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PERKINS 1012016 CTE Interns
PHOUANG HAMILTON
Office of Superintendent of Public InstructionCareer and Technical EducationPhouang.Hamilton@k12.wa.us
360-725-6245
Jill Pilbro, Office AssistantCareer and Technical Education
Jill.Pilbro@k12.wa.us360-725-6245
Monica Trabue, Office AssistantCareer and Technical Education
Monica.Trabue@k12.wa.us360-725-6245
DISCLAIMER
The opinions and guidance expressed in this training/workshop is for educational and information purposes only. I use reasonable efforts to insure that information provided herein is accurate and is the most current information available at the time of training. However, districts are urged to contact the CTE program office directly via email to verify its accuracy prior to making costly programmatic decisions.
PERKINS IV
• There has been some type of CTE/Vocational program funded since 1917 (Smith Hughes Vocational Act)
• In terms of raw dollars, Perkins is not a major educational grant (WA – 20.6M)
• Perkins, the largest grant targeted at secondary education
PERKINS 101
• Perkins is “split funded” between the secondary (high schools) and the postsecondary (community colleges) programs
• The average split nationally is 59.24% secondary and 38.89% postsecondary
• The splits are determined by each state• WA –
• 56% Postsecondary
• 44% Secondary
PERKINS – In Trouble?
The President’s Administration has agreed to the:• Elimination of Tech Prep (Title II of Perkins)
• Continual reduction in Perkins funds to States
Continual funding cuts to States and Locals will require everyone to plan on the conservative side
• THE BASICS
PERKINS
• YOUR LIBRARY
7
The Bible
How does Perkins fit in CTE programs?
• It’s a Federal formula program meant to improve and enhance existing CTE programs
• The Perkins act was originally authorized in 1984; the most recent authorization is Perkins IV in 2006
• District funding allocations are based on Federal census and poverty data
• Perkins is federal money – The state (OSPI) and local grantees (districts) must follow the Education Department General Administrative Regulations
PERKINS 101
• State Allocations Are Census Based
• In-State Allocation – Secondary• District census data
• 70% based on school aged kids 5-17 census count at or below poverty guidelines
• 30% total district census data(Section 131 (a)(b))
PERKINS 101
GETTING STARTED
LEAs – Your District’s Perkins 5-Year Application Plan(iGrants form package 214, 215, or 274)
Pitfalls – • Don’t just write “something” to get the money• Local applications –
• Recipients, follow it or amend it
• Check your progress and budget at least mid-grant and 90 days before your end date
PERKINS 101
DISTRICT PERKINS APPLICATION PLAN -
• The law is just the minimum requirements
• States can add more requirements, set parameters, restrictions, etc..
• Prioritize uses of funds
• Connect accountability to uses of funds
PERKINS 101
PRIVATE SCHOOL PARTICIPATION -
• Secondary students attending nonprofit private schools can participate in public CTE programs
• Consultation with nonprofit private schools regarding the private school participation is a must
PERKINS 101NOT AN ENTITLEMENT GRANT –
• You have to have one or more programs of sufficient size, scope and quality to warrant the receipt of grant funds
• If your allocation is $15k or less, locals will need to either – • Request and receive a waiver (page 3 of the local Perkins
application plan)Or• Enter into a consortium agreement with another district(s) (form
package 214)
Waivers – Locals need to be able to justify the waiver
PERKINS IV
Waivers – Districts need to be able to justify the waiver• The district has a viable program, and
• Districts are not able to enter into a consortium due to:
• Rural isolation
• No one within a reasonable distance wishes to enter into a consortium
(Section 131 (c) (1-2): Section 132(a)(3-4): Section 132 (C): Section 132 (C)(2))
PERKINS 101LEARN THE TIMELINE
• States – Without an approved State Plan or a Plan judged to be in a “substantially approvable form” a state may not obligate Perkins funds
• Recipients – Are in the “same boat” – they can’t obligate their new grant funds until their application is “substantially approvable”…
EDGAR 34 CFR §76.703(d)EDGAR 34 CFR §76.708(a)
Example – A recipient’s new fiscal year begins July 1st. On July 6th, in anticipation of school starting, the district buys some badly needed CTE equipment . Their application for the new school year is substantially approved two days later on July 8th. This district may not use Perkins funds to pay for this equipment – even if the delay is the state’s fault.
PERKINS 101
PERKINS 101
Your district’s Perkins application is approved – you’re ready to go and spend your money! What can I spend $$$ on?
Follow your approved Perkins 5-Year Application Plan
PERKINS 101GENERAL TEST OF ALLOWABILITY
• Fits with your application
• Allowable per the appropriate OMB Circular
• Reasonable and Necessary
• Allocable
• Consistent with your district’s policies
• Not charged elsewhere
• Adequately Documented When in doubt, contact the CTE program office at OSPI
PERKINS 101SALARIES• Yes – You must do “time-and-effort” (T&E) reporting• Employee works full time on Perkins you –
• Must certify the employee at least annually• T&E records must be signed by the employee or a supervisor with first
hand knowledge• Multiple cost objectives require regular Personnel Activity
Reports (PARs)• The cost has to be “allocable” to your Perkins grant• After-the-fact reporting• Signed by employee• Coincide with pay periods; at least monthly
OSPI Bulletin #051-11Secondary, SEAs, Governments, BIE – OMB Circular A87 Appendix B.8.h.
The most common problems, goofs!
PERKINS
21
A COMMON PROBLEM
FAILURE TO FOLLOW YOUR DISTRICT’S APPROVED APPLICATION PLAN
YOUR APPLICATION
OUR APPLICATION WAS APPROVED – WE’RE GETTING THE MONEY – “LIFE IS GOOD” & I AM DONE!
• Review it at least at the 6 and 9 month points.• Follow it, or • AMEND IT• The OMB Circular A133 CTE Supplement – 4-84.048 (15 pgs.)
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COMMON PROBLEMSPROCUREMENT –
If your procurement shop or business office are not known for their attention to details - Cover your “butt”
• If you have to, keep your own set of documents• Purchase orders• Receiving documents• A mini-inventory, with item location info
• Keep it current• You need to put special procedures in place for items that cost less than $5K but are high-theft
items• Do your approved purchases agree with your approved application?• Does your annual fiscal completion report reconcile to your actual purchases?
PERFORMANCE INDICATORS
PERKINS ACCOUNTABILITY
PERKINS ACCOUNTABILITY
Purpose of Section 113 is to set out the Act’s accountability requirements and core indicators for performance at the secondary and postsecondary levels for all CTE students.
A. Sub-sections in Section 113 identify the (a) purpose, (b) state performance measures and (c) reporting.
B. Sub-section 2 Indicators of Performance identifies WHAT indicators you are being held accountable for.
PERKINS ACCOUNTABILITYSecondary Postsecondary
1S1: Academic Attainment | Reading/ Language Arts 1P1: Technical Skill Attainment
1S2: Academic Attainment | Mathematics
2P1: Credential, Certificate, or Diploma
2S1: Technical Skill Attainment 3P1: Student Retention or Transfer
3S1: Secondary School Completion 4P1: Student Placement
4S1: Student Graduation Rates 5P1: Nontraditional Participation
5S1: Secondary Placement 5P2: Nontraditional Completion
6S1: Nontraditional Participation
6S2: Nontraditional CompletionSection 113 Core Indicators of Performance
PERKINS ACCOUNTABILITYSACTIONS ARE REAL!!
Possible Sanctions if States:• Fail to implement an improvement plan, OR• Fail to show performance improvement once an improvement plan is in
place, OR• Fail to meet 90% of the same performance indicator for 3 consecutive
years
• District sanction language mirrors that of the State• State Education Agency can withhold some or all of the entire
local grant allocation
DATA SYSTEMS AND REPORTS
DATA SYSTEMS AND REPORTS
• What is CEDARS?
• What are Student Information Systems (SIS)?
• What are the Adjust Graduation Cohort Report (formerly known as the P210) and the Annual CTE Student Enrollment File (formerly known as the P210Voc Report)?
• What is Data Matching?
• Why is it important for us to submit these reports?
• What are the repercussions if we do not comply with reporting requirements?
DATA SYSTEMS AND REPORTS
The Comprehensive Education Data and Research System (CEDARS)
• Districts submit individual student, teacher, and course information on a frequent bases
• Data elements for Perkins requirements are pulled from CEDARS
• Districts verify and certify all data submitted for the CTE student enrolled for the reported year
DATA SYSTEMS AND REPORTS
Where does the student data come from?
• Annual CTE Student Enrollment File – a summary of all students served in any CTE courses in grades 7-12 in CEDARS for the current reporting
• Perkins federal reporting only includes students in grades 9-12
• Collection period: September 2014 through September 2015
How do we identify CTE Concentrators?
• Districts do not identify or report concentrators to OSPI. A concentrators is a secondary student who has enrolled in 2 or more CTE courses above the exploratory level in a single cluster.
Note: Concentrators are determined by reviewing a students entire high school enrollment history
DATA SYSTEMS AND REPORTS
CEDARS Outcomes
• CEDARS has reduced the redundancy in reporting from districts
• Allow OSPI to generate and consolidate reports for district viewing
• CEDARS reports are used for federal, state, and local use to determine funding of certain programs
CEDARS Data FilesLocation File
Student Demographics Student Enrollment Information Course Catalog Student Schedules* Grade History
D–Course Catalog
H-Grade History
E-Student Schedules
C–School Student File (enrollment)
B–District Student File
(demographics)
A–Location File
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CIP CODEState
Course Code
TEACHER CERTIFICATION
V-CODE COURSE NAME
010504 18102 V010000 Dog/Pet/Animal Grooming
010507 18104 V010000 Equestrian/Equine Studies
190706 19052, 22204 V200002 Child Development/Parenting
State Course Codes… mapped to CIP Codes
Grade History File data elements• Element H04 – State Student ID (SSID)
• Element H05 – Location ID
• Element H06 – Staff ID
• Element H07 – Course ID
• Element H08 – Course Title
• Element H09 – Grade Level Code
• Element H10 – Letter Grade
• Element H11 – Credits Attempted
• Element H12 – Credits Earned
CEDARS Grade History File
Grade History File data elements, cont’d• Element H13 – Course Designation Code
• Element H16 – (AP) and (IB) Code
• Element H17 – (CIP) Code Number
• Element H18 – Term End Date
• Element H19 – Term
CEDARS Grade History File
CTE Grade History File data elements –• Element H20 – Is the Student a Career and Technical Education
(CTE) Program Completer?
• Element H21 – Did Student Receive a State or Nationally Recognized Industry Certification?
• Element H22 – Is Career and Technical Education (CTE) Direct Transcription Available?
• Element H23 – Is Tech Prep Completer?
• Element H24 – Did the Student Take or Pass a State or Nationally Recognized Assessment of Technical Skills and Knowledge?
CEDARS Grade History File
WORK CLOSELY WITH YOUR CTE TEACHERS AND CEDARS
ADMINISTRATORS
CTE DATA AND REPORTS
ALLOWABLE/UNALLOWABLE USES OF PERKINS FUNDS
• EDGAR (34 CFR §80.1) defines equipment as personal property that costs $5,000 or more – The issue has more to do with a state’s inventory requirements (and the associated costs) than the purchase price
• The OIG (Office of Inspector General) has been issuing findings relative to items of equipment that are considered “attractive theft” items – cell phones, digital cameras, flat screen monitors, etc. that cost a lot less than $5,000
• When is something a supply and not equipment?
• Use a “reasonable person approach” – Does it have a useful life of a year or more, would you throw it away or repair it, does your own district’s criteria treat it as a supply or equipment? (see handout on Criteria for Distinguishing Non-capitalized Items from Capital Outlay – blue handout)
EQUIPMENT
PERKINS
41
• Get it written into your approved application
• Items like your CTE computer lab
• Specialized workstations
• The cost of connecting equipment
• Etc.
• Avoid paying for stuff your district typically supplies to all your district’s educational programs – desks, chairs, PCs
• USE NON-PERKINS FUNDING WHERE POSSIBLE
• Trade Perkins-funded CTE costs for those CTE costs funded with non-federal $$$
• Pursue donated equipment where possible
EQUIPMENT CONT.
PERKINS
42
Little guidance – the Feds typically refer you back to 34 CFR §403.71(c) – The last regulatory guidance for Perkins, under Perkins I
• Allowed – Instructional related costs (very narrow)
• Disallowed – All the fun stuff…
CAREER AND TECHNICAL STUDENT ORGANIZATIONS
CTSO
States – Section 124(c)(4)Local Recipients – Section 135(c)(5)
43
(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) Cost of non-instructional activities such as athletic, social, or recreational events;
(iv) Printing and disseminating non-instructional newsletters;
(v) Purchase of awards for recognition of students, advisors, and other individuals; or
(vi) Payment of membership dues;
(d) Leadership and instructional programs in technology education; and
(e) Data collection.
(3) The support of vocational student organizations may not include—
My guess, they mean, non-instructional, out-of-the-classroom-type activities that don’t meet the conditions of 34 CFR § 403.71(c)(2)(iv) & – “all students…”
34 CFR §403.71(C)
PERKINS
44
45
PERKINSAllowable Costs
• Reasonable and Necessary;
• Allocable to the Federal Award;
• Legal Under State and Local Law;
• Properly Documented;
• Consistent with the Provisions of the Grant Program; and
• Not used for cost sharing or matching any other grant agreement.
OMB Circular A-87See Handout Appendix B
• “NO”
• Unless it is related to –
• Approved travel (subject to your state’s per diem guidelines)
• Included in your approved registration
• Not considered entertainment
• Included as part of an approved conference or meeting (attending or sponsoring)
• A consumable training supply (culinary arts)
• Alcohol never allowed
Read Goods or services for personal use – A87 Attachment B.20 & A21 Section J. 22.
FOOD & BEVERAGES PERKINS
OMB A87 B.3; OMB A21 J.3OMB A87 B.14; OMB A21 J.17OMB A87 B.27; OMB J.32OMB A87 B.43; OMB J.5346
• Travel is allowable when it supports your approved grant or plan
• Meals, lodging, all the usual stuff is allowable, when approved
• Should be reasonable
• DOES NOT INCLUDE ENTERTAINMENT COST
What about those conferences where entertainment is included in the registration fee?
• It’s your state’s call…
If the cost is separate and identifiable and the employee wants to participate they must cover the cost out of their own pocket
OMB A87 Attachment B.43 or OMB A21 Section J.53
TRAVEL FOOD & BEVERAGES
PERKINS
47
OMB A87 B.27 (Comparable language in OMB A21 J.32)
“Meetings and conferences. Costs of meetings and conferences, the primary purpose of which is the dissemination of technical information, are allowable. This includes costs of meals, transportation, rental facilities, speaker’s fees, and other items incidental to such meetings or conferences. See OMB A87 B.14; OMB A21 J.17, “Entertainment Costs”.
• Must be reasonable
• Must be able to stand the, “Would you like to see this on the front page of your local paper?” test
• Does NOT include internal staff meetings
MEETINGS & CONFERENCES/FOOD & BEVERAGES
PERKINS
48
• Memberships for a district is OK . For example the cost would be OK for your district CTE Director’s position, regardless of who the individual is – but not for the individual who is the CTE Director
• Must be “allocable” to your Perkins project or plan
• Use the “reasonable person” approach
• It is recommended that you utilize your procurement system procedures if you are looking at a -
• Significant cost
• Sole source provider (speakers, intellectual property, copyrighted, etc.)
MEMBERSHIPS, SUBCRIPTIONS & PROFESSIONAL ACTIVITY COSTS
PERKINS
49
• Awards or Gifts -Typically Not Allowed
• However you can purchase nice frames through your approved local office supply contract, print out a nice certificate on your color laser printer and hand the result to folks…
• Hand out donated items from your state’s Chamber of Commerce, local industry groups, etc.
AWARDS
PERKINS
OMB A87 B.1.f(3); OMB A21 J.1.f(3)OMB A87 B.20; OMB A21 J.22
50
• Alcohol
• Entertainment expense
• Awards (gifts)
• Promotional items (freebies)
• Promotional advertising
NOT ALLOWED
PERKINS
• OMB A87 B.3; OMB A21 J.3• OMB A87 B.14; OMB A21 J.17• OMB A87 B.20; OMB A21 J.22• OMB A87 B.1.f.(3); OMB A21 J.1.f(3)• OMB A87 B.1.f(4); OMB A21 J.1.f(4)
51
CONSOLIDATED PROGRAM REVIEW (CPR)
CONSOLIDATED PROGRAM REVIEW (CPR)
• Monitor multiple federally funded programs under the Elementary and Secondary Education Act (ESEA)
• Fulfills OSPI’s compliance monitoring requirements under Federal regulations (2 CFR 200)
• The CPR process consists of an OSPI team reviewing school districts federal and selected state programs
• The monitoring activities are designed to focus on the results of the district’s efforts to implement critical requirements of the ESEA using available resources and flexibility provisions
District Contacts
CPR Contact
• Responsible for coordinating the review for all monitored federal and state programs.
• All future communication will be sent to this individual and the district superintendent.
• Provide name, title, phone number and email address.
• Fiscal Contact
• Point of contact for fiscal cross‐cutting portion of review.
• Provide name, title, phone number and email address.
CONSOLIDATED PROGRAM REVIEW (CPR)
Title I, A Title IV, B –Rural Education
LAP (Learning Assistance Program) Title X –McKinney-Vento (Homeless)
Title I, C –Migrant Ed Highly Capable
Title I, D –Neglected and Delinquent Perkins / CTE
Title I, G –AP (Advanced Placement) Private Schools
Title II, A –Highly Qualified Civil Rights
TBIP (Transitional Bilingual Instructional Program / Title III
Fiscal
Gun-Free Schools Act OSSS (Office of Student and School Success)
CONSOLIDATED PROGRAM REVIEW (CPR)
CPR Review Timeline
2015-16:Districts in ESDs 121 and 1712016-17:Districts in ESDs 105, 112, and 1132017-18:Districts in ESDs 105, 112, and 113
2018-19: Districts in ESDs 123 and 189 The “BIG 4” Districts
• Reviewed annually.
• Due to the size and amount of federal funds managed, these districts pose a potentially higher risk for noncompliance.
• Generally two day visits.
Other LEAs Reviewed
We are moving to a process that reviews other Local Education Agencies (LEA)s that receive funds from OSPI as the State Education Agency (SEA) and provide services.
This year as part of CPR, we are reviewing:• 3 Tribal Compact Schools
• 2 ESDs
• 1 Charter School
CPR 2015-161-Day Sample Agenda
8:30-9:30 a.m.
Entrance Meeting:Introductions and Overview of CPR ProcessDiscussion about Program Practices with OSPI and District Staff
9:30-11:30 a.m.
Discussion with District Program StaffBuilding visits
11:30-12:30 p.m.
Lunch
12:30-3:00 p.m.
Continuation of Building VisitsContinuation of Discussion with District Program Staff
3:00-4:00 p.m.
CPR Team Preliminary Report Preparation(OSPI team will be at the district office to prepare for the exit interview)
4:00-4:30 p.m.
Exit Meeting and Closing Observations
Day 1 CPR team members continue with review and end day around 4:00-4:30pm
Day 28:30-3:00 p.m.
Continuation of Building VisitsContinuation of Discussion with District Program Staff
3:00-4:00 p.m.
CPR Team Preliminary Report Preparation(OSPI team will be at the district office to prepare for the exit interview)
4:00-4:30 p.m.
Exit Meeting and Closing Observations
CPR 2015-162-Day Sample Agenda
Digital Checklist
• OSPI will use Program Monitor, a web application in the Education Data System (EDS), for the management of review content and as a replacement of the paper checklists used in the past.
• Districts upload all documentation for review to the online Program Monitor tool beginning 12 weeks (and no later than 6 weeks) prior to the review start date.
• We do not accept emails or paper copies of documentation.
• Access Program Monitor here: https://eds.ospi.k12.wa.us/ProgramMonitor/
CONSOLIDATED PROGRAM REVIEW (CPR)
Uploading and Formatting
CPR - Follow‐Up Process
CONSOLIDATED PROGRAM REVIEW (CPR)
CPR TEAM LEAD CONTACT INFORMATION
Anne Renschler, Program SupervisorConsolidated Program ReviewAnne.Renschler@k12.wa.us360-725-6229
Sylvia Reyna, Program SupervisorMigrant EducationSylvia.Reyna@k12.wa.us360-725-6147
Timothy McNeely, Program SupervisorConsolidated Program Review and Rural Education Timothy.Mcneely@k12.wa.us360-725-6234
PERKINS 101 TAKE WAYS
• Learn the timeline
• Understand the performance indicators
• Understand fiscal responsibilities
• Establish a local team; internal and external
• Seek and participate in technical assistance provided by State staff
• Organize electronic/paper files
• Monitor and adjust
66
CTE PROGRAM OFFICE CONTACT INFO
67
Ken Emmil, Assistant SuperintendentCareer and College ReadinessKen.Emmil@k12.wa.us360-725-6245
Vacant, DirectorCareer and Technical Education@k12.wa.us360-725-6245
Marianna Goheen, Program SupervisorHealth SciencesMarianna.goheen@k12.wa.us360-725-6257
Rebecca Wallace, Program SupervisorAgriculture EducationRebecca.wallace@k12.wa.us360-725-6244
Phouang Hamilton, Program SupervisorGrants and Innovative ProgramsPhouang.hamilton@k12.wa.us360-725-6253
Denise Mileson, Program SpecialistGRADS Denise.Mileson@k12.wa.us360-725-0417
Mary Nagel, Program SupervisorFamily and Consumer SciencesMary.nagel@k12.wa.us360-725-6242
Lance Wrzesinski, Program SupervisorBusiness and MarketingLance.wrzesinski@k12.wa.us360-725-6258
Deifi Stolz, Program SupervisorMethods of AdministrationDeifi.stolz@k12.wa.us360-725-6254
Denny Wallace, Program SupervisorSkills and Technical SciencesDennis.wallace@k12.wa.us360-725-6241
Mary Kanikeberg, Program SupervisorJobs for Washington’s GraduatesMary.kanikeberg@k12.wa.us360-725-6244
Clarence Dancer, Program SupervisorSTEMClarence.dancer@k12.wa.us 360-725-4467Diane Gard, Executive Assistant | Diane.Gard@k12.wa.us
Monica Trabue, Secretary| Monica.Trabue@k12.wa.us Jill Pilbro, Secretary | Jill.pilbro@k12.wa.us
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