Pre-Award Risk-Based Assessment Tawanna Fields-Mphande October 14,2016
Overview • Pre-Award Risk-Based Assessment Process • Risk-Based Assessment Timeline • Agency-Wide Compliance & Monitoring Updates • Resources
Risk-Based Assessment
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.
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
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.
Purpose and Intent Ensure that subrecipients use federal funds for the intended purpose Provide preventative assistance before mistakes are made Increase efficient use of resources & transparency Reduce, waste, fraud & abuse
Criteria Selection Process
Criteria Selection Process Just kidding!
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.
Pre-Award Risk-Based Assessment Tool
Assessment Tool Based on the results of High the risk-based assessment tool, all districts will be Medium categorized as high, medium or low risk. Low
Risk-Based Assessment Tool
Assessment Scores 0 to 1 points low risk 2 to 3 points medium risk 4 to 7 points high risk
Risk Levels Risk Level Monitoring Guidelines Risk Levels High Required to submit detailed financial reports such as general ledgers, (4-7) supporting documentation and performance reports. On-site monitoring will be at the discretion of the education program specialist. Medium Required to receive additional targeted assistance. Required attendance (2-3) at trainings/conferences. Follow-up with district via phone audit review. Low No known programmatic, financial instability or significant audit findings. (0-1) No significant program changes. The district shall receive technical assistance upon request.
FY18 Pre-Award Risk Assessment Timeline July 2017 May 2017 Funds allocated to High-Risk field Districts Notified June 2017 April 2017 Monitoring Pre-Award Risk Guidelines Assessment implemented Note: The timeline is contingent on the availability of data.
Agency-Wide Updates
Pre-Award Risk-Assessment 1 Agency-Wide Process
Agency-Wide Process • All federal programs are required to implement the risk-assessment process. • Each departments process is unique to their grant.
Program Monitoring 2 Agency-Wide Process
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
3 Compliance Dashboard
New Compliance Dashboard
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!
Resources
Scheduled to be Monitored
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
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
Miguel Ruiz
education.ohio.gov
Social Media OhioFamiliesAndEducation @OHEducation @OHEducationSupt OhioEdDept
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