Report 2012-044 Recommendations and Responses in 2015-041

Report 2012-044: California Department of Education: Despite Some Improvements, Oversight of the Migrant Education Program Remains Inadequate

Department Number of Years Reported As Not Fully Implemented Total Recommendations to Department Not Implemented After One Year Not Implemented as of 2014-041 Response Not Implemented as of Most Recent Response
California Department of Education 2 16 13 13 8

Recommendation 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.

Response

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 Status: Fully Implemented
  • Completion Date: June 2015
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Will Not Implement
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Pending
  • Estimated Completion Date: March 2014
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Pending
  • Estimated Completion Date: December 2014
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Pending
  • Estimated Completion Date: March 2014
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Resolved
  • Completion Date: June 2015
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Resolved
  • Completion Date: June 2015
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Resolved
  • Completion Date: June 2015
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Partially Implemented
  • Estimated Completion Date: June 2015
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Partially Implemented
  • Estimated Completion Date: September 2014
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Not Fully Implemented
  • Completion Date: December 2015
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Not Fully Implemented
  • Completion Date: June 2016
  • Response Date: October 2015

Recommendation 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.

Response

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 Status: Fully Implemented
  • Completion Date: December 2014
  • Response Date: October 2015

Current Status of Recommendations

All Recommendations in 2015-041