Speed bumps on the fiduciary road
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Speed Bumps on the Fiduciary Road. Title I Administrative Meeting Timonium Maryland April 14, 2010 Cvieta Jovanovich. Purpose of Speed Bumps. Caution. Focus. Keep Honest. Safety. Watch. Monitor. Warning. “Spend funds quickly. . . .”. Save and create jobs

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Speed Bumps on the Fiduciary Road

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Speed Bumps on the Fiduciary Road

Title I Administrative Meeting

Timonium Maryland

April 14, 2010

Cvieta Jovanovich


Purpose of Speed Bumps

Caution

Focus

Keep Honest

Safety

Watch

Monitor

Warning


“Spend funds quickly. . . .”

  • Save and create jobs

  • Improve student achievement through school improvement and reform


But ensure:

Transparency

Reporting

Accountability

Including Title I Part A

Invest ARRA funds thoughtfully . . .


Where are Title I “speed bumps” located?

  • Title I Law – ESEA

  • Regulations – 34CFR Part 200

  • Education Department General Administrative Regulations (EDGAR)

  • OMB Circular A-87 – Cost Principles

  • OMB Circular A-133 – Audit Requirements

  • A-133 Compliance Supplement

  • Non regulatory guidance

  • Letters and press releases issued by ED


Requirements

  • Maintenance of Effort

  • Comparability

  • Supplement Not Supplant


Federal Cost Principles

  • Necessary

  • Reasonable

  • Allocable

  • Legal

???


Bumps Missed or Forgotten??

Spend down of funds!

  • Parent Involvement

  • Services to Private School Students

  • Required Reservations ( homeless, professional development, N/D)

  • School Level Allocations

  • ARRA Funds (late allocating

    to schools)


More Missed!

  • Supplement/ Supplant – Time and Effort

  • Carryover – First in First Out

  • Audits – Same Findings

  • Equipment/Inventory – Missing Written Process or Not Implemented


How to Safely Travel the Fiduciary Road

  • Training

  • Increase Knowledge of the Requirements within the LEA (central office and schools)

  • Monitor

  • Ask for Technical Assistance


Questions


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