APRIL 2014 93.235 ABSTINENCE EDUCATION BLOCK GRANT PROGRAM ABSTINENCE EDUCATION (PRC 101) State Project/Program: U. S. Department of Health and Human Services Federal Authorization: Social Security Act Title V, Section 510(b), 42 U.S.C. 710(b) State Project/Program: N. C. Department of Public Instruction Agency Contact Person Confirmation Address Letters To: Program Ellen Essick, Section Chief NC Healthy Schools Ellen.essick@dpi.nc.gov (919) 807-3859 Gene Bruton, Accountant N.C. Department of Public Instruction Division of School Business Monitoring and Compliance Section Education Building 6334 Mail Service Center Raleigh, NC 27699-6334 (919) 807-3726 Financial Gene Bruton, Accountant Monitoring and Compliance Gene.Bruton@dpi.nc.gov (919) 807-3726 The auditor should not consider the Supplement to be “safe harbor” for identifying audit procedures to apply in a particular engagement, but the auditor should be prepared to justify departures from the suggested procedures. The auditor can consider the supplement a “safe harbor” for identification of compliance requirements to be tested if the auditor performs reasonable procedures to ensure that the requirements in the Supplement are current. The grantor agency may elect to review audit working papers to determine that audit tests are adequate. I. PROGRAM OBJECTIVES The purpose of the Abstinence Education project is to enable the State to provide abstinence education, and at the option of the State, where appropriate, mentoring, counseling, and adult supervision to promote abstinence from sexual activity, with a focus on those groups which are most likely to bear children out-of-wedlock, such as youth in or aging out of foster care. II. PROGRAM PROCEDURES DPI allocates funds to up to 19 of the 115 local education agencies and eligible Charter Schools, identified as “Priority LEAs”, to implement the legislative priorities of the funding. Priority is determined based on high rates of 1) teen pregnancy, 2) teen birth, 3) children aged 0-17 in foster care, 4) free and reduced lunch eligibility, and 5) other academic risk factors. III. COMPLIANCE REQUIREMENTS NC Department of Public Instruction (DPI) mandates that all testing in the DPI CrossCutting Requirements be performed by the local auditor. Please refer to Cross-Cutting Requirements DPI-0. B-4 93.235 1 ABSTINENCE EDUCATION (PRC 101) A. Activities Allowed or Un-allowed Compliance Requirement – Funds from this grant must be used to develop an abstinence education program that does the following: (a) has as its exclusive purpose, teaching the social, psychological, and health gains to be realized by abstaining from sexual activity; (b) teaches abstinence from sexual activity outside of marriage as the expected standard for all school age children; (c) teaches that abstinence from sexual activity is the only certain way to avoid out-ofwedlock pregnancy, sexually transmitted diseases, and other associated health problems; (d) teaches that a mutually faithful monogamous relationship in the context of marriage is the expected standard of human sexual activity; (e) teaches that sexual activity outside of marriage is likely to have harmful psychological and physical effects; (f) teaches that bearing children out-of-wedlock is likely to have harmful consequences for the child, the child’s parents, and society; (g) teaches young children how to reject sexual advances and how alcohol and drug use increases vulnerability to sexual advances; and (h) teaches the importance of attaining self-sufficiency before engaging in sexual activity. Audit Objectives – Determine that funds were spent in accordance with an abstinence education program that complies with the approved State Plan and supports the eight specified spending criteria. Suggested Audit Procedures: Test expenditures and related records to determine if expenditures were made only for allowable services. Examine expenditures for appropriate approval and documentation. Determine that personnel paid from these funds do not exceed budgeted personnel in the approved program budget. See State Public School Fund guidelines for salary audit requirements. B. Allowable Costs/Cost Principles Addressed in the NC Department of Public Instruction Cross-cutting Requirements. B-4 93.235 2 ABSTINENCE EDUCATION (PRC 101) C. Cash Management Addressed in the NC Department of Public Instruction Cross-cutting Requirements. E. Eligibility Eligibility for Sub recipients – Priority is determined by ranking counties using published State and local data on teen pregnancy, teen births, children aged 0-17 in foster care, free and reduced lunch eligibility, and academic risk factors. No testing is required. Eligibility for Individuals – This compliance requirement does not apply at the local level. No testing is required. F. Equipment and Real Property Management Addressed in the NC Department of Public Instruction Cross-cutting Requirements. G. Matching, Level of Effort, Earmarking 1. Matching Compliance Requirement - The Abstinence Education Program’s funding is comprised of Federal funds (Federal share) through a Block Grant. The State of North Carolina is required to match these federal funds 3:4. This match is the responsibility of the State as a whole, and not just programs participating in the federal program. Only non-federal funds can be used to support this match requirement. Audit Objective - To verify LEAs keep matching records for the Abstinence Education Program. Suggested Audit Procedures: Verify records that support any in-kind contributions counted toward satisfying the local grantee contribution. Verify that reports of matching expenditures were submitted to DPI and supported by appropriate documentation. H. Period of Availability of Federal Funds Compliance Requirement – Expenditures may not be incurred before the beginning date of the project. Audit Objective – Determine that no expenditures were incurred prior to the beginning date of the approved project. Suggested Audit Procedures: B-4 93.235 3 ABSTINENCE EDUCATION (PRC 101) I. Review transactions to verify that no expenditures were incurred prior to the approved application beginning date. Procurement and Suspension and Debarment Addressed in the NC Department of Public Instruction Cross-Cutting Requirements N. Special Tests and Provisions Addressed in the NC Department of Public Instruction Cross-cutting Requirements. B-4 93.235 4