1. Data and Fiscal Management Monthly Webinar October 7, 2014

2. OFFICE OF SPECIAL EDUCATION
Continuous Improvement Monitoring Plan

3. §37-23-5 of the Mississippi Code 1972
Introduction
§ of the Mississippi Code 1972
Foster, inspect, approve, and administer a program of education of exceptional children
Ensure implementation of Federal/State laws
Protect the rights of all Mississippi children and youth with disabilities

4. FOCUS Improve educational results
Improve functional outcomes for all children with disabilities
Ensure public agencies meet program requirements

5. PROCESS Implementation of a four (4) year cyclical process
Examine the compliance with Federal and State special education requirements in five priority areas

6. PRIORITY AREAS Child Find process
Delivery of services and alignment with IEPs, including the area of Language-Speech
Decision-making process for determining least restrictive environment (LRE) decisions
Discipline
Fulfillment of IDEA Part B fiscal requirements

7. SELECTION PROCESS Randomly selected
LEAs were:
Randomly selected
Assigned to a cycle year based on Enrollment Group
35 districts selected for
Audits will be conducted November - April

8. FISCAL PROCESS Selected LEAs will be required to provide:
Fiscal Policy and Procedures
Fixed Asset Listing by location
History Transaction Listing
Employee Payroll Listing
Purchase orders
Semi-annual Certification forms
Personnel Activity Report (PAR)

9. On-Site Activities Conduct an Entrance meeting
Discuss the district’s fiscal process/procedures
Review documents
Conduct a random inventory review
Conduct an Exit briefing

10. FISCAL AIDS
In preparation for the visit the following will be posted to the webpage
Fiscal Monitoring Instrument
Top Ten (10) findings
Tips to prepare for the visit

11. Monitoring Instrument
District Name:
District Code #:
Date of Site Visit:
Team Member:
Policy, Regs, Law Document
Source:
Comments:
Findings:
Documentation Review:
IDEA Part B and Preschool
General Questions 1
Obtain and review the grant award/application to identify activities approved, this includes approved amendments. IDEA grant funds are to pay for the excess cost of students with disabilities on a cost reimbursement basis. Monies drawn down should be for reimbursement of allowable items listed in the approved application.
34 CFR § CFR § CFR § CFR § CFR § Circular A-87 2
Does the LEA program budget reflect the approved IDEA application? Have initial award budgets been amended?
34 CFR § CFR § 3
What is the process for determining that expenditures are allowable and to be charged to the IDEA grant?
34 CFR § EDGAR § 80.22 4
Were IDEA funds used for private school students with disabilities? Are the number of private school students submitted for state funding documented?
34 CFR § 5
Were IDEA funds used to reimburse expenses prior to the release of funds?
EDGAR, § 6
Does the LEA anticipate that funds awarded will be expended prior to the end of the award period?
EDGAR, § EDGAR, § 7
Is there a published method for public & employee reporting of fraud, waste and abuse? Are there existing procedures for investigating/substantiating suspected/reported instances?
Whistle Blower Protection Enhancement Act of 2007 8
How does the entity ensure that a vendor has not been excluded or disqualified from covered transactions?
EDGAR, § 85
Monitoring Instrument

12. Monitoring Instrument
Maintenance of Effort 9
Does the LEA meet the Maintenance of Effort (MOE) requirement, and is there documentation to substantiate? What procedures does the LEA perform to periodically monitor compliance with the MOE requirement? MOE must be maintained, supplement not supplant applies. If MOE is not maintained is there documented release from the requirement by the SEA on file?
34 CFR § CFR § CFR § 10
Does the LEA have on file the calculations for excess costs to demonstrate that the LEA has spent at least the minimum average for education of children with disabilities before Part B funds are used?
Appendix A to Part CFR
Cash Request 11
Review the most recent cash requests and compare to accounting records to verify that grant expenditures reconcile to the request and the receipt of payment is recorded as IDEA funds received.
Circular A-133;CMIA; EDGAR, § 80.20(b)(7); EDGAR, § 74.21; EDGAR, § 74.22; EDGAR, § 80.20; EDGAR, § 80.21 12
Who is responsible for approving requests for cash? Are requests for cash made on a reimbursement basis and not based on anticipated costs?
CMIA , 1990 (Cash Management Improvement Act of 1990); EDGAR, § 74.22(a); EDGAR, § 80.21(b) 13
Is the selected cash request drawn based on reimbursement of expenditures and meets the 72 hour disbursement requirements?
EDGAR, § 74.22(a); EDGAR, § 80.21(b) 14
Did the LEA earn interest on funds drawn for actual expenditures?
EDGAR, § 80.21(h)(i)

13. Contractual Services – Including Procurement
Personnel 15
Where employees are funded 100% from the award does LEA have on file documentation that the employee worked solely on the program for the period covered?
Circular A-87 Attachment B(8)1-3 16
Are there employees paid partially from IDEA funds?
Circular A-87 17
Does the LEA keep personnel activity logs to track employees funded from different sources? 18
Do time sheets reflect both IDEA and non-IDEA hours worked? 19
If salaries are not funded at 100% IDEA, benefits must be prorated based on the funding ratio. Verify that benefits are charged to the appropriate funding source for those salaries paid with multiple funding sources.
Circular A-87 Attachment B(8) 4-6 20
Do all job titles have an MSIS code? Review documentation to confirm job titles have appropriate codes. For those personnel selected for review, are salaries reasonable?
MS Public School Asset Management Manual 21
Review any substitute pay funded with IDEA funds to verify that it is used to fund special education teachers and assistant teachers. Substitute pay is only allowed for special education teachers to attend approved professional development training, workshops and conferences.
34 CFR § ; CFR §
Contractual Services – Including Procurement 22
Were IDEA funds used for contractual services? If yes, describe the types of services.
34 CFR § ; CFR § (a); EDGAR, § 80.36(b)(2) 23
Were services procured competitively? Examine a contractual services procurement file for documentation to support MDE/State regulations were followed.
EDGAR, § 80.36 24
Do contractual services contracts include appropriate IDEA terms and conditions?
EDGAR, § 80.36(i) 25
Were Instructional Services provided by an outside entity for any students? Are approved contracts on file? How are these services being monitored?

14. Equipment or Construction if an Intended Use – Including Procurement 26
Were IDEA funds used by the LEA for construction activities? Did the LEA receive approval from MDE prior to obligating federal funds? Is this activity included in the award budget?
34 CFR § 27
If yes, how were these procured - via open competitive or EPL? Examine documentation for a selected procurement to verify MDE policy was followed.
EDGAR, § 80.36 28
If IDEA funds were used for construction, does the contract include required IDEA terms?
34 CFR § , CFR Appendix A, subpart ; 28 CFR, Part 36 29
Does the construction contract meet the thresholds to invoke the Davis Bacon Act?
Davis-Bacon Act 30
Verify that the "product" of any completed construction is recorded as a fixed asset.
EDGAR, § 80.32; 31
Were IDEA funds used by the LEA to purchase equipment? Were these purchases included in the award budget?
Davis-Bacon Act, Circular A-87 Attachment B(15) 32
How was the equipment procured, via open competitive or EPL? Examine documentation for a selected procurement to verify MDE policy was followed.
EDGAR, § 80.32, Circular A-87 Attachment B(15) 33
Verify that the equipment is recorded as a fixed asset and includes a property identification tag which includes funding source.
EDGAR, § 80.32(d)(1-2); MS Public School Asset Management Manual EDGAR, § Circular A-87

15. Other Expenditures 34
Review expenditure transaction detail for disbursements within the designated IDEA funds for purposes other than those expenditure types reviewed in steps above. Are these consistent with the award budget/intended use and are they reasonable and allowable?
EDGAR, § 80.21; CFR § ; CFR § 35
Are there legal fees paid from IDEA funds? Only Legal expenses required in the administration of the Federal programs are allowable.
34 CFR § (b), Circular A-87 Attachment B(10) 36
Any funds used for adjustment of local effort, School-wide Programs, or Coordinating Early Intervening Services (CEIS)? If so, were they used only as allowed and records kept?
34 CFR § CFR § 37
Is the LEA required to set aside 15% of its IDEA award for CEIS? If so, is there documentation to show that the funds were used for allowable cost?
34 CFR § ; CFR § 38
Is documentation on file to detail the proportionate amount of funds must be reserved for providing services to private school students with disabilities? Is there documentation on file to substantiate the number of private school students submitted to the State for funding purposes?
34 CFR § Appendix B to Part 300 39
If indirect costs are charged to the IDEA grant, are these charges at the statewide MDE calculated rate?
EDGAR, §§ , Circular A-87 Attachment A(F)

16. Top Ten Findings
Time sheets/Semi-Annual Certification forms not available and/or not signed by employee and/or supervisor
Equipment not on the Asset List
Equipment not tagged and funding source not indicated
Purchasing of equipment not approved or deleted from project application
Invalid or no contracts for contractual services

17. Top Ten Findings
Asset Listing does not indicate description of item, serial number or location
Equipment not properly hand receipted
Equipment not being used for its intended purpose
Unauthorized use of IDEA funds
Equipment purchased with IDEA funds used in general education classrooms

18. Tips to Prepare for the Visit
Prepare your Staff
Assemble the Players
Set the tone
Organize Documentation
Be prepared to address identified noncompliance as they arise
Select a meeting/work place
Use the Fiscal Protocol to prepare

19. NON-CYCLIC AUDITS A financial review will be conducted of each LEA
Purpose is to determine the level of financial risk
Financial Risk Assessment reviews four areas
General Assessment
Monitoring/Audit Assessment
Fiscal Assessment
Financial Stability
Each area has a total point value assigned
Questions within each area have a point value
100 total points

20. Risk Assessment Factors
General Assessment (25 points)
Is the Special Education Director new to operating or managing IDEA funds?
Has the LEA been untimely in submission of reports?
Have any other entities alerted us of potential risk areas?

21. Risk Assessment Factors
Monitoring/Audit Assessment (10 points)
Has the LEA had a single audit exception?
Fiscal Assessment (35 points)
Has the LEA returned any unspent funds or been untimely in the request of funds?
Does the LEA have a large amount of budget carryover?
Does the LEA have any variation between expenditures and the approved budget?

22. Risk Assessment Factors
Financial Stability Assessment (30 points)
Has the State placed the LEA in a special financial status?
Has the State place special financial conditions on the LEA’s award?
Has the LEA met Maintenance of Effort?

23. Risk Assessment scoring
Risk assessment scores are determined by the number of points received
LEAs are assigned a risk level based on their scores
Three levels of risks
High Risk – 60 points or more
Medium Risk – 30 points to 59 points
Low Risk – 29 points and below
9/21/2018

24. Risk Levels Low Risk Medium Risk High Risk On-site visit
History Transaction Listing
Medium Risk
Payroll Listing of personnel
Time & Effort Report
Semi-annual Certification forms
High Risk
On-site visit

25. CONTACT INFORMATION
Audrey Shaifer
Office Director, Fiscal Management
Mary Bobbitt
Division Director, Program Management
Barbara Quarles
Division Director, Educable Child
Louis King
Program Coordinator, Special Education