Pre-Award Risk-Based Assessment Mphande - Pre-Awar… · Risk Level Monitoring Guidelines Risk...
Transcript of Pre-Award Risk-Based Assessment Mphande - Pre-Awar… · Risk Level Monitoring Guidelines Risk...
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Pre-Award Risk-Based Assessment
Tawanna Fields-Mphande October 14,2016
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Overview
• Pre-Award Risk-Based Assessment Process
• Risk-Based Assessment Timeline
• Agency-Wide Compliance & Monitoring
Updates
• Resources
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Risk-Based Assessment
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The Law
• The Uniform Guidance (Super Circular)
requires all Pass-Through entity to conduct a
risk-based assessment prior to making
awards. (OMNI Federal Circular §200.331)
• To comply with this requirement, the Office of
Career Technical Education will conduct an
annual risk assessment of all Perkins
recipients.
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Required Monitoring Activities
Framework for evaluating risks before applicant
receives funding:
• Financial stability
• History of performance
• Reports from single-audit findings
• Applicant’s ability to effectively implement
statutory, regulatory or other requirements
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Risk-Based Assessment
The risk-based assessment process is
designed to conduct a more thorough review
for Perkins recipients with higher risk factors.
The risk-based assessment review identifies
potential problems that could lead to risks in
the accountability, fiscal accounting and grant
operations.
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Purpose and Intent
Provide preventative assistance before
mistakes are made
Increase efficient use of resources &
transparency
Reduce, waste, fraud & abuse
Ensure that subrecipients use federal funds
for the intended purpose
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Criteria Selection Process
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Criteria Selection Process
Just kidding!
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Criteria Selection Process
Risk-based assessment criteria used to
determine risk for FY17 districts (2016-2017
school year):
• Previously non-compliant;
• Failure to meet accountability measures;
• New career-technical education personnel;
• Failure to meet required deadlines; and
• Single Audit Findings.
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Pre-Award Risk-Based
Assessment Tool
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Assessment Tool
High
Medium
Low
Based on the results of the risk-based assessment tool, all districts will be categorized as high, medium or low risk.
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Risk-Based Assessment Tool
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Assessment Scores
0 to 1 points low risk
2 to 3 points medium risk
4 to 7 points high risk
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Risk LevelsRisk Level Monitoring Guidelines Risk Levels
High(4-7)
Required to submit detailed financial reports such as general ledgers, supporting documentation and performance reports. On-site monitoring will be at the discretion of the education program specialist.
Medium(2-3)
Required to receive additional targeted assistance. Required attendance at trainings/conferences. Follow-up with district via phone audit review.
Low(0-1)
No known programmatic, financial instability or significant audit findings. No significant program changes. The district shall receive technical assistance upon request.
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FY18 Pre-Award Risk Assessment Timeline
May 2017
High-Risk
Districts Notified
April 2017
Pre-Award Risk
Assessment
June 2017
Monitoring
Guidelines
implemented
July 2017
Funds allocated to
field
Note: The timeline is contingent on the availability of data.
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Agency-Wide Updates
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Pre-Award Risk-Assessment
Agency-Wide Process1
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Agency-Wide Process
• All federal programs are required to
implement the risk-assessment process.
• Each departments process is unique to their
grant.
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Program Monitoring
Agency-Wide Process2
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Monitoring • Working collaboratively to reduce our foot-
print in the field.
• In FY16:
– There were a total of 112
districts/organizations with overlap
–Team approach – 107 onsite/desk review
and 5 with desk review only overlap
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Compliance Dashboard3
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New Compliance Dashboard
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In Summary
• A high-risk assessment score should
NEVER be interpreted as a negative
reflection.
• Technical assistance will be provided
• FY2017 districts were notified in August,
2016
• Notification of high-risk will be sent via the
CCIP and email to the Superintendent
• Compliance dashboard coming soon!
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Resources
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Scheduled to be Monitored
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Additional Resources• Carl D. Perkins Career and Technical Education Act of 2006
http://www.fldoe.org/workforce/perkins/pdf/Perkins_IV_text.pdf
• U.S. Office of Management and Budget (OMB) Circulars
http://www.whitehouse.gov/omb/circulars/
• Education Department General Administrative Requirements
(EDGAR)
• http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html
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Resources• Subpart A – Acronyms & Definitions (§200.0 -§200.99)
• Subpart B – General Provisions (§200.100 - §200.113)
• Subpart C – Pre-Federal Award Requirements and
Contents
• of Federal Awards (§200.200 - §200.211)
• Subpart D – Post-Federal Award Requirements
Standards for
• Financial and Program Management (§200.300 -
§200.345)
• Subpart E – Cost Principles (§200.400 - §200.475)
• Subpart F – Audit Requirements (§200.500 - §200.521
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Miguel Ruiz
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education.ohio.gov
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Social Media
@OHEducation
@OHEducationSupt
OhioFamiliesAndEducation
OhioEdDept