1. PERKINS 101 2016 CTE Interns

2. PHOUANG HAMILTON Office of Superintendent of Public Instruction Career and Technical Education Phouang.Hamilton@k12.wa.us 360-725-6245 Jill Pilbro, Office Assistant Career and Technical Education Jill.Pilbro@k12.wa.us 360-725-6245 Monica Trabue, Office Assistant Career and Technical Education Monica.Trabue@k12.wa.us 360-725-6245

3. DISCLAIMER The opinions and guidance expressed in this training/workshop is for educational and information purposes only. I use reasonable efforts to insure that information provided herein is accurate and is the most current information available at the time of training. However, districts are urged to contact the CTE program office directly via email to verify its accuracy prior to making costly programmatic decisions.

4. PERKINS IV There has been some type of CTE/Vocational program funded since 1917 (Smith Hughes Vocational Act) In terms of raw dollars, Perkins is not a major educational grant (WA – 20.6M) Perkins, the largest grant targeted at secondary education

5. PERKINS 101 Perkins is “split funded” between the secondary (high schools) and the postsecondary (community colleges) programs The average split nationally is 59.24% secondary and 38.89% postsecondary The splits are determined by each state WA – 56% Postsecondary 44% Secondary

6. PERKINS – In Trouble? The President’s Administration has agreed to the: Elimination of Tech Prep (Title II of Perkins) Continual reduction in Perkins funds to States Continual funding cuts to States and Locals will require everyone to plan on the conservative side

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8. The Bible

9. How does Perkins fit in CTE programs? It’s a Federal formula program meant to improve and enhance existing CTE programs The Perkins act was originally authorized in 1984; the most recent authorization is Perkins IV in 2006 District funding allocations are based on Federal census and poverty data Perkins is federal money – The state (OSPI) and local grantees (districts) must follow the Education Department General Administrative Regulations

10. PERKINS 101 State Allocations Are Census Based In-State Allocation – Secondary District census data 70% based on school aged kids 5-17 census count at or below poverty guidelines 30% total district census data (Section 131 (a)(b))

11. PERKINS 101 GETTING STARTED LEAs – Your District’s Perkins 5-Year Application Plan (iGrants form package 214, 215, or 274) Pitfalls – Don’t just write “something” to get the money Local applications – Recipients, follow it or amend it Check your progress and budget at least mid-grant and 90 days before your end date

12. PERKINS 101 DISTRICT PERKINS APPLICATION PLAN - The law is just the minimum requirements States can add more requirements, set parameters, restrictions, etc.. Prioritize uses of funds Connect accountability to uses of funds

13. PERKINS 101 PRIVATE SCHOOL PARTICIPATION - Secondary students attending nonprofit private schools can participate in public CTE programs Consultation with nonprofit private schools regarding the private school participation is a must

14. PERKINS 101 NOT AN ENTITLEMENT GRANT – You have to have one or more programs of sufficient size, scope and quality to warrant the receipt of grant funds If your allocation is $15k or less, locals will need to either – Request and receive a waiver (page 3 of the local Perkins application plan) Or Enter into a consortium agreement with another district(s) (form package 214) Waivers – Locals need to be able to justify the waiver

15. PERKINS IV Waivers – Districts need to be able to justify the waiver The district has a viable program, and Districts are not able to enter into a consortium due to: Rural isolation No one within a reasonable distance wishes to enter into a consortium (Section 131 (c) (1-2): Section 132(a)(3-4): Section 132 (C): Section 132 (C)(2))

16. PERKINS 101 LEARN THE TIMELINE States – Without an approved State Plan or a Plan judged to be in a “substantially approvable form” a state may not obligate Perkins funds Recipients – Are in the “same boat” – they can’t obligate their new grant funds until their application is “substantially approvable”… EDGAR 34 CFR §76.703(d) EDGAR 34 CFR §76.708(a) Example – A recipient’s new fiscal year begins July 1 st. On July 6 th, in anticipation of school starting, the district buys some badly needed CTE equipment. Their application for the new school year is substantially approved two days later on July 8 th. This district may not use Perkins funds to pay for this equipment – even if the delay is the state’s fault.

17. PERKINS 101

18. Your district’s Perkins application is approved – you’re ready to go and spend your money! What can I spend $$$ on? Follow your approved Perkins 5-Year Application Plan

19. PERKINS 101 GENERAL TEST OF ALLOWABILITY Fits with your application Allowable per the appropriate OMB Circular Reasonable and Necessary Allocable Consistent with your district’s policies Not charged elsewhere Adequately Documented When in doubt, contact the CTE program office at OSPI

20. PERKINS 101 SALARIES Yes – You must do “time-and-effort” (T&E) reporting Employee works full time on Perkins you – Must certify the employee at least annually T&E records must be signed by the employee or a supervisor with first hand knowledge Multiple cost objectives require regular Personnel Activity Reports (PARs) The cost has to be “allocable” to your Perkins grant After-the-fact reporting Signed by employee Coincide with pay periods; at least monthly OSPI Bulletin #051-11 Secondary, SEAs, Governments, BIE – OMB Circular A87 Appendix B.8.h.

21. The most common problems, goofs! 21

22. A COMMON PROBLEM FAILURE TO FOLLOW YOUR DISTRICT’S APPROVED APPLICATION PLAN

23. OUR APPLICATION WAS APPROVED – WE’RE GETTING THE MONEY – “LIFE IS GOOD” & I AM DONE! Review it at least at the 6 and 9 month points. Follow it, or AMEND IT The OMB Circular A133 CTE Supplement – 4-84.048 (15 pgs.) 23

24. COMMON PROBLEMS PROCUREMENT – If your procurement shop or business office are not known for their attention to details - Cover your “butt” If you have to, keep your own set of documents Purchase orders Receiving documents A mini-inventory, with item location info Keep it current You need to put special procedures in place for items that cost less than $5K but are high-theft items Do your approved purchases agree with your approved application? Does your annual fiscal completion report reconcile to your actual purchases?

25. PERFORMANCE INDICATORS PERKINS ACCOUNTABILITY

26. Purpose of Section 113 is to set out the Act’s accountability requirements and core indicators for performance at the secondary and postsecondary levels for all CTE students. A. Sub-sections in Section 113 identify the (a) purpose, (b) state performance measures and (c) reporting. B. Sub-section 2 Indicators of Performance identifies WHAT indicators you are being held accountable for.

27. PERKINS ACCOUNTABILITY SecondaryPostsecondary 1S1: Academic Attainment | Reading/ Language Arts 1P1: Technical Skill Attainment 1S2: Academic Attainment | Mathematics2P1: Credential, Certificate, or Diploma 2S1: Technical Skill Attainment3P1: Student Retention or Transfer 3S1: Secondary School Completion4P1: Student Placement 4S1: Student Graduation Rates5P1: Nontraditional Participation 5S1: Secondary Placement5P2: Nontraditional Completion 6S1: Nontraditional Participation 6S2: Nontraditional Completion Section 113 Core Indicators of Performance

28. PERKINS ACCOUNTABILITY SACTIONS ARE REAL!! Possible Sanctions if States: Fail to implement an improvement plan, OR Fail to show performance improvement once an improvement plan is in place, OR Fail to meet 90% of the same performance indicator for 3 consecutive years District sanction language mirrors that of the State State Education Agency can withhold some or all of the entire local grant allocation

29. DATA SYSTEMS AND REPORTS

30. What is CEDARS? What are Student Information Systems (SIS)? What are the Adjust Graduation Cohort Report (formerly known as the P210) and the Annual CTE Student Enrollment File (formerly known as the P210Voc Report)? What is Data Matching? Why is it important for us to submit these reports? What are the repercussions if we do not comply with reporting requirements?

31. DATA SYSTEMS AND REPORTS The Comprehensive Education Data and Research System (CEDARS) Districts submit individual student, teacher, and course information on a frequent bases Data elements for Perkins requirements are pulled from CEDARS Districts verify and certify all data submitted for the CTE student enrolled for the reported year

32. DATA SYSTEMS AND REPORTS Where does the student data come from? Annual CTE Student Enrollment File – a summary of all students served in any CTE courses in grades 7-12 in CEDARS for the current reporting Perkins federal reporting only includes students in grades 9-12 Collection period: September 2014 through September 2015 How do we identify CTE Concentrators? Districts do not identify or report concentrators to OSPI. A concentrators is a secondary student who has enrolled in 2 or more CTE courses above the exploratory level in a single cluster. Note: Concentrators are determined by reviewing a students entire high school enrollment history

33. DATA SYSTEMS AND REPORTS CEDARS Outcomes CEDARS has reduced the redundancy in reporting from districts Allow OSPI to generate and consolidate reports for district viewing CEDARS reports are used for federal, state, and local use to determine funding of certain programs

34. CEDARS Data Files Location File Student Demographics Student Enrollment Information Course Catalog Student Schedules* Grade History D–Course Catalog H-Grade History E-Student Schedules C–School Student File (enrollment) B–District Student File (demographics) A–Location File 34

35. CIP CODE State Course Code TEACHER CERTIFICATION V-CODE COURSE NAME 01050418102V010000Dog/Pet/Animal Grooming 01050718104V010000Equestrian/Equine Studies 19070619052, 22204V200002Child Development/Parenting State Course Codes… mapped to CIP Codes

36. Grade History File data elements Element H04 – State Student ID (SSID) Element H05 – Location ID Element H06 – Staff ID Element H07 – Course ID Element H08 – Course Title Element H09 – Grade Level Code Element H10 – Letter Grade Element H11 – Credits Attempted Element H12 – Credits Earned CEDARS Grade History File

37. Grade History File data elements, cont’d Element H13 – Course Designation Code Element H16 – (AP) and (IB) Code Element H17 – (CIP) Code Number Element H18 – Term End Date Element H19 – Term CEDARS Grade History File

38. CTE Grade History File data elements – Element H20 – Is the Student a Career and Technical Education (CTE) Program Completer? Element H21 – Did Student Receive a State or Nationally Recognized Industry Certification? Element H22 – Is Career and Technical Education (CTE) Direct Transcription Available? Element H23 – Is Tech Prep Completer? Element H24 – Did the Student Take or Pass a State or Nationally Recognized Assessment of Technical Skills and Knowledge? CEDARS Grade History File

39. WORK CLOSELY WITH YOUR CTE TEACHERS AND CEDARS ADMINISTRATORS CTE DATA AND REPORTS

40. ALLOWABLE/UNALLOWABLE USES OF PERKINS FUNDS

41. EDGAR (34 CFR §80.1) defines equipment as personal property that costs $5,000 or more – The issue has more to do with a state’s inventory requirements (and the associated costs) than the purchase price The OIG (Office of Inspector General) has been issuing findings relative to items of equipment that are considered “attractive theft” items – cell phones, digital cameras, flat screen monitors, etc. that cost a lot less than $5,000 When is something a supply and not equipment? Use a “reasonable person approach” – Does it have a useful life of a year or more, would you throw it away or repair it, does your own district’s criteria treat it as a supply or equipment? (see handout on Criteria for Distinguishing Non-capitalized Items from Capital Outlay – blue handout) EQUIPMENT 41

42. Get it written into your approved application Items like your CTE computer lab Specialized workstations The cost of connecting equipment Etc. Avoid paying for stuff your district typically supplies to all your district’s educational programs – desks, chairs, PCs USE NON-PERKINS FUNDING WHERE POSSIBLE Trade Perkins-funded CTE costs for those CTE costs funded with non-federal $$$ Pursue donated equipment where possible EQUIPMENT CONT. 42

43. Little guidance – the Feds typically refer you back to 34 CFR §403.71(c) – The last regulatory guidance for Perkins, under Perkins I Allowed – Instructional related costs (very narrow) Disallowed – All the fun stuff… CAREER AND TECHNICAL STUDENT ORGANIZATIONS States – Section 124(c)(4) Local Recipients – Section 135(c)(5) 43

44. (i)Lodging, feeding, conveying, or furnishing transportation to conventions or other forms of social assemblage; (ii) Purchase of supplies, jackets, and other effects for students' personal ownership; (iii) Cost of non-instructional activities such as athletic, social, or recreational events; (iv) Printing and disseminating non-instructional newsletters; (v) Purchase of awards for recognition of students, advisors, and other individuals; or (vi) Payment of membership dues; (d) Leadership and instructional programs in technology education; and (e) Data collection. (3) The support of vocational student organizations may not include— My guess, they mean, non-instructional, out-of-the-classroom-type activities that don’t meet the conditions of 34 CFR § 403.71(c)(2)(iv) & – “all students…” 44

45. 45 Allowable Costs Reasonable and Necessary; Allocable to the Federal Award; Legal Under State and Local Law; Properly Documented; Consistent with the Provisions of the Grant Program; and Not used for cost sharing or matching any other grant agreement. OMB Circular A-87 See Handout Appendix B

46. “NO” Unless it is related to – Approved travel (subject to your state’s per diem guidelines) Included in your approved registration Not considered entertainment Included as part of an approved conference or meeting (attending or sponsoring) A consumable training supply (culinary arts) Alcohol never allowed Read Goods or services for personal use – A87 Attachment B.20 & A21 Section J. 22. FOOD & BEVERAGES OMB A87 B.3; OMB A21 J.3 OMB A87 B.14; OMB A21 J.17 OMB A87 B.27; OMB J.32 OMB A87 B.43; OMB J.53 46

47. Travel is allowable when it supports your approved grant or plan Meals, lodging, all the usual stuff is allowable, when approved Should be reasonable DOES NOT INCLUDE ENTERTAINMENT COST What about those conferences where entertainment is included in the registration fee? It’s your state’s call… If the cost is separate and identifiable and the employee wants to participate they must cover the cost out of their own pocket OMB A87 Attachment B.43 or OMB A21 Section J.53 TRAVEL FOOD & BEVERAGES 47

48. OMB A87 B.27 (Comparable language in OMB A21 J.32) “Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental facilities, speaker’s fees, and other items incidental to such meetings or conferences. See OMB A87 B.14; OMB A21 J.17, “Entertainment Costs”. Must be reasonable Must be able to stand the, “Would you like to see this on the front page of your local paper?” test Does NOT include internal staff meetings MEETINGS & CONFERENCES/FOOD & BEVERAGES 48

49. Memberships for a district is OK. For example the cost would be OK for your district CTE Director’s position, regardless of who the individual is – but not for the individual who is the CTE Director Must be “allocable” to your Perkins project or plan Use the “reasonable person” approach It is recommended that you utilize your procurement system procedures if you are looking at a - Significant cost Sole source provider (speakers, intellectual property, copyrighted, etc.) MEMBERSHIPS, SUBCRIPTIONS & PROFESSIONAL ACTIVITY COSTS 49

50. Awards or Gifts -Typically Not Allowed However you can purchase nice frames through your approved local office supply contract, print out a nice certificate on your color laser printer and hand the result to folks… Hand out donated items from your state’s Chamber of Commerce, local industry groups, etc. AWARDS OMB A87 B.1.f(3); OMB A21 J.1.f(3) OMB A87 B.20; OMB A21 J.22 50

51. Alcohol Entertainment expense Awards (gifts) Promotional items (freebies) Promotional advertising NOT ALLOWED OMB A87 B.3; OMB A21 J.3 OMB A87 B.14; OMB A21 J.17 OMB A87 B.20; OMB A21 J.22 OMB A87 B.1.f.(3); OMB A21 J.1.f(3) OMB A87 B.1.f(4); OMB A21 J.1.f(4) 51

52. CONSOLIDATED PROGRAM REVIEW (CPR)

53. Monitor multiple federally funded programs under the Elementary and Secondary Education Act (ESEA) Fulfills OSPI’s compliance monitoring requirements under Federal regulations (2 CFR 200) The CPR process consists of an OSPI team reviewing school districts federal and selected state programs The monitoring activities are designed to focus on the results of the district’s efforts to implement critical requirements of the ESEA using available resources and flexibility provisions

54. District Contacts CPR Contact Responsible for coordinating the review for all monitored federal and state programs. All future communication will be sent to this individual and the district superintendent. Provide name, title, phone number and email address. Fiscal Contact Point of contact for fiscal cross ‐ cutting portion of review. Provide name, title, phone number and email address.

55. CONSOLIDATED PROGRAM REVIEW (CPR) Title I, ATitle IV, B –Rural Education LAP (Learning Assistance Program)Title X –McKinney-Vento (Homeless) Title I, C –Migrant EdHighly Capable Title I, D –Neglected and DelinquentPerkins / CTE Title I, G –AP (Advanced Placement)Private Schools Title II, A –Highly QualifiedCivil Rights TBIP (Transitional Bilingual Instructional Program / Title III Fiscal Gun-Free Schools Act OSSS (Office of Student and School Success)

56. CONSOLIDATED PROGRAM REVIEW (CPR) CPR Review Timeline 2015-16:Districts in ESDs 121 and 171 2016-17:Districts in ESDs 105, 112, and 113 2017-18:Districts in ESDs 105, 112, and 113 2018-19: Districts in ESDs 123 and 189 The “BIG 4” Districts Reviewed annually. Due to the size and amount of federal funds managed, these districts pose a potentially higher risk for noncompliance. Generally two day visits.

57. Other LEAs Reviewed We are moving to a process that reviews other Local Education Agencies (LEA)s that receive funds from OSPI as the State Education Agency (SEA) and provide services. This year as part of CPR, we are reviewing: 3 Tribal Compact Schools 2 ESDs 1 Charter School

58. CPR 2015-16 1-Day Sample Agenda 8:30-9:30 a.m.Entrance Meeting: Introductions and Overview of CPR Process Discussion about Program Practices with OSPI and District Staff 9:30-11:30 a.m.Discussion with District Program Staff Building visits 11:30-12:30 p.m.Lunch 12:30-3:00 p.m.Continuation of Building Visits Continuation of Discussion with District Program Staff 3:00-4:00 p.m.CPR Team Preliminary Report Preparation (OSPI team will be at the district office to prepare for the exit interview) 4:00-4:30 p.m.Exit Meeting and Closing Observations

59. Day 1CPR team members continue with review and end day around 4:00-4:30pm Day 2 8:30-3:00 p.m. Continuation of Building Visits Continuation of Discussion with District Program Staff 3:00-4:00 p.m.CPR Team Preliminary Report Preparation (OSPI team will be at the district office to prepare for the exit interview) 4:00-4:30 p.m.Exit Meeting and Closing Observations CPR 2015-16 2-Day Sample Agenda

60. Digital Checklist OSPI will use Program Monitor, a web application in the Education Data System (EDS), for the management of review content and as a replacement of the paper checklists used in the past. Districts upload all documentation for review to the online Program Monitor tool beginning 12 weeks (and no later than 6 weeks) prior to the review start date. We do not accept emails or paper copies of documentation. Access Program Monitor here: https://eds.ospi.k12.wa.us/ProgramMonitor/https://eds.ospi.k12.wa.us/ProgramMonitor/

61. CONSOLIDATED PROGRAM REVIEW (CPR)

62. Uploading and Formatting

63. CPR - Follow ‐ Up Process

64. CONSOLIDATED PROGRAM REVIEW (CPR) CPR TEAM LEAD CONTACT INFORMATION Anne Renschler, Program Supervisor Consolidated Program Review Anne.Renschler@k12.wa.us 360-725-6229 Sylvia Reyna, Program Supervisor Migrant Education Sylvia.Reyna@k12.wa.us 360-725-6147 Timothy McNeely, Program Supervisor Consolidated Program Review and Rural Education Timothy.Mcneely@k12.wa.us 360-725-6234

65. PERKINS 101 TAKE WAYS Learn the timeline Understand the performance indicators Understand fiscal responsibilities Establish a local team; internal and external Seek and participate in technical assistance provided by State staff Organize electronic/paper files Monitor and adjust

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67. 67 Ken Emmil, Assistant Superintendent Career and College Readiness Ken.Emmil@k12.wa.us 360-725-6245 Vacant, Director Career and Technical Education @k12.wa.us 360-725-6245 Marianna Goheen, Program Supervisor Health Sciences Marianna.goheen@k12.wa.us 360-725-6257 Rebecca Wallace, Program Supervisor Agriculture Education Rebecca.wallace@k12.wa.us 360-725-6244 Phouang Hamilton, Program Supervisor Grants and Innovative Programs Phouang.hamilton@k12.wa.us 360-725-6253 Denise Mileson, Program Specialist GRADS Denise.Mileson@k12.wa.us 360-725-0417 Mary Nagel, Program Supervisor Family and Consumer Sciences Mary.nagel@k12.wa.us 360-725-6242 Lance Wrzesinski, Program Supervisor Business and Marketing Lance.wrzesinski@k12.wa.us 360-725-6258 Deifi Stolz, Program Supervisor Methods of Administration Deifi.stolz@k12.wa.us 360-725-6254 Denny Wallace, Program Supervisor Skills and Technical Sciences Dennis.wallace@k12.wa.us 360-725-6241 Mary Kanikeberg, Program Supervisor Jobs for Washington’s Graduates Mary.kanikeberg@k12.wa.us 360-725-6244 Clarence Dancer, Program Supervisor STEM Clarence.dancer@k12.wa.us 360-725-4467 Diane Gard, Executive Assistant | Diane.Gard@k12.wa.usDiane.Gard@k12.wa.us Monica Trabue, Secretary| Monica.Trabue@k12.wa.usMonica.Trabue@k12.wa.us Jill Pilbro, Secretary | Jill.pilbro@k12.wa.usJill.pilbro@k12.wa.us