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Perkins IV

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Hey Joe, you better look a little harder at ... Hey Dan, What's with all this negotiation and monitoring stuff? ... Hey Mitch, The 'N' in NCLB means negotiate. ... – PowerPoint PPT presentation

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Title: Perkins IV


1
Perkins IV HOT TOPICS A 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.
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