Arizona Department of Education (ADE)

**February 25-29, 2008**

**Scope of Review:** A team from the U.S. Department of Education's (ED)
Student Achievement and School Accountability Programs (SASA) office
monitored the Arizona Department of Education (ADE) the week of February
25-29, 2008. This was a comprehensive review of the ADE'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 VII, Subtitle B of the McKinney-Vento
Homeless Assistance Act (Education for Homeless Children and Youth) as
amended by NCLB.

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 of the
State educational agency (SEA). During the onsite week, the ED team
visited three LEAs -- (Alhambra School District \[ASD\], Creighton
School District \[CSD\] and Precision Academy, \[an LEA charter
school\]), interviewed administrative staff, visited six schools in the
LEAs that have been identified for improvement, and conducted two parent
meetings. The ED team then interviewed the ADE 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 two local projects -- the Issac
Even Start program and Mesa Even Start program**.** During the onsite
review, the ED team visited these local projects and interviewed
administrative and instructional staff. The ED team also interviewed the
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 applications, technical
assistance provided to the SA, the State's oversight and monitoring plan
and activities, SA subgrant plans and evaluations for the Departments of
Adult and Juvenile Corrections (Subpart 1) and Queen Creek Unified
School District and Superior School Charter Academy (Subpart 2). The ED
team interviewed administrative, program and teaching staff. The ED team
also interviewed the ADE Title I, Part D State coordinator to confirm
information obtained at the State agency site 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 programs in Mesa
Unified School District and Peoria Unified School District. The ED team
also interviewed the ADE McKinney-Vento State coordinator to confirm
information obtained at the local site and discuss administration of the
program.

# Previous Audit Findings: 

# Audit Control Number - 09-05-68543

[05-107]{.underline}- The ADE did not follow its procedures for ensuring
compliance with 1127 of ESEA by failing to notify 2 of 14 LEAs that
their carryover balances appeared to exceed 15 percent of their initial
allocation. The ADE required each LEA to provide documentation, reviewed
the expenditures, and determined that neither LEA had carryover
exceeding the 15 percent limitation.

[05-103]{.underline} -- The ADE did not have adequate policies and
procedures in place to ensure that program recipients were meeting the
local matching requirement of 40 percent under Even Start, 1234 (b)(1)
of ESEA. The ADE required current projects with miscalculated local
shares to resubmit corrected local share budgets. The questioned costs
of \$559,988 was not sustained and no further corrective action was
required.

[05-104]{.underline} -- The ADE did not prepare the National Public
Education Financial Survey form accurately. ADE overstated expenditures
from operation of "noninstructional services food service -- other" and
included expenditures for property in determining the State's per-pupil
expenditures. NCES verified that corrected data was received from the
ADE.

# 

[05-102]{.underline} - The ADE did not document its site visits to the
Even Start subrecipients, Title I, Part B, Subpart 3, ESEA and did not
have procedures in place to examine subrecipient financial records. The
ADE implemented new procedures for subrecipient monitoring to ensure
compliance with EDGAR 80.40.

# Audit Control Number - 09-06-79574

[06-102]{.underline} -- The ADE used incorrect financial codes to
extract data from the LEAs' Annual Financial Reports (AFRs) resulting in
a misstatement of expenditures on the line item for instructional
salaries reported on the NPEFS form and an overstatement of the subtotal
funding of the Dropout Prevention Programs. The ADE's corrective action
responded to the audit and identified the School Finance Unit's
responsibility for implementing internal controls and strengthened the
three level review of the process by adding an internal control that
requires the Finance Director and the Deputy Superintendent to sign off
on the accuracy, completeness, and maintenance of SPPE data submissions
to NCES.

[06-107]{.underline}

ADE did not have edits in its Grants Management Enterprise System to
prohibit disbursing cash to subrecipients when they had cash on hand
from a prior year's project. The ADE's modified the Grants Management
Enterprise System to produce two additional reports that allow program
areas to monitor cash on hand at the LEA level for compliance with 1127
of ESEA.

**Previous Monitoring Findings:** ED last reviewed Title I programs in
the ADE during the week of April 25-29, 2005. As a result of that
review, ED identified compliance findings in the following areas for
Title I, Part A: (1) reliability of adequate yearly progress, (2)
appeals process for school improvement, (3) content of report cards, (4)
supplemental educational services, (5) schoolwide programs, (6) within
district allocations procedures, (7) maintenance of effort, (8) services
to eligible children attending private schools, (9) within State
allocation procedures (reservations) and (10) LEA applications. For
Title I, Part B (Even Start): (1) content of the ADE's request for
proposal and application, (2) local evaluations, and (3) Even Start
program goals. For Title I, Part D: (1) content of State agency
applications, (2) funding criteria, (3) uses of Part D funds, and (4)
compliance monitoring of Part D programs. For the McKinney-Vento
Homeless Education program: (1) reservations of funds for non-McKinney
Vento subgrants and (2) compliance monitoring. The ADE subsequently
provided ED with documentation sufficient to address all compliance
issues identified.

**[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 its 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 States 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.

**[Status:]{.underline}** Met requirements

Title I, Part A

**Summary of Monitoring Indicators**

+------------+-------------------------------------+-------------+----+
| **         |                                     |             |    |
| Monitoring |                                     |             |    |
| Area 1,    |                                     |             |    |
| Title I,   |                                     |             |    |
| Part A:    |                                     |             |    |
| Accoun     |                                     |             |    |
| tability** |                                     |             |    |
+------------+-------------------------------------+-------------+----+
| *          | **Description**                     | **Status**  | #  |
| *Indicator |                                     |             | Pa |
| Number**   |                                     |             | ge |
+------------+-------------------------------------+-------------+----+
| 1.1        | SEA has approved system of academic | Met         | N  |
|            | content standards, academic         | R           | /A |
|            | achievement standards and           | equirements |    |
|            | assessments (including alternate    |             |    |
|            | assessments) for all required       |             |    |
|            | subjects and grades, or has an      |             |    |
|            | approved timeline for developing    |             |    |
|            | them.                               |             |    |
+------------+-------------------------------------+-------------+----+
| 1.2        | The SEA has implemented all         | Rec         | 6  |
|            | required components as identified   | ommendation |    |
|            | in its accountability workbook.     |             |    |
+------------+-------------------------------------+-------------+----+
| 1.3        | The SEA has published an annual     | Finding     | 6  |
|            | report card as required and an      |             |    |
|            | Annual Report to the Secretary.     |             |    |
+------------+-------------------------------------+-------------+----+
| 1.4        | The SEA has ensured that LEAs have  | Finding     | 6  |
|            | published annual report cards as    |             |    |
|            | required.                           |             |    |
+------------+-------------------------------------+-------------+----+
| 1.5        | The SEA indicates how funds         | Met         | N  |
|            | received under Grants for State     | R           | /A |
|            | Assessments and related activities  | equirements |    |
|            | (Section 6111) will be or have been |             |    |
|            | used to meet the 2005-06 and        |             |    |
|            | 2007-08 assessment requirements of  |             |    |
|            | NCLB.                               |             |    |
+------------+-------------------------------------+-------------+----+
| 1.6        | The SEA ensures that LEAs meet all  | Met         | N  |
|            | requirements for identifying and    | R           | /A |
|            | assessing the academic achievement  | equirements |    |
|            | of limited English proficient       |             |    |
|            | students.                           |             |    |
+------------+-------------------------------------+-------------+----+

**Title I, Part A**

# Monitoring Area 1: Standards, Assessment and Accountability

**Indicator 1.2 --The SEA has implemented all required components as
identified in its accountability workbook.**

**[Recommendation]{.underline}:** Neither of the LEAs visited understood
ED's policy regarding when a student cannot be assessed due to a
significant medical emergency nor how to apply for this exemption. This
policy, sent to Chief State School Officers on May 19, 2004, entitled
"Calculating Participation Rates" allows States not to include a student
with a significant medical emergency in the participation rate
calculation when determining the percentage of students taking an
assessment. The ADE should provide LEAs guidance and training regarding
ED's medical emergency policy.

**Indicator 1.3 -- The SEA has published an annual report card as
required and an annual Report to the Secretary**

**[Finding:]{.underline}** In the Arizona State report card, one of the
required elements is missing --

\(1\) information in the aggregate on student achievement at each
proficiency level on the State academic assessments. The ADE reports
only a proficient and above level of achievement instead of proficient
and advanced performance levels.

[Citation:]{.underline} Section 1111(h)(1)(i) of the ESEA requires that
the State report cards include (i) information in the aggregate, on
achievement at each proficiency level on the State academic
assessments....

[Further action required:]{.underline} The ADE must submit to ED a
template of the State report card that includes the missing information.
When the State report card for the spring 2008 assessments is complete,
Arizona must submit the completed report card to ED.

**Indicator 1.4 -- The SEA has ensured that LEAs have published annual
report cards.**

**[Finding:]{.underline}** In the Arizona LEA reports, three of the
required elements are missing: (1) comparison of the actual achievement
levels of each group of students with the State's annual measurable
objectives, (2) aggregate information on the attendance rate used by
Arizona, and (3) graduate rates for secondary school students.

[Citation:]{.underline} Section 1111(h)(2) of the ESEA requires that the
LEA report cards include: (1) information that provides a comparison
between the actual achievement levels of each group of students and the
State's annual measurable objectives for each group of students on each
of the academic assessments, (2) aggregate information on any other
indicator used by the State to determine the adequate yearly progress of
students in achieving State academic achievement standards, and (3)
graduation rates for secondary school students.

[Further action required:]{.underline} The ADE must submit to ED a
template of the LEA report cards that includes the missing information.
When the LEA report cards for the spring 2008 assessments are completed,
the ADE must submit to ED a sample of completed report cards from the
three LEAs visited during the onsite review.

+------------+-------------------------------------+------------+-----+
| ##         |                                     |            |     |
|  Monitorin |                                     |            |     |
| g Area 2,  |                                     |            |     |
| Title I, P |                                     |            |     |
| art A: Pro |                                     |            |     |
| gram Impro |                                     |            |     |
| vement, Pa |                                     |            |     |
| rental Inv |                                     |            |     |
| olvement a |                                     |            |     |
| nd Options |                                     |            |     |
+------------+-------------------------------------+------------+-----+
| **I        | ## Description                      | ## Status  | #   |
| ndicator** |                                     |            | # P |
|            | ##                                  |            | age |
| **Number** |                                     |            |     |
+------------+-------------------------------------+------------+-----+
| 2.1        | The SEA has developed procedures to | Finding    | 9   |
|            | ensure the hiring and retention of  |            |     |
|            | qualified paraprofessionals.        |            |     |
+------------+-------------------------------------+------------+-----+
| 2.2        | The SEA has established a statewide | Met        | N/A |
|            | system of support that provides, or | Re         |     |
|            | provides for, technical assistance  | quirements |     |
|            | to LEAs and schools as required.    |            |     |
+------------+-------------------------------------+------------+-----+
| 2.3        | The SEA ensures that LEAs and       | Met        | N/A |
|            | schools meet parental involvement   | Re         |     |
|            | requirements.                       | quirements |     |
+------------+-------------------------------------+------------+-----+
| 2.4        | The SEA ensures that LEAs and       | Met        | N/A |
|            | schools identified for improvement, | Re         |     |
|            | corrective action, or restructuring | quirements |     |
|            | have met the requirements of being  |            |     |
|            | so identified.                      |            |     |
+------------+-------------------------------------+------------+-----+
| 2.5        | The SEA ensures that requirements   | Met        | 9   |
|            | for public school choice are met.   | Re         |     |
|            |                                     | quirements |     |
|            |                                     |            |     |
|            |                                     | Reco       |     |
|            |                                     | mmendation |     |
+------------+-------------------------------------+------------+-----+
| 2.6        | The SEA ensures that requirements   | Met        | N/A |
|            | for the provision of supplemental   | Re         |     |
|            | educational services (SES) are met. | quirements |     |
+------------+-------------------------------------+------------+-----+
| 2.7        | The SEA ensures that LEAs and       | Met        | N/A |
|            | schools develop schoolwide programs | Re         |     |
|            | that use the flexibility provided   | quirements |     |
|            | to them by the statute to improve   |            |     |
|            | the academic achievement of all     |            |     |
|            | students in the school.             |            |     |
+------------+-------------------------------------+------------+-----+
| 2.8        | The SEA ensures that LEA targeted   | Met        | N/A |
|            | assistance programs meet all        | Re         |     |
|            | requirements.                       | quirements |     |
+------------+-------------------------------------+------------+-----+

# Title I, Part A

# Monitoring Area 2: Program Improvement, Parental Involvement, and Options

Indicator 2.1 - The SEA has developed procedures to ensure the hiring
and retention of qualified paraprofessionals

**[Finding:]{.underline}** The ADE has not ensured that all LEAs have
met the requirement for highly qualified paraprofessionals in Title I
schools. In an interview with ASD officials, the ED team was informed
that the LEA's local academic assessment for paraprofessionals had not
been approved by the ADE. ASD was not sure if all paraprofessionals in
Title I schools met the qualifications for Highly Qualified.

[Citation:]{.underline} Section 1119 of the ESEA and sections 200.58 and
200.59 of the Title I regulations require that each local educational
agency receiving assistance shall ensure that all paraprofessionals
hired after the date of enactment of the No Child Left Behind Act of
2001 and working in a program supported with funds under this part shall
have --- (A) completed at least 2 years of study at an institution of
higher education; and (B) obtained an associate\'s (or higher) degree.
The law further requires that paraprofessionals meet a rigorous standard
of quality, and can demonstrate - through a formal State or local
academic assessment- knowledge of, and the ability to assist in
instructing, as appropriate- (A) reading/language arts, writing, and
mathematics; (B) reading readiness, writing readiness, and mathematics
readiness.

[Further action required:]{.underline} The ADE must provide guidelines
to ASD on which assessment to utilize for certifying paraprofessionals
in Title I Schools. A written timeline of compliance must be issued to
ASD with deadlines for the testing of all paraprofessionals in Title I
schools. The ADE must provide ED with written verification that all ASD

Title I paraprofessionals are certified and assurance that other
districts have been monitored and are in compliance with the statute.

**Indicator 2.5 - The SEA ensures that requirements for public school
choice are met.**

##### Recommendation: Precision Academy (LEA), a school/LEA identified for improvement is not offering choice to parents because it is itself a LEA and has no other schools to offer for choice. A letter to parents from the school, dated November 15, 2007 stated, "Precision High School is a single site school with no options for transfer."

The ADE should issue clear written guidelines to its Charter Schools
that state if all public schools within the LEA are identified for
school improvement, corrective action, or restructuring , the LEA- must
to the extent practicable, establish a cooperative agreement for a
transfer with one or more other LEAs in the area, or offer the student a
return to the students "home" public school. Any guidelines the state
writes should be consistent with sections 1112 and 1116 of the ESEA,
section 200.44 of the Title I regulations and the Department's 2004
document, "The Impact of the New Title I Requirements on Charter Schools
Non-Regulatory Guidance."

+----------+----------------------------------------+------------+-----+
| **Mo     |                                        |            |     |
| nitoring |                                        |            |     |
| Area 3,  |                                        |            |     |
| Title I, |                                        |            |     |
| Part A:  |                                        |            |     |
| F        |                                        |            |     |
| iduciary |                                        |            |     |
| Re       |                                        |            |     |
| sponsibi |                                        |            |     |
| lities** |                                        |            |     |
+----------+----------------------------------------+------------+-----+
| **I      | # Description                          | **Status** | **  |
| ndicator |                                        |            | Pag |
| Number** |                                        |            | e** |
+----------+----------------------------------------+------------+-----+
| 3.1      | SEA complies with---                   | Met        | ### |
|          |                                        | Re         | ### |
|          | -   The procedures for adjusting       | quirements | ##  |
|          |     ED-determined allocations outlined |            | N/A |
|          |     in sections 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.           |            |     |
+----------+----------------------------------------+------------+-----+
| 3.2      | SEA ensures that its LEAs comply with  | Met        | ### |
|          | the provision for submitting an annual | Re         | ### |
|          | application to the SEA and revising    | quirements | ##  |
|          | LEA plans as necessary to reflect      |            | N/A |
|          | substantial changes in the direction   |            |     |
|          | of the program.                        |            |     |
+----------+----------------------------------------+------------+-----+
| 3.3      | SEA ensures that all its LEAs comply   | Met        | ### |
|          | with the requirements in section 1113  | Re         | ### |
|          | of the Title I Statute and sections    | quirements | ##  |
|          | 200.77 and 200.78 of the regulations   |            |     |
|          | with regard to (1) Reserving funds for | Reco       | 12  |
|          | the various set-asides either required | mmendation |     |
|          | or allowed under the statute, and (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.                                  |            |     |
+----------+----------------------------------------+------------+-----+
| 3.4      | -   SEA complies with the maintenance  | Met        | ### |
|          |     of effort (MOE) provisions of      | Re         | ### |
|          |     Title I.                           | quirements | ##  |
|          |                                        |            | N/A |
|          | -   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.          |            |     |
+----------+----------------------------------------+------------+-----+
| 3.5      | SEA ensures that its LEAs comply with  | Met        | N/A |
|          | all the auditee responsibilities       | Re         |     |
|          | specified in Subpart C, section 300(a) | quirements |     |
|          | through (f) of OMB Circular A-133.     |            |     |
+----------+----------------------------------------+------------+-----+
| 3.6      | SEA ensures that its LEAs comply with  | Met        | ##  |
|          | requirements regarding services to     | Re         | ### |
|          | eligible private school children,      | quirements | ### |
|          | their teachers and families.           |            |  12 |
|          |                                        | Recom      |     |
|          |                                        | mendations |     |
+----------+----------------------------------------+------------+-----+
| 3.7      | SEA complies with the requirement for  | Met        | ### |
|          | implementing a system for ensuring     | Re         | ### |
|          | prompt resolution of complaints.       | quirements | ##  |
|          |                                        |            | N/A |
+----------+----------------------------------------+------------+-----+
| 3.8      | SEA complies with the requirement to   | Met        | ### |
|          | establish a Committee of Practitioners | Re         | ### |
|          | and involves the committee in          | quirements | ##  |
|          | decision-making as required.           |            | N/A |
+----------+----------------------------------------+------------+-----+

**Title I, Part A**

**Monitoring Area 3: Fiduciary Responsibilities**

**Indicator 3.3 -- Within District Allocation Procedures. The LEA
complies with the requirements in sections 1113, 1116, & 1118 of the
ESEA and sections 200.77 and 200.78 of the Title I regulations with
regard to: (1) Reserving funds for the various set-asides either
required or allowed under the statute, and (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.**

[**Recommendation**:]{.underline} During the onsite review, one LEA was
in the process of reallocating funds for summer activities that had
previously been budgeted for SES and Choice activities. The initial
reallocation proposed did not account for equitable services for private
school participants; however, the LEA subsequently adjusted the
reallocation in order to ensure equitable services. In discussions with
the ED team, the Deputy Associate Superintendent and the ADE's Title I
Director agreed to modify the forms as well as the instructions for the
consolidated application and budget amendments to account for and ensure
equitable services in the reallocation of funds. The ED team recommends
that the ADE implement the agreed-upon procedures to include assurances
that: (1) The ADE must ensure that an approved budget amendment has been
properly prepared and that the LEA has reallocated funds in compliance
with the provisions for equitable services for private school
participants. (2) The ADE should continue to revise the budget amendment
format and instructions for the consolidated application, and (3) the
ADE should ensure updated directions for subgrants are issued to LEAs.

**Indicator 3.6 -- Services to Private School Children.**

**[Recommendation (1):]{.underline}** The ED team recommends that the
ADE provide guidance to Washington Elementary School District (WESD) as
the Fiscal Agent for the Intergovernmental Agreement for Title I
Services to Private School Children regarding:

-   [Carryover -]{.underline} Currently, the agreement states that any
    funds not expended by the Fiscal Agent at the end of each fiscal
    year will be carried over to the following fiscal year. It is
    possible under this arrangement for some participating LEAs to be in
    violation of the 15 percent carryover limitation. Since these
    carryover funds are funds that each LEA transferred to WESD, as the
    Fiscal Agent; and not originally WESD's funds, WESD should not
    include any of these funds when calculating the percentage of
    carryover. Instead, ADE should assist WESD in determining each
    participating LEA's proportionate share of the carryover funds,
    which must be included in that LEA's total carryover calculations.
    Each LEA could either retain these funds for allowable uses or
    transfer these funds back to WESD for the purpose of providing
    equitable services to private school children, their parents and
    teachers the following school year.

-   [Agreement -]{.underline} The Intergovernmental Agreement should
    clarify that the LEAs transfer all responsibilities for providing
    equitable services under Section 1120 of the Title I statute to the
    Fiscal Agent.

-   [Deadline for Receiving Funds]{.underline} -- The Intergovernmental
    Agreement should describe the actions that the Fiscal Agent will
    take if payment from a participating LEA is not received within a
    responsible time.

**[Recommendation (2):]{.underline}** The ED team recommends that the
ADE consider having the [title]{.underline} of the Intergovernmental
Agreement amended so it doesn't infer that private schools get Title I
services, for example, "Intergovernmental Agreement for Title I Services
to Private School Children".

**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  |
+-----------+-------------------------------------+-------------+-----+
| 1.1       | The SEA complies with the subgrant  | Met         | N/A |
|           | award requirements.                 | R           |     |
|           |                                     | equirements |     |
+-----------+-------------------------------------+-------------+-----+
| 1.2       | The SEA requires applicants to      | Met         | N/A |
|           | submit applications for subgrants   | R           |     |
|           | with the necessary documentation.   | equirements |     |
+-----------+-------------------------------------+-------------+-----+
| 1.3       | In making non-competitive           | Finding     | 15  |
|           | continuation awards, the SEA        |             |     |
|           | reviews the progress of each        |             |     |
|           | subgrantee in meeting the           |             |     |
|           | objectives of the program and       |             |     |
|           | evaluates the program based on the  |             |     |
|           | indicators of program quality, and  |             |     |
|           | refuses to award subgrant funds to  |             |     |
|           | an eligible entity if the agency    |             |     |
|           | finds that the entity has not       |             |     |
|           | sufficiently improved the           |             |     |
|           | performance of the program.         |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.4       | The SEA develops indicators of      | Met         | N/A |
|           | program quality for Even Start      | R           |     |
|           | programs, and uses the Indicators   | equirements |     |
|           | to monitor, evaluate, and improve   |             |     |
|           | projects within the State.          |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.5       | The SEA ensures that projects       | Met         | N/A |
|           | provide for an independent local    | R           |     |
|           | evaluation of the program that is   | equirements |     |
|           | used for program improvement.       |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.6       | The SEA reports to ED in a timely   | Met         | N/A |
|           | manner using the required           | R           |     |
|           | performance measures and ensures    | equirements |     |
|           | that local projects are assessing   |             |     |
|           | the progress of their participants  |             |     |
|           | using those measures.               |             |     |
+-----------+-------------------------------------+-------------+-----+
| 1.7       | The SEA ensures compliance with all | Met         | N/A |
|           | Even Start program requirements.    | R           |     |
|           |                                     | equirements |     |
+-----------+-------------------------------------+-------------+-----+

Title I, Part B, Subpart 3

Monitoring area: Accountability

Indicator 1.3 -- In making continuation awards, the SEA reviews the
progress of each subgrantee in meeting the objectives of the program and
evaluates the program based on the indicators of program quality, and
refuses to award subgrant funds to an eligible entity if the agency
finds that the entity has not sufficiently improved the performance of
the program.

[**Finding**:]{.underline} The ADE has developed performance indicators
but does not have a clear definition of insufficient progress, nor does
it have procedures for discontinuing a project.

[Citation:]{.underline} Section 1238(b)(3) and (4) of the ESEA requires
States to use their indicators of program quality to evaluate whether
projects are making sufficient progress for the purpose of making
decisions about continuation awards.

[Further actions required:]{.underline} The ADE must develop and submit
to ED its definition of sufficient progress after review by the State
COP. Furthermore, the ADE must develop and submit to ED policies and
procedures for discontinuing projects that are not making sufficient
progress under the State indicators of program quality, or evidence that
such a system is in development, including any appropriate timelines.

## 

+-----------+-------------------------------------+-------------+----+
| ##        |                                     |             |    |
|  Monitori |                                     |             |    |
| ng Area 2 |                                     |             |    |
| , Title I |                                     |             |    |
| , Part B, |                                     |             |    |
|  Subpart  |                                     |             |    |
| 3: Progra |                                     |             |    |
| m Support |                                     |             |    |
+===========+=====================================+=============+====+
| **        | # Description                       | ### Status  | #  |
| Indicator |                                     |             | #  |
| Number**  |                                     |             | Pa |
|           |                                     |             | ge |
+-----------+-------------------------------------+-------------+----+
| 2.1       | The SEA uses funds to provide       | Met         | N  |
|           | technical assistance to local       | R           | /A |
|           | projects to improve the quality of  | equirements |    |
|           | Even Start family literacy services |             |    |
|           | and comply with State indicators of |             |    |
|           | program quality.                    |             |    |
+-----------+-------------------------------------+-------------+----+
| 2.2       | Each program assisted shall include | Met         | N  |
|           | the identification and recruitment  | R           | /A |
|           | of eligible families.               | equirements |    |
+-----------+-------------------------------------+-------------+----+
| 2.3       | Each program assisted shall         | Findings    | 16 |
|           | implement all 15 program elements.  |             |    |
+-----------+-------------------------------------+-------------+----+
| 2.4       | The SEA ensures that all families   | Met         | N  |
|           | receiving services participate in   | R           | /A |
|           | all four core instructional         | equirements |    |
|           | services.                           |             |    |
+-----------+-------------------------------------+-------------+----+
| 2.5       | The local programs shall use        | Met         | N  |
|           | high-quality instructional programs | R           | /A |
|           | based on scientifically based       | equirements |    |
|           | reading research (SBRR) for         |             |    |
|           | children and adults.                |             |    |
+-----------+-------------------------------------+-------------+----+

#### **Monitoring Area: Program Support**

**Indicator 2.3 -- Each program assisted shall implement all 15 program
elements.**

**Element #1 -- Recruitment of Most in Need.**

**[Finding]{.underline}:** Both Even Start projects visited had
documentation the eligibility of each family being served but are not
serving adults who are among those most in need. The ED team found that
projects are serving adults with college degrees.

[Citation]{.underline}: Section 1235(1) and section 1235(14) of the ESEA
require that each project identify, recruit, and serve families most in
need of Even Start services, as indicated by 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.

[Further action required]{.underline}: The ADE must provide ED with
documentation that it has provided guidance to local Even Start projects
on the requirement to serve families most in need of family literacy
services.

**Element #5 - Qualified Personnel**

**[Finding]{.underline}**: Based on interviews with staff at the Isaac
Even Start program, the ED team determined that some staff who are paid
totally or partially with Even Start funds that do not meet the
statutory requirements to provide instruction. Specifically, at the
Isaac Even Start project, the assistants act as substitutes for
classroom teachers in their absence. During this time, the assistants
are providing academic instruction.

[Citation]{.underline}: Section 1235(5)(A)(ii) of the ESEA requires that
the individual responsible for administration of family literacy
services under this subpart has received training in the operation of a
family literacy program. Section 1235(5)(B)(i)-(ii) requires that all
new personnel hired to provide academic instruction have obtained an
associate's, bachelor's, or graduate degree in a field related to early
childhood education, elementary school or secondary school education, or
adult education; and 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 ADE must provide ED with
evidence that all instructional staff in the Isaac Even Start project
meet the staff qualification requirements in the statute. Also, the ADE
must provide technical assistance to all Even Start projects to ensure
that only those staff that are qualified are providing instruction.

**Element \# 6 -- Staff Training**

# [Finding:]{.underline} The ADE has not ensured that all program directors have received the training in the operation of a family literacy program. At the time of the visit, there was no evidence presented to show that the program director, at the Isaac Even Start project, had taken the training in the operation of a family literacy program. 

[Citation:]{.underline} Section 1235(5)(A)(ii) of the ESEA states that
the individual responsible for administration of family literacy
services must have received training in the operation of a family
literacy program.

[Further action required:]{.underline} The ADE must submit an action
plan to ED for ensuring, through technical assistance, monitoring, and
training, that all local projects are aware of and receive the required
training in the operation of a family literacy program.

**Element #7 -- Home-based Instruction**

**[Recommendation:]{.underline}** Home visits, at both sites, are not
occurring at least once a month. It is recommended that a minimum of one
visit will be conducted per month per family.

**Element \# 11 -- Attendance and Retention**

**[Recommendation:]{.underline}** The ED team recommends that the ADE
work with local projects in developing attendance policies and other
strategies to ensure that families attend regularly and understand the
requirements as they relate to attendance.

+-----------+-------------------------------------+-------------+------+
| # Moni    |                                     |             |      |
| toring Ar |                                     |             |      |
| ea 3, Tit |                                     |             |      |
| le I Part |                                     |             |      |
|  B, Subpa |                                     |             |      |
| rt 3: SEA |                                     |             |      |
|  Fiduciar |                                     |             |      |
| y Respons |                                     |             |      |
| ibilities |                                     |             |      |
+-----------+-------------------------------------+-------------+------+
| **        | # Description                       | ### Status  | ##   |
| Indicator |                                     |             | Page |
| Number**  |                                     |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.1       | The SEA complies with the           | Met         | N/A  |
|           | allocation requirements for State   | R           |      |
|           | administration and technical        | equirements |      |
|           | assistance and award of subgrants.  |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.2       | The SEA ensures that subgrantees    | Met         | N/A  |
|           | comply with statutory and           | R           |      |
|           | regulatory requirements on uses of  | equirements |      |
|           | funds and matching.                 |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.3       | The SEA complies with the           | Met         | 18   |
|           | cross-cutting maintenance of effort | R           |      |
|           | provisions.                         | equirements |      |
|           |                                     |             |      |
|           |                                     | Rec         |      |
|           |                                     | ommendation |      |
+-----------+-------------------------------------+-------------+------+
| 3.4       | The SEA ensures that grantees       | Finding     | 18   |
|           | comply with requirements with       |             |      |
|           | regard to services for eligible     |             |      |
|           | private school children, their      |             |      |
|           | teachers, and their families.       |             |      |
+-----------+-------------------------------------+-------------+------+
| 3.5       | The SEA has a system for ensuring   | Met         | N/A  |
|           | fair and prompt resolution of       | R           |      |
|           | complaints and appropriate hearing  | equirements |      |
|           | procedures.                         |             |      |
+-----------+-------------------------------------+-------------+------+

#### **Monitoring Area: Fiduciary Responsibilities**

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

**[Recommendation:]{.underline}** Some ADE staff members were not aware
of the maintenance of effort requirement and others did not have an
understanding of the requirement. It is recommended that the ADE provide
technical assistance to all staff members to ensure that they understand
the maintenance of effort requirement.

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

**[Finding:]{.underline}** The ADE and the two sites visited did not
provide any evidence that they consulted 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 that local
programs provide an appropriate amount of those services and benefits
through an eligible provider.

[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 ADE must submit evidence to ED of how it will ensure that all Even Start projects are aware of such requirements, are given guidance on how to meet such requirements, and meaningfully consult with private school officials in order to provide Even Start services and benefits to eligible private school students and their teachers or other educational personnel on an equitable basis. The State should refer to the Even Start guidance document for assistance. 

#  Title I, Part D

#  Summary of Monitoring Indicators

+------------+-----------------------------------+-------------+------+
| # Neglec   |                                   |             |      |
| ted, Delin |                                   |             |      |
| quent or A |                                   |             |      |
| t-Risk of  |                                   |             |      |
| Dropping-O |                                   |             |      |
| ut Program |                                   |             |      |
+------------+-----------------------------------+-------------+------+
| **I        | # Description                     | ### Status  | ##   |
| ndicator** |                                   |             | Page |
|            |                                   |             |      |
| **Number** |                                   |             |      |
+------------+-----------------------------------+-------------+------+
| 1.1        | The SEA has implemented all       | Met         | > 20 |
|            | required components as identified | R           |      |
|            | in its Title I, Part D (N/D)      | equirements |      |
|            | plan.                             |             |      |
+------------+-----------------------------------+-------------+------+
| 1.2        | The SEA ensures that State agency | Met         | >    |
|            | (SA) plans for services to        | R           |  N/A |
|            | eligible N/D students meet all    | equirements |      |
|            | requirements.                     |             |      |
+------------+-----------------------------------+-------------+------+
| 1.3        | The SEA ensures that local        | Met         | >    |
|            | educational agency (LEA) plans    | R           |  N/A |
|            | for services to eligible N/D      | equirements |      |
|            | students meet all requirements.   |             |      |
+------------+-----------------------------------+-------------+------+
| 2.1        | The SEA ensures that              | Met         | >    |
|            | 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.           |             |      |
+------------+-----------------------------------+-------------+------+
| 3.1        | The SEA ensures each SA has       | Met         | >    |
|            | reserved not less than 15 percent | R           |  N/A |
|            | and not more than 30 percent of   | equirements |      |
|            | the amount it receives under      |             |      |
|            | Subpart 1 for transition          |             |      |
|            | services.                         |             |      |
+------------+-----------------------------------+-------------+------+
| 3.2        | The SEA conducts monitoring of    | Met         | >    |
|            | its subgrantees sufficient to     | R           |  N/A |
|            | ensure compliance with Title I,   | equirements |      |
|            | Part D program requirements.      |             |      |
+------------+-----------------------------------+-------------+------+

**McKinney-Vento Homeless Education Program**

**Summary of Monitoring Indicators**

+------------+------------------------------------+------------+------+
| # M        |                                    |            |      |
| cKinney-Ve |                                    |            |      |
| nto Homele |                                    |            |      |
| ss Educati |                                    |            |      |
| on Program |                                    |            |      |
+------------+------------------------------------+------------+------+
| *          | # Description                      | ### Status | ##   |
| *Indicator |                                    |            | Page |
| Number**   |                                    |            |      |
+------------+------------------------------------+------------+------+
| Indicator  | The SEA collects and reports to ED | Met        | 21   |
| 1.1        | assessment data from LEAs on the   | Re         |      |
|            | educational needs of homeless      | quirements |      |
|            | children and youth.                |            |      |
|            |                                    | Reco       |      |
|            |                                    | mmendation |      |
+------------+------------------------------------+------------+------+
| 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       | Met        | N/A  |
| 3.2        | complies with providing comparable | Re         |      |
|            | Title I, Part A services to        | quirements |      |
|            | 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     | Met        | N/A  |
| 3.4        | LEAs with and without subgrants,   | Re         |      |
|            | sufficient to ensure compliance    | quirements |      |
|            | with McKinney-Vento program        |            |      |
|            | requirements.                      |            |      |
+------------+------------------------------------+------------+------+

**Indicator 1.1 - The SEA collects and reports to ED assessment data
from LEAs on the educational needs of homeless children and youth.**

**[Recommendation:]{.underline}** Approximately half of Arizona's LEAs
report that they have no homeless students. While a report of zero
homeless students may be accurate, this high percentage needs further
review. ED recommends that the SEA Homeless Coordinator conduct outreach
efforts to a cluster of LEAs with proportionally high Title I
allocations that report 'zero' or low numbers of homeless students. The
coordinator should provide targeted technical assistance to determine
what kinds of outreach/identification activities are taking place, and
to assist local liaisons in verifying that zero or low numbers are
indeed an accurate reflection of incidence of homeless families in their
respective communities.