1. Bureau of Indian Education Division of Performance and Accountability
FISCAL MANAGEMENT
Special Education Funds
SY High Risk Schools
Webinar - October 20, 2014

2. The purpose of the training is:
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

3. Challenges unique to SY 2013-14
FBMS created delays in allocating funds to the schools
National formats no longer a way of disseminating training and information; increased use of webinars, s, conference and phone calls
Due dates were adjusted to accommodate changes
Native Star was used for the first time to submit documents
Web Budget was used for the first time
DPA Special Education staff decreased from 11 to 6

4. Fiscal Monitoring for Special Education
Procedures
The Fiscal Monitoring Procedures for Special Education ensures a school’s compliance to certain fiscal and administrative requirements for special education funds, 15% ISEP Instructional Funds and IDEA Part B Supplemental Funds.

5. 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 in the Least Restrictive Environment;
Problems are identified and remediated; and
Oversight is provided that would result in improved student outcomes.

6. Process
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.

7. A. Desk Audit
The BIE reviews and rates the following fiscal documents:
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)

8. 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

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

10. B. On-Site Fiscal Review
An on-site visit provides an intensive level of fiscal review, and is the result of continuing violations of federal and IDEA fiscal requirements

11. Criteria – if a school meets 2 of the following, the school is identified for an on-site fiscal review:
High risk level for two consecutive 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
Annual Report (TCS)

12. Written notification of an on-site fiscal review is sent by January 31
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

13. Analysis of data collected during the on-site fiscal review
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.

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

15. Conduct quarterly progress checkpoints
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

16. Data Analysis
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.

17. Evaluation
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.

18. Desk Audit Process School Part B Application: 4 Points
Timely submission (1)
Complete application (1)
Signature after School Board Approval (2)
BIE Web Budget/Consolidated S W Budget
K-8 Schools (19)
K-12 Schools (23)
FASA (45)
CEIS (9)

19. SY2013-14 Fiscal Risk Desk Audit School Results
Regions
Number of
Low Risk
Schools
Medium Risk
High Risk
Total
Number of Schools
East 1 25 29 55
Navajo 20 40 61
West 2 16 42 60 4
111
176

20. Budget Reviews
Timely submission of the budget with appropriate signatures?
Were there adequate allocations and justification provided to support the allocation?
FTEs for personnel (special education teachers, education technicians, related service providers, special education coordinators, secondary transition specialists) per the ratio of students with disabilities (SWD) and their service needs
Supplies, materials, equipment and assistive technology

21. 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 placements in settings away from the school (incarceration, intensive specialized instruction or therapy, illness of student)

22. Budget Analysis Findings
Most schools demonstrated appropriate use of Special Education funds in the following areas:
Transportation
Personnel
Related Services
Education Technicians
Special Education Teachers
Majority of schools provided Budgets and used the BIE format
Few entries of “Inappropriate and Non Allowable Costs”

23. Secondary Transition Specialist
Questionable Costs (based on 164 schools submitting budgets, not all used the BIE format)
Budget Item
# of Schools/Percent
Parent Training
116/70%
Assistive Technology
98/59%
Child Find
Equipment (92/56%)
Materials (76/45%)
Supplies (69/42%)
48% (Average)
Staff Training
76/46%
Secondary Transition Specialist
26 (60 HS)/43%
Work Study Programs
20 (60 HS)/33%

24. FASA Analysis Findings
School received the score because:
No information/description was not entered (90%)
WebEx on October 28, 2014
The upload documents were not available in Native Star for review (87%)
Travel and training to achieve the goals & objectives were not reasonable and necessary.
May grantees use Federal grant funds to pay for the cost of attending a meeting or conference?
If attending a meeting or conference is necessary to achieve the goals and objectives of the grant, and if the expenses are reasonable (based on the grantee’s own policies and procedures, and State and local laws), Federal grant funds may be used to pay for travel expenses of grantee employees, consultants, or experts to attend a meeting or conference. To determine whether a meeting or conference is “necessary,” grantees should consider whether the goals and objectives of the grant can be achieved without the meeting or conference and whether there is an equally effective and more efficient way (in terms of time and money) to achieve the goals and objectives of the grant (see question #3). To determine whether the expenses are “reasonable,” grantees should consider how the costs (e.g., lodging, travel, registration fees) compare with other similar events and whether the public would view the expenses as a worthwhile use of Federal funds.
What travel expenses may be paid for with Federal grant funds?
Grantees may use Federal grant funds for travel expenses only to the extent such costs are reasonable and necessary and do not exceed charges normally allowed by the grantee in its regular operations consistent with its written travel policies. In the absence of an acceptable written policy regarding travel costs, grantees must follow the Federal travel and subsistence rates established by the General Services Administration. 48 CFR (a) (established under subchapter I of Chapter 57, Title 5, United States Code (“Travel and Subsistence Expenses; Mileage Allowances”)). Federal grant funds may be used to pay expenses for transportation, per diem, and lodging if the costs are reasonable and necessary. Grantees should follow their own travel and per diem rules and costs when charging travel expenses to their Federal grant. As noted in the cost principles, grantees that do not have travel policies must follow:
…the rates and amounts established under subchapter I of Chapter 57, Title 5, United States Code (“Travel and Subsistence Expenses; Mileage Allowances”), or by the Administrator of General Services, or by the President (or his or her designee) pursuant to any provisions of such subchapter shall apply to travel under sponsored agreements (48 CFR (a)).
See 2 CFR Parts 220, 225, and 230.

25. Justification of unusual items
Use of indirect cost
Separation of duties
Special education coordinator/lead teacher not involved in the verification of purchase of supplies, and contracts.
Justification of unusual items
Looking at it another way, indirect costs are those costs that are not classified as direct. Direct costs can be identified specifically with particular cost objectives such as a grant, contract, project, function or activity. Direct costs generally include:
Salaries are wages (including vacations, holidays, sick leave, and other excused absences of employees working specifically on objectives of a grant or contract – i.e, direct labor costs).
Other employee fringe benefits allocable on direct labor employees.
Consultant services contracted to accomplish specific grant/contract objectives.
Travel of (direct labor) employees.
Materials, supplies and equipment purchased directly for use on a specific grant or contract.
Communication costs such as long distance telephone calls or telegrams identifiable with a specific award or activity.

26. CEIS Analysis Findings
Regions
Low Risk
Medium Risk
High Risk
Total
East 18 5 4 27
Navajo 6 1 10 17
West 8 9 22
TOTAL 24 14 23 61

27. Schools received a score of 0 because:
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;
Schools exceeded the threshold of 15%. Schools may use the option to use up to 15% of their Part B allocation for the given year if they are meeting the IDEA requirements; however, the Part B amount for CEIS cannot exceed the 15% threshold.

28. The CEIS rating was based on the following:
The Part B allocation was below the 15% Part B threshold
The “Responsible Person” for CEIS at the school was identified
The “targeted audience” was identified
The School’s CEIS program was described
The number of student participants was provided
The entrance and exit tools and criteria were provided

29. TECHNICAL ASSISTANCE Parent Training – 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

30. 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

31. Native American Parent Technical Assistance Center (NAPTAC): Education for Parents of Indian Children with Special Needs (EPICS)
Judy Wiley, Lead Training Specialist
(541)

32. There are a broad range of assistive devices:
Assistive Technology
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

33. IEP Goal Example Present Level of Education Performance
Trisha demonstrates knowledge of basic computer
functions using a standard keyboard and word
processor. She dictates sentences and uses a
scribe for transcription. She uses a spell checker
to write short sentences. Typically she makes five
spelling, four punctuation, and three grammar
errors per page of familiar material.

34. Measurable Annual Goal Trisha will compose paragraphs and classroom
assignments using a word processor for
correction of spelling, punctuation and grammar
Short-Term Objectives or Benchmarks
Using a word processor, Trisha will compose a complete paragraph consisting of four sentences, with fewer than a total of three spelling, punctuation, or grammar errors on a final report completed in the resource room on a topic identified the previous day
Using a word processor, Trisha will correct spelling on selected classroom assignments at 90% accuracy for five or more consecutive assignments

35. Accommodations/Modifications Example Skill Area: Written Expression
Method
Material
Technology
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
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

36. Some AT Resources, there are many
National Center for Learning Disabilities
technology-education
Parent Training and Information Centers
Alliance for Technology Access Resource Centers
State Tech Act Projects
Education World

37. Child Find
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

38. 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

39. 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

40. 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

41. 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

42. Conduct school data grass roots 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
Training to be provided to all BIE High Schools (refer to the DPA Special Education Unit Calendar of Activities and Due Dates for SY – posted to the BIE Website)

43. Next Steps
When we receive input from schools on training and technical assistance needs, DPA will review and identify subsequent activities in this area.
Please send your input to rachael.nicholas-
Thanks!

44. Contact Information
Gloria Yepa (505) Laura N. Tsosie (505) Connie Albert (505)