1 OSEP Verification Visits Fiscal Component FFY Office of Special Education Programs

2 Introducing The Critical Elements Analysis Guide (CrEAG) CrEAG is a tool for organizing and analyzing data to identify what will be addressed during a verification visit. Part B CrEAG document Part C CrEAG document

3 Introducing CrEAG CrEAG replaces old information collection forms, including the OSEP Fiscal Desk Audit form. CrEAG is used to organize data and information collected prior to, and during, the verification visit.

4 Introducing CrEAG Pre-visit sharing of CrEAG with States Pre-visit conversations with States about questions in CrEAG

5 Introducing CrEAG A State is not required to complete the CrEAG and submit it to OSEP. A State is permitted to complete all or part of CrEAG and submit it to OSEP.

6 Components of CrEAG Critical Elements for each focus area Related Questions for Critical Elements – Cells for responses and notes for each Related Question – Cells for flagging issues Related Requirements for each Critical Element

7 Components of CrEAG CrEAG includes sections to record the review and analysis of-- Customer Service Information (e.g., parent contacts) Information from interviews Documents (e.g., SPP/APR)

8 How OSEP Uses CrEAG To organize relevant data and documents for review prior to a verification visit To summarize information from various sources (e.g., parent contacts, APR issues, data reports, audit reports, etc.)

9 How OSEP Uses CrEAG To determine who is interviewed on-site To identify what will be addressed on- site To develop the foundation of OSEP’s verification letter

10 Critical Elements in CrEAG Revised Critical Elements Revised Related Questions for the Critical Elements

11 Fiscal Critical Elements There are Fiscal Critical Elements for Part B and Part C Fiscal Critical Elements for Part B apply to Section 611 and Section 619 grants

12 Fiscal Critical Elements There are differences between Section 611 and Section 619 requirements The SEA is responsible for proper disbursement and use of Section 619 funds

13 First Fiscal Critical Element for Part B and Part C FS-1 Does the State have procedures that are reasonably designed to ensure the timely obligation and liquidation of IDEA funds?

14 Related Questions Under of FS-1 FS-1 includes questions about— Timely obligation of funds (within the 27 month obligation period) Timely liquidation of funds (no later than 90 days after the obligation period)

15 Second Fiscal Critical Element for Part B FS-2 Does the State have procedures that are reasonably designed to ensure appropriate distribution of IDEA funds within the State?

16 Related Questions Under of FS-2— Part B FS-2 includes questions about-- Expending funds consistent with Part B requirements Calculating subgrants Use of administrative

17 Related Questions Under of FS-2— Part B (continued) Funds to charter schools State funding mechanisms and LRE Funds for children parentally-placed in private schools Funds for the LEA Risk

18 Second Fiscal Critical Element for Part C FS-2 Does the State have procedures that are reasonably designed to ensure appropriate use of IDEA funds at the State level?

19 Related Questions Under of FS-2 -- Part C (continued) How does the lead agency ensure that Part C is the payor of last resort – that other public or private sources pay for commitments for which they are legally responsible?

20 Related Questions Under of FS-2 -- Part C (continued) How does the State ensure that Part C funds are not commingled with State funds?

21 Related Questions Under of FS-2-- Part C (continued) How does the lead agency ensure that the total amount of State and local funds expended for early intervention services in one year is maintained or increased in each subsequent year?

22 Related Questions Under of FS-2-- Part C (continued) How does the lead agency ensure that Federal funds are used only for allowable purposes (consistent with 20 U.S.C and 1438)?

23 Related Questions Under of FS-2-- Part C (continued) Does the lead agency have a system of payments? If yes, is it approved by OSEP?

24 Related Questions Under of FS-2 -- Part C (continued) Describe the system of payments, including use of co-insurance, co- payments, sliding fees, defining inability to pay, etc. What is the Status of the State’s indirect cost rate?

25 Related Questions Under of FS-2 -- Part C (continued) What are the barriers that impede the State’s ability to ensure fiscal compliance with the Part C requirements? What is the State doing to address these barriers?

26 Third Fiscal Critical Element Part C does not have a third Critical Element.

27 Third Fiscal Critical Element for Part B FS-3 Does the State have procedures that are reasonably designed to ensure appropriate use of IDEA funds? (Note: Section 611 and Section 619 have different requirements.)

28 Related Questions Under of FS-3 FS-3 includes questions about-- – Communication between finance and program officials – Accounting procedures – Supplement/not supplant – Maintenance of effort / excess cost

29 Related Questions Under of FS-3 (continued) – Continuous Early Intervening Services (CEIS) – Control over property, equipment, etc. in schools serving parentally- placed students – Conducting Single Audits

30 QUESTIONS Discuss questions with your State Contact.