Sub-recipient monitoring of IDEA funds

The matrix below details the sub-recipient monitoring of IDEA funds for the Department:

Elements Reviewed

What to Look For

Citation

Program Elements: IDEA

Equipment (EDGAR 80.32)

Does the SAU maintain property/equipment records which include a description, serial number or other identifier, source, and acquisition cost and date?

Desk Audit

CrEAG FS-2 (H)

Has the SAU completed a physical inventory within the last two years with evidence that shows description, purchase price, location, condition, disposal data (if applicable), sale price and fair market value?

Desk Audit
This is considered as part of the year end report.

CrEAG FS-2 (H)

Does the SAU ensure sole use of property purchased with Part B funds?

Desk Audit

CrEAG FS-2 (H)

Excess Cost

Does the SAU correctly calculate the excess cost requirement?

Desk Audit
Verify figures that were used to calculate excess costs.

§300.818, Appendix A
CrEAG FS-1 (F)

Grant to Accounting Records

Do the SAU’s accounting records match the IDEA award notice and approved applications?

On-site Audit

EDGAR 80.20

Do the SAU’s accounting records, including journal entries, correct any disallowed costs?

Look at program tracking notes in application.

 

Do the SAU’s accounting records verify that funds were not committed prior to submission of the application in substantially approvable form?

On-site Audit

 

Are any SAU charges for travel expenditures in accordance with local policy?

Desk Audit

OMB Circular
A-110 and A-122
Travel Regulations

Does the SAU have financial documents and reports that verify appropriate expenditures under IDEA?

On-site Audit

 

Internal Controls Review

Does the SAU have adequate policies and procedures for charging employees to federal grants?

Desk Audit

EDGAR 80.20
A-87

Does the SAU have adequate policies and procedures for equipment purchased with federal funds?

Desk Audit

EDGAR 80.20; 80.32

Does the SAU have adequate policies and procedures to ensure contracts are not awarded to vendors on the list of suspended/disbarred vendors?

Desk Audit

A-87; EDGAR 80.22

Does the SAU have adequate policies and procedures to ensure that grant money is spent only on allowable costs?

Desk Audit

A-87: EDGAR 80.22

Does the SAU have adequate policies and procedures for cash management of IDEA funds?

Desk Audit

EDGAR 80.20; 80.21

Does the SAU have adequate policies and procedures regarding regular reimbursement request submissions?

Desk Audit
Check to ensure that reimbursement requests through GEM can be backed up with invoices.

EDGAR 80.21

Does the SAU have adequate policies and procedures to ensure expenditures are made during their period of availability?

Desk Audit

EDGAR 80.23

Does the SAU have adequate policies and procedures to ensure appropriate grant reports are complete and accurate and filed in a timely manner?

Desk Audit

EDGAR 80.50

Does the SAU place any federal funds in an interest-bearing account? If so, what is the amount of interest earned? If applicable, was interest in excess of $100 returned to federal government?

Desk Audit

CrEAG FS-2 (G)

Does the SAU maintain financial and programmatic records for the period of time required by federal law?

Desk Audit

IDEA
CrEAG FS-2 (F)

Maintenance of Effort

Did the SAU correctly calculate its Maintenance of Effort (MOE)?

Desk Audit
Verify figures reported on Local Entitlement application. Test selected budget codes.

§300.202(a)(3)
§300.202(b)(1)
§300.202(b)(3)

Does the SAU appropriately claim an exception to MOE, if applicable?

Desk Audit
Verify figures that were used to justify an exception to MOE, if applicable.

§300.204

If the SAU made an adjustment to local fiscal efforts in certain fiscal years, was the amount correctly calculated?

Desk Audit

§300.205

Proportionate Share (34 CFR §300.133)

Does the SAU have evidence of the correct proportionate share calculation?

Desk Audit
Confirm that figures used in application calculation are substantiated. This is considered as part of the application process.

 

Does the SAU have expenditure reports designating proportionate share expenditures?

Desk Audit
Check local entitlement application and year end report.

 

Does the SAU have evidence that proportionate share funds are available for 2 years and then spent on regular Part B purposes?

On-site Audit

 

Does the SAU use the required proportionate share of federal funds under 34 CFR §300.133(b) to provide equitable services to children with disabilities placed by their parents in private schools?

Desk Audit

CrEAG FS-2 (B)

Does the SAU have policies and procedures to ensure that it retains fiscal and decision making control related to services for the students with disabilities parentally placed in private schools within their district borders?

Desk Audit

 

Are the IDEA non-public expenditures allowable?

Desk Audit
Check policies and procedures to ensure that only allowable expenditures were made.

A-87

Time and Effort (OMB Circular A-87)

Does the SAU require IDEA funded staff who work on a single federal cost objective to complete time and activity certification statements?

Desk Audit
Salaries and wages paid for employees who work on a single federal cost objective must be supported by periodic certifications that the employees worked solely on that program for the period covered by the certification. These certification must be prepared at least semi-annually and signed by the employee or supervisor who has first-hand knowledge of the employee’s work. Date of signature must be subsequent to the end of the certification period. Specific federal cost objectives must be specified.

OMB A-87, Attachment B, Section 8.h
EDGAR 80.20
CrEAG FS-2 (E)

Does the SAU require IDEA funded staff who work on multiple cost objectives to complete and sign Personnel Activity Reports (PAR) that reflect an after-the-fact distribution of the total activity for which the employee is compensated at least monthly, coinciding with one of more pay periods?

Desk Audit
Salaries and wages paid for employees who work on multiple cost objectives must be supported by at least monthly (coinciding with pay periods) signed personnel activity reports showing the distribution of the employee’s time on each cost objective. Date of signature must be subsequent to the end of the certification period.

 

Does the SAU at least twice a year make a comparison of actual costs (based on monthly personnel activity reports) to budgeted distributions?

On-site Audit

 

Does the SAU adjust the federal program charges when actual effort did not support budgeted distributions?

On-site Audit

 

Does each PAR have a handwritten employee signature and date that is subsequent to the PAR period?

On-site Audit

 

Does each PAR have a handwritten supervisor’s signature?

On-site Audit

 

Does the SAU separately identify personnel charged to IDEA grants?

On-site Audit

A-87
EDGAR 80.20

Are salaries charged to proper grant(s) and accounts?

On-site Audit
Check coding

EDGAR 80.20