Matrix of Financial Considerations for Partnerships between the California Department of Education (CDE), Child Development Division (CDD), and the Office of Head Start (OHS)
This matrix contains fiscal and audit guidance for California programs which are braiding the CDE, CDD, and federal OHS program funds. It was created in 2007 by the California Head Start Association under contract with the California Head Start State Collaboration Office.
- Pages 1 and 2:
- List collaborative models currently used by OHS and Early Head Start program and the various CDE contract types.
- List Important fiscal audit considerations for each collaboration model.
- Pages 2 to 5:
- List the State and federal allowability of various costs and any differences.
- List specific costs requiring prior approval.
- List relevant State and federal audit requirements.
While this document has been reviewed by the CDE and Region IX Head Start fiscal staff, it is not intended to be a comprehensive guide or inclusive of all relevant fiscal and audit requirements.
Note: Under normal circumstances, a reference to “Head Start” also includes all references to “Early Head Start," as well. However, when program partnerships and collaborations are identified specifically as to “Head Start” or “Early Head Start," then the general reference does not apply. The Head Start Program requires that the child receives three and one-half hours of service, be Head Start eligible, and receives Head Start comprehensive services.
| Partnership Design | Definitions | Notes |
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CDE contract types: California Full Day Preschool (CFDP) and California Prekindergarten and Family Literacy Full-Day (CPKF) |
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CDE contract types: CCTR and CFCC |
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The CDE reimbursable and nonreimbursable costs, OHS reimbursable and nonreimbursable costs, prior approvals, OHS prior approvals, citation(s) and references, and audit requirements listed below apply to all partnership designs listed above. The various partnership designs may have unique definitions and notes, and are referenced on pages one and two.
CDE Reimbursable and Nonreimbursable Costs
Reimbursable
- Start-up
- Close-down (part-year migrant only)
- Administrative
- Employee compensation
- Equipment
- Improvement of sites
- Taxes, insurance, and maintenance
- Depreciation
- Use allowance for buildings and improvements
- Travel and per diem
- Indirect cost
- Lease payments, principal, and interest, etc.
- Interest on private sector debt financing for purchase, lease, renovation, or repair
- Payments to providers
Nonreimbursable
- Bad debts
- Contributions
- Amusement or entertainment
- Fines or penalties
- Idle facilities
- Costs incurred after contract termination
- Fund raising
- Consumer interest
- Investment management
- Organization of a nonprofit corporation
- Public relations consultant fees
- Costs of legal, consulting, or accounting services in prosecution claims against the State
- Income taxes
- Acquisition of unlicensed sites
- Bonuses
- Compensation to board members
- Subcontracts with a costs plus a percentage of costs clause
- Future or prior year costs
OHS Reimbursable and Nonreimbursable Costs
Reimbursable
- Start-up
- Administrative
- Compensation of personnel services
- Equipment (CDE)
- Equipment (OHS)
- Improvement of sites
- Taxes, insurance and maintenance
- Maintenance, operation and repair
- Depreciation
- Use allowance
- Travel and per diem
- Indirect costs
- Lease payments
- Lease payments principal and interest
- Interest on private sector debt financing for purchase, lease, renovation, or repair
- Payments to providers
- Advertising costs
- Bonding costs
- Communication costs
- Fringe benefits
- Severance pay
- Employee morale, health and welfare
- Material and supplies
- Meetings and conferences
- Memberships
- Professional services
- Proposal costs
- Publication and printing costs
- Alteration costs
- Rental costs of building and equipment
- Close down (migrant only)
- Termination costs
- Training costs
- Travel cost (domestic)
- Pre-award costs
- Foreign travel
Nonreimbursable
- Donations and contributions
- Entertainment
- Fines and penalties
- Idle facilities costs
- Costs incurred after contract termination
- Fundraising
- Investment management
- Organization of nonprofit corporation
- Public relations consultant fees
- Legal fees against the federal or state government
- Income taxes
- Acquisition of unlicensed sites
- Bonuses
- Alcoholic beverages
- Bad debts
- Compensation to board members
- Subcontracts with costs plus percentage
- Future or prior year costs
- Contingency reserves
- Lobbying
CDE Prior Approvals
- Equipment ($7,500 and up): For private nonprofit facilities (PNP), three bids must be obtained for equipment of $5,000 or more.
- Renovation and repair ($10,000 and up): For PNPs, three bids must be obtained for work of $5,000 or more.
- Subcontracts ($10,000 and up)
- Purchase or construction of facilities, regardless of cost, must be approved by CDE.
- Travel outside the state
OHS Prior Approvals
If not included in the annual refunding application:
- Equipment ($25,000 and up)
- Major renovation ($200,000 and up)
- Construction (any new construction, regardless of cost)
- Purchase of facility, including portables or modulars, must be approved, regardless of cost.
- Facilities, even if no federal funding is being used for the project, must be approved.
- Changing program options
- Travel outside United States, its territories, and Canada
- Cost allocation: See ACYF, IM, HS, 01-06
- Idle facilities may be allowable for short period, if approved by ACF.
Citation(s) and References
- EC, sections 8200-8499
- CCR, Title 5, sections 18000-18464
- CDE funding terms and conditions (current year)
- California School Accounting Manual
- California Public Contract Code
- Head Start administrative regulations and performance standards
- Head Start: Office of Management and Budget circulars A-87 (local governments), A-122 (PNPs)
- Head Start: 45 CFR Part 74 (PNPs) and 45 CFR Part 92 (local governments)
- Head Start: Davis-Bacon Act
- ACYF, IM, HS, 01-06
- 2002 CDE/CDD (Full-Day, Full-Year Early Care, Education Partnerships Report, and CDE Press)
Audits and Requirements
- CDE audits due by the 15th day of the 5th month following the end of the fiscal year. See Funding Terms and Conditions for specific date and time requirements for various agency types (i.e., PNP, County Office of Education, school districts, etc.).
- CDE must submit Annual Audit Status Certification forms by September 15.
- OHS must comply with OMB A-133, nine months from the end of the fiscal year.