PERKINS COMPLIANCE
PREPARING FOR SUPPLEMENTAL MONITORING
Monieca West
ADHE Federal Program Manager
October 19, 2012
COMPLIANCE REVIEWS
Annual Compliance
• Annual
• Routine
• Focus
• Program
• Fiscal
• Accountability
Supplemental Monitoring
• As needed
• Need based on risk
• Risk determined by points
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Grant size
Coordinator tenure
Unused funds
Reimbursement patterns
Programmatic deadlines
Amendment patterns
Improvement plan status
Other compliance areas
ADHE AUTHORITY
PERKINS SEC. 122. STATE PLAN.
• (c) Plan Contents- The State plan shall include
information that-• (11) provides assurances that the eligible agency will
comply with the requirements of this Act and the provisions
of the State plan, including the provision of a financial audit
of funds received under this Act which may be included as
part of an audit of other Federal or State programs
STATE PLAN
• Annual on-site compliance/technical assistance
• Risk management plan
FINANCIAL GOVERNANCE
AUTHORITIES
• The Carl D. Perkins CTE Act of 2006
• EDGAR (Education Department General Administrative
Regulations)
• OMB Circulars (Office of Management and Budget)
• A-87—Cost Principles for State and Local Governments
• A-21—Cost Principles for Postsecondary Educational
Institutions
• Arkansas Perkins State Plan for Career and Technical
Education
• Arkansas Department of Higher Education Policy
Defaults to the most restrictive
SUPPLEMENTAL
MONITORING CHECKLIST
WW W . A D H E P E R K I N S . C O M / F O R M S . H T M L
WWW.ADHEPERKINS.COM
GENERAL ACCOUNTING
• Personnel interviewed:
• Describe how transactions are recorded in the accounting
system.
• Who posts A/R, A/P, general ledger? Who signs checks? Who
reconciles bank statements? How are ETF transactions handled?
• How are purchase discounts, rebates, returns and refunds
accounted for?
• Supporting documents accompany checks to be signed.
• Promptness of recording of transactions.
• Approvals for correcting/adjusting entries.
• Frequency of financial reports.
• Access to accounting records.
• Source documents available for examination
(approval/obligation/payment/reimbursement).
• Previous year audit findings.
PERKINS ACCOUNTING
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Personnel interviewed:
Responsibility for Perkins fiscal management.
Process for classification as Perkins expenditure.
Documentation of cost sharing with other programs/grants.
Perkins coordinator approves all Perkins related expenses.
Frequency of financial reporting to Perkins coordinator.
Authority for expensing to Perkins.
Alignment of Annual Plan budget with institution Business Office
account coding.
Control for supplanting.
Reversing entry process and approvals.
Quarterly comparison of budget to actual and reconciling
amendments if needed.
Control for allocability (CTE limitation/proportionality).
Retention of records (3 years from date of final expenditure report for
given year).
INVENTORY
• Personnel interviewed:
• Adherence to procurement standards, including
competition.
• Process for tracking Perkins funded equipment.
• Complete listing of Perkins funded inventory (item/serial
number/inventory number/acquisition date/location/cost
and % Federal /disposal).
• Items disposed of appropriately.
• Items physically found at location records indicated.
SALARIES AND WAGES
• Personnel interviewed:
• Time and effort documented for Perkins funded salaries
(monthly for multiple cost objectives or semi-annually for
single cost objective).
• PARs reflect after-the fact distribution of actual activity,
account for total employee activity, and signed by
employee and supervisor.)
• Prorated salaries are reconciled quarterly and activity
budgets amended as needed.
• Name of all Perkins funded employees and % Perkins
funding.
CONSORTIA
• Personnel interviewed:
• Memorandum of Agreement in place and signed by
member institutions.
• Distribution of funds is by method other than what institutions
would have received using Pell/BIA formula.
• All member institutions receive benefit.
• Fiscal agent maintains administrative responsibility for
annual plan, reimbursements, accountability and
improvement plans.
• Member agencies provide fiscal agent with information
and documentation necessary to meet program, financial
and accountability requirements.
COMPLIANCE REVIEW
CHECKLIST
WW W . A D H E P E R K I N S . C O M / F O R M S . H T M L
REVIEW ELEMENTS
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I.
II.
III.
IV.
V.
VI.
Program Review
Fiscal Review
Accountability/Program Improvement Review
Other Information/Technical Assistance
Activities Review
Summary/Exit Interview
I. PROGRAM REVIEW
• Personnel interviewed:
• Review how Perkins supports or is integrated into institution’s CTE
improvement activities, including institutions requirement for addressing
Required Use of Funds.
• Review how activities are selected for Perkins funding.
• Review how data is used to determining activity selection and clearly
defining CTE goals.
• Review how special populations and nontraditional students are
supported.
• Review how institution links with secondary programs for seamless transition
from high school to college.
• Review how professional development is funded and targeted.
• Review how institution assesses effectiveness of Perkins funded activities.
• Review consortia issues or concerns, if appropriate.
• Verify current AA page.
• Verify current PoS documentation.
• Review organization and management of Perkins programs and records.
II. FISCAL REVIEW
• Personnel interviewed:
• Review financial management system as related to Perkins, including
quarterly reconciliation.
• Review PARs on file for Perkins funded positions.
• Review documentation of admin funds, including Indirect Cost Rate Letter,
if appropriate.
• Review Perkins inventory management system and physical check of
selected items.
• Review selected expenditures (Annual Plan approval through Request for
Reimbursement).
• Review Supplemental Review areas of concern.
___ Unused Funds
___Late reports
___Results
___Amendments
___Tenure
III. ACCOUNTABILITY REVIEW
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Personnel interviewed:
Review collection and reporting of Special Populations information.
Review collection and reporting of Technical Skills Assessment results.
Review how Perkins performance results are used on campus.
Review historical results and future year targets.
Review progress on Improvement Plans, if appropriate.
IV. OTHER/TECH ASSISTANCE
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Personnel interviewed:
Review collection and reporting of Special Populations information.
Review collection and reporting of Technical Skills Assessment results.
Review how Perkins performance results are used on campus.
Review historical results and future year targets.
Review progress on Improvement Plans, if appropriate.
V. ACTIVITIES REVIEW
• Review progress to date (interview person responsible for implementing
activity)
• Review assessment method tracking
• Review End of Year Program Report from previous year, including
professional development impact
VI. SUMMARY/EXIT INTERVIEW
• Review progress to date (interview person responsible for implementing
activity)
• Review assessment method tracking
• Review End of Year Program Report from previous year, including
professional development impact
• Perkins reauthorization update.
POST REVIEW
• Compliance review summary drafted.
• If there are findings, coordinator is given a chance
to review.
• Report uploaded to Portal and coordinator notified.
• Written Compliance Review Report provided to
president/chancellor.
PREPARING FOR VISIT
• Review the checklist and anticipate the discussions.
• Have appropriate staff available.
• Perkins Team representation
• Business office
• Lead person for each funded activity
• Have Perkins documents available.
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Financial documents
Inventory records and access arranged
PARs
Program of Study documentation
Indirect cost rate letter
Improvement plan progress
QUESTIONS
MONIECA.WEST@ADHE.EDU
BRINDA.BERRY@ADHE.EDU