Dear Workability I Region Managers, Program Coordinators, Regional Treasurers, and Grantees:

Workability I Regional Meeting and Bank Account Guidance

The purpose of this letter is to provide additional program guidance specific to Workability I (WAI) regional bank accounts, as addressed in the letter issued on April 5, 2021, and located on the California Department of Education (CDE) website at https://www.cde.ca.gov/sp/se/lr/om040521.asp.

As mentioned in the guidance letter from April 5, 2021, WAI grant funds are for the provision of the WAI grant program in accordance with California Education Code (EC) Section 56471(e). The assurances agreed upon receipt and signature of the Grant Award Notification (GAN) do not change with the deposit of WAI grant funds into another account, or the redirection of the WAI grant funds by the grantee to another party. Therefore, funds collected from WAI grantees for the purpose of providing WAI regional business meetings or other regional expense remain WAI funds and subject to the conditions of the grant award and EC 56471(e). WAI grantees cannot redirect WAI grant funds without approval by the CDE as it presents a heightened risk that the funds may be misappropriated and utilized for unallowable activities.

The collection and pooling of WAI funds from WAI grantees is no longer a permissible practice. WAI regional bank accounts will no longer be permitted and shall be closed by June 30, 2021.

The CDE recognizes the value of the regional business meetings which provide training and professional development within each WAI region. The CDE will be providing funding to one (1) designated WAI grantee within each region for the purpose of hosting in-person regional meeting(s). The WAI funds provided to the designated WAI grantee must be spent on organizing in-person regional meeting(s) within the same fiscal year (FY) in which the funds were received.

General Guidelines for Meetings and Trainings

Allowable expenditures for WAI staff, related to regional business meetings, workshops, in-service or other trainings shall meet the following criteria:

• Be reasonable and necessary for the implementation of the WAI regional business meetings.
• Expenses incurred by WAI grantees shall be budgeted in the approved WAI grant budget(s).
• Expenses incurred by the regional designee for the regional business meetings are limited to training and professional development for the provision of WAI services.
• If an in-person meeting is not feasible, WAI grantees shall use other modes of communication to disseminate information, such as telephone, email, or videoconference, instead of incurring expenses related to in-person meetings. This requirement does not waive the GAN condition number 9 (page 2 of the GAN), which requires grantees to convene regional meetings a minimum of twice a year.

Unallowable WAI Regional Meeting Expenses

Unallowable expenditures for WAI staff, related to regional business meetings, workshops, in-service, or other trainings shall meet the following criteria:

• Costs related to social activities such as food, potlucks, dances, holiday and graduation parties, or any other celebrations.
• Costs related to entertainment, including amusement and diversion.
• Cost related to promotional items or materials.
• Costs related to speakers or presenters.

The WAI funds provided for regional business meetings must be tracked by the WAI designee (e.g. regional treasurer) within each WAI region and are subject to an audit by the CDE per WAI GAN condition number 12 (page 2 of the GAN):

The grantee must maintain expenditure reports with supporting evidence and be prepared to submit them to the CDE upon request. The CDE has the authority to conduct program and fiscal reviews or audits.

The WAI regional designee shall submit an end of year regional expenditure report each fiscal year, no later than the August 10, that includes the following:

• All allowable expenditures associated with the operating costs of the WAI regional business meeting(s).
• The regional designee’s budget should delineate between the costs for the regional business meeting and the traditional grant award amount.
• If there are unspent WAI grant funds that were allocated for regional business meetings, the WAI regional designee will submit a final expenditure report indicating the amount of remaining grant funds to be returned to the CDE.

The WAI grantees receiving grant funds are required per EC Section 41010 to follow the definitions, instructions, and procedures in the California School Accounting Manual (CSAM). This includes the provision of additional WAI grant funds to the WAI designee within each region for the purpose of conducting regional business meetings. Operating agencies and districts are mandated to follow CSAM guidelines for conformity with generally accepted accounting principles, which are essential for consistency and comparability in financial reporting.

The CSAM is to be used for classifying, developing, and recording all revenues and expenditures for the WAI program.

The CSAM may be viewed and downloaded at https://www.cde.ca.gov/fg/ac/sa. Please refer to the CSAM web page to view the object classification codes.

The CDE will be creating and providing training for regional designees and managers at the beginning of fiscal year 2021–22. We look forward to your attendance.

If you have additional questions on the above information, please contact Nick Wavrin, Education Programs Consultant by email at NWavrin@cde.ca.gov, or Wes Roberson, Education Programs Consultant by email at WRoberson@cde.ca.gov.

Sincerely,

Heather Calomese, Director
Special Education Division

HC: nh