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© 2021 Tennessee Department of Education

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We will set all students on a path to success.


Regional LEA Grant Oversight Professional Development In-Person Sessions

Office of Districts and Schools | July 2021

AgendaTime Overview

5 minutes Welcome

40 minutes Results-Based Monitoring and IEP Monitoring Changes

20 minutes Reimbursement Request Monitoring

10 minutes Break

60 minutes EDGAR Q & A with Brustein and Manasevit

20 minutes Department Updates

20 minutes Q & A with TDOE Program Leads

5 minutes Closing


Welcome

S T U D E N T R E A D I N E S S

TENNESSEE PUBLIC SCHOOLS WILL BE EQUIPPED TO SERVE THE ACADEMIC AND NON-ACADEMIC NEEDS OF ALL

STUDENTS IN THEIR CAREER PATHWAYS

A C A D E M I C S

ALL TENNESSEE STUDENTS WILL HAVE ACCESS TO A HIGH-QUALITY EDUCATION,

NO MATTER WHERE THEY LIVE

E D U C AT O R S

TENNESSEE WILL SET A NEW PATH FOR THE EDUCATION PROFESSION AND BE

THE TOP STATE TO BECOME AND REMAINA TEACHER AND LEADER FOR ALL

We will set all students on a path to success.


Results-Based Monitoring and IEP Monitoring Changes Geneva Taylor | Senior Director of Compliance


Results-Based and IEP Monitoring Agenda

Common Terms Monitoring Basics

– Risk Analysis– Monitoring Components– Identification

What to Expect Monitoring Tiers Results-Based Monitoring Key Changes Risk Analysis Examples IEP Monitoring Key Changes Summary

Monitoring Basics: Common Terms

Tier: One of three Results-Based Monitoring processes– On-Site: Monitoring tier for LEAs earning a significant risk designation on the

risk analysis (at least 10%; approximately 15% in FY22)– Desktop: Monitoring tier for LEAs earning an elevated risk designation on risk

analysis (at least 10%; approximately 15% in FY22)– Self-Assessment: Monitoring tier for LEAs earning a low risk designation on

the risk analysis (all remaining LEAs; approximately 70% in FY22) Risk Analysis: evaluation of each LEA’s risk of non-compliance for

purposes of monitoring Risk Analysis Guide: data factors, business rules, and processes

that outline the risk analysis– will be publicly available for the first time this year!

Monitoring Basics: More Common Terms

Focus Monitoring: Not part of tiered RBM process; a specific review of a certain program(s) exhibiting systemic or egregious compliance concerns discovered via the monitoring processes, filed complaints, or observations Wave: a group of LEAs participating in IEP Monitoring at a specific time IEP Protocol: the document by which LEAs are reviewed to determine

compliance in IEP Monitoring

IEP Monitoring

Other Types of Monitoring Managed by FPO

CCEISFocus

Monitoring

CEIS Discretionary

Monitoring Basics: Why is a risk analysis required? The department must conduct a risk analysis according to 2 CFR

200.331 (pg. 147 of EDGAR), evaluate each subrecipient's (LEA's) risk of non-compliance for purposes of determining appropriate monitoring, and monitor its subrecipients to assure compliance and performance goals are achieved. Monitoring must include reviewing financial (OCFO) and

programmatic (FPO) reports, ensuring corrective action (Monitoring Results), and issuing a management decision on audit findings (approval/non-approval).

Key Changes: Results-Based Monitoring

FY21 (Last year)– ESEA/IDEA Program Monitoring,

Perkins Program Monitoring, and Fiscal Monitoring were in separate instruments.

– All LEAs identified for ESEA/IDEA Program monitoring participated in a separate, additional IEP monitoring (in addition to IEP-Self Monitoring) of 5 files per school.

– Mostly one day visits (virtually)– Agendas were shared via email.

FY22 (Upcoming Monitoring Cycle)– ESEA/IDEA/Perkins/ESSER/Fiscal in one

instrument, all embedded in ePlan (like ESEA/IDEA and Perkins was in FY21)

– LEAs identified for Results-Based Monitoring will not, by default, complete a separate, additional IEP monitoring.

– 1.5-day visits more likely.– Agendas will be embedded in ePlan.

Monitoring Expectations

Virtual (mostly) in FY22– Visits related to Focus Monitoring will have a small team onsite

Monitoring Merge– Reducing duplication of questions across sections– Increasing coherence with department feedback– Less burdensome over all for all LEAs

Monitoring Basics: Identifying LEAs via a Risk Analysis The risk analysis includes factors related to missed deadlines, staff

experience, Office of Civil Rights (OCR) findings, total allocations of federal funds received, fiscal issues such as releasing funds, audit findings, program compliance findings, and years since last monitored on-site, in addition to other factors. The risk analysis process occurs by July, dependent on the release

of data that is often unavailable at the department until later in the summer months. By Aug. 15, LEA-level staff may access the risk analysis to guide

conversation regarding specific areas of concern and to better understand how to mitigate risk factors within their control.

Monitoring Process: What to Expect Identification:

– The department identifies LEAs based on the results of the risk analysis in July or August.

– New: Risk Analysis access in August. Review and Acknowledge/Appeal within 5 business days.

Data Collection: – The department examines assessment and growth data for application and

budgets, plans, EIS data, state report card, and LEA and school websites. Communication:

– The department notifies the identified LEA's director of schools, ESEA director, and IDEA director via email in August.

– The email includes the tier of monitoring, deadline, and time period in which the department will review monitoring submissions.

Monitoring Process: What to Expect School Selection (on-site and desktop only):

– The department selects the schools for monitoring based upon risk analysis results, poverty percentages, demographic information, subgroup performance, and other factors.• For LEAs served by East/Middle/West, two Title I schools, a non-public school (if applicable),

and a charter school (if applicable) are chosen for the ESEA/IDEA monitoring.• For LEAs that are the 20 Most Populous, three Title I schools, a non-public school (if

applicable), and a charter school (if applicable) are chosen for the ESEA/IDEA monitoring.

Monitoring Process: What to Expect Preparation:

– The department opens the Monitoring Instrument in ePlan for LEAs and schools to respond to pre-visit questions.

– FPO divisional coordinators meet virtually with the LEA to provide technical assistance .

– Assigned team members review documentation and data uploaded by the LEA and school(s) and identify additional questions to ask.

Monitoring Process: What to Expect On-Site Visit/Review:

– FPO conducts a visit or review that lasts one to five days depending on the size of the LEA, with about two hours dedicated per school identified.

– The team and LEA leaders meet for a brief entrance discussion, and with the ESEA, IDEA, CTE, and ESSER director(s), fiscal team, and other LEA-level staff.

– Monitors also engage with leaders, staff members, and other stakeholders from selected schools.

Monitoring Process: What to Expect Monitoring Results Review:

– FPO develops Monitoring Results based on information collected. – Monitoring Results (exceeded requirements, met requirements, improvement

recommended, corrections required, finding(s) of non-compliance) are presented at an exit conference to the director and LEA leadership team via a web conference approximately 10 business days after the conclusion of the on-site visit.

– All members present for the exit access the Monitoring Results in ePlan and confirm electronically that they understand the results and required action steps (if any).

Monitoring Process: What to Expect Follow-Up and Technical Assistance:

– After the review of the Monitoring Results, the assigned FPO divisional coordinators follows up with the LEA staff until all compliance issues are resolved.

– Failure to meet deadlines outlined in the Monitoring Results can result in added points to the subsequent risk analysis, a focus monitoring, conditions on grant awards, or other actions.

Closure: – Once all items have been completed, an official correspondence via an

automated status change in ePlan is shared with the LEA. – In addition, a survey link is emailed to LEA and school staff members to collect

feedback on the monitoring process for FPO to continue to improve the process and ensure it is effective and not overly burdensome to LEA partners.

Risk Analysis – Summary of Categories

ESSA– Subgroup Data– ESSA Complaints with Findings– RBM Action Steps– ESSA & ESL Director Experience

IDEA– APR Determination– IDEA Complaint/Due Process Findings– Significant Disproportionality– IDEA Director Experience– RBM Action Steps– IEP Monitoring Action Steps

Perkins– CTE PD Attendance– CTE Monitoring Results– CTE Drawdown– CTE Director Experience– CTE PD Allocation

Finance– Single Audit Findings or N/A– Fiscal Monitoring Findings– Central Finance Office– IDEA Excess Carryover– Fiscal Rep/Bookkeeper Same– ESSEA/IDEA/Perkins/ESSER Awards– ESSER 1.0 RR Half Expended– ESSER 2.0 Monthly RR– ESSA & IDEA Bookkeeper Experience– CFO Treasurer Experience– IDEA Dropdead/Release– ePlan Final Budget Deadline

Cross-Cutting– CSI Schools– Priority Schools– In Need of Improvement– Grant Conditions Notifications– ESEA/IDEA Director Same– TN OCR Findings– Director of Schools Experience

Risk Analysis – Embedded in ePlan

ePlan > Search > Data and Information Automatic notices will go out when available. (on or by Aug. 15) Summary included on each risk analysis

– Total Score (ESSA Subtotal + IDEA Subtotal + Perkins Subtotal + Other Subtotal + Fiscal Subtotal + Years Since Last Monitored Subtotal)

– Results-Based Monitoring Tier for FY22– Reason for Tier - (ESSA Subtotal, IDEA Subtotal, Perkins Subtotal, Finance Subtotal,

Focus Monitoring, or Total Score)

Reminder: LEAs must acknowledge.

Risk Analysis – New Guide

Available by Aug. 15, the guide will serve as a companion manual to the risk analysis, guiding LEAs through reviewing the risk analysis results, including data used, business rules, and process for choosing schools.


That was a lot!

Questions before we talk about IEP monitoring for a few seconds?

Key Changes: IEP Monitoring

FY21 (Last year)– IEP Self-Monitoring

• 4-level process– IEP Self-Monitoring required LEAs to

provide 10 IEP records, identified by the SEA, for review during one of three time periods, called waves.

– 3 waves– 30-day review window (20 business

days)

FY22 (Upcoming Monitoring Cycle)– IEP Monitoring

• Still a 4-level process• Better reflects the non-self part of IEP

Monitoring– IEPs reviewed based on the confidence

interval using last year’s finding ratio.– 4 waves– 14-day review window (10 business days)

Key Similarities: IEP Monitoring

The purpose of the two LEA-level reviews is not to correct issues before IEP files are submitted to the SEA for review.

Use this time to create or improve upon a system of internal controls and monitoring and self-identify trends.

Examples:– Correcting uploading errors is encouraged (i.e. deleting that soccer photo and uploading the

correct PWN)– Attempting to correct issues of non-compliance in the IEP document is not the purpose. (i.e.

an issue that would require a new meeting within the 10-day review time period) The purpose of the two SEA-level reviews is to norm LEA-level responses,

determine trends, and determine appropriate corrective actions (when needed), as well as provide support through closure.

What are the four levels of review?– The Case Manager– The IDEA Director– IDEA Monitoring Specialist– IDEA Compliance Coordinator

IEP File Reviews

Confidence Interval and Response Distribution used to determine a Sample Size for file reviews in FY22.– FY21 file review data used to determine risk.– Taking % of non-compliance (number of findings/total items reviewed) to

determine IEP non-compliance risk.

– * IEPs and associated documents.

Minimal

6

~31

0-2.9%

4self-assessment

IEPs* Reviewed

Likely # of LEAs

Non-Compliance %

Wave

Low

10

~27

3.0-4.9%

Mostly 4self-assessment

Medium

15

~55

5.0-9.99%

Mostly 3self-assessment

Elevated

20

~27

10.0-19.99%

2 desktop; elevated

Significant

28

~8

20+%

1on-site; significant

Hyperlinks to law and general language “tweaks” Separation of Transition and Post-Secondary Transition

IEP File Reviews: Protocol Updates

Focus Area: TransitionItem Category Response Criteria: Meet response criteria for compliance for each item. Required Document(s)

T.38Student Invitation to MeetingTN SBE Rule 0520-01-09-.12

The LEA provided written documentation inviting the student to the IEP meeting and states the purpose (all applicable reasons for meeting must be listed and/or checked) was the consideration of postsecondary goals & transition services needed to assist the student in reaching these goals.

Student Meeting Invitation

Focus Area: Secondary TransitionItem Category Response Criteria: Meet response criteria for compliance for each item. Required Document(s)

S.38Student Invitation to Meeting34 CFR § 300.321(b)(1)34 CFR § 300.322(b)(2)(I)(A)

The LEA provided written documentation inviting the student to the IEP meeting and states the purpose was the consideration of postsecondary goals & transition services needed to assist the student in reaching these goals. Note: All applicable reasons for meeting must be listed and/or checked.

Student Meeting Invitation

https://www.tn.gov/content/dam/tn/stateboardofeducation/documents/2021-sbe-meetings/february-5%2c-2021-sbe-meeting/2-5-21%20III%20D%20Special%20Education%20Programs%20and%20Services%20Rule%200520-01-09%20Clean.pdf#page=19

https://sites.ed.gov/idea/regs/b/d/300.321

https://sites.ed.gov/idea/regs/b/d/300.322

IEP File Reviews: Protocol UpdatesItems Focus Area Requirements

I.1 - I.15 Initial Evaluation

School- or LEA-level reviewers will complete only one of these two categories during a file review. If the category showing on the monitoring platform does not align to student record, please contact the SEA immediately.R.1 - R.13 Reevaluation

16 - 37 IEP School- or LEA-level reviewers must complete these items for all selected files.

T.38 - T.40

Transition Prior to the age of 14 up to the IEP in which the student will turn 16

School- or LEA-level reviewers must complete these items if the student was turning age 14 (or younger if determined appropriate by the IEP team) or was in grade 9 at the time of the most recently developed IEP.If the category showing on the monitoring platform does not align to student record, please contact the SEA immediately.

S.38 - S.44

Post-Secondary Transition Age 16 or older

School- or LEA-level reviewers must complete these items if the student was turning age 16 at the time of the most recently developed IEP.If the category showing on the monitoring platform does not align to student record, please contact the SEA immediately.


Results-Based and IEP Monitoring Review

Common Terms Monitoring Basics What to Expect:

– Mostly Virtual in FY22; merging instruments Monitoring Tiers:

– On-Site, Desktop, Self-Assessment Results-Based Monitoring Key Changes Risk Analysis Examples IEP Monitoring Key Changes:

– files based on risk; – on-site LEAs not subject to separate monitoring by default– IEP Protocol has links to law now!– IEP Protocol splits transition and secondary transition


Contact

Geneva Taylor | Senior Director of [email protected]

mailto:[email protected]


Request: If your LEA has or will have a new IDEA director in FY22… Please complete this very short survey to let

us know so we can be sure to contact the correct individuals for IEP Protocol training. https://forms.office.com/r/w7SRyyAFx2


Reimbursement Request Monitoring Maryanne Durski

Reimbursement Request Monitoring Process

In accordance to §200.332 (d), all pass-through entities must: “(d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.”– Includes reviewing financial documentation supporting reimbursement

requests.

Reimbursement Request Monitoring Process: What to Expect Identification:

– The department will select specific reimbursement requests to monitor based on sampling all submitted reimbursement requests.

Communication: – The department will notify the relevant federal grant contact identified in each

based on the specific reimbursement request via email. – The email will request all supporting documentation for the selected

reimbursement request’s details. Provided details include:• Date requested in ePlan• Amount• Grant• Voucher number

Reimbursement Request Monitoring Process: What to Expect Supporting Documentation:

– The LEA will provide all supporting documentation pertinent to the reimbursement request.

– Documents may include but not limited to:• Invoices• Purchase orders• Payroll registers

– Do not submit any information with personally identifiable information (PII)! Redact or remove this data.

Reimbursement Request Monitoring Process: What to Expect Review:

– Grants Management will conduct a review to determine if documentation is adequate and supports allowability under grant requirement.

– Parameters include but not limited to:• Period of availability• Allowability• Accuracy (does the supporting documentation add up to the reimbursement?)

Additional Questions: – Grants Management will contact the LEA with any follow up questions to

resolve any outstanding issues.– If any potential issues are identified, Grants Management will provide the LEA

with notification of what those issues are.

Reimbursement Request Monitoring Process: What to Expect Exit:

– Grants Management will develop Reimbursement Request Monitoring Results based on information collected.

– Reimbursement Request Monitoring Results (met requirements, corrections required due to finding(s) of non-compliance) are presented at an exit letter to the director

• Met Requirements: No further action required. The monitoring process is complete.• Corrections Required Due to Finding(s) of Non-Compliance: A corrective action is

required. Corrections may include removing the transaction from the grant and replace with an allowable transaction or pay the department back.

Monitoring Process: What to Expect

Follow-Up and Technical Assistance:– After the review of the Reimbursement Request Monitoring Results, the

assigned Grants Management staff will continue to follow up with the LEA staff until all issues are resolved.

– Failure to meet deadlines outlined in the Reimbursement Request Monitoring Results can result in added points to the subsequent risk analysis, a focus monitoring, conditions on grant awards, or other actions.

Break10 minutes


EDGAR Q & ABrustein & Manasevit, LLC


BruMan Link

Dogwood ES: Click here to join the meeting

Hamilton BOE: Click here to join the meeting

Cookeville Life Church: Click here to join the meeting

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Department UpdatesEve Carney

© 2020 Tennessee Department of Education © 2020 Tennessee Department of Education

Pursuant to the authority under ESEA § 8401, the Tennessee Department of Education will be providing LEAs the opportunity to request waivers of the following provisions: Section 1127(b) of Title I, Part A of the ESEA so that your LEA

may waive, more than once every three years, if necessary, the 15 percent carryover limitation in ESEA § 1127(a) for FY21 Title I, Part A funds.

Section 421(b) of the General Education Provisions Act (GEPA) to extend the period of availability of FY20 funds until Sept. 30, 2022.

Waivers for ESEA Programs


FY22 final allocations for the Elementary and Secondary Education Act (ESEA) and Individuals with Disabilities Education Act (IDEA) programs will be loaded into the Consolidated Funding Application (CFA) the first week of Sept.

In addition, later this summer, the department will load the additional funds earmarked for IDEA grants from the American Rescue Plan Act of 2021 (Public Law 117-2). These additional funds are provided to LEAs to help recover from the Coronavirus pandemic's impact and reopen schools and sustain safe operations safely.

FY22 ESEA and IDEA Final Allocations

Required District Plans

Health and Safety Plan Spending Plan Public-facing District Plan

– Posted on websites– Updated regularly– Due August 27– Will be reviewed as received– All public-facing plans must have Commissioner approval prior to

approval of spending plan


Relief Funding Opportunities Eve Carney


Best For All: Leveraging ESSER Plans

Understandwhat is needed for students to access grade-level content over the next 3 years

Assess the academic, mental health, and other needs to students and staff.

Design an LEA recovery plan aligned to the one-time funds received and needs of students.

Implement the components of the plan, with a strong focus on quality of a few, large initiatives, and a clear process for data collection.

Monitor, Evaluate and Adjust based on the results of the data collection and feedback from students and staff.


ARP IDEA Application Timeline

July 15• ARP IDEA Allocations Released

July 21 • ARP IDEA Webinar Releases and Posts

July 22• ARP IDEA Application opens in ePlan

July 22 • ARP IDEA Office Hours start

Aug. 27• All applications due in ePlan

ARP IDEA Funds expire Sept. 30, 2023


The department submitted the ARP Homeless 2.0 application to the U.S. Department of Education on July 15.ARP Homeless 2.0 funds are expected to be allocated to LEAs in early

September.Allocations will be based on FY21 Title I, Part A allocations and either FY19 or

FY20 homeless students counts for each LEA (higher count of the two years).Webinars and office hours will be offered to support LEAs in the ePlan

application process.More information will be shared soon.

ARP Homeless 2.0

ARP Homeless Funds expire Sept. 30, 2024


ESSER 1.0 and ESSER 2.0 Funding Application Timeline

July 1• Fiscal Year 22 begins

Aug. 1• ESSER 1.0 and ESSER 2.0 Final Expenditure Report (FER) due

Aug. 27• All ESSER 1.0 and ESSER 2.0 FY22 applications due in ePlan

ESSER 1.0 funds expire Sept. 30, 2022 | ESSER 2.0 funds expire Sept. 30, 2023


ESSER 3.0 Funding Application Timeline

Apr. 15• Application opens in ePlan

Aug. 27• Application due in ePlan

Sept.

• Application reviewed by department staff (multiple levels including Commissioner approval)

ESSER 3.0 funds expire Sept. 30, 2024


Planning Grant Support districts in developing strong ESSER plans, targeted at moving

student achievement forward

TN ALL Corps Approximately 25% of students will have access to three years of consistent,

quality tutoring supports – with strong core instruction and summer school, there is no better way to improve student achievement.

Other Grants to Support the Workhttps://www.tn.gov/content/dam/tn/education/esser-planning-resources/ESSER%20Planning%20Grant_District%20Overview.pdf

Other Grant Opportunities

https://www.tn.gov/content/dam/tn/education/esser-planning-resources/ESSER%20Planning%20Grant_District%20Overview.pdf


Q & A with TDOE Program LeadsTheresa Nicholls Debby Thompson Sarah Williams Maryanne Durski


ClosingEve Carney


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