Report 2012-044 Recommendations and Responses in 2014-041

Report 2012-044: California Department of Education: Despite Some Improvements, Oversight of the Migrant Education Program Remains Inadequate

Department Number of Years Reported As Not Fully Implemented Total Recommendations to Department Not Implemented After One Year Not Implemented as of 2013-041 Response Not Implemented as of Most Recent Response
California Department of Education 1 16 13 n/a 13

Recommendation 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.

Response

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.

Recommendation To: Education, Department of

To improve its understanding of regional expenditures, Education should increase the level of detail required in its quarterly expenditure reports. The level of detail should allow Education to select expenditures for review.

Response

Education considers this recommendation fully implemented. As reported in Education's one-year response dated March 24, 2014, the quarterly expenditure reports have been redesigned to reflect the new, more detailed, Regional Application (RA) and District Service Agreement (DSA) budget formats. The expenditure reports provide detailed region expenditures by object and resource codes to align with the approved budget expenditures in the RA. The increased level of detail will be utilized by Education to evaluate expenditures for adherence to federal administrative cost principles.

Recommendation To: Education, Department of

For regions that have not recently received a federal monitoring review, Education should use the detailed expenditure reports to select a sample of expenditures, request supporting documentation from the regions, and then review the expenditures to determine if they meet applicable federal and state criteria.

Response

Education is currently developing a multi-year plan to monitor the expenditures of regions not selected for federal monitoring review. This monitoring plan will be included in the revised MEPFH that will be finalized in December 2014. Monitoring of expenditure reports will include: (1) selecting a sample of expenditures; (2) requesting supporting documentation from the regions; and (3) reviewing expenditures to determine compliance with applicable federal and state criteria. In addition, Education's detailed reviewer checklist ensures that all appropriate signatures and approvals are obtained prior to release of program funds.

Recommendation To: Education, Department of

As part of the reviews based on quarterly reports, Education should verify that regions are using the appropriate accounting codes to classify their expenditures.

Response

Education considers this recommendation fully implemented. As reported in Education's one-year response dated March 24, 2014, The quarterly expenditure reports have been redesigned to reflect the new, more detailed, RA and DSA budget formats. The expenditure reports provide detailed region expenditures by object and resource codes to align with the approved budget expenditures in the RA. The increased level of detail will be utilized by Education to verify that regions are using the appropriate accounting codes to classify expenditures.

Recommendation To: Education, Department of

To address problems with its methodology for calculating administrative costs, Education should review the regions' current use of accounting codes to identify the areas in which regions differ in accounting for similar migrant program costs.

Response

As reported in Education's response update to CSA Recommendation No. 1, to facilitate consistency and more guidance to regions, the revised 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 also addresses 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.

Recommendation To: Education, Department of

To address problems with its methodology for calculating administrative costs, Education should provide regions with more specific direction about how to charge these expenses.

Response

As reported in Education's response update to CSA Recommendation No. 1, to facilitate consistency and more guidance to regions, the revised 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 also addresses 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.

Recommendation To: Education, Department of

To address problems with its methodology for calculating administrative costs, Education should revise its list of accounting codes that it considers administrative in light of its review of regional coding.

Response

As reported in Education's response update to CSA Recommendation No. 1, to facilitate consistency and more guidance to regions, the revised 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 also addresses 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.

Recommendation To: Education, Department of

Once it has addressed the underlying issues with regional accounting, provided direction to regions about which expenditures it will consider administrative, and obtained accurate expenditure data, Education should review its administrative cost goal to ensure that this goal is reasonable given the requirements of the migrant program.

Response

To address the underlying issues with regional accounting for expenditures, in addition to the new MEPFH, Education is developing administrative cost guidance to the regions. This guidance will consider factors such as: (1) 2013-14 fiscal year expenditure report data; (2) local educational agency indirect cost rates; (3) individual regional administrative constraints; and (4) guidance from the federal Office of Migrant Education (OME).

To ensure the majority of MEP funding is utilized for direct MEP services and activities, Education has established a "15 percent or below" administrative cost percentage as a reasonable goal. Administrative cost percentages can be calculated from the regional Summary Budget Worksheets by dividing the total administrative cost by the total budget amount. If a region is found to have incurred excessive administrative costs, Education requires the region to submit an "Action Plan to Reduce General Administrative Costs" delineating specific actions to reduce administrative costs down to 15 percent or less over the following two fiscal years.

Recommendation To: Education, Department of

To address past federal findings that are not yet resolved, Education should respond as recommended in Appendix B of this report.

Response

Education considers this recommendation fully implemented. Education worked directly with the OME to resolve past audit findings. OME letters indicating the resolution of past audit findings will be sent separately to the CSA.

Recommendation To: Education, Department of

To determine if the statewide migrant education program is effective, Education should finalize its current evaluation of the program and begin developing the capacity to produce a more robust annual evaluation of the program.

Response

Education completed the evaluation of the migrant program and is in the process of implementing two projects that will lead to a more robust annual evaluation. The first project focuses on regular data exchanges between the Migrant Student Information Network and the California Longitudinal Pupil Achievement Data System (CALPADS). This data exchange will facilitate the acquisition of statewide migrant student assessment data, and ensure that eligible migrant program students are identified in CALPADS.

The second project is the implementation of the first phase of a statewide Comprehensive Needs Assessment. In 2014-15, the migrant regions will conduct local assessments that will identify program needs. These assessments will also allow Education to identify performance targets with measurable objectives. In the forthcoming State Plan for Services, Education will ensure that identified performance targets can be measured and migrant student data is available to conduct the analysis.

Recommendation To: Education, Department of

To address a lack of detailed migrant program service and outcome data, Education should either expand the capabilities of its existing statewide databases or implement additional systems that would allow regions to capture more detailed data about migrant students.

Response

Education plans to conduct a study of viable data improvement solutions. The results of this endeavor will enable Education to make a determination as to expanding the capabilities of statewide databases or acquiring additional systems that will allow regions to capture more detailed migrant student data.

Recommendation To: Education, Department of

To ensure that it receives satisfactory services and outcomes for the funds spent on statewide contracts for the migrant program, Education should develop and execute a plan to monitor each of its contracts and cancel any it determines do not provide adequate or cost-effective services.

Response

Education considers this recommendation fully implemented. Education's Migrant Education Intervention Team (Team) completed reviews of MEP contracts for statewide services and provided recommendations regarding the adequacy and cost-effectiveness of each contract. Based on the work of the Team, Education cancelled contracts that did not demonstrate cost-effectiveness and/or adequate services. In addition, Education is providing contract administration and monitoring training to all staff that oversee contracts; all staff are targeted to be trained by December 2014.

Recommendation To: Education, Department of

To demonstrate its willingness to fairly evaluate regional expenditures, Education should allow San Joaquin to reimburse its general fund for the vehicle purchase Education incorrectly disallowed.

Response

Education does not concur with this recommendation. Education conducted an independent and unbiased review of San Joaquins migrant expenditures with the objective of determining whether costs charged to the migrant program are reasonable, necessary, and properly supported in accordance with federal requirements. Based on the documentation provided by San Joaquin, Education disallowed a significant portion of the vehicle due to incomplete, or lack of, information contained in the mileage logs. However, as previously stated, Education did allow mileage for those trips on the logs that clearly documented that the trips were specific to the migrant program.

As stated in Educations status update for Recommendation No. 1, the revised MEPFH requires effective internal control and accountability over travel and capital purchases, including the documentation for vehicle usage and maintaining adequate mileage logs.

Current Status of Recommendations

All Recommendations in 2014-041