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

Exploring the EC Fiscal Monitoring Webpage https://ec.ncpublicschools.gov/finance-grants/fiscal-monitoring

Exploring the EC Grant Management System http://ecgrants.dpi.state.nc.us/ecgrants.nsf/?Open

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

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

Compliance with IDEA

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

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.

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

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.

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

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)

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

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

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”)

Sample PAR

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.

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).

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.

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?

Equipment

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

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)

Contract Services

Who? What? When? Where?

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

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

Maintenance of Fiscal Effort

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

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

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

Exceptions & Adjustments Under IDEA, two categories allowing reduction of level of effort required to meet MOE: Exceptions (§ 300.204) Adjustments (§ 300.205) Under both, reduced level retained moving forward

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

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 §300.203(d)

Timely and Accurate

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

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

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

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

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

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

Questions & Comments

Exceptional Children Division Special Projects and Data Grant and Fiscal Team Contact Information Section Chief Kevin Allen Phone: 919-807-3948 Email: kevin.allen@dpi.nc.gov IDEA Consultant Districts 1, 2 and 4 Dr. Ronda Sortino Phone: 919-807-3951 Email: ronda.sortino@dpi.nc.gov IDEA Consultant Districts 3 and 5 Valencia Davis Phone: 252-537-9435 Email: valencia.davis@dpi.nc.gov IDEA Consultant Districts 6, 7 and 8 Keashia Walker Phone: 919-807-3966 Email: keashia.walker@dpi.nc.gov