mera may 17, 2011

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MERAMay 17, 2011

Mike Radke, Director, Office of Field Services, Michigan Department of Education

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Evaluation Project Goals

1. Develop the MDE framework and tools to evaluate program impact on student achievement

2. Utilize the evaluation information to analyze and inform the improvement planning and implementation processes

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Evaluation Project Guiding Principles

Must be practical enough to implement in any schoolMust be driven by formative and summative dataMust be transparent and replicableMust inform planning and implementationMust empower effective decision makingThis is NOT research

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Evaluate at what level of detail?

Program

Strategy

Activity

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• Provide a framework• Provide tool(s)• Provide training• Inform decision

making

How will the evaluation project accelerate

student achievement?

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Percent of ARRA funds drawn?

Title I Part A, ARRA drawdownsAverage all states = 67.2%Michigan = 54.1%

Must be completely obligated by September 30, 2011 and completely drawn by November 30, 2011What can LEAs do to draw ARRA?

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Title I, Part A and Title II, Part D: Spend ARRA First

Draw down ARRA Carryover funds for approved ARRA program expenditures. Draw ARRA funds to cover Regular approved program costs

In the same function code(s) and object code(s) as were approved in the ARRA budgets.

If impossible, ARRA Carryover funds can be used to cover Regular program costs in other approved function code(s) and object code(s).

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Title I, Part A and Title II, Part D: Spend ARRA First (con’t)

Regular Title I, Part A expenditures paid with ARRA funds must be recoded to ARRA Title I, Part A and reported as ARRA expenditures in the Final Expenditure Report, Financial Information Database, and ARRA Section 1512 quarterly reports.

An amendment will not be required to your LEA’s 2010-11 Consolidated Application to revise the Regular and ARRA budgets for Title I, Part A and Title I, Part D.

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Tough Economic Times

TemptationsUse grant funds to replace state & local funds = supplantingCut corners: loss of internal controls

Challenges: dramatically improve student achievementBalance the budget, andUse appropriate accounting procedures

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MDE using risk criteria to select LEAs for monitoring

QuantitativeSingle Audit & FindingsTime since last monitoringSize of grant(s)Findings from other monitoringDeficit or watch list

Qualitative School improvement plan qualityLeadership expertiseKnowledge of the rules

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Consolidated Application Monitoring

LEA characteristicsLarge, medium and smallUrban, suburban and ruralNew PSAs, mature PSAs

Monitoring typeProgramFiscal On-siteDeskCombination

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Fiscal internal control policies and proceduresProcurementContract managementPersonnel timekeeping (PARs or Time & Effort certifications)SupplantingUnallowable costs or documentation problemsEquipment inventory

Fiscal Monitoring Findings

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Fiscal Monitoring FindingsDeficient documentation for transfers between accountsDraws for federal programs occur prior to actual expendituresConflicts of interest or related party transactionsFinal expenditure report deviations

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Program Findings: PlanningComprehensive needs assessment, analysis of total and subgroup data or educational processesSchool improvement plans: Schoolwide or Targeted AssistancePlanned supplementary services or programs not aligned with needs

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Program Monitoring Findings: Planning

Supplementary services or activities not research basedStakeholder involvement in school improvement planning, implementation and evaluationEvaluation of effectiveness for program reforms, strategies or activities

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Program Findings: Planning

No (little) school-level decision making in plan design, implementation or evaluationProfessional development plan not developed with stakeholder input or not aligned with needsInadequate program monitoring of implementation

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Program Monitoring Findings

Core academic program not aligned to state standards, instruction or assessmentsInadequate parent involvement district policy, school plan and compactProgram grant management inadequate

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Required ActionsDevelop & implement corrective action planPayback Federal programs with general fundsContract for program expertise at district expenseContract with CPA firm (at district expense) to establish amount to be paid back retrospectively

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Required ActionsContract with CPA firm (at district expense) to verify allowability prior to draw down of federal fundsCarry over funds to subsequent yearRevise or amend application consistent with requirementsRequire a single audit

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Required Actions

Implement internal controls to be eligible for fundsDevelop and implement policies and desk procedures

Approved by MDERequire training of staff annuallyConsequences for failure to implement

Open criminal investigationFederal High Risk status

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Region Three Pilot“Virtual” Consolidation

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What Does Consolidation Mean?

Schoolwide school treats the funds it is consolidating as a single “pool” of funds.

Funds from the contributing programs lose their identity.

The school uses funds from this consolidated schoolwide (SW) pool to support any activity of the SW program.

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What is the Purpose of Consolidation?

The purpose of consolidating funds is to help a SW program school effectively design and implement a comprehensive plan to upgrade the entire educational program in the school based on the school’s needs identified through its comprehensive needs assessment [E-1].

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Which funds can be consolidated in the pilot?

State Aid and local tax revenueState Section 31a

Title I, Part ATitle II, Part ATitle II, Part DTitle III Title VI

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Prerequisites to participation: High Quality

School level comprehensive needs assessmentSchool improvement plan meeting Schoolwide requirementsDefine your basic program and demonstrate it is fundedIdentify funds and amount of funds in consolidation

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Supplement not Supplant

Each school operating a SW program must receive all the state and local funds it would otherwise receive to operate its educational program in the absence of Title I, Part A or other [supplemental] education funds [E-2].

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Programmatic Record Keeping

• Evidence that intent and purposes of programs were fulfilled.

• Fulfill all required set aside

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Financial Accounting

“Virtual” pooling – maintain multiple grant numbers, function codes and cost objectives.

Two drawdown options: (1) Proportionate charging (2) Sequence charging

Functional category reporting must still be maintained

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QUESTIONS

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Contact

Mike RadkeDirector, Office of Field Services

517-373-3921radkem@michigan.gov