Monitoring Concerns
Presented By
WVDE Federal Programs Staff
June 15, 2011
2010-2011 Findings
Title I LEA
Homeless
School/LEA
Improvement
12%
Highly Qualified
Teachers
25%
Parent Involvement
Fiscal Issues
49%
Private
Schools
Fiscal Issues
Fiscal Issues
 7.1 Expending funds for administrative costs that are
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reasonable and necessary
7.2 Supplement/Supplant
7.3 Indirect Cost
7.4 Records of program review (now 7.12)
7.5,7.6,7.7 Equipment inventory
7.9, 7.10 Time and Effort
7.11 Written contracts
7.1 Expending funds for administrative costs that
are reasonable and necessary
 Ensure expenditures are reasonable and necessary for proper and
efficient performance and administration of the federal program
 Ensure expenditures are allowable expenditures according to OMB
Circular A-87
 Approve all requisitions, purchase orders, and invoices for payment
 Signature of the district Title I director
 Incorporate this procedure as part of the written procurement procedures
 Avoid the use “blanket” purchase orders –POs must include an itemization
list of articles purchased
7.2 Supplement/Supplant
 Be conscious of supplement/supplant issues
 Purchase of materials and equipment
 Teacher salaries
 Title I funded staff members substituting for teachers
 Title I teachers are used daily to cover teacher planning periods
 Child nutrition program
 Title I funds to support attendance at non-Title I conferences and
trainings for principals
7.3 Indirect Cost
 Use restricted indirect cost amount
 Use appropriate fiscal year’s rate – year in which funds
are expended
 Ensure the amount withdrawn does not exceed the rate
allowable for the amount of funding which has been
expended
7.4 Records of program review (now 7.12)
 Documentation of review of the Title I school programs
 Evidence of an annual mock monitoring
7.5,7.6,7.7 Equipment inventory
 Maintain an updated inventory list, including the following
information:
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description of the item;
serial number;
acquisition date;
funding source and the % of funding from each source;
purchase price;
location; and
condition
 Conduct and document the date of a physical inventory at
least once every two years
7.9, 7.10 Time and Effort
 Maintain time and effort documentation
 Monthly personnel activity reports-reconciled quarterly
 Semi annual certification
7.11 Written contracts
 Contracts are required for any supplemental work paid with
Title I funds (e.g, consulting services, after school programs)
 Required information not on contracts
 Required signatures
 Lack of invoices to accompany contracts
Highly Qualified Teachers
Highly Qualified Teachers
 2.1 Highly Qualified in Title I schools
 2.6 Utilizing 5% set aside for tuition reimbursement
Highly qualified teachers
 Require principals to complete the “Principal’s Attestation
Statement”, annually – LEA director should check for accuracy
 Ensure the amount of time assigned for non instructional
duties for Title I funded professionals and paraprofessionals is
proportional to similar personnel at the same school
 Ensure all teachers in schools supported with Title I funding,
hired after the first day of school in 2002, are highly qualified
at the time of hire
Parent Involvement
Parent Involvement
 4.2 Developing with and distributing to parents- a district
parent involvement policy
 4.3 Training staff to work with parents-this must be
completed at the LEA and also the school level
Parent Notifications
 5.1c Highly Qualified – parent letter
 Provide to each individual parent timely notice that the
parent’s child has been assigned, or has been taught for 4 or
more consecutive weeks by a teacher who is not highly
qualified
Private Schools/Equitable Services
Private Schools
 6.1 Meaningful consultation with private school officials
 6.6 Complaint procedures distributed to the officials of the
private school informing them of the right to complain if the
LEA has not engaged in timely and meaningful consultation
LEA/School Improvement
School and LEA Improvement
 8.5 Using 10% set aside for PD in the school budget
(now 8.6)
 8.7 Making SES available at least twice (now 8.8) Sept. &
Jan.
 8.15 Spending 10% for PD for LEA on improvement
(now 8.17)
Homeless Set Aside
Homeless Set-aside
 9.2a Administration of the homeless set aside
2010-2011 Findings
Title II LEA
2010-2011 Findings
RLIS LEA
Highly Qualified Teachers
Title II
Highly Qualified Teachers
2.2 Reaching 100% HQT
2.3 Implementing an Effective HQT Plan
Reaching 100% HQTs
 Requires an effective HQT plan
 Requires tracking progress toward HQT status
 Requires timely cleanup of HQT reports
 Requires that the county and schools harvest positive culture
and work environments
Implementing an Effective HQT Plan
 Recruiting
 Retention
 Retraining
 Must have a written plan
 Must show evidence of communicating the plan
 Tuition reimbursement policy included as one part of the
overall plan
Professional Development
Title II
Professional Development
3.1 Tracking high quality professional development for core
subject area teachers
 The issue is not tracking professional development
 The challenge is being specific to NCLB definitions
High Quality Professional
Development - NCLB
Must be:
 Based on scientific research
 Based on the needs of the school district
 Sustained and ongoing training(s)
 Review collaboration is provided
Core Subject Areas - NCLB
 English and reading or language arts
 mathematics
 science
 foreign languages
 civics and government, economics, history, geography
 arts (including music, dance, theatre, art, etc.)
 special education (because they teach core subject area
information to students)
Parent Involvement
Title II
Parent Involvement
4.1 Supporting a partnership between schools, parents, and the
community. Soliciting feedback from parents.
Issues:
 Neglecting non-Title I schools
 Not soliciting feedback from parents
Parent Involvement
4.3 Training teachers, service personnel, and principals on
parental involvement
Issues:
 Need one definitive piece of high quality professional
development for parental involvement
 Need enough evidence to show that all groups of
stakeholders were trained
Fiscal Issues
Title II and RLIS
Fiscal Issues
7.1 Reasonable and necessary administrative cost
 Limited to 5% or less for both Title II or RLIS programs
7.2 Supplement and not supplant
 Spend Title II funds only on items required to hold the
professional development session(s)
 Limit CSR expenses to 50% of the total allocation
 CSR student to teacher ratio
 10/1 ratio for students / teachers or aides in Kindergarten
 17 or less students per teacher in grades 1-3
Fiscal Issues
7.4 Keeping records necessary for fiscal audit and program
evaluation
Issues:
 No evidence of a carryover waiver at over 15%
 Coding errors (incorrect project function and object codes)
 Professional Development listed in supplies code
 Salaries and benefits listed in the wrong program function code
 No record of transfers between projects
Fiscal Issues
7.8 Budget Transfers
 Requests are required for all changes of 10% or more from
the allocation as outlined in the online WVEIS budgets
2010-2011 Findings
Title III LEA
Title III Findings
14.2 ESL
instruction
26%
2.8 Highly
Qualified
Personnel
32%
6.1 Private
School
16%
5.2 Parental
Notification
21%
3.2 Professional
Development
5%
Common Findings 2010-2011
 2.8 Highly Qualified Teachers
 ESL Endorsed Teachers need to work with LEP students (Direct
instruction)
 5.2 Parent Notification Letter
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Within 30 day timeline -Better communication to the
principals/schools of the procedures to follow upon the
arrival of an ESL student in the school – notification to
central office to begin testing process
(2 weeks if a child enrolls after the beginning of school)
Including all components required by law
Put graduation time line in the parents notification letter
(only for high school students)
Common Findings 2010-2011
 6.1 Private School
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Notify private schools that they can receive ESL services as
well. Notification can be in the
same letter as Title I letters to the private schools.
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Timely and meaningful consultation
 14.2 (13. 2) High Quality programs (school visits)
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Amount services
Linked to ELP/CSO standards (Content Based ESL)
Grade Placement
Special Education
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Appropriate space
Title III - Recommendations
14.5 WESTELL
13%
14.2 ESL Instruction
13%
6.1 Private School
12%
3.2 Professional Development
62%
Remember…
The West Virginia Department of Education (WVDE)
monitoring process includes the following goals:
 Provide an academic focus for program improvement;
 Promote student achievement; and
 Provide technical assistance to schools and districts in utilizing
federal funding to impact instructional practice and increase
student performance.