Recurring Findings

Education: Recurring Less severe Noncompliance
Federal Program Issue First Year Reported
Department's Assertion Page Number
Title I Grants to LEAs (Local Educational Agencies) Education lacks adequate monitoring procedures to ensure local educational agencies (LEAs) promptly implement proposed corrective actions on deficiencies noted during monitoring reviews. Of the 45 reviews tested, 5 had an unresolved status for more than 225 days. In addition, four of those five LEAs had either not submitted their corrective actions or submitted insufficient corrective actions for all deficiencies noted during the review. 2005-06
Partially Corrected. The new functionalities were implemented in the California Accountability and Improvement System in December 2011. Training for Education staff occurred in November 2011. Since July 2011, the Federal Programming Monitoring Office continues to send monthly updates on the resolution of findings to program managers and began posting the report to Education?s Intranet in January 2012. 61
Child Care Mandatory and Matching Funds of the Child Care and Development Fund A sample of support for the follow-up by the Federal Program Monitoring Unit (FPM) was reviewed to ensure corrective action on deficiencies noted during FPM?s reviews of local educational agencies (LEAs). One LEA was delinquent in submitting its Proposed Resolution of Findings on Noncompliance (PRFN); however, there was no communication from Education to the LEA regarding the delinquency of its PRFN. Also, two LEAs had unresolved deficiencies beyond the allowed period. Delayed resolution of outstanding monitoring deficiencies appears to be due to a combination of delayed follow-up and ineffective sanctions imposed by Education on the LEAs for belated implementation of corrective action plans. 2008-09
Fully Corrected. The new functionalities were implemented in the California Accountability and Improvement System in December 2011. Training for Education staff occurred in November 2011. Since July 2011, the FPM continues to send monthly updates on the resolution of findings to program managers and in January 2012, began posting the report to Education?s Intranet. 62
Child Care and Development Block Grant A sample of support for the follow-up by the Federal Program Monitoring Unit (FPM) was reviewed to ensure corrective action on deficiencies noted during FPM?s reviews of local educational agencies (LEAs). One LEA was delinquent in submitting its Proposed Resolution of Findings on Noncompliance (PRFN); however, there was no communication from Education to the LEA regarding the delinquency of its PRFN. Also, two LEAs had unresolved deficiencies beyond the allowed period. Delayed resolution of outstanding monitoring deficiencies appears to be due to a combination of delayed follow-up and ineffective sanctions imposed by Education on the LEAs for belated implementation of corrective action plans. 2008-09
Fully Corrected. The new functionalities were implemented in the California Accountability and Improvement System in December 2011. Training for Education staff occurred in November 2011. Since July 2011, the FPM continues to send monthly updates on the resolution of findings to program managers and in January 2012, began posting the report to Education?s Intranet. 62
National School Lunch Program Education lacks adequate internal controls to ensure approval of subrecipient contracts with food service companies within its Child Nutrition Information and Payment System is documented prior to funding reimbursements. 2009-10
Partially Corrected. By September 2012, Education planned to fill the newly approved positions to maintain the Food Safety Manager Certification (FSMC) pre-approval process. The FSMC registry is currently on hold pending regulations development. 76
School Breakfast Program Education lacks adequate internal controls to ensure approval of subrecipient contracts with food service companies within its Child Nutrition Information and Payment System is documented prior to funding reimbursements. 2009-10
Partially Corrected. By September 2012, Education planned to fill the newly approved positions to maintain the Food Safety Manager Certification (FSMC) pre-approval process. The FSMC registry is currently on hold pending regulations development. 76
Career and Technical Education--Basic Grants to States Education lacks adequate internal controls over record retenton to ensure student count used to determine its 2010-11 maintenance of effort (MOE) is supported. 2010-11
Partially Corrected. All documentation for detemining MOE will be organized and stored both electronically and hard copy. All electronic documents will be clearly identified and stored in one folder on the unit's shared drive. Additionally, all documents will be printed and stored in an organized and labeled binder. 67
School Improvement Grants Cluster: School Improvement Grants Education did not design or implement a subrecipient monitoring process for the School Improvement Grant (SIG) program. Specifically, Education does not monitor subrecipients for their use of program funds through site visits, limited scope audits, or other means to ensure subrecipients administer federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements; and that performance goals are achieved. 2010-11
Partially Corrected. Education?s monitoring process for SIG subgrantees includes fiscal and programmatic monitoring. As part of the Cohort 1 (FY 2009) year one monitoring process, and to inform the decision for renewal of year two funding, Education staff has conducted conference calls with each of the 41 local educational agencies (LEAs) funded. Each call averaged 90?120 minutes initially with some follow-up calls. Any LEA that had not fully implemented a required component of the SIG was required to complete and submit to Education a ?corrective plan? addressing specific areas that have not been fully implemented, timeline and evidence of full implementation, and resolution to any fiscal concerns identified by Education staff. As a result of a follow-up conference call with the U.S. Department of Education where additional clarification was provided about the increased learning time requirement for the Turnaround and Transformation models, a secondary rigorous review was completed during the summer of 2011. Education staff reviewed applications submitted by all 41 Cohort I LEAs. A thorough review of the implementation charts and budget documents was completed to ensure activities fully address and increase the three areas discussed in the guidance (core, enrichment, and teacher collaboration) and are available to all students. Areas of concern identified, such as lack of clarity, inappropriate activities, and budget concerns, were documented on a summary sheet for each LEA/school, and follow-up calls are being conducted with those districts to develop a corrective plan or revision to the application as appropriate. On-site monitoring of SIG subgrantees has been occurring since December 2011. Education has conducted on-site monitoring of approximately one-half of SIG Cohort 1 LEAs during the 2011?12 school year and anticipates monitoring the other one-half in the 2012?13 school year. Education staff conducted a minimum of one site visit, over the three- year grant period, to SIG-funded LEAs and schools in order to verify implementation. LEAs are required to upload evidence of compliance with grant requirements in the California Accountability and Improvement System (CAIS). Documents that have been uploaded in the CAIS are reviewed by Education staff prior to the on-site visit. The monitoring visit includes interviews with LEA staff, school staff, students (for grades 6?12), and parents. In addition, LEA and school plans and financial documents are reviewed by Education staff to ensure proper management of SIG funds. Education staff specifically request the following fiscal items: a report of expenditures of SIG funds to date for LEA and schools that indicate major object and sub codes for the 3180 and 3181 resource codes; job descriptions and duty statements for all LEA- and school-level employees funded with SIG and a personnel list for the whole LEA that indicates position, title, resource code, and location; time-accounting records; personnel activity reports for all SIG funded employees; and a description of its process for ensuring district-level activities are directed toward SIG schools. 75
School Improvement Grants Cluster: School Improvement Grants, Recovery Act Education did not design or implement a subrecipient monitoring process for the School Improvement Grant (SIG) program. Specifically, Education does not monitor subrecipients for their use of program funds through site visits, limited scope audits, or other means to ensure subrecipients administer federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements; and that performance goals are achieved. 2010-11
Partially Corrected. Education?s monitoring process for SIG subgrantees includes fiscal and programmatic monitoring. As part of the Cohort 1 (FY 2009) year one monitoring process, and to inform the decision for renewal of year two funding, Education staff has conducted conference calls with each of the 41 local educational agencies (LEAs) funded. Each call averaged 90?120 minutes initially with some follow-up calls. Any LEA that had not fully implemented a required component of the SIG was required to complete and submit to Education a ?corrective plan? addressing specific areas that have not been fully implemented, timeline and evidence of full implementation, and resolution to any fiscal concerns identified by Education staff. As a result of a follow-up conference call with the U.S. Department of Education where additional clarification was provided about the increased learning time requirement for the Turnaround and Transformation models, a secondary rigorous review was completed during the summer of 2011. Education staff reviewed applications submitted by all 41 Cohort I LEAs. A thorough review of the implementation charts and budget documents was completed to ensure activities fully address and increase the three areas discussed in the guidance (core, enrichment, and teacher collaboration) and are available to all students. Areas of concern identified, such as lack of clarity, inappropriate activities, and budget concerns, were documented on a summary sheet for each LEA/school, and follow-up calls are being conducted with those districts to develop a corrective plan or revision to the application as appropriate. On-site monitoring of SIG subgrantees has been occurring since December 2011. Education has conducted on-site monitoring of approximately one-half of SIG Cohort 1 LEAs during the 2011?12 school year and anticipates monitoring the other one-half in the 2012?13 school year. Education staff conducted a minimum of one site visit, over the three- year grant period, to SIG-funded LEAs and schools in order to verify implementation. LEAs are required to upload evidence of compliance with grant requirements in the California Accountability and Improvement System (CAIS). Documents that have been uploaded in the CAIS are reviewed by Education staff prior to the on-site visit. The monitoring visit includes interviews with LEA staff, school staff, students (for grades 6?12), and parents. In addition, LEA and school plans and financial documents are reviewed by Education staff to ensure proper management of SIG funds. Education staff specifically request the following fiscal items: a report of expenditures of SIG funds to date for LEA and schools that indicate major object and sub codes for the 3180 and 3181 resource codes; job descriptions and duty statements for all LEA- and school-level employees funded with SIG and a personnel list for the whole LEA that indicates position, title, resource code, and location; time-accounting records; personnel activity reports for all SIG funded employees; and a description of its process for ensuring district-level activities are directed toward SIG schools. 75
School Improvement Grants Cluster: School Improvement Grants, Recovery Act Education lacks adequate controls to ensure accuracy of the quarterly Section 1512 report for the School Improvement Grant. Education prepares the report from information maintained by program personnel. This information is not reconciled to the accounting records, such as the general ledger. In addition, the School Improvement Grant understated the disbursed amount for one local educational agency in the June Section 1512 report by $344,781 due to one payment which was excluded from the program spreadsheet. Education?s failure to implement adequate controls over Section 1512 reports increases the risk that inaccurate or incomplete information will be reported. 2010-11
American Recovery Reinvestment Act (ARRA) disbursements and expenditures are reported on a cumulative basis. Ultimately, when the grant is closed, Education performs a detailed reconciliation and the final report submitted to the federal government reconciles with Education?s accounting records. However, Education will further strengthen the process over Section 1512 quarterly reporting by reviewing the data for accuracy prior to submission. Education will correct the understated School Improvement Grant amount of $344,781 in the next reporting period. 73
Special Education - Grants to States (IDEA, Part B) Education lacks adequate controls to ensure maintenance of effort (MOE) requirements are met. Education?s MOE expenditures for the 2009/2010 federal fiscal year totaled $3,541,343,038, which was $83,464,446 less than its 2008/2009 federal fiscal year expenditures. Unless a waiver is received from the federal government, Education could be subject to a reduction of federal funding. 2010-11
If there is an issue in meeting the State?s MOE, Education notifies the Legislature of the potential shortfall. However, only the Legislature has the power to determine the amount of funds that are appropriated for the Special Education program. Education will provide information regarding the funding shortfall cited by the auditors to the California Legislature. Education will petition for additional state funds. If necessary, Education will submit a State MOE waiver request to the Office of Special Education Programs of the U.S. Department of Education. 64
Title I, Part A Cluster: Title I Grants to Local Educational Agencies--Recovery Act Education lacks adequate monitoring procedures to ensure local educational agencies (LEAs) promptly implement proposed corrective actions on deficiencies noted during monitoring reviews. Of the 45 reviews tested, 5 had an unresolved status for more than 225 days. In addition, four of those five LEAs had either not submitted their corrective actions or submitted insufficient corrective actions for all deficiencies noted during the review. 2010-11
Partially Corrected. The new functionalities were implemented in the California Accountability and Improvement System in December 2011. Training for Education staff occurred in November 2011. Since July 2011, the Federal Programming Monitoring Office continues to send monthly updates on the resolution of findings to program managers and began posting the report to Education?s Intranet in January 2012. 61
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