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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

Speed Bumps on the Fiduciary Road

Title I Administrative Meeting

Timonium Maryland

April 14, 2010

Cvieta Jovanovich


Purpose of speed bumps
Purpose of Speed Bumps

Caution

Focus

Keep Honest

Safety

Watch

Monitor

Warning


Spend funds quickly
“Spend funds quickly. . . .”

  • Save and create jobs

  • Improve student achievement through school improvement and reform


Invest arra funds thoughtfully

But ensure:

Transparency

Reporting

Accountability

Including Title I Part A

Invest ARRA funds thoughtfully . . .


Where are title i speed bumps located
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
Requirements

  • Maintenance of Effort

  • Comparability

  • Supplement Not Supplant


Federal cost principles
Federal Cost Principles

  • Necessary

  • Reasonable

  • Allocable

  • Legal

???


Bumps missed or forgotten
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
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
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