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OSEP Verification Visits Fiscal Component

FFY 2008-2009

Office of Special Education Programs

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Introducing The Critical Elements Analysis Guide (CrEAG)

CrEAG is a tool for organizing and analyzing data to identify what will be addressed during a verification visit.

Part B CrEAG documentPart C CrEAG document

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Introducing CrEAGCrEAG replaces old information

collection forms, including the OSEP Fiscal Desk Audit form.

CrEAG is used to organize data and information collected prior to, and during, the verification visit.

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Introducing CrEAGPre-visit sharing of CrEAG with States

Pre-visit conversations with States about questions in CrEAG

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Introducing CrEAGA State is not required to complete the

CrEAG and submit it to OSEP.

A State is permitted to complete all or part of CrEAG and submit it to OSEP.

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Components of CrEAGCritical Elements for each focus areaRelated Questions for Critical Elements

– Cells for responses and notes for each Related Question

– Cells for flagging issuesRelated Requirements for each Critical

Element

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Components of CrEAGCrEAG includes sections to record the review and analysis of--

Customer Service Information (e.g., parent contacts)

Information from interviewsDocuments (e.g., SPP/APR)

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How OSEP Uses CrEAG

To organize relevant data and documents for review prior to a verification visit

To summarize information from various sources (e.g., parent contacts, APR issues, data reports, audit reports, etc.)

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How OSEP Uses CrEAGTo determine who is interviewed on-siteTo identify what will be addressed on-

siteTo develop the foundation of OSEP’s

verification letter

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Critical Elements in CrEAG

Revised Critical Elements

Revised Related Questions for the Critical Elements

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Fiscal Critical Elements

There are Fiscal Critical Elements for Part B and Part C

Fiscal Critical Elements for Part B apply to Section 611 and Section 619 grants

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Fiscal Critical Elements There are differences between Section

611 and Section 619 requirements

The SEA is responsible for proper disbursement and use of Section 619 funds

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First Fiscal Critical Elementfor Part B and Part C

FS-1 Does the State have procedures that are reasonably designed to ensure the timely obligation and liquidation of IDEA funds?

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Related Questions Under of FS-1

FS-1 includes questions about—Timely obligation of funds (within the 27

month obligation period)Timely liquidation of funds (no later

than 90 days after the obligation period)

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Second Fiscal Critical Element for Part B

FS-2 Does the State have procedures that are reasonably designed to ensure appropriate distribution of IDEA funds within the State?

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Related Questions Under of FS-2—Part B

FS-2 includes questions about--Expending funds consistent with Part B

requirementsCalculating subgrantsUse of administrative

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Related Questions Under of FS-2—Part B (continued)Funds to charter schoolsState funding mechanisms and LREFunds for children parentally-placed in

private schoolsFunds for the LEA Risk

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Second Fiscal Critical Element for Part C

FS-2 Does the State have procedures that are reasonably designed to ensure appropriate use of IDEA funds at the State level?

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Related Questions Under of FS-2 --Part C (continued)

How does the lead agency ensure that Part C is the payor of last resort – that other public or private sources pay for commitments for which they are legally responsible?

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Related Questions Under of FS-2 --Part C (continued)

How does the State ensure that Part C funds are not commingled with State funds?

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Related Questions Under of FS-2-- Part C (continued)How does the lead agency ensure that

the total amount of State and local funds expended for early intervention services in one year is maintained or increased in each subsequent year?

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Related Questions Under of FS-2--Part C (continued)How does the lead agency ensure that

Federal funds are used only for allowable purposes (consistent with 20 U.S.C. 1435 and 1438)?

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Related Questions Under of FS-2-- Part C (continued)Does the lead agency have a system of

payments? If yes, is it approved by OSEP?

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Related Questions Under of FS-2 --Part C (continued)Describe the system of payments,

including use of co-insurance, co-payments, sliding fees, defining inability to pay, etc.

What is the Status of the State’s indirect cost rate?

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Related Questions Under of FS-2 --Part C (continued)What are the barriers that impede the

State’s ability to ensure fiscal compliance with the Part C requirements?

What is the State doing to address these barriers?

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Third Fiscal Critical Element

Part C does not have a third Critical Element.

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Third Fiscal Critical Element for Part B

FS-3 Does the State have procedures that are reasonably designed to ensure appropriate use of IDEA funds?

(Note: Section 611 and Section 619 have different requirements.)

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Related Questions Under of FS-3

FS-3 includes questions about--– Communication between finance and

program officials– Accounting procedures– Supplement/not supplant – Maintenance of effort / excess cost

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Related Questions Under of FS-3 (continued)

– Continuous Early Intervening Services (CEIS)

– Control over property, equipment, etc. in schools serving parentally-placed students

– Conducting Single Audits

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QUESTIONS

Discuss questions with your State Contact.