Federal Program monitoring visits are in full swing around the state. It may be your turn next year if you weren’t monitored this year. Even if you aren’t one of the chosen lucky ones (touch of sarcasm there), maintaining documentation for each indicator is always a good practice. This is an excellent self-assessment for risk management.
There are several ways one can maintain monitoring documentation for the indicators. Some districts use electronic files such as Google Docs to store the documentation, while others use paper files and boxes. Title I Crate is an electronic storage system many districts use. Most MDE monitors are familiar with Title I Crate, and one does not have to upload anything in MCAPS. However one chooses to store the information, it is essential to file the documents in such a way that it is easy to access and easy for the monitors to find the documents that support the fulfillment of the indicator.
As mentioned in an earlier blog, the Federal Programs Procedure Manual is critical. The monitors read what your procedures state and want specific documentation supporting the procedures being followed. For example, suppose your procedures state 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 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. I like to recommend people label the procedure clearly with the appropriate indicator. Doing so eliminates the risk of the auditor saying they couldn’t find it. Make sure all documentation is clearly labeled with the proper indicator.
Another hint is clearly labeling the folders being used if electronic or paper. For instance, BB-3 Monitoring and Supporting Student Progress requires specific documentation described in the LEA and school plans. You will want to refer to your plans and have documentation supporting what is written. My district’s plan states we use NWEA scores and Tier documentation. I will upload a file labeled Student 1. In this file, I include the tier documentation showing how we monitor that student’s progress. I will then provide a second student example and label this folder accordingly. Uploading each piece of paper individually in the electronic storage systems is not recommended. Group folders and label them clearly.
On the other hand, it is not recommended to upload one folder and put all pages in the folder. If an auditor has to go through 20 to 30 pages of documents, they may quit looking. As stated earlier, make this process as easy for the reader as possible, even if it may cause more work for you.
This year, a strong focus for many monitors appears to be on indicators dealing with FERPA and Personal Identifiable Information (PII) and, subsequently, with data management. These are the E Records and Information Management and O Data Quality indicators. Documentation is necessary to support teachers and staff dealing with student information, having been trained on FERPA and PII. This will include personnel dealing with registration, student data entry, and MSIS documentation. Another group of critical indicators is C Internal Controls, specifically D-2, which deals with waste, fraud, and abuse. Monitors are looking for a policy that clearly states how one can report waste, fraud, and abuse and what one will do about it. And as always, fixed assets are significant. Ensure that all fixed assets are found where the fixed asset reports list them and that they are clearly labeled and tagged.
Monitoring is time-consuming; however, if one staggers the indicators over the year for both the district and the schools, the documentation is complete by the end of the year. The goal is to make monitoring as stress-free as possible.