UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF ELEMENTARY AND SECONDARY EDUCATION

January 10, 2017

Secretary Rebecca Holcombe 

Vermont Agency of Education

219 North Main Street, Suite 402

Barre, Vermont 05641

Dear Rebecca Holcombe:

On September 26-28, 2016, a team from the U.S. Department of Education (ED) (the 

Department) conducted an onsite monitoring of the Vermont Agency of Education’s (AOE) 

implementation of its approved Preschool Development Grant (PDG). This monitoring aims to 

continue the collaborative relationship that began at the grant award and development of the 

scope of work. It provides the Department with a deeper understanding of each State’s overall 

performance; the successes, challenges, and strategies for the implementation of its plans for its 

PDG Development grant; and the fiscal management of the grant funds. It also helps us tailor 

technical assistance to each State’s specific needs.

The site visit included presentations and discussions related to all projects in the approved scope 

of work, including grants management, high-quality preschool programs, early learning 

standards, comprehensive services, workforce development, and sustainability. During the visit, 

ED project officers visited the Vermont Agency of Education and several Preschool classrooms 

located in five high-need communities: Capstone Head Start, St. Johnsbury School District, 

Northeast Kingdom Head Start, Chittenden Central Supervisory Union and Burlington School 

District. 

Enclosed is a summary report based upon this review. The report includes highlights of 

Vermont’s implementation of PDG and a snapshot of Vermont’s progress under each PDG key 

area. This report will be posted on the PDG website. The report includes “next steps” to ensure 

that Vermont implements PDG consistent with its approved application, scope of work, and 

timelines identified in its project plans.

We want to thank you and your staff for your cooperation and hospitality during the site visit, 

and for your efforts in providing high quality preschool opportunities through the Preschool 

Development Grant. As we have discussed and as detailed further in this report, Vermont is 

receiving a corrective action report as a result of the visit. As such, a written response to the 

corrective action is expected by January 30, 2017. We hope you will continue to communicate 

any needs or concerns to your ED project officer(s). 
We look forward to continuing our work with you and supporting Vermont’s technical assistance 

needs to ensure successful implementation of PDG. Thank you for your commitment to 

Vermont’s youngest children.

Sincerely,

/s/

Libby Doggett

Deputy Assistant Secretary 

Office of Early Learning

Office of Elementary and Secondary Education

U.S. Department of Education

Enclosure
UNITED STATES DEPARTMENT OF EDUCATION

OFFICE OF ELEMENTARY AND SECONDARY EDUCATION

PDG Site Visit Report

Monitoring Information

State Lead Agency Vermont Agency of Education

State Participating Agency(s) Vermont Agency of Education

Grant Period January 1, 2015-December 31, 2019

Current Year of Grant January 1, 2016-December 31, 2016

PDG Monitoring Period May 2016 – September 30, 2016

PDG Monitoring Activity (Desk 

or Onsite)

Onsite

Monitoring Review Date(s) September 26, 2016-September 28, 2016

State Participants/Project Leads Karin Edwards, Kate Rodgers, Ben Allen

U.S. Department of Education 

Project Officer(s)

Rubén J Vázquez and Steven Hicks

Overview of PDG Monitoring

The Department of Education (the Department) is committed to supporting States as they 

implement the expansion of high-quality preschool programs for eligible children through their 

PDG grant. Consistent with this commitment, the Department has designed a monitoring process 

to assess a State’s implementation of the program requirements and its approved Scope of Work 

for PDG and the State-level systems and processes needed to support implementation.
During the recent onsite monitoring, Vermont’s implementation of PDG was reviewed across 

several key areas which represent the core priorities for implementation as outlined in the PDG 

Monitoring Tool: Capacity Building and Increasing Slots, Subrecipient Monitoring, Birth to 

Third Grade Continuum, Budget and Sustainability, and Fiscal Accountability. In each area, the 

Department identified key elements that are required under PDG and are likely to increase the 

access to and quality of State Preschool programs and lead to increased high-quality 

opportunities for young children and their families. 

Vermont was identified for a site visit based on the following factors: 

• Vermont has had challenges fully implementing new high-quality preschool programs;

and

• Vermont’s number and percentage of children to be served in year 1 is significantly less 

than the target numbers identified in the State application. 

The report contains the following sections:

• Summary of Visit. This section describes, in brief, the topics covered, the lead agency 

and subrecipients visited, as well as personnel participation in any meetings or activities.

• Highlights of the State’s Implementation. This section identifies key accomplishments 

in the State’s implementation of PDG as identified during the site visit.

• Status of Implementation of PDG. This section indicates the State’s implementation 

progress based on the monitoring and information collected.

• Elements Requiring Next Steps. This section identifies any elements for which the State 

is not on target for meeting its timelines outlined in the approved scope of work and 

includes next steps that the State must take to meet the grant outcomes, as identified 

during the monitoring. 

• Recommendations to Strengthen Implementation. This section provides 

recommendations to support the State in continuing to meet the goals and timelines of its 

PDG grant, as identified during the monitoring.

• Additional Comment. As appropriate, this section includes any additional information 

related to the State’s implementation of PDG not included elsewhere.

Summary of Visit

The PDG onsite monitoring visit for Vermont was conducted September 26-28, 2016. During the 

first day of the visit, ED project officers discussed a variety of topics with the Vermont Agency 

of Education (AOE) and Vermont Agency of Human Services (AOHS) staff pertaining to PDG 

implementation. Discussions included the targets and actual number of students served;

recruitment of educators with high staff qualifications; challenges with space and buildings; 

comparable salaries; non-Federal matching funds; processes for tracking funds and reimbursing 

subgrantees; outreach activities such as student recruitment; and the State’s capacity to create 

new and improved high-quality preschool slots. On the same day, ED, AOE and AOHS officials 

visited Capstone Community Action. Capstone Head Start, a Head Start center administered by 
Capstone Community Action, provides early care and education services to low-income children 

and engages families in their children’s development and well-being serving the counties of 

Lamoille, Orange and Washington. Capstone Head Start offers an inclusive 6 1⁄2 - hour- day 

preschool program for 13 children. Capstone Head Start provides children and families a broad 

range of services that lead to positive child outcomes including: parent education and training, 

family health and nutrition resources, access to physical and mental health services, disability 

services, and resources on assisting with child behavior and more. 

The second day of the visit, ED, AOE and AOHS officials visited two PDG sites: St. Johnsbury 

School District and Northeast Kingdom Head Start. The Johnsbury School District offers a fullday preschool program for 43 students. The Johnsbury School District provides all sites 

guidance on working with children and families, instructional equipment and materials, 

professional development, playground equipment, and furniture. The Northeastern Kingdom 

Head Start offers a full- day preschool program for 20 children. In addition to providing highquality preschool programs and family programs, the Northeastern Kingdom Head Start provides 

eligible PDG children with a comprehensive health program that includes immunizations, 

medical, dental, mental health, and nutritional services; services for children with special needs; 

and parental involvement training that includes parenting education.

The final day of the visit, ED, AOE and AOHS officials visited Chittenden Central Supervisory 

Union and Burlington School District. The Chittenden Central Supervisory Union and 

Burlington School District offer full-day programs, serving 14 children and 15 children 

respectively. Both subgrantees offer a broad range of services which include: parental 

involvement, home visits, instructional materials, professional development. 

During the afternoon, ED staff met with AOE officials to discuss preliminary observations from 

the visit including: State monitoring of subgrantees, professional development for subgrantees 

and future strategies for identifying more for dual language learners. Additionally, ED and State 

staff discussed the State’s challenges serving the targeted number of children resulted in 

discussions about potential solutions, such as additional outreach options and recruitment efforts.

Status of Implementation of PDG 

In the onsite monitoring, the Department used a monitoring and accountability rubric to help 

determine progress of the State’s implementation. The rubric includes three implementation 

status levels: 

• Level 1 – Developing: the State is in the process of developing this activity, or the 

activity is very new. The State may be facing challenges in implementation, roll-out, or 

communications with subrecipients and other stakeholders. 
• Level 2 – Implementing: the State has developed and implemented the activity, although 

the activity might still benefit from adjustments, training, or communications with 

subrecipients and other stakeholders. 

• Level 3 – Sustaining & Continuing Improvement: the activity is well-established in the 

State, and may be undergoing a process of evaluation or program improvement. 

Subrecipients, stakeholders and users have been trained and/or communications strategies 

have been established.
Element Status

Capacity Building and Increasing Slots

The State public awareness and recruitment 

activities are targeted towards eligible 4 year old 

children in high need communities and families 200 

percent below poverty. 

Level 2-Implementing

The State’s expansion efforts are targeted towards 

increasing the access to high quality preschool 

programs for 4 year olds.

Level 1-Developing

The State has a plan to ensure that existing State 

Preschool slots met the twelve standards of a High 

Quality Preschool Program under the PDG funding. 

Level 1-Developing

Subrecipient Monitoring

The State Lead Agency has a process to monitor 

grant and sub-recipients activities to ensure 

implementation of the goals and performance 

measures outlined in the approved PDG State Plan. 

Level 1-Developing

The State is on schedule with its monitoring of 

subrecipients to ensure that all of the high quality 

standards for Preschool are met within PDG funded 

preschool classrooms.

Level 1-Developing

 

The State is providing access to comprehensive 

services to all children enrolled in the PDG funded 

preschool classrooms.

Level 2-Implementing

Birth to Third Grade Continuum

The State has aligned the PDG funded program 

within the Birth to Third Grade Continuum of early 

learning standards and activities that help prepare 

children for kindergarten thru third grade. 

Level 2-Implementing

The State is implementing a data collection system 

for tracking student outcomes from prekindergarten 

to kindergarten entry through third grade.

Level 2-Implementing

The State is implementing a transition protocol to 

ensure that children transitioning from early care 

and education environments to kindergarten to third 

grade settings receive the supports necessary for a 

smooth transition.

Level 2-Implementing

Budget and Sustainability

The State has policies and procedures to track the 

State and Subrecipient budget activities to ensure 

that funds are expanded according to State, Local 

and Federal procurement laws.

Level 1-Developing

The State has in place a system to track the “use of 

funds” under the PDG grant. 

Level 1-Developing

 

The State has a plan to ensure that High Quality 

State Preschool Programs will remain of high 

quality after federal funds are no longer available. 

Level 1-Developing
Highlights of the State’s PDG Implementation

• AOE is fully implementing Universal Pre-Kindergarten (Pre-K) State Program for all 3, 4 

and 5 year old children who are not enrolled in Kindergarten in Vermont. The new law, 

Act 166, requires school districts to provide access to at least 10 hours of instruction for 

35 weeks to any preschool-aged child. 

• AOE requires that all educators in preschool programs be licensed. To be eligible for an 

educator’s license, a professional must have a Bachelor’s Degree or a Master’s Degree in 

a field related to early childhood education. 

• Vermont Early Learning Standards (birth through grade 3) were approved by the State 

Board of Education in August 2015 and the State provided regional trainings and support 

for all PDG subgrantees. 

Recommendations to Strengthen Implementation

• The AOE has not demonstrated that it is providing enough technical assistance for its 

subgrantees. The State should develop a timeline and plan to provide technical assistance 

to PDG subgrantees on a regular basis. The State should consider providing additional 

training to its subgrantees; for example, monthly calls, webinars, technical assistance 

meetings and/or annual PDG conferences. 

Elements Requiring Next Steps: 

Through its onsite monitoring, annual performance reporting and monthly calls over the past 

year, the Department has noted its concern about AOE’s implementation of its PDG grant. The 

areas of concern are: State capacity and ability to increase the number of high-quality preschool 

slots; sub-recipient monitoring; and fiscal accountability. As a result of its program review and 

ongoing monthly calls, the Department is imposing a Corrective Action Plan (CAP) targeted on 

the following areas: 

Fiscal Accountability

The State has policies and procedures in place to 

ensure the grant funds are expended according to the 

federal laws outlined in the federal Super Circular 

and EDGAR.

Level 1-Developing

 

The State has a system in place to ensure that its 

Subrecipients are meeting the federal laws of the 

Super Circular and comply with the “supplement not 

supplant” requirements. 

Level 1-Developing
1. Pre-K facilities and staff across the State have been working to implement Act 166, 

which has impacted the number of facilities and staff that can participate in the PDG 

subgrants. The Department has approved Vermont’s revised plan and targets for serving 

eligible children in PDG-funded classrooms. As many of Vermont’s low income 

children participate in the State’s universal PreK, the Department encourages AOE to 

continue working with head start programs to provide high-quality preschool program 

improved slots to eligible children, as it committed to in its approved application. By 

January 30, 2017, Vermont must submit a plan to meet or exceed the revised targets for 

numbers of children served in High-Quality Preschool Programs in Years 3 and 4. If 

AOE is not able to make create new and/or improved slots to provide preschool programs 

under this grant, the State must find other methods of outreach/recruitment and/or secure 

new subrecipients to help meet its program goals. Vermont must also spend at least 95% 

of its PDG funds on High-Quality Preschool Programs for Eligible Children

2. AOE has not implemented a process to monitor PDG subgrantees for compliance with all 

programmatic and fiscal requirements. By January 30, 2017, AOE must submit to ED a 

revised plan, for monitoring its PDG subgrantees, including procedures, protocols, and a 

schedule, as well as evidence that the State is implementing this plan beginning in Spring 

2017. The AOE must also submit to ED evidence that the State has established 

corrective action procedures to ensure that PDG subgrantees effectively address and 

resolve compliance issues and that it provides PDG subgrantees an explanation of any 

concerns, recommendations and/or commendations, and clear expectations and timelines 

for resolving such concerns. For example, the State could propose to establish a 

procedure by which it provides subgrantees with formal reports following every 

monitoring visit containing such information. 

3. On September 23, 2016, the Vermont Agency of Education submitted an amendment 

request to decrease the number of children served in PDG classrooms, as well as to 

update its budget to more accurately reflect the cost of a high-quality preschool program 

slot. The AOE must submit to ED a revised, detailed scope of work and budget 

reflecting all changes associated with this amendment. 

Additional Comments

As part of the grant requirement, AOE submitted a Scope of Work (SOW) that was reviewed and 

approved by the Department. The SOW should be updated monthly, a week prior to the monthly 

call, to consistently record timelines as they shift. Vermont has not updated the SOW regularly. 

The project officer will continue to monitor the progress through monthly phone calls.
Corrective Action Plan (CAP) Template

This Corrective Action Plan (CAP) template is a tool to help staff address the grant requirements 

in the PDG grant while working together to create meaningful, practical, and supportive CAPs. It 

uses the steps and tracking below. 

Step I. Areas Identified for Improvement (examples)

• State’s new and improved slots targets

• Fiscal Requirements

• Subgrantee Monitoring 

Step II. Goals and Professional Responsibilities

• Goals and responsibilities to be developed for each area of deficiency

• Team has 30 days to submit CAP

Step III. CAP Progress Summary

• Request a quarterly report in writing on the progress of the CAP with sub 

reports on targeted tasks monthly in advance of each monthly call with Program 

Officer

Interim Review of CAP Progress

• 6 month review by Project Officer from date of signed CAP

Summative Review of CAP Progress

• 12 month review by Project Officer from date of signed CAP
Corrective Action Plan (CAP) Template

State Name: State Agency on Grant: Date

Vermont Vermont Agency of Education

Project Officer Name : Date of Monitoring Visit: Plan Begin/End Dates

Ruben J Vazquez September 26-28, 2016

I. Areas Identified for Improvement

No. Areas Identified for Improvement Sources of Information/Evidence Corresponding Component

(if applicable)

1 Building capacity and slots Revised Plan and Documentation showing capacity reached (and recruitment 

efforts) with eligible preschool children being served in a high quality 

preschool program

2 Sub-recipient monitoring Revised Plan Evidence of feedback report to subgrantees including 

documentation of findings, recommendations and commendations etc

3 Fiscal accountability Spend at least 95% of its PDG funds on High-Quality Preschool Programs for 

Eligible Children

4
II. Goals and Professional Responsibilities 

Area

No.

Demonstrable Goals Staff Member Responsibilities Supervisor Responsibilities Completion

Date

Estimated

Hours

1

2

3

Area

No.

Demonstrable Goals Staff Member Responsibilities Supervisor Responsibilities Completion

Date

Estimated

Hours

4

5
My signature below indicates that the leadership team and I have received a copy of this Corrective Action Plan and that I understand and

contributed to its contents. 

Lead Agency Signature: 

Leadership Team Member Signature: 

Leadership Team Member Signature: 

Leadership Team Member Signature: 

Date:

Date:

Date:

Date:
III. CAP Progress Summary

Interim Review of CAP Progress

Area

No.

Demonstrated Progress Sources of Evidence CAP Revisions (if applicable) Review Date

1

2

3

My signature below indicates that the leadership team and I have reviewed the information recorded in the Interim Review of CAP Progress

and that I understand its contents:

Lead Agency Signature: 

Leadership Team Member Signature: 

Leadership Team Member Signature: 

Leadership Team Member Signature: 

Date:

Date:

Date:

Date:
Summative Review of CAP Progress

Area

No.

Demonstrable Goals Expectations

Met (Y) or 

Not Met (N)

Sources of Evidence Review Date

1

2

3

My signature below indicates that the leadership team and I have reviewed the information recorded in the Summative Review 

of CAP Progress and that I understand its contents:

Lead Agency Signature: Date:________

Leadership Team Member Signature: Date:________

Leadership Team Member Signature: Date:________

Leadership Team Member Signature: Date: __