The Mississippi Department of Education (MDE) is finishing the FY22 monitoring on FY21 documentation. After spending time with districts going through monitoring and working with them as they receive their reports, I would like to share some feedback that would better help the rest of us as we prepare for future monitoring visits from MDE.
First, the Federal Programs Procedure Manual is critical. I have shared information about that manual in previous blog posts. The monitors do read what your procedures state, and they want specific documentation that supports the procedures being followed. For example, suppose your procedures say that the Federal Program Director (FPD) meets with the Business Manager to complete the monthly draw-down process. In that case, the monitors will want documentation to show this meeting took place. The documentation can be meeting agendas/minutes/sign-in sheets or just a document signed and dated by both parties with the meeting description. Findings result from when (a) the monitor looks for the indicator in the manual and can’t find it, and (b) the monitor reads the procedure in the manual, but the documentation in the evidence folder does not reflect what is written.
Indicator A-6 is one of the most frequently cited indicators. This indicator requires the budget and accounting records to align with the approved funding application. Districts encounter problems when the accounting budgets run into the negative before revisions occur. As many of you know, it is easy for personnel costs to run into negatives due to changes in personnel, changes in benefits amounts, or changes in salary. Indicator A-6 can easily result in questioned costs requiring the district to reimburse the State Treasurer Fund. It is recommended that the percentage expended on the salary be monitored monthly. Are the percentages remaining sufficient to carry the fund through the balance of the year? If not, make revisions before expending the fund while keeping in mind the time frame for revision approvals at the MDE.
Another indicator that needs close attention is Indicator H-1. Key words in the indicator include “full and open competition.” The Federal Program Director must ensure the procurement policies are followed according to the spending categories established by the State. Goods between $5,000 and $49,999 must have two or more signed and dated quotes. Goods $50,000 or over must follow the reverse auction guidelines unless there is a state contract or on the Express Products List (EPL). MDE takes the position there are no sole source vendors. If a district believes the item required is a sole source, the FPD should email MDE’s Office of Federal Programs and request written permission to identify the vendor as a sole source. As Federal Program Directors, we recognize some vendors have unique items that other vendors do not sell. Remember, the requirement is to have “full and open competition.” If the district posts on public websites a Request for Proposal/Quotes detailing the specifics of what is needed, and only one vendor replies, then the district has met the condition of the law. However, keep in mind that the proposal’s requirements should not be so specific that it names the product in the request. In addition, it should be evident to all that the district did not attempt to limit vendor participation. Keep all documentation to support an honest attempt to solicit an adequate number of vendors.
My recommendation is that one does not look at monitoring as punishment or as a “gotcha” moment; use it as a learning experience. The key to a successful monitoring experience is being well prepared by understanding the monitoring instrument, knowing your procedure manual, and maintaining documentation throughout the year.
I will give more lessons and suggestions on monitoring in the coming months.
Summer is here! Find some time to relax and enjoy the weather!