US Department of Education Office of Elementary Education
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1 APRIL State Project/Program: READING FIRST STATE GRANT (PRC 106) US Department of Education Office of Elementary Education Federal Authorization: Reading First State Grant (PRC 106) Office of Elementary Education Department of Education, Education Department General Administrative Regulations (EDGAR)0 State Authorization: Elementary and Secondary Education Act of 1965, As amended, Title I, Part B, Subpart 1 N. C. Department of Public Instruction Agency Contact Person - Program Jackie Colbert, Chief Reading First Section jcolbert@dpi.state.nc.us (919) Agency Contact Person - Financial Gene Bruton, Accountant I Monitoring and Compliance gbruton@dpi.state.nc.us (919) Confirmation Address Letters To: Gene Bruton, Accountant I N.C. Department of Public Instruction Division of School Business Monitoring and Compliance Section Education Building 6334 Mail Service Center Raleigh, NC (919) The auditor should not consider the Supplement to be safe harbor for identifying audit procedures to apply in a particular engagement, but the auditor should be prepared to justify departures from the suggested procedures. The auditor can consider the supplement a safe harbor for identification of compliance requirements to be tested if the auditor performs reasonable procedures to ensure that the requirements in the Supplement are current. The grantor agency may elect to review audit working papers to determine the audit tests are adequate. I. PROGRAM OBJECTIVES The purpose of Reading First is to ensure that all children can read at grade level or above by the end of third grade. The Reading First program will provide the necessary assistance to schools to implement programs based on scientifically based reading research for students in kindergarten through third grade. Reading First funds will also focus on providing significantly increased teacher professional development to ensure that all teachers, including special education teachers, Title I teachers and teachers of limited English proficient students have the skills they need to teach these programs effectively. Additionally, the program provides assistance to schools in preparing classroom teachers to effectively screen, identify and overcome reading barriers facing their students.
2 II. PROGRAM PROCEDURES Reading First grants are provided to DPI by the U.S. Department of Education (ED) for allocation to public and Charter schools. The amounts provided to the schools have been calculated by starting with an equal base amount of $75,000; the remainder of the funds provided to the schools is allocated based on the percentage of Reading First K-3 students. Source of Governing Requirements The Reading First program is authorized by Title I, Part B, Subpart 1 of the Elementary and Secondary Education Act of 1965, as amended by the No Child Left Behind Act of 2001 (20 USC 6361 et seq.). No regulations have been published on this program. However, this program is subject to the Department of Education s General Administrative Regulations at 34 CFR parts 76, 77, 80, 82 and 85. Availability of Other Program Information Other program information is available on the Internet at and III. COMPLIANCE REQUIREMENTS The North Carolina Department of Public Instruction (DPI) mandates that all testing in the DPI Cross- Cutting Requirements, DPI-0, be performed by the local auditor. Other procedures that pertain to this program can be found in the US Department of Education Cross- Cutting and the OMB Circular A-133 Compliance Supplement, Section A. In addition to the Federal requirements, each SEA has the authority, in accordance with State law, to issue rules consistent with Federal statutes and regulations. These rules should be reviewed before beginning the audit. A. Activities Allowed or Unallowed Compliance Requirement Funds may be used by a public school only in accordance with the approved State subgrant and only for those services or activities in its subgrant. Expenditures must be reported to the SEA each month. Audit Objective To determine that expenditures are allowable and are properly recorded. Suggested Audit Procedure Obtain a copy of the Budget Balance Reconciliation Report (305/705) from the finance officer and compare to local accounting records for appropriateness. Test expenditure and related records to determine if expenditures were made only for those services or activities in the subgrant. Examine expenditures for appropriate approval and documentation. Obtain a copy of the subgrant, and review expenditures to determine that expenditures are in accordance with the subgrant. Determine that personnel paid from these funds do not exceed budgeted personnel in approved program budget. Compliance Requirement Funds are used only to purchase approved reading assessments, reading programs, instructional materials and professional development tools found on DPI Reading First website. B
3 Audit Objective To determine that expenditures are allowable and are properly recorded. Suggested Audit Procedure Obtain invoices and expenditure data to determine if expenditures were made only on the approved reading materials and tools on the DPI Reading First website. B. Allowable Costs/Cost Principles 1. Documentation of Employee Time and Effort Addressed in the NC Department of Public Instruction Cross-cutting Requirements. 2. Indirect Costs Addressed in the NC Department of Public Instruction Cross-cutting Requirements. C. Cash Management Addressed in the NC Department of Public Instruction Cross-cutting Requirements. E. Eligibility 3. Eligibility for Subrecipients The Department of Public Instruction program consultants determine if the eligibility requirements are met when the subgrant was approved. There have been no additional schools added to the eligibility list. However, one school withdrew and several other schools have redistricted. That impacted the schools that are receiving grant schools. G. Matching, Level of Effort, Earmarking 1. Matching - Not Applicable. 2. Level of Effort - Not Applicable. 3. Earmarking Addressed in the US Department of Education Cross-Cutting Section Compliance Requirement A LEA/Charter School may not spend more than 3.5 percent for planning and administration (20 USC 6362(c) (8)). Audit Objective Determine that the LEA/Charter School did not spend more than 3.5 percent of its funds for administration and supervision. Suggested Audit Procedure Ascertain the amount of Reading First expenditures. Review expenditure records and supporting documentation for administrative costs. Ascertain that the administrative is within the 3.5 percent requirement following the outlined formula. Include any account with the following Purpose. Purpose Code s Object Codes 6200 General Administration Any object associated with this purpose B
4 8100 Indirect Cost 392 The 6200 benefit codes associated with the salary codes will be included in the Administrative Cost. To Calculate: Determine the Allotment amount for the current fiscal year. (Do not include carryover) FY Allotment $600, Calculate the Allowable Amount of Administration by multiplying the Allotment amount by the current year's percentage limitation. 3.5% limitation $600,000 x 3.5% =$21, Allowable amount of Administration Determine the Administrative Expenses using the codes below: $10, , , Total Administration $18, Compare the allowable amount of Administration to the total Administrative cost. When the total administration expenditures are less than the allowable amount of administration the LEA/Charter School is in compliance with the Administrative Policy. $21, , = $2, The remaining $2, can be carried over at June 30 and added to the allowable amount of Administrative cost for use in the next fiscal year, if sufficient carryover exists. H. Period of Availability of Federal Funds Compliance Requirement Expenditures may not be incurred before the subgrant begins. Any expenditure prior to the beginning date is considered unallowable and must be refunded to DPI. Audit Objective To determine that no expenditures were incurred prior to the date the subgrant began. Suggested Audit Procedure: B
5 Review transactions to verify that no expenditures were incurred prior to the approved application beginning date. I. Procurement and Suspension and Debarment Addressed in the US Department of Education and NC Department of Public Instruction Cross-cutting Requirements. L. Reporting 1. Financial Reporting Addressed in the US Department of Education Cross-Cutting Section and NC Department of Public Instruction Cross-Cutting Requirements. 2. Performance Reporting - Not Applicable. 3. Special Reporting - Not Applicable. N. Special Tests and Provisions 1. Participation of Private School Children (SEAs/LEAs) Addressed in the US Department of Education Cross-Cutting Requirements. B
6 B
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