Of Federal Funds Under The

Bureau of Indian Education

Fiscal Review

of Federal Funds Under the

Elementary and Secondary Education Act and the Individuals with Disabilities Education Act

[Insert Date Here]

[Insert School Name Here]

REPORT

Table of Contents

I. Executive Summary 1

II. School Profile and Funding 2

III. Background 5

A. Program Purpose 5

B. Methodology 5

IV. Fiscal Review 7

Part I: Financial Systems and Processes 7

A. Budget Development 7

B. Purchasing and Procurement 8

C. Accounting and Timekeeping Systems Policies 10

D. Bank Deposits, Inventory and Equipment 11

E. A-133 Audit Findings 12

Part II: ESEA and IDEA Fiscal Compliance 13

A. ESEA Title I, Part A Funds 13

B. ESEA Title II, Part A Funds 18

C. Special Education Funds (IDEA, Part B and 15% ISEP Set Aside) 19

V. Reviewer Contact Information 26

Appendix A 27

201X-1X BIE FISCAL REVIEW / [Insert School Name Here]

I.  Executive Summary

The Executive Summary will collectively describe the school’s fiscal strengths, findings and the BIE team’s recommendations in the following areas:

Financial Management

o  Budgeting Systems

o  Accounting and Timekeeping Systems

o  Internal Controls

o  A-133 Findings on systems

Expenditures and Budget Alignment during SY 2013-14 of:

o  Title I, Part A

o  Title I, SIG 1003(g)

o  Title II, Part A

o  Title IV

o  Title X

II.  School Profile and Funding

The School Profile will highlight the following areas:

·  Name of School

·  Type of School Operation (e.g. Tribal or BIE Operated)

·  Most Recent AYP Status and Year

·  ADD Region

·  Chief School Administrator

·  Finance/Business Manager

·  Number of Students

·  Grades Served

·  Funding Per Pupil for SY 2013-14

·  Number of Teaching/Instructional Positions (Budgeted-Current Year)

·  Number of Non-Teaching Support Positions

School funding information for each program is listed below. BIE-operated and tribally controlled schools receive funding through both the U.S. Department of the Interior and the U.S. Department of Education. Zero amounts indicate that the school did not receive funding for the specified program.

Department of the Interior Funding
Instructional Funding Source / Descriptions of Funded Programs / SY 2013-14 / SY 2014-15
Indian School Equalization Program (ISEP)
[Special Education (15% ISEP)] / This program funds for primary and secondary education. Funds may be used for the education of Indian children in BIE-funded schools. Funds may not be used for construction. Fifteen percent of ISEP funds are reserved for Special Education purposes. / $XXX,XXX / $XXX,XXX
Department of Education Funding
Instructional Funding Sources / Descriptions of Funded Programs / SY 2013-14 / SY 2014-15
Title I, Part A, Sec. 1114-1119 – Improving the Academic Achievement of the Disadvantaged / This program provides financial assistance to local educational agencies (LEAs) and schools with high numbers or high percentages of children from low-income families to help ensure that all children meet challenging state academic standards. In BIE-funded schools, all students are considered low income and thus are eligible for Title I, Part A funded services, and all schools are considered schoolwide, meaning that all Title I, Part A funds can serve all students / $XXX,XXX / $XXX,XXX
Title I, Part A, Sec. 1003(g) - Improving the Academic Achievement of the Disadvantaged, School Improvement Grant (SIG) / School Improvement Grants (SIG), authorized under section 1003(g) of Title I of the Elementary and Secondary Education Act of 1965 (Title I or ESEA), are grants awarded to State educational agencies (BIE serves as SEA) that SEAs use to make competitive sub grants to local educational agencies (Schools are LEAs in the BIE) that demonstrate the greatest need for funds and the strongest commitment to use these funds to provide adequate resources in order to raise substantially the achievement of students in their lowest‐performing schools. The funds are three year awards to be used to meet the needs of the students and staff as determined by data. / $XXX,XXX / $XXX,XXX
Title II, Part A – Highly Qualified Teachers and Improving Teacher Quality / The purpose of the program is to increase academic achievement by improving teacher and principal quality. This program is carried out by: increasing the number of highly qualified teachers in classrooms; increasing the number of highly qualified principals and assistant principals in schools; and increasing the effectiveness of teachers and principals by holding LEAs and schools accountable for improvements in student academic achievement. / $XXX,XXX / $XXX,XXX
Title IV - 21st Century Community Learning Centers / The 21st Century Community Learning Centers (21st Century) program supports the creation of community learning centers that provide academic enrichment opportunities during non-school hours for children, particularly students who attend high-poverty and low-performing schools.The program helps students meet state and local student standards in core academic subjects, such as reading and math; offers students a broad array of enrichment activities that can complement their regular academic programs; and offers literacy and other educational services to the families of participating children. / $XXX,XXX / $XXX,XXX
Title X, Subtitle C - McKinney-Vento Education for Homeless Children and Youths Program / The purpose of theprogramis to provide educational opportunities and support to its homeless youth and children, to ensure that these students have access to a free and appropriate education and that the barriers faced by these students have equal opportunity in receiving quality education. Homelessness exists and impacts enrollment, attendance, and academic success of children and youth in this situation. With receipt of this grant, the BIE assists schools in ensuring that homeless students receive comparable educational services received by non-homeless students. / $XXX,XXX / $XXX,XXX
Individuals with Disabilities Education Act (IDEA), Part B / The Secretary of Education reserves 1.226 percent from the amount appropriated to provide funds to the Secretary of the Interior to fund the excess costs of providing special education and related services to children with disabilities enrolled in elementary schools and secondary schools for Indian children operated or funded by the Secretary of the Interior. The BIE funded schools must use 15% of the Instructional ISEP for special education. If the ISEP funds are inadequate to pay for services needed by all eligible ISEP students with disabilities the school must submit an application to obtain part B funds of the Individuals with Disabilities Education Act (IDEA). Permitted expenditures include the salaries of special education teachers and costs associated with related services personnel, such as speech therapist, psychologist, etc. Other expenditures include staff training; parent training; Child Find; extended school year services for individual children; assistive technology; supplies, materials and equipment; and secondary transition (for student 16 years and older). / $XXX,XXX / $XXX,XXX
Instructional Funds Available from Listed Funding Sources (without Carryover) for SY 2014-15 / $XXX,XXX / $XXX,XXX

III.  Background

A.  Program Purpose

The BIE is required to meet the federal requirements of conducting a fiscal monitoring system that ensures BIE-funded schools appropriately use funds for intended purposes as identified in the statute. The fiscal review and verification process gauges the school’s fiscal compliance with selected statutes of the Elementary and Secondary Education Act (ESEA) and the Individuals with Disabilities Education Act (IDEA), and reviews the school’s adherence to selected financial management standards outlined in Title 2 and Title 25 of the Code of Federal Regulations, Public Law 93-638 and Public Law 100-297, as applicable.[[1]] An essential component of the BIE’s fiscal review process is the provision of technical assistance to improve the school’s operations and proper use of funds. Pursuant to 25 CFR Subchapter E, Part 32.4 (x), 25 CFR Subchapter E, Part 36.51, P.L. 107-110 ESEA Section 1116(c)(1)(A-B), and P.L.108-446 IDEA Section 616(a), the BIE is required to "enforce a strict standard of fiscal, programmatic and contract accountability to the Tribes and Alaskan Native entities and assist them in the development of their own standards of accountability and carry out annual evaluations of all Bureau-operated or funded education programs."

The Fiscal Review Team relies on the following information to form its analysis of a school’s finances: veracity of documents submitted by school personnel; information contained within the prior year's OMB Circular A-133 Audit; personnel and stakeholder interviews; verification of educational services provided and limited sampling of expenditures. Compared to an A-133 audit, this fiscal review process undertakes a deeper evaluation of the school’s compliance with the ESEA and IDEA programmatic requirements, provides technical assistance on budget development and fund management practices, and verifies the school’s compliance with fiscal requirements. The fiscal review process also facilitates timely corrections of noncompliance that may serve to improve effectiveness and efficiency of operations, increase reliability of financial and management reporting, address compliance with laws and regulations, and safeguard of assets.

The fiscal review process does not constitute an A-133 audit because it does not provide an attestation by a certified public accountant on internal controls or accuracy of financial statements. Therefore, the review does not fulfill a school’s responsibility to undergo an annual A-133 audit.

B.  Methodology

For School Year (SY) 2015-16, the BIE’s Division of Performance and Accountability (DPA) has selected ten schools to undergo a fiscal review based on the results of the BIE - Special Education Fiscal Desk Audits. The identified schools were selected due to two consecutive years of being designated as "high risk." Other factors used to determine that a school is “high risk” include untimely submission of reports and the inability to adhere to the prescribed guidance for the use of special education funds.

[Insert School Name Here] was assessed through review of the school's (1) Financial System and Processes and (2) Fund-specific compliance with ESEA and IDEA. During the onsite review, the Fiscal Review Team reviewed the school's requisition forms to determine allowable and unallowable costs. The Fiscal Review Team randomly sampled requisition forms for SY201x to SY201x. Additionally, payroll records from SY201x-1x and applicable underlying documentation were evaluated to determine if proper payroll procedures have been followed. The Fiscal Review Team also conducted interviews with school staff to determine whether stated policies are implemented, gauge administrators’ proficiency with budget development, and identify areas that necessitate additional technical assistance.

The Fiscal Review Team reviewed additional ESEA and IDEA programmatic requirements. The Fiscal Review Team reviewed teacher personnel files to determine the highly qualified credentials of the staff, the ESEA Consolidated Application and the IDEA Part B Application.

C.  Fiscal Items Outside of the Scope of the Monitoring Process

This section will highlight items of concern that are outside of the scope of the monitoring process or are not funded by the monitored federal funds.

Through the onsite visit, the Fiscal Review Team encountered items that are outside of the scope of the monitoring process or are not funded by the monitored federal funds but require management's attention. These issues are addressed below:

·  Item 1

·  Item 2

(Example only)

IV.  Fiscal Review

Part I: Financial Systems and Processes

A. Budget Development

REQUIREMENT: / STATUS: / FURTHER ACTION:
1.  The school has submitted the Consolidated Schoolwide Budget within the specified time period.[1] In addition, the Business Technician regularly consults the Principal or the Leadership Team in developing the Consolidated Schoolwide Budget. Finally, the school responds to coaching comments made, if any, by the Education Line Officer (ELO) regarding the Consolidated Schoolwide Budget.
Legal Citation: 2 CFR 200.308, 25 CFR 276.14, Title I, Part A Section 1112(a) (1)&(2). 25 CFR 900.45(a), ESEA Title I, Part A, Section 1112(a)(2) Consolidated Application / Requirement Met:
[If the school has met the requirement, explain here.]
(Example only)
The school submitted its Consolidated Schoolwide Budget in a timely manner. The Business Manager and Principal has scheduled regular meetings for collaboration in developing the Consolidated Schoolwide Budget.
Finding:
[If the school has not met the requirement, explain here.] / Corrective Action:
[If the school, has not met the requirement, recommend a corrective action here.]
Recommendation:
Make any further recommendations here.
REQUIREMENT: / STATUS: / FURTHER ACTION:
2.  The school has submitted a complete Fiscal Accountability Self-Assessment (FASA) by the due date.[2]
Legal Citation: 2 CFR 200.303 / Requirement Met:
[If the school has met the requirement, explain here.]
Finding:
[If the school has not met the requirement, explain here.]
(Example only)
The school did not submit its FASA for SY 2013-14 in a timely manner. / [If the school has met the requirement and there are no recommendations, insert “N/A” in this column.]
Corrective Action:
[If the school, has not met the requirement, recommend a corrective action here.]
REQUIREMENT: / STATUS: / FURTHER ACTION:
3.  The School Board approves quarterly budget reports.
Legal Citation: 25 CFR 47.8, 2 CFR 200.303, 25 CFR 276.14, 2 CFR 200.210(9) / Requirement Met:
[If the school has met the requirement, explain here.]
Finding:
[If the school has not met the requirement, explain here.] / [If the school has met the requirement and there are no recommendations, insert “N/A” in this column.]
Corrective Action:
[If the school, has not met the requirement, recommend a corrective action here.]
REQUIREMENT: / STATUS: / FURTHER ACTION:
4.  The Business Technician and other appropriate staff have received training in budget development.
Legal Citation: 2 CFR 200.303, 25 CFR 276.14, school training policies and procedures / Requirement Met:
[If the school has met the requirement, explain here.]
Finding:
[If the school has not met the requirement, explain here.] / [If the school has met the requirement and there are no recommendations, insert “N/A” in this column.]
Corrective Action:
[If the school, has not met the requirement, recommend a corrective action here.]

B. Purchasing and Procurement

REQUIREMENT: / STATUS: / FURTHER ACTION:
1.  School staff has received adequate training on requisition preparation, credit cards, and simplified purchase procedures.
Legal Citation: 2 CFR 200.303, 25 CFR 276.12, 25 CFR 900.48, 25 CFR 900.47, school training policies and procedures / Requirement Met:
[If the school has met the requirement, explain here.]