001Thank you for attending today's training webinar from the federal program compliance division. Today I will be talking about the program monitoring validations for the every student succeeds act private nonprofit schools equitable services the school system inventory control of purchases for equitable services. This presentation will share a few selected program monitoring validation requirements that must be submitted if a school system is selected for validation. However, there are many other program requirements for keeping inventory control and purchases for equitable services on file. Please ensure that as a school system you have all documented records and documentation for each of the requirements that I will speak of. This presentation is intended solely to provide general information and guidance to Texas school systems, education service centers, nonprofit subgrantees, and participating private schools receiving equitable services. The content in this
002presentation reflects the Texas education agency's current understanding of statute and applicable federal guidance. The content of this presentation is subject to change as a result of future guidance and/or other updates provided by federal agencies within regulatory oversight of these programs. This presentation does not constitute legal advice and entities are therefore advised to seek legal counsel regarding the information and guidance provided in this presentation before acting upon the information provided. Artificial intelligence disclaimer recording or use of artificial intelligence. The Texas Education Agency or TEA does not permit thirdparty recording or the use of artificial intelligence AI summary services during its grants related trainings. Attendees of the TEA's grants related trainings may not use AI services, language models, applications, interfaces, or assistance to attend, review, or record the trainings. TEA further prohibits any person or entity from
003using the information included in its grants related trainings to train AI technologies. Any attendees of TEA's grant related trainings who violate this prohibition may be removed from the trainings and may be barred from attending future grants related trainings. Please note that documentation for viral meetings is an acceptable form of documentation given the increased of virtual meeting environments. Participant rosters that include the meeting title, meeting date, and stakeholder names and roles would be acceptable substitutes for the more traditional signin sheets. This eliminates the need of a participant signature. Documentation requested. Take note of these items. Documenting overall compliance for a program requirement may require several forms of documentation to be maintained locally and available upon request by TEA andor an auditor to ensure overall compliance with program requirements. School systems should refer to the program guide
004and/or other program related resources that reference the multiple forms of documentation required to be maintained locally. The documentation requested for submission during the validation process may not include all forms of documentation that are required to be maintained locally. ESSA section 1117 provides the statutory requirement for the title one part A program. The el the school system must maintain inventory control of private nonprofit or PMP purchases for equitable services. The school system must keep control of all funds titled to materials, equipment, and property purchased. 8501 provides the statutory requirements and references for title 8 programs. The title 8 programs include title one C migrant, title 2 part A, title three part A English learners and immigrants, title four part A, and title four part B which is the 21st century competitive grant. School systems must keep
005control of funds and title to all purchases for PNP equitable services regulations title 34 section 76.661. It gives us that the citation references about maintaining inventory control of purchases for equitable services. And so it states under some program statutes, a public agency must keep title to and exercise continuing administrative control of all equipment and supplies. And so anything that the school system purchases to be used by a private school, it must retain those titles. It must ensure that it's keeping an inventory log and it must ensure that whatever those items are, they can be removed from the private school without any remodeling or repairing of the private school facility. The school system shall remove equipment or supplies from a private school if the equipment or supplies are no longer needed for the purposes of the
006project or removal is necessary to avoid use of the equipment and supplies for other project purposes. They also find programsp specific provisions and asurances that are related to the title one part A program um private nonprofit requirement on maintaining inventory control. And so one of the insuranceances says the control of the title one part a funds entitled to materials, equipment and property purchased with such funds shall be in a public agency and the public agency is the one that shall administer such funds, materials, equipment and property. The same is true for any of the equipment and supplies that are purchased under the title 8 programs. We do have an assurance in the ESA consolidated application under the title 4 part A program specific provisions and asurances which states the same as the title one part
007A program that the school system is complying with those provisions for providing private school programs as specified according to the statute. on this school systems compliance report which is the PR 3099 for private nonprofit schedule. One of the program compliance selfch check indicators are for it to maintain inventory control of purchases for PNP equitable services. And on the consolidated federal grant application, the PS399, which is the private school schedule in the application, must keep policies and procedures documented to maintain a controlled technology, equipment, and supplies purchased for the participating PMP equitable services programs. documentation that is required to meet the requirement of school systems maintaining the inventory control of purchases for equitable services. There are three different requirements for documents. 1.1 is that the school systems internal control policies and procedures that you actually have
008a written inventory control policy and procedure for the pre previous year and you must submit at least one sample of that dated agenda, the consultation mo notes and other auditable documentation specifying that the school system maintain control of those private nonprofit purchases for equitable services. And the third piece of documentation would be the school systems evidence of inventory control. Generally that is a inventory list that is in the school systems control and that one example to ensure that you're meeting control meeting the requirement for that is documentation of the school systems prior inventory list of items purchased for PMP equitable services on one private school campus for each of the participating ISA program And that is some examples may be uh for supplemental property and equipment, materials, supplies, any devices or lab equipment. Those will
009be some of the examples of inventory listed items that the school system should have available and would submit along with 1.1 and 1.2 to documentation that is required to show that it is maintaining the control of those purchases. If, for example, the school system does not have any equipment or supplies that were purchased as inventory, then the school system would indicate in a document that they did not purchase any equipment or um for the private schools. And so you will still need to submit something if by chance you are selected for this particular um item. Some of the most common areas in which a school system will miss requirement is that the and result in an improvement need a status are auditable documentation requested from the applicable year was not submitted. The documentation submitted did
010not specify the requested validation requirements. documentation did not provide applicable year the of the inventory purchases per participating private school and the documentation did not indicate the school system maintain control of those purchases during the applicable year. And so these are things that you want to ensure that you have in place so that you would be able to answer those questions and meet the requirement without having an improvement needed status. It is very important that the school system selects that one school and with that one school if it participated in multiple programs and there were inventory purchases for multiple programs that you actually submit documentation. So, if there were uh inventory items for title one part A and title four part A, then you would need to list those inventory logs and items and all
011of the documentation for those different programs for one private school. And it is up to the school system to decide which school they will select to submit documentation for. And again, if there was no funding spent on inventory at all, then the school system would just need to submit documentation stating, "We did not have any inventory purchases. But you still need to submit your inventory policies and procedures because that is something that should be updated annually and shared with the private school in the event that there is a inventory request within that school year. So you still must have it on file uh the procedures and policies even if you did not make any purchases. So you still would need to submit some documentation. Now I'd like to share a few examples of resources and
012support. There are program monitoring validations process online resources. For example, there are uh program monitoring validation process handbooks, instructions for how to submit documentation through the work app. There's a training video and there's also the training slides for this particular training. Program specific resources are available under the guidance documents for each program and requirement as well as those videos and training slides that are program specific. And you may see all of the pro all of the program resources are available by clicking on the ESA program monitoring validations webpage link at the bottom of this presentation. on the Federal Program Compliance Division's web page that are directly uh designed to help school systems understand what the program monitoring validation of inventory control uh means and what the requirements are. There's a guidance document, training slides, and
013a training video where you can select to listen to the video at any time. You can also download the slides and the guidance document. I highly recommend that you take the time to share your your planned documentation with your local ESC, education service center staff so that they're able to review it and ensure that it meets the requirements because many times there are school systems that upload documentation that does not even address the requirements that TEA is asking. for or the documentation submitted is not detailed enough or it's too much documentation. You do not want to submit more than what TEA is asking for. And you also need to ensure that you're submitting the year that is being requested. And so that's why it's so important to share these documents with your ESC staff so
014that they can review it. they can provide any guidance on any additional support or additional revisions that you should make before you upload the documentation through the TEA's work app. School systems may also receive support from their local education service center um as a complimentary technical assistance and training service. You may find the ESC contacts for each regional center on the TEA Title 4 Part A web page of just a few of the specific education service centers basic services that are provided free of charge to the school systems to ensure that it is meeting compliance when it comes to the program monitoring validations. And so the ESC staff, they are available to help you with the equitable service requirements under title one part A and title 8 to assist the school system in their development
015and all the way through the submission process for the consolidated grant application, which is the PS3099 private school schedule and the PR3099, which is the consolidated compliance report schedule. And so they are there ready and available to help you because they receive a grant to provide those services across the state. And also they are also there to help those school systems as they work to submit documentation for their PMP equitable services program monitoring validations. So please use those ESC's and their services to ensure that you are actually submitting documentation that hopefully is going to help you to meet compliance. Thank you for attending this virtual training session. If you have questions, please let me know. Have a wonderful day.