Bureau of Indian EducationDivision of Performance

and AccountabilityFISCAL MANAGEMENT

Special Education FundsSY 2014-15 Fiscal Risk Level

Webinar – January 7, 2016

To provide information on BIE,DPA Special Education Fiscal Management

To provide the 2014-15 Desk Audit findings

To initiate technical assistance to the schools

To provide a time for schools to request clarification, ask questions and provide input to delivery of technical assistance and training

The purpose of the training is:

Training and information continues to be shared via webinars, emails, conference and phone calls

Due dates were adjusted to accommodate changes

Turn around of school staff

Native Star continues as the process to submit documents

FDD

Understanding of CEIS

Challenges for SY 2014-15

I. Overview

The Fiscal Monitoring Procedures for Special Education ensures a school’s compliance to certain fiscal and administrative requirements for special education funds, 15% ISEP Academic base funds and IDEA Part B Supplemental Funds. Part B funds are allocated to the schools for excess costs of special education and related services and to supplement the ISEP 15% Academic base fund.

The school submits an application that provides assurances that the school will meet the requirements of Public Law 108-446

Fiscal Monitoring for Special Education

The procedure is established to ensure: Program and fiscal policies and procedures are

developed and implemented to meet certain fiscal and administrative requirements;

Appropriate use of special education funds for the intended purpose, Free and Appropriate Public Education (FAPE) in the Least Restrictive Environment (LRE);

Problems are identified and remediated; and

Oversight is provided that would result in improved student outcomes.

Fiscal Monitoring for Special Education

Each school submits all fiscal documents in the Native Star link on the BIE website with the exception of the Unmet Needs Request. Each document, with a timeline, is used for the fiscal desk audit completed on each school in June.

II. Process

1.The BIE reviews and rates the following fiscal documents: Local Education Agency LEA/School Part B

Application and if applicable, the Coordinated Early

Intervening Services (CEIS) Plan;

BIE Web Budget, BIE Operated Schools only; or Consolidated School-Wide Budget, Tribally Controlled Schools (TCS) only;

Fiscal Accountability Self-Assessment (FASA)

A. Desk Audit

2. Fiscal findings of noncompliance identified during the desk audit process for which no written findings are issued, the following will apply:

◦ A) The school will be issued a warning notification for instances of noncompliance related to IDEA fiscal requirements

◦ B) Targeted technical assistance will be provided to ensure instances of noncompliance are corrected within 30 school days of identification.

A. Desk Audit Cont.

◦ C) Findings of noncompliance corrected by the school will be verified through the review of the school’s required upload of fiscal evidence in Native Star or Native American Student Information System

◦ D) Findings of noncompliance not corrected by the school within 30 calendar days will result in a written notification

A. Desk Audit

3. The IDEA Fiscal Risk Level Scoring Sheet is used to communicate to the schools the risk level for each school

Low Risk: minimal concerns identified for meeting fiscal and administrative requirements

Medium Risk: concerns identified for meeting fiscal and administrative requirements

High Risk: numerous concerns identified for meeting fiscal and administrative requirements

Fiscal Risk Level

4. Written notification of risk level is issued to the school

5. Targeted technical assistance is provided to medium and high risk level schools

Fiscal Risk Level Cont.

An on-site visit provides an intensive level of fiscal review, and is the result of continuing violations of federal and IDEA fiscal requirements

B. On-Site Fiscal Review

1. Criteria – if a school meets two of the five are used to identify a school for an on-site fiscal review:

Late submission or incomplete LEA/Part B application

High risk level for current and preceding years;

Administration Financial Reviews (BIE Operated Schools);

Recommendation for an on-site fiscal review from the Integrated Accountability and Support (IA&S) monitoring report;

Indian Student Equalization Program (ISEP) Special Education Certification submitted by the Education Line Office (ELO) that identifies findings of noncompliance; and/or

Administration Financial Reviews (BIE Operated Schools) or Annual Report (Tribally Controlled Schools) or A-133 (Tribally Controlled Schools)

B. On-Site Fiscal Review Cont.

2. Written notification of an on-site fiscal review is sent

3. On-Site Fiscal Review Activities: Entrance meeting Demographic data and budget FASA and Fiscal Rating Verification of expenditures Evaluation of fiscal review process Exit meeting

B. On-Site Fiscal Review Cont.

4. Analysis of data collected during the on-site fiscal review

5. Written report (also referred to as the written notification) issued to the school within 90 days of an on-site visit to inform of the intensive review results and if applicable, findings of noncompliance and corrective action.

B. On-Site Fiscal Review Cont.

BIE identifies and corrects finding(s) of noncompliance as follows:

A. Schedule conference call with school(s) within 15-days of written report:

◦ Review findings of noncompliance◦ Provide clarification/guidance◦ Review correction process

III. Fiscal Findings of Noncompliance and Correction

B. Conduct quarterly progress checkpoints

C. Ensure timely correction on noncompliance School corrects within required timeline

BIE verifies correction of noncompliance BIE issues close-out letter within 30-days of verification

School does not timely correct; placed in continuing status of noncompliance BIE issues written notification BIE applies enforcement BIE verified correction BIE issues close-out letter within 30-days of verification

Fiscal Findings of Noncompliance and Correction Cont.

The data from the desk audit and on-site fiscal review activities are analyzed and summarized to examine patterns and trends. The BIE offers training and targeted technical assistance to ensure fiscal resources are directed to areas needing improvement.

IV. Data Analysis

An evaluation is performed to assist the BIE in improving the fiscal monitoring procedures, activities include:

School completes post-fiscal review evaluation form

BIE assembles representatives from the BIE Administration, BIE Advisory Board for Exceptional Children, ELO staff and schools to evaluate the fiscal monitoring process.

V. Evaluation

School Part B Application: 3 Points Timely submission (1) Complete application (1) Signature after School Board Approval (1)

BIE Web Budget/Consolidated S W Budget◦ K-8 Schools (19)◦ K-12 Schools (23)

FASA (45)

CEIS (8)

Desk Audit Process

Regions

# Low Risk Schools

#Medium Risk

Schools

#High Risk Schools

TotalNumbe

r of School

s2014-15 2013-14 2014-15 2013-14 2014-15 2013-14

East 1 1 21 25 33 29 55Navajo 1 1 20 20 40 40 61West 2 2 16 16 42 42 60Total 4 4 57 61 115 111 176

Fiscal Risk Desk Audit School Results

Timely submission of the budget with appropriate signatures?

Were there adequate allocations and justification provided to support the allocation? Fulltime Equivalency's (FTE) for personnel

(Student/Teacher Ratio Paraprofessionals Special Education Teacher Supplies, materials,

equipment and assistive technology

Budget Reviews

◦ Professional Development for total school staff, for special education staff, and/or provided based on needs of individual SWD.

Transportation as a related service for SWD

Parent Training

Child Find Activities

Least Restrictive Environment (LRE) placements in settings away from the school (incarceration, intensive specialized instruction or therapy, illness of student)

Budget Reviews Cont.

Most schools demonstrated appropriate use of Special Education funds in the following areas: Transportation Personnel

Related Services Special Education Teachers

Majority of schools provided Budgets Few entries of “Inappropriate and Non Allowable

Costs” Understanding the definition of Allowable Cost Utilization of the Allowable Cost Document

Budget Analysis

Questionable CostsBudget ItemParent Training

Assistive TechnologyChild Find

Equipment Materials Supplies

Staff TrainingSecondary Transition

SpecialistWork Study Programs

Areas of improvement: The upload documents into Native Star

Internal controls – describing the process for monitoring internal

controls. Separation of duties Assessing of fiscal risk as it relates to theft &

embezzling

Travel and training input of staff who attended, position and purpose

FASA Analysis

Carryover

Inventory and safeguard to ensure fraud is not occurring

Special education coordinator/lead teacher not involved in the verification of purchase of supplies, and contracts.

Justification of unusual items

Schools will be issued findings of noncompliance if there are violations of IDEA requirements.

FASA Analysis

Regions Low Risk Medium Risk

High Risk Total

East 13 4 0 17Navajo 4 0 0 4West 4 2 1 7

TOTAL 21 6 1 28

Coordinated Early Intervening Services (CEIS) Data

Schools will be issued findings of noncompliance if there are violations of IDEA requirements.

Schools received a score of 0 because: a CEIS Plan was not submitted or was not submitted

by the due date;

CEIS Cont.

The CEIS rating was based on the following (8 pts): The Part B allocation was below the 15% Part B threshold (1pt)

The “Responsible Person” for CEIS at the school was identified (1pt)

The “targeted audience” was identified (1pt)

The School’s CEIS program was described (0-2 pts)

The number of student participants was provided (1pt)

The entrance and exit tools and criteria were provided (0-2pts)

CEIS Cont.

Examples of topics Procedural Safeguards (Individuals with Disabilities

Education Act) Overview of Special Education procedures &

processes Parenting a child with a disability Overview of the Individualized Education Program

(IEP) Developing your child’s IEP Supplementary aids & services; accommodations &

modifications; Assistive Technology Nurturing Self-determination

TECHNICAL ASSISTANCEParent Training

Assistance is available for parents 100 Parent Centers across the nation at least one

is located in each state

Sometimes they are referred to as Parent Training and Information Centers (PTIs) and/or Community Parent Resource Centers (CPRCs)

They help parents to participate effectively in the education of their children at school and at home, thereby improving outcomes for children with disabilities

Parent Training Cont.

Native American Parent Technical Assistance Center (NAPTAC): Education for Parents of Indian Children with Special Needs (EPICS)

Parent Training Cont.

Assistive technology devices or services, or both, are made available to a child with a disability if required as part of the child’s special education, related services, or supplementary aids and services.

The child’s IEP team determines if an assistive technology service and/or devise is necessary for the child to benefit from his or her education program

There are a broad range of assistive devices: Low-tech examples: pencil grips, highlighters, paper

stabilizers, magnifiers, books on tape High-tech examples: computers, computer based assistive

technology, voice synthesizers, Braille readers

Assistive Technology (AT)

Accommodations/Modifications ExampleSkill Area: Written ExpressionAccommodations:

Method Material TechnologyAccept outlines or notes to reduce written workCreate sentences aloudDo not grade for spellingExtra time for completionProcess reminders on chalkboard or desk Provide writing sampleShorten assignments Study carrel for solo work

Pocket dictionaryPocket thesaurusProcess reminders on chalk board or desk

Electronic dictionaryElectronic thesaurusSpell checkUse computer or word process for writingUse tape recorder to do assignments verballyWord Prediction software

There are many: Alliance for Technology Access Resource Centers

National Center for Learning Disabilities Parent Training and Information Centers

Alliance for Technology Access Resource Centers http://www.ataccess.org

Center for Innovation in Learning http://www.edutopia.org/article/assistive-technology-resources

Education World www.educationworld.com

AT Cont.

is a component of the Individuals with Disabilities Education Act that requires States and Local Education Agencies to identify, locate, and evaluate all children with disabilities residing in the State, regardless of the severity of their disabilities, and who are in need of special education and related services.

is a continuous process of public awareness activities,

screening and evaluation designed to locate, identify, and evaluate children with disabilities who are in need of Early Childhood Intervention Programs or Special Education and Related Services

Child Find

Examples of Child Find activities: The school publishes a child find notice in the local

newspaper or the school’s newsletter school participates in conjunction with community

agencies such as HeadStart, preschool services, and other area preschools; Child find notices are sent to all area clinics, doctors, preschools and daycare centers in conjunction with preschool screening activities

All children entering kindergarten are screened to identify children with suspected disabilities

Child Find Cont.

The files of all children transferring to the school are screened to identify children who may have been receiving special services in their prior school

Parents of older children who enter the school for the first time are given a document, which explains the school’s special services and who to contact if they suspect their child may have a disability

For children attending the school ages 5 to 21, the primary child find process is parent and teacher referrals. In-service activities to assist teachers in making appropriate referrals are provided annually

Child Find Cont.

The school student services team reviews the files of all students with a health plan to screen for suspected disabilities

Student Assistance Team (other names may be used) ensure appropriate interventions have been utilized to help the student overcome their learning problems before beginning a referral for special education services

Child Find Cont.

Child find is integrated with ESEA: Under ESEA, each LEA (school) must have an improvement plan developed to guide school and staff in the improvement of student performance for all student groups in order to attain state standards. The school improvement plan must include strategies for improvement of student performance such as: instructional methods designed based on the needs of student groups not achieving; processes for addressing the needs of children in special programs; integration of technology in instructional and administrative program; positive behavior supports; staff development for educators; and accelerated instruction

Child Find Cont.

Conduct school data analysis to determine improvement needs in the following areas: Equipment, supplies, materials Staff Training

Include training on School Records and Confidentiality; Family Educational Rights and Privacy Act (FERPA)

Secondary Transition

Plan, Plan, Plan

Gloria Yepa (505) 563-5264gloria.yepa@bie.edu

Laura N. Tsosie (505) 563-5275laura.tsosie@bie.edu

Connie Albert (505) 563-5180connie.albert@bie.edu

Contact Information