The Policy Committee of the Expanded Learning Division has completed an analysis of the Federal Program Monitoring (FPM) findings for the 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 |
|---|---|---|---|---|
Expanded Learning Program (EXLP) 5 Before and After School Program (BASP) 5 7 Findings |
Late Arrival and Early Release Policies Grantee and/or their subcontractor has established policies for the reasonable late arrival of pupils to the before school program and/or reasonable early release of pupils from the after school program. |
Grantee and/or their subcontractor has established and consistently applied a Late Arrival Policy for the before school program and/or an Early Release Policy for the after school program. Parents/Guardians are signing pupils in (late arrival) or out (early release). Documentation must be site specific. |
There is not a Late Arrival and/or Early Release Policy. The Late Arrival/Early Release Policies are not implemented (i.e., parents not indicating the reason for late arrival or early release on the sign out sheets) by the program. Program staff fill in the reasons box for the late arrival or early release of students, not the parents/guardians. |
Late Arrival and Early Release Guidance ASES, 21st CCLC, and ASSETs Frequently Asked Questions (FAQs)(DOCX) |
EXLP 9 BASP 12 12 Findings |
Funding Direct Services to Pupils (85/15) Grantee allocates no less than 85 percent of the total grant award amount for Direct Services to pupils and no more than 15 percent of the grant award amount for Administrative Costs, including Indirect Costs for each site. If the grantee subcontracts with a provider, the combined Administrative Costs, including Indirect Costs should not exceed 15 percent of the grant award amount for each site. |
Fiscal records, such as detailed general ledger for Resource 6010 (ASES) and Resource 4124 (21st CCLC/ASSETs) for the previous Fiscal Year (FY). Duty statements for all staff charging time towards the grant. Memorandum of Understandings (MOUs) or Subcontractor Agreements with supporting fiscal records for subcontracted service that are at least $30,000. Time accounting records, such as timesheets and/or Personnel Activity Reports. Invoices from sub-contractors with supporting fiscal records upon request. Documentation must be site specific. |
Grantees are spending more than 15 percent on Administrative Costs, including Indirect Costs. Grantees and their subcontractors are each spending 15 percent on Administrative Costs, including Indirect Costs. Grantee and/or subcontractor administrative staff are charging time to Direct Services, but do not have the documentation to support the charges. Grantees and/or their subcontractors are charging items to the grant that are not allowable. There is no differentiation of time if a staff member worked for the school and the expanded learning program. Grantees are applying the 85/15 to the grant, not for each site. |
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EXLP 10 BASP 14 5 Findings |
Local Contribution of Cash or In-Kind (ASES only) Grantee operating an ASES program has obtained a local contribution of cash or in-kind funds equal to not less than one-third of the total grant award amount. Facilities or space usage may fulfill not more than 25 percent of the required local match (or eight percent of the total grant amount). Note: There will be a Match/In-Kind guidance coming out soon. |
Spreadsheet/documentation listing any non-ASES funded resource that provides support to the after school program: 1) snacks, 2) supper, 3) rent-free facilities used to operate after school programs, 4) teachers or Principals time for the after school program paid out of general funds, 5) any volunteer time, and 6) food bank items, etc. Grantee/District has MOUs and Subcontractor Agreements, or other documents showing how these services were funded. Documentation must be site specific. |
Grantee has not obtained a one-third match. Grantee does not have documentation/evidence for each item they are using as part of the match. Grantees has not applied the match requirement to each individual site. |
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EXLP 11 BASP 15 5 findings |
Supplement not Supplant Grantee and/or subcontractor uses program (ASES, 21st CCLC, or ASSETs) funds to only supplement, and not supplant, state and local funds. |
Grantee and/or subcontractor uses program funds to increase (supplement) services to the current students or provide similar services to additional students, and not replace (supplant) current funding to current students. Fiscal records, such as detailed general ledger for Resources 6010 (ASES) and Resource 4124 (21st CCLC/ASSETs) for the previous FY. Duty Statements for all staff charging time towards the grant. Inventory of equipment purchased with categorical funds. Justification for equipment purchased with categorical funding being used by non-ASES students (May have a cost-sharing arrangement). |
Grantee and/or subcontractor do not maintain adequate supporting documentation such as a cost-sharing arrangement between the expanded learning program and the site. Grantee and/or subcontractor uses program funds to pay for programs and services (journalism class, yearbook, etc.) that the site would typically provide using state and local funds. |
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EXLP 16 BASP 20 8 Findings |
Staff Minimum Qualifications Grantee and/or their subcontractor ensures that all staff members who directly supervise pupils meet the minimum qualifications for an instructional aide according to the policies of the school district. |
District’s current policy related to the instructional aide minimum qualifications. List of staff providing expanded learning program services at each site. Personnel records for all staff and/or subcontracted staff providing program services, including copies of transcripts, degrees, or district administered test(s). Documentation must be site specific. |
Program/front line staff do not meet the minimum qualifications of an instructional aide according to the district’s policies (even if the district is not the fiscal agent, the staff must meet their requirements). Grantee and/or their subcontractor do not have the qualification documentation(s) for each staff. |
ASES, 21st CCLC, and ASSETs FAQs (DOCX) Program Plan Guide (Number 7–Quality Staff) |
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