FY25 Monitoring Focus Area 2 Overview: Program Design, Management, and Improvements and Fiscal Infrastructure
Glenna Davis: Hello, and welcome, everyone to the FY25 Monitoring Focus Area 2 Program Design, Management and Implementation, also known as PDMI, and Fiscal Infrastructure informational session. It is now my pleasure to turn the floor over to Tamara White. Tamara, the floor is yours.
Tamara White: Thank you, Glenna, I really appreciate it. Good afternoon, everyone. My name is Tamara White, and I am a member of the oversight team here at the Office of Head Start. We have an exciting FA2 information session for you today. We're going to be doing a deep dive into two content areas that are covered in the FA2 review, and they are, the program design, management and implementation, which is PDMI, and fiscal infrastructure.
As Glenna stated, you will get these slides at the end of the presentation, and this session is being recorded and will be posted. We're going to cover all of the areas listed on this slide, and more. Buckle up, let's go. We're going to cover as much as we can in our time together today. Again, please use the Q&A feature to submit your questions, and we'll take as many questions as we can during the call.
Now this is the second of three information sessions that we have been hosting, or plan to host on FA2. Yesterday, we had the fun time of discussing ERSEA and FCE, and today we're going to discuss, as I stated, PDMI and fiscal. Tomorrow, last but not least, we're going to discuss ECD and health. I hope you're able to join us for them. Now it is my privilege to turn the spotlight over to our illustrious monitoring lead, Adia Brown.
Adia Brown: Hi, everybody. I feel like this should be like a "Yaaaay" after that - Tamara, thank you for such a warm welcome. I am so excited to be here with you another day, talking about another thing. Hi, everybody, I'm glad everybody's here.
Today, we're going to talk about PDM. It's two of us, I have a special guest that's going to be coming on later, but I'm going to first take you through program, design, management and improvement. Let's go. There's a few things that I'm going to do on every one of these calls, if you came here yesterday, you're going to hear it again. But I want to make sure that everybody understands what we're doing and where we're going.
Now, we're going to be having some fun in the chat. I always ask questions in the chat, I ask you to do things, I ask questions, as you to have reactions in the chat - that's what we're going to use the chat for. But if you have a question, look down on your screen, and there's a Question and Answer - it says "Q&A." That's where you put your questions. You put any questions in the chat, we won't be able to find them, and they probably won't get answered. Make sure you use Q&A for questions, and the chat to have some fun. If you're ready to have some fun, say, "I'm ready to have fun" in the chat. Let's see it!
The first thing that we do is, we're going to tell when we're going to begin. We're starting a little later this year, we normally start back in September; however, with the new Head Start Performance Standards, we actually slow things down to give people the opportunity to get ready for that.
We won't be starting until December the 16th. If you have already been - if you're going to be reviewed this year, you've already gotten something called a "global letter." That global letter tells you that you're going to be a part of our review pool this year. It tells you what review type you're going to have, but it doesn't tell you the review date. The letter that tells you the review date is the 45-day letter, and you get that 45 days prior to your review. Let's keep motoring along.
Right now, on HeadStart.gov, formerly know as ECLKC, and you can still go to ECLKC and find HeadStart.gov. We have the monitored protocols. We put them there every year, the FY25 protocol is there - you should check it out, it's a great resource. We're going to be talking about it throughout this presentation.
Let's really jump into it. In case you're new and today is your first day, there are six performance areas that we look at, we call them performance or content areas in monitoring. The first one is one we're going to talk about day, is program design, management and improvement. The next is education and child development.
We do health services, we do family and community engagement, fiscal infrastructure, and eligibility, recruitment, selection, enrollment and attendance, otherwise known as ERSEA, or some people say ERSE-A. Those are the six sections that we actually look at in the FA2. You should be familiar with them. Today, we're going to be talking about program design and management. If you are a program design and management professional, in the chat, put, "I'm here." Let's go to the next slide.
Program design and management - program design and management is something that is really the umbrella for everything that we do in monitoring. We start off in program design and management thinking about your actual program design. Why did you design the program the way that you did, is that design really indicative of the community that you serve? Are you doing a lot of things that strategically help you to meet their needs? The very first section of program design and management is how we really understand who you are as a program.
There's another piece of program design and management that's super - important, and I want everybody to pay attention, because this is data. In the last few years, since the Performance Standards - not this change, but since the very last change, the Office of Head Start has been super-focused on making sure that programs had data that helped them to improve. What I really want you to think about, as you're thinking about getting ready for your review is, how do you actually use your data?
It's one thing to have it, it's one thing to have Child Plus, or maybe Promise, or maybe you get reports from your managers - it's one thing to just physically have that data, but it's another thing to actually use the data. When our review team comes, you want to be able to talk about your trends, the things that are happening, progress that kids are making.
You want to be able to have a great conversation with the review team about how you use your data to make improvements, and how you understand that the goals that you've set out at the beginning of your five-year period are actually happening. I want people to really take some time, I slow down there all the time, because I want you to take some time in your mind to think about, how do you use data? In the chat, I want you to give me one example of how you use data in your program.
The other thing that we look at is program governance. Program governance is super important. We have two governing bodies, the Policy Council and the Governing Board, and we asked for those two teams to really work with you as a program to help you think about ways to better connect to your community, better connect to your parents, and better understand all of their needs. The governing body is super important. It's somebody who we want to make sure you connect with, that you're talking to, and that they're supporting the program, reach all of your illustrious goals.
The third thing that we look at under PDM is staffing, and staff member supports. Head Start programs don't go anywhere, they don't do anything. We can't do the work without this there. In order to have an excellent Head Start program, you have to have excellent staff. You have to have staff that understand the program, they have to understand the Head Start Performance Standards, they have to understand how they fit into all of that. They have to understand what the outcomes are that you want, and they have to understand your program goals.
In order to do that, you have to do several things to help them. You have to train them, you have to support them, and you have to actually monitor them on a regular basis to make sure that they're doing the things that you want them to do. In that section, the monitoring team actually looks at all of those things and sees, how does that happen in your program? Let's go to the next slide.
For program design, management and improvement, there are some things that you need. What is it that you need to have when we come on site? The first thing is you need to have your community assessment available. The community assessment helps us to understand why you made the plans that you did. Teams will take a look at that, see what's in your community assessment, and they'll begin to understand how this program is actually designed.
We also want to see your self-assessment. That helps us understand whether or not you take a look at what you're doing on an annual basis to see, in fact, is it working? You heard me talk a lot about data, we want to see your data. We want to make sure that is available and that the teams can see it, and we want to not just see the data, but we want to see how that data turns into continuous improvement.
Those two things go together. We want to see trends. We also want to see the data reports that you give to your Governing Body and Policy Council. We want to see your organizational chart. That helps us understand who does what in this program? We want to see your Standards of Conduct, because that helps us understand how does everybody know the rules on how to keep kids safe.
We want to see your wage study because we want to understand how are you thinking about wages, and how are those wages comparable to everybody else's in your community. We want to see your staff member retention data. It's really important for us to understand how you're keeping staff, whether or not they're staying aboard. We want to understand it. Let's go to the next slide.
When we come on site to do PDMI, there's a lot of things that you have to be ready for. The first thing is, we want to have a Management Team Kickoff Meeting. This meeting is not a presentation. We're not asking for you to make a PowerPoint presentation, have everybody stand up, tell us about your program, this is a conversation. This is the first opportunity for the team to actually get to meet you and your team.
We want you to bring whomever you want. We want everybody to talk. We want you to actually start to warm up and build a collaboration with the review team. The Management Team Kickoff Meeting is where you do that. You give us an opportunity to understand where everything is, where all your centers, your sites, who does what - who works on ERSEA? Who is the education manager? Who is the person that's doing health services?
We want to know who all of the people are so that we're talking to the right people about the right thing. Your time to do that is at the Management Team Kickoff Meeting. We then have a Head Start Director Data Tour - that's an important tour. What we're looking for in the Head Start Director is, we're looking to see how you get data from everybody in your program and how you use it to direct the program.
I'm the monitoring lead here, I get data, all kinds of data about Head Start programs, about findings, about - you cannot imagine the amount of data that I get here. But I use all that data to help me to actually direct what's happening in monitoring, it helps me change the protocol each year. It helps me think about what tools I need to have for the review team. It helps me answer questions to the grantees.
As the Head Start Director, you need to have a body of work of data that helps you direct the program. When we do the Head Start Data Tour, that's what the team is looking for. They're looking to see how do you, on a regular basis, use data to do your job.
We're also going to do a Human Resources Data Tour. The Human Resources Data Tour consists of two really important things - criminal background checks - we want to understand your process for criminal background checks and making sure that folks have it, and staff qualifications.
If you were the HR manager, you want to make sure that you have all of those things ready for us to review, and we want to understand how you use that data on a regular basis. We're going to ask to call to the Policy Council and the Governing Body. We're going to ask them for their data - what do you look at? How do you get information that actually helps you help the program? You can see that at the bottom of the screen that there's a lot of discussion around data.
The focus area to review is all about demonstration. When we go to Focus Area 1 talking about foundation, we want to find out what are you going to do? How might you do it? What are your strategies? The Focus Area 2 is all about demonstrating what you have done. The best way for you to demonstrate what you have done is to have data and documents that show the team what it is that you do on a regular basis.
We're going to talk to you, we want to have conversations, we want to have open conversations. We want you to feel really good about bragging about your program and tell us everything you do, and then we want you to back all of that up with your data. Let's move on to the next slide.
Let's talk a little bit about some highlights in each one of the sections. You heard me talk a lot about data - it should be a key or a clue-in for you to understand that data is super important, and that we're going to be looking at that and reviewing it across all of the content areas. Everybody in your program should have some data. They should be able to show us that data, and they should be able to show us how they regularly use that data.
I'm going to pause here, because a lot of people ask me all the time, well, should we have binders? Should we have a presentation on each thing? The answer is no. What we want to do when we're looking at your data is, we want to see how you use it every day. However, it is that you use that data every day, show that to the team.
If you regularly go in and check Child Plus to see how kids are doing, show that to the team. If you get a report weekly from your staff to show you how your different goals are actually coming to fruition, show that to the team. We want to see how you're using data to manage the program. This is super important. I've hammered that message down a whole bunch, what I want people - when we come out and we visit you, I'm expecting that all programs are going to have these beautiful conversations and these beautiful examples of how you're using data to improve your program over time. Let's go to the next slide.
Let's talk a little bit about program governance. Program governance has always been something that's super-important to the Office of Head Start. We want to make sure that you have Governing Bodies that really can support your program. We ask for the composition of a Governing Body to have a legal representative, a fiscal representative, and an education representative.
We ask for those people to be on your Governing Body because we have some expectation that you can utilize their outside expertise to help you as a program. But the only way to do that is if you actually train the Governing Bodies. The first thing is, the Governing Body, they need to understand, “What are my roles and responsibilities?” As a board member, as a Policy Council, “What am I supposed to do for this program?”
The first thing that you have to make sure they understand from the very beginning - what is their job? The review team comes in and they look to see, have you done that? Have you trained them? Do they know what to do? Do they understand their roles? Do they know based on the Head Start Act - What's the Governing Body supposed to do?
The review team also looks at, how do you collaborate with your board, and how do you collaborate with your Policy Council? When you have to make important decisions, when you have to spend funds, when you have to make key hires, how do you include the Policy Council and the board to make sure that those things are done with the community and the parents in mind?
Then the other thing that we do is, we actually try to understand whether or not the board and the Policy Council get enough information to do their jobs. We go to programs all the time, and for some reason, programs are not giving the board and the Policy Council any information.
They're not giving them the budget, they're not giving them the credit card expenditures, they're not giving them all the things that are required by the Performance Standards for them to actually get. Without those pieces of data, the board and Policy Council, they cannot do their jobs. We want you to know that you really need to focus in on thinking about, what is it that you're giving to your board and your Policy Council, and is it helping them to do the job that they're required to do? Let's go on to the next slide.
As I said, our top-cited funding - top-cited - if something is top-cited, we try to actually reduce it in the next year. The top-cited finding is that the board and the Governing Body do not get the required data shared with them. When we say, "required data," there's a lot of things that you have to share with your boards and your Policy Council - your annual FIT audit, your financial statement, your monthly credit card statements.
The progress that you're making with the children in your program - all kinds of things. I want you, when you get off this call, go back and look at the Act and Head Start Performance Standards and look at the list of all the things that you're supposed to share with your Governing Bodies. I think it's really important for you to refresh yourself on that and make sure that they're getting all of those things, so that when we come in and do the review, you don't wind up on our top-cited list. I know nobody wants to be there.
In the chat, name some of the things that the board and Policy Council are supposed to get as part of their data. In the chat, put in some of the things you think you're supposed to give to the board and Policy Council. I'm going to give you a hint - all of the clues are on this slide. In the chat, put down what do you think some of the things are that the board and the Governing Body are supposed to get as part of their data review? I hope everybody looked at that slide. Let's go to the next one.
The next thing that we look at in PDI is staffing and staff member supports. As I said earlier, staff is the key part of Head Start. When the managing team comes in, they're looking to see, one, what is the management system? Who manages what? Who's responsible for what? What are their qualifications? Do they really understand how to manage whatever it is, if they're managing health, if they're managing education, if they're managing fiscal?
They look to see whether or not these folks have the right qualifications to do their job. That's the first thing. The second thing they look at is, do they understand what they're supposed to be doing? Are their roles clear? Are their responsibilities clear? Do they know, oh, this is what I'm supposed to do, I'm supposed to do this. This is my job, I'm supposed to have this done, I understand. They look to see whether or not they understand the Performance Standards that are related to their roles, the things that they're supposed to do as it relates to performance standards.
They also look to see whether or not they understand the goals of the program, as is related to their rules. For example, if one of your goals is, we want to implement our curriculum to fidelity - does your education coordinator understand that? Do they know what fidelity means? If one of your goals is, we want to make sure that all of our teachers understand what "developmentally appropriate" practice is. Does your education coordinator know what that is, and are they able to share that information with all of the staff?
Once we understand everything about the management team, then the next thing that we want to understand is, how does that management team support staff? The review team goes in, and they actually talk with teachers, they talk with family service workers. They talk with everyone to see if they're supported, if they get trained, if they get coaching, if they have clear policies and procedures that they know how to follow.
This whole section is really about how you manage the staff in your program and how your managers are equipped to do that. During the monitoring review, we'll talk about all of those things, do data tours and conversations. We try to weave it together by not only asking the managers what's happening, but we ask the people who they manage. We actually go to the direct-line staff and say, "How is this going for you? Are you feeling supported and are you getting what you need in order to do your job really well?" Let's go to the next slide.
We also incorporate in monitoring; we don't just look for things that are not in compliance. We also try to look for things that we think are promising or strong practices. We think these are really important because the Head Start story is not just a story that's about things that are not in compliance.
The Head Start story is really about what programs are doing that's just absolutely wonderful. I will tell you, in my years and years of working for Head Start, I have been to some of the most fantastic Head Start programs around, there are just amazing Head Start programs everywhere. I'm so proud to be a part of this effort that we all do together.
When we do monitoring, we look for those strong practices. We look to see whether or not you have ongoing training, not just training that only happens at the beginning of the year. But is your training happening all the time? Are you always thinking about new ways to train your staff, new things to give them? New opportunities to help them learn?
We look to see whether or not you remove barriers to Policy Council -- like do you make sure that Policy Council can attend? Maybe sometimes you just make sure they have a snack or something, or they have childcare -- are you doing things that make sure that they can fully participate in the program? Are you encouraging them to do that?
Think of whether or not you're providing fair compensation - that helps people that really want to do a good job, or whether you're creating pathways to advancement. Everything on this screen are things that we're looking at as examples of very strong practices that we want to see programs do.
Some of them sometimes feel like the Performance Standards, but it's really when people have taken the Performance Standards, and they've used them in their community in ways that just make their program shine. At the end of the day, we want to see how you shine, how you make Head Start ultimately your own, and how you make it something that is really beneficial in your community. Strong practices help us to identify that. Let's go on to the next slide.
I think here, it's not my turn anymore. I hope it isn't, because you probably want to hear somebody else talk to you. My team usually puts this in the chat when it's time for me to introduce somebody else. If it is - can somebody put in the chat who I'm introducing? It helps me. Is it Milenia or Milena? This is a new person, so if I butcher your name, I apologize. Somebody should have practiced with me earlier. We will have another staff person come on from DLH, we'll let her introduce herself, and she's going to tell you about the Human Resources Data Tour.
Milenis Gonzalez: Thanks, Adia. Hi, everyone. My name is Milenis Gonzalez, and I'm the monitoring support lead at DLH. We want to spotlight some resources we've prepared to help your program understand what to expect during the FA2 review. The At-A-Glance tip sheet provide information about the topics and the data that will be covered in each of the FA2 review activities.
These are available on the Aligned Monitoring System 2.0 Virtual Expo. We encourage you to review them and to share them with your team members. As a reminder, one of the key events that addresses PDMI topics in the Human Resource Data Tour with the grant recipient's HR manager and HR director. This will focus on the program's approach to staff recruitment compensation, supervision, retention, professional growth, and other staff member supports. Additionally, during this event, the HR manager will be asked to review and share information on staff qualifications and the criminal background checks.
Here's another monitoring activity we want to remind you of, the Head Start Director Data Tour. In this event, reviewers will ask about the program's community needs assessment, the self-assessment, and other program data the Director collects and uses to inform strategic planning. Reviewers will also ask about the program's approach to supervision of staff, and how the Director engages with and supports the work of the Policy Council and the Governing Body.
There will be separate discussions with the Governing Body and the Policy Council, and similar topics will be covered in both discussions. Reviewers would like to hear about the composition of the Policy Council and the composition of the Governing Body. They'd also like to hear about the data they regularly review, and how the program supports them to carry out their roles. We'll also ask your program to help reviewers identify a convenient time for the Governing Body and Policy Council to meet with the review team during the course of the review week.
These activities can be conducted virtually if an in-person meeting is not available. Program staff members will not be required to join these discussions. We'll ask program staff members to ask how they engage with and support the Policy Council and Governing Body in other review activities. I know that was a lot of information, we're going to pause for a few questions. Tamara, what questions do we have?
Tamara: Actually, Courtney, I know you have some ready for us.
Courtney: I do. Adia, this first one is for you, and this is just kind of a general question about the FA2. We have some folks who would like to understand as much as you can share regarding the unannounced reviews, and what communication folks can expect to receive or to not receive if they had been selected for an unannounced review.
Adia: Wow, that's a really good question, Courtney. OK, I can do it. First of all, every - the Head Start Act requires that we do unannounced reviews. We took them off the books awhile during COVID, but they're back. For 10% of all the reviews that we do, they are unannounced. If we do 300 reviews, 30 of them are unannounced.
If you wind up being selected for an unannounced review, it's kind of tricky, right, because it's unannounced. You will know that you are going to have a review, because you get a global letter. That global letter tells you, hey, I'm going to get reviewed sometime this year. If you get a 45-day letter, that 45-day letter tells you, oh, this is your review date. But there's a small subset of programs that they never get that 45-day letter. The review team just appears one day. They come to your program, they have a letter in their hand, and they say, "We're here to do your review."
Now one of the ways that you can help us and help yourself is to make sure that your availability calendar is up to date. The worst thing, the thing that we don't want to have happen is that the review team shows up to your program and nobody's there. That's not a good idea.
What helps us to make sure that that doesn't happen is that your availability calendar tells us that these are the weeks and the times when you're available to be reviewed. You want to make sure that you fill out that calendar, that you have as many open weeks as you possibly can according to whatever the rules are for doing it.
I will tell you a secret: If you don't fill out your calendar, you automatically get an unannounced review. If you fill out your calendar, you have a better chance of getting an announced review. But for those people who don't fill out their calendar, or they don't fill out their calendar in time, we just go ahead, and we assign you an unannounced review. Hopefully that helps. Thanks for the question, Courtney.
Courtney: Thanks Adia. I've got another one for you. Does the credit card statement that is shared with the Policy Council and Governing Body, does that need to be the actual credit card statement, or could it be some kind of summary report of different categories that have had expenses? Or does it really need to be the actual credit card statement?
Adia: Hmm. You know what? I've got a special guest here who could answer that question really well. Nekeya O'Connor, we're going to bring you on early. This is a fiscal question.
Nekeya O'Connor: I knew when I heard about credit statement, I knew my name was going to be called. I just knew it. I think that that's a really good question, and here's the question that you have to ask yourself. If you did not get the credit card statement and you just got a summary of the expenses, how would you know that that's the total amount? How would you know that it was actually spent?
Now what could be helpful is that you can actually give a document that actually explains some of those expenses and categorizes them, but ideally, without the actual credit card statement, there is no way for the board or the Policy Council to actually know that that was actually the total and full amount that was spent within that month, on that card.
I want you to kind of think backwards, I would say, as far as the kind of documentation that you're giving the board and Policy Council so that they can understand the transparency that you want to show, but also make yourselves available to explain it to them so they can understand how the expenses are being conducted. Does that help, Adia?
Adia: It does. I knew I needed to call on you, Nekeya. That was a great answer. Nekeya is giving you two things; she's giving you the opportunity to think about it, and she's also telling you that the board and Policy Council have to get the actual credit card statements. You want to make sure they get them, but she gave you a great reason why, and I love that. Thank you, Nekeya.
Nekeya: No problem.
Adia: Well, those were our two questions for this section. If you have more questions, we're holding those questions. If we can, we'll try to answer them. Let's keep going.
Nekeya, it was just the perfect timing for me to call on you -
Nekeya: It seems like it.
Adia: Since we're going into the fiscal infrastructure section. You know, I'm so happy to have you on board. I want you to introduce yourself to the folks, and then I'm going to let you run away with this fiscal section.
Nekeya: Well, thanks Adia. It's really good to be here with you, too. It is such a pleasure to sit in this seat, not only because of the position [Inaudible] and different things like that, but actually getting to work with you again because I used to be a reviewer, and I was trained under you a long, long time ago. I am really glad to be here.
Hello, and good afternoon to all of you. For those of you who I have not had the pleasure of meeting, my name is Nekeya O'Connor, and I am the newly mentored Office of Head Start fiscal specialist. It is such a pleasure, and I am excited to be here with you today for a couple of reasons; one of which, as I shared, I used to actually be a reviewer, a fiscal reviewer some time ago. But the other is really because I also was in your seat.
I know what it feels like to receive that monitoring event, to have to prepare for that monitoring event as a CFO of a Head Start and an Early Head Start program. I know the anxieties that come with it, I know what it feel like when you're trying to get things together. My job today is to really kind of support you through that process, prepare you for that process and give you a little bit of that confidence boost so that you can rock your monitoring event wonderfully. We know that you guys are doing excellent in your programs, and the whole purpose of the FA2 is for you to demonstrate that.
One of the things that I like to say about fiscal is that we're the little team in the back. We're the ones behind the scenes, making sure that people are getting paid, which is also important, making sure that you have what you need in order to carry out your program and services.
Fiscal itself supports everything, and it is there in order for you to carry out those program deliveries, in order for you to make sure that those operations in your buildings and all of those things. It is very important that the infrastructure, the fiscal infrastructure of your program is solid. That is what we're going to talk about today, and I can't wait to dive right in. Let's click over to the next slide, because I want to talk to you a little bit about the fiscal performance areas and the performance measures.
Really, this is about the money, and it is one of those thing that I actually love to talk about, aside from the fact that I love money, and I'm sure some of you do, too. But as a former fiscal officer, I took pride in being able to talk about how we use the money to support our program in meeting high-quality child and family outcomes. What does it look like? In everything, no matter where you start, it starts with the budget. Adia told you guys earlier in the chat to talk about and share what are some of the ways in which you use data, and I was really excited to see that somebody put budgeting in there, because that's exactly what it is.
This particular performance area focuses on how you develop those budgets and manage them. How are you using that money? How are you making sure that there is an integrated and collaborative approach to the budget process, and making sure that it is actually responsive to the program goals and needs?
In order for you to do that, you have to have an actual comprehensive system that is in place. This is your opportunity to demonstrate that. What kind of fiscal system has your program established? Who is a part of that system? What are the different roles that exist? Are they qualified? Do they meet the requirements of the standards? How are the tasks assigned? Is there segregation of duties? Are you implementing strong internal controls? How do you plan the work?
How do you make sure that there's oversight for the fiscal, and how do you make sure that there is accuracy and allowability according to the Uniform Guidance, because we are all called to be proper stewards of those federal funds. You want to make sure that in particular to your system, you are implementing those strong internal controls so that you can demonstrate how you are doing your documentation, how you are preparing accurate financial records, and how you are ultimately reporting them.
Then lastly - and I love this - is this idea of the facilities and the equipment management. The question that you kind of have to ask yourself is, would I put my kids here? If I could, what does that look like now demonstrated? In this particular performance area, we're looking at, did you follow the process to engage in a real property activity, whether it is a purchase, a construction or major renovation.
If you had to go through a disposition of that facility, did you do it the right way? Do you have a process in place to be able to do that? How are you acquiring and disposing of equipment? Are you activating true depreciation methods in your books, and can demonstrate that?
All of these different areas focus on the risk around our quality environments, as is one of the five priorities for the Office of Head Start and making sure that in their associated program operations that you are maintaining insurance and mitigating those risks as much as possible. The real reason why the performance area focuses on these different three buckets is because the Office of Head Start really just wants to know how you are integrating it, and how you are being very intentional in those practices.
What I'd like to do is, I'd like to show you what that looks like under the methodology. I want to tell you about the different type of documentation that you would have to give in order to do that. If we could go to the next slide - in this is a part of your Fiscal Data Tour.
As Adia said, your job is going to be, show us how did you actually do it? We want to see the different types of documentation that your organization has in order to make sure they're in compliance with the standards and the Uniform Guidance in the act. For this part, we're going to ask our fiscal officers to definitely be a part as well as our Head Start director. Why? Because they're in charge.
Ultimately, you are the ones who are responsible for setting the tone for how this information in this system is integrated properly. During the transaction testing, during this tour and throughout the week, your fiscal reviewer is actually going to collect some samples of different types of transactions and review them for allowability. They're going to review them for accuracy, and they're going to review them for compliance to the Head Start requirements, and your fiscal policies and procedures.
In order for the reviewer to be able to do that in a timely manner, there's a couple of things that they're going to ask for from you ahead of time. It's important that the fiscal officer is definitely present and make themselves available. As Adia said, please make sure that you are filling out that schedule because you want to make sure that your person is available.
One of the very things very similar to an audit, but not an audit, that they're going to ask you for is your general ledger. They'd like to see your general ledger for the previous and the current program year. That is part of how they are going to look at your transactions and look to make sure that they can select the samples for the review. They're also going to ask you for a couple of other things to demonstrate how you're integrating these systems.
They want to review your records for the grant reporting to make sure that you are meeting the period of performance. They're going to look at anything that has most recently ended, and they're going to look at your current program year to make sure that things are doing well in compliance to the Uniform Guidance. In addition to that, they're going to ask you for some other documents and data that you can share to demonstrate your implementation of the requirements. That's going to include your budget to actual report.
Adia talked about the kind of information that should be provided to the board and Policy Council - that should be included. Your cost allocation plan: that's supposed to be reviewed and certified annually. Your procurement policies and procedures, any indirect cost documentation - they want to see your fiscal policies and procedures, any reporting forms that you've had, any recent transactions.
They're going to look at your equipment inventory, any insurance documentation that you have. All the things that you're using to track your non-federal match. If you have a facility that has federal interests, did you post your notice of federal interest in your facility? They're going to want to see that.
The other thing very similar to what Adia talked about earlier is that they're going to ask you for your personal records. They're going to look to see, how are you keeping time in your system? While it is that this list may be extensive, it's not exhaustive. There may be other documents that you might be using in your program in order to demonstrate your compliance with the requirements and implementation of the standards. It is up to you to be able to show that.
I want to talk a little bit about budget development, and the implementation and the oversight. This is one of the first performance areas, and it is something that is very critical because if you look at the way in which not only that the standards are written, but the monitoring protocol is written, the goal is to see how you are integrating all of your systems together to support high-quality child and family services and outcomes.
We want to hear about your program's success and planning and your annual budget - who is involved? What kind of data are you reviewing? How does your budget actually meet the needs of the program? I want to take a pause real quick, and I'm going to invite you into the chat - I want to see who do you include in your budget process? If you could in the chat for me, just tell me who's included in your budget process.
Are you only keeping it to your fiscal team, or are you including others? If you are, who are you including? OK, I see John saying the program coordinator. I'm seeing staff, parents, fiscal officer, the policy council - I love that. Your leadership team - great. Wonderful. I love that you guys are seeing and sharing all of these different people who - and officers that should be included in this budget process.
This is excellent, because again, your budget should be reflective of your program goals, the reviewer is actually going to ask you that. They're going to ask you how the program not only develops the budget, but how they review the actual spending against the plan budget over the course of the year. They're going to actually just show your budget versus actual reporting and discuss how you use that report to continuously oversee and manage the spending to make any needed adjustments. Great job, guys.
The next one that we're going to talk about is dovetailing from budgets. I want to talk a little bit about reporting. In the last session last week, when we were talking about the Focus Area 1 - next slide, please - we started to talk a little bit about reporting. This is actually one of the top-cited findings. We shared that with you last week on the Focus Area 1. It's not just enough to do the budgeting and the budget planning, but how, then, are you reporting to the Office of Head Start and demonstrating how you're using the funds?
As we look at the second performance area about the comprehensive financial management structure in the system, we want to highlight this particular area for you because it seems to pop up a lot. A lot of recipients have not been able to submit their required federal reports on time, due to different reasons. It could be succession planning, it could be not having access, it could be anything. But it is the program's responsibility within their fiscal system to ensure that you have the access, and you have a backup plan to make sure that you meet the requirements of the standards and the Uniform Guidance.
These concerns actually indicate that a grant recipient might not have that system that is in place, which is adequate enough to enable you to make sure that you are reporting that accurate information within a timely manner. This could include submitting the appropriate report, which is like the 425, which should be submitted through the PMS system, the Payment Management System, or the 429, which would be submitted through the online data collection portal within Grant Solutions.
The reviewers are actually going to ask you to show them this information, and how you submit it and making sure that it's accurate and submitted timely. They're also going to ask you to see your annual audit. They want to make sure that if you have subrecipients, or delegates if you're still using the old term, the reviewer is going to ask you to see the required reports on their behalf in order for you to submit those for your reporting to the federal government.
The good part - and I shared this last week and I'm going to share it again - is that the Office of Head Start has plenty of resources that are actually available for you right now on ECLKC that you can use to make sure that you are submitting your reports on time.
I'm going to ask the folks in the chat to drop two links for you that I think would actually be helpful: it's the Program Instruction 1703, and it's the Program Instruction 2401. Both of these links actually discuss the timelines and the requirements for federal reporting. On the SF - 425, which is the Federal Financial Report, the SF - 429 which is the Real Property Report, as well as the SF - 428, which is the Tangible Property Report.
Moving forward, all of this, ultimately, in the end, really speaks to your internal controls. Within your comprehensive financial management structure and system, it really is about how are you implementing strong internal controls according to the Uniform Guidance?
The reviewers are going to ask you about the different qualifications of your team to make sure that you are doing that. They're also going to make sure that you are providing ongoing professional development to your fiscal team. Yes, the fiscal team needs training too to make sure that they are staying on top of the regulations as required.
The reviewers are going to ask you about your policies and procedures - what do you have in place? How do you ensure that segregation of duties are implemented correctly? What type of authorization practices have you put in place? What kind of consistent oversight do you have for your fiscal recording and record keeping practices? Those are the types of things that you want to make sure you are implementing correctly.
The reviewers are going to want to learn a lot about how you are conducting your own internal monitoring. What kind of strategies did you put in place to make sure that you are in compliance with your own fiscal policies and procedures? Are you performing your bank reconciliations on time? Who's signing off on it? Who is making sure that the transactions are accurate, and they are appropriate, and they are allowable, according to the cost principles of the Uniform Guidance?
Then lastly through this topic, the reviewers are going to look at how you draw down your federal funds in order to support your Head Start program. They want to make sure that you are minimizing the time between the draws of the funds and the actual expense in order to make sure that you are in compliance with the regulations. Internal controls are very important. I know that my fiscal officers know this, I know that you probably, just like how I used to have a picture of the coastal framework in your office, please continue to do that.
Then the last area in which they are looking at for the reviewers is the idea of our quality environments, and that focuses on facilities and the equipment management systems. In this particular structure, they're looking to see, how do you, as a program purchase or acquire, use, manage and dispose of your facilities and equipment with these federal funds, according to the Uniform Guidance.
How are you conducting your equipment inventory to track and manage these different items that you have, your fixed assets, essentially? How are you assessing the risk around your facilities and your equipment within your program operations? Are you maintaining adequate insurance? Are you doing inventory on a regular basis? What do you have in place in order to make sure that your assets are protected? Remember that quality environments is one of the five priorities for the Office of Head Start, again, ask yourself, would I bring my kiddos to this program? If the answer is yes, now is your time to shine and to demonstrate that.
I've talked a lot about the different systems, the different ways in which the fiscal review is going to come into your program. We've talked about reporting and documentation, and a little bit about internal controls. All of this ultimately boils down to the different types of strong practices that hopefully you would be able to demonstrate in your program.
Thinking about what Adia said to you earlier, strong practice is an activity or a strategy that actually shows promise for long-term, sustainable impact. These are the different things that your program may actually do uniquely well and should be highlighted ultimately. We want to hear about that, because remember, while it is a compliance event, ultimately, it's your time to shine and demonstrate the things that you said that you do from your Focus Area 1.
There's a couple of examples that I can share with you that are on your screen about strong practices that are in place; one is about collaboration and ongoing communication not just within your fiscal team, but between fiscal and program staff. Ideally, how are you breaking down those siloes? How do you make sure that they don't exist?
The other strong practice is, looking at and examining the financial impact of your changing program needs or your goals, or changes within your program operations. You do a community assessment update - what does it mean, and how does it impact your program? How are you integrating that, and how is it reflected in your budget?
All of these different things are strong practices that you can begin to think about, and I really hope that you find that this information has been helpful, because ideally, we want to see just how well you're doing. If you need support, this is a great time for you to ask your TNTA Specialist or reach out to your regional office.
I really hope you find this helpful. I think that what I'd like to do now, I actually want to turn it over to Helen. Helen, I'm calling you a little bit, if you don't mind, because if you can for me, we've talked all of these different things. I'd love for you to share what does the actual transition testing look like?
Helen Budziak: Absolutely. Thanks, Nekeya. I'm going to talk a little bit about transaction testing. The fiscal reviewer will use a general ledger to choose transactions to test throughout the week. This is why it is so important to provide your general ledger on Day 1 of the review. Thanks in advance.
You should ensure you pass off a general ledger, inclusive of all federal Head Start grants being reviewed if your program has multiple grants for both the current and the previous program year. This is what the fiscal reviewer will use to complete the transaction testing that we'll outline next.
The types of things we will test for in transaction testing are covered on the slide. Overall, the fiscal reviewer will ensure that costs being charged to the Head Start grant are allowable. The fiscal reviewer will discuss the program's Fiscal Policy and Procedures and the Fiscal Data Tour, and then verify the information provided through transaction testing.
The fiscal reviewer will explore how the grant recipient ensures that costs are reasonable and necessary, how the grant recipient appropriately allocates costs across funding sources, if the program has multiple funding sources. The grant recipient's procurement process and how it is implemented, how administrative costs and non-federal match are tracked and accounted for, how the grant recipient identifies direct and indirect costs.
All of this information is a lot to take in, and we want to make sure your fiscal team is supported to engage productively in the FA2 review. We've prepared an At - A - Glance tip sheet for the Fiscal Data Tour that we encourage all fiscal teams to review. If your program will be receiving an FA2 review this year, this tip sheet can help your fiscal team understand what to expect during the review, and all the data and documentation that needs to be available.
Please visit the Aligned Monitoring System 2.0 Virtual Expo to check out all of the resources that are available to support your team. Again, that was a lot of information, and we see the questions coming in. Tamara, do you have a few ready for us today?
Tamara: I don't. But I know Courtney does. Are you ready with those questions, Courtney?
Courtney: That's true. All right, Nekeya, you were very popular.
Nekeya: Oh, OK, well, let me take a sip of my tea while you guys - go ahead. Go ahead, I'm ready.
Courtney: All right. A question about going back to the prior question on credit card statements. We have a lot of folks who are sharing that they have multiple programs, and they use the same credit card for multiple programs. Is it appropriate - how should they handle that? Can they black out some of the lines if it was an expense for a different program if not all of the information on the credit card statement seems appropriate to share with Policy Council or Governing Body?
Nekeya: I think that that's a great question. I would say this is where you get to demonstrate and ensure how you show your own transparency. Cost allocation is important. This also comes into play with cost allocation, but thinking about the documentation, if there's nothing to hide it shouldn't be a problem - flat out honest. But if you only want to show the Head Start expenses, then you can do whatever you feel is necessary for you. I would just make sure that in whatever it is that you share, you can back it up with your own policies and procedures, and you're able to show alignment with the requirements. That's it.
Courtney: Thank you, Nekeya. Let's see, another question is, can Nekeya explain some of the strategies and practices that help to demonstrate the process of budget planning?
Nekeya: Yeah, sure. I'm going to give you an example of when I was in the program. I think that that might help. One of the ways - our team was small; it was only three of us. One of the ways that we wanted to make sure that we included others in the budget process is that we created a template that the different directors could use, gave them a history - used the historical data from the prior year, or even looked at the average over within the grant period.
Within the five-year grant period, let's say that we were in budget period 4 - we would look at the historical information Figures 1 through 3, and provide it to the managers and say, “OK, here is what you've actually spent over the first three years of the grant.” We want to be able to make sure that your needs are met, let's start to talk about what your plans are, how are they different from what you have done in the past? Is it an extension or a project that you're continuing? I would make sure that that is documented.
Then I would work with those different division directors to actually put together a budget that made sense. Now, of course, everything doesn't always end up in the budget. You have your grant amount, and that's just what it is. But we try to make sure that they were included in the process so that the budget was reflective of the priorities.
If the education team had a priority of focusing on professional development, so that means that they would probably work with a local community center, or different things like that to use non-federal share to get some of their supplies so they can focus other monies on professional developing. I would say it's about having documented conversations. It's about using historical data that you can integrate in developing your new budget, then making sure that all of that is a part of the process.
Then when you're bringing it to the board and Policy Council, you are explaining it to them. It's demonstrated in the minutes; it's signed off properly. I would even do a budget training for the board and the Policy Council - all of that is a part of the budget process, and that's how you demonstrate it. Does that help? I hope it helps.
Courtney: Yes. Yeah. I hope it helps as well, certainly it's very insightful for me listening to you, Nekeya.
Nekeya: No problem.
Courtney. Let's see, I hope we're not jumping in between topics too quickly here, I'm going to share another one of the Q&A's.
Nekeya: OK.
Courtney. All right, regarding the Notice of Federal Interest - does that have to be posted on site? Or does it simply get filed? Is that a requirement for all properties that have federal interest? Or is it just related to some properties?
Nekeya: It is required for all facilities that have federal interest. There is a regulation, and I'll put it in the chat a little bit later since I don't have it up, but there is a requirement for the Notice of Federal Interest to be not only filed in the public record, but I believe it is also to be posted within the facility.
Courtney: Thank you. And then -
Nekeya: I will get the proper regulation and share it, because I don't want to tell you the wrong thing, but I believe that that's what it says.
Courtney: Nekeya, my last question for you, if you're ready.
Nekeya: I am almost ready. No, I'm kidding. Sure.
Courtney. Could you speak a little bit more to bank reconciliations? We've got a couple of questions about just sort of internal controls, resources for learning more about internal controls, resources for learning more about expectations around bank reconciliations. I wonder if you could speak to that.
Nekeya: Okay, as a part, just in general, I found the information about the Notice of Federal Interest for recording and posting it - so that is the link that I'm putting in the chat. You want to make sure that you do that. I'm just going to do that - quick pause. OK.
As a part of the internal controls, when you're thinking about your control activities, and you're also thinking about monitoring in general, it's a part of that internal control process, the coastal framework. I believe that Tamara White put it in the chat a little bit earlier - allows you different types of opportunities to be able to demonstrate that you have transparency in your numbers, that everything is actually posted, recorded and accurately reflected within your financials.
The reconciliation of your bank recs actually impact the final number that shows up on your balance sheet. When you're thinking about activities which you should put in place, bank reconciliation should be a part of your month and close process.
It's almost like the last step before you're closing out your financials, because it is ultimately telling you everything that has hit your bank account. You usually know if things aren't recorded, because there's generally a difference between what you have on your books and what the bank is reflecting. It's a part - that reconciliation process is actually a part of the, I would say, an internal monitoring process that recipients should implement in order to demonstrate transparency and effective internal controls. Is that helpful?
Courtney: Thank you, Nekeya.
Nekeya: That's all right.
Courtney: I was checking out the Q&A, and I couldn't get off mute in time.
Nekeya: It's OK. It's OK.
Courtney: If you have an appetite for one more, there is one more that we would like to share with you.
Nekeya: Sure! Sure.
Courtney: Could you talk for a moment - I think folks started to click on the program instructions that we shared a couple of minutes ago related to the federal reporting.
Nekeya: OK.
Courtney: Someone asked the question about whether there are any similar resources for federal recording requirements for some subrecipients, or delegate agencies.
Nekeya: OK. I don't want to - I wish I knew the regulations off the top of my head, but within the Uniform Guidance, there is a section about having subrecipients, where they're talking about subrecipients. Ultimately, subrecipients are held to the same standards as direct recipients of the grant. However, because our direct recipients are the ones that receive the federal funds, they are the ones that are responsible for reporting on their entire grant.
Subrecipients are not required to report on the funds that they receive from the direct recipient, they have to do that internal to their own financial reporting, but as far as filling out the Federal Financial Report, which is the SF - 425, or anything about their equipment and unused aggregated supplies, which is the SF - 428, or even a Federal Interest Property which is the SF - 429, it is the direct recipient that is responsible for reporting on the federal funds that they have received.
Courtney: Thank you, Nekeya!
Nekeya: You're welcome.
Courtney: Let's see, Adia, I think we still may have a couple of Q&A's that are trickling in.
Adia: OK.
Courtney: But as those continue, would you like to just share a little bit more information and resources with us, and maybe we can see if there's any additional Q&A's by the end of our slide presentation?
Adia: I sure can, I'm here to do that. Wow, thank you Nekeya O'Connor, it was wonderful having you on this presentation. We're so lucky to be able to have a fiscal expert back in our midst.
Nekeya: Thank you, Adia.
Adia: We really missed having that in this part of monitoring. We enjoy having you, I'm sure we'll be doing lots of these together.
Nekeya: I'm looking forward to it.
Adia: Let's talk about some addition - I know you are. Let's talk about some additional resources. All right, guys, additional resources. Here we go. First thing is first - remember I told you earlier today that the protocol is available for you. All you have to do is, you can go onto HeadStart.gov, formerly known as ECLKC, maybe presently known as ECLKC, and you can go there, and you can actually get the FY25 protocol.
It will have all of the purpose for monitoring, the methodology, many of the questions that we're going to ask. It's a great resource. I hope people go and get that document. The second thing that you want to do is, you want to go onto the Aligned Monitoring System 2.0 Virtual Expo. There you will find all the At - A - Glance documents that the team talked about today.
These documents are so helpful. You can use them with your teams. They're broken down by content area, you can get one for fiscal, you can get one for health services. You can get a At - A - Glance document to share and work with each member of your management team, and then the staff that they work with. Please, try the At - A - Glance documents. They are super-helpful. We designed them with you in mind.
We are coming down to the final of these information sessions. We did one yesterday, we did one today, and tomorrow, if you return, come back with your education coordinators and anybody who you want to hear about education and child development.
We're going to have a bunch of guest speakers there tomorrow; I think it's going to be exciting. We're also going to talk about a huge topic, health services. If you come back tomorrow, we're going to dig deep into those topics, and we hope that we will see you again and you'll share a little bit more of your time with us.
Finally, I want to say "thank you" to everyone who attended today. We do understand that Head Start is a tough job, and that you guys are out there doing all of this incredible work for so many people in your community, so many children. I joined Head Start quite a long time ago, and I stayed because I just really believe in what we do.
There's nothing that delights me more than to come out and see your programs in action. This year I hope to see some of you guys out there on the road. I hope to see your programs. All the ones that I have been to have been pretty doggone amazing, from the facilities to the teachers, to the managers, to the Head Start directors, to even sometimes what the kids are having for lunch.
I can't wait to come out and see you guys again. My teams will be out there. I just wish you a wonderful holiday season, and we'll be seeing you in the next couple of weeks, with next week starting, and then for the remainder of the new year. Have a great rest of your day, and I'm sure I’ll see some of you guys tomorrow. Thanks for coming!
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