Perkins IV

1
Perkins IV HOT TOPICSA Dialogue with Dan

• Tennessee Directors of Career and Technical
  Education
• CTE Conference--MTSU
• July 16, 2008
• McWherter Learning Resource Center

2
Accountability Major Emphasis

• The Perkins Reauthorization
• Emphasizes accountability for improved results
• Improves monitoring and enforcement
• Disaggregates performance goals and report
  information by special populations
• Provides sanctions for not meeting FAUPL

3
Hey Dan,

• What happens if I do not meet my benchmarks?
  Bill
• Into the dungeon you will go! Bill
• To develop an Improvement Plan
• to determine how to get out of the dungeon!
• Dan

4
Accountability

• Insures accountability for career and technical
  education to meet the new system and move from
  the status quo.
• Insures workforce competitiveness through skill
  attainment measures.
• Insures transitions to post secondary.
• Insures planning for careers through rigorous
  technical programs of study.
• Measures through performance based.

5
Hey Dan,

• Whats with all this accountability stuff? Cant
  I keep on doing what I have been doing? I am not
  trying to impress but ride it out to retirement.
  Joe
• Hey Joe, you better look a little harder at your
  levels and what you are doing. You are a
  candidate for risk based monitoring because
  youve got 3 more years to go!

6
Accountability Why?

• A Renewed Emphasis From USDE on Monitoring and
  Compliance
• Criticism that OVAE is not monitoring effectively
• Criticism that the states are not conducting
  in-depth auditA-133
• Office of Chief Financial Officers (OCFO) will
  now do the fiscal portion of the Perkins
  monitoringUh, OH!!!

7
Hot Topic--Negotiations for Performance

• Hey Dan, Whats with all this negotiation and
  monitoring stuff? I am having a hard enough time
  negotiating with my wife and kids where we are
  going out to eat! Mitch
• Hey Mitch, The N in NCLB means negotiate. The
  OVAE in OVAE means, Often, Validate, Actual,
  Expectations . Plus, on your way home, just stop
  by the Kroger deli and bring dinner home because
  they are OVAEing at this minute where yall are
  going out to eat plus your yard needs mowing.

8
POP Quiz--Performance Standards Review Test

• Meet or exceed baseline levels of performance on
  the core indicators required by The Carl D.
  Perkins Career and Technical Education Act of
  2006.

• Baseline7/1/05-6/30/06-Academic Indicators NCLB
• Baseline----7/1/06-6/30/07-Technical Skill,
  Completion, Placement, and Non traditional
• Year One- 7/1/07-6/30/08-Report three Performance
  Indicators
• Year Two7/1/08-6/30/09-Report on all

9
OVAE -Self Help Sheet for Quiz
10
Accountability Performance and Program Improvement

• Sanctions
• If a local recipient fails to meet at least 90
  of an agreed upon local adjusted level of
  performance for any core indicator
• The local recipient shall develop an improvement
  plan during the first program year succeeding
  the program year for which the recipients failed
  to meet the performance level Section 123 (b)
  (2)

11
Hey Dan

• What does that mean for me? Marilyn
• Well Marilyn, That means for 2007-08, if your
  concentrators do not meet your 90 threshold for
  1S1, 1S2 and 4S1, you will have to write an
  improvement plan in 2008-09 for how you will make
  those levels you did not meet. Dan

12
Accountability Local Performance and Evaluation

• YOU ARE NOT ALONE!
• The state must work with the local recipient to
  implement improvement activities Section 123 (b)
  (3)
• STATE TEAM
• Regional Field Service Consultants, CTE
  Program Consultants, and other State
  staff-Title I, Sp. Ed., Teaching and Learning
  Consultants, plus your local staff

13
Accountability State and Local

• The State must negotiate with OVAE for Final
  Agreed upon Levels of Performance Levels for the
  STATE (FAUPL)
• Each local system must negotiate their own
  performance levels with their supporting data
• Quality Data Do Matter for State and LEA
  Performance Levels!

14
Hot TopicData Driven-New Game!

• DATA DRIVEN DECISIONMAKING
• TIMELY DATA REPORTING
• DATA INTEGRITY and ACCURACY
• DATA DISSAGREGATION
• DATA REPORTING TO THE PUBLIC
• ADDS UP TO THE
• Tennessee Perkins Report Card
• Tennessee Consolidated Annual Report (CAR)
• Washington-Perkins Report to Congress
• --Tennessee-Report Card
• --Washington-Report to Congress

15
Hot Topic--Spending Questions

• Hey Dan, Get away from this negotiation stuff
  and deal with how we can spend our money. Kay
• Hey Kay, Ill do it but I am not sure youll
  like to hear what I have to say! Dan

16
What Rules and Regs are Referred to the Most?-

• Your approved Plan
• 2006 Perkins-Section 135, Local Uses of Funds
• Equipment-EDGAR 34 CFR 80.3, 80.20 80.32
• Assigning Cost to the Correct Fiscal year-EDGAR
  34 CFR 76.707
• K-12 OMB Circular A-87, Attachment B (Allowable
  Costs)

17
What Rules and Regs are Referred to the Most?-

• State statutesEducational, procurement, etc.
• State Accounting Manual
• State Guidance from TDOE relative to Perkins
• State Audit Guidelines. What your auditors will
  use to review your fiscal practices when you are
  audited.

18
Your LibraryLEA Eligible Recipients

• Program law and applicable regulations
• Your school and district guidelines-
• State financial reporting requirements.
• State and local procurement requirements
• State and local inventory and personal property
  requirements.
• K-12, OMB Circular A-87
• The consolidated audit requirements-OMB Circular
  A 133

19
Your LibraryLEA Eligible Recipients

• EDGAR (34 CFR 74-99)
• State Accounting Manual
• Federal Grants Management Handbook
• Perkins ACT of 2006The Official Guide
• OMB Circularshttpwww.whitehouse.gov/omb/circular
  s
• EDGAR http//www/ed.gov/policy/fund/reg/edgarReg/e
  dgar.html
• OIG website www.ed.gov (Click on Office,
  left-hand column, then select Offices of
  Inspector General, home-page.)

20
Hot Topic--Spending

• Hey Dan, With all this library stuff you are
  telling us we need to have, Ill have to buy a
  new bookcase from Mr. Perk? Carolyn
• Sorry Carolyn, Perkins will not allow you to buy
  furniture. Get one out of the other supervisors
  office while they are out and paint LOCAL CTE on
  it. Dan

21
General Tests of Allowability

• Fits with your plan
• Allowable per the appropriate Circular
• Reasonable
• Allocable
• Consistently Treated
• Consistent to your organizations policies
• Not Charged elsewhere
• Adequately Documented.

22
Hot Topics--OCFO Issues

• From the Office of the Chief Financial Officer,
  USDOE
• 249 findings
• 48 related to procurement and distribution
• 38 related to equipment controls
• RememberThe other side of Can I
• Follow the rules
• Like golf or battingThe follow through is really
  important
  

23
Some of the Biggest Goofs--

• Costs not incurred in your approved plan
• Specifically disallowed costsentertainment,
  meals (outside of travel)
• Violated the agencys procurement rules
• Get Approval 1st then spend (dont obligate your
  agency before you have approval)
• People costsfailing to keep the Time and Effort
  documentation

24
Hot Topics--Lets get down to the Major Can Is

• Salaries
• Yes
• Dont Forget-
• Time and Effort reporting requirements (Item 8 in
  OMB Circular A87)
• The individual you pay has to be working on
  Perkins related activities

25
Can Is

• Equipment
• The definition of equipment in EDGAR (34 CFR
  80.1) 5000
• General purpose equipment is not allowed A87
• DefinitionA87.15.a.(4)
• Restriction-A87.15.b.(1)
• Examples of general purpose equipment include
  office equipment, and furnishings,reproduction
  and printing equipment,automated data processing
  equipment.

26
Hey Dan

• My system has a lower dollar figure on equipment
  than EDGAR. Melissa
• Well Melissa, Use the Equipment guidelines for
  your system/state and you cannot go wrong. Dan

27
Can Is--Continued

• Get it written into your approved application
• Items like your CTE computer lab
• Specialized workstations
• Avoid paying for stuff your district typically
  supplies to all educational programsdesks,
  chairs, etc.

28
Supplanting (OMB Circular 133)

• The Supplement states supplanting is presumed to
  have occurred when
• the entity used Federal funds to provide
  services which were provided with non-Federal
  funds in the prior year
• This becomes an issue in tight budget times!
• In shortIf you supported it with local or state
  funds use caution to apply it now to Federal
  funds.

29
Hey Dan

• I need to wallpaper my office to make it more
  pleasant for my teachers while we have our perked
  coffee in the morning. Will Mr. Perk let me Perk
  the Paper? Ron
• Sorry Ron, The Perked Paper you are Proposing to
  Purchase Prevents you from Paying with the
  Perkins Procurement Process.
• Dan

30
Can Is Continued

• Food and Beverage
• No!
• Unless it is related to
• Approved travel
• Included in your approved registration
• Not considered entertainment
• Included as part of an approved conference or
  meeting
• A consumable training supply (culinary arts)
• Alcohol never allowed
• Read Goods or services for personal useA87 Attch
  B.20

31
Can Is continued

• Travel/Food and Beverage
• Allowable when it supports your approved grant or
  plan
• Meals, lodging, all the usual stuff is allowable,
  when approved
• DOES NOT INCLUDE ENTERTAINMENT COSTS

32
Hey Dan

• My hospitality/tourism teacher and class want me
  to go with them on a cruise to the Bahamas to
  learn all aspects of the cruise industry. The
  kids are paying their own way but I want to use
  Perkins for our PD venture. Paulette
• Hey Paulette, You might want to think this
  through! To go outside of the US and be
  supported with federal funds requires approval of
  the USDE Secretary of Education. I would also
  want to think your local board and newspaper
  folks want to go, too. Dan

33
Can Is Meetings/Conf/Food/Beverage

• A 87 Attachment B.27
• Meetings and conferences. Cost of meeting and
  conferences, the primary purpose of which is the
  dissemination of technical information, are
  allowable. This includes costs of meals,
  transportation, rental facilities, speakers fees,
  and other items incidental to such meetings and
  conferences. But see Attachment B, Section 14,
  Entertainment costs.
• Must be reasonable
• Must be able to stand the Would you like to see
  this on the six oclock news? test
• Does Not mean your Monday morning CTE teachers
  meeting, with coffee and donuts provided courtesy
  of the federal grant.
• Etc.

34
Hey Dan

• We want to go to a conference but the early
  registration fee and plane ticket purchase
  crosses the fiscal year because the conference is
  held in late July. Can I pay with Perkins?
  Jerry
• Well Jerry, Pre-paid fees and travel can lead to
  headaches related to the issue when is cost
  incurred. You may need to transfer the expense
  from one fiscal year to the next if the fee is
  paid prior to the fiscal year in which the
  activity will occur. Dan

35
Hot TopicsCTSOs

• Little guidance-the Feds typically refer you back
  to 34 CFR403.71)c)The last regulatory guidance
  for Perkins under Perkins II.
• AllowedInstructional related costs (very narrow)
• DisallowedAll the fun stuff.

36
34 CFR 403.71(c)

• The support of vocational student organizations
  may not include-
• (i) Lodging, feeding, conveying, or furnishing
  transportation to conventions or other forms of
  social assemblage
• (ii) Purchase of supplies, jackets, and other
  effects for students personal ownership
• (iii) Printing and disseminating
  non-instructional newsletters
• (v) Purchase of awards for recognition of
  students, advisors, and other individuals or
• (vi) Payment of membership dues

37
Hey Dan

• We have been told it is ok to pay for the bus to
  carry the kids to state. Monica
• Well Monica, It appears from my research that
  this was with state approval by the previous
  administration but I have found nothing to
  document that OVAE approved it but Ill keep
  looking and you keep carrying. Dan

38
Can Is..The Biggie!

• You can always ask us to ask the federal program
  office for an exception
• Most states have never been successfulTypically
  you need to figure out another way to get what
  you want if its that important.
• Just RememberIf your thought is you cant use
  state or local funds for that! THEN WHY DO YOU
  EXPECT THE FEDS TO PAY FOR IT?

39
Hey Dan

• You got me all depressed with all this stuff. I
  need a vacation! Harold
• Well Harold, We all deserve a vacation! It is
  just the price we have to pay for all of us doing
  such an outstanding job managing Mr. Perkins,
  much better than mortgage and fuel companies
  these days. Dan

40
THANKS FOR ALLOWING ME TO BE WITH YOU TODAY!

• My presentation will be posted on our website for
  your future reference.
• Dan
• AND NOW--(because it is an election year and
  proper protocol is in) and for a much better PPT
  presentation, I yield the remainder of my time to
  my colleague, Gay Burden, Director, Secondary to
  Post Secondary Transition, who will enlighten you
  on dual credit and dual enrollment data that you
  will have to report.