The Program Monitoring Office of the Expanded Learning Division has completed an analysis of the Federal Program Monitoring (FPM) findings for the Expanded Learning Opportunities Program (ELO-P), After School Education and Safety (ASES), 21st Century Community Learning Centers (CCLC), and High School After School Safety and Enrichment for Teens (ASSETs) programs in an effort to communicate the most common findings with the field. This tip sheet not only identifies the top five findings, but outlines the most common issues that grantees face with each item listed while providing additional resources. This is not an exhaustive list of all FPM findings.
| Federal Program Monitoring Numbers | Description | Evidence Required | Common Issues | Resources |
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Expanded Learning Program (EXLP) 9 15 Findings |
Funding Direct Services to Students (85/15) LEA/Grantee spends no more than 15 percent of the amount of the grant for Administrative Costs, which includes any Indirect Costs. Grantees are funded and monitored by site, thus the grantee is required to track expenditures by site. LEA/Grantee incurred expenditures that are necessary, reasonable and documented for the activities included in the board approved ASES program plan and/or ELO-P plan. LEA/Grantee must maintain and make available for review records that clearly document how the funds were expended, the total cost of the project, the share of cost provided from other sources, and other records to facilitate an effective audit. |
Prior Fiscal Year (FY) fiscal records, such as detailed general ledger for Resource 6010 (ASES), Resource 4124 (21st CCLC/ASSETs), and Resource 2600 (ELO-P) that are aligned with expenditures reported to CDE in the After School Support and Information System (ASSIST). Prior FY fiscal records tracking no less than 85 percent of the total grant award amount for Direct Services to students and no more than 15 percent of the grant award amount for Administrative Costs, including Indirect Costs for each site. Board-approved ELO-P and ASES program plans to verify purchases/expenditures are necessary, reasonable, and documented. Prior FY Memorandum of Understandings (MOUs) or Subcontractor Agreements with supporting fiscal records for subcontracted services. Prior FY time accounting records for all staff paid with EXLP funds:
Documentation must be site specific.
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LEAs/Grantees are spending more than 15 percent on Administrative Costs, including Indirect Costs. LEAs/Grantees and their service providers are each spending 15 percent on Administrative Costs, including Indirect Costs. LEAs/Grantees are applying the 85/15 to the grant, not for each site. LEAs/Grantees are not tracking the 85/15 by each site. LEAs/Grantees are not tracking fiscal records by resource code. LEAs/Grantees lack oversight of service providers .LEAs/Grantees and/or service providers’ administrative staff are charging time to Direct Services, but do not have the documentation to support the charges. LEAs/Grantees and/or service providers are charging items to the grant that are not allowable. There is no differentiation of time if a staff member worked for the LEA/Grantee and the expanded learning program. LEAs/Grantees and/or service providers are not tracking time accounting records. LEAs/Grantees are not retaining records of MOUs. |
Direct Services and Administrative Costs Guidance (85/15) 85/15: Direct Services to Pupils, Administrative, Indirect Costs and Supplement versus Supplant
ASES Program Plan Guide (DOCX) |
EXLP 11 11 Findings |
Supplement not Supplant LEA/Grantee uses categorical funds only to supplement, and not supplant, state and local funds. |
Prior FY fiscal records, such as detailed general ledger for Resource 6010 (ASES), Resource 4124 (21st CCLC/ASSETs), and Resource 2600 (ELO-P) that are aligned with expenditures reported to CDE in the After School Support and Information System (ASSIST). Prior FY fiscal records tracking no less than 85 percent of the total grant award amount for Direct Services to students and no more than 15 percent of the grant award amount for Administrative Costs, including Indirect Costs for each site. Board-approved ELO-P and ASES program plans to verify purchases/expenditures are necessary, reasonable, and documented. Duty statements for all staff paid with EXLP funds. Inventory records tracked since inception of the expanded learning program for single-item purchases of at least $500 with a log/documentation of last physical inventory. |
LEAs/Grantees are spending more than 15 percent on Administrative Costs, including Indirect Costs. LEAs/Grantees and their service providers are each spending 15 percent on Administrative Costs, including Indirect Costs. LEAs/Grantees are applying the 85/15 to the grant, not for each site. LEAs/Grantees are not tracking the 85/15 by each site. LEAs/Grantees are not tracking fiscal records by resource code. LEAs/Grantees lack oversight of service providers. LEAs/Grantees and/or service providers are charging items to the grant that are not allowable. LEAs/Grantees and/or service providers misused categorical funds. LEAs/Grantees and/or service providers do not maintain record of staff duty statements. LEAs/Grantees are not retaining inventory records.
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Direct Services and Administrative Costs Guidance (85/15) 85/15: Direct Services to Pupils, Administrative, Indirect Costs and Supplement versus Supplant
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EXLP 13 6 Findings |
Data-Driven Quality Improvement Process LEA/Grantee maintains documentation/evidence of a data-driven quality improvement process that is based on the department’s guidance on program quality standards. |
Documentation that the LEA/Grantee has developed a data-driven continuous quality improvement process that is based on the Expanded Learning Quality Standards. Documentation should include Continuous Quality Improvement (CQI) Process by site. |
LEAs/Grantees have not started a CQI process. LEAs/Grantees have a CQI process that lacks explicit inclusion of the Expanded Learning Quality Standards. |
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EXLP 15 8 Findings |
Student-to-Staff Ratio LEA/Grantee ensures that programs maintain a student-to-staff ratio of no more than 20 to 1. LEA/Grantee ensures that ELO-Programs serving transitional kindergarten (TK) or kindergarten pupils maintain a pupil-to-staff member ratio of no more than 10 to 1. |
Documentation of one month of student sign-in/out sheets that show daily attendance by rosters and/or assignments. Documentation of one month of staff sign-in/out sheets. Documentation of staff roster and/or assignment (e.g., Staff X - TK; Staff Y - Grade 1, etc.). All documentation must have students’ names and any other personally identifiable information redacted. |
LEAs/Grantees do not maintain student-to-staff ratios. LEAs/Grantees do not maintain attendance records. LEAs/Grantees do not maintain accurate and/or clear records of student-to-staff ratios. LEAs/Grantees do not maintain student-to-staff ratios. LEAs/Grantees do not maintain staff attendance records. |
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EXLP 16 8 Findings |
Staff Minimum Qualifications LEA/Grantee ensures that all staff members who directly supervise students meet the minimum qualifications for an instructional aide according to the policies of the school district. All program staff and volunteers shall be subject to the health screening and fingerprint clearance requirements in current law and district policy for school personnel and volunteers in the school district. |
LEA’s/Grantee’s policy regarding: minimum qualifications for instructional aides, health screening requirements, and a fingerprinting clearance policy that explicitly states staff must be fingerprinted. Copies of actual documentation (e.g., high school diplomas, transcripts, test scores, resumes). Dates of health and fingerprint clearances documented on LEA/Grantee letterhead and signed by the Human Resources (HR) Director. Documentation is required for all program staff directly supervising students. |
LEAs/Grantees do not have a policy in place outlining the minimum qualifications for instructional aides, health screening requirements, and/or fingerprint clearance procedures. LEAs/Grantees do not maintain records of staff directly supervising students have passed the health and/or fingerprint clearances. LEAs/Grantees do not maintain records of actual documentation that staff directly supervising students have met the minimum qualifications for instructional aides. |
ASES, 21st CCLC, and ASSETs FAQs (DOCX)
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