Nick Chitwood Teacher on Special Assignment Academic English Learners/Student Support Riverside Unified School District

 Reviewed areas ◦ BASP (Before and after school programs) ◦ CE (Compensatory Ed) ◦ EL (English Learner Online) ◦ FM (Fiscal Monitoring) ◦ HE (Homeless Education)  Reviewed sites ◦ Two Elementary (Title I) ◦ Two High School (EIA Only)

 RUSD Selected for Online Review and Notified – 2/15/2013  RUSD attends CDE training for FPM – July 2013 ◦ More oriented towards in-person reviews  Upload deadline – 3/15/2014  Review Dates – 4/14 to 4/18/2014

 Individual meetings conducted with site key contacts in Fall to review monitoring instruments  As a results of many personnel transitions over the course of FPM process from identification to final review we held a group meeting on February 3, 2014 to coordinate responsibilities for response to monitoring instruments with possible overlap (especially fiscal monitoring)

 BASP ◦ 142 total documents ◦ All uploaded by upload deadline (3/15/2014)  CE ◦ 246 total uploads (includes time accounting and job descriptions for approximately 51 CE personnel between district/reviewed sites) ◦ 174 uploaded by 3/15/2014 ◦ Feedback from reviewer occurred on 3/27/2014 (Right before spring break) ◦ 56 additional documents uploaded before review ◦ 16 additional documents uploaded week of review

 EL ◦ 86 Total documents ◦ 62 by 3/15/2014 ◦ 20 in response to reviewer feedback and questions starting 3/24/2014 ◦ 4 documents uploaded week of review (including one financial report in 4 different forms!)  FM ◦ 86 total documents ◦ 11 by 3/15/2014 (We had a conference call with reviewer, and she asked for broad lists of expenditures/personnel, and then picked 30 transactions and 12 personnel to sample in greater detail) ◦ 18 documents uploaded prior to review start ◦ 57 documents uploaded week of the review based upon requests for further information from reviewer

 HE ◦ 38 documents uploaded ◦ 34 uploaded by 3/15/14 deadline ◦ 4 uploaded before review

 Transitions in personnel necessitated more group discussion of all key personnel involved with the review to get a clear sense of everyone’s perception of responsibilities and roles  Differing reviewers had different ideas regarding sampling and selection of expenditures/personnel ◦ FM reviewer had conference call in early February to clarify procedures and set up a sampling system ◦ CE reviewer wanted documentation for ALL personnel charged to the program, creating a much larger documentation burden

 Create a much earlier deadline for sites for documentation upload. Two weeks early was not enough for some of the four sites. ◦ This will allow more time for review of content of the submitted documentation, as opposed to struggling to meet upload deadlines  Written communication tended to make things seem pretty stark ◦ Follow-up phone conversations helped to cut through the official language

 Some are proactive, some are non-responsive  CAIS is not great for communication, it really exists for formal communication  Phone calls are incredibly useful to both get clarification about reviewer needs, as well as to make the case regarding potential findings  At first I was very careful regarding the things I said, out of fear of opening up more issues for possible review ◦ As I built rapport, it seemed to loosen up towards working with the reviewer towards solutions

 CE-01: Parent involvement policy ◦ Agendas must include parent review of the 1%  CE-07: SSC Composition ◦ All sites must hold elections, even if the number of volunteers matches the number of open spots  CE-32: Objective Criteria Identifying Students ◦ This item requires board policy on the FPM instrument. However, documentation of multiple criteria used at private schools may be used to satisfy requirements instead.

 FM-02 – Allowable costs ◦ FOOD! Title I/Title III Food is not allowed for:  Food for parents, unless light refreshments for non- state mandated parental involvement activities  Full meals for students  Food for student incentives  Food for student entertainment events

 CE-08 – SSC Approves SPSAs ◦ Minutes must be detailed enough to show a sufficient level of engagement by the Site Councils at all four sites in regards to SPSA approval ◦ Transactions in SPSAs should:  Not be for state mandates (graduation, CAHSEE)  Not be for base program publications (student planners)  Be clearly delineated as coming from district administrative set-aside if for non-direct services  Be clearly aligned to SPSAs goals and activities

 CE-08 Ideas for Resolution ◦ Improve procedures and training in regards to minutes taken at sites to better support documentation of SSC required activities ◦ Rewrite SPSAs to better articulate budgeted expenses with needs assessment and action plan based upon identified strategies for instructional improvement

 CE-18 Supplement Not Supplant ◦ Coordination of Title I funds with Title IV funds may not be allowable ◦ Title I funds should not fund Common Core expenses (State funding for this program)  Suggested Response ◦ Improved Job Descriptions/Time Accounting to better articulate Title I responsibilities of affected personnel

 CE-27 – Annual Evaluation of SPSA Services ◦ Similar to CE-08 should provide enough detail in minutes to support fulfillment of these responsibilities.  CE-27 Suggested Response ◦ Improve procedures and training in regards to minutes taken at sites to better support documentation of SSC required activities

 EL-11 – EIA Funds Disbursed to School Sites ◦ Maximum 2% is allowable for indirect services in Title III  EL-11 Suggested Response ◦ Upload documents with the understanding that reviewers may have program expertise, but not fiscal expertise, and provide appropriate support for understanding of fiscal documentation

 EL-15 – Teacher Credentialing ◦ All teachers must have CLAD  EL-15 – Suggested Response ◦ Develop a plan to get all teachers certified ◦ CDE requires MOUs with all affected teachers ◦ Avoid enrolling students with teachers without the appropriate credential

 CE-19/FM-01 – Time Accounting ◦ Monthly effort as documented on PARs should not be percentage based, but instead document hours of effort ◦ Matching percentages of budget and effort may be difficult to support in reviews unless personnel have a very predictable schedule

 CE-19/FM-01 Suggested Response ◦ Move some personnel to semi-annual PARs based upon more nuanced definition of “cost objective”  Examples of cost objectives  Title I  Title II  BASP (Title IV/ASES) ◦ Others can move to the substitute accounting system for 2014/2015 and file only semi-annual certifications ◦ Some personnel may need to do daily logging as part of a monthly PAR