1. 2012 Fiscal Responsibility Title III Webinar
Stephanie English, Chief
Monitoring & Compliance Section
School Business Division
ESL/Title III Consultants
Glenda Harrell Joanne Marino Ivanna Mann Thrower

2. Monitoring Indicators -- Fiduciary
Items Included:
 Student count documentation
 Budget, including Administrative costs
 Implementation of Activities
 Documentation of expenditures for equipment, personnel, contracted services
 Supplement/Supplant (basic services as well as assessments)
ESL

3. 1.3: Annual Measurable Achievement Objectives (AMAOs).
Guiding Questions
Acceptable LEA Evidence
Compliance Indicator(s) Rating
Has the LEA met all three AMAOs?
Has the LEA followed its improvement plan related to two-year /or four-year accountability provisions?
LEA notification letters to parents regarding LEA has not met AMAOs, if applicable.
Possible Documentation:
State content assessments data
Documentation of testing accommodations
Agendas from teacher meetings where AMAOs and related issues are discussed
Rating:______
For a rating of ‘2’, list the change(s) suggested to be implemented.
For a rating of ‘1’, list the action(s) required to be taken to meet compliance requirements.
ESL
Describe the format – In our monitoring document we have:
Guiding questions – All will not be asked but what the monitoring will be looking for. Can ask others.
Evidence – possible pieces. Don’t have to have all of them. May be others.
Compliance Indicators explained on cover of application
3 in compliance
2 boarderline in compliance but to remain in compliance these are suggested changes needed
1 not in compliance- MUST make changes.

4. 3.1 Student Count
Does the LEA have documentation of the count of LEP Students?
Explanation of the headcount procedures
Headcount is important in the fiduciary section of the monitoring document because your money is based on your count!
ESL How are LEP students Identified – HLS, ESL specialist determines HL, testing, results recorded in W-APT, archive of count of Oct 1, Dec MetriTech File (reference for hand coding), Feb 1 and end of year.
Not only are LEAs obligated to W-APT identify students as LEP within 14 days of enrollment after the beginning of the school year, they must also enter the information into the W-APT CFDC.

5. Budget Issues Administrative Cost Limitation
2% of current year allotment
Purpose code 6200
Indirect cost ( )
When is a budget amendment required? When total of overspent lines is more than 10% of approved budget
Monitored via Budget vs. Expenditures printout
Stephanie will address admin…indirect cost interplay

6. Implementation of Activities
Evidence that the LEA is implementing required activities.
Evidence that the LEA is implementing activities that are supplemental (budget reports, record of expenditures)
ESL
When monitoring we are checking to see that you are doing what you said you would do in the application and/or amendments.
Explain why supplement/supplant is so important. The government takes this very seriously. We have been cited in our draft findings for supplanting Title III funds.
The Supplemental Title III Program - Required Services (Question 10 on page 9 of the Application) Parent involvement, PD- targeting LEP, Application is a collaborative process – parents, teachers, administrators – should match your budget
What application says is actually being done, includes optional section of application. (Question 12 on page 10 of the Application)

7. Questions

8. 3.2 Title III expenditures / equipment
How do Title III expenditures meet federal fiscal requirements?
How does equipment benefit the Title III program?
Stephanie
Similar to previous question but looking more at the EDGAR requirements of Time and Effort, equipment inventory and invoices.
Documentation how equipment is being used to benefit Title III. Suggest a spreadsheet.

9. Equipment Documentation
Governed by EDGAR 80.32
Tagging and tracking of non-consumable items with a useful life greater than one year
Monitored via list of “federal” equipment
Physical inventory at least once every two years; evidence required
Follow DPI’s Federal Equipment Disposition process when removing items from inventory; keep approval letters on file. (Form on web at under “Compliance Resources, Monitoring.”)
Stephanie

10. Personnel Documentation
Also known as “Time & Effort” documentation
For employees paid with federal funds, including tutors (but not subs)
Semi-annual certifications for individuals who work only on Title III activities
Personnel Activity Reports (PARs) for individuals who work on Title III and something else
Stephanie

11. Time & Effort – additional information
Additional training info on web at ; see “Documenting Time & Effort” under Federal Information.
Your finance staff is your first line of defense – all federal programs must document time and effort.
Compliance monitored by matching time & effort documentation to payroll printouts.
Quarterly reconciliation of PAR data to payroll expense (typically the responsibility of finance staff).
Stephanie

12. Invoices for Contracted Services
Object code 311
Invoices must be specific – who, what, when, where
Stephanie

13. Additional documentation
Internal Controls – LEA’s policies/procedures for purchasing/procurement, fixed assets, etc.
Responsibility of finance office; Title III staff should also be aware of the existence of these policies.
Stephanie

14. Procurement – one additional note
Suspension/Debarment
Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred.
Debarred Vendors list – State and Federal can be found at
Stephanie
Debarment: strategies for checking
ESL comment: This is why the super has to do one of the statement of assurances

15. Questions

16. 3.3 Supplement, Not Supplant
What is the basic instructional program/service provided to all students (e.g., to meet Lau requirements)? How are Title III funds providing activities/services that are supplemental?
What funds is the LEA using to provide the basic language instruction educational program for LEP students?
How has the LEA demonstrated that services provided with Title III funds are in addition to services that students would otherwise receive from State, local or other Federal funds?
ESL
When we are discussing S/not S you first have to determine what your basic program is. In Basic cannot be paid out of T3 funds – supplanting – teachers delivering basic ESL program not T#.
How provide supplemental? Icing on cake? Cake is ESL what above and beyond. Can be paid for with T3.
Application –– similar to previous question with focus on not supplanting.
54 funds should not be the only funds used – comes after basic requirement. Should use local, other
3 bullets are asking the same question in different ways to address different learning styles.

17. Supplement, Not Supplant
What services is the LEA required by other Federal, State, local laws or regulations to provide?
How has the LEA demonstrated that it is not using Title III funds to provide services that it is required to make available under State or local laws or other Federal laws?
How has the LEA demonstrated that it is not using Title III funds to provide services that it provided in the prior year with State, local or other Federal funds?
ESL
Explain why NC DPI is so serious about this – Feds are serious!
Are they providing services required by 054, EC, core subjects, Title I
Same
Expenditures from previous year to assure not supplanting
Ask yourself to be sure you are not supplanting

18. 3.3A Supplement, Not Supplant
Use of Funds to Administer ELP Assessments
What funds other than Title III has the LEA used to identify LEP students who may need language services, including the development of ELP screening or placement assessments?
What funds other than Title III does the LEA use to pay for the costs of administration, scoring or reporting of ELP assessment, and materials or equipment related to the administration of annual ELP assessments?
ESL
Title III are not additional funds to extend the services you are already providing – teachers in core, interpreters interpreting what is required by OCR, are not allowed
This applies to the W-APT. Cannot use funds for W-APT
ACCESS – reporting is talking about the scores that go to Accountability, not FDC. FDC can use Title III funds depending on the job description because it is for federal recording which is required.
An LEA may use Title III, Part A funds to pay for initial LEP assessments for private school students in cases where the use of such funds would not supplant other Federal, State and/or local funds that may be used for such purposes.

19. Supplement, Not Supplant
Screening and Placement Assessments for LEP Students [W-APT]
What funds other than Title III does an LEA use to develop and administer assessments to identify LEP students and place them in basic language programs?
ESL
Cannot use Title III funds for W-APT. You can use Title III funds to purchase an off the shelf test to identify pre-K students since it is a supplemental service.

20. Questions

21. Resources Federal information: OMB Circulars, EDGAR
Other:
Debarred Vendors list –

22. Contacts Stephanie English, Chief Monitoring & Compliance Section
ESL/Title III Consultants
Glenda Harrell Joanne Marino Ivanna Mann Thrower