FISCAL MANAGEMENT Special Education Funds SY Fiscal Risk Level Webinar – January 7, 2016

 To provide information on BIE,DPA Special Education Fiscal Management  To provide the Desk Audit findings  To initiate technical assistance to the schools  To provide a time for schools to request clarification, ask questions and provide input to delivery of technical assistance and training

 Training and information continues to be shared via webinars, s, conference and phone calls  Due dates were adjusted to accommodate changes  Turn around of school staff  Native Star continues as the process to submit documents  FDD  Understanding of CEIS

I. Overview The Fiscal Monitoring Procedures for Special Education ensures a school’s compliance to certain fiscal and administrative requirements for special education funds, 15% ISEP Academic base funds and IDEA Part B Supplemental Funds. Part B funds are allocated to the schools for excess costs of special education and related services and to supplement the ISEP 15% Academic base fund. The school submits an application that provides assurances that the school will meet the requirements of Public Law

 The procedure is established to ensure:  Program and fiscal policies and procedures are developed and implemented to meet certain fiscal and administrative requirements;  Appropriate use of special education funds for the intended purpose, Free and Appropriate Public Education (FAPE) in the Least Restrictive Environment (LRE);  Problems are identified and remediated; and  Oversight is provided that would result in improved student outcomes.

Each school submits all fiscal documents in the Native Star link on the BIE website with the exception of the Unmet Needs Request. Each document, with a timeline, is used for the fiscal desk audit completed on each school in June.

 1.The BIE reviews and rates the following fiscal documents:  Local Education Agency LEA/School Part B Application  and if applicable, the Coordinated Early Intervening Services (CEIS) Plan;  BIE Web Budget, BIE Operated Schools only; or Consolidated School-Wide Budget, Tribally Controlled Schools (TCS) only;  Fiscal Accountability Self-Assessment (FASA)

 2. Fiscal findings of noncompliance identified during the desk audit process for which no written findings are issued, the following will apply: ◦ A) The school will be issued a warning notification for instances of noncompliance related to IDEA fiscal requirements ◦ B) Targeted technical assistance will be provided to ensure instances of noncompliance are corrected within 30 school days of identification.

◦ C) Findings of noncompliance corrected by the school will be verified through the review of the school’s required upload of fiscal evidence in Native Star or Native American Student Information System ◦ D) Findings of noncompliance not corrected by the school within 30 calendar days will result in a written notification

 3. The IDEA Fiscal Risk Level Scoring Sheet is used to communicate to the schools the risk level for each school  Low Risk: minimal concerns identified for meeting fiscal and administrative requirements  Medium Risk: concerns identified for meeting fiscal and administrative requirements  High Risk: numerous concerns identified for meeting fiscal and administrative requirements

 4. Written notification of risk level is issued to the school  5. Targeted technical assistance is provided to medium and high risk level schools

An on-site visit provides an intensive level of fiscal review, and is the result of continuing violations of federal and IDEA fiscal requirements

 1. Criteria – if a school meets two of the five are used to identify a school for an on-site fiscal review:  Late submission or incomplete LEA/Part B application  High risk level for current and preceding years;  Administration Financial Reviews (BIE Operated Schools);  Recommendation for an on-site fiscal review from the Integrated Accountability and Support (IA&S) monitoring report;  Indian Student Equalization Program (ISEP) Special Education Certification submitted by the Education Line Office (ELO) that identifies findings of noncompliance; and/or  Administration Financial Reviews (BIE Operated Schools) or Annual Report (Tribally Controlled Schools) or A-133 (Tribally Controlled Schools)

 2. Written notification of an on-site fiscal review is sent  3. On-Site Fiscal Review Activities:  Entrance meeting  Demographic data and budget  FASA and Fiscal Rating  Verification of expenditures  Evaluation of fiscal review process  Exit meeting

 4. Analysis of data collected during the on-site fiscal review  5. Written report (also referred to as the written notification) issued to the school within 90 days of an on-site visit to inform of the intensive review results and if applicable, findings of noncompliance and corrective action.

BIE identifies and corrects finding(s) of noncompliance as follows: A. Schedule conference call with school(s) within 15-days of written report: ◦ Review findings of noncompliance ◦ Provide clarification/guidance ◦ Review correction process

B. Conduct quarterly progress checkpoints C. Ensure timely correction on noncompliance  School corrects within required timeline  BIE verifies correction of noncompliance  BIE issues close-out letter within 30-days of verification  School does not timely correct; placed in continuing status of noncompliance  BIE issues written notification  BIE applies enforcement  BIE verified correction  BIE issues close-out letter within 30-days of verification

The data from the desk audit and on-site fiscal review activities are analyzed and summarized to examine patterns and trends. The BIE offers training and targeted technical assistance to ensure fiscal resources are directed to areas needing improvement.

An evaluation is performed to assist the BIE in improving the fiscal monitoring procedures, activities include:  School completes post-fiscal review evaluation form  BIE assembles representatives from the BIE Administration, BIE Advisory Board for Exceptional Children, ELO staff and schools to evaluate the fiscal monitoring process.

 School Part B Application: 3 Points  Timely submission (1)  Complete application (1)  Signature after School Board Approval (1)  BIE Web Budget/Consolidated S W Budget ◦ K-8 Schools (19) ◦ K-12 Schools (23)  FASA (45)  CEIS (8)

Regions # Low Risk Schools # Medium Risk Schools # High Risk Schools Total Number of Schools East Navajo West Total

 Timely submission of the budget with appropriate signatures?  Were there adequate allocations and justification provided to support the allocation?  Fulltime Equivalency's (FTE) for personnel (Student/Teacher Ratio  Paraprofessionals  Special Education Teacher Supplies, materials, equipment and assistive technology

◦ Professional Development for total school staff, for special education staff, and/or provided based on needs of individual SWD.  Transportation as a related service for SWD  Parent Training  Child Find Activities  Least Restrictive Environment (LRE) placements in settings away from the school (incarceration, intensive specialized instruction or therapy, illness of student)

Most schools demonstrated appropriate use of Special Education funds in the following areas:  Transportation  Personnel  Related Services  Special Education Teachers  Majority of schools provided Budgets  Few entries of “Inappropriate and Non Allowable Costs”  Understanding the definition of Allowable Cost  Utilization of the Allowable Cost Document

 Questionable Costs Budget Item Parent Training Assistive Technology Child Find Equipment Materials Supplies Staff Training Secondary Transition Specialist Work Study Programs

 Areas of improvement:  The upload documents into Native Star  Internal controls –  describing the process for monitoring internal controls.  Separation of duties  Assessing of fiscal risk as it relates to theft & embezzling  Travel and training input of staff who attended, position and purpose

 Carryover  Inventory and safeguard to ensure fraud is not occurring  Special education coordinator/lead teacher not involved in the verification of purchase of supplies, and contracts.  Justification of unusual items  Schools will be issued findings of noncompliance if there are violations of IDEA requirements.

RegionsLow RiskMedium RiskHigh RiskTotal East Navajo4004 West42 17 TOTAL216128

 Schools will be issued findings of noncompliance if there are violations of IDEA requirements.  Schools received a score of 0 because:  a CEIS Plan was not submitted or was not submitted by the due date;

 The CEIS rating was based on the following (8 pts):  The Part B allocation was below the 15% Part B threshold (1pt)  The “Responsible Person” for CEIS at the school was identified (1pt)  The “targeted audience” was identified (1pt)  The School’s CEIS program was described (0-2 pts)  The number of student participants was provided (1pt)  The entrance and exit tools and criteria were provided (0- 2pts)

 Examples of topics  Procedural Safeguards (Individuals with Disabilities Education Act)  Overview of Special Education procedures & processes  Parenting a child with a disability  Overview of the Individualized Education Program (IEP)  Developing your child’s IEP  Supplementary aids & services; accommodations & modifications; Assistive Technology  Nurturing Self-determination

 Assistance is available for parents  100 Parent Centers across the nation at least one is located in each state  Sometimes they are referred to as Parent Training and Information Centers (PTIs) and/or Community Parent Resource Centers (CPRCs)  They help parents to participate effectively in the education of their children at school and at home, thereby improving outcomes for children with disabilities

 Native American Parent Technical Assistance Center (NAPTAC): Education for Parents of Indian Children with Special Needs (EPICS)

 Assistive technology devices or services, or both, are made available to a child with a disability if required as part of the child’s special education, related services, or supplementary aids and services.  The child’s IEP team determines if an assistive technology service and/or devise is necessary for the child to benefit from his or her education program  There are a broad range of assistive devices:  Low-tech examples: pencil grips, highlighters, paper stabilizers, magnifiers, books on tape  High-tech examples: computers, computer based assistive technology, voice synthesizers, Braille readers

 Accommodations/Modifications Example Skill Area: Written Expression Accommodations: MethodMaterialTechnology Accept outlines or notes to reduce written work Create sentences aloud Do not grade for spelling Extra time for completion Process reminders on chalkboard or desk Provide writing sample Shorten assignments Study carrel for solo work Pocket dictionary Pocket thesaurus Process reminders on chalk board or desk Electronic dictionary Electronic thesaurus Spell check Use computer or word process for writing Use tape recorder to do assignments verbally Word Prediction software

 There are many:  Alliance for Technology Access Resource Centers  National Center for Learning Disabilities  Parent Training and Information Centers Alliance for Technology Access Resource Centers  Center for Innovation in Learning  Education World

 is a component of the Individuals with Disabilities Education Act that requires States and Local Education Agencies to identify, locate, and evaluate all children with disabilities residing in the State, regardless of the severity of their disabilities, and who are in need of special education and related services.  is a continuous process of public awareness activities, screening and evaluation designed to locate, identify, and evaluate children with disabilities who are in need of Early Childhood Intervention Programs or Special Education and Related Services

 Examples of Child Find activities:  The school publishes a child find notice in the local newspaper or the school’s newsletter  school participates in conjunction with community agencies such as HeadStart, preschool services, and other area preschools; Child find notices are sent to all area clinics, doctors, preschools and daycare centers in conjunction with preschool screening activities  All children entering kindergarten are screened to identify children with suspected disabilities

 The files of all children transferring to the school are screened to identify children who may have been receiving special services in their prior school  Parents of older children who enter the school for the first time are given a document, which explains the school’s special services and who to contact if they suspect their child may have a disability  For children attending the school ages 5 to 21, the primary child find process is parent and teacher referrals. In-service activities to assist teachers in making appropriate referrals are provided annually

 The school student services team reviews the files of all students with a health plan to screen for suspected disabilities  Student Assistance Team (other names may be used) ensure appropriate interventions have been utilized to help the student overcome their learning problems before beginning a referral for special education services

 Child find is integrated with ESEA: Under ESEA, each LEA (school) must have an improvement plan developed to guide school and staff in the improvement of student performance for all student groups in order to attain state standards. The school improvement plan must include strategies for improvement of student performance such as: instructional methods designed based on the needs of student groups not achieving; processes for addressing the needs of children in special programs; integration of technology in instructional and administrative program; positive behavior supports; staff development for educators; and accelerated instruction

 Conduct school data analysis to determine improvement needs in the following areas:  Equipment, supplies, materials  Staff Training  Include training on School Records and Confidentiality; Family Educational Rights and Privacy Act (FERPA)  Secondary Transition

Gloria Yepa (505) Laura N. Tsosie (505) Connie Albert (505)