Report 2012-044 All Recommendation Responses

Report 2012-044: California Department of Education: Despite Some Improvements, Oversight of the Migrant Education Program Remains Inadequate (Release Date: February 2013)

Recommendation #1 To: Education, Department of

To minimize the potential for disagreement over allowable migrant program costs, Education should better define the criteria by which it will consider program costs allowable and include those criteria in the migrant program fiscal handbook it provides to the regions.

Annual Follow-Up Agency Response From October 2015

Education completed the revision of the Migrant Education Program Fiscal Handbook (MEPFH) in June 2015, posted the final MEPFH on the Web, and provided a Web-based presentation to subgrantees (regions and direct-funded districts). The MEPFH includes information on: (1) allowable program costs; (2) clear definitions of administrative costs; (3) direct services and Migrant Education Program (MEP)-unique administrative costs; (4) new citations to align with the updated Uniform Grants Guidance; and (5) the use of funds for, but not limited to, administrative salaries, procurement, meetings, food, travel, conferences, field trips, capital outlay, and property.

In Fiscal Year 2015-16, Education plans to execute a series of three to five in-depth Webinars to fully explain each section of the MEPFH.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2014

To minimize the potential for disagreement over allowable migrant program costs, Education is developing a Migrant Education Fiscal Handbook (MEPFH). In June 2014, Education convened a stakeholder group comprised of county and district fiscal staff, as well as Migrant Education Program regional directors, to review the draft of the MEPFH. The MEPFH will include: 1) an updated list of accounting codes; (2) criteria for allowable program costs; and (3) general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH will also address capital outlay and property, including criteria for capital purchases such as vehicles and other equipment. Education plans to complete the final MEPFH by December 2014.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Education is in the final stages of updating the Migrant Education Program Fiscal Handbook (MEPFH). The revised MEPFH includes criteria for allowable program costs and general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment. Education plans to obtain input on the MEPFH from county and district fiscal staff, as well as Migrant Education Program (MEP) regional directors, in the spring of 2014.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

Criteria for allowable program costs have been improved. Education and the Migrant Education Intervention Team developed guidance with criteria defining allowable types of expenditures. This guidance will be presented to the regional directors for implementation during fiscal year 2013-14. This guidance will also be incorporated into the migrant grant award notification letters and the upcoming revised Migrant Education Fiscal Handbook (see Enclosure A, draft of Fiscal Handbook Ch. 7: Allowed Uses).

In addition, Education is currently updating the District Service Agreements (DSAs) and the Regional Applications (RAs) for FY 2013-14. The updates include guidance regarding specific policies and criteria on services and processes for supplement and supplant. Education is following the Migrant Education Program (MEP) Guidance from the U. S. Department of Education's Office of Migrant Education (OME) (Chapter V, A7) in the review and evaluation of DSAs and RAs to ensure that state educational agencies use a wide variety of service delivery designs, including extended day programs, before/after school programs, in-class program (with prior Education approval), Saturday programs, in-home instruction (with prior Education approval), summer/intersession programs, and distance learning programs.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Education and the Migrant Education Intervention Team are working collaboratively with the migrant regions to identify the specific expenditure classifications that may need enhanced approval criteria. As an example, in the current District Service Agreement and the Regional Application for fiscal year 2013-14, guidance regarding specific policy and criteria on supplemental services and processes for supplement and supplant has been updated to align with federal guidance. Education will incorporate the updated guidance in the upcoming revised Migrant Education Fiscal Handbook.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

Recommendation #2 To: Education, Department of

To demonstrate its willingness to fairly evaluate regional expenditures, Education should allow San Joaquin to reimburse its general fund for the vehicle purchase Education incorrectly disallowed.

Annual Follow-Up Agency Response From November 2017

Education continues to not concur with this recommendation and no further updates will be provided.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

Annual Follow-Up Agency Response From November 2016

Education will not implement this recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

Annual Follow-Up Agency Response From October 2015

Education does not concur with this recommendation. Education conducted an independent and unbiased review of San Joaquin's migrant expenditures with the

objective of determining whether costs charged to the migrant program were reasonable, necessary, and properly supported in accordance with federal requirements. Based on the documentation provided by San Joaquin, Education disallowed a portion of the vehicle due to incomplete or absent information contained in the mileage logs. However, as previously stated, Education did allow mileage for those trips on the logs that clearly documented that the trips were specific to the migrant program.

California State Auditor's Assessment of Annual Follow-Up Status: Will Not Implement

1-Year Agency Response

Education does not concur with this recommendation. Education conducted an independent and unbiased review of San Joaquins migrant expenditures with the objective of determining whether costs charged to the migrant program are reasonable, necessary, and properly supported in accordance with federal requirements. Based on the documentation provided by San Joaquin, Education disallowed a significant portion of the vehicle due to incomplete, or lack of, information contained in the mileage logs. However, as previously stated, Education did allow mileage for those trips on the logs that clearly documented that the trips were specific to the migrant program.

As stated in Educations status update for Recommendation No. 1, the revised MEPFH requires effective internal control and accountability over travel and capital purchases, including the documentation for vehicle usage and maintaining adequate mileage logs.

California State Auditor's Assessment of 1-Year Status: Will Not Implement

6-Month Agency Response

As stated in Education's previous response, Education does not concur with this recommendation. Education did allow a portion of the vehicle to be charged to the migrant program. However, based on the documentation provided by San Joaquin, Education disallowed the portion of costs that was not substantiated as being used solely for migrant program purposes.

California State Auditor's Assessment of 6-Month Status: Will Not Implement

60-Day Agency Response

Education does not concur with this recommendation. Based on the documentation provided by San Joaquin, the vehicle was not substantiated as being used solely for migrant program purposes. However, as previously stated, Education did allow a portion of the vehicle to be charged to the migrant program.

California State Auditor's Assessment of 60-Day Status: Will Not Implement

As we note on page 15 of the audit report, we reviewed San Joaquin's documentation and found that it provided reasonable assurance that the vehicle in question was used for the migrant program. As we note on page 75 of the audit report, Education's statement that it allowed a portion of the vehicle's mileage is lacking some crucial details. Education's auditors determined that 0.42 percent of the total miles in the logs were allowed. As a result, Education allowed just $148.88 of the total vehicle purchase price. We found no support for this calculation in the federal program monitoring review documents or in the logs themselves. We asked Education's auditors about this percentage and received no answer.

Recommendation #3 To: Education, Department of

To improve its understanding of regional expenditures, Education should increase the level of detail required in its quarterly expenditure reports. The level of detail should allow Education to select expenditures for review.

Annual Follow-Up Agency Response From November 2016

Fully Implemented. As reported in Education's one-year response dated

March 24, 2014, and the annual response dated October 7, 2015, the quarterly expenditure reports have been redesigned to reflect the more detailed grant application (also referred to as the Regional Application and District Service Agreement) budget formats. In 2015-16, for those regions not evaluated via a Federal Program Monitoring Review, Education updated its internal quarterly expenditure report checklist (Attachment 1) to include item No. 17, which requires subgrantees (also referred to as regions and direct funded districts) to

submit additional supporting documentation. For example, the supporting documentation requested includes copies of local budgeted expenditure reports to support expenses reported under object code 4300 (materials and supplies), object code 5800 (contracts with outside vendors), and any other object code Education deems necessary as part of the expenditure review process.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

We verified that Education's new quarterly expenditure review form directs analysts to request supporting documentation for the object codes for which Education believes most questionable costs are likely to be found. We reviewed examples of Education analysts requesting supporting documentation and an example of Education disallowing a particular expenditure based on this review. As a result of this review, we agree that this recommendation has been fully implemented.

Annual Follow-Up Agency Response From October 2015

Education considers this recommendation fully implemented. As reported in Education's one-year response dated March 24, 2014, the quarterly expenditure reports have been redesigned to reflect the more detailed Regional Application (RA) and District Service Agreement (DSA) budget formats. The expenditure reports provide detailed region expenditures by object and resource codes that align with the approved budget expenditures in the RA. The increased level of detail is utilized by Education to evaluate expenditures for adherence to federal administrative cost principles.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Education's expenditure forms do not include a level of detail that would allow Education to select expenditures for review, which was a key element to this recommendation. Because of this, we assess this recommendation as pending implementation.

Annual Follow-Up Agency Response From October 2014

Education considers this recommendation fully implemented. As reported in Education's one-year response dated March 24, 2014, the quarterly expenditure reports have been redesigned to reflect the new, more detailed, Regional Application (RA) and District Service Agreement (DSA) budget formats. The expenditure reports provide detailed region expenditures by object and resource codes to align with the approved budget expenditures in the RA. The increased level of detail will be utilized by Education to evaluate expenditures for adherence to federal administrative cost principles.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

Although Education provided us with its revised expenditure forms, those forms do not include a level of detail that would allow Education to select expenditures for review. Because this was a key element to this recommendation, the recommendation is still pending implementation.

1-Year Agency Response

The quarterly expenditure reports have been redesigned to reflect the new, more detailed, Regional Application (RA) and District Service Agreement (DSA) budget formats. The expenditure reports provide detailed region expenditures by object and resource codes to align with the approved budget expenditures in the RA. The increased level of detail will be utilized by Education to evaluate expenditures for adherence to federal administrative cost principles.

California State Auditor's Assessment of 1-Year Status: Pending

Although Education provided us with its revised expenditure forms, those forms do not include a level of detail that would allow Education to select expenditures for review. Because this was a key element to this recommendation, the recommendation is still pending implementation.

6-Month Agency Response

The quarterly expenditure reports are being redesigned to reflect the new more detailed RA and DSA budget formats. The alignment of expenditure reports to the new applications will allow Education to compare expenditures to the approved services and budget. In addition, the increased level of detail will allow Education to more readily evaluate expenditures for adherence to Office of Management and Budget (OMB) Circular A-87 Cost Principles. Education plans to have the revised expenditure reports ready for field use in 2013-14. Guidance on completing the revised expenditure reports will be incorporated into the revised Migrant Education Fiscal Handbook.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The U.S. Department of Education revised the budget portions of the District Service Agreement and the Regional Application for fiscal year 2013-14 to clarify the types of expenditures as they relate directly to programs. In addition, as described in the response to recommendation number four, Education is also making other reporting revisions to allow a more effective selection of expenditures for review.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #4 To: Education, Department of

For regions that have not recently received a federal monitoring review, Education should use the detailed expenditure reports to select a sample of expenditures, request supporting documentation from the regions, and then review the expenditures to determine if they meet applicable federal and state criteria.

Annual Follow-Up Agency Response From November 2016

Fully implemented. Education utilizes a detailed checklist for reviewing each subgrantee's expenditure report. The checklist includes: (1) reviewing reported expenditures; (2) identifying abnormalities such as unapproved items, over budgeted items, and offsetting credits; and (3) requiring LEAs to provide a budgeted expenditure report for object code 4300 (materials and supplies), object code 5800 (contracts with outside vendors), and any other object code Education deems necessary as part of the expenditure review process. Education utilizes this detailed information to evaluate expenditures for adherence to federal administrative cost principles. In addition, a Webinar was conducted for all subgrantees to alert and reinforce the new requirement to include budgeted expenditure reports.

Attachments 2, 3, 4, and 5 illustrate an example of Education's detailed expenditure review process, across four quarters in 2015-16, for one subgrantee.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Education's internal guidance indicates that the department is targeting regions that have not had a recent federal monitoring review. Education's requests support for expenditures in key object codes and reviews them to see if they are allowable. We reviewed an example of Education disallowing an expenditure as a result of this process.

Annual Follow-Up Agency Response From October 2015

In 2014-15, Education developed a detailed checklist for reviewing each subgrantee's expenditure report. This checklist includes: (1) reviewing reported expenditures; and (2) identifying abnormalities such as unapproved items, over-budgeted items, and offsetting credits.

For 2015-16, Education will add an item to the checklist for regions that have not recently received a federal monitoring review. For these regions, Education will select a sample of expenditures and request supporting documentation to

ensure the expenditures are aligned with the approved budget, and meet applicable federal and state criteria.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

As it acknowledges in its response, Education has not yet implemented a review of a sample of expenditures at regions that have not recently received a federal monitoring review. Therefore, this recommendation is pending implementation.

Annual Follow-Up Agency Response From October 2014

Education is currently developing a multi-year plan to monitor the expenditures of regions not selected for federal monitoring review. This monitoring plan will be included in the revised MEPFH that will be finalized in December 2014. Monitoring of expenditure reports will include: (1) selecting a sample of expenditures; (2) requesting supporting documentation from the regions; and (3) reviewing expenditures to determine compliance with applicable federal and state criteria. In addition, Education's detailed reviewer checklist ensures that all appropriate signatures and approvals are obtained prior to release of program funds.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Education standardized procedures for reviewing Migrant Regions expenditure reports. These procedures include, when necessary, selecting a sample of expenditures, requesting supporting documentation from the regions, and reviewing the expenditures to determine compliance with applicable federal and state criteria. A detailed reviewer checklist ensures that all appropriate Education signatures and approvals are obtained prior to release of program funds.

California State Auditor's Assessment of 1-Year Status: Pending

Although Education provided a checklist used by its fiscal staff to review regular budget reports from its migrant program regions, the checklist does not direct staff to consider how long it has been since a region received a federal monitoring review. Further, as noted in recommendation three, the expenditure reports that regions submit would not allow Education to select expenditures for review.

6-Month Agency Response

The increased level of detail of the redesigned expenditure reports will allow Education to more readily evaluate expenditures for adherence to OMB Circular A-87 Cost Principles. For FY 2013-14, Education will provide technical assistance to the regions over the new and revised expenditure reports, and follow up to ensure regions are completing the reports correctly. In addition, Education's administrators will provide guidance and oversight to Education staff responsible for the review and monitoring of the expenditure reports and will conduct random checks of reports, both internal and external, to ensure consistency.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

To determine if regions are meeting applicable federal and state criteria, Education created a new District Service Agreement and the Regional Application (RA) that includes specific guidance and direction. The revised applications require more specific details from regions on their proposed services as they relate to specific budget line items. Education is also revising the current expenditure report to align with the new budget template that is part of the RA which results in a more detailed review of expenditures necessary to fund the Migrant Education Program (MEP) regionally. The revised expenditure reports will also provide clearer expenditure breakdowns to more accurately determine specific administrative costs (e.g., administrative salaries, support staff, materials), direct services (e.g., instructional program, pre-school services) and state required activities (e.g. identification and recruitment).

In addition to the Federal Program Monitoring reviews, Education is developing a MEP expenditure review process in which regions will be selected on a rotating basis to ensure applicable federal and state criteria are being met. Education plans to review 25 percent of the regions each fiscal year using the revised expenditure reports. Education will then select a sample of expenditures reported by these regions and request the necessary documentation to substantiate the costs. As part of these reviews, Education will provide ongoing technical assistance in addition to other specific technical assistance meetings.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #5 To: Education, Department of

As part of the reviews based on quarterly reports, Education should verify that regions are using the appropriate accounting codes to classify their expenditures.

Annual Follow-Up Agency Response From November 2016

Fully implemented. To verify that subgrantees are correctly classifying expenditures according to accounting codes, Education redesigned the quarterly expenditure reports to align with the more detailed grant application budget formats, including object and resource codes. In addition, the Migrant Education

Program (MEP) Fiscal Handbook (Appendix A: Object Classification Codes) requires subgrantees to follow definitions, instructions and procedures in the California School Accounting Manual (CSAM), as well as to select the appropriate object classification codes and check for updates to the handbook.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Education approves regional budgets that establish the accounting codes that regions use to charge expenditures. Education conducts quarterly reviews to determine whether regions have remained on budget under each account code. Education has directed its staff to review any cases where a region's expenditures exceed the budgeted amount in any accounting code by greater than $3,500. Performing these reviews helps Education identify any expenditures that were charged to an incorrect accounting code.

Annual Follow-Up Agency Response From October 2015

Education considers this recommendation fully implemented. As reported in Education's one-year response dated March 24, 2014, the quarterly expenditure reports have been redesigned to reflect the more detailed RA and DSA budget formats. The expenditure reports provide detailed region expenditures by object and resource codes that align with the approved budget expenditures in the RA. The increased level of detail is utilized by Education to verify that regions are using the appropriate accounting codes to classify expenditures.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

As indicated under recommendation number three, Education has not yet developed expenditure reports that would allow it to identify individual expenditures. As such, we do not agree that its expenditure forms would allow it to ensure that regions are using the appropriate accounting codes to classify expenditures.

Annual Follow-Up Agency Response From October 2014

Education considers this recommendation fully implemented. As reported in Education's one-year response dated March 24, 2014, The quarterly expenditure reports have been redesigned to reflect the new, more detailed, RA and DSA budget formats. The expenditure reports provide detailed region expenditures by object and resource codes to align with the approved budget expenditures in the RA. The increased level of detail will be utilized by Education to verify that regions are using the appropriate accounting codes to classify expenditures.

California State Auditor's Assessment of Annual Follow-Up Status: Pending

As noted in recommendation three, the expenditure reports that Education asks regions to complete do not include an expenditure level of detail. Without this level of detail, Education cannot determine if a region is appropriately using certain accounting codes with certain types of expenditures.

1-Year Agency Response

The quarterly expenditure reports have been redesigned to reflect the new, more detailed, RA and DSA budget formats. The expenditure reports provide detailed region expenditures by object and resource codes to align with the approved budget expenditures in the RA. The increased level of detail will be utilized by Education to verify that regions are using the appropriate accounting codes to classify expenditures.

California State Auditor's Assessment of 1-Year Status: Pending

As noted in recommendation three, the expenditure reports that Education asks regions to complete do not include an expenditure level of detail. Without this level of detail, Education cannot determine if a region is appropriately using certain accounting codes with certain types of expenditures.

6-Month Agency Response

Education will ensure that reviews of quarterly reports include verification that regions are using the appropriate accounting codes by revising the current regional expenditure report format and implementing the activities outlined in status update to Recommendations No. 3 and 4.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Education is revising the current budget expenditure report to align with the changes that the U.S Department of Education made to the RA for 2013-14. In addition, Education is developing a MEP expenditure review process in which regions will be selected on a rotating basis to ensure that applicable federal and state criteria are being met. As part of these reviews, Education will provide ongoing technical assistance in addition to other specific technical assistance meetings.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #6 To: San Joaquin County Office of Education

To guard against future conflicts of interest, San Joaquin should complete its evaluation and revision of its procurement policies and procedures, update its conflict-of-interest code, and ensure that all its managers receive conflict-of-interest training.

6-Month Agency Response

This letter is a follow-up to our letter of April 23, 2013, and is our six month report. As requested in your letter we received on March 1, 2013, we are responding within six months and one year on our efforts to implement recommendations that are within our statutory authority.

I. Evaluation and revision of procurement policies and procedures

Person Responsible: Jim Thomas, Deputy Superintendent of Business Services

As noted in our letter of April 23, SJCOE has revised its procurement procedures and policies to align with all applicable government codes and regulations that pertain to County Offices of Education.

The attached policy has been revised and approved by the Superintendent and will be implemented beginning September 1, 2013. (See Attachment A)

Proposed Timeline for Completion and Implementation: September 1, 2013

II. Update the Conflict-of-Interest Code

Person Responsible: Janai Stanton, Administrative Services Coordinator

As noted in our letter of April 23, SJCOE has updated and amended its conflict-of-interest code and it was approved at the San Joaquin County Board of Education's public meeting on April 17, 2013. Subsequently, the conflict-of-interest code was approved by the San Joaquin County Board of Supervisors at their June 18, 2013 meeting.

The final, approved minutes of the April 17, 2013 SJC Board of Education meeting are attached. (See Attachment B)

The agenda and final, approved minutes of the June 18, 2013 SJC Board of Supervisors meeting are attached. (See Attachments C and D)

III. Ensure that all managers receive conflict-of-interest training.

Person Responsible: Janai Stanton, Administrative Services Coordinator

All workshops and activities indicated on the timeline submitted as Attachment D with our April 23 letter have been completed.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

Beginning in March 2013, San Joaquin County Office of Education (SJCOE) requires that all custodial contracts must have three quotes from three independent vendors prior to selecting a vendor. These quotes are thoroughly reviewed by the Operations Department including adherence to its specifications and cost-effectiveness.

SJCOE's Operations Department is conducting a review of all existing custodial contracts to determine whether any costs appear to be excessive. If so, SJCOE will obtain quotes on those contracts and terminate the existing contracts if SJCOE can achieve significant savings.

SJCOE has requested a legal opinion as to the requirements of codes and regulations governing county offices of education regarding procurement policies and procedures. Upon receipt of this information, SJCOE will ensure that its procurement procedures and policies align with all applicable government codes and regulations.

SJCOE has updated and amended its conflict-of-interest code and the code was approved at the San Joaquin County Board of Education's public meeting on April 17, 2013.

Three conflict of interest training workshops have been scheduled for management staff in April and May of 2013. SJCOE will schedule and conduct annual conflict-of-interest training workshops for management staff in subsequent years.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

Recommendation #7 To: Education, Department of

Education should follow up with San Joaquin to ensure that it takes the actions we recommend.

6-Month Agency Response

Education received a letter dated July 24, 2013, from the Superintendent of the San Joaquin County Office of Education confirming the county's compliance with this recommendation. Conflict of interest training was held for a total of three hours on April 25, May 2, and May 16, 2013 (see Enclosure B).

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

Education expects the San Joaquin County Superintendent of Education to submit evidence of compliance to the BSA's recommendations by June 1, 2013.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #8 To: Education, Department of

To address problems with its methodology for calculating administrative costs, Education should review the regions' current use of accounting codes to identify the areas in which regions differ in accounting for similar migrant program costs.

Annual Follow-Up Agency Response From October 2015

In 2013-14, Education revised its expenditure reporting forms to align with the revised budget forms and to standardize the use of accounting codes. The revised expenditure report form utilizes object classification codes instead of function codes. The revised MEPFH includes a section on object classification codes. This section of the MEPFH states that California Education Code, Section 41010, requires local educational agencies to follow the definitions, instructions, and procedures in the California School Accounting Manual (CSAM). Operating agencies and districts are mandated to follow CSAM guidelines for conformity with generally accepted accounting principles (GAAP), which are essential for consistency and comparability in financial reporting. The CSAM is to be used for classifying, developing, and recording all MEP revenues and expenditures.

California State Auditor's Assessment of Annual Follow-Up Status: Resolved

Since our final audit report, Education has changed how it calculates administrative costs. Education's new method, which identifies administrative and services costs through the annual application for migrant program funding, addresses the concerns we had about Education's former practice of retroactively calculating administrative costs based on the accounting codes that its migrant program regions used. Because regions sometimes differed in their use of accounting codes, Education's previous methodology had classified some service costs as administrative and vice versa. Under its new methodology, Education reviews how regions are accounting for service and administrative costs as part of its approval of each region's application for funding. This provides clarity about what expenditures will be considered administrative and, provided that Education is uniform in its review of all regional applications, should ensure that it calculates service and administrative costs more accurately across regions.

Annual Follow-Up Agency Response From October 2014

As reported in Education's response update to CSA Recommendation No. 1, to facilitate consistency and more guidance to regions, the revised MEPFH will include: 1) an updated list of accounting codes; (2) criteria for allowable program costs; and (3) general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment. Education plans to complete the final MEPFH by December 2014.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Education is in the final stages of revising the MEPFH. To facilitate consistency and more guidance to regions, the revised MEPFH includes an updated list of accounting codes and criteria for allowable program costs and general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

Education established a Migrant Education Office (MEO) "fiscal team" of individuals to provide feedback and expertise throughout the process of revising the Migrant Education Fiscal Handbook (see status update to Recommendation No. 1). The fiscal team is working to ensure accounting code consistency and the incorporation of new allocation codes; guidance will be provided to regions as explained in status updates to Recommendations No. 3 and 4.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The U.S. Department of Education revised the budget portions of the DSA and RA for 2013-14 to clarify the types of expenditures as they relate directly to programs. In addition, as described in the response to recommendation number four, Education is also making other reporting revisions to allow a more effective selection of expenditures for review.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #9 To: Education, Department of

To address problems with its methodology for calculating administrative costs, Education should provide regions with more specific direction about how to charge these expenses.

Annual Follow-Up Agency Response From October 2015

Education completed the revision of the Migrant Education Program Fiscal Handbook (MEPFH) in June 2015, posted the final MEPFH on the Web, and provided a Web-based presentation to subgrantees (regions and direct-funded districts). The MEPFH includes information on: (1) allowable program costs; (2) clear definitions of administrative costs; (3) direct services and Migrant Education Program (MEP)-unique administrative costs; (4) new citations to align with the updated Uniform Grants Guidance; and (5) the use of funds for, but not limited to, administrative salaries, procurement, meetings, food, travel, conferences, field trips, capital outlay, and property.

In Fiscal Year 2015-16, Education plans to execute a series of three to five in-depth Webinars to fully explain each section of the MEPFH.

California State Auditor's Assessment of Annual Follow-Up Status: Resolved

As noted under recommendation number eight, Education no longer relies directly on accounting codes to calculate administrative costs, but instead uses its regional application process to define the service and administrative costs at each region. Therefore, we believe Education has addressed the issue that underlay this recommendation to provide more specific direction regarding which accounting codes regions should use to charge administrative expenditures.

Annual Follow-Up Agency Response From October 2014

As reported in Education's response update to CSA Recommendation No. 1, to facilitate consistency and more guidance to regions, the revised MEPFH will include: 1) an updated list of accounting codes; (2) criteria for allowable program costs; and (3) general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment. Education plans to complete the final MEPFH by December 2014.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Education is in the final stages of revising the MEPFH. To facilitate consistency and more guidance to regions, the revised MEPFH includes an updated list of accounting codes and criteria for allowable program costs and general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

Education established a Migrant Education Office (MEO) "fiscal team" of individuals to provide feedback and expertise throughout the process of revising the Migrant Education Fiscal Handbook (see status update to Recommendation No. 1). The fiscal team is working to ensure accounting code consistency and the incorporation of new allocation codes; guidance will be provided to regions as explained in status updates to Recommendations No. 3 and 4.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The U.S. Department of Education revised the budget portions of the DSA and RA for 2013-14 to clarify the types of expenditures as they relate directly to programs. In addition, as described in the response to recommendation number four, Education is also making other reporting revisions to allow a more effective selection of expenditures for review.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #10 To: Education, Department of

To address problems with its methodology for calculating administrative costs, Education should revise its list of accounting codes that it considers administrative in light of its review of regional coding.

Annual Follow-Up Agency Response From October 2015

The MEPFH contains a revised definition of administrative expenditures and guidance on how to annotate administrative positions in the expenditure reports.

California State Auditor's Assessment of Annual Follow-Up Status: Resolved

As noted under recommendation eight, Education's method for calculating administrative costs no longer relies directly on a region's use of a particular accounting code. Education has provided guidance in its migrant education program fiscal handbook about what costs should be considered administrative. Therefore, although it appears Education did not conduct a review of the regional coding of administrative costs, we consider this recommendation resolved.

Annual Follow-Up Agency Response From October 2014

As reported in Education's response update to CSA Recommendation No. 1, to facilitate consistency and more guidance to regions, the revised MEPFH will include: 1) an updated list of accounting codes; (2) criteria for allowable program costs; and (3) general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment. Education plans to complete the final MEPFH by December 2014.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Education is in the final stages of revising the MEPFH. To facilitate consistency and more guidance to regions, the revised MEPFH includes an updated list of accounting codes and criteria for allowable program costs and general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

Education established a Migrant Education Office (MEO) "fiscal team" of individuals to provide feedback and expertise throughout the process of revising the Migrant Education Fiscal Handbook (see status update to Recommendation No. 1). The fiscal team is working to ensure accounting code consistency and the incorporation of new allocation codes; guidance will be provided to regions as explained in status updates to Recommendations No. 3 and 4.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The U.S. Department of Education revised the budget portions of the DSA and RA for 2013-14 to clarify the types of expenditures as they relate directly to programs. In addition, as described in the response to recommendation number four, Education is also making other reporting revisions to allow a more effective selection of expenditures for review.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #11 To: Education, Department of

Once it has addressed the underlying issues with regional accounting, provided direction to regions about which expenditures it will consider administrative, and obtained accurate expenditure data, Education should review its administrative cost goal to ensure that this goal is reasonable given the requirements of the migrant program.

Annual Follow-Up Agency Response From November 2016

Fully implemented. To provide subgrantees with additional expenditure data guidance, Education: (1) clarified the method to account for MEP administrative expenditures through the 2013-14 redesign of the grant application, budget and expenditure forms; and (2) identified an administrative limit of 15 percent, as set forth by Education Code (EC) Section 63001 (which requires educational agencies to spend no less than 85 percent of funds received from specific categorical programs on direct services).

In addition, after reviewing two years of expenditure data, Education revised administrative cost goals for each subgrantee and provided guidance in the updated MEP Fiscal Handbook, which was re-posted in June 2015. The MEP Fiscal Handbook recognizes administrative expenditures that are unique to the MEP, such as the identification and recruitment of migrant families, the convening of parent advisory councils, and the coordination of health related services.

On October 5, 2016, the State Controller's Office (SCO) issued its audit report on Education's MEP oversight efforts. The SCO reported that Education restored its administrative oversight efforts and implemented several improvements including: (1) redesigning accounting forms; (2) building a competent program-oversight workforce; (3) organizing Webinar trainings; (4) updating policies and procedures; (5) revising the MEP FiscaI Handbook; (6) performing a comprehensive analysis and updated the contents of the annual funding application and quarterly expenditure reports; and (7) fostering a collaborative relationship with the subgrantees (see Attachment 7). Education continues to interact with subgrantees to improve oversight efforts.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

In our assessment of Education's October 2015 response to this recommendation, we did not agree that Education had fully implemented this recommendation because the administrative cost goals it had developed for its migrant program regions were based on expenditure decisions the regions had made before Education had issued new guidance on administrative costs in its MEP Fiscal Handbook. Since that time, Education has continued to refine its administrative cost goals in light of expenditures the regions made since receiving the updated guidance. As it has revised administrative cost goals for each region, Education has attempted to account for unique features of the migrant education program and differences between regional structures (i.e, directly funded school districts versus regional offices that oversee the migrant education program multiple school districts).

Annual Follow-Up Agency Response From October 2015

In 2013-14, Education collected detailed administrative expenditure data to: (1) calculate the percentage of funds dedicated to administrative services; (2) analyze the major program-specific requirements for administration; (3) identify MEP unique administrative functions, which are documented in the MEPFH (MEP-unique administrative functions are specifically exempted from the calculation of the administrative formula to ensure that subgrantees do not reduce administrative expenditures in areas that are required for program implementation.) Education also utilized the expenditure data analysis to revise administrative cost goals. Education will continue to seek administrative cost goals of 15 percent for districts, but will consider slightly higher cost goals for county offices of education.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Education provided evidence that it has reviewed regional administrative costs as it states in its response. However, Education's migrant education program fiscal handbook, which contains guidance related to which expenditures Education considers administrative, was adopted in June 2015. Therefore, although Education claims to have used fiscal year 2013-14 expenditure data to revise its administrative cost goal, this expenditure data was not reflective how regions may account for their expenditures now that they have received additional guidance. Therefore, we assess this recommendation as partially implemented until Education has reviewed its administrative cost goals in light of a full fiscal year's worth of expenditure information under the new direction included in its handbook.

Annual Follow-Up Agency Response From October 2014

To address the underlying issues with regional accounting for expenditures, in addition to the new MEPFH, Education is developing administrative cost guidance to the regions. This guidance will consider factors such as: (1) 2013-14 fiscal year expenditure report data; (2) local educational agency indirect cost rates; (3) individual regional administrative constraints; and (4) guidance from the federal Office of Migrant Education (OME).

To ensure the majority of MEP funding is utilized for direct MEP services and activities, Education has established a "15 percent or below" administrative cost percentage as a reasonable goal. Administrative cost percentages can be calculated from the regional Summary Budget Worksheets by dividing the total administrative cost by the total budget amount. If a region is found to have incurred excessive administrative costs, Education requires the region to submit an "Action Plan to Reduce General Administrative Costs" delineating specific actions to reduce administrative costs down to 15 percent or less over the following two fiscal years.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Education conducted two WEBEX trainings on completing new budget forms, ME-1, on April 3, 2013, and on May 21, 2013. The ME-1 worksheet includes three coding cost columns (service, administrative, and total), and does not allow any administrative coded costs to be entered in the service column. The definitions of administrative costs are included in the revised MEPFH:

General Administrative Costs: Personnel that have job descriptions stating that all job functions are strictly administrative such as program directors, secretaries, and coordinators.

MEP- Unique Administrative Costs: Personnel involved in Identification and Recruitment activities, and support personnel with job descriptions stating that they provide direct services to parents; or are in health related activities such as health clerks, para-professionals, and migrant resource specialists.

Other: Personnel and activities where the administrative definition is unclear such as nurses, and teachers on special assignment, will be reviewed by Education on a case-by-case basis.

To ensure the majority of MEP funding is utilized for direct MEP services and activities, Education has established a 15 percent or below administrative cost percentage as a reasonable goal. Administrative cost percentages can be calculated from the regional Summary Budget Worksheets by dividing the total administrative cost by the total budget amount. If a region is found to have incurred excessive administrative costs, Education requires the region to submit an Action Plan to Reduce General Administrative Costs delineating specific actions to reduce administrative costs down to 15 percent or less over the following two fiscal years.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

Education has provided training to the regional staff regarding the use of revised expenditure forms, but as it notes in its response to recommendation eight, it has not yet finalized its Migrant Program Fiscal Handbook. Until this guidance is finalized and Education has an opportunity to review expenditure data that incorporates that guidance, Education is early in its conclusion that a 15 percent administrative cost goal is reasonable.

6-Month Agency Response

Education will address this recommendation at the end of FY 2013-14 once the activities in status updates to recommendations 1, 3, 4 and 7 have been implemented and aligned as stated.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

In order to determine if regions are meeting applicable federal and state criteria, Education created a new DSA and RA that includes specific guidance and direction. The revised applications require more specific details from regions on their proposed services as they relate to specific budget line items. Education is also revising the current expenditure report to align with the new budget template that is part of the RA which results in a more detailed review of expenditures necessary to fund the Migrant Education Program (MEP) regionally. The revised expenditure reports will also provide clearer expenditure breakdowns to more accurately determine specific administrative costs (e.g., administrative salaries, support staff, materials), direct services (e.g., instructional program, pre-school services) and state required activities (e.g. identification and recruitment).

In addition to the Federal Program Monitoring reviews, Education is developing a MEP expenditure review process in which regions will be selected on a rotating basis to ensure applicable federal and state criteria are being met. Education plans to review 25 percent of the regions each fiscal year using the revised expenditure reports. Education will then select a sample of expenditures reported by these regions and request the necessary documentation to substantiate the costs. As part of these reviews, Education will provide ongoing technical assistance in addition to other specific technical assistance meetings.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #12 To: Education, Department of

To address past federal findings that are not yet resolved, Education should respond as recommended in Appendix B of this report.

Annual Follow-Up Agency Response From November 2016

Fully implemented. Education worked directly with the U.S. Department of Migrant Education to resolve past audit findings. As a result, for 2016-17, there were no conditions identified on the MEP grant award (see Attachment 6). Education also contracted with the SCO to conduct an audit of the MEP. On October 5, 2016, the SCO issued its audit report on Education's MEP oversight efforts. The SCO reported that Education restored its administrative oversight efforts and implemented several improvements including: (1) redesigning accounting forms; (2) building a competent program-oversight workforce;

(3) organizing Webinar trainings; (4) updating policies and procedures;

(5) revising the MEP FiscaI Handbook; (6) performing a comprehensive analysis and updated the contents of the annual funding application and quarterly expenditure reports; and (7) fostering a collaborative relationship with the subgrantees (see Attachment 7). Education continues to interact with subgrantees to improve oversight efforts.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

We reviewed the latest grant award notification from the U.S. Department of Migrant Education and found, as Education stated above, that it was free of any special conditions, indicating that all past audit findings have been resolved.

Annual Follow-Up Agency Response From October 2015

Education considers this recommendation fully implemented. Education worked directly with the federal Department of Migrant Education to resolve past audit findings.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

The federal Office of Migrant Education has cleared past audit findings related to migrant program eligibility re-interviews and the data contained in the State's Consolidated State Performance Report and there were no grant conditions related to these items placed on the 2015 migrant program grant award. However, the 2015 grant award continues to have a grant condition related to federal concern about Education's fiscal oversight. Therefore, this recommendation remains partially implemented.

Annual Follow-Up Agency Response From October 2014

Education considers this recommendation fully implemented. Education worked directly with the OME to resolve past audit findings. OME letters indicating the resolution of past audit findings will be sent separately to the CSA.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Although OME has resolved some of the past federal findings, it has continued to note issues with Education's fiscal monitoring of its regional subgrantees and its eligibility reinterview discrepancy rate. These remaining issues are now being addressed through grant conditions on Education's 2014 grant award. Also, as a condition on its 2013 grant award, OME expects that Education will continue to implement corrective action related to Education's required reporting to the federal level about the migrant program in the State's Consolidated State Performance Report.

1-Year Agency Response

Education worked directly with the federal Office of Migrant Education (OME) to resolve past audit findings. In doing so, the OME has expressed appreciation for Educations implementation efforts and honest communication as to the barriers faced in meeting program requirements, as well as Educations willingness to heed direction from the OME in negotiating those barriers.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

Education provided evidence that it continues to work with the federal Office of Migrant Education to resolve some of the federal concerns. However, as of the time of this response, Education had not yet resolved those federal findings.

6-Month Agency Response

Education has taken corrective actions to address past federal findings; Education continues to work with OME on resolving the two conditions regarding Fiscal Reporting of Regions and the Identification and Recruitment processes. In regard to the recommendations contained in Appendix B, a summary of Education's corrective actions taken are as follows:

- On April 19, 2013, Education submitted its response to the Fiscal Report of Regional/District Administrative Cost. In accordance with federal guidelines, all applications and budget plans were carefully reviewed by Education (2012 Grant Condition #2).

- On May 17, 2013, Education submitted its update on the status of efforts to implement its corrective action concerning the State Parent Advisory Council (2012 Grant Condition #1).

- On June 18, 2013, Education submitted to OME its response to the Re-interview Correction Actions (2012 Grant Condition #3).

- On July 31, 2013, Education submitted to OME its responses to further clarify the steps Education has taken to resolve data quality problems as reflected in the State's Consolidated Performance Report (CSPR) (Audit Control Numbers 09-08-910517 and 09-09-010580).

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Education continues to provide responses to the conditions required by the U.S. Department of Education, Office of Migrant Education (OME) as part of the 2012-13 Federal Grant as well as to previous audit findings. Correspondences with supporting documentation were sent to the OME on the following dates: Report on State Parent Advisory Council (Condition 1): February 28, 2013, Report on Fiscal Review of Regional Subgrantees (Condition 2): April 19, 2013 (final response unless further response is requested), Report on Prospective Re-Interview (Condition 3): January 15, 2013, Investigations of Allegations against Regional MEP Staff (Condition 4): In process of being resolved and closed, Audit Finding: Consolidated State Performance Report (CSPR): Letter submitted January 30, 2013; currently following up with the OME and developing a plan and process for continued improvements to the systems of data management and monitoring.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #13 To: Education, Department of

To determine if the statewide migrant education program is effective, Education should finalize its current evaluation of the program and begin developing the capacity to produce a more robust annual evaluation of the program.

Annual Follow-Up Agency Response From November 2017

Fully implemented. A series of stakeholder meetings were held to develop both the statewide comprehensive needs assessment and state service delivery plan (SSDP), completed in June 2017 and October 2017, respectively. The SSDP identifies strategies to: (1) address migratory students' needs; (2) provide measurable program outcomes (MPO), which evaluate the subgrantees' strategy implementation; and (3) set migrant education specific performance targets (PT). At the end of the first year of the plan's implementation in 2018-19, Education will begin to evaluate the SSDP's MPOs and PTs. In addition, subgrantees will receive annual progress reports to support continuous program improvement.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From November 2016

Partially implemented. In December 2015, each of Education's 20 subgrantees completed a local Comprehensive Needs Assessment (CNA). Education is utilizing these findings to develop a meta-analysis to serve as a basis for the statewide CNA. Education anticipates the new statewide CNA and State Service Delivery Plan (SSDP) will be available online in the summer of 2017. Once Education identifies measurable outcomes in the SSDP, the local MEPs will provide an annual update to Education as part of the yearly grant application process. This process will encourage the local MEPs to continuously improve processes and services to students, and ensure that necessary data is collected for the next iteration of the evaluation process in three years.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From October 2015

Education completed the evaluation of the MEP for the first cycle of the Comprehensive Needs Assessment. Education provided each of its grantees grants to contract with independent researchers to conduct Local Needs Assessments. Each subgrantee will be required to submit final reports to Education in December 2015. Education will utilize these reports as the basis for a statewide Comprehensive Needs Assessment, which will serve as the foundation for the development of a new State Service Delivery Plan (SSDP). The SSDP will identify new measurable objectives, which will allow for the production of a more robust annual evaluation of the MEP.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From October 2014

Education completed the evaluation of the migrant program and is in the process of implementing two projects that will lead to a more robust annual evaluation. The first project focuses on regular data exchanges between the Migrant Student Information Network and the California Longitudinal Pupil Achievement Data System (CALPADS). This data exchange will facilitate the acquisition of statewide migrant student assessment data, and ensure that eligible migrant program students are identified in CALPADS.

The second project is the implementation of the first phase of a statewide Comprehensive Needs Assessment. In 2014-15, the migrant regions will conduct local assessments that will identify program needs. These assessments will also allow Education to identify performance targets with measurable objectives. In the forthcoming State Plan for Services, Education will ensure that identified performance targets can be measured and migrant student data is available to conduct the analysis.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

For 2013-14, Education redesigned the RA for regions and districts to complete as part of the grant application process. Education evaluates all submitted RAs; the redesigned RAs provide Education with an increased level of detail for evaluating regions program descriptions and implementation processes. During the initial evaluation, Education identifies informational deficiencies which may entail requesting regions to explain or specify the: (1) alignment of service programs to identified student needs; (2) detail on program descriptions; (3) itemization of service budgets; and (4) reasonableness of administrative cost percentages in relation to the 15-percent goal. Once the informational requests are fulfilled, Education re-evaluates the RAs with the updated information. Education intends to continue this robust program evaluation process and provide any necessary technical assistance to the regions.

California State Auditor's Assessment of 1-Year Status: Pending

It is unclear to us how Education's review of regional applications will ensure it can produce a robust annual evaluation of the statewide migrant program as we recommended.

6-Month Agency Response

Education is in the process of finalizing its current evaluation of the MEP. The collection of quantitative and qualitative data has been completed and is being analyzed; Education anticipates review completion by 2013-14. The data analyses will help Education assess the alignment of regional activities with the MEP State Service Delivery Plan (SSDP) performance measures as provided by Education.

In an effort to produce a more robust evaluation of the MEP, and regions' alignment with Education's performance measures per the SSDP, Education has designed a new Regional Application for regions and districts to complete each school year prior to providing services to migrant students. The new Regional Application incorporates seven critical components of service delivery. These components include: (1) School Readiness; (2) English Language Arts; (3) Mathematics: (4) High School Graduation; (5) Health; (6) Out of School Youth; (7) Parent Involvement. In addition, the new Regional Application requests regions to: (a) evaluate migrant student data; (b) identify student needs; (c) design supplemental programs that address such needs; (d) implement programs; and (e) monitor program performance regularly.

***will e-mail full response

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

The estimated completion date for the evaluation of the statewide delivery of migrant education services is October 31, 2013. This information, together with the new regional applications and district service agreements, and the next statewide Comprehensive Needs Assessment, will inform the development of a more robust annual evaluation.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #14 To: Education, Department of

To address a lack of detailed migrant program service and outcome data, Education should either expand the capabilities of its existing statewide databases or implement additional systems that would allow regions to capture more detailed data about migrant students.

Annual Follow-Up Agency Response From October 2019

Education has completed phase one and two of the augmentation of its data collection system, the Migrant Student Information Network (MSIN). Phase one captured student and family eligibility information and phase two included the module for capturing detailed student program services and generates service reports at the school, district, and regional levels.

The Application Programming Interface (API) build, previously scheduled for deployment in December 2018, was delayed until November 2019. The API will allow Education's Migrant Program the ability to retrieve student data directly from the California Longitudinal Pupil Achievement Data System (CALPADS) and import data from MSIN into CALPADS. The Migrant Program contract developers now have access to the CALPADS API staging environment and are testing data queries. The production environment, which will produce the data requested, is scheduled to be available November 2019. Once the API is in production, the Migrant Program will be able to develop its MSIN system for automatic data transmissions.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Annual Follow-Up Agency Response From October 2018

Education completed phase one and two of the augmentation of its data collection system, the Migrant Student Information Network (MSIN). Phase one captures student and family eligibility information, as required by the federal government, and phase two includes the module for capturing detailed student program services and generating service reports at the school, district, and county levels.

Education is in the final stages of completing the Application Programming Interface (API), which will import current migrant student identification data from MSIN directly into the California Longitudinal Pupil Achievement Data System. The data transfer will provide local district staff the most current migrant student data. The API is scheduled for production deployment in December 2018, and the subsequent automation of the data exchange between the two systems is scheduled for production deployment in March 2019.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Annual Follow-Up Agency Response From November 2017

Fully Implemented. In November 2016, Education completed phase one of the augmentation of its data collection system, the Migrant Student Information Network (MSIN). MSIN captures student and family eligibility information, as required by the federal government. Education also completed phase two, which includes the module for capturing detailed student program services and generating service reports at the school, district, and county levels.

Education is continuing to work with its California Longitudinal Pupil Achievement Data System (CALPADS) to create an application programming interface that will provide local migrant program staff the ability to identify migrant children in CALPADS.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

Education has expanded the capabilities of its Migrant Student Information Network to provide comprehensive information about students and their services in a central database. As it acknowledges in its response, Education is still pursuing changes that will allow local staff the ability to identify migrant students in CALPADS. Accordingly, we assess this recommendation as partially implemented.

Annual Follow-Up Agency Response From November 2016

Education has contracted with WestEd to augment and enhance its current MEP data collection system, the Migrant Student Information Network. The first deployment of the system augmentation has been developed and will be online in November 2016. The first phase of the deployment will include an interface to capture federally required family and student program eligibility information. The second phase, scheduled for spring 2017, will include a system for capturing detailed program service data, as well as the capacity for generating service reports and viewing assessment data, imported from the California Longitudinal Pupil Achievement Data System (CALPADS). Education is also seeking the creation of a user interface to provide local school districts the ability to verify and update MEP data.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From October 2015

Education is conducting a study of viable data system improvement solutions. The results of this study will enable Education to make determinations as to expanding the capabilities of statewide databases or acquiring additional systems that will allow regions to capture more detailed migrant data.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

Annual Follow-Up Agency Response From October 2014

Education plans to conduct a study of viable data improvement solutions. The results of this endeavor will enable Education to make a determination as to expanding the capabilities of statewide databases or acquiring additional systems that will allow regions to capture more detailed migrant student data.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

To improve the availability of program outcome data, in the summer of 2014, Education plans to conduct a gap analysis of data needs and services as well as a study of viable solutions that exist both in and out of state. The results of this endeavor will enable Education to make a viable determination as to expanding the capabilities of statewide databases or acquiring additional systems that could allow regions to capture more detailed migrant student data. In addition, in fiscal year 2014-15, Education will standardize the codes utilized by migrant regions when entering service data into the COEstar database.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

Education established a monthly process for May, August, and September whereby it plans to continue matching Migrant Student Information Network (MSIN) and California Longitudinal Pupil Achievement Data System (CALPADS) data to obtain Statewide Student Identifier (SSID) information. After three months of matching, Education will establish a quarterly schedule to conduct SSID matching with CALPADS. Education is also taking other steps that will lay the foundation for the collection of accurate program service and outcome data. Education will implement a year-long process beginning in FY 2013-14 to standardize the service codes utilized by migrant regions when entering service data into the Certificate of Eligibility (COEstar) database.

During FY 2013-14, Education will also take other steps to ensure that the corrective actions taken to this recommendation are focused on addressing all data needs. The first step will include the hiring of a consultant to conduct a gap analysis of data needs and services as well as a study of viable options/solutions that exist both in-state and out-of-state. The second step will include a review of the consultant's findings and the selection of a course of action regarding a data-collection solution, either newly-designed or existing.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

In assessing MEP data management needs, Education is working collaboratively with the migrant regions in developing a data system to capture more detailed migrant student data. Education is also exploring the enhancement of existing statewide databases to include service and outcome data and expects to develop a course of action during fiscal year 2013-14.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #15 To: Education, Department of

To ensure that it receives satisfactory services and outcomes for the funds spent on statewide contracts for the migrant program, Education should develop and execute a plan to monitor each of its contracts and cancel any it determines do not provide adequate or cost-effective services.

Annual Follow-Up Agency Response From October 2015

Education considers this recommendation fully implemented. Education's Migrant Education Intervention Team (Team) completed reviews of MEP contracts for statewide services and provided recommendations regarding the adequacy and cost-effectiveness of each contract. Based on the work of the Team, Education cancelled contracts that did not demonstrate cost-effectiveness and/or adequate services, and provided contract administration and monitoring training to all staff that oversee contracts.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2014

Education considers this recommendation fully implemented. Education's Migrant Education Intervention Team (Team) completed reviews of MEP contracts for statewide services and provided recommendations regarding the adequacy and cost-effectiveness of each contract. Based on the work of the Team, Education cancelled contracts that did not demonstrate cost-effectiveness and/or adequate services. In addition, Education is providing contract administration and monitoring training to all staff that oversee contracts; all staff are targeted to be trained by December 2014.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

As it acknowledges in its response, Education has not yet provided contract administration and monitoring training to all of the staff that oversee contracts. Therefore, we continue to assess this recommendation as partially implemented.

1-Year Agency Response

Educations Migrant Education Intervention Team (Team) completed its review of nine MEP contracts for statewide services, and provided recommendations regarding the adequacy and cost-effectiveness of each contract. The Team also made recommendations to improve contract management and oversight; training on the improvements is mandatory for all of Educations MEP contract monitors.

California State Auditor's Assessment of 1-Year Status: Partially Implemented

Although Education states that training on contract monitoring improvements is mandatory for all contract monitors, it provided no evidence that this training is mandatory or that any contract monitors attended this type of training.

6-Month Agency Response

The Migrant Education Intervention Team's scope of work includes the monitoring and review of contracts. To date, the Intervention Team has reviewed six of the nine statewide contracts, and all of the contracts related to the operation of the Statewide Parent Advisory Committee (SPAC). On a rolling basis, the Intervention Team provides Education recommendations about contract renewal, monitoring, and development. Upon the recommendation of the Intervention Team, Education put two long-standing contracts out to bid to ensure high quality service and efficient use of funds.

California State Auditor's Assessment of 6-Month Status: Partially Implemented

Education's response describes laudable efforts by its intervention team. Before we would consider this recommendation fully implemented, Education's Migrant Office needs to put processes in place to continue to monitor its contracts after the term of the intervention team has ended.

60-Day Agency Response

The Migrant Education Intervention Team review of contracts is ongoing and expects to be completed in May 2013. Education's Migrant Education Office (MEO) will utilize the review results to improve the contract renewal and monitoring processes. The MEO plans to implement improved contract monitoring procedures in fiscal year 2013-14.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #16 To: Education, Department of

To ensure that the state parent council complies with the requirement that two-thirds of its membership consist of parents of migrant children, Education should accurately and continually update its member directory and inform the regional parent councils regularly about the current composition of the state parent council.

1-Year Agency Response

Education verified State Parent Advisory Council (SPAC) membership eligibility and compliance in December 2013; all identified ineligible members were replaced with new representatives. In addition, Educations new database system includes a warning feature for Certificate of Eligibility (COE) expiration and member ineligibility. Education is also developing a database system to keep the member directory updated and monitor the composition of the state parent council.

California State Auditor's Assessment of 1-Year Status: Fully Implemented

6-Month Agency Response

SPAC membership eligibility and compliance is being verified and will be updated continually. Education is in the final stages of database development and completion to improve the efficiency and accuracy of the verification and review process and to ensure compliance of the two-thirds migrant parent membership requirement. The transition to this data-driven process is expected to take effect in or before September 2013.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Education ensures compliance with the two-thirds migrant parent requirement by checking the members' certificates of eligibility. Where member eligibility is questionable, Education contacts the regional director for verification. Education conducts these three times per year: April, August, and December. Additionally, Education has developed regulations which address the two-thirds requirement to ensure State Parent Advisory Council's (SPAC's) future compliance. The proposed regulations are under review and are expected to be completed and implemented by January 2014.

Education is also designing a new data system for gathering and retrieving member information. This new data system will: (1) maintain both current and former member information; (2) prompt for expiration of certificates of eligibility; (3) disallow the entry of more than one-third non-migrant parent membership (or require special permissions); (4) allow querying of specific member information; and (5) run reports and data in spreadsheet and chart formats. This data storage and retrieval process will improve the efficiency and accuracy of the review process to ensure it complies with the two-thirds requirement. This process is currently being managed using a paper-based color-coding system and will transition to a data-driven process upon database completion.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation #17 To: Education, Department of

To ensure that it receives a report from the state parent council, Education should continue to provide the necessary training to the council regarding the report and ensure that the council report appears on the agenda for state parent council meetings.

6-Month Agency Response

Prior to the CSA's audit, Education has provided training to the council on preparing and submitting state parent council reports; Education will continue to provide necessary training and guidance.

Education supported the SPAC membership in the writing of the 2012-13 report by utilizing SPAC member surveys and statewide parent conference surveys to give context to the document. The data was analyzed, summarized, and provided to the SPAC members for sharing with their regional councils and for obtaining additional feedback. A report update and additional survey data were mailed to the SPAC members on May 31, 2013. In an effort to encourage and increase the feedback and information from all migrant parents, Education provided a self-addressed stamped envelope to facilitate the mailing back of any additional information from each of the region's migrant parents.

Education facilitated the completion of the report at the regularly scheduled SPAC meeting on July 13, 2013, at which time the SPAC membership provided its recommendations and concluding statement. Education is finalizing the structure and format of the document in order to move it forward for approval. Additionally, Education has presented the SPAC membership with a proposed schedule for the regularly scheduled meetings. The schedule includes information pertaining to Education/MEP components to facilitate the evaluation of programs and begin the process of writing the 2013-14 report. It is expected that the program evaluation and report writing process will regularly appear on the agenda for state parent council meetings.

California State Auditor's Assessment of 6-Month Status: Fully Implemented

60-Day Agency Response

The data being compiled for the fiscal year 2012-13 annual report comes from two sources: (1) SPAC member surveys; and (2) statewide parent conference surveys.

Education is analyzing SPAC member survey data to assist in the completion of the current and future reports. Education has provided a summary of the members' survey responses related to parent involvement and program improvement to SPAC members and to the region directors. The summary was mailed to the address on file for each SPAC member on April 8, 2013, and was e-mailed to the directors on April 11, 2013.

Education received approximately 350 valid survey responses from the March 2013 statewide parent conference. Data collected in this survey includes MEP services received and uses a three-point scale to rate the quality of the services. Education shared the conference survey responses with the SPAC members at the May 4, 2013, meeting.

Collectively, the data from each of the above two sources will provide the necessary information to complete the annual report. The 2012-13 SPAC report is on schedule for completion by June 14, 2013.

Moving forward, Education will continue to engage with and obtain feedback from SPAC members and provide the necessary training to support their efforts in completing future annual reports. Education will ensure that the SPAC report regularly appears on the agenda for state parent council meetings. Education is committed to the collaboration with parents in support of their efforts to improve the educational outcomes of all migrant students.

California State Auditor's Assessment of 60-Day Status: Pending

Recommendation for Legislative Action

To help the state parent council meet the State's open-meeting requirements, the Legislature should consider whether it needs to clarify its intent as to which open-meeting law applies to the state parent council.

Description of Legislative Action

Legislation has not been introduced to address this specific recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: No Action Taken

Description of Legislative Action

N/A

California State Auditor's Assessment of Annual Follow-Up Status: Legislation Proposed But Not Enacted

AB 275 (Alejo, 2013) , if enacted, would have required, in part, that all meetings of the statewide parent advisory council be held pursuant to the Bagley-Keene Open Meeting Act.

All Recommendations in 2012-044

Agency responses received after June 2013 are posted verbatim.