upon total CRF allocation. A percentage of LEAs from each tier was randomly selected. No LEA selected that is also undergoing desk or onsite monitoring for the 2020-21 school year. NEW THE JERSEY STATE OF DEPARTMENT OF JERSEY EDUCATION 28#29NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION Questions [email protected] 29#30What is Collaborative Monitoring? Internal Control of sub- recipient award Oversight, guidance and support of subrecipient awards. SEA fiduciary responsibility ensuring compliance with federal statutes, regulations and conditions NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY EDUCATION SEA Intended + Purpose LEA#31Intended Outcomes of Success ✓ Achievement of Funding Initiative ✓ Adherence to federal and state statutes and regulations Compliance with the terms and conditions of federal award Relationship building & establishing SEA as a resource * GREAT STATE O NEW THE JERSEY TERSEY STATE OF DEPARTMENT OF NEW JERSEY OF EDUCATIO ATION GOAL #110043577 31#32Myths vs Truths Myths 1. It is not an "I Gotcha" exercise 2. Auditing 3. Enforcement 4. Training 5. Any more.……… Truths 1. Fiduciary Responsibility 2. Monitoring 3. Compliance 4. Technical Assistance 5. Any more... NEW THE JERS STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY EDUCATION BUSTED#33Ten Phases of Collaborative Monitoring 1. Preplanning 2. Risk Assessment 3. LEA Selection 4. LEA Notification 5. SEA Coordination 6. Onsight Visit (Virtual) 7. Drafting the Report 8. LEA Response 9. Corrective Action Plan 10. Corrective Action Plan follow up visit. NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION#34● #1 Preplanning Coordination between OFAC and Programs Office Updated and Revising of Collaborative Monitoring Tools & Protocols • Ensure that associated tools of the on-site monitoring, desk reviews, comprehensive risk analysis and universal support are updated in accordance with the Uniform Guidance NEW THE JERSEY STATE OF STATE O SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION#35. #4 LEA Notification • Contact LEA with notification of plan to monitor •Provide proposed dates for monitoring • Upon date of agreement- SEA appointment letter and document list to LEA. NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION#36#5 Onsite Monitoring Visit • Entrance Conference • Fieldwork/Engagement • Review of Preliminary Findings •Exit Conference NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION#37#6 Drafting of the Report • Cross divisional collaboration between fiscal and program office Submission of Title I, Title II, Title III, Title III Immigrant, Title IV, IDEA and Perkins (where applicable). Review, editing, and accessibility requirements NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION#38#7 Final Report Issuance • Final review of report from directors from each subaward area. • Final review for accessibility compliance. • Final clearance from assistant commissioner. • Issuance to LEA by mail. NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION#39#8 LEA Response LEA is required to publicly review and discuss the findings in the on- site monitoring report at a public board meeting no later than 30 days after receipt of the report Within 30 days of the public meeting, the board must adopt a resolution certifying that the findings were discussed in a public meeting and approve a corrective action plan (CAP) • A copy of the board resolution and CAP and/or appeal must be submitted to the Director of the OFAC within 10 days of board approval. NEW THE JERS STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY DUCATION#40#9 Corrective Action Plan • LEAs are required to submit its CAP related to findings of noncompliance with the ESSA and Perkins programs, to the Director of the OFAC, and subsequently forwarded to the team lead for review. The LEAs are also required to develop a separate CAP for the Office of Special Education Policy & Dispute Resolution (SPDR). • The SPDR reviews the CAP and provides assistance to the LEA to ensure that the corrective actions outlined in the IDEA on-site monitoring report, are implemented. Likewise, the SPDR responds the CAP in a separate report to the LEA. STATE SEAL OF GREAT SE NEW THE STATE JERSEY OF DEPARTMENT OF JERSE EDUCATION#41• #10 Corrective Action Plan Visit Six months and one year after the approval of the CAP, the team lead conducts a follow up visit to the LEA to review the implementation of the corrective actions. • If the LEA is effectively implementing the corrective actions, the team lead generates a letter indicating that the case is closed and submits the letter to the Director of the OFAC, for signature. NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION#42#10 Corrective Action Plan Visit (cont.) • If the LEA still has unresolved issues, the Director of the OFAC determines the next steps which may include: ✓ Provide additional technical assistance ✓ Contacting the appropriate program office for follow up ✔ Initiating an OFAC Investigation ✓ Suspending reimbursement of funds. • In accordance with federal requirements, LEAs have one year from the date of issuance of the report to correct findings of noncompliance with IDEA program requirements. STATE SEAL OF GREAT SE NEW THE JERSEY STATE OF DEPARTMENT OF JERSEY EDUCATION#43NEW THE JERSEY STATE OF STATE OF SEAL OF GREAT SE DEPARTMENT OF JERSEY UCATION Questions, Comments, Closing Remarks [email protected] 43