BIE Pine Springs Day School 1001 Pine Springs Rd., PO Box 4198 Houck BIE
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1 BIE Pine Springs Day School 1001 Pine Springs Rd., PO Box 4198 Houck BIE /06/2015 Bureau of Indian Education Division of Performance and Accountability BIE FISCAL ACCOUNTABILITY SELF-ASSESSMENT (FASA) SY Purpose: The FASA fulfills the monitoring and fiscal management responsibility for the education of children with disabilities enrolled in BIE funded schools as mandated by Public Law , the Individuals with Disabilities Education Act (IDEA) of 2004, and Public Laws , and , Section 1043; 25 CFR Part 276. The FASA also partially fulfills the Elementary and Secondary Education Act (ESEA) monitoring and fiscal requirements to address Office of Management and Budget (OMB) Circular A-87 to ensure that costs for Federal awards must be allowable, necessary, and allocable. Tribally Controlled Schools OMB Circular A-50 Audit Follow-Up P.L , Title V, Part B for Tribal controlled P.L Sec. 5(a) and Sec. 108 OMB Circular A-87 Cost Principles for State, Local, & Indian Tribal Governments OMB Circular A-102 Grants and Cooperative Agreements with State and Local Governments DIRECTIONS FOR TRIBALLY CONTROLLED SCHOOLS: Please complete ALL questions on the FASA. BIE-Operated OMB Circular A-123 Managements' Responsibility for Internal Control 43 CFR Subtitle A Administrative and Audit Requirements and Cost Principles for Assistance Programs 43 CFR Subsection Standards for financial management systems Budget & Accounting Act of 1921, as amended (31 USC 16 & 53) Budget and Accounting Procedures Act of 1950 GAO Policy & Procedures Manual of Guidance of Federal Agencies (Title 2 - Accounting) 25 CFR, Chapter V, Part 900 Subpart F, Subsections , Standards for Tribal Organization Mgt Systems DIRECTIONS FOR BIE OPERATED SCHOOLS: Please complete only the questions on the FASA that are NOT highlighted in yellow. Those highlighted in yellow are designated for Tribally-Controlled Schools only. Both BIE Operated and Tribally Controlled Schools P.L , Title 5, Part A for BIE Operated & Contracts Appropriations Act of 1981 (P. L ) OMB Circular A-76 Performance of Commercial Activities 34 CFR, Part 300, Subsection Secretary of the Interior 34 CFR, Part 300 Subsection (a)(1)-(3)(b)(i) Use of amounts Individuals with Disabilities Education Improvement Act of 2004 (IDEA) 2004, Part B, Sec (h)(2)(a), Sec. 612, Sec. 612 (a)(11), Sec. 613, and Sec. 613 (a)(7) 20 U.S.C et seq. (The Elementary and Secondary Education Act of 1965), P.L , P.L U.S.C et seq. (The No Child Left Behind Act of 2001), P.L , Authorized through U.S.C (The Education Amendments Acts of 1978) 92 Stat P.L , as amended with the authorizing statutes. Tribally Controlled Schools gfedc BIE-Operated School gfedcb School Information: Education Line Office Arizona Navajo South School name Pine Springs Day School Date of completion December 09, 2013 Name(s)/position of person(s) completing this FASA Lou Ann Jones, Principal, Angela Yazza, Education Specialist (Special Education Coordinator), Ambrose Ashley, Business Technician Page 1 of 7
2 SECTION 1: FISCAL OVERSIGHT 1A. IDEA Part B funds: Individual(s) responsible for the fiscal oversight. First and Last Name: Position: Contact Info: Address: Lou Ann Jones Principal lou.jones@bie.edu Ambrose Ashley Business Technician ambrose.ashley@bie.edu 1B. ESEA funds: Individual(s) responsible for the fiscal oversight. First and Last Name: Position: Contact Info: Address: Lou Ann Jones Principal lou.jones@bie.edu Ambrose Ashley Business Technician ambrose.ashley@bie.edu Angela Yazza SPED Coordinator angela.yazza@bie.edu SECTION 2: FISCAL AUTHORITY 1. Does your school have written internal control requirements and procedures? a. If yes: Describe the process you use to monitor internal controls. [or you may indicate in the block below that you have provided a copy in the Fiscal Accountability Self Assessment SY14-15 folder in the Native Star Document Upload]. The Fiscal Accountability internal monitor controls are address by the Navajo Region Office, Shiprock New Mexico Dr. Rena Yazza through monthly budget reviews, telephone consultations and interviews. All school fiscal activities are completed through the web-budget system. The comprehensive Fiscal Accountability manual is consistently referred to for guides and procedures. Not all sections of this manual is upload in the Native Star system. There is a two logs where all the information about a requisition is written, so that it is easy to track the status of a requisition. The special education staff reviews all IEP and cooperatively completes the Spending Plan (Budget). The school Business Technician maintains the official budget and cuff accounts and provides information to the special education staff. Requisitions are completed by the special education staff and forwarded to the approving officials; first to the Business Technician when to the Principal for final approval. Copies of the requisitions are maintain by the special education staff. The internal process described above is the same for all school programs. All programs have initial spending plan budgets where consideration is given on how the funds would be spend. The business technician provides monthly budget reports to staff and quarterly budgets to school boards for approval. The business technician is also an active member of the Native Star Leadership team. b. If yes: How are fiscal policies and procedures in your program documented and communicated? The school principal, coordinator, technician and teachers develop the program plan, along with a budget plan. When the program and budget plans is approved, the school receives a notification through the FDD for the approved budget funding. The business technician along with the assigned special education or responsible staff input the dollar amounts into the school wide web budget, and is reviewed by the chain of command for approval. The school monitors their spending through an establishes cuff accounts. Each program and object classes are coded based on the Fiscal Accountability manual. Information on the budget is communicated through quarterly reports by the Principal and business technician. The principal consults with the special education teacher and coordinator prior to final approval and forwarded to business technician. The business technician maintains all the documentations of expenditures and balances. Upon request from the special education teacher or coordinator the business technician provides updates on the balance and expenditures of the special education account. The budget is communicated to the school staff on the first Friday of every month. 2. (TRIBALLY CONTROLLED SCHOOLS ONLY) List the type of training that is provided to: a. individual involved with fiscal oversight and management of IDEA Part B funds? b. individual involved with fiscal oversight and management of ESEA (Title) funds? 3. Do you assess fiscal risks? Page 2 of 7
3 If yes: Please briefly describe risk assessment procedures [or you may indicate in the block below that you have provided a copy in the Fiscal Accountability Self Assessment SY14-15 folder in the Native Star Document Upload]. Each department has to communicate with the Principal and Business Technician prior to placing a requisition for purchase. Principal and Business Technician ensures items included in the initital budget and justification of the items to be ordered. No purchase is made without an approved requisition. When the items are received the business technician check the shipping slip and the requestor signs off on the order. The monthly card billing statement report is prepared with documentations (requisition with appropriate signature andand invoices) for principal's review. Mr Ashley has a monthly teleconference to review the acquisitions for Pine Springs Day School. If there is a red flag the principal is requested to be on the teleconference for clarification and corrective action. 4. Has your school had a breach of internal controls in the last 12 months? If yes, explain the issue and how it was resolved. None SECTION 3: BUDGET 1. (TRIBALLY CONTROLLED SCHOOLS ONLY) Describe your school's budget development, reconciliation, and amendment process for: a. The school as a whole: b. For special education c. For ESEA programs 2. Are all budgeted special education expenses directly related to excess costs for students with disabilities? 3. Do all budgeted ESEA expenses provide supplemental services and address the intent of the ESEA programs to improve student achievement? 4. Do the school's budgets include indirect costs? If yes: Provide example(s) of how indirect costs are used. 5. How is the special education coordinator informed of expenditures and balances for the special education budget at any point in time? The business technician provides information on the special education budget balances and expenditures only upon request by the special education coordinator. Usually the majority of the special education budget is based on just a few line items there forth is not complicated, however the special education teacher has to submit requisitions throughout the school years to ensure all required materials and equipment are ordered to implement the special needs of students with a disability. 6. How is the Leadership Team/Native Star Leadership Team informed of expenditures and balances for the ESEA program budgets at any point in time? The Principal shares the balances and budget with the Leadership during the monthly Native Star meetings and the business technician is a member of the leadership team. Budget is also uploaed into Native Star. amd verified by the principal. 7. Is a cuff account system/accounting system used to manage all federal program budgets? If yes: Describe how the special education budget is updated and shared with the special education department and the name of the accounting system. All federal funds received by the school is manage through the FBMS, and the WebEx Budget and maintained by the business technician. Once the Official FDD for the special education is received the cuffs accounts for special education and all federal program budgets by the business technician. The special education program uses the Consolidated Budget accounting system, found in Native Star and uploarded into the Native Star folder. Page 3 of 7
4 If yes: Describe how ESEA cuff accounts are updated and shared with the School Leadership Team/Native Star Leadership Team. Detailed ESES cuff accounts are updated every month and then into Summary Budget Expense Report along with all the other accounts, then shared with Leadership Team/Native Start Leadership Team, and management. Further more thise same data information are updated in Web-budget report and sent to Navajo Region, Shiprock for review and approval by Dr. Yazzie. 8. Is a system in place for records that provide support for the budget and expenditure activities in your schools? 9. Who has signatory authority over each federal program accounts (special education, Title I-A, Title II-A, etc)? Federal Special Education Program Lou Ann Jones Principal All Other federal program Lou Ann Jones Principal 10. Does the person who prepares checks or payments: a. Approve the special education program account? b. Reconcile the special education bank account? c. Approve the ESEA program account? d. Reconcile the ESEA bank account? 11. Describe how the school would provide justification for unusual items if such an issue arises and provide an example. For the special education program the special education teacher or the special education coordinator provides justification for all expenditures and must be linked to the Individual Education Plan (IEP) for each student with a disability. Example: A new student is referred, evaluated and is eligible for special education and related services; and the parent, and teacher would like to attend an in-state conference to implement goals on the IEP, and in order of the teacher to implement a special equipment such as the NEC writer, because the student does not have adequate writing skills to progress in the general or resource room. All IEP members must agree and the administrator signs to commit funds. SECTION 4: PROCUREMENT / PAYMENT 1. (TRIBALLY CONTROLLED SCHOOLS ONLY) Describe your school's procurement process [or you may indicate in the block below that you have provided a copy in the Fiscal Accountability Self Assessment SY folder in the Native Star Document Upload]. 2. Who is responsible for writing the justifications on the requisitions for: a. Special education programs Special Education program Marlinda Yazzie Special Education Teacher Special Education program Angela Yazza Special Education Coordinator b. ESEA programs (Title I-A, Title II-A, Title IV-B, Title X-C, etc)? ESEA All Other Programs Lou Ann Jones Principal Academic Programs Ms. Irene Nez Ms. Pam McCraken Mrs. Doreen Earle Mr. Bardley Bundger Teachers 3. How does the school ensure that authorized persons who handle IDEA Part B funding comply with appropriate use of special education funds? Training is provided by Navajo Region Office-Dr. Rena Yazzie. The special education department from the Division of Performance and Accountability produce a guideline of what is allowable cost and what is not. WebEx training also Page 4 of 7
5 provided, and information shared at monthly Principals teleconference/meetings. School administrator, business technician and board members sign program assurances to comply with program guidelines and procedures. 4. How does the school ensure that authorized persons who handle ESEA program funding comply with the appropriate use and allowable costs of each ESEA program fund? Training by Navjap Region Office-Dr. Rena Yazzie for Principals and business technician on OMB Circular A087 allowable costts and A-102, includes state and local training. They have monthly meetings to review budget information and reference back to the Fiscal Accountability Manual, for unique issues. School administrator, business technician and board members sign program assurances to comply with program guidelines and procedures in the use of appropriate expenditures for all school funds. 5. (TRIBALLY CONTROLLED SCHOOLS ONLY) Who is involved in the process listed below for special education and each ESEA program: a. Placing orders with vendors: b. Approving the order and account code c. Receiving d. Processing approved invoices or vouchers: 6. Describe any lease agreements you have. None 7. (TRIBALLY CONTROLLED SCHOOLS ONLY) Does your school have a bid procurement process? If yes: Please describe[or you may indicate in the block below that you have provided a copy in the Fiscal Accountability Self Assessment SY14-15 folder in the Native Star Document Upload]. 8. (TRIBALLY CONTROLLED SCHOOLS ONLY) Do you have any carryover IDEA Part B funds from SY13-14? a. If yes: Please answer the following: Program Carryover Amount Undelivered Orders b. Provide the reason(s) on why the school had carryover and describe a plan for the use of the funds. 9. (TRIBALLY CONTROLLED SCHOOLS ONLY) Do you have any carryover ESEA funds from SY13-14? a. If yes: Please provide the following information for applicable ESEA programs (Title I-A, Title II-A, Title IV-B, Title X-C, etc). ESEA Program Carryover Amount Undelivered orders b. Provide the reason(s) on why the school had carryover and describe a plan for the use of the funds. Page 5 of 7
6 10. (TRIBALLY CONTROLLED SCHOOLS ONLY) Does your department make any payments that do not go through Accounts Payable or the school procurement process? 11. (TRIBALLY CONTROLLED SCHOOLS ONLY) Does the school ensure that an approved purchase order is in place prior to making a purchase? 12. (TRIBALLY CONTROLLED SCHOOLS ONLY) How is the departmental staff aware of timelines for submitting invoices to Accounts Payable to allow sufficient processing time to meet vendor payment deadlines? 13. (TRIBALLY CONTROLLED SCHOOLS ONLY) For what cases, if any, are funds disbursed to school personnel (cash)? 14. (TRIBALLY CONTROLLED SCHOOLS ONLY) Does your department have record retention guidelines or policies? If yes: Please briefly describe [or you may indicate in the block below that you have provided a copy in the Fiscal Accountability Self Assessment SY14-15 folder in the Native Star Document Upload]. 15. (TRIBALLY CONTROLLED SCHOOLS ONLY) What is your procedure if you encounter any "irregular" or excessive expenses? 16. (TRIBALLY CONTROLLED SCHOOLS ONLY) How are the department-specific policies or guidelines relating to travel or business meal expense reimbursements communicated to the staff? SECTION 5: TRAVEL & TRAINING FOR FY travel was completed for SY13-14 Complete the following for all travel completed during FY using IDEA Part B funds: Name of event: Location: Name of attendee/position Amount: ($) Purpose: No travel during SY 2013/2014 due to travel restriction. SECTION 6: SCHOOL PURCHASING/PROCUREMENT CARD 1. Has your school implemented a school charge card program? 2. Who reviews the card statement? Name Lou Ann Jones Cheryle Battle/Arlene Routtatopc Principal Contract Specialist Position 3. Describe the school's policy on how cardholders in the appropriate department (i.e., Special Education, Title I, 21st CCLC, McKinney-Vento) review billing statements and provide a business purpose for expenses in compliance with policy? Each department has to communicate with the Principal and Business Technician prior to placing a requisition for purchase. Principal and Business Technician ensures items included in the initital budget and justification of the items to be ordered. No purchase is made without an approved requisition. When the items are received the business technician check the shipping slip and the requestor signs off on the order. The monthly card billing statement report is prepared with documentations (requisition with appropriate signature andand invoices) for principal's review. 4. Have transactions for purchases using a purchase charge card been approved prior to the transaction by the authorized manager/supervisor? If yes, provide an example. 1. Requestor, Special eduation teacher submitts PR for purchase to Principal, threshole of $3, supplies/materials and threshole of $25, for services. 2. Business Tech reviews purchase request to ensure funds are available and checks for approval on IT orders. 3. Principal approves PR for purchase and then submitted to BIE-property for further approval. 4. Business Tech uses credit card to purchase supplies or services within the threshold amount on requisitions. SECTION 7: PROPERTY MANAGEMENT 1. (TRIBALLY CONTROLLED SCHOOLS ONLY) What is your school's property management policy for determining when (what type and dollar threshold) and how acquired items need to be recorded, inventoried, safeguarded, and accounted in financial records? [Or you may indicate in the block below that you have provided a copy in the Fiscal Accountability Self Assessment SY14-15 folder in the Native Star Document Upload.] SECTION 8: INDEPENDENT CONTRACTORS/CONSULTANTS DURING SY Page 6 of 7
7 1. Did the school contract out for any related services for special education? (Include CAU services) If yes, list the related services. gfedcb i. Speech gfedcb ii. OT gfedcb iii. PT gfedcb iv. Psychological gfedcb vii. Other 2. Did the school pay any other consultants or contractors on a periodic basis for recurring services over the course of a contract? If yes: Please describe and list the other services the school contracted for and how often these services will take during the course of the year. None 3. Is the special educaton coordinator involved in the verification process for payment of invoices? SECTION 9: A-133 AUDIT 1. (TRIBALLY CONTROLLED SCHOOLS ONLY) Is your school current with A-133 audits? 2. (TRIBALLY CONTROLLED SCHOOLS ONLY) Is your school on sanctions? 3. (TRIBALLY CONTROLLED SCHOOLS ONLY) Were there any violations or audit findings in the last three years in special education? Reviewer Comments (if necessary): Feedback - December 23, 2014 The purpose of the FASA is for the school's to provide information regarding the school fiscal management responsibility with IDEA and ESEA. The information the school provides will be used to verify if the school should have an onsite fiscal visit. Upon review of the school's FASA submission, below is my feedback. Please call me if you have any questions/feedback you would like clarified Connie Albert Section 2; Question 1a Add: more information on internal controls process specific to the whole school and not just special education. The school should have a policy on internal controls. As a BIE school what written control do you follow? 2. Section 2: Question 1b Clarify: How are fiscal policies and procedures documented and communicated to the school staff? 3. Section 2: Question 3 Review: Why do you not assess for fiscal risk? What does to school do to ensure theft and embezzlement do not occur and what is the process? What else do you do? 4. Section 6: Question 3 - blank -answer question THANK YOU FOR COMPLETING THE FASA Page 7 of 7
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