Delaware Department of Education

**October 3-7, 2005**

**Scope of Review:** A team from the U.S. Department of Education's (ED)
Student Achievement and School Accountability (SASA) Programs Office
monitored the Delaware Department of Education (DDE) the week of October
3-7, 2005. This was a comprehensive review of DDE's administration of
the following programs authorized by the Elementary and Secondary
Education Act of 1965 (ESEA), as amended by the No Child Left Behind Act
(NCLB): Title I, Part A; Title I, Part B, Subpart 3; and Title I,

Part D. Also reviewed was Title X, Part C, Subtitle B, of NCLB (also
known as the McKinney-Vento Homeless Education Assistance Improvements
Act of 2001).

A representative of ED's Office of the Chief Financial Officer's (OCFO)
Internal

Control Evaluation Group participated with SASA staff in the review of
selected

fiduciary elements of the onsite Title I monitoring review. The Improper
Payments

Information Act of 2002 requires ED to conduct a risk assessment of the
Title I program

to determine if program funds are being delivered and administered in a
manner that

complies with the congressional appropriation. The OCFO representative
is working

with SASA staff in a cooperative effort on Title I monitoring reviews to
carry out the

required assessment. Findings related to this portion of the review are

presented under the Title I, Part A Fiduciary Indicators.

## In conducting this comprehensive review, the ED team carried out a number of major activities. In reviewing the Part A program, the ED team conducted an analysis of State assessments and State Accountability System Plans, reviewed the effectiveness of the instructional improvement and instructional support measures established by the State to benefit local educational agencies (LEAs) and schools, and reviewed compliance with fiscal and administrative oversight requirements required of the SEA. During the onsite week, the ED team visited two LEAs -- the Red Clay School District (RCSD) and the Christina School District (CSD) as well as Dover Academy, a charter LEA. The ED team interviewed administrative staff, interviewed principals and staff from 12 schools in the LEAs and met with two groups of parents. The ED team then interviewed DDE personnel to confirm data collected in each of the three monitoring indicator areas. 

In its review of the Title I, Part B, Subpart 3 Even Start program, the
ED team examined the State's request for proposals, State Even Start
guidance, State indicators of program quality, and the most recent
applications and local evaluations for local projects. During the onsite
review, the ED team visited two district sites: Kent Sussex and Poly
Teach Even Start. The ED team also interviewed the Delaware Even Start
State Coordinator to confirm information obtained at the local sites and
to discuss State administration issues.

In its review of the Title I, Part D program, the ED team examined the
State's application for funding, procedures and guidance for State
Agency (SA) applications under Subpart 1 and LEA applications under
Subpart 2, technical assistance provided to SAs and LEAs, the State's
oversight and monitoring plan and activities, SA and LEA subgrant plans
and local project evaluations. The ED team interviewed administrative,
program and teaching staff. The ED team also interviewed the SA -- the
Department of Services for Children Families and Youth (DSCF) as well as
the Title I, Part D State coordinator to confirm information obtained at
the local sites and discuss administration of the program.

In its review of the Education for Homeless Children and Youth program,
(Title X,

Part C, Subpart B), the ED team examined the State's procedures and
guidance for the identification, enrollment and retention of homeless
students, technical assistance provided to LEAs with and without
subgrants, the State's McKinney-Vento application, and LEA applications
for subgrants and local evaluations for projects in the Red Clay,
Christina and Capital School Districts and interviewed administrative
and program staff. The ED team also interviewed the DDE McKinney-Vento
State coordinator to confirm information obtained at the local sites and
discuss administration of the program.

**Previous Audit Findings:** None to report.

**Previous Monitoring Findings:** ED last reviewed Title I, Part A
programs in Delaware

in April of 1999 as part of a Federal integrated review initiative. One
compliance finding was identified as a result of that review, in the
area of the State's definition of adequate yearly progress (AYP), and
DDE subsequently provided documentation to ED sufficient to address the
issue. ED has not previously conducted a comprehensive review of the
Even Start, Neglected/Delinquent or Education for Homeless Children and
Youth programs in Delaware.

**[Overarching Requirement -- SEA Monitoring]{.underline}**

A State's ability to fully and effectively implement the requirements of
NCLB is directly related to the extent to which it is able to regularly
monitor it's LEAs and provide quality technical assistance based on
identified needs. This principle applies across all Federal programs
under NCLB.

Federal law does not specify the particular method or frequency with
which States must monitor their grantees, and States have a great deal
of flexibility in designing their monitoring systems. Whatever process
is used, it is expected that States have mechanisms in place sufficient
to ensure that they are able to collect and review critical
implementation data with the frequency and intensity required to ensure
effective (and fully compliant) programs under NCLB. Such a process
should promote quality instruction and lead to achievement of the
proficient or advanced level on State standards by all students.

## Met requirements. 

Title I, Part A Monitoring

**Summary of Monitoring Indicators**

+-------+-----------------------------------------+-------------+----+
| **    |                                         |             |    |
| Monit |                                         |             |    |
| oring |                                         |             |    |
| Area  |                                         |             |    |
| 1,    |                                         |             |    |
| Title |                                         |             |    |
| I,    |                                         |             |    |
| Part  |                                         |             |    |
| A:    |                                         |             |    |
| A     |                                         |             |    |
| ccoun |                                         |             |    |
| tabil |                                         |             |    |
| ity** |                                         |             |    |
+-------+-----------------------------------------+-------------+----+
| *     | **Description**                         | **Status**  | #  |
| *Indi |                                         |             | Pa |
| cator |                                         |             | ge |
| Num   |                                         |             |    |
| ber** |                                         |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.1   | The SEA has approved academic content   | Met         | N  |
|       | standards for all required subjects or  | r           | /A |
|       | an approved timeline for developing     | equirements |    |
|       | them.                                   |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.2   | The SEA has approved academic           | Met         | N  |
|       | achievement standards and alternate     | r           | /A |
|       | academic achievement standards in       | equirements |    |
|       | required subject areas and grades or an |             |    |
|       | approved timeline to create them.       |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.3   | The SEA has approved assessments and    | Met         | N  |
|       | alternate assessments in required       | r           | /A |
|       | subject areas and grades or an approved | equirements |    |
|       | timeline to create them.                |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.4   | Assessments should be used for purposes | Met         | N  |
|       | for which such assessments are valid    | r           | /A |
|       | and reliable, and be consistent with    | equirements |    |
|       | relevant, nationally recognized         |             |    |
|       | professional and technical standards    |             |    |
|       | (Section 1111(b)(3)(C)(iii)).           |             |    |
|       |                                         |             |    |
|       | Adequate yearly progress (AYP) shall be |             |    |
|       | defined by the State in a manner that   |             |    |
|       | is statistically valid and reliable     |             |    |
|       | (Section 1111(b)(2)(C)(ii)).            |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.5   | The SEA has implemented all required    | Met         | N  |
|       | components as identified in its         | r           | /A |
|       | accountability workbook.                | equirements |    |
|       |                                         |             |    |
|       | N.B. Report card requirements are       |             |    |
|       | addressed separately                    |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.6   | The SEA has published an annual report  | Finding     | 5  |
|       | card as required and an Annual Report   |             |    |
|       | to the Secretary (Section 1111(h)(1)).  |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.7   | The SEA has ensured that LEAs have      | Finding     | 5  |
|       | published annual report cards as        |             |    |
|       | required (Section 1111(h)(2)).          |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.8   | The SEA indicates how funds received    | Met         | N  |
|       | under Grants for State Assessments and  | r           | /A |
|       | related activities (Section 6111) will  | equirements |    |
|       | be or have been used to meet the        |             |    |
|       | 2005-06 and 2007-08 assessment          |             |    |
|       | requirements of NCLB.                   |             |    |
+-------+-----------------------------------------+-------------+----+
| 1.9   | The SEA ensures that LEAs meet all      | Met         | N  |
|       | requirements for identifying and        | r           | /A |
|       | assessing the English language          | equirements |    |
|       | proficiency of limited English          |             |    |
|       | proficient students.                    |             |    |
+-------+-----------------------------------------+-------------+----+

**Monitoring Area 1, Title I, Part A: Accountability**

Indicators 1.6 and 1.7 - The SEA has published an annual report card and
ensured that LEAs have published annual report cards as required.

**[Finding]{.underline}:** Reports do not include the percentage of
classes not taught by a highly qualified teacher disaggregated by high
and low poverty schools.

## [Citation]{.underline}: Section 1111(h)(1) and (2) of the ESEA requires annual report cards for States and local educational agencies. The report cards require information on teacher quality and student achievement results disaggregated by subgroups.

[Further action required]{.underline}: For the 2005-06 year, the DDE
must ensure that State and district report cards include all the
required elements, particularly the percentage of classes not taught by
highly qualified teachers disaggregated by high and low poverty schools
(top and bottom quartile of poverty in the State). The DDE must ensure
that LEA report cards also include information on the performance of the
LEA regarding whether it made AYP and whether it has been identified for
improvement, and school achievement data compared with LEA achievement.

# 

+-------+-----------------------------------------+-------------+-----+
| ## Mo |                                         |             |     |
| nitor |                                         |             |     |
| ing A |                                         |             |     |
| rea 2 |                                         |             |     |
| , Tit |                                         |             |     |
| le I, |                                         |             |     |
|  Part |                                         |             |     |
|  A: I |                                         |             |     |
| nstru |                                         |             |     |
| ction |                                         |             |     |
| al Su |                                         |             |     |
| pport |                                         |             |     |
+-------+-----------------------------------------+-------------+-----+
| *     | ## Description                          | ## Status   | #   |
| *Indi |                                         |             | # P |
| cator |                                         |             | age |
| Num   |                                         |             |     |
| ber** |                                         |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.1   | The SEA designs and implements          | Met         | N/A |
|       | procedures that ensure the hiring and   | r           |     |
|       | retention of qualified                  | equirements |     |
|       | paraprofessionals and ensure that       |             |     |
|       | parents are informed of educator        |             |     |
|       | credentials as required.                |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.2   | The SEA has established a statewide     | Met         | N/A |
|       | system of support that provides, or     | r           |     |
|       | provides for, technical assistance to   | equirements |     |
|       | LEAs and schools as required.           |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.3   | The SEA ensures that the LEA and        | Finding     | 7   |
|       | schools meet parental involvement       |             |     |
|       | requirements.                           |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.4   | The SEA ensures that schools and LEAs   | Finding     | 7   |
|       | identified for improvement, corrective  |             |     |
|       | action, or restructuring have met the   |             |     |
|       | requirements of being so identified.    |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.5   | The SEA ensures that requirements for   | Finding     | 8   |
|       | public school choice are met.           |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.6   | The SEA ensures that requirements for   | Finding     | 8   |
|       | the provision of supplementary          |             |     |
|       | educational services (SES) are met.     |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.7   | The SEA ensures that LEAs and schools   | Findings    | 9   |
|       | develop schoolwide programs that use    |             |     |
|       | the flexibility provided to them by law |             |     |
|       | to improve the academic achievement of  |             |     |
|       | all students in the school.             |             |     |
+-------+-----------------------------------------+-------------+-----+
| 2.8   | The SEA ensures that LEA targeted       | Finding     | 10  |
|       | assistance programs meet all            |             |     |
|       | requirements.                           |             |     |
+-------+-----------------------------------------+-------------+-----+

**Monitoring Area 2, Title I, Part A: Instructional Support**

[]{.mark}

**Indicator 2.3 -- The SEA ensures that the LEAs and schools meet
parental involvement requirements**.

**[Finding]{.underline}:** The DDE has not ensured that: (1) LEA parent
involvement policies contain the requirements in section 1118(a)(2), and
(2) Title I schools have parent involvement policies as required by
section 1118(b)(1). The written LEA parental involvement policies
submitted by both the CSD and the RCSD to ED do not include any required
components. Further, district staff from the RCSD indicated that each
Title I school uses the district's policy as the school's parental
involvement policy. If this is the case, these Title I schools do not
have written parental involvement policies that meet the Title I
requirements.

[Citation]{.underline}: Section 1118(h) of the ESEA require the SEA to
review the LEAs' parental involvement policies and practices to
determine if they meet the Title I parental involvement requirements.
Section 1118(a) of the ESEA requires each LEA that receives Title I,
Part A funds to develop a written parental involvement policy that
establishes the LEA's expectations for parental involvement. The policy
must be developed jointly with, and agreed upon by, the parents of
children participating in Title I, Part A programs and distributed to
parents of all children participating in Title I, Part A programs.
Sections 1118 (b) and (c) of the ESEA require that each school served
under Title I jointly develop with and distribute to parents of
participating children a written parental involvement policy agreed on
by the parents that describes the requirements of sections 1118(c)
through (f) of the ESEA. The school level policies are expected to be
different from the district parental involvement policies as these
policies must address the particular parental involvement needs of the
individual schools.

[Further action required]{.underline}: The DDE must ensure that all LEAs
receiving Title I funds have written district and individual school
parental involvement policies developed with parents of participating
children that contain the components required in sections 1118(a) and
(b) of the ESEA. The DDE must provide ED with copies of the parental
involvement policies developed consistent with the content and process
requirements in sections 1118(a) and (b) of the ESEA, for the CSD and
the RCSD and for each of the schools reviewed by the ED team.

Indicator 2.4 -- The SEA ensures that schools and LEAs identified for
improvement, corrective action, or restructuring have met the
requirements of being so identified.

**[Finding]{.underline}:** The DDE has not ensured that the school
improvement plans for the schools in need of improvement (1) provide an
assurance that such school set aside ten percent of their school
allocations for the purpose of providing to the school's teachers and
principal high quality professional development that directly addresses
the academic achievement problem that caused the school to be identified
for school improvement, and (2) specify how these funds will be used to
remove the school from school improvement status. School improvement
plans reviewed by ED lacked these two required components of the school
improvement plan.

[Citation]{.underline}: Section 1116(b)(3)(A)(iii) of the ESEA requires
that the school plan developed or revised by each school identified for
improvement, no later than three months after being so identified
provide an assurance that the school will spend not less than ten
percent of the funds made available to the school under section 1113 of
the ESEA for each fiscal year that the school is in school improvement
status for the purpose of providing to the school's teachers and
principal high-quality professional development. Section
1116(b)(3)(A)(iv) requires the school plan to specify how school
improvement funds made available under section 1113 will be used to
remove the school from school improvement status.

[Further action required]{.underline}: The DDE must provide technical
assistance to its LEAs and their schools on developing or revising
school improvement plans that meet the statutory requirements, in
particular the requirements under sections 1116(b)(3)(A)(iii) and (iv).
The DDE must require all its LEAs with schools in improvement to review
all school improvement plans to ensure they meet the required
components. Further, the DDE must submit to ED a copy of a school
improvement plan for one school in each of the one LEAs visited (a total
of two plans) as evidence that the DDE has worked with LEAs to ensure
that the school improvement plans for the schools in need of improvement
contain all required components.

5.  **-- The SEA ensures that requirements for public school choice are
    met.**

6.  **-- The SEA ensures that requirements for the provision of
    supplemental**

**educational services (SES) are met.**

**[Finding]{.underline}:** The DDE has not ensured that LEA letters
notifying parents of public school choice and SES contain all required
components. The RCSD and CSD choice and SES letters, while containing
some required information, did not contain an explanation of how parents
can be involved in addressing the academic issues that lead to the
school being identified for improvement.

[Citation]{.underline}: Section 1116(b)(6)(E) of the ESEA requires LEAs
to promptly provide to parents an explanation of the identification of
their child's school for school improvement that includes how parents
can be involved in addressing the academic achievement problem.

[Further action required]{.underline}: The DDE must provide LEAs with
guidance on the requirements of notices to parents of children attending
schools identified for improvement. The guidance must include all
required components listed in section 1116(b)(6), including the
requirement that an explanation of how parents can become involved in
addressing the academic achievement problems be included in these
notices. The DDE must provide a copy of that guidance to ED. In
addition, the DDE must incorporate into its monitoring process the
review of the content of LEA parent notification letters to ensure that
they contain the required information and submit to ED a copy of the
indicators that the DDE will use to monitor this requirement.

Indicator 2.7 -- The SEA ensures that LEAs and schools develop
schoolwide programs that use the flexibility provided to them by law to
improve the academic achievement of all students in the schools.

**[Finding]{.underline}:** The DDE has not ensured that LEAs require
their schools with schoolwide programs to include all ten schoolwide
required components in the school's combination school improvement and
schoolwide plan. While a seamless planning process that integrates the
requirements of the Title I school improvement plan and the schoolwide
plan into a single plan is a good educational strategy, the Title I
requirements for both plans must be included in the single plan. The
DDE's directions provided to LEAs on development of schoolwide plans
does not contain all ten required schoolwide components.

[Citation]{.underline}: Section 1114(b)(1) of the ESEA lists the ten
components that a comprehensive schoolwide plan for reforming the total
instructional program in the school must contain as required by section
1114(b)(2) of the ESEA.

[Further action required]{.underline}: The DDE must provide technical
assistance to its LEAs and their schools on developing or revising
schoolwide plans that meet the statutory requirements in section
1114(b)(1). The DDE must require all its LEAs with schools with
schoolwide programs to review all schoolwide/school improvement plans to
ensure they meet the required components for a schoolwide plan. Further,
the DDE must submit to ED a copy of a schoolwide/school improvement plan
for one Title I school in each of the LEAs visited (a total of two
plans) as evidence that the DDE has worked with LEAs to ensure that the
schoolwide plans contain all the required components.

Indicator 2.8 -- The SEA ensures that LEA targeted assistance programs
meets all requirements.

[Finding]{.underline}: The DDE has not ensured that LEAs with targeted
assistance schools comply with the Title I requirements for targeted
assistance schools and supplement not supplant. In RCSD, a Title I
teacher in targeted assistance school, who is paid 100 percent with
Title I funds, provides mathematics instruction to every student in
grades four through six. No other teacher provides mathematics
instruction to these students.

[Citation]{.underline}: Section 1115 of the ESEA requires that targeted
assistance schools use Title I, Part A funds only (1) for programs that
provide Title I services to those children identified for services as
required under section 1115(b), and (2) for Title I services that
supplement, and do not supplant, the services that would be provided in
the absence of Title I from non-Federal funds. Section 1120A(b), Federal
Funds to Supplement, Not Supplant, Non-Federal Funds, requires that an
LEA use Title I funds to supplement the funds made available from
non-Federal sources for the education of pupils participating in Title I
programs.

[Further action required]{.underline}: The DDE must provide technical
assistance to the RCSD and other LEAs with targeted assistance schools
that these schools may only provide Title I services to those children
identified to participate in accordance with section 1115(b), that Title
I services may not be provided to all children in the school or in a
particular grade, and that services provided Title I participants must
supplement the educational services that the targeted assistance school
must provide with non-Federal funds. The DDE must require the RCSD to
cease immediately providing Title I mathematical services to every
student in grades four through six in this school referenced in the
finding. Further, the DDE must provide documentation of these
activities, including meeting agenda and technical assistance materials.

+----------+---------------------------------------+-------------+-----+
| **Mo     |                                       |             |     |
| nitoring |                                       |             |     |
| Area 3,  |                                       |             |     |
| Title I, |                                       |             |     |
| Part A:  |                                       |             |     |
| F        |                                       |             |     |
| iduciary |                                       |             |     |
| Re       |                                       |             |     |
| sponsibi |                                       |             |     |
| lities** |                                       |             |     |
+----------+---------------------------------------+-------------+-----+
| **I      | # Description                         | **Status**  | **  |
| ndicator |                                       |             | Pag |
| Number** |                                       |             | e** |
+----------+---------------------------------------+-------------+-----+
| I        | SEA complies with---                  | Finding     | ##  |
| ndicator |                                       |             | ### |
| 3.1      | -   The procedures for adjusting      |             | ### |
|          |     ED-determined allocations         |             |  12 |
|          |     outlined in §§200.70 -- 200.75 of |             |     |
|          |     the regulations.                  |             |     |
|          |                                       |             |     |
|          | -   The procedures for reserving      |             |     |
|          |     funds for school improvement,     |             |     |
|          |     State administration, and (where  |             |     |
|          |     applicable) the State Academic    |             |     |
|          |     Achievement Awards program.       |             |     |
|          |                                       |             |     |
|          | -   The reallocation and carryover    |             |     |
|          |     provisions in section 1126(c) and |             |     |
|          |     1127 of Title I statute.          |             |     |
+----------+---------------------------------------+-------------+-----+
| I        | SEA ensures that its LEAs comply with | Met         | ### |
| ndicator | the provision for submitting an       | r           | ### |
| 3.2      | annual application to the SEA and     | equirements | ##  |
|          | revising LEA plans as necessary to    |             | N/A |
|          | reflect substantial changes in the    |             |     |
|          | direction of the program.             |             |     |
+----------+---------------------------------------+-------------+-----+
| I        | SEA ensures that all its LEAs comply  | Findings    | ##  |
| ndicator | with the requirements in section 1113 | and         | ### |
| 3.3      | of the Title I Statute and §§200.77   | Reco        | ### |
|          | and 200.78 of the regulations with    | mmendations |  12 |
|          | regard to (1) Reserving funds for the |             |     |
|          | various set-asides either required or |             |     |
|          | allowed under the statute, & (2)      |             |     |
|          | Allocating funds to eligible school   |             |     |
|          | attendance areas or schools in rank   |             |     |
|          | order of poverty based on the number  |             |     |
|          | of children from low-income families  |             |     |
|          | who reside in an eligible attendance  |             |     |
|          | area.                                 |             |     |
+----------+---------------------------------------+-------------+-----+
| I        | -   SEA complies with the maintenance | Finding     | ##  |
| ndicator |     of effort (MOE) provisions of     |             | ### |
| 3.4      |     Title I.                          |             | ### |
|          |                                       |             |  14 |
|          | -   SEA ensures that its LEAs comply  |             |     |
|          |     with the comparability provisions |             |     |
|          |     of Title I.                       |             |     |
|          |                                       |             |     |
|          | -   SEA ensures that Title I funds    |             |     |
|          |     are used only to supplement or    |             |     |
|          |     increase non-Federal sources used |             |     |
|          |     for the education of              |             |     |
|          |     participating children and do not |             |     |
|          |     supplant funds from non-Federal   |             |     |
|          |     sources.                          |             |     |
+----------+---------------------------------------+-------------+-----+
| I        | SEA ensures that its LEAs comply with | Finding     | 15  |
| ndicator | all the auditee responsibilities      |             |     |
| 3.5      | specified in Subpart C, Section       |             |     |
|          | 300(a) through (f) of OMB Circular    |             |     |
|          | A-133.                                |             |     |
+----------+---------------------------------------+-------------+-----+
| I        | SEA ensures that its LEAs comply with | Met         | ### |
| ndicator | requirements regarding services to    | r           | ### |
| 3.6      | eligible private school children,     | equirements | ##  |
|          | their teachers and families.          |             | N/A |
+----------+---------------------------------------+-------------+-----+
| I        | SEA complies with the requirement for | Met         | ### |
| ndicator | implementing a system for ensuring    | r           | ### |
| 3.7      | prompt resolution of complaints.      | equirements | ##  |
|          |                                       |             | N/A |
+----------+---------------------------------------+-------------+-----+
| I        | SEA complies with the requirement to  | Met         | ### |
| ndicator | establish a Committee of              | r           | ### |
| 3.8      | Practitioners and involves the        | equirements | ##  |
|          | committee in decision-making as       |             | N/A |
|          | required.                             |             |     |
+----------+---------------------------------------+-------------+-----+
| I        | Equipment and Real Property. The SEA  | Findings    | ##  |
| ndicator | and component LEA's establish         |             | ### |
| 3.9      | controls over the procurement,        |             | ### |
|          | recording, custody, use, and          |             |  15 |
|          | disposition of Title I equipment in   |             |     |
|          | accordance with the provisions of     |             |     |
|          | State policies and procedures, the No |             |     |
|          | Child Left Behind Act (NCLB), the     |             |     |
|          | Improper Payments Information Act,    |             |     |
|          | standards of internal control, and    |             |     |
|          | any other relevant standards,         |             |     |
|          | circulars, or legislative mandates.   |             |     |
+----------+---------------------------------------+-------------+-----+
| I        | SEA and LEAs comply with requirements | Findings    | ##  |
| ndicator | regarding procurement of goods and    |             | ### |
| 3.10     | services and the disbursement of      |             | ### |
|          | Title I funds in accordance with      |             |  16 |
|          | State policies and procedures, NCLB,  |             |     |
|          | the Improper Payments Information     |             |     |
|          | Act, and any other relative           |             |     |
|          | standards, circulars, or legislative  |             |     |
|          | mandates.                             |             |     |
+----------+---------------------------------------+-------------+-----+

**Monitoring Area 3, Title I Part A: Fiduciary responsibilities**

**Indicator** **3.1--- Within State Allocations, Reallocations, and
Carryover**

**[Finding]{.underline}:** The DDE did not reserve the required four
percent for school improvement. Discrepancies may have occurred when
trying to ensure that an under-funded charter school in school year 2004
received the correct amount in school year 2005.

[Citation]{.underline}**:** Section 1003(a) of the ESEA requires that
each State shall reserve 4 percent of the amount received under such
subpart for fiscal years 2004 through 2007, to carry out sections 1116
and 1117, including carrying out the State educational agency's
statewide system of technical assistance and support for local
educational agencies.

[Further action required]{.underline}: The DDE must provide ED with
spreadsheets for 2004-2005 and 2005-2006, which demonstrate that the
proper percentages for school improvement have been reserved.

# Indicator 3.3-- Within District Allocation Procedures

**[Finding (1)]{.underline}:** The DDE is requiring the125 percent rule
to be applied to the per pupil amount of funds in districts of poverty
greater than 35 percent. The state cannot require districts to implement
anything that is inconsistent with the law. Conversations with
administrators in RCSD and CSD revealed that the DDE supplied the
formula to be used and neither district was aware of any alternatives.

[Citation]{.underline}: Section 1113 (c)(1) of the ESEA requires that,
"a local educational agency shall allocate funds received under this
part to eligible school attendance areas or eligible schools, identified
under subsections (a) and (b), in rank order, on the basis of the total
number of children from low-income families in each area or school."

[Further action required]{.underline}: The DDE must revise directions in
the consolidated application plan to give LEAs the option to apply the
125 percent rule in cases where all schools served are at 35 percent or
greater; however, it must make clear that the law only requires that
schools served at 35 percent or greater allocate funds on the basis of
the total number of children from low-income families. The DDE must
provide evidence of the revised directions.

**[Finding (2)]{.underline}:** The DDE did not ensure that not less than
95 percent of the one percent of funds reserved for parental involvement
were distributed to Title I-funded schools. Further interviews with LEAs
revealed that although some administrators were aware of the law, this
was not a mandate of the State and guidance was not given by the State.
Discussions with the State also revealed that there is a
misunderstanding regarding the application of the parental involvement
reservation. In interviews with the DDE, the administrator said that
parental involvement funds allocated to the building could be used and
in most cases would be used to pay for the district administrator
regardless of whether the school's needs assessment required the use of
those funds to be used in other ways; however, this requirement would be
inconsistent with the intent of the law. The requiring of schools to use
parental involvement funds for district-wide activities was a finding in
the RCSD.

[Citation]{.underline}: Section 1118(a)(3)(C) of the ESEA requires not
less than 95 percent of the funds reserved under subparagraph (A) shall
be distributed to schools served under this part.

[Further action required]{.underline}: The DDE must provide guidance to
districts describing the reservation and distribution of parental
involvement funds under Title I, Part A. The DDE must provide evidence
that 1) guidance has been provided as to the appropriate procedures for
reserving funds for parental involvement, 2) evidence that the districts
that were visited are distributing not less than 95 percent of the one
percent of funds reserved for parental involvement to Title I schools,
and 3) evidence that the state has provided guidance to the proper use
of parental involvement funds that are allocated to school buildings,
emphasizing that the funds are available to the school for its use and
is not required to be used for district-wide activities.

**[Finding (3)]{.underline}:** The DDE is not ensuring that LEAs
calculate an equitable proportion of funds for children being served in
non-public schools for district-wide activities. District-wide
activities could include, but are not limited to parental involvement,
professional development, preschool programs (if the DDE considers
preschool to be part of elementary education), and summer school
programs.

An LEA must, after timely and meaningful consultation with appropriate
private school officials, provide Title I educational services to
private school children who live in participating public school
attendance areas and are identified by the LEA as at risk of failing.
These services must be equitable in comparison to services and benefits
provided to public school participants (section 1120(a) of the ESEA).

If an LEA reserves funds off the top of its Title I allocation for
district-wide instructional programs for public elementary and secondary
school students, the equitable services requirement applies.

[Citation]{.underline}: Section 200.64(a)(2)(i)(A) of the Title I
regulations requires that, if an LEA reserves funds for instructional
and related activities for public elementary or secondary school
students at the district level, the LEA must also provide from these
funds, as applicable, equitable services to eligible private school
children. The amount of funds available to provide equitable services
from the applicable reserved funds must be proportional to the number of
private school children from low-income families residing in
participating public school attendance areas.

[Further action required]{.underline}: The DDE must provide evidence
that guidance has been given to LEAs as to how to proportionately
calculate an equitable proportion of funds for children being served in
non-public schools.

**[Recommendation]{.underline}:** The different formulas used to
allocate funds to school buildings and the rationale for using one or
the other could be included in the consolidated application for a
reference.

**[Recommendation]{.underline}:** The formula to be used for calculating
the equitable proportion of funds for children being served in
non-public schools could be included in the consolidated application as
a reference.

**Indicator 3.4-- Fiscal Requirements**

**[Finding]{.underline}:** The DDE is not ensuring that districts are
determining comparability requirement of Title I. The districts
monitored did not develop procedures for determining comparability of
Title I funded schools to non-Title I funded schools. Further, the DDE
was not requiring districts to have in place procedures for determining
comparability and instead had districts provide a written assurance,
based on no computations, stating that it had established and
implemented a local educational agency-wide salary schedule and policy
to ensure equivalence among schools in the provision of curriculum
materials and instructional supplies.

As a requirement for receiving Title I, Part A funds, school districts
must ensure that their Title I schools are comparable with their
non-Title I schools each year. Title I schools must be comparable to
non-Title I schools using current year data.

[Citation]{.underline}: Section 1120A(c) of the ESEA states that an LEA
may receive Title I, Part A funds only if State and local funds are used
in participating Title I schools to provide services that, taken as a
whole, are at least comparable to services in non-Title I schools.

1120A(c)(3) Comparability of Services. Procedures and Records. ---Each
local

educational agency assisted under this part shall---

"(A) Develop procedures for compliance with this subsection; and

"(B) Maintain records that are updated biennially documenting such
agency's

compliance with this subsection.

[Further action required]{.underline}: The DDE must notify LEAs that
procedures determining comparability must be developed and records must
be maintained. These records must be monitored at least biennially by
the DDE. Also, the DDE must ensure that all districts receiving Title I
funding provide evidence that comparability has been met. The DDE must
provide ED with 1) correspondence to LEAs requiring that comparability
procedures be developed and determined, 2) current year comparability
calculations for the districts visited as a part of ED's onsite
monitoring review, and 3) a written assurance that compliance has been
met for all districts that receive Title I, Part A funds.

Indicator 3.5-- The SEA ensures that its LEAs are audited annually in
accordance with the Single Audit Act, and that all corrective actions
required through this process are fully implemented.

[Finding]{.underline}: The DDE did not provide guidance to the LEAs, in
the form of documented procedures, for the preparation of corrective
action plans and the timely completion of corrective actions to address
audit findings.

[Citation]{.underline}: Section 80.26(b)(3) of EDGAR requires that
"State and local governments . . . that provide Federal awards to a
subgrantee, which expends \$300,000 or more (or other amount as
specified by OMB) in Federal awards in a fiscal year...Ensure that
appropriate corrective action is taken within six months after receipt
of the audit report in instances of noncompliance with Federal laws and
regulations." OMB Circular A-133, Subpart D, section 400(d)(5) requires
a pass-through entity to "...ensure that the subrecipient takes
appropriate and timely corrective action."

[Further action required]{.underline}: The DDE must distribute written
procedures to the LEAs defining the form and content for corrective
action plans addressing findings in audits and monitoring reviews, and
requirements for formulating, monitoring, and completing timely
corrective action steps and submit to ED a copy of these procedures.

**Indicator 3.9 -- The SEA ensures that equipment and real property are
procured at a cost that is recognized as ordinary and the equipment and
real property are necessary for the performance of the Federal award.**

**[Finding (1)]{.underline}**: The DDE did not ensure that RCSD, and CSD
maintained adequate controls to account for procurement, location,
custody, and security of, equipment and did not maintain a
comprehensive, accurate, and current inventory of, equipment purchased
with Title I funds. The ED team was unable to locate a substantial
number of equipment items selected for inspection from inventory lists
provided at the RCSD and CSD offices. At RCSD and CSD the team was
unable to find 44% and 36% respectively of items selected for test.

## [Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State \[LEA\]...use, manage and dispose of equipment acquired under a grant by the State in accordance with State laws and procedures." Section 443 of the General Education Provisions Act requires each recipient of Federal funds, such as an LEA, to keep records, which fully disclose the amount and disposition of the funds, the total costs of the activity for which the funds are used...and such other records as will facilitate an effective financial or programmatic audit.

[Further action required]{.underline}: The DDE must ensure that all LEAs
implement and maintain adequate controls to account for the procurement,
location, custody, and security of equipment purchased with Title I
funds. The DDE must provide to ED a copy of a corrective action plan to
address this requirement inclusive of a follow-up plan to monitor
compliance.

**[Finding (2)]{.underline}:** Effective policies and procedures for the
physical inventory of equipment purchased with Title I funds do not
exist or are not being applied at RCSD and CSD.

## [Citation]{.underline}: Section 80.32(b) of EDGAR requires that "A State \[LEA\]...use, manage and dispose of equipment acquired under a grant by the State in accordance with State laws and procedures." 

## 

[Further action required]{.underline}: The DDE must distribute written
procedures to the RCSD and CSD defining a requirement to conduct an
annual physical inventory of equipment purchased with Title I funds and
the reconciliation of the physical inventory to the equipment recorded
in the LEA's property system and submit these procedures to ED.

**[Finding (3)]{.underline}:** The RCSD uses a \$25,000 threshold for
capitalizing equipment purchased with Title I funds.

## [Citation]{.underline}: OMB Circular A-87 (Revised 05/10/04), "Cost Principles for State, Local, and Indian Tribal Governments," defines "equipment" as an "...article of nonexpendable, tangible personal property having a useful life of more than one year and an acquisition cost which equals or exceeds the lesser of the capitalization level established by the governmental unit for financial statement purposes, or \$5,000."

[Further action required]{.underline}: The DDE must distribute written
procedures to the RCSD and CSD defining a requirement to capitalize
articles of nonexpendable, tangible personal property having a useful
life of more than one year and an acquisition cost which equals or
exceeds the lesser of the capitalization level established by the
governmental unit for financial statement purposes, or \$5,000 and
submit these procedures to ED.

Indicator 3.10 -- SEA and LEAs comply with requirements regarding
procurement of goods and services and the disbursement of Title I funds
in accordance with State policies and procedures, NCLB, the Improper
Payments Information Act, and any other relative standards, circulars,
or legislative mandates.

**[Finding (1)]{.underline}:** At RCSD and CSD, contractor invoices with
no description of services provided, no identification of location of
service, and no description of number of students served were approved.

## [Citation]{.underline}: When procuring property and services under a grant, Section 80.36(a) of EDGAR requires that "...a State \[LEA\]...follow the same policies and procedures it uses for procurement from its non-Federal funds." This section also requires that "The State \[LEA\]...ensure that every purchase order or other contract includes any clauses required by Federal statutes and executive orders and their implementing regulations."

[Further action required]{.underline}: The DDE must provide ED with
documentation that it has distributed procurement policy guidance to the
LEAs addressing the need for sufficient descriptions of goods or
services provided to be included in all vendor invoices. At a minimum,
the vendor invoice for professional services must include an adequate
description of the services performed, dates and location of service,
and, if applicable, number of students served. The information provided
should be consistent with the description of deliverables specified in
contracts and purchase orders.

**[Finding (2)]{.underline}:** At RCSD, an unapproved invoice for more
than \$2,500 was paid and no purchase order was provided for review.
RCSD staff stated there is a policy that requires purchase orders only
for procurements over \$2,500. A \$3,094.00 disbursement transaction on
April 15, paid to Advanced Student Services, had no supporting purchase
order and the vendor invoice was not approved for payment.

## [Citation]{.underline}: When procuring property and services under a grant, Section 80.36(a) of EDGAR requires that "...a State \[LEA\]...follow the same policies and procedures it uses for procurement from its non-Federal funds." This section also requires that "The State \[LEA\]...ensure that every purchase order or other contract includes any clauses required by Federal statutes and executive orders and their implementing regulations."

[Further action required]{.underline}: The DDE must implement a
corrective action plan to ensure the RCSD adheres to the procurement
procedures requiring the issuance of purchase orders and the review and
approval of vendor invoices by individuals with appropriate delegations
of authority. The DDE must provide a copy of the corrective action plan
to ED.

**[Finding (3)]{.underline}:** At CSD, 19 vendor invoices presented to
support disbursements had no notations indicating date of receipt or
approval signature. From the universe of 42 transactions selected for
test, the 19 invoices represented a 45% exception rate.

## [Citation]{.underline}: When procuring property and services under a grant, Section 80.36(a) of EDGAR requires that "...a State \[LEA\] . . . follow the same policies and procedures it uses for procurement from its non-Federal funds." This section also requires that "The State \[LEA\]...ensure that every purchase order or other contract includes any clauses required by Federal statutes and executive orders and their implementing regulations."

## 

[Further action required]{.underline}: The DDE must implement a
corrective action plan to ensure the CSD adheres to the procurement
procedures requiring the review and approval of vendor invoices by
individuals with appropriate delegations of authority and submit this
plan

to ED.

**[Finding (4)]{.underline}:** RCSD and CSD were unable to provide
copies of contracts with a provider of instructional services to support
disbursements selected for test. Documents provided were not in contract
format and did not have clearly defined deliverables.

## [Citation]{.underline}: When procuring property and services under a grant, Section 80.36(a) of EDGAR requires that "...a State \[LEA\]...follow the same policies and procedures it uses for procurement from its non-Federal funds." This section also requires that "The State \[LEA\]...ensure that every purchase order or other contract includes any clauses required by Federal statutes and executive orders and their implementing regulations." 

[Further action required]{.underline}: The DDE must provide ED with
documentation that it has distributed procurement policy guidance to the
LEAs addressing the form and content of contracts with service
providers. The guidance must specify the need to include specific
descriptions of the goods or services (deliverables) to be provided by
the contractor. At a minimum, the contract for professional services
must include a clear and specific description of the services to be
performed, the dates and location of services to be provided, and, if
applicable, number of students to be served.

**[Finding (5)]{.underline}:** CSD paid an invoice that included charges
for instructional services that were provided within CSD to students
from both CSD and RCSD. CSD did not require the service provider to bill
RCSD separately.

## [Citation]{.underline}: When procuring property and services under a grant, Section 80.36(a) of EDGAR requires that "...a State \[LEA\]...follow the same policies and procedures it uses for procurement from its non-Federal funds." 

## [Further action required]{.underline}: The DDE must provide ED with documentation that it has distributed policy guidance to the LEAs addressing the requirement for service providers to charge districts separately and directly for services provided to students from a district even when services are provided to the students while they are in a location outside the district.

**[Finding (6)]{.underline}:** CSD paid two invoices that had altered
invoice dates. The transactions processed on April 21, 2005, were
payments made on invoices received from Jonathan Dragon Inc. The
invoices with the altered dates also had no had no notations indicating
approval.

## [Citation]{.underline}: When procuring property and services under a grant, Section 80.36(a) of EDGAR requires that "...a State \[LEA\]...follow the same policies and procedures it uses for procurement from its non-Federal funds." 

## 

[Further action required]{.underline}: The DDE must implement a
corrective action plan to ensure the CSD adheres to the procurement
procedures requiring the review and approval of vendor invoices by
individuals with appropriate delegations of authority. The DDE must
provide a copy of the corrective action plan to ED.

### Other Fiscal Management Issues

**[Finding]{.underline}:** The DDE did not ensure that \$59,619.67 in
fiscal year (FY) 2004 school improvement funds was distributed prior to
expiring in FY 2005. During the review the ED team was advised that the
DDE policy was to apply a 'first in first out' policy for the carryover
of undistributed school improvement funds. Failure to apply the DDE
policy resulted in the undistributed school improvement funds expiring.

## [Citation]{.underline}: Section 80.20(a) of EDGAR requires "A State \[LEA\]...expand \[sic\] and account for grant funds in accordance with State laws and procedures for expending and accounting for its own funds." Section 80.23(a) states, "Where a funding period is specified, a grantee may charge to the award only costs resulting from obligations of the funding period unless carryover of unobligated balances is permitted, in which case the carryover balances may be charged for costs resulting from obligations of the subsequent funding period." Section 80.23(b) of EDGAR requires that a grantee "...liquidate all obligations incurred under the award not later than 90 days after the end of the funding period (or as specified in a program regulation) to coincide with the submission of the annual Financial Status Report (SF-269)." Section 80.23(b) of EDGAR also states, "The Federal agency may extend this deadline at the request of the grantee." 

[Further action required]{.underline}: The DDE must implement a
corrective action to ensure the timely distribution of undistributed
school improvement funds carried over to the next fiscal year and submit
that plan to ED.

# Summary of Title I, Part B, Subpart 3 (Even Start) Monitoring Indicators

# 

+-----------+-------------------------------------+-------------+-----+
| # Monitor |                                     |             |     |
| ing Area  |                                     |             |     |
| 1, Title  |                                     |             |     |
| I, Part B |                                     |             |     |
| , Subpart |                                     |             |     |
|  3: Accou |                                     |             |     |
| ntability |                                     |             |     |
+-----------+-------------------------------------+-------------+-----+
| **        | **Description**                     | # Status    | #   |
| Indicator |                                     |             |  Pa |
| Number**  |                                     |             | ge  |
+-----------+-------------------------------------+-------------+-----+
| Indicator | The SEA complies with the subgrant  | Finding     | 21  |
| 1.1       | award requirements.                 | Rec         |     |
|           |                                     | ommendation |     |
+-----------+-------------------------------------+-------------+-----+
| Indicator | The SEA requires applicants to      | Finding     | 21  |
| 1.2       | submit applications for subgrants   |             |     |
|           | with the necessary documentation.   |             |     |
+-----------+-------------------------------------+-------------+-----+
| Indicator | In making non-competitive           | Met         | N/A |
| 1.3       | continuation awards, the SEA        | r           |     |
|           | reviews the progress of each        | equirements |     |
|           | subgrantee in meeting the           |             |     |
|           | objectives of the program and       |             |     |
|           | evaluates the program based on the  |             |     |
|           | Indicators of Program Quality.      |             |     |
+-----------+-------------------------------------+-------------+-----+
| Indicator | The SEA refuses to award subgrant   | Met         | N/A |
| 1.4       | funds to an eligible entity if the  | r           |     |
|           | agency finds that the entity has    | equirements |     |
|           | not sufficiently improved the       |             |     |
|           | performance of the program, as      |             |     |
|           | evaluated based on the Indicators   |             |     |
|           | of Program Quality.                 |             |     |
+-----------+-------------------------------------+-------------+-----+
| Indicator | The SEA develops, based on the best | Met         | N/A |
| 1.5       | available research and evaluation   | r           |     |
|           | data, Indicators of Program Quality | equirements |     |
|           | for Even Start programs.            |             |     |
+-----------+-------------------------------------+-------------+-----+
| Indicator | The SEA uses the Indicators of      | Met         | N/A |
| 1.6       | Program Quality to monitor,         | r           |     |
|           | evaluate, and improve local         | equirements |     |
|           | programs within the State.          |             |     |
+-----------+-------------------------------------+-------------+-----+
| Indicator | The SEA conducts monitoring of its  | Finding     | 22  |
| 1.7       | subgrantees sufficient to ensure    |             |     |
|           | compliance with Even Start program  |             |     |
|           | requirements.                       |             |     |
+-----------+-------------------------------------+-------------+-----+
| Indicator | The SEA ensures that projects       | Finding     | 22  |
| 1.8       | provide for an independent local    |             |     |
|           | evaluation of the program that is   |             |     |
|           | used for program improvement.       |             |     |
+-----------+-------------------------------------+-------------+-----+

**Title I, Part B, Subpart 3 (Even Start)**

**Monitoring Area 1: Accountability**

Indicator 1.1 -- The SEA complies with the subgrant award requirements.

**[Finding]{.underline}:** The DDE is awarding Even Start subgrants to
LEAs in collaboration with non-profit organizations or to non-profit
organizations in collaboration with LEAs; the DDE is not awarding
subgrants to partnerships between one or more LEAs and one or more
non-profit organizations, which is now required by the Even Start
statute.

[Citation]{.underline}: Sections 1232(e)(1)(A) and (B) of the ESEA state
that an eligible entity for the purposes of Even Start is a partnership
composed of one or more local educational agencies, and one or more
non-profit community-based organizations, public agencies other than a
local educational agencies, institutions of higher education, or public
or private non-profit organizations other than local educational
agencies of demonstrated quality.

[Further action required]{.underline}: The DDE must require all Even
Start subgrantees to form partnerships with the appropriate composition
as required by the Statute and provide documentation demonstrating that
each partner has formally agreed to be part of the eligible entity. The
DDE must submit a list of eligible entities to ED that shows the
organizations included in the partnership, and must also correct its
guidance and request for proposals so that eligible entity is correctly
defined.

**[Recommendation]{.underline}:** The State should encourage all
subgrantees to develop a partnership agreement outlining the roles and
responsibilities of each of the organizations that compose the eligible
entity.

Indicator 1.2 -- The SEA requires applicants to submit applications for
subgrants with the necessary documentation.

**[Finding]{.underline}:** The DDE's application to applicants is
missing a statement of the methods that the project will use to: ensure
that it will serve families most in need of Even Start activities and
services, provide Even Start services to individuals with special needs
such as individuals with limited English proficiency and individuals
with disabilities, and encourage participants to remain in the program
for a time sufficient to meet the program\'s purpose

[Citation]{.underline}: Section 1237(b) of the ESEA states that an
application submitted to the SEA in request of an Even Start subgrant
includes the required documentation, and a plan of operation and
continuous improvement for the program that includes a description of
how the applicant project will meet the 15 required program elements, as
stated under Section 1235 of the ESEA.

[Further action required]{.underline}: The DDE must update its
application to include a statement of the methods that the project will
use to: ensure that it will serve families most in need of Even Start
activities and services, provide Even Start services to individuals with
special needs such as individuals with limited English proficiency and
individuals with disabilities, and encourage participants to remain in
the program for a time sufficient to meet the program\'s purpose. In
addition, the DDE must update the Lobbying Certification form in the
RFP. The DDE must submit the revised application to ED.

# Indicator 1.7 and 1.8 -- The SEA conducts monitoring of its subgrantees sufficient to ensure compliance with Even Start program requirements. The SEA ensures that projects provide for an independent local evaluation of the programs that is used for program improvement. 

**[Finding]{.underline}:** The DDE uses a peer review process that
includes State officials for the purposes of monitoring and ensuring
that local programs have an independent local evaluation. The process is
not sufficient for monitoring because it does not cover all critical
areas for compliance with NCLB. Furthermore, it is not sufficient as an
independent local evaluation as the State officials are not independent
of the administration of the local projects. The peer review process may
also not be sufficiently tailored for each local Even Start project to
ensure it meets the need of the projects for continuous improvement.

[Citation]{.underline}: Section 1235(15) of the ESEA requires that each
program assisted provide for an independent evaluation of the program to
be used for program improvement. Sections 76.700, 76.722, 76.730,
76.731, and 76.770 of the ESEA require States to provide oversight and
monitoring of subgrantees sufficient to ensure compliance with
applicable statutes and regulations.

[Further action required]{.underline}: The State must develop a plan for
monitoring that includes all requirements for Even Start projects under
NCLB and submit this plan to ED. The DDE must also ensure that all local
Even Start projects conduct an independent local evaluation and use the
evaluation results for program improvement. The DDE must provide
documentation that all Even Start projects have been informed of this
requirement and the actions it will take to monitor that evaluations are
completed.

+-----------+-------------------------------------+-------------+------+
| ## Monit  |                                     |             |      |
| oring Are |                                     |             |      |
| a 2, Titl |                                     |             |      |
| e I, Part |                                     |             |      |
|  B, Subpa |                                     |             |      |
| rt 3: Ins |                                     |             |      |
| tructiona |                                     |             |      |
| l Support |                                     |             |      |
+===========+=====================================+=============+======+
| **        | # Description                       | ### Status  | ##   |
| Indicator |                                     |             | Page |
| Number**  |                                     |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The SEA uses funds to provide       | Met         | N/A  |
| 2.1       | technical assistance to local       | r           |      |
|           | programs to improve the quality of  | equirements |      |
|           | Even Start family literacy          |             |      |
|           | services.                           |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | Each program assisted shall include | Finding     | 25   |
| 2.2       | the identification and recruitment  |             |      |
|           | of families most in need, and serve |             |      |
|           | those families.                     |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | Each program shall include          | Met         | N/A  |
| 2.3       | screening and preparation of        | r           |      |
|           | parents and enable those parents    | equirements |      |
|           | and children to participate fully   |             |      |
|           | in the activities and services      |             |      |
|           | provided.                           |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | Families are participating in all   | Finding     | 25   |
| 2.4       | four core instructional services.   |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | Each program shall be designed to   | Met         | N/A  |
| 2.5       | accommodate the participants' work  | r           |      |
|           | schedule and other                  | equirements |      |
|           | responsibilities, including the     |             |      |
|           | provision of support services, when |             |      |
|           | those services are unavailable from |             |      |
|           | other sources.                      |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | Each program shall include          | Finding     | 26   |
| 2.6       | high-quality, intensive             |             |      |
|           | instructional programs that promote |             |      |
|           | adult literacy and empower parents  |             |      |
|           | to support the educational growth   |             |      |
|           | of their children, and in           |             |      |
|           | preparation of children for success |             |      |
|           | in regular school programs.         |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | All instructional staff of the      | Finding     | 27   |
| 2.7       | program hired after enactment of    |             |      |
|           | the LIFT Act (December 21, 2000),   |             |      |
|           | whose salaries are paid in whole or |             |      |
|           | in part with Even Start funds, meet |             |      |
|           | the Even Start staff qualification  |             |      |
|           | requirements.                       |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | By December 21, 2004, a majority of | Met         | N/A  |
| 2.8       | the individuals providing academic  | r           |      |
|           | instruction shall have obtained an  | equirements |      |
|           | associate's, bachelors, or graduate |             |      |
|           | degree in a field related to early  |             |      |
|           | childhood education, elementary     |             |      |
|           | school or secondary school          |             |      |
|           | education, or adult education.      |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | By December 21, 2004, if            | Met         | N/A  |
| 2.9       | applicable, a majority of the       | r           |      |
|           | individuals providing academic      | equirements |      |
|           | instruction shall meet the          |             |      |
|           | qualifications established by the   |             |      |
|           | [State]{.underline} for early       |             |      |
|           | childhood education, elementary or  |             |      |
|           | secondary education, or adult       |             |      |
|           | education provided as part of an    |             |      |
|           | Even Start program or another       |             |      |
|           | family literacy program.            |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | By December 21, 2004, the person    | Met         | N/A  |
| 2.10      | responsible for administration of   | r           |      |
|           | family literacy services has        | equirements |      |
|           | received training in the operation  |             |      |
|           | of a family literacy program.       |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | By December 21, 2004,               | Met         | N/A  |
| 2.11      | paraprofessionals who provide       | r           |      |
|           | support for academic instruction    | equirements |      |
|           | have a secondary school diploma or  |             |      |
|           | its recognized equivalent.          |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local programs shall include    | Met         | N/A  |
| 2.12      | special training of staff,          | r           |      |
|           | including child-care workers, to    | equirements |      |
|           | develop the necessary skills to     |             |      |
|           | work with parents and young         |             |      |
|           | children.                           |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local programs shall provide    | Met         | N/A  |
| 2.13      | and monitor integrated              | r           |      |
|           | instructional services to           | equirements |      |
|           | participating parents and children  |             |      |
|           | through home-based programs.        |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local programs shall operate on | Finding     | 27   |
| 2.14      | a year-round basis, including the   |             |      |
|           | provision of some program services, |             |      |
|           | including instructional and         |             |      |
|           | enrichment services, during the     |             |      |
|           | summer months.                      |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local program shall be          | Met         | N/A  |
| 2.15      | coordinated with other relevant     | r           |      |
|           | programs under the Adult Education  | equirements |      |
|           | and Family Literacy Act, the        |             |      |
|           | Individuals with Disabilities Act,  |             |      |
|           | and Title I of the Workforce        |             |      |
|           | Investment Act of 1988, and the     |             |      |
|           | Head Start program, volunteer       |             |      |
|           | literacy programs, and other        |             |      |
|           | relevant programs.                  |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local programs shall use        | Met         | N/A  |
| 2.16      | instructional programs based on     | r           |      |
|           | scientifically based reading        | equirements |      |
|           | research for children and adults.   |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local program shall encourage   | Met         | N/A  |
| 2.17      | participating families to attend    | r           |      |
|           | regularly and to remain in the      | equirements |      |
|           | program a sufficient time to meet   |             |      |
|           | their program goals.                |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local programs shall use        | Met         | N/A  |
| 2.18      | reading-readiness activities for    | r           |      |
|           | preschool children based on         | equirements |      |
|           | scientifically based reading        |             |      |
|           | research.                           |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The local program shall, if         | Met         | N/A  |
| 2.19      | applicable, promote the continuity  | r           |      |
|           | of family literacy to ensure that   | equirements |      |
|           | individuals retain and improve      |             |      |
|           | their educational outcomes.         |             |      |
+-----------+-------------------------------------+-------------+------+

## Monitoring Area 2: Program Support

Indicator 2.2 - Funded programs shall include the identification and
recruitment of eligible families most in need and serve those families.

**[Finding]{.underline}:** The definition of participant eligibility and
participant continuing eligibility are incorrect in the State's RFP
Guidelines. The Guidelines had not been updated to reflect changes made
under NCLB. The process used, at both projects visited during the
review, for the identification and recruitment of families most in need
does not use income as one of the required criteria. At one site, only
83% of participating families are low-income.

[Citation]{.underline}: Section 1235(1) of the ESEA states that each
project must identify and recruit families most in need of Even Start
services, as indicated by a low level of income, a low level of adult
literacy or English language proficiency of the eligible parent or
parents, and other need-related indicators. It is important to note the
distinction between the larger subset of families that are "eligible"
for participation in Even Start services (as defined in section 1236 of
the ESEA) and those that a project is required to recruit and serve.
Even Start projects serve a small subset of the "eligible" population.
Specifically, section 1235(14)of the ESEA requires each project to serve
only those families most in need of Even Start activities and services.

[Further action required]{.underline}: The DDE must ensure that each
local project maintain documentation demonstrating that the families
served by Even Start are eligible for the program and have been
determined to be among those most in need of services. Each project must
also document what criteria were used to determine that the family was
low-income and that one or both parents were eligible for Even Start
because of educational need. In addition, local projects must establish
criteria to determine which eligible families are among those "most in
need" and be able to demonstrate that these are the families served by
the program. The DDE must update State's RFP Guidelines with the correct
definition of participant eligibility and participant continuing
eligibility.

**Indicator 2.4 - The SEA ensures that family members are participating
in all four core instructional services.**

**[Finding]{.underline}:** While one of the two projects visited had
verified participation by enrolled families in all four components, due
to the lost of data at the second project, we were unable to fully
assess this area. The project director in the second project indicated
that the data had been lost as a result of a computer system failure.
The project director also indicated that the children in the project
participated in a variety of early childhood services including center
and home- based care. She was not able to describe the instructional
program being provided in the home-based setting, and it was not clear
that all of the home-based services were sufficient to constitute early
childhood education.

[Citation]{.underline}: Section 1235(2) of the ESEA requires that
parents and children participate fully in the activities and services
provided by the Even Start program. Section 9101(20) of the ESEA defines
family literacy services as those services provided to participants on a
voluntary basis that are of sufficient intensity in terms of hours, and
of sufficient duration, to make sustainable changes in a family, and
that integrate interactive literacy activities between parents and their
children, training for parents regarding how to be the primary teacher
for their children and full partners in the education of their children,
parent literacy training that leads to economic self-sufficiency, and an
age-appropriate education to prepare children for success in school and
life experiences.

[Further action required]{.underline}: The DDE must develop, submit to
ED, and implement a plan to ensure that all enrolled family members
participate in all core instructional services in local Even Start
projects. Additionally, as part of the monitoring plan required under
Even Start Indicator 1.7, the DDE must include a method for monitoring
the extent to which subgrantees are ensuring that all families receiving
services participate in all four core instructional activities.

**Indicator 2.6 - Each program shall include high-quality, intensive
instructional programs.**

**[Finding]{.underline}:** The recommended number of instructional hours
was not being offered at either project visited. The projects visited
were particularly low in intensity in the parenting education and early
childhood components. Furthermore, the DDE's indicators of program
quality did not have the recommended number of instructional hours.

[Citation]{.underline}: Section 1235(4) of the ESEA requires that Even
Start programs include high-quality, intensive instructional programs
that promote adult literacy and empower parents to support the
educational growth of their children, developmentally appropriate early
childhood education services, and preparation of children for success in
regular school programs. Each of the required four core components
(adult literacy training, early childhood education, parenting
education, and interactive literacy activities) is considered an
instructional program.

[Further action required]{.underline}: The DDE must develop, submit to
ED, and implement an action plan to ensure that local projects provide
high quality and intensive instructional programs that promote adult
literacy and empower parents to support the educational growth of their
children, and in preparation of children for success in regular school
programs. The recommended minimum intensities for the four core
components are:

> Adult Education - 60 hours per month\
> Early Childhood Education (birth - 3) - 60 hours per month
>
> Early Childhood Education (3 - 4) - 65 hours per month
>
> Parenting Education and Interactive Literacy Activities between
> Parents and Children - 20 hours per month

In addition, the DDE must update the state indicators to reflect the
recommended minimum intensities for the four core components.

**Indicator 2.7 -- All instructional staff of the program hired after
the enactment of the LIFT Act (December 21, 2000), whose salaries are
paid in whole or in part with Even Start funds, meet the Even Start
staff qualification requirements.**

**[Finding]{.underline}:** At one site visited by the ED team, one early
childhood teacher paid with Even Start funds and hired since December
21, 2000, did not meet the qualifications for instructional staff. State
staff explained that this individual would, in the future, provide
support for instruction and would be supervised by qualified staff.

[Citation]{.underline}: Section 1235(5)(B) of the ESEA states, "all new
personnel hired to provide academic instruction (i) have obtained an
associate's, bachelors, or graduate degree in a field related to early
childhood education, elementary school or secondary school education, or
adult education; and (ii) if applicable, meet qualifications established
by the State for early childhood education, elementary school or
secondary school education, or adult education provided as part of an
Even Start program or another family literacy program."

[Further action required]{.underline}: The DDE must provide ED with
documentation demonstrating that the staff person lacking adequate
qualifications for Even Start instructional staff will no longer provide
instruction, but will work under the supervision of a qualified teacher
to support instruction for children in the program.

**Indicators 2.14 - Local programs shall use instructional programs
based on scientifically based reading research for children and
adults.**

**[Finding]{.underline}:** The instructional program at one site visited
by the ED team was not based on scientifically based reading research.
The project did not use a curriculum or systematic program of
instruction in the parenting education or early childhood components.

[Citation]{.underline}: Sections 1235 (10) and (12) of ESEA require
local Even Start projects to use instructional services based on
scientifically based reading research, including reading readiness
activities for preschool children based on scientifically based reading
research.

[Further action required]{.underline}: The DDE must provide technical
assistance to local projects and monitor them to ensure that
instructional programs and practices are based on scientific research,
including practices that promote language development and early reading
skills in the early childhood education component. The DDE must provide
ED with a description of the instructional program for the early
childhood and parenting education components with an explanation of the
scientific research on which the instructional components are based.

+-----------+-------------------------------------+-------------+------+
| # Moni    |                                     |             |      |
| toring Ar |                                     |             |      |
| ea 3, Tit |                                     |             |      |
| le I Part |                                     |             |      |
|  B, Subpa |                                     |             |      |
| rt 3: SEA |                                     |             |      |
|  Fiduciar |                                     |             |      |
| y Respons |                                     |             |      |
| ibilities |                                     |             |      |
+-----------+-------------------------------------+-------------+------+
| **        | # Description                       | ### Status  | ##   |
| Indicator |                                     |             | Page |
| Number**  |                                     |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The SEA complies with the           | Met         | N/A  |
| 3.1       | allocation requirements for State   | r           |      |
|           | administration and technical        | equirements |      |
|           | assistance and award of subgrants.  |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The SEA ensures that subgrantees    | Finding     | 29   |
| 3.2       | comply with statutory and           |             |      |
|           | regulatory requirements on uses of  |             |      |
|           | funds and matching.                 |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The SEA complies with the           | Finding     | 29   |
| 3.3       | cross-cutting maintenance of effort |             |      |
|           | provisions.                         |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The SEA ensures timely and          | Finding     | 29   |
| 3.4       | meaningful consultation with        |             |      |
|           | private school officials on how to  |             |      |
|           | provide Even Start services and     |             |      |
|           | benefits to eligible elementary and |             |      |
|           | secondary school students attending |             |      |
|           | non-public schools and their        |             |      |
|           | teachers or other instructional     |             |      |
|           | personnel, and local programs       |             |      |
|           | provide an appropriate amount of    |             |      |
|           | those services and benefits through |             |      |
|           | an eligible provider.               |             |      |
+-----------+-------------------------------------+-------------+------+
| Indicator | The SEA has a system for ensuring   | Met         | N/A  |
| 3.5       | fair and prompt resolution of       | r           |      |
|           | complaints and appropriate hearing  | equirements |      |
|           | procedures.                         |             |      |
+-----------+-------------------------------------+-------------+------+

**Title I, Part B, Subpart 3 (Even Start)**

# Area 3: SEA Fiduciary responsibilities

Indicator 3.2 -- The SEA ensures that subgrantees comply with
requirements on uses of funds and matching.

**[Finding]{.underline}:** The DDE's guidance regarding the statutory
match requirements is incorrect. Neither project visited had sufficient
match for programs operating beyond the 8^th^ year. Both projects had a
Federal share of 50 percent.

[Citation]{.underline}: Section 1234(b) of the ESEA states that the
Federal share for a local Even Start project may not exceed 35 percent
in any year beyond the eighth year of operation.

[Further action required]{.underline}: The DDE must update the State's
Guidelines to reflect the requirement for match under NCLB. The DDE must
also provide ED with revised budgets for the two projects visited
demonstrating a local share of at least 65 percent.

**Indicator 3.3 - The SEA complies with cross-cutting maintenance of
effort provisions.**

**[Finding]{.underline}:** State and local staff were not aware that
Even Start is now a covered program for maintenance of effort.

[Citation]{.underline}: Section 9521(b)(1) of the ESEA states that the
SEA shall reduce the amount of the allocation of funds under a covered
program in any fiscal year in the exact proportion by which a local
educational agency fails to meet the maintenance of effort requirement
in section 9521(a) by falling below 90 percent of the previous year's
combined fiscal effort per student or aggregate expenditures (using the
measure most favorable to the local agency).

[Further action required]{.underline}: The DDE must provide ED with
documentation demonstrating it has notified local projects about the
maintenance of effort provisions that apply to LEA partners in Even
Start subgrants, and that the State is including the Even Start program
among those to which the maintenance of effort requirement applies.

Indicator 3.4 - The SEA ensures timely and meaningful consultation and
provision of equitable services to private school children.

**[Finding]{.underline}:** Both projects reviewed by the ED team were
not aware that equitable participation of private school children is now
required and that they needed to provide for meaningful consultation
with private school officials

[Citation]{.underline}: Sections 9501-9506 of the ESEA require local
Even Start projects to meaningfully consult, on a timely basis, with
private school officials on how to provide Even Start services and
benefits to eligible elementary and secondary school students attending
non-public schools and their teachers or other instructional personnel,
and to provide an appropriate amount of those services and benefits
through an eligible provider.

# [Further action required]{.underline}: The DDE must develop and submit a plan for ensuring that all Even Start projects meaningfully consult with private school officials in order to provide equitable Even Start services and benefits to eligible private school students and their teachers or other educational personnel on an equitable basis. 

# Summary of Title I, Part D Monitoring Indicators

+------------+-----------------------------------+-------------+------+
| # Neglec   |                                   |             |      |
| ted, Delin |                                   |             |      |
| quent or A |                                   |             |      |
| t-Risk of  |                                   |             |      |
| Dropping-O |                                   |             |      |
| ut Program |                                   |             |      |
+------------+-----------------------------------+-------------+------+
| **I        | # Description                     | ### Status  | ##   |
| ndicator** |                                   |             | Page |
|            |                                   |             |      |
| **Number** |                                   |             |      |
+------------+-----------------------------------+-------------+------+
| Indicator  | The SEA has implemented all       | Met         | >    |
| 1.1        | required components as identified | r           |  N/A |
|            | in its Title I, Part D (N/D)      | equirements |      |
|            | plan.                             |             |      |
+------------+-----------------------------------+-------------+------+
| Indicator  | The SEA ensures that State Agency | Met         | >    |
| 1.2        | (SA) plans for services to        | r           |  N/A |
|            | eligible N/D students meet all    | equirements |      |
|            | requirements.                     |             |      |
+------------+-----------------------------------+-------------+------+
| Indicator  | The SEA ensures that Local        | Met         | >    |
| 1.3        | Educational Agency (LEA) plans    | r           |  N/A |
|            | for services to eligible N/D      | equirements |      |
|            | students meet all requirements.   |             |      |
+------------+-----------------------------------+-------------+------+
| Indicator  | The SEA ensures that              | Met         | >    |
| 2.1        | institutionwide programs          | r           |  N/A |
|            | developed by the SA under Subpart | equirements |      |
|            | 1 use the flexibility provided to |             |      |
|            | them by law to improve the        |             |      |
|            | academic achievement of all       |             |      |
|            | students in the school.           |             |      |
+------------+-----------------------------------+-------------+------+
| Indicator  | The SEA ensures each State agency | Met         | >    |
| 3.1        | has reserved not less than 15     | r           |  N/A |
|            | percent and not more than 30      | equirements |      |
|            | percent of the amount it receives |             |      |
|            | under Subpart 1 for transition    |             |      |
|            | services.                         |             |      |
+------------+-----------------------------------+-------------+------+
| Indicator  | The SEA conducts monitoring of    | Finding     | > 32 |
| 3.2        | its subgrantees sufficient to     |             |      |
|            | ensure compliance with Title I,   |             |      |
|            | Part D program requirements.      |             |      |
+------------+-----------------------------------+-------------+------+

**Indicator 3.2 - The SEA conducts monitoring of its subgrantees
sufficient to ensure compliance with Title I, Part D program
requirements.**

**[Finding]{.underline}:** The DDE does not have a comprehensive process
to monitor its State agency programs

[Citation]{.underline}: Section 1414(a)(2)(c)(i) of the ESEA requires
that each SEA plan must contain assurances that programs assisted under
Title I, Part D will be carried out in accordance with the State plan.
The SEA is required to ensure that the State agencies and local
educational agencies receiving Part D subgrants comply with all
applicable statutory and regulatory requirements. Additionally, Section
1426 requires the SEA to hold LEAs accountable for demonstrating student
progress in identified areas. Finally, Section 9304(a) of the ESEA
requires that the SEA ensures that programs authorized under the ESEA
are administered with all applicable statutes, regulations, program
plans and applications.

[Further action required]{.underline}: The DDE must provide a plan to ED
that indicates how it will implement a monitoring process that
determines whether the DSCYF State agency is complying with Part D
requirements, and carry out comprehensive monitoring to ensure that the
DSCYF State agency implement requirements.

**Summary of McKinney-Vento Homeless Education Program Monitoring
Indicators**

+------------+------------------------------------+------------+------+
| # M        |                                    |            |      |
| cKinney-Ve |                                    |            |      |
| nto Homele |                                    |            |      |
| ss Educati |                                    |            |      |
| on Program |                                    |            |      |
+------------+------------------------------------+------------+------+
| *          | # Description                      | ### Status | ##   |
| *Indicator |                                    |            | Page |
| Number**   |                                    |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA implements procedures to   | Met        | N/A  |
| 2.1        | address the identification,        | re         |      |
|            | enrollment and retention of        | quirements |      |
|            | homeless students.                 |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA provides, or provides for, | Met        | N/A  |
| 2.2        | technical assistance for LEAs to   | re         |      |
|            | ensure appropriate implementation  | quirements |      |
|            | of the statute.                    |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA ensures that LEA subgrant  | Met        | N/A  |
| 3.1        | plans for services to eligible     | re         |      |
|            | homeless students meet all         | quirements |      |
|            | requirements.                      |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA ensures that the LEA       | Finding    | 34   |
| 3.2        | complies with providing comparable |            |      |
|            | Title I, Part A services to        |            |      |
|            | homeless students attending        |            |      |
|            | non-Title I schools.               |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA has a system for ensuring  | Met        | N/A  |
| 3.3        | the prompt resolution of disputes. | re         |      |
|            |                                    | quirements |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA conducts monitoring of     | > Finding  | 34   |
| 3.4        | LEAs with and without subgrants,   |            |      |
|            | sufficient to ensure compliance    |            |      |
|            | with McKinney-Vento program        |            |      |
|            | requirements.                      |            |      |
+------------+------------------------------------+------------+------+

**Indicator 3.2 - The SEA ensures that the LEA complies with providing
comparable Title I, Part A services to homeless students attending
non-Title I schools.**

**[Finding]{.underline}:** The DDE did not ensure that LEAs consistently
reserved Title I funds to serve homeless students. ED staff found is
inconsistency across LEAs because different criteria were used.

[Citation]{.underline}: Section 1113(3)(c)(A) of the ESEA requires LEAs
to reserve funds to provide comparable services for homeless students
not attending Title I schools. Educationally related support services
may occur in schools, shelters or other locations where homeless
children reside.

[Further action required]{.underline}**:** The DDE must provide guidance
and technical assistance to LEAs on the requirement of the reservation
of Title I, Part A funds under section 1113(3)(c)(A) of the ESEA. ED
further requires the DDE to provide evidence that it has provided such
guidance and technical assistance and provide assurance that the SEA
will oversee the reservation of Part A funds for homeless students.

**Indicator 3.4 - The SEA conducts monitoring of LEAs with and without
subgrants, sufficient to ensure compliance with McKinney-Vento program
requirements.**

**[Finding]{.underline}:** The DDE does not have a comprehensive process
to monitor LEAs with and without McKinney-Vento subgrants.

[Citation]{.underline}: Section 722(g)(2) of the State plan for the
education of homeless children and youth requires the State to ensure
that local educational agencies in the State will comply with the
requirements of the McKinney-Vento statute. Section 80.40 of the EDGAR
further requires that the State, as the grantee, is responsible for
monitoring grant and subgrant-supported activities to assure compliance
with applicable Federal requirements.

[Further action required]{.underline}: The DDE must provide a plan to ED
that indicates how it will implement an onsite monitoring process that
determines whether LEAs are complying with McKinney-Vento requirements,
and carry out comprehensive monitoring to ensure that all LEAs implement
requirements.