Georgia Department of Education 7/19/2016

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1 How to Draft and Revise Internal Controls: Fiscal and Programmatic Implementation of Title II, Part A July 19, 2016 Collaboratively Presented by the Georgia Department of Education Office of Internal Audits & Title II, Part A Program Office The contents of this presentation were developed under a grant from the U.S. Department of Education. However, those contents do not necessarily represent the policy of the U.S. Department of Education, and you should not assume endorsement. Federal Internal Auditors Name Title Alan Abercrombie Federal Internal Auditor aabercrombie@doe.k12.ga.us Wes Sherrell Internal Audit Manager wsherrell@doe.k12.ga.us Will Smith Internal Audit Supervisor wsmith@doe.k12.ga.us 07/19/ Avis King Deputy Superintendent Office of School Improvement Cindy Saxon Associate Superintendent Teacher and Leader Effectiveness Division Julie Noland Program Manager Teacher and Leader Effectiveness Division 07/19/

2 Maps and Specialists Julie Noland Program Manager Division of Teacher and Leader Effectiveness Specialists Carly Ambler Saralyn Barkley Sharon Brown Pam Daniels Greg Petersen Terri Still Elizabeth Zipperer 07/19/ Outline of Presentation Purpose and Definition of Internal Controls Drafting and Revising Internal Controls Internal Controls for Title II, Part A Fiscal Internal Controls Program Internal Controls 07/19/ Purpose of Internal Controls Uniform Administrative 2 C.F.R. Part 200 o Requires LEAs to have certain internal controls Single Audits o Require internal controls for review by auditors Program Monitoring o Requires policies and procedures for compliance with federal law and for adherence to internal controls and consistent implementation (all Federal programs) Staff o Serves as an annual training tool for applicable leaders and staff o Enables new staff to remain consistent in federal program implementation o Helps the LEA to retain important information and prevent errors 07/19/

3 Defining Internal Controls Internal Controls Activities undertaken by management to increase the likelihood of achieving management objectives in the areas of efficiency and effectiveness, reliability of financial reporting, compliance with laws and regulations and safeguarding of assets. 07/19/ Defining Internal Controls Internal controls Internal control over compliance requirements for Internal controls means a process, Federal awards. implemented by a non Federal entity, Internal control over compliance requirements for Federal designed to provide reasonable awards means a process implemented by a non Federal entity assurance regarding the achievement designed to provide reasonable assurance regarding the of objectives in the following achievement of the following objectives for Federal awards: categories: (a) Transactions are properly recorded and accounted for, in (a) Effectiveness and efficiency of order to: operations; (1) Permit the preparation of reliable financial statements and (b) Reliability of reporting for internal Federal reports; and external use; and (2) Maintain accountability over assets; and (3) Demonstrate (c) Compliance with applicable laws compliance with Federal statutes, regulations, and the terms and regulations. and conditions of the Federal award; (b) Transactions are executed in compliance with: (1) Federal statutes, regulations, and the terms and conditions of the Federal award that could have a direct and material effect on a Federal program; and (2) Any other Federal statutes and regulations that are identified in the Compliance Supplement; and (c) Funds, property, and other assets are safeguarded against loss from unauthorized use or disposition. 07/19/ Types of Internal Controls Preventative Detective These are controls to stop something bad from happening. Preventative controls are before the fact controls. These are controls designed to detect something bad in a timely manner. They are designed to detect an error or adverse event after it occurs, but within a reasonable time to permit correction through awareness of the problem, helps prevent other errors from occurring. Corrective Compensating These are controls that correct problems found in defective controls. Many corrective controls rely on computer automation. These are controls designed to address the weakness of other controls. Compensating controls can compensate for shortcomings elsewhere. 07/19/

4 Examples of Internal Controls Preventative The LEA Federal Programs Manual requires the Title II, Part A Coordinator (with current program knowledge) to approve all expenditures prior to charging the grant. Detective Corrective Compensating The LEA Title II, Part A Coordinator reviews source documentation for PL to determine allowability of participants and PL content and ensure program compliance. The LEA Federal Programs Manual requires any unallowable charges made to each grant and discovered during routine reconciliation to be reclassified to another funding source. Board policy limits the amount that can be charged per expenditure to purchasing cards (p cards) for LEA employees issued cards. Further limitations are set for which employees may be issued p cards. 07/19/ Policies v Procedures Policies Typically Approved by the LEA Board of Ed. Business Rules and Guidelines of a LEA that ensure consistency and compliance and with which all staff and programs must comply. Policies are the guidelines under which procedures are developed. Example: Laws and Rules of the Road such as speed limits Procedures Typically Developed by LEA Staff The detailed steps required to perform a task. These detail who performs the procedure, what steps are performed, when the steps are performed, and how the procedure is performed. (Best if can apply to multiple programs.) Example: Google Maps step by step instructions to reach Atlanta 07/19/ Aligning Internal Controls Source of Requirement Example 07/19/

5 Required Internal Controls Review existing internal controls CONTENT: Are all required controls present? Do they require revisions? How often is it reviewed and revised? FORMAT: What format do your internal controls take? (Document on Shared Drive, Posted On Website, Hard Copy Manual) Is the format accessible to applicable staff? EFFECTIVENESS: Do District staff follow the internal controls? Why or why not? Do they need training? Who monitors the implementation/ effectiveness of the established internal controls? 07/19/ Required Internal Controls Revise internal controls Develop questions for clarification Schedule interviews with relevant staff in order to gather information on actual practice Reconcile existing written policies and procedures with actual practices and existing laws, policies, and guidance. Review internally with appropriate staff Formally adopt (if applicable) and implement Train applicable staff 07/19/ Required Internal Controls UPDATED Title II, Part A Internal Controls Quick Guide 07/19/

6 Fiscal Internal Controls 07/19/ DRAFT UNIQUE LEA POLICIES AND PROCEDURES General procurement standards. (a) The non Federal entity must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section Policy guide. The application of these cost principles is based on the fundamental premises that: (c) The non Federal entity, in recognition of its own unique combination of staff, facilities, and experience, has the primary responsibility for employing whatever form of sound organization and management techniques may be necessary in order to assure proper and efficient administration of the Federal award. 07/19/ ALLOWABILITY 2 CFR (b)(7) The financial management system of each non Federal entity must provide Written procedures for determining the allowability of costs in accordance with Subpart E Cost Principles of this Part and the terms and conditions of the Federal award. 2 CFR (a) Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Internal Controls should be updated from A 87 to 2 CFR Part 200. In FY17 expenditures must comply with both 2 CFR Part 200 and ESEA/ NCLB. In FY18 expenditures must comply with both 2 CFR Part 200 and ESEA/ESSA. Reference your plans: System Improvement Plan/ CLIP, LEA Equity Plan, LEA SSIP, Schoolwide Plan Source documentation kept on file will determine allowability. 07/19/

7 SUPPLEMENT NOT SUPPLANT ESEA Sec. 2123(b) Funds received under this subpart shall be used to supplement, and not supplant, non Federal funds that would otherwise be used for activities authorized under this subpart. Supplement not supplant provisions vary by program. (Examples: Schoolwide, Title I, Title II, IDEA) State and district mandates may not be funded with NCLB and IDEA funds. Salaries previously supported by local funds. The portion of salaries required by state or local board rule. Software licensing, memberships, and financial incentives, etc. previously supported by another funding source. 07/19/ SOURCE DOCUMENTATION 2 CFR (b)(3) The financial management system of each non Federal entity must provide Records that identify adequately the source and application of funds for federallyfunded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. 2 CFR (g) Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: Be adequately documented. The source documentation required by LEA finance departments may not be sufficient documentation to determine compliance with grant requirements. Source documentation should answer: With which need(s) does this expenditure align? Which equity gap does this address? Who: Who authorized? Who traveled? Who substituted? Who attended? etc. What: What was ordered? What topics were covered in the training? etc. When: When was the payment made? When did the travel occur? When is the licensing valid? When were services received? etc. 07/19/ PERIOD OF PERFORMANCE 2 CFR Period of performance means the time during which the non Federal entity may incur new obligations to carry out the work authorized under the Federal award. 2 CFR A non Federal entity may charge to the Federal award only allowable costs incurred during the period of performance and any costs incurred before the Federal awarding agency or passthrough entity made the Federal award that were authorized by the Federal awarding agency or passthrough entity. 2 CFR (g) Period of performance must be adequately documented. 34 CFR Table addressing obligations for various kinds of properties and services LEA s have more flexibility in regards to period of performance with State and local dollars than Federal dollars. Common pitfalls include: software licensing, subscriptions, contracts and travel arrangements made well in advance. Source documentation must reflect the period of performance. Internal controls should address what to do if an expenditure does not fall within the period of performance. (proration) 07/19/

8 Original Allowable and Unallowable Costs Any purchases made with Title funds must follow the guidelines for allowable costs. ABC SD programs will follow guidelines as detailed in EDGAR, OMB Circulars (such as A 87), and the Title I Handbook for Georgia. Title I purchases will also adhere to any memos, letters, and/or communication regarding allowable/unallowable purchases. Any questionable expense will be directed by the Title I Coordinator to the area program specialist for further clarification Revised Federal Programs Allowable Costs The current Federal Programs Director reviews all expenditures to determine allowability by considering the following Aligns to LEA Prioritized Needs (SIP) Necessary and Reasonable Adequately Documented Allocable to Federal Program (Law and Non Regulatory Guidance) Aligns with Program Purpose Supplements Not Supplants 2 C.F.R., Part 200 Aligns to Cost Principle Allowability Adheres to Period of Performance Avoids Conflict of Interest Follows Procurement Methods Remains consistent with non Federal Purchasing Procedures This is a SAMPLE for demonstration purposes, NOT a recommended procedure for LEAs. 07/19/ CONSISTENT POLICIES 2 CFR Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non Federal entity.) 2 CFR In determining reasonableness of a given cost, consideration must be given to: (e)whether the non Federal entity significantly deviates from its established practices and policies regarding the incurrence of costs, which may unjustifiably increase the Federal award s cost. Policies and procedures are applied consistently to local and federal dollars, including expenditures related to personnel overtime, travel and stipends/ honorariums/ financial incentives, etc. The consistent application of policies and procedures increases the chance that written internal controls will be followed by LEA staff. 07/19/ Original Travel for Title II, Part A Coordinator complies with the travel guidelines of ABC SD to ensure that Title II, Part A travel follows federal guidance. Revised Federal Programs Travel Requires preapproval (for allowability of participant and activity) Per diem, lodging, mileage must be paid out of pocket and are reimbursed at cost, no higher than state per diem Post Travel expenses must be entered with electronic receipts and agenda in online program. FP Director must authorize payment on all travel reimbursements. Any costs exceeding state per diem, must be preapproved by FP Director and require written explanation This is a SAMPLE for demonstration purposes, NOT a recommended procedure for LEAs. 07/19/

9 Acquisition 2 CFR (a) Use 2 CFR (a)(1,3), (c) Inventory 2 CFR (d) Disposition 2 CFR (e) INVENTORY Equipment purchased for Title programs must meet program requirements (aligns to prioritized needs, allowable uses) and be reasonable, necessary and allocable. Local policies/ procedures must, at a minimum, comply with Federal requirements. Internal controls should address who will monitor and what type of documentation is required to document use. LEAs may need to review current inventory to ensure all required components are included. Items purchased from July 2015 forward should include the FAIN. Should address: timeframe for conducting inventory, reconciliation, safeguards and maintenance. All inventory purchased will be checked. If equipment purchased with Federal funds (like Title II) is no longer needed, LEAs should first consider whether or not another Federal Program (like Title I) could benefit from the equipment. Local policies/ procedures must, at a minimum, comply with Federal requirements. 07/19/ Original Required Inventory Information Item Item description The cost The source of funding The date of acquisition The item serial number The location of the equipment The use and current condition of the item The record of the disposition of the item Revised Inventory of Equipment Inventory must include: Item Item description with vendor The cost The source of funding (percent if prorated) The Federal Award Identification Number The date of acquisition The item serial number or other identification number The location of the equipment The use and current condition of the item The record of the disposition of the item 07/19/ Participants and Activities ESEA Sec. 2123(a), 2 CFR (a) Conferences 2 CFR Recruitment 2 CFR COST PRINCIPLES & TITLE II, PART A GaDOE Title II, Part A Program Staff recommend addressing the following cost principles that are commonly supported by Title II, Part A Memberships, Subscriptions, and Professional Activity Costs 2 CFR (a b) Supplies 2 CFR , Title II, Part A restricts which staff may participate in PL, receive financial incentives and be the focus for recruitment. Title II, Part A restricts which staff may participate in PL and which topics are allowable. The source documentation that is required to show a conference is reasonable and necessary. The UAR restricts advertising for recruitment. The UAR requirements may be more restrictive than State and local requirements for schools and LEAs not individuals The UAR restricts the purchase of supplies to those necessary to implementing the program. 07/19/

10 PROCUREMENT METHODS General Procurement Standards 2 CFR The non Federal entity must use its own documented procurement procedures which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal law and the standards identified in this section. [Procurement] Competition 2 CFR Methods of Procurement to be Followed 2 CFR Local policies that address procurement must be in compliance with Federal requirements. Policies last updated prior to July 2015 may need to be reviewed for compliance. Levels are subject to change. Local procurement levels and methods may be more restrictive than Federal. 07/19/ Ethical Conduct 2 CFR , ; (c); White House Executive Order 12731; Contract Oversight 2 CFR (b) GENERAL PROCUREMENT Ensure local board policies and procedures comply with Federal and State requirements. Ensure procedures explicitly address all requirements. The amount of a contract that is charged to Title II, Part A must align both with allowability and period of performance. Services must be received prior to payment. While the Title II, Part A Coordinator might not authorize the contract, the Coordinator must authorize any payments charged to the grant. Source documentation that fulfills program requirements must be maintained. Contracts charged in part or in whole to Title II, Part A must meet Federal procurement requirements. 07/19/ GENERAL PROCUREMENT Segregation of Duties 2 CFR (a); GAO G Standards for Internal Controls for the Federal Government Expenditure Authorization 2 CFR In meeting the requirements for segregation of duties, charges to Title II, Part A must include the authorization of the Title II, Part A Coordinator. While two signatures are allowable, three signatures are preferred. In Georgia, the LEA must have written procedures to include at least one staff member in the approval of Title II, Part A expenditures who has current (annual), firsthand knowledge of Federal and State Program Implementation. 07/19/

11 Drafting Internal Controls Original Internal Controls for Cash Management The district s Finance Coordinator ensures procedures are followed to adequately handle the cash management of the federal funds. Finance Coordinator makes sure that all appropriate information concerning the program s expenditures is obtained before completing a request for funds from GaDOE. Revised Internal Controls for Payment ABC SD requires segregation of duties for all expenditures as listed below Expenditure Approval all expenditures must have prior approval for allowability by program director and must follow system purchasing guidelines used by all system bookkeepers Expenditure Processing The purchase requisition must have all required signatures and be turned into a PO. The bookkeeper will send PO to vendor. Expenditure Receipt Person purchasing must receive and reconcile PO items and forward invoice to accounts payable. Expenditure Payment Accounts payable runs the check and a final review is conducted by Associate Superintendent for business operations This is a SAMPLE for demonstration purposes, NOT a recommended procedure for LEAs. 07/19/ Records 2 CFR (b)(3) The financial management system of each non Federal entity must provide records that identify adequately the source and application of funds for federally funded activities. These records must contain information pertaining to Federal awards, authorizations, obligations, unobligated balances, assets, expenditures, income and interest and be supported by source documentation. Reconciliation 2 CFR (b)(5) The financial management system of each non Federal entity must provide Comparison of expenditures with budget amounts for each Federal award. Reporting 2 CFR (b)(2), ; The financial management system of each non Federal entity must provide Accurate, current, and complete disclosure of the financial results. ACCOUNTING Records and source documentation maintained for audit may not contain sufficient detail to determine compliance with Federal grant requirements (allowability). Internal controls might address who maintains the various types of documentation. Internal controls might address how often this occurs, but should not be so restrictive that employees cannot reasonably implement procedures. Internal controls might address types of financial and programmatic reports and corresponding deadline and reporting requirements such as: completion report, equity plan, monitoring reports, audit reports. 07/19/ DRAWDOWN OF FUNDS Timeliness 2 CFR (b) payments methods must minimize the time elapsing between the transfer of funds from the the pass through entity [SEA] and the disbursement by the non Federal entity [LEA] whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means. Payments Based on Actual Cost 2 CFR The timing and amount of payments must be as close as is administratively feasible to the actual disbursements by the non Federal entity for direct program or project costs and the proportionate share of any allowable indirect costs. Internal controls should allow LEAs to drawdown regularly, but only based on actual need. Internal controls should enable LEAs to avoid supplanting (ensuring salaries are drawn down regularly), but not so restrictive that they require drawdowns in the absence of actual costs. Needs may vary by program and good internal controls will allow for this variation. LEAs should include who is responsible for the drawdowns. Internal controls might include how to address discrepancies. 07/19/

12 Time and Effort Allowability 2 CFR (i)(1)(i, vii)...records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (vii) Support the distribution of the employee s salary or wages among specific activities or cost objectives. Time and Effort Records Reconciliation 2 CFR (i)(1)(viii)(B,C) (B) Significant changes in the corresponding work activity (as defined by the non Federal entity s written policies) are identified and entered into the records in a timely manner. (C) The non Federal entity s system of internal controls includes processes to review after the fact interim charges made to a Federal awards based on budget estimates. All necessary adjustment must be made such that the final amount charged to the Federal award is accurate, allowable, and properly allocated. TIME AND EFFORT Coordinators should ensure job descriptions and actual time and effort records reflect allowable activities in accordance with requirements and the portion of compensation paid by each funding source. Internal controls might address how often time and effort documentation is collected, reviewed, and reconciled. Auditors require that, at a minimum, reconciliations occur quarterly. 07/19/ TIME AND EFFORT Time and Effort Source Documentation 2 CFR (i)(1 8) These records must: (ii) Be incorporated into the official records of the non Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non Federal entity, not exceeding 100% of compensated activities; (iv) Encompass both federally assisted and all other activities compensated by the non Federal entity on an integrated basis (v) Comply with the established accounting policies and practices of the non Federal entity; (vii) Support the distribution of the employee s salary or wages among specific activities or cost objectives Internal controls might address the types of source documentation required for the different types of compensation funded. Controls may address who will authorize the documentation, when it will be collected and where it will be housed. 07/19/ Program Internal Controls 07/19/

13 NEEDS ASSESSMENT Needs Assessment ESEA Sec. 2122(c)(1), Sec. 2122(b)(7), Sec. 2122(c)(2) The GaDOE Title II, Part A Program requires LEAs to have written procedures ensuring an annual needs assessment is conducted which includes all components, supporting data and data analysis, and required stakeholders. All program required components and subcomponents must be addressed; however each component and subcomponent need not be listed. Supporting data is required for each component, however, explicitly listing document names rather than generic types may restrict LEA ability to comply with procedures. All stakeholders required by the program should be included in the needs assessment; however each stakeholder need not be listed. While explicit listing of components and stakeholders may not be required, listing examples is encouraged and it may be requested in corrective action for noncompliant LEAs. 07/19/ Original Title II, Part A Needs Assessment ABC SD includes teachers, administrators and parents. Stakeholders must review CCRPI, GAPSC Equity Technical Assistance Report, CRCT, and ITBS. Revised Title II, Part A Needs Assessment Title II, Part A needs should be addressed within the ABC SD comprehensive needs assessment. All required components must be explicitly addressed and all required stakeholders must be invited to participate in some portion of the needs assessment process. The Title II, Part A coordinator should review annual guidance to determine what must be addressed. Supporting documentation must be kept on file by the Title II, Part A Coordinator for each required component in support of the data summary and needs analysis provided. This data should be gathered, reviewed and used to determine the needs that will be reported in the CLIP and Equity Plan and which will guide the selection of strategies to be included in the budget. This is a SAMPLE for demonstration purposes, NOT a recommended procedure for LEAs. 07/19/ EQUITY LEA Equity Action Plan ESSA Sec. 1111(g)(1)(B), 1112(b)(2), 2101(d)(2)(E), 2103 (b)(3)(b); Georgia s Equitable Access to Effective Educators State Plan The GaDOE Title II, Part A Program requires LEAs to have written procedures ensuring the implementation of the LEA s Equity Action Plan and the maintenance of corresponding documentation. Maintain a copy of the equity plan and the source documentation to verify implementation. 07/19/

14 EFFECTIVENESS Effectiveness Plan ESEA Sec. 2101(2), Sec. 2122(b)(2); 2 CFR (a) The GaDOE Title II, Part A Program requires LEAs to have written procedures describing specifically the LEA s identified steps for determining the effectiveness of Title II, Part A funded strategies. The Effectiveness Plan is not the same as the Equity Plan. The Effectiveness Plan outlines procedures for determining effectiveness of funded strategies in one year. LEA internal controls for developing, monitoring and documenting a LEA Title II, Part A Effectiveness Plan should reflect procedures that are inclusive of plans developed in any year. 07/19/ Original The Equity Effectiveness Plan The ABC SD must implement the District s Plan and maintain the corresponding documentation. The coordinator will distribute professional learning surveys and gather focus group data to compare feedback on professional learning effectiveness. Revised The Title II, Part A Coordinator is responsible for coordinating all required plans and maintaining corresponding documentation. The LEA Equity Action Plan In the spring, the Title II, Part A Coordinator works with required stakeholders to determine equity gaps and draft the annual LEA Equity Action Plan in accordance with SEA requirements. The Title II, Part A Effectiveness Plan The Title II, Part A Coordinator will draft the annual Effectiveness Plan based on current planned budget expenditures in accordance with SEA requirements. The Effectiveness Plan should be revised and uploaded if a budget amendment is submitted due to a change in needs and/or a significant change in budgeted strategies. This is a SAMPLE for demonstration purposes, NOT a recommended procedure for LEAs. 07/19/ PROFESSIONAL LEARNING Scientifically Based/ Evidence Based ESEA Sec. 2122(b)(1)(B) Coordination of Funds ESEA Sec. 2122(b)(4), Sec. 2122(b)(6) Priority and Focus School PL ESEA Sec. 1115(e)(3) Documentation of research/ evidence base must be available for each strategy that is budgeted. Internal controls should require LEA staff to document when expenditures are split across programs. Controls should address that funding must be provided to support PL in priority and focus schools. If not adequately funded by another source, the LEA must use Title II, Part A funds or coordinate Title II, Part A funds with those of another source. 07/19/

15 PROFESSIONAL QUALIFICATIONS Hiring and Assignment ESEA Sec. 1119(a)(1), Sec. 1119(a)(3); ESSA Sec. 1112(h)(5)(D)(i iii); Transitioning to the Every Student Succeeds Act (ESSA) FAQs C 7a (June 29, 2016) Parent Notification: Right to Know ESEA Sec. 1111(h)(6)(A) Minimum requirements for the hiring and assignment are still in place in FY17 for paraprofessionals and special education teachers.**usde FAQs updated ** While HiQ is suspended in FY17, it will return as PQ in FY18 and expand to include all teachers. It is recommended that LEAs continue to maintain procedures to guide the hiring and assignment of teachers in fields in which the teacher has demonstrated content area expertise (certification, content test, degree and/ or coursework) Internal controls should include multiple methods dissemination of notification by all schools at the start of the school year and for any students who enroll after that time. Maintenance of records documenting dissemination. Staff person by position responsible for ensuring all required content is included in the notification. 07/19/ Original Right to a 20 Day Letter At the end of 20 days a Title I school must send home a certified letter notifying parents of a teacher s HiQ status. Revised Parents Right to Know At the start of school, every school principal must notify parents of their right to request the professional qualifications of their child s teachers and paraprofessionals using the LEA template. This should be sent home in the student handbook and posted to the school webpage. A sample of the handbook acknowledgement form should be forwarded to the Title II, Part A Coordinator. Students enrolling after the beginning of school receive a letter of their rights upon enrollment. Receipt of the letter is recorded by a parent/ guardian signature. 20 Day Letter This notification is not required in This is a SAMPLE for demonstration purposes, NOT a recommended procedure for LEAs. 07/19/ PRIVATE SCHOOLS Private Schools ESEA Sec. 9501(a)(1) Invitation Consultation Provision of Services The GaDOE Title II, Part A Program requires LEAs to have written procedures ensuring invitation, consultation, and the equitable provision of services to private schools within a LEA s geographic boundaries. As of guidance suggests that LEAs will continue to issue invitations to participate, provide consultative meetings, and serve as the fiscal agent for Title II, Part A funds. In Georgia, LEAs MUST consult the GaDOE Private School List to determine private schools located within the LEAs geographic boundaries. If the LEA is aware of private schools within the geographic boundaries that are not on the GaDOE list, those schools must also be invited to participate. The LEA may not place restrictions on a private school s ability to participate. 07/19/

16 COMPLAINTS Complaints ESEA Sec. 9304, 9306, 9503 The LEA must have written procedures for the receipt and resolution of complaints alleging violations of law in the administration of the programs. Procedures should include how the LEA will comply with the SEA in the investigation of complaints. Procedures should address how the LEA will receive, investigate, and resolve complaints from parents, teachers, or other individuals and organizations concerning violations of section 9501 private schools. Procedures for resolving complaints that originate at the LEA level should emphasize local resolution. If complaints originate at the SEA level, LEAs must have procedures for complying with the SEA investigation. 07/19/ Resources ESEA/ NCLB and ESEA/ ESSA EDGAR 2 CFR Part 200 Uniform Administrative 34 CFR Part 76 State Administered Grants Green Book USGAO Standards for Internal Control in the Federal Government (2014) OMB and USDE Guidance on 2 CFR Part /19/ Questions 07/19/

17 How to Draft and Revise Internal Controls: Fiscal and Programmatic Implementation of Title II, Part A July 19, 2016 Collaboratively Presented by the Georgia Department of Education Office of Internal Audits & Title II, Part A Program Office The contents of this presentation were developed under a grant from the U.S. Department of Education. However, those contents do not necessarily represent the policy of the U.S. Department of Education, and you should not assume endorsement. 17