Report 2012-044 Recommendation 1 Responses

Report 2012-044: California Department of Education: Despite Some Improvements, Oversight of the Migrant Education Program Remains Inadequate (Release Date: February 2013)

Recommendation #1 To: Education, Department of

To minimize the potential for disagreement over allowable migrant program costs, Education should better define the criteria by which it will consider program costs allowable and include those criteria in the migrant program fiscal handbook it provides to the regions.

Annual Follow-Up Agency Response From October 2015

Education completed the revision of the Migrant Education Program Fiscal Handbook (MEPFH) in June 2015, posted the final MEPFH on the Web, and provided a Web-based presentation to subgrantees (regions and direct-funded districts). The MEPFH includes information on: (1) allowable program costs; (2) clear definitions of administrative costs; (3) direct services and Migrant Education Program (MEP)-unique administrative costs; (4) new citations to align with the updated Uniform Grants Guidance; and (5) the use of funds for, but not limited to, administrative salaries, procurement, meetings, food, travel, conferences, field trips, capital outlay, and property.

In Fiscal Year 2015-16, Education plans to execute a series of three to five in-depth Webinars to fully explain each section of the MEPFH.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2014

To minimize the potential for disagreement over allowable migrant program costs, Education is developing a Migrant Education Fiscal Handbook (MEPFH). In June 2014, Education convened a stakeholder group comprised of county and district fiscal staff, as well as Migrant Education Program regional directors, to review the draft of the MEPFH. The MEPFH will include: 1) an updated list of accounting codes; (2) criteria for allowable program costs; and (3) general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH will also address capital outlay and property, including criteria for capital purchases such as vehicles and other equipment. Education plans to complete the final MEPFH by December 2014.

California State Auditor's Assessment of Annual Follow-Up Status: Not Fully Implemented

1-Year Agency Response

Education is in the final stages of updating the Migrant Education Program Fiscal Handbook (MEPFH). The revised MEPFH includes criteria for allowable program costs and general guidelines pertaining to supplement-not-supplant, meetings and trainings, travel, conferences, food, field trips, and other areas. The revised MEPFH also addresses capital outlay and property, including criteria for capital purchases such as vehicles and other equipment. Education plans to obtain input on the MEPFH from county and district fiscal staff, as well as Migrant Education Program (MEP) regional directors, in the spring of 2014.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

Criteria for allowable program costs have been improved. Education and the Migrant Education Intervention Team developed guidance with criteria defining allowable types of expenditures. This guidance will be presented to the regional directors for implementation during fiscal year 2013-14. This guidance will also be incorporated into the migrant grant award notification letters and the upcoming revised Migrant Education Fiscal Handbook (see Enclosure A, draft of Fiscal Handbook Ch. 7: Allowed Uses).

In addition, Education is currently updating the District Service Agreements (DSAs) and the Regional Applications (RAs) for FY 2013-14. The updates include guidance regarding specific policies and criteria on services and processes for supplement and supplant. Education is following the Migrant Education Program (MEP) Guidance from the U. S. Department of Education's Office of Migrant Education (OME) (Chapter V, A7) in the review and evaluation of DSAs and RAs to ensure that state educational agencies use a wide variety of service delivery designs, including extended day programs, before/after school programs, in-class program (with prior Education approval), Saturday programs, in-home instruction (with prior Education approval), summer/intersession programs, and distance learning programs.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Education and the Migrant Education Intervention Team are working collaboratively with the migrant regions to identify the specific expenditure classifications that may need enhanced approval criteria. As an example, in the current District Service Agreement and the Regional Application for fiscal year 2013-14, guidance regarding specific policy and criteria on supplemental services and processes for supplement and supplant has been updated to align with federal guidance. Education will incorporate the updated guidance in the upcoming revised Migrant Education Fiscal Handbook.

California State Auditor's Assessment of 60-Day Status: Partially Implemented

All Recommendations in 2012-044

Agency responses received after June 2013 are posted verbatim.