July 7, 2023

Dear California State Preschool Program Executive Directors and Program Directors:

FISCAL YEAR 2022–23 JUNE YEAR-END REPORTING REMINDERS

The purpose of this letter is to compile reporting information provided throughout Fiscal Year (FY) 2022–23 and to provide contractors the due dates and reporting requirements for purposes of completing June year-end and audit reports for the fiscal year ending June 30, 2023. Please share this letter with your agency staff. A subsequent letter will be issued by the Early Education and Nutrition Fiscal Services (EENFS) unit in the coming weeks to inform contractors of any changes to California State Preschool Program (CSPP) contracts and reporting procedures for FY 2023–24.

Contracts and Contract Amendments

Any outstanding original contracts and contract amendments requiring signature for FY 2022–23 must be signed and returned to the California Department of Education (CDE) Contracts Office as soon as possible. The CDE cannot make payments based on amended terms until amendments requiring signature have been signed and returned.

As a reminder, due to the Allocation Letter process implemented in FY 2021–22, most original contracts and amendments do not require a signature. Contractors unsure whether an amendment requires a signature should contact the CDE’s Contracts Office at EarlyEducationContracts@cde.ca.gov. 

Fiscal Year 2022–23 June Year-End Reports Reporting Deadline

FY 2022–23 June year-end Enrollment, Attendance, and Fiscal Reports are due by July 20, 2023. All reports must be submitted online through the Child Development Provider Accounting Reporting Information System (CPARIS). Acceptable reports not certified by July 20, 2023 will be considered delinquent. Pursuant to California Code of Regulations, Title 5 (5 CCR) Section 17814, a delinquent report results in withholding any remaining apportionments due for FY 2022–23. Additionally, apportionments for FY 2023–24, beyond the initial payment, will be withheld until the contractor has complied with this contract requirement.

CPARIS can be found on CDE’s website at https://cparis.cde.ca.gov/cparis/. The CPARIS User Manual, which provides CSPP contractors with instructions on how to navigate the web-based application, can be found at https://www.cde.ca.gov/fg/aa/cd/documents/cparisusermanual23.docx. A recording of the CPARIS webinar held in January 2023, during which a system overview, the process to certify and revise previously certified reports, and a review of the CSPP contract earnings calculation was discussed, can be found at https://www.cde.ca.gov/fg/aa/cd/cpariswebinar.asp.

FISCAL YEAR 2022–23 ENROLLMENT, ATTENDANCE, AND FISCAL REPORTING

Coronavirus (COVID-19) Related Closures, Reporting, and Reimbursement

Assembly Bill (AB) 210 (Chapter 62, Statutes of 2022), Section 9, specifies that for FY 2022–23, CSPP contractors are to be reimbursed the lesser of 100 percent of the contract Maximum Reimbursable Amount (MRA) or net reimbursable program costs, without regard to enrollment or attendance, when they meet the policy directives set forth by the Early Education Division (EED).

In order to be reimbursed as provided in AB 210, all CSPP contractors must:

• Open to provide in-person early education services for enrolled families in accordance with the contracting agency’s FY 2022–23 approved program calendar, and remain open and offer services through the 2022–23 program year;or

1. Not provide in-person services by the start date of the contracting agency’s FY 2022–23 approved program calendar, due to local or state public health orders or guidance that prevent the program from operating;or
2. Open for in-person services in accordance with the contracting agency’s FY 2022–23 approved program calendar, with any future days of closure being due to a local or state public health order or guidance.

CSPP contractors, whether providing in-person or distance learning services, are required to report the days of enrollment for all children receiving services in the program. CSPP contractors will only report the days of attendance for children who receive in-person services and will not report days of attendance for any children participating in distance learning activities. Excused absences will only be reported as a day of attendance for children who were expected to physically attend the program on any given day, but the child did not attend.

In the case where a contractor’s days of closure are not attributable to closure by a local or state public health order or guidance or an approved non-COVID-19 emergency closure, the contractor’s MRA will be pro-rated by the days of operation that the contractor was not open to provide in-services. Contractors must submit a revised FY 2022–23 program calendar and a program narrative change to their assigned EED Program Quality Implementation (PQI) Regional Consultant to ensure that the correct minimum days of operation (MDO) are reflected in their contract. The revised calendar will be used by EENFS to determine the pro-rated FY 2022–23 MRA.

Reporting Waived Family Fees

Pursuant to Education Code (EC) Section 8252(h)(1), family fees are waived for all families effective July 1, 2022, through June 30, 2023. The EED released Management Bulletin (MB) 22-07: Assessment, Waivers and Reporting of Family Fees for FY 2022–23, notifying contractors that all family fees were waived for all families in FY 2022–23. Although family fees are being waived for FY 2022–23, contractors are still required to calculate and assess the appropriate family fee.

The Enrollment, Attendance, and Fiscal Report in CPARIS allows contractors to report the amount of family fees waived. All contractors are required to report the total amount of family fees that were assessed, but waived, in accordance with the directive in MB 22-07. Contractors must report the amount of family fees waived on the line Waived Family Fees for Certified Children. The cumulative amount reported in this field should represent the total amount of fees that would have been collected from families in FY 2022–23 if family fees had not been waived.

For additional details, please refer to MB 22-07, which can be found here:  https://www.cde.ca.gov/sp/cd/ci/mb2207.asp.

CSPP Reimbursement Rate Supplement Allocations

AB 131 (Chapter 116, Statutes of 2021), subsequently amended by AB 185 (Chapter 571, Statutes of 2022), allocated funding to provide CSPP contractors with one-time reimbursement rate supplements to address the inequities between the standard reimbursement rate and the regional market rate (RMR) ceiling. The CDE allocated rate supplements to fund the difference between the State preschool program reimbursement rates as of January 1, 2022 and reimbursement rates equivalent to the 85th percentile of the 2018 RMR Survey preschool rate. Note that not all CSPP contractors will receive an allocation due to their current rate exceeding the percentile attained by the allocation of these funds.

The CDE began releasing rate supplement payments beginning in June 2023 and eligible CSPP contractors will receive a notification email from their fiscal analyst as allocations are released to contractors. As a reminder, rate supplements are considered restricted income and should be reported only when the corresponding expenses are reported. Rate supplements funded by the American Rescue Plan Act (ARPA) shall be reported on the line Restricted Income: American Rescue Plan Act (ARPA) in CPARIS. Rate supplements funded by State General Fund or Proposition 98 shall be reported on the line Restricted Income: Other in CPARIS. Please refer to the Reporting Revenue and Expenses section of this letter below for additional revenue and expense reminders.

Reporting Revenue and Expenses

Contractors must follow Generally Accepted Accounting Principles (GAAP) for accrual accounting and shall follow the accounting procedures specified in the most recent edition of the California School Accounting Manual (CSAM). The CSAM 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.

Contractors are reminded that reporting revenue is dependent on the source of the income and how it is expended. Revenue should only be reported when its corresponding expenses are also reported. Restricted revenue reported in the Restricted Income categories in the Enrollment, Attendance, and Fiscal Report is income provided for a specific, limited purpose and that can only be expended for certified children (5 CCR Section 17700).  

Additionally, if contractors earned government funding, such as Paycheck Protection Program or Employee Retention Tax Credit funding, related to expenses claimed as reimbursable to a contract, that revenue is considered program revenue and the funds must be reported as restricted income. It is important to ensure all restricted income is correctly reported throughout the year. Restricted income that is not reported until a contractor’s audit could result in a large unexpected billing.

When determining whether an expense may be charged to the contract, contractors should follow GAAP. This guidance includes situations where a contractor prepays for supplies or equipment in one contract year and does not receive those supplies or equipment until the following contract year. Per CCR, Title 5, Sections 18037 and 18063, with the exception of audit costs, expenses considered incurred in a future year per GAAP are not reimbursable under the current year contract.

For additional details, please refer to the CSAM, which can be found at https://www.cde.ca.gov/fg/ac/sa/.

Reporting Start-up Allowance

Contractors with a FY 2022–23 CSPP 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 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.

Allowable start-up expenses are negotiated and approved by the CDE and are 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 Enrollment, Attendance, and Fiscal Report. In most cases, these grant funds should be reported as supplemental revenue and expenses.

Reporting Reminders for the Prekindergarten and Family Literacy Support Contract

The Prekindergarten and Family Literacy Support (CPKS) contract is a support contract that also requires that a June year-end fiscal report be certified by the July 20, 2023 deadline. CSPP contractors who hold a CPKS contract must submit their June year-end fiscal report in CPARIS, even if the contractor fully expended and reported the full contract amount prior to the end of the year.

REVISED JUNE YEAR-END REPORTS

June year-end reports must be certified by the deadline of July 20, 2023 to avoid becoming delinquent. However, revisions to year-end reports may be submitted later under the limited circumstances outlined below by non-Local Education Agency (LEA) and LEA.

CSPP Contractor Revision Deadlines for Non-LEAs

Non-LEA contractors may submit revised year-end reports through August 21, 2023. Upon approval by EENFS, a preliminary contract closure calculation will be viewable in CPARIS based on the June year-end report, or a revised June year-end report, that is received by the August 21 deadline. Revised reports cannot be submitted after this date; contract closure and year-end reimbursement calculations will be based on the contractor’s audit.

CSPP Contractor Revision Deadlines for LEAs

LEA contractors may submit revised June year-end reports according to the deadlines below. Contract closure and year-end reimbursement calculations for an LEA are based on the June year-end report, so it is vital that information is complete and accurate. LEAs should submit a revised report, if necessary, to EENFS 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 EENFS Fiscal Analyst (FY 2022–23 Contract Terms and Conditions (CT&Cs)).

• A County Superintendent of Schools/School District audit is due on December 15 (EC Section 41020). The revised report deadline for FY 2022–23 is February 13, 2024.
• A Community College audit is due to CDE on December 31 (CT&Cs).  The revised report deadline for FY 2022–23 is March 1, 2024.

PRESCHOOL RESERVE ACCOUNTS

Due to the transition of General Childcare and Development Program (CCTR), Migrant Childcare and Development Program (CMIG), and Severely Disabled Program (CHAN) contracts from the CDE to the California Department of Social Services (CDSS), effective July 1, 2021, Center-Based Reserve Accounts were split into two Reserve Accounts: one for CSPP (referred to as the Preschool Reserve) and one reserve for CCTR, CMIG, and CHAN contract types (referred to as the Center-Based Reserve).

Effective July 1, 2022, EC Section 8336 was amended to remove the requirement that 10 percent of the reservable amount must be utilized on professional development for the CSPP. Therefore, CSPP contractors may now utilize their total Preschool Reserve Account balance for all allowable CSPP expenses.

Preschool Reserve Account Reporting

If a CSPP contractor has a Preschool Reserve Account, a Preschool Reserve Account Activity Report is required, regardless of whether the Preschool Reserve Account has a balance. A copy of the contractor’s general ledger report page(s) that reflects the cash balances maintained in the Reserve Account must be submitted via email to the assigned EENFS Fiscal Analyst by July 20, 2023.

To be considered acceptable, the Preschool Reserve Account Activity Reports must comply with the following:

• The beginning balance reported on the FY 2022–23 Preschool Reserve Account Activity Report must be correct and must match the ending balance of the most recent FY 2021–22 EENFS 9530 Reserve Account Status Report provided by EENFS.
• The Preschool Reserve Account amounts must be kept in an interest-bearing account within the contractor’s early education fund. Preschool Reserve Account Activity Reports submitted to EENFS that indicate a balance with no interest reported will be deemed as unacceptable.
• Requested transfers from Preschool Reserve Accounts must match what is reported in the Transfer from Preschool Reserve line in the Revenue section of the June year-end Enrollment, Attendance, and Fiscal Report in CPARIS. Contractors who utilize Preschool Reserve Account funds for expenses incurred in FY 2022–23 must report the transfer from the reserve on the Preschool Reserve Account Activity Report as well as on the Enrollment, Attendance, and Fiscal Report. These amounts must be the same.
• The general ledger must be submitted by email to the assigned EENFS Fiscal Analyst.

Establishing a Preschool Reserve Account

Contractors who do not currently have a Preschool Reserve Account and wish to open one can do so in CPARIS. The request to open a Reserve Account can be found in the Reporting tab of CPARIS. Requests to open a Preschool Reserve Account must be received by July 20, 2023 to be established as of FY 2022–23. Requests received after that date will not be processed. Requests to establish a Preschool Reserve Account do not need to be made annually; contractors that established a Preschool Reserve Account in prior years do not need to establish a reserve account again in FY 2022–23.

For further information, please refer to the Preschool Reserve Account instructions in the CPARIS User Manual, which can be found at https://www.cde.ca.gov/fg/aa/cd/documents/cparisusermanual23.docx.

Closing a Preschool Reserve Account

Contractors who wish to close a Preschool Reserve Account may do so by completing the Request to Close Reserve Account in CPARIS. If a Preschool Reserve Account is closed, any balance currently held in the Preschool Reserve Account, as well as any interest accrued by the funds, must be returned to CDE. Requests to close a Reserve Account should be submitted on the same date the contractor’s June year-end Enrollment, Attendance, and Fiscal Reports are submitted, which are due July 20, 2023.

AUDITS AND INVESTIGATIONS DIVISION: AUDITED ATTENDANCE AND FISCAL REPORTS 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.

Pursuant to 5 CCR Section 17825(c), contractors that fail to produce or submit an acceptable audit within one year of the due date, as specified in CCR, Title 5, Section 17814, may be billed for 100 percent of the preschool funding received by the contractor for that fiscal year.

Fiscal Year 2022–23 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 2022–23, can be found at https://www.cde.ca.gov/fg/au/pm/.

Fiscal Year 2022–23 Electronic Submission Instructions

FY 2022–23 audit reports may be electronically submitted to CDE using the following information:

Website: https://www3.cde.ca.gov/exfiles/index.aspx?pid=204

Project Code: AUDIT23

Password: UPaudit23

Audit reports that need to be submitted to the CDSS may be emailed to AuditsOffice@dss.ca.gov.

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/.

• 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 211).
• Except for contractors on conditional status, a CSPP 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.
• Per Section 360, as of FY 2020–21 audit submissions, contractors are required to submit a quality review checklist along with their audit reports and include a supplemental schedule titled Notes to the Child Development Contract Supplemental Information in the audit report. CDE will make the checklist and a template of the supplemental schedule available on its website at https://www.cde.ca.gov/fg/au/pm/ and by request at AuditSubmissions@cde.ca.gov.
• 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 Preschool 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 preschool 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 211.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).
• 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.

Costs Disallowed in Child Development Audits

The following are examples of costs disallowed in audits of preschool 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 CT&Cs for Preschool Programs. The CT&Cs can be found at: https://www.cde.ca.gov/fg/aa/cd/ctc2023.asp

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 (CT&C, Section VI.F).

The following costs are disallowed, as they are specifically prohibited by the contract. Note, this is only a partial list (CT&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 (CT&C, Section V.H)
• Costs are disallowed if they are not reasonable and necessary to the performance of the contract (CT&C, Section V.A), 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 (CT&C, Section III.D).
• When a contractor lacks prior written approval from the EED, costs are disallowed for:
  • Renovation and repairs or equipment purchases in excess of the CT&Cs thresholds (CT&C, Section III.E)
  • Subcontracts for direct early learning and care services (CT&C, Section IV.E)
• Rent is disallowed (CT&C, Section II.O):
  • 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. (CT&C, Section VI.F).
• 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 A&I Division at 916-322-2288.

Additional Resources

The EENFS webpage contains valuable resources for contractors, including the Enrollment, Attendance, and Fiscal Reporting, and Reimbursement Procedures for Early Education Contractors, also known as the EENFS Fiscal Handbook. Supplemental fiscal guidance, such as contract-related updates, rate reform resources, a link to CPARIS, the CPARIS User Manual, and Frequently Asked Questions, and links to view past webinars, can also be found on the EENFS webpage.

CSPP contractors will continue to be informed of added content to this webpage by notification through the EED Email Distribution List Subscription. The subscription page for the EED email distribution list can be found at https://www.cde.ca.gov/sp/cd/ci/progspeclist.asp. The EENFS webpage can be found at https://www.cde.ca.gov/fg/aa/cd/. Additionally, MBs distributed by the EED throughout FY 2022–23 can be found at https://www.cde.ca.gov/sp/cd/ci/allmbs.asp. The MBs also contain fiscal directives, when applicable.

If you have questions or need clarification about any other topic covered in this letter, please contact your assigned EENFS Fiscal Analyst. The EENFS Fiscal Analyst directory can be found at https://www.cde.ca.gov/fg/aa/cd/faad.asp.