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California Department of Education
Official Letter
California Department of Education
Official Letter
July 12, 2021

Dear Executive Directors, Child Care and Development Programs:

Fiscal Year (FY) 2020–21 Year–End Reporting Reminders

The purpose of this letter is to compile reporting information provided throughout FY 2020-21 and provide contractors the due dates and reporting requirements for purposes of completing year-end and audit reports for the fiscal year ending June 30, 2021. Please share this letter with your agency staff. A subsequent letter will be issued in the coming weeks to inform contractors of any changes to California State Preschool contracts and reporting procedures for FY 2021–22.

Additional Resources

Due to policy and associated funding updates that occurred throughout the 2020-21 fiscal year, Child Development and Nutrition Fiscal Services (CDNFS) did not release updated Attendance & Fiscal Reporting & Reimbursement Procedures, also known as the CDNFS Fiscal Handbook. However, additional resources have been provided throughout the year. The CDNFS web page will continue to be updated with supplemental fiscal guidance, including contract-related updates and guidance specific to the COVID-19 pandemic. Contractors will continue to be informed of added content to this web page for the California State Preschool Program by notification through the Early Learning and Care Division (ELCD) Email Distribution List Subscription. The CDNFS web page can be found at https://www.cde.ca.gov/fg/aa/cd/. Management Bulletins (MBs) distributed by the ELCD throughout FY 2020-21 can be found at: https://www.cde.ca.gov/sp/cd/ci/allmbs.asp. The MBs also contain fiscal directives.

Contracts and Contract Amendments

All original contracts and any remaining contract amendments for FY 2020–21 must be signed and returned to the Contracts Office as soon as possible. The CDNFS cannot make payments based on amended terms until the amendment has been signed and returned.

Year-End Reports Reporting Deadline

Year-end attendance and fiscal reports are due by July 20, 2021. Acceptable reports not received by July 20, 2021 will be considered delinquent. A delinquent report results in withholding any remaining apportionments due for FY 2020–21. Additionally, apportionments for FY 2021–22, beyond the initial payment, will be withheld until the contractor has complied with this contract requirement.

Contractors holding General Child Care and Development Programs (CCTR), California State Preschool Programs (CSPP), Severely Disabled Programs (CHAN), Migrant Child Care and Development Programs (CMIG), Resource and Referral (CRRP), Childcare Initiative Project (CCIP, Health and Safety Training Activities (CHST), Local Childcare and Development Planning Councils (CLPC), and Prekindergarten and Family Literacy Support (CPKS) contracts must submit year-end reports in the Child Development Provider Accounting Reporting System (CPARIS).

Contractors holding Alternative Payment, Resource and Referral, and Center-Based reserve accounts will also submit reserve account activity reports in CPARIS. For additional information regarding reserve account reporting, see the “Reserve Accounts” section of this letter.

The CPARIS can be found on CDE’s website here: https://www2.cde.ca.gov/cparis/logon.aspx. The CPARIS User Manual, which provides early learning and care contractors with instructions on how to navigate the web-based application, can be found here: https://www.cde.ca.gov/fg/aa/cd/documents/cparisusermanual.docx.

Contractors holding California Work Opportunity and Responsibility to Kids (CalWORKs) Stage 2 (C2AP), CalWORKs Stage 3 (C3AP), Alternative Payment Program (CAPP), Family Childcare Home Education Networks (CFCC), and Migrant Alternative Payment Program (CMAP), must submit year-end reports in the Alternative Payment/CalWORKs Online Reporting System, which can be found on the California Department of Social Services website here: https://cdfs.adm.dss.ca.gov/logon.aspx

FY 2020–21 Attendance and Expenditure Reporting

Reimbursement and Closures: CCTR, CSPP, CFCC, CHAN, and CMIG Contractors

EC Section 8209(f) addresses reimbursement for contracting agencies that closed in FY 2020–21 due to COVID-19. The Management Bulletin 21-07 provided updated guidance based on the passage of Assembly Bill (AB) 82 to CCTR, CSPP, CFCC, CHAN, and CMIG direct service contractors regarding reopening and reimbursement requirements. Contractors who met the reopening criteria set forth in MB 21-07 are to be reimbursed the lesser of 100 percent of the contract’s Maximum Reimbursable Amount (MRA) or net reimbursable program costs. Contractors will be reimbursed without regard to enrollment or attendance. For additional details, please refer to MB 21-07, which can be found here: https://www.cde.ca.gov/sp/cd/ci/mb2107.asp.

If a contractor’s days of closure are not attributable to closure by a local or state public health order or guidance related to COVID-19 and specific to early learning or childcare, or without verification of a mandated closure for the LEA campus, or due to a non-COVID-19 emergency closure under EC 8271, the contractor’s MRA will be pro-rated by the days of operation that the contractor was not open to provide services.

Contractors who do not meet the requirements outlined in MB 21-07 must contact their assigned ELCD Program Quality Consultant and submit a revised operating calendar. The revised calendar will be used by CDNFS to determine the FY 2020-21 MRA. A pro-rated FY 2020-21 MRA will not impact an agency’s MRA in FY 2021-22.

Reimbursement and Closures: C2AP, C3AP, CAPP, CFCC and CMAP Contractors

The C2AP, C3AP, CAPP, CFCC and CMAP contract reimbursement calculations remain unchanged, as contractors are currently reimbursed based on the lesser of the contract’s MRA or net reimbursable program costs. For directives related to provider payments funded by a CFCC contract, please refer to MB 21-07. For directives related to provider payments funded by a C2AP, C3AP, CAPP or CMAP contract, please refer to MB 20-15 and MB 21-06. For updates in reporting requirements associated with provider non-operational days, see below.

Other Emergency Closures

Contracts that closed due to an emergency not related to the COVID-19 pandemic, such as earthquakes, fire, flood, or other circumstances beyond their control, must submit an Emergency Closure Request, in accordance with MB 20-20: Non-COVID-19 Emergency Closure Requests for Fiscal Year 2020–21. Please reference MB 20-20: “Non-COVID-19 Emergency Closure Requests for Fiscal Year 2020–21 for more information”. The MB 20-20 can be located at https://www.cde.ca.gov/sp/cd/ci/mb2020.asp.

Reporting: Non-Operational Days

The CAPP, C2AP, C3AP, CMAP contractors, as well as CCTR, CFCC, CSPP and CMIG contractors who provide services through a family childcare home education network, are required to report to the CDE the use of childcare provider’s 30 non-operational days for closures related to COVID-19, and associated costs, when the primary provider is closed, and the child receives care from an alternate provider.

This information will be utilized to reimburse providers until the $31.25 million provided in Senate Bill (SB) 820 is exhausted. The data required to be reported by contractors for this purpose is:

  • Number of children requiring care from an alternate provider
  • Sum of all the days children received care from an alternate provider
  • Total cost associated with paying alternate providers due to the primary provider’s closure

The final date to submit a COVID-19 Non-Operational Report, or to revise a previously submitted report, is July 20, 2021. After this date, revised reports must follow the instructions outlined in the Revised Reports section of this letter.

Reporting: Family Fees Collected and Waived

The ELCD released MB 20-19a: Updated Guidance on Family Fees for Fiscal Year (FY) 2020–21, notifying contractors that family fees were waived for the months of July and August 2020, and providing a directive to contractors that family fees must not be collected for the months of July and August 2020. As required by SB 820, family fees are waived from September 1, 2020, to June 30, 2021, for families when all children in the family enrolled in subsidized ELC programs remain at home: (1) either for distance learning services when the facility is closed due to the COVID-19 pandemic, or when all currently enrolled children are not able to receive in-person services due to a public health order that limits capacity, or (2) for families sheltering-in-place due to COVID-19.

The MB 20-19a further instructed contractors to report waived family fees on two new lines added to the CDNFS Fiscal Reports: Waived Family Fees for Certified Children (July and August) and Waived Family Fees for Certified Children (September–June). Any amount reported on these lines should represent the amount of fees that would have been collected from families if family fees had not been waived.

Contractors must report the amount of family fees collected on the line Family Fees Collected for Certified Children (September–June). Family fees reported on the line Family Fees Collected for Certified Children (September–June) must be based on the amount of fees the contractor expects to collect in the report month, regardless of when the revenue is actually received. Family fees are in lieu of contract payments and therefore family fees reported on this line will be subtracted from contract reimbursement.

Contractors must report the amount of family fees waived for the months September through June on the line Waived Family Fees for Certified Children (September–June). Any amount reported on these lines should represent the amount of fees that would have been collected from families if family fees had not been waived

For additional details, please refer to MB 20-19a, which can be found here: https://www.cde.ca.gov/sp/cd/ci/mb2020.asp.

Reporting: Revenue and Expenses

Contractors are reminded that reporting revenue is dependent on the source of the income and how it is expended. Restricted revenue reported on CDNFS forms is income provided for a specific, limited purpose and that can only be expended for certified children. Generally, any funds received by a contractor that are allocable to the child development program, but must be used for a specific purpose or which the contractor does not have to return, such as a funds received through the Paycheck Protection Program, should be reported as restricted revenue. The associated expense must also be reported.

Revenue should only be reported when its corresponding expenses are also reported, with the exception of the $525 per child one-time stipends provided pursuant to AB 82. Expenditures associated with these stipends are not required to be reported on CDNFS report forms. However, as with all Federal and State funds allocated for Early Learning and Care programs, the use of stipend funds is subject to audit, and must be appropriately tracked by contractors. This includes, but is not limited to, maintaining records for payments to providers, and all purchase orders or receipts to verify appropriate use of funds.

Contractors must follow Generally Accepted Accounting Principles (GAAP) for accrual accounting. Contractors shall follow the accounting procedures specified in the most recent edition of the California School Accounting Manual. The School Accounting Manual specifies that under an accrual basis of accounting, revenues are recorded when earned and expenditures are recorded when a liability is incurred, regardless of when the receipt or payment of cash takes place.

Reporting: Enrollment, Attendance, and Days of Operation for Center-Based Contractors

Reporting requirements associated with enrollment, attendance, and days of operation are specified in MB 21-07. In FY 2020-21, programs are reimbursed the lesser of 100 percent of the contract’s MRA or net reimbursable program costs, provided they met criteria outlined in MB 21-07. If the reopening criteria specified in MB 21-07 is not met, contractors must submit a revised program calendar to reflect the days of operation eligible to be funded under the early learning and care contract.

The CDE held a webinar on October 26, 2020, providing guidance to contractors regarding enrollment, attendance, and days of operation reporting, including charts for quick reference. The webinar is posted to CDE’s website here: https://www.cde.ca.gov/sp/cd/re/documents/elcdcovidwebinar1026.pptx.

Reporting: Start-up Allowance

Contractors with a FY 2020–21 Child Development contract containing approved start-up associated with expansion funding must report any expenses associated with the start-up allowance on the “Start-up Expenses” line of the appropriate report in CPARIS. Start-up expenses should be reported only on the “Start-up Expenses” line, and not included in the expenses reported in categories 1000-6500.

With the exception of a start-up/close down allowance associated with seasonal migrant contracts, allowable start-up expenses were negotiated and approved by the CDE specific to each contract. Expenses reported on the start-up line must only include what was requested by the contractor and approved by the CDE.

Reporting: Quality Rating and Improvement System (QRIS)

The QRIS is a local level block grant with a focus on improving program quality. It was created to meet the needs of early learners and ensure access to high quality programs for California’s children. The primary purpose of this funding includes training, professional development days, stipends, and bonuses. Contractors are reminded that income and expenses associated with the use of these funds must be reported on the Attendance and Fiscal Report. In most cases, these grant funds should be reported as supplemental revenue and expenses. For additional information, refer to the CSPP QRIS Block Grant web page on the CDE website at: https://www.cde.ca.gov/sp/cd/op/csppqrisblockgrant.asp.

Reporting: Support Contracts

Support contracts – CCIP, CHST, CLPC, and CPKS – also require a year-end fiscal report by the July 20, 2021 deadline. Contractors who have expended and reported the full contract amount prior to the end of the year are still required to submit a year-end fiscal report by July 20, 2021. Support contract reports must be submitted in CPARIS.

Reporting: Local Child Care Planning Council and Child Care Initiative Match Requirement

CLPC contracts require a local match. Per the CLPC Program Requirements, each contractor shall contribute a match, in the form of monetary and/or in-kind services. The required local contribution for each CLPC contract is shown on the contract face sheet, and is part of the total CLPC Maximum Reimbursable Amount (MRA). Match contributions are to be reported as Restricted Income in the CLPC Support Contract Expenses report in CPARIS. The expenses associated with the reported match contribution should be included within the expenses portion of the report.

Any CCIP contracts with a local match requirement shall report the match as Restricted or Unrestricted Income. Reporting associated with CCIP contracts should be done in the CCIP Support Contract Expenses report in CPARIS.

Revised Reports

Year-end reports must be received by the deadline of July 20, 2021 to avoid becoming delinquent. However, revisions to year-end reports may be submitted later under the limited circumstances outlined below.

Non-LEA contractors may submit revised year-end reports until August 20, 2021. Contractors will receive a preliminary contract closure calculation from CDNFS based on the year-end report, or a revised year-end report, that is received by the August 20 deadline. Revised reports will not be accepted after this date; contract closure and year-end reimbursement calculations will be based on the contractor’s audit.

Contract closure and year-end reimbursement calculations for an LEA are based on the year-end report, so it is vital that information is complete and accurate. LEAs should submit a revised report, if necessary, to CDNFS as soon as possible, but “Contractors have sixty (60) days from the due date for submission of the audit to submit a revised report” to your CDNFS fiscal analyst (Funding Terms and Conditions (FT&C)).

  • A County Superintendent of Schools/School District audit is due on December 15 (EC Section 41020). The revised report deadline for FY 2020-21 is February 13, 2022.
  • A Community College audit is due on December 31 (FT&C), so the revised report deadline for FY 2020-21 is March 1, 2022.

Both LEA and Non-LEA contractors can submit revised year-end reports related to their CalWORKs Stage 2 and Stage 3 contracts through September 30, 2021. 

CalWORKs Billings

Contractors can submit revised year-end reports related to their CalWORKs Stage 2 and Stage 3 contracts through September 30, 2021. After September 30, 2021, contractors will be invoiced for any over-advanced CalWORKs contract funds based on the most recent year-end earnings calculation report. This invoice will be sent to the contractor prior to the receipt of the audit in order to facilitate the dis-encumbrance of unearned CalWORKs contract funds. It is imperative that CalWORKs contractors pay these invoices as promptly as possible to avoid having the outstanding billing become delinquent and future apportionments withheld. An invoice that becomes 90 days delinquent will result in a withholding of all future apportionments.

Any additional payment or billing determinations made for a CalWORKs contract upon audit closure for a Non-LEA or revised report submission for an LEA will be processed during contract closure.

California Alternative Payment Program (CAPP) Multi-Year Contracting

CAPP9 Contracts

The EC Section 8220.1 allows for under earning CAPP contractors, or contractors that did not fully expend contract funds in the first year of the contract, to fully spend the contract in the second year. At the end of FY 2019-20, contractors who were projected to under-earn their CAPP9 contract received an amendment extending the contract period from June 30, 2020 to June 30, 2021. Contractors that received an extension to their CAPP9 contract were instructed to report expenditures to the CAPP9 contract in FY 2020–21 until it was fully expended. Expenditures were not to be reported to the FY 2020–21 CAPP contract (CAPP0) until the CAPP9 contract was fully expended. The CAPP9 contracts that were extended through June 30, 2021 will not be further extended, and close-out calculations will therefore be performed. As with all other close-out periods, if a CAPP9 contract is due additional funds or has an accounts receivable, the contractor will be notified via the relevant CDNFS close-out calculation worksheet provided by the CDNFS fiscal analyst.

CAPP0 Contracts

FY 2020-21 CAPP contracts were extended through June 30, 2022. All CAPP0 contractors must submit a year-end report by July 20, 2021 whether or not the CAPP0 contract was fully expended.

Reserve Accounts

Reserve account calculations will remain the same for FY 2020-21. This includes the calculation of funds being transferred into the reserve account, as well as reporting the usage of reserve account funds for eligible expenses.

Reserve Account Reporting

A reserve account activity report is required for each type of reserve account a contractor maintains, regardless of whether the reserve account has a balance. Contractors that have one or more Reserve Accounts must submit the Reserve Account Activity Report (previously report form CDNFS 9530-A) in CPARIS for each reserve account. A copy of the contractor’s general ledger report page(s) that reflects the cash balances maintained in the Child Development reserve account must be submitted via email to the assigned fiscal analyst by July 20, 2021. Instructions for submitting the reserve account activity report will be posted to CPARIS early July.

All transfers from a reserve account to a CSPP contract should be separated by (1) amounts transferred to cover professional development expenses (professional development of CSPP instructional staff) and (2) amounts transferred for general expenses (reimbursable cost for any center-based contract) as indicated on the form. Transfers from the reserve to any other center-based contract should be reported on the line specific to the contract type (CCTR, CMIG, or CHAN).

Reserve account activity reports must comply with the following to be deemed acceptable:

  • The beginning balance reported on the FY 2020–21 reserve account activity report must match the ending balance of the most recent FY 2019-20 CDNFS 9530 reserve account status report provided by CDNFS. Balances must reconcile in order for the reserve account activity report to be deemed acceptable.
  • Reserve accounts with a balance must accrue interest, and the interest must be reported on the reserve account activity report. Reserve account funds must be kept in an interest-bearing account within the contractor’s Child Development Fund. Reserve account activity reports submitted to CDNFS that indicate a balance, but interest is not reported, will be deemed as unacceptable.
  • Requested transfers from reserve must match what is reported in the “Transfer from Reserve” line in the Revenue section of the year-end attendance and fiscal report. Contractors who utilize reserve account funds for expenses incurred in 2020-21 must report the transfer from the reserve on the reserve account activity report submitted in CPARIS as well as the relevant fiscal and attendance report form, and the amounts must be the same.
  • The general ledger must be submitted by e-mail to the assigned CDNFS fiscal analyst.

Establishing a Reserve Account

Contractors who do not currently have a reserve account and wish to open one can do so in CPARIS. To do so, navigate to the Reporting tab of CPARIS to complete the 2020-21 Reserve Account New Request, select the relevant reserve account type, complete the Authorized Representative information, and submit. Requests to open a reserve account must be received by July 20, 2021. Requests received after that date will not be processed. Requests to establish a reserve account do not need to be made annually; contractors that established a reserve account in prior years do not need to establish a reserve account again in FY 2020-21.

Closing a Reserve Account

Contractors who wish to close a reserve account may do so by completing the 2020-21 Reserve Account Close Request in CPARIS. If a reserve account is closed, any balance currently held in the Child Development Reserve Account, as well as any interest accrued by the funds, must be returned to the California Department of Education. Requests to close a reserve account should be submitted on the same date the contractor’s enrollment and attendance reports are submitted, which are due July 20, 2021.

Contingency Fund Applications

Pursuant to EC Section 8222.1, CDE shall reallocate funds as necessary to reimburse CAPP contractors for actual and allowable costs incurred for additional services provided. A CAPP contractor may apply for reimbursement of up to three percent of their contract amount, or for a greater amount subject to the discretion of the Department, based on availability of funds.

Applications may be submitted as early as May 1, 2021 but no later than September 30, 2021. The CDE will approve or deny applications submitted pursuant to the above EC section, and will not consider applications received after September 30, 2021 for additional costs incurred during FY 2020–21. The CDE will distribute reimbursement funds for each approved application within 90 days of receipt of the application, if the application was filed between May 1, 2021 and July 20, 2021. Applications received after July 20, 2021, are not subject to the 90-day requirement for the distribution of funds. If requests for reimbursement exceed available funds, the CDE will assign priority for reimbursement according to the order in which it received the applications. Funds received by a CAPP contractor pursuant to this section that are not substantiated by the program’s annual audit or a year-end report must be returned to the CDE. Billings for contingency funds are not subject to the appeal process.

Further information on the contingency funds process, including the application, can be found on CDE’s website at https://www.cde.ca.gov/fg/aa/cd/alternativepmt.asp.

Audits and Investigations Division: Audited Attendance and Fiscal Report Reminders and Changes

Please share the following information with your fiscal staff and independent auditor, e.g., Certified Public Accountant (CPA), who performs your annual audit that you submit to the CDE.

FY 2020–21 AUD Forms

CDE’s Audits and Investigations Division (A&I)’s resource page, which includes audit guidelines and Audited Attendance and Fiscal Reports (AUD forms) and Instructions for FY 2020–21, can be found at https://www.cde.ca.gov/fg/au/pm/.

Reminders

The following audit requirements of the CDE Audit Guide, referenced by section number, are important to discuss with your CPA. The CDE Audit Guide can be found at: https://www.cde.ca.gov/fg/au/pm/documents/auditguide2015.pdf.

  • Ensure that the audit engagement letter between the agency and the CPA states that the audit will be performed in accordance with the CDE Audit Guide (see Section 160.C.2) and identifies the date that the final audit report must be submitted (due dates in Section 210).
  • Except for Child Development (CD) program contractors on conditional status, a CD contractor may be granted a one-time-only per year, 30 calendar-day extension of the audit due date, provided the inability of the contractor to submit the audit by the due date was beyond the fault and control of the contractor. The extension request due date and instructions for submission are specified in Section 212.
  • Section 310.A provides an overview of the AUD forms. Also see A&I’s Resources Page for AUD form instructions.
  • Preparation of the Audited Reserve Account Activity Report (form AUD 9530‑A) is explained in Section 350. Detailed instructions for preparing the AUD 9530-A form are included in the AUD form instructions.
  • The AUD forms and supplementary information are required for subcontracts, except for subcontractors that operate CD programs for school districts (Section 345). The contractor is responsible for providing an audit report of its subcontractor that includes the supplementary information detailed in Chapter 200, Exhibit A and the AUD forms for any subcontracts (Section 210.D).
  • If start-up expenses (service level exemption) are reported on the AUD forms, the audit report must include a “Schedule of Reimbursable Start-up Expenses” (Section 320). Note that part-year Migrant Programs may also contain close-down expenses that would be reported in the same manner as start-up expenses.
  • Include in the audit report a “Combining Statement of Activities” (Section 315.B). Revenues reported on the “Combining Statement of Activities” must be traceable to individual CDE contracts in the revenue section of the respective AUD form.
  • If CDE reporting requirements differ from those of Generally Accepted Accounting Principles (GAAP), e.g., for depreciation, a “Reconciliation of CDE and GAAP Expense Reporting” is required (Section 315.C).
  • Cost Allocation Guidance is provided in Section 718.

New Audit Requirement

In order to streamline the audit report review process, the CDE developed a Quality Review Checklist for FY 2020–21 Child Development Agencies and a new supplemental schedule template titled Notes to the Child Development Contract Supplemental Information. The checklist is required to be completed by an agency representative and submitted along with the agency’s 2020–21 audit report and the supplemental schedule should be included in the audit report. These items are designed to reduce or eliminate the need for follow-up questions that arise as CDE and/or CDSS reviews the organization’s audit report submission in accordance with California Code of Regulations, Title 5, Section 18072. CDE will make these items available in the 2021 version of the CDE Audit Guide and by request at AuditSubmissions@cde.ca.gov.

Costs Disallowed in Child Development Audits

The following are examples of costs disallowed in audits of Child Development programs. When costs are disallowed by CPAs or the A&I, the CDE will not reimburse those costs. Each example is followed by a bracketed citation to identify the applicable requirement in the contract Funding Terms and Conditions (FT&Cs) for Child Development Programs. The FT&Cs can be found at: https://www.cde.ca.gov/fg/aa/cd/documents/ftc1819.doc

  • Payroll costs for salaries and benefits are disallowed when a contractor does not adequately support its claim for reimbursement, e.g., does not maintain payroll records that indicate the actual amount of time spent (performing direct cost activities) in each program per day for multi-funded employees (FT&C, Section VI.E).
  • The following costs are disallowed, as they are specifically prohibited by the contract– this is only a partial list (FT&C, Section V.H):
    • Bad debts, excepting parent fees if collection attempts are adequately documented
    • Amusement and entertainment
    • Idle facilities for full-year programs, e.g., office or classroom used for storage
    • Fines and penalties
    • Bonuses
    • Costs incurred outside the contract period, except for audit fees (FT&C, Section V.I)
    • Costs are disallowed if they are not reasonable and necessary to the performance of the contract (FT&C, Section V.B), for example:
      • Granite counter tops in kitchen and bathrooms
      • Cellular telephones for employees’ spouses and children
      • High-end office furnishings
    • Depreciation is disallowed when claimed on: (a) assets purchased with public funds, (b) donated assets; or (c) idle or excess facilities (FT&C, Section III.D).
    • When a contractor lacks prior written approval from the Early Learning and Care Division, costs are disallowed for:
      • Renovation and repairs or equipment purchases in excess of the FT&Cs thresholds (FT&C, Section III.E)
      • Subcontracts for direct early learning and care services (FT&C, Section IV.D)
    • Rent is disallowed (FT&C, Section II.P):
      • On property owned by the contractor (an expense may be claimed only as depreciation or use allowance)
      • On property owned by affiliates, officers or other key personnel of the contractor or their families, unless the contractor obtains (and claims no more than) a fair market rental cost estimate from an independent appraiser licensed by the California Office of Real Estate Appraisers
    • Claims for reimbursement are disallowed if there is insufficient documentation to support the claim, e.g., no paid invoice or receipt to support an expense; the contractor has the burden of proof. (FT&C, Section VI.E).
    • Costs of advertising are disallowed when the advertisement is not necessary to meet the requirements of the Child Development contract (Title 2 Code of Federal Regulations, Section 200.421).

For additional information regarding the AUD forms or audit requirements, please contact the CDE Audits and Investigations Division at 916-322-2288.

If you have questions or need clarification about any other topic covered in this letter, please contact your assigned CDNFS analyst.

Last Reviewed: Monday, July 12, 2021

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