Federal Programs Procedural Manual
Tracie Turrentine - Superintendent
Honi Smith- Director of Federal Programs
256-309-2100
Table of Contents
*Disclaimer: This handbook is subject to change at any time given updates in federal or state legislation or guidance.
MCS Federal Programs Calendar 2
SUMMARY OF PROGRAMS MANAGED BY FEDERAL PROGRAMS 3
MCS Federal Funding Overview 4
Alabama Continuous Improvement Plan (ACIP) 5
Qualifications of Teachers & Paraprofessionals 7
State Accountability / Performance 7
Every Student Succeeds Act (ESSA) Consolidated Grants 11
Title I, Part-A - Improving Basic Programs Overview 11
PARENT AND FAMILY ENGAGEMENT 12
School-Parent-Student Compact 13
Parent's Right to Know/4-Week Teacher Notification 16
Other Title I Federal Programs 17
Title I, Part C – Migrant Children Education 17
Title I, Part D – Neglected and Delinquent Children Programs 17
Title II, Part A – Supporting Effective Instruction Overview 18
Title II Professional Development Plan 18
Title Ill, Part A – Language Instruction for English Learners (EL) & Immigrant Students 19
What Is the State Definition of An English Learner (EL)? 20
English Learner Supplemental Services Waiver Form: 21
Title IV, Part A - Student Support and Academic Enrichment Grant (SSAEP) 21
Federal Grants Budget Overview 22
Authorized Use of Federal Funds 22
Expenditure Reporting for Federal Grants 24
Federal Grants Budget Process 26
Allocating Title Funds to Non-Public/Private School Children 26
Participation of Private School Children 27
Title II, Part A Supporting Effective Instruction Overview 27
Title Ill, Part A English Language Acquisition (ELA)/ Limited English Proficient (LEP) 27
Title IV, Part A Student Support and Academic Enrichment Grant (SSAEP) 28
Federal Grants Compliance Requirements 28
Supplement Not Supplant:(Funding Sources: Title I, Title II, Title III) 28
Purchase orders must be complete to include the following: 31
SEGREGATION OF DUTIES FOR PURCHASING 31
New Item/Property Inventory Process 32
Salvage/Disposal or Transfer of Equipment 32
Loss, Damage, or Theft of Inventory item 33
Private School Inventoried Items 33
Procurement Policies and Procedures 39
JULY
Due date September 1 AUGUST
SEPTEMBER
Due date October 15 OCTOBER
NOVEMBER
Due date ongoing DECEMBER
| JANUARY
Due date TBA FEBRUARY
MARCH
Due date TBA APRIL
Due date last working day in May MAY
JUNE
|
The Federal Programs Department is responsible for the administration of various federal and state funded programs. The funding is provided to the Local Educational Agency (LEA) to supplement those activities and programs already in place within the Morgan County Schools District.
All Title programs and special grants are governed by the Every Student Succeeds Act (ESSA); however, reauthorization of the Elementary and Secondary Education Act (ESEA) allows the opportunity for State Educational Agencies (SEAs) to request flexibility on behalf of itself, its Local Educational Agencies (LEAs), and schools regarding portions of ESSA. Flexibility may be granted in exchange for rigorous and comprehensive state-developed plans designed to improve educational outcomes for all children, close achievement gaps, increase equity, and improve the quality of instruction. Each SEA must submit a request that addresses four principles:
TITLE I, Part A
Improving Basic Programs Operated by State and Local Education Agencies
Purpose: To ensure that all children have a fair, equal, and significant opportunity to obtain a high-quality education and reach, at a minimum, proficiency on challenging state academic achievement standards and state academic assessments.
TITLE I, Part D
Prevention and Intervention Programs for Children and Youth Who Are Neglected, Delinquent, or At-Risk
Purpose: To improve educational services for children and youth who are generally institutionalized or are attending community day programs for neglected and delinquent children and youth. Services provide the opportunity for students to meet the same state academic content and achievement standards that all students in the state are expected to meet.
TITLE II, Part A
Preparing, Training, and Recruiting High-Quality Teachers, Principals, or Other School Leaders
Purpose: To provide grants to State Educational Agencies (SEA’s), Local Educational Agencies (LEAs), state agencies for higher education, and eligible partnerships in order to increase student academic achievement through strategies such as improving teacher and principal quality and increasing the number of profession ready teachers in the classroom, principals and assistant principals in schools.
TITLE III, Part A
Language Instruction for English Learners and Immigrant Students
Purpose: To help ensure that children who are limited English proficient, including immigrant children and youth, attain English proficiency, develop high levels of academic attainment in English, and meet the same challenging State academic content and student academic achievement standards as all children are expected to meet.
TITLE IX, Part A
Education for the Homeless and Other Laws (McKinney-Vento 2001 Homeless Assistance Act)
This program is part of the national policy for the education of homeless children, which provides funds to facilitate enrollment and attendance.
TITLE IX, Part A
Children in Foster Care
The Every Student Achieves Act provides all children and youth in foster care with core protections for school stability and school access through a statutory vehicle that is separate from the McKinney-Vento Act, and that outlines clear, distinct and appropriate responsibilities for both the education and child welfare agencies.
The purpose of this manual is to describe the processes and procedures for the application of federal funding within the Morgan County School District. This manual may not be all inclusive and will be updated as needed or required.
Morgan County works to ensure all federal laws and requirements are applied in a consistent and appropriate manner to meet the needs of all students and as required by federal grant program regulations.
The core components that drive the federal funding cycle provide the basis for determining students’ instructional needs. These components also include required elements that are aligned together to ensure a successful implementation of the program. These components complement each other as important steps in this continual cycle.
The Comprehensive Needs Assessment develops the framework for the Alabama Continuous Improvement Plan (ACIP) in identifying the needs, budgets, challenges, measurements, assessment and planning for the impact of federal funding on student achievement as well as district and school improvement.. The plan is designed through the collaborative efforts of all stakeholders, ie. teachers, principals, parents, community entities etc. The plan is implemented throughout the year, regularly monitored, and revised as necessary. It is based on students’ needs and ensures that students are provided opportunities to meet challenging State academic standards.
Notifications of federal funding through discretionary and competitive grant opportunities are received from the Alabama State Department of Education. The federal grant opportunities are made available for application at the district and school level.
The Superintendent and Central Office Administrators will consider all aspects of external funding opportunities and will appropriate the funds to meet the current and future needs of the District, schools and students..
The federal funding application process is driven by the Comprehensive Needs Assessment, availability of funds, and the vision/mission of the district. The Federal Programs Staff collects the data and works with school and district personnel to plan the best usage of funds throughout the funding application process.
Federal funds are disbursed to the Morgan County School District via The Alabama State Department of Education. Schools receiving Federal funding do not charge fees for courses, items, supplies, technology, etc.
Oversight is primarily the responsibility of the district’s Federal Programs Director and Director of ESSER, working closely with the Chief School Financial officer and the Superintendent to ensure all federal guidelines are being met during the program implementation process. This includes budget reviews and collection of all appropriate documentation as required for program compliance.
Implementation is completed with the assistance of other Central Office personnel, as well as school personnel and key support staff by regulating all key grant components to meet the original grant application specifications.
As mandated by statute, districts must conduct an evaluation for each federally-funded program in order to determine if the established goals were met, evaluation component is driven primarily through data from Elementary and Secondary Curriculum in collaboration with the Comprehensive Needs Assessment findings and funds previously budgeted. The Federal Programs staff collects valuable information used to comply with program performance reporting.
Morgan County ensures all eligible schools are allocated Title I, Part A funds, in accordance with the number of economically disadvantaged students per campus. The Federal Program staff collects the data of economically disadvantaged students enrolled in the Morgan County School District annually. These funds are used to enhance the entire educational program and climate of the school and to address student achievement needs as determined by the Comprehensive Needs Assessment and Alabama Continuous Improvement Plan. These funds are used consistently in compliance with all statutory and regulatory requirements in a schoolwide program.
All federal grants include provisions and assurances that the district agrees to comply with when a grant is accepted through the Alabama State Department of Education. The provisions and assurances will be reviewed for understanding at the time a federal grant is submitted for approval by the state agency. The provisions and assurances under the EDGAR (Education Department General Administrative Regulations) will be followed.
A situation where individuals or entities involved in the procurement process for federally funded projects have personal or financial interests that may improperly influence or compromise their ability to make impartial and unbiased decisions regarding the selection of vendors or suppliers. Such conflicts can create a risk of favoritism, unfair competition, or the misallocation of federal funds, and they must be identified and managed in accordance with the regulations to ensure transparency and integrity in procurement activities. This may involve disclosure, recusal, or other appropriate measures to address the conflict and maintain the integrity of the procurement process. If one finds there is a conflict of interest, they should: Disclose the conflict to supervisors and recuse themselves. If recusal isn't possible or doesn't fully address the conflict, explore ways to mitigate it. This may involve establishing safeguards or mechanisms to ensure that decisions are made fairly and without undue influence.
Morgan County will continue to comply with section 1119 of the Elementary and Secondary Education Act (ESEA), as amended by the Every Student Succeeds Act (ESSA), which requires the district to implement strategies and report the progress toward all teachers being highly effective and ensure that paraprofessionals meet qualifications and perform specific duties as allowed under the federal grant requirements.
Teachers and Paraprofessionals hired with the use of federal funds will be required to perform specific duties allowable under the federal grant requirements. The Federal Programs Director, Director of ESSER, and school administrators will monitor to ensure that program requirements are met.
Every district that receives Title I, Part A funding is responsible for distributing the state-, district-, and school-level report cards to each of its schools, the parents of all enrolled students, and the general public/community. The Morgan County Board of Education ensures the Federal Report Cards are disseminated accordingly when the data is made available by the Alabama State Department of Education. Additional information on the Federal Report Cards can be found at https://alsde.edu.
Every district is responsible for informing parents and guardians about their child's school individual characteristics and academic performance. The Morgan County School District ensures the School Report Card is disseminated accordingly to parents/guardians when the data is released by the Alabama State Department of Education. Additional information on the School Report Cards can be found at https://alsde.edu.
Maintaining the security and confidentiality of assessment results for students is important in the district. The District Testing Coordinator provides an annual training to school testing coordinators, school administrators, and teachers to ensure assessment security systems are followed thus eliminating any procedural irregularities that can result if procedures are not followed.
MCS operates with a Board-approved Enrollment policy (Policy 6.01: Admissions and Attendance) All homeless, migrant, immigrant, and English Learner students and children in foster care will have equal access to the same free appropriate public education, including public preschool education, provided to other children and youth and will be provided the opportunity to meet the same challenging state content and state student performance standards to which all students are held without being stigmatized or isolated.
MCS Enrollment Process:
Parents complete an online enrollment form at morgank12.org
The student is then immediately invited to the school to register, confirm personal data for Powerschool, deliver available documents (possibly ID, proof of residence, etc.)
The registrar creates a schedule for the student to complete the enrollment process.
The enrollment of homeless, migrant, immigrant, and English learner students and children in foster care shall not be denied or delayed due to any barriers that are specifically prohibited by applicable law, which may include the following:
The sending school in Alabama should promptly compile and transfer the student's records to the receiving school in the new state. The records should include all relevant educational and health information.
A student in foster care will enroll or remain in the student’s school of origin, unless it is determined that remaining in the school of origin is not in such a student's best interest.
If it is not in a student’s best interest to stay in the school of origin, a student in foster care may be enrolled in any school in the system that serves the attendance area in which the student is living, even if the student is unable to produce records normally required for enrollment. The school system will immediately contact the school last attended by the student to obtain relevant academic and other records.
[Reference: 20 U.S.C. §§6311(g)(1)(E)]
Morgan County Schools collects and reports data on the following:
• the number of students experiencing homelessness in each grade
• the type of primary nighttime residence
• the number of students in each subgroup of homeless students,
• the academic achievement of homeless students
• the number of students served by McKinney-Vento subgrants
• the number of students served by Title I targeted assistance (TAS) or schoolwide (SWP) programs,
• the adjusted cohort graduation rate (ACGR) of homeless students,
• the number of homeless students who complete high school,
• the number of homeless students who drop out
• McKinney-Vento subgrant status
The purpose of Title I, Part-A grant is to enable schools to provide opportunities for children to acquire knowledge and skills contained in the challenging state content standards and to meet the challenging state performance standards (state mandated assessments) developed for all children. The LEA shall use Federal funds received under Title I, Part A to supplement the funds that would, in the absence of such Federal funds, be made available from State and local sources, and not to supplant such funds.
This purpose is accomplished by:
• Ensuring high standards for all students and aligning the efforts of states, local educational agencies, and schools to help students served with Title I funds reach such standards;
• Providing students with an enriched and accelerated educational program, including, when appropriate, the use of supplemental resources, schoolwide programs, or the increase of the amount and quality of instructional time so that students served with Title I funds receive at least the classroom instruction that other students receive;
• Promoting school wide reform and ensuring all children have access to effective instructional strategies and challenging academic content that includes complex thinking and problem solving experiences;
• Providing substantial staff development opportunities to significantly upgrade the quality of instruction;
• Coordinating all Title I services with other educational services, and to the extent possible, with health and social service programs funded from other sources;
• Providing parents meaningful opportunities to participate in the education of their children at home and at school;
• Distributing resources, in amounts sufficient to make a difference, to areas and campuses where needs are the greatest;
• Improving accountability by using the state assessment data to measure how well Title I students are achieving the challenging state student performance standards expected of all students;
• Providing greater decision making authority and flexibility to schools and teachers in exchange for greater responsibility for student performance.
Components of a School-Wide Program
All schoolwide campuses must include the following components:
• Conduct a comprehensive needs assessment and evaluation of the entire school to determine the performance of its children in relation to the state mandated assessments and the school Alabama Continuous Improvement Plan;
• Implement schoolwide reform strategies that are based on effective means of improving the achievement of children and that address the needs of all children in the school;
• Provide instruction by highly effective professional staff;
• Provide high quality and ongoing professional development for teachers, principals, and paraprofessionals and if appropriate, student services personnel, parents and other staff;
• Implement strategies to attract highly effective teachers;
• Implement strategies to increase parent & family engagement activities; • Plans for assisting preschool children in the transition from early childhood programs to elementary school programs;
• Measures to include teachers in the decisions regarding the use of academic assessments in order to improve the achievement of individual students and the overall instructional program;
• Provide activities to ensure students who experience difficulty mastering standards or state mandated assessments standards shall be provided with effective, timely additional assistance;
• Coordination and integration of federal, state, and local services and programs.
Title I, Part A
Title I places enormous emphasis on parental and family engagement for an important reason: there are few strategies as powerful in raising student achievement as active, engaged parents. Although Parent and Family Engagement has always been a key part of Title I, it was not tightly defined until the passage of the Elementary and Secondary Education Act of 1965 (ESEA). The law defines Parent and Family Engagement as the participation of parents in regular, two-way, and meaningful communication involving student academic learning and other school activities, including ensuring—
Schools and districts share three primary responsibilities under Title I Parent and Family Engagement Policy:
Part I. Providing Information
It is the school’s (or district’s) responsibility to make sure that information provided to
parents is:
In accordance with Title I regulations, each Title I school is required to develop and annually update a School-Parent-Student compact jointly with school administrators, teachers, parents, and family members. The compact will provide an outline to enable the school and parents (to include family members) to share responsibility for student performance and success. The School-Parent-Student Compact includes the "Parent's Right to Know" and to inquire about the professional qualifications of the student's classroom teachers and paraprofessionals as appropriate.
The compact is made available to all students at the beginning of each school year as new students enroll throughout the school year. The compact is required to be signed and retained at the local school. All involved parties are encouraged to discuss the contents of the compact.
The compact will be reviewed and evaluated annually.
What is a Parent and Family Engagement Plan?
It is a portion of the school and district Continuous Improvement Plan (ACIP) identified as “Strategies to Increase Parent and Family Engagement” which describe effective strategies that will strengthen the quantity and quality of Parent and Family Engagement.
The plan must describe how each school shall:
How often should the Parent and Family Engagement plan be reviewed and revised?
It should be reviewed throughout the year to ensure the plan is being implemented, goals and objectives are being met, and revised in accordance with the ACIP.
Who should conduct this review?
The review is conducted jointly with the school and parents on the school parent advisory committee. However, all parents should be provided the opportunity to review and revise the plan.
What is the School-Parent Compact?
Each school must develop, with parent input, a school-specific agreement of how the parent, the school staff, and students share the responsibility for improved student achievement. This document is meant to formalize a partnership for the school and parents to work together to support students.
Schools are required to distribute copies of this compact to every parent, obtain parent signatures, and keep these on file. These compacts can be useful in parent-teacher conferences as a reminder of activities that parents, and students have agreed upon. Schools are also required to provide parents with a copy of the School-Parent Compact after all signatures have been obtained.
The compacts are: (1) retained at the school in the homeroom teacher’s classroom or a designated central location for use during conferences with parents and students; (2) customized for the school and grade-level; and (3) are to be updated annually.
How are the school-parent compacts to be used?
The school-parent compact is to be used by the teacher during any conference with a parent. Any comments or changes agreed upon by the parent and/or teacher that is specific to that student should be documented on the student’s compact. The compact should be viewed as a means of establishing two-way and meaningful communication between the parent and teacher.
What information should be on the school-parent compact?
All compacts must be identifiable by the current school year and school’s name. All School-Parent Compacts shall:
The School-Parent Compact is required to include six provisions under School Responsibilities: (as listed on the ALSDE School-Parent Compact Template)
to observe classroom activities.
The purpose of "Parent's Right to Know" is to ensure that parents are well-informed about the qualifications of their child's teachers and paraprofessionals, as well as the status and options for their child's school if it is identified as needing improvement. Parents have the right to request information about the professional qualifications of their child's classroom teachers, and paraprofessionals, including whether the teacher has met state qualifications and licensing criteria for the grade levels and subjects they are teaching, and whether the teacher is teaching under emergency or provisional status. The purpose of "Parent's Right to Know" is to ensure that parents are well-informed about the qualifications of their child's teachers and paraprofessionals, as well as the status and options for their child's school if it is identified as needing improvement.
The "4-Week Teacher Notification Letter": This notification should be sent to parents at the beginning of the school year or within the first four weeks of the school year. The letter should include information about the qualifications of their child's classroom teachers, such as whether the teacher meets state qualifications and licensing criteria for the grade levels and subjects they are teaching, or whether they are teaching under emergency or provisional status.
Staff and Parent Communication
Title I schools will communicate with parents and family members on a regular basis. Newsletters, teacher notes, the school marquee, conferences, personal contacts, phone calls, school messenger system and written notices will be used to establish and maintain open lines of communication with parents as needed. As much as possible, all communication will be provided in a language and format the parents can understand.
Parents are encouraged to contact the school or the child's teacher when questions or problems arise.
Parent and Family Engagement Surveys
Title I schools will distribute Parent and Family Engagement Surveys annually. Every effort will be made to collect the surveys from the parents in a timely manner by school personnel. The survey results will be used in the development of the School/District Needs Assessment.
Funds provided under Title I, Part C shall be used to address the supplemental needs of migratory children that are not addressed by services available from other Federal or non Federal programs, except those migratory children who are eligible to receive services under Title I, Part A may receive those services through funds provided under Title I, Part A, or through funds under Title I, Part C that remain after the agency addresses the needs described in the comprehensive plan.
Procedures for Intrastate (In-State) and Interstate (Out-of-State) Migrant Student Record Transfer(s)- Enrollment clerks at each school will ensure prompt transfer of student records. The sending school compiles and transfers the student's records to the receiving school in a timely manner. The records should include information on coursework completed, assessments, special education services, and other pertinent details.
The sending school in Alabama should promptly compile and transfer the student's records to the receiving school in the new state. The records should include all relevant educational and health information.
Recruitment: Migrant student recruitment procedures are designed to identify and support students who come from migrant families, ensuring they have access to quality education. MCS will streamline the enrollment process to accommodate the mobility of migrant students. Schools will provide assistance with documentation and offer flexible enrollment procedures, particularly for mid-year enrollments. MCS collaborates with other state agencies, social workers, community organizations, and schools to provide comprehensive support to migrant students. Schools will regularly assess the progress and well-being of migrant students to determine if the provided support is effective and make necessary adjustments. The goal of MCS is to ensure that migrant students receive a quality education and the necessary support to overcome the challenges associated with their mobility.
A program under this subpart that supplements the number of hours of instruction students receive from State and local sources shall be considered to comply with the supplement, not supplant requirement without regard to the subject areas in which instruction is given during those hours.
PREPARING, TRAINING, AND RECRUITING HIGH QUALITY TEACHERS AND PRINCIPALS
The purpose of Title II, Part A is to increase the academic achievement of all students by helping schools and districts improve teacher and principal quality and ensure that all teachers are profession ready. Through the program, State and local educational agencies (SEAs and LEAs), and State agencies for higher education (SAHEs) receive funds on a formula basis. Eligible partnerships consisting of high-need LEAs and institutions of higher education (IHEs) receive funds that are competitively awarded by the SAHE.
In exchange, agencies that receive funds are held accountable to the public for improvements in academic achievement. Title II, Part A provides these agencies with the flexibility to use these funds creatively to address challenges to teacher quality, whether they concern teacher preparation and qualifications of new teachers, recruitment and hiring, induction, professional development, teacher retention, or the need for more capable principals and assistant principals to serve as effective school leaders.
The Morgan County Schools system professional development plan is designed to ensure that all teachers are qualified and effective. The development of this plan includes activities based on the Alabama Educator Standards:
Standard 1: Effective professional development organizing adults into learning communities whose goals are aligned with those of the school, the district, and the state.
Standard 2: Effective professional development requiring knowledgeable and skillful school and district leaders who actively participate in and guide continuous instructional improvement.
Standard 3: Effective professional development requiring resources to support adult learning and collaboration.
Standard 4: Effective professional development using disaggregated student data to determine adult learning priorities, monitor progress, and help sustain continuous improvement.
Standard 5: Effective professional development using multiple sources of information to guide improvement and demonstrate its impact.
Standard 6: Effective professional development preparing educators to apply research to decision making.
Standard 7: Effective professional development using learning strategies appropriate to the intended goal.
Standard 8: Effective professional development applying knowledge about human learning and change.
Standard 9: Effective professional development providing educators with the knowledge and skills to collaborate.
Standard 10: Effective professional development preparing educators to understand and appreciate all students, create safe, orderly and supportive learning environments, and hold high expectations for their academic achievement.
Standard 11: Effective professional development deepening educators’ content knowledge, provides them with research-based instructional strategies to assist students in meeting rigorous academic standards, and prepares them to use various types of classroom assessments appropriately.
Standard 12: Effective professional development providing educators with knowledge and skills to involve families and other stakeholders appropriately.
The professional development will be directly focused on helping to achieve student learning goals and supporting student learning needs as identified through the district and local schools Continuous Improvement Plan process. The district instruction team in partnership with other district and school staff will provide job embedded school-based professional learning offering teacher choice options where appropriate and possible.
The content of professional development programs will be based on organizational needs. This consists of training for administrators, counselors, library media specialists, instructional partners, as well as, strategies for the integration of technology with classroom instruction. A focus on the following categories and the connections among them will establish relevant and meaningful goals and objectives for the learning experience: Safety, Culture, and Instruction along with, Instructional Leadership, Curriculum Development, Instructional Practices, Understanding the Learning Process, and Assessment.
The purpose of Title Ill, Part A grant is to improve the education of limited English proficient children by assisting the children to learn English, meet challenging State academic content and meet student academic achievement standards.
This purpose is accomplished by:
• Providing activities that use evidence based approaches and methodologies to teach EL children;
• Developing and implementing new language instruction educational programs and academic content instruction programs for EL children, including programs of all age groups, early childhood through secondary;
• Carrying out highly focused, innovative, locally designed activities to expand or enhance existing language instruction educational programs and academic content instruction programs for EL children; with careful consideration of the English Learner’s least restrictive environment.
• Implementing, within an individual school, schoolwide programs for restructuring, reforming, and upgrading all relevant programs, activities, and operations relating to language instruction educational programs and academic content instruction for EL children.
• English Learner Exit Forms: Morgan County Schools provide students with documentation that they have successfully passed the Access Test with a minimum score of 4.8.
• English Learner 4-year Monitoring: Morgan County Schools provide monitoring of exited English language learners for the required four years after successfully Exiting the program.
According to ESSA, an EL is an individual who
-English Learner Supplemental Services Waiver Procedures: Parents or guardians must formally request a waiver of supplemental Title III services for their child. This request may need to be submitted in writing to the school or district administration.
The purpose of Title IV is to provide funding to improve the academic achievement of all students by increasing capacity for Morgan County, its schools, and communities.
This purpose is accomplished by:
• Providing all students with access to a well-rounded education;
• Improving school conditions for student learning;
• Improving the use of technology in order to enhance academic
outcomes and digital literacy of students.
Morgan County works to ensure the federal laws and requirements are applied in a consistent and appropriate manner to meet the needs of students as required by federal grants.
Budget Development for Federal Grants
The following sources are used to collect data and to develop budgets for federal grants:
• Comprehensive Needs Assessment
• Evaluation results
• Alabama School Improvement Plan (ACIP)
• District Strategic Improvement Plan
• Staffing needs
• Grant requirements
• Carryover, if applicable
• Budget development meeting with school and district administrators
Data is compiled on the budget worksheet and Harris (financial management software) to ensure budgeted amounts match allocations. The data is then used in the submission of the online eGap Grant application. Budgeting projections are performed by the Federal Programs Coordinator. Data entry into the online eGap Grant application is performed by the Federal Programs Staff. The certification and submission of the completed online eGap Grant application is performed by the Federal Programs Director, Federal Programs Coordinator, the Chief School Financial Officer and Superintendent.
All expenditures utilizing Federal funds must comply with Federal Cost Principles. All costs must:
• Be necessary and reasonable for proper and efficient performance and administration of Federal awards;
• Be allocable to Federal awards under the provisions of the Federal cost Principles;
• Be authorized or not prohibited under State or local laws or regulations; • Conform to any limitations or exclusions set forth in the Federal Cost Principles, Federal laws, terms and conditions of the Federal
award, or other governing regulations as to types or amounts of
cost items;
• Be consistent with policies, regulations, and procedures that
apply uniformly to both Federal awards and other district
activities;
• Be accorded consistent treatment. A cost may not be assigned to a 9
Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost;
• Except as otherwise provided for in the Federal Cost Principles, be determined in accordance with generally accepted accounting
principles;
• Not be included as a cost or used to meet cost sharing or matching requirements of any other Federal award in either the current or a
prior period, except as specifically provided by Federal law or
regulation;
• Be the net of all applicable credits;
• Be adequately documented.
The Federal Programs Director will refer to the applicable program guidelines issued by the Alabama State Department of Education to determine allowable use of grant funds and ensure that expenditures do not violate the Supplement Not Supplant requirement. In addition, the Federal Programs Director and Director of ESSER will ensure that costs are allowable according to the program guidelines and conform to the Federal Cost Principles prior to approval of any expenditure with Federal funds.
Preparation for any budget process begins with determining a combination of improvements, expansion of services and or sustainability in providing support for any organization.
A Comprehensive Needs Assessment will be created by each school and by the Central Office Administrators in the district. The Comprehensive Needs Assessment is a systematic effort to acquire an accurate, thorough picture of the strengths of a school community that can be used in response to the identified educational needs of students. Every effort must be made to collect and review all data available to make appropriate decisions for the student body. The comprehensive needs assessment should be the centerpiece of the planning process - the database from which the planning team develops its vision of the future. Assessing needs comprehensively means getting the full breadth of information for depth of understanding. The Comprehensive Needs Assessment is submitted to the Federal Programs Director.
Conducting a CNA
• Clarify the Vision of the school/district
• Create a School/district Profile
• Determine Data Collection Methods
• Collect and Summarize Data
• Analyze Data - Identify Needs and Set Goals
• Implement Strategies and Evaluate Progress
Stakeholders
• Administrators
• Teachers
• Parents and Family Members
• Community Leaders
• District Administration
Documentation Required
• Agenda with date, time and location
• Sign-in sheet (participant name, role, signature
• Title of meeting, date, time and location
• Meeting minutes/summary with date
• Completed Comprehensive Needs Assessment Form
An annual evaluation of the results achieved by the schoolwide programs and revision of the schoolwide plan based on that evaluation must be conducted at the end of each school year. The district/schools are required to develop a District or School Improvement Plan based on the needs identified in the district/schools needs assessments. The district/school improvement plan should include the Components of a Schoolwide Plan as described in the Cognia eProve online based program.
Expenditure reports will be created and approved by the Chief School Financial Officer. The CSFO shall be responsible for gathering the applicable data and preparing the required expenditure reports for all Federal awards. The Chief School Financial Officer shall be responsible for reviewing and approving required Federal expenditure reports and for ensuring that these reports are submitted before the required deadline.
The Chief School Financial Officer will grant final approval for drawdowns through the certification process of the ALSDE. The CSFO will review cumulative expenditures for Federal grants and request any necessary drawdowns on a monthly basis. This review should occur after the processing of monthly payroll. The CSFO will ensure the drawdown request will not exceed the threshold amount established by ALSDE.
The CSFO will generate a General Ledger Summary report in Harris for each Federal grant. The actual expenditures will be totaled by object code. Any payroll liabilities that appear in the balance sheet accounts will be deducted. This will prevent drawing more cash than has actually been expended.
The CSFO will then complete the required documentation used to track grant program year expenditures. Each grant is tracked on a separate worksheet. Every draw will be recorded on the appropriate worksheet. This will allow the Chief School Financial Officer to determine the last time a draw was made. If cumulative expenditures have increased since the last draw, a new draw is required.
The CSFO will keep records of Cash Receipts for the district and will be informed of each draw and to which account code(s) to post the revenue.
Audit trail ledgers will be reconciled by the CSFO to confirm that expenditures only are requested.
A final expenditure report will be submitted on the ALSDE Grant Expenditure Reporting website by the deadline set for each program. The final expenditure report for federal grants will be performed by the Chief School Financial Office. The expenditure monitoring for the federal grants will be performed by the Chief School Financial Officer, Federal Programs Director, and Director of ESSER.
ESSA (Every Student Succeeds Act) Federal Grant Application the Director of Federal Programs completes the application according to the guidelines provided and specific to the grant. A Comprehensive Needs Assessment is conducted pertinent to the application. Information collected from all present is discussed and entered in the application. Documentation of attendance, agenda and minutes are kept by the Federal Programs Coordinator. Once the application is approved it will be reviewed on an ongoing basis to determine if amendments are needed.
Obligation of Federal Funds and Effective Date for use of Funds
The Federal Programs Staff will monitor purchase orders and expenditures to ensure the timing of obligation of federal grant funds comply with federal requirements
Title I, Part A Schoolwide Programs
The Federal Programs Staff will prepare a proposed budget covering all estimated needs of the program for the following school year. The preparation of the budget will include consultation with the Title I Advisory Committee made up of school administrators, parents, teachers, support staff, district administrators and federal programs staff. The budget adoption will meet all timelines required by law. The grant allows for a 15% of its entire entitlement in Title I, Part A funds to be rolled forward and/or carried over during the grant period. The district will make every effort to spend all its entitlements to address the needs of students in a timely manner. The Federal Programs Coordinator meets with each school administrator to finalize proposed federal budgets.
In a schoolwide program, the school must use Title I, Part A funds to support activities that address specific educational needs of the school identified by the needs assessment and articulated in the school's Continuous Improvement Plan.
Funds are allocated to private schools as per state and federal guidelines, when private schools choose to participate. MCS is the fiscal agent and must maintain control of all federally funded purchases for materials, property, and equipment. This will be addressed in the Inventory section.
MCS will hire and oversee all staff providing instructional services to non-public school students. MCS funds for non-public school educational services shall be obligated within the same fiscal year received. MCS shall provide to non-public school officials a written explanation for disagreements.
MCS must ensure all non-public school program services meet the needs (according to data) of the students/staff and are reasonable, necessary, allowable, allocable, and meet all Education Department General Administrative Regulation (EDGAR)requirements. Non-public school officials shall have the right to file a formal complaint with the ALSDE if the LEA did not provide due consideration to non-public school official views or did not make decision(s) that treat non-public school/students equitably (after documented attempts to collaborate and reach an agreement with the LEA are not successful).
Equitable Services are not influenced by religious, political, or specific belief systems, and aim to be impartial and pragmatic. Title I equitable services are secular, neutral, and non-ideological and makes decisions without being swayed by religious, political, or ideological considerations, focusing instead on practical and inclusive solutions.
Morgan County Schools does not charge non-public school stakeholders for any services.
Morgan County implements provisions for equitable participation of private school children. Morgan County contacts all private schools in the spring. After timely and meaningful consultation with private school officials, the district offers equitable services to eligible private school children, their teachers, and their families through the development of the Equitable Services Implementation Plan. Equitable services are monitored and enforced by the ALSDE and guidance from MCS.
The Federal Programs Director and Professional Development Coordinator will communicate with district staff including the Curriculum & Instruction Director, School Improvement Specialist, and Personnel Director on the Title II, Part A grant application and entitlements. The Federal Programs Director and Coordinator, in collaboration with district staff, will prepare a proposed budget covering all estimated needs of the program for the following year. The preparation of the budget will take into consideration the needs assessment and apply the needs in defining the program activities and strategies supported through Title II, Part A grant requirements. The budget adoption will meet all timelines required by statute. The Chief School Financial Officer will approve this. budget to cover all required activities and expenditures according to the Title II, Part A grant for the coming year.
The Federal Programs Director will communicate with the district staff including Curriculum & Instruction Director and EL staff on the Title III grant application and the entitlement amount. The Federal Programs Director in collaboration with the district staff will prepare a proposed budget covering all estimated needs of the program for the following school year for Title Ill, Part A. The preparation of the budget will take into consideration the Comprehensive Needs Assessment and apply the needs in defining the program activities and strategies supported through the Title III, Part A grant requirements. The budget adoption will meet all timelines required by statute.
The Chief School Financial Officer will approve this budget to cover all required activities and expenditures according to the Title III, Part A grant for the following school year. Morgan County is currently in a consortium with Phenix City and Troy City Schools.
The Federal Programs Director and At Risk/Attendance Director will communicate with the district staff including the Curriculum & Instruction Director, Student Services Director, Personnel Director, Technology Director, and Professional Development Coordinator on the Title IV grant application and the entitlement amount. A proposed budget covering all estimated needs will be developed for the following school year for Title IV, Part A. The preparation of the budget will take into consideration the Comprehensive Needs Assessment and apply the needs in defining the program activities and strategies supported through the Title IV, Part A grant requirements. The budget adoption will meet all timelines required by statute.
The Chief School Financial Officer will approve this budget to cover all required activities & expenditures according to the Title IV, Part A grant for the following school year.
Morgan County ensures all compliance requirements are met for the federal grants. Documentation is kept on-file. The uploaded data and files are reviewed by the Federal Programs Staff on an ongoing basis and the data is used to meet compliance purposes.
Eligible schools are able to use their Title I, Part A funds, in accordance with the number of economically disadvantaged students per school. These funds are used to upgrade the entire educational program of the school and to raise academic achievement for students. These funds are used consistently in compliance with all statutory and regulatory requirements in a schoolwide program.
Any services that a district is required to provide under state law, Alabama State Department of Education, or local policy must be provided using state or local funds. If federal funds are used to provide those services, the USDE will presume that a supplant has occurred.
Morgan County uses the Foundation Program weighted grade divisors which are established for kindergarten through grade 12. The grade divisors include an
adjustment for weighing special education and career technical educators to reflect increased programmatic costs. Local units are distributed based on enrollment variations, school size, educational programs and needs of students based on annual needs assessment and continuous improvement plans of each school. Variations are to serve the needs of students and education programming.
The Federal Programs Director and Chief Financial Officer reviews allocations and distribution of local units to ensure that any variations in allocations are not due to a school's participation in Title I.
The Title I, Part A Comparability of Services report is an accountability requirement. The district will complete the report, as required by the Alabama State Department of Education (ALSDE) and it will be reviewed by the Federal Programs Director and the Superintendent prior to submission. The report will be completed and submitted by the Federal Programs Director.
The report is also generated during the budget process, more than once, to project comparability and ensure compliance, but will be finalized to meet submission deadlines as required. The measurements used to determine comparability are identified by the ALSDE. The measures and instructions will be adhered to and no deviations will occur. Any required adjustments will be made prior to the submission of the report.
All purchases must follow Board Policy. The Board shall ensure equity in services among campus programs and shall maintain appropriate records reflecting equity. Equity shall be maintained Districtwide in one of the following areas:
• Expenditures of money per student from state and local funds; • Instructional salaries per student from state and local funds;
• Instructional staff/student ratios.
The Morgan County School District general management costs are costs and activities that are for the direction and control of the district affairs that are organization wide, such as central accounting services, payroll preparation and personnel management. Indirect cost will be applied to grants in accordance to grant guidelines and at the approved rate stated in the guidelines.
Carryover funds are budgeted in one of the following:
• District-wide initiatives
• PPA to Title I Schools
• Combination of District-wide initiatives and PPA
The appropriations made with the carryover will be based on the identified needs and recommendations made by the district and/or schools. The carryover funds will be appropriated by the Federal Programs Staff and will be expended accordingly in a timely manner. The Federal Programs Staff will verify the appropriations have been placed in the correct account code(s).
The Federal Programs Director will ensure the carryover funds are distributed appropriately. Documentation of expenditures will be maintained by the Federal Programs Staff to ensure all activities are in compliance with federal requirements. Federal Programs staff will ensure all activities are allowable and meet the federal requirements. Monthly budget/account reports will be reviewed for compliance as well.
The Elementary and Secondary Education Assistance Act of 1965 (ESEA) reauthorized by the Every Student Succeeds Act of 2015 (ESSA) requires, among other things, that Local Educational Agencies (LEAs) implement and maintain financial management systems that substantially comply with federal systems management requirements. These requirements, detailed in 2 C.F.R., Part 200.62- Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 C.F.R., Part 200) states that LEAs shall provide: "effective control over and accountability for all funds, property, and other assets. Recipients shall adequately safeguard all assets and assure they are used solely for authorized purposes".
The requisition for the purchase of equipment should follow the LEA's internal control procedures. Procedures should be in place to ensure prior approval of all purchases and provide specifications for receiving the equipment and issuing the equipment to the proper locations.
• All district purchases must follow the procedures outlined in
Financial Procedures for Local Schools
• All district/school purchases will be made with an approved
purchase order. The district will assume no responsibility for
purchases made without an approved purchase order.
• Purchase orders will be processed through the Harris Finance System.
• District/school purchases must be made to approved vendors and must comply with state, federal and local purchasing guidelines.
• Purchase orders may require approval at the central office level by the Technology, Federal Programs, Curriculum & Instruction,
Special Education Departments or the Superintendent.
• Purchase orders must be processed at the school/district level
with sufficient time to allow for delivery of the materials and /or
equipment within the required time.
• If an attachment is required for purchase order the
school/department must attach all completed documents to the
request via finance system procedures
Once approved, the school or department will forward fully approved purchase orders to the vendor.
• complete vendor information
• quantity
• unit price
• shipping and handling costs
• contract codes (if applicable)
• commodity codes (if applicable)
• ACIP (Goal, action step, or strategy)
• correct account coding
• reasonable and accurate descriptions
• discounts (if applicable)
• and completed approved attachments
The person requesting to purchase an item completes a Morgan County Requisition. The requisition goes to the supervisor of those funds. The requisition is approved or denied. If approved, the requisition is sent to the CFSO for final approval. The requisition contains the item being purchased and the fund source used for payment. The requisition is sent to accounting where it is transferred to a purchase order. The items are ordered by department head or designee and contain the information on the requisition. The items are delivered to the appropriate address. The person checking off the items utilizing the PO will sign the PO, as well as the packing slip, and return it to accounting. Accounting will pay for the items that were received. All documentation is kept in the bookkeeper and accounting office.
Items purchased at a price of $100.00 to $4,999.00 will be inventoried with asset ID stickers. Each item will have the funding source, purchase order and date notated on it. This information, along with all purchase order information will be entered into the district inventory system.
Equipment procedures, whether acquired in whole or in part under a Federal award, are checked annually, at the end of the year, and are as follows:
(1) A description of the property;
(2) A serial number or other identification number;
(3) The source of funding for the property (including the FAIN);
(4) Who holds the title;
(5) The acquisition date and cost of the property;
(6) The present location;
(7) Use and condition of the property
(8) The above information will be kept in a spreadsheet, on the PO, and/or our Asset Management system;
(9) And any ultimate disposition data including the date of the disposal and sale price of the property.
All equipment must remain at the school until all salvage or transfer requirements have been met and approved by the Federal Programs Director and/or the Chief School Financial Officer or designee. ·
All requests to salvage poor, broken, or obsolete equipment must have a Fixed Assets Transfer form completed by the school. It must include the funding code and purchase order number in order to comply with procedures.
Procedures for Disposition of Inventory
When an item is broken beyond repair or repair cost would be greater than replacement, a school will request the removal of an item from inventory by completing the Inventory Deletion Form.
Once the completed form is received and reviewed by Federal Programs, the item is removed from inventory. When necessary, the correct department is notified, and removal is scheduled with the school.
**Equipment items with an acquisition cost/current per unit fair market value of less than $5,000 and are more than three years old may be retained, sold, or disposed of, with no further obligation to ALSDE. The disposition of such items should be noted on the equipment inventory maintained by the LEA.
2 C.F.R. Part 200.313 (d)(3) requires that a control system be developed by recipients of federal funds to ensure that there are adequate safeguards to prevent loss, damage, or theft of the property, including real property, equipment, and pilferable Items.
Schools will notify the Federal Programs Department should an item be lost, damaged, or stolen and maintain documentation of notification of loss,
damage, or theft of equipment, and if appropriate, any police reports. Item will be removed from inventory if not recovered.
Funds from several federal programs may be used to purchase materials and equipment to meet the needs of participating (students eligible to receive services) private school students. It is important to remember that although the equipment may be used by the private school, the LEA purchasing the equipment retains title and must continue to account for the equipment in its inventory management system. The ALSDE shall require all LEAs serving private school children to implement adequate procedures and internal controls to account for inventory – labeled, used for authorized purposes, safeguarded from non-authorized use, kept in good condition, disposed of following LEA procedures, accounted for within the yearly physical inventory, and removable from the non-public school. ESSA §1117 & ESSA §8501 & 34 CFR §76.651 & 2 CFR §75.618 & 2 CFR §200.302 & 2 CFR §200.303 & 2 CFR §200.313 & 2 CFR §200.314
An employee whose salary and wages are supported, in whole or in part, with Federal funds is required to document their time spent working on Federal programs. The submitted documentation is used to ensure that charges reflect an accurate account of the employee’s time and effort devoted to each Federal program.
100% Certification Documentation for One or Multiple Fund Source
Employees who work 100% of the time on a program or activity and are paid through a single or multiple Federal award(s) or cost objective(s) must complete a 100% Certification Form on a quarterly basis. The form will include all fund sources paid from and signed by their supervisor after the work is completed. The document is submitted to the Federal Programs Clerk quarterly basis after time worked.
Some examples of multiple cost objectives include:
● More than one Federal award
● A Federal award and a non-Federal award
● An indirect cost activity and a direct cost activity
● Two or more indirect activities that are allocated using different allocation bases ● An unallowable activity and a direct or indirect cost activity
100% Certification Letters
Step 1:
Federal Programs Administrative Assistant/Bookkeeper generates a Gross Employee Salary Report for employees paid with any federal funds. Reports are generated semi-annually.
Step 2:
Administrative Assistant verifies reports and names are added to Federal Programs Time and Effort Tracking Log.
Step 3:
Letters are prepared and distributed by the Federal Programs office quarterly.
Step 4:
Listed personnel and administrator/supervisors date and sign letter. Letters are returned to the administrative assistant as well as PAR reports or Time and Effort tracking logs.
Step 5:
Returned letters are reviewed and signed by the Federal Programs Coordinator.
Substitutes and Stipends
Miscellaneous payroll forms will reflect that person(s) attest that 100% of the time reflected on the payroll form was spent on allowable Title I activity aligned with the improvement plan of the school.
Employment Survey
The "Alabama State Department of Education Employment Survey" is required to be completed at the beginning of the school year for all students in Kindergarten and students that are new to our system and throughout the school year as students new to our system are enrolled. The completed surveys will be collected by the SDE through the use of PowerSchool data and reporting.
Each Title I school will hold an annual meeting during the first semester of the new school year for all parents and family members. The Title I program will be described, the Parent and Family Engagement Policy (Spanish) will be discussed, and opportunities for participation will be explained. The annual meeting will be held at a convenient time and location; notice of the meeting will be provided through
written invitations to parents/caregivers and through public notices. Translators will be present at the meeting if needed.
Morgan County Schools utilizes the contract provisions below as applicable for contracts. Finance department director collaborates with appropriate staff to ensure appropriate contract processes and procedures are followed. Federal programs coordinator participates in regular meetings with finance department staff to ensure compliance as appropriate.
Contracts for more than the simplified acquisition threshold ($15,000) must address administrative, contractual, or legal remedies in instances where contractors violate or breach contract terms, and provide for such sanctions and penalties as appropriate.
All contracts in excess of $10,000 must address termination for cause and for convenience by the non-Federal entity including the manner by which it will be effected and the basis for settlement.
Equal Employment Opportunity. Except as otherwise provided under 41 CFR Part 60, all contracts that meet the definition of “federally assisted construction contract” in 41 CFR Part 60-1.3 must include the equal opportunity clause provided under 41 CFR 60-1.4(b).
Davis-Bacon Act. When required by Federal program legislation, all prime construction (remodeling) contracts in excess of $2,000 awarded by non- Federal entities must include a provision for compliance with the Davis-Bacon Act. In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland “Anti-Kickback” Act.
Contract Work Hours and Safety Standards Act (40 U.S.C. 3701-3708). Where applicable, all contracts awarded by the non-Federal entity in excess of
$100,000 that involve the employment of mechanics or laborers must include a provision that each contractor must be required to compute the wages of every mechanic and laborer on the basis of a standard work week of 40 hours. Work in excess of the standard work week is permissible provided that the worker is compensated at a rate of not less than one and a half times the basic rate of pay for all hours worked in excess of 40 hours in the work week. The requirements of 40 U.S.C. 3704 are applicable to construction work and provide that no laborer or mechanic must be required to work in surroundings or under working conditions which are unsanitary, hazardous or dangerous. These requirements do not apply to the purchases of supplies or materials or articles ordinarily available on the open market, or contracts for transportation or transmission of intelligence.
Rights to Inventions Made Under a Contract or Agreement. If the Federal award meets the definition of “funding agreement” under 37 CFR § 401.2 (a) and the recipient or subrecipient wishes to enter into a contract with a small business firm or nonprofit organization regarding the substitution of parties, assignment or performance of experimental, developmental, or research work under that “funding agreement,” the recipient or subrecipient must comply with the requirements of 37 CFR Part 401
Clean Air Act (42 U.S.C. 7401-7671q.) and the Federal Water Pollution Control Act (33 U.S.C. 1251-1387). Contracts and subgrants of amounts in excess of $150,000 must contain a provision that requires the non-Federal award to agree to comply with all applicable standards, orders or regulations issued pursuant to the Clean Air Act and the Federal Water Pollution Control Act as amended. Violations must be reported to the Federal awarding agency and the Regional Office of the Environmental Protection Agency (EPA).
Debarment and Suspension. A contract award must not be made to parties listed on the governmentwide exclusions in the System for Award Management (SAM), in accordance with the OMB guidelines at 2 CFR 180 that implement Executive Orders 12549 and 12689,
“Debarment and Suspension.” SAM Exclusions contains the names of parties debarred, suspended, or otherwise excluded by agencies, as well as parties declared ineligible under statutory or regulatory authority other than Executive Order 12549
Byrd Anti-Lobbying Amendment (31 U.S.C. 1352). Contractors that apply or bid for an award exceeding $100,000 must file the required certification.
Procurement of recovered materials. The requirements of Section 6002 include procuring only items that contain the highest percentage of recovered materials practicable, consistent with maintaining a satisfactory level of competition, where the purchase price of the item exceeds $10,000 or the value of the quantity acquired during the preceding fiscal year exceeded $10,000; procuring solid waste management services in a manner that maximizes energy and resource recovery; and establishing an affirmative procurement program for procurement of recovered materials identified in the EPA guidelines.
Prohibition on certain telecommunications and video surveillance services or equipment.
As guided by Appendix II to 2 CFR Part 200 and 2 CFR part 200.216 and in addition to other provisions required by the federal agency or non-federal entity, all contracts made by MCS under the federal funding will not procure or obtain; extend or renew a contract to procure or obtain; or enter into a contract or extend or renew a contract to procure or obtain equipment, services, or systems that use covered telecommunications equipment or services as a substantial or essential component of ny system, as as critical technology as a part of any system. District federal programs department will collaborate with the technology and finance departments to ensure compliance with this regulation and follow procedures for technology purchases and contracts related to telecommunications and video surveillance services or equipment.
Domestic preferences for procurements. As appropriate and to the extent consistent with law, the non-Federal entity should, to the greatest extent practicable under a Federal award, provide a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States. The requirements of this section must be included in all subawards including all contracts and purchase orders for work or products under this award.
LEA Process for Oversight of Contractors
Morgan County Schools monitors the work of contractors to ensure that work is performed in accordance with agreements and Federal requirements for all projects funded with federal funds. Appropriate program supervisor oversees the contractors as appropriate for the project funded with the program they supervise. As the work is completed, such supervisor inspects each step according to agreement and specifications to compare the work and ensure it was performed according to such agreement and federal requirements. Invoices for any projects are not paid until the appropriate program supervisor inspects the work of contractors to ensure that work is performed in accordance with agreements and Federal requirements for all projects funded with federal funds.
LEA Non-Competitive Procurement Procedures
Morgan County Schools utilizes state and federal guidance for all non-competitive procurement processes. Based on such guidance, non-competitive procurement can only be awarded if one or more of the following circumstances apply:
LEA Domestic Procurement Preference Procedures
As appropriate and to the extent consistent with law, Morgan County Schools, to the greatest extent practicable under a Federal award, provides a preference for the purchase, acquisition, or use of goods, products, or materials produced in the United States. The requirements of this section must be included in all subawards including all contracts and purchase orders for work or products under this award. Appropriate program supervisor coordinates domestic procurement preference with the finance department prior to making any purchases to ensure the above guidance is followed. Finance department staff and federal programs staff monitor compliance with domestic procurement preference, as applicable.
LEA Cost Price Analysis Procedures
Morgan County Schools performs a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. As needed, MCS negotiates profit as a separate element of the price for each contract in which there is no price competition and in all cases where cost analysis is performed.
Appropriate program supervisor consults with the outside professionals in the area where service is sought for the price estimates to create a budget for the project. Once the baseline budget is created, the program supervisor follows district, state, and federal guidance to initiate the price-cost analysis with the involved vendors or contractors. Once the estimated from the vendor/contractor are received, MCS finance department staff considers for following factors for price-cost analysis: complexity of the work to be performed, the risk borne by the contractor, the contractor’s investment, the amount of subcontracting, the quality of its record of past performance, and industry profit rates in the surrounding geographic area for similar work. Once these considerations are reviewed for each vendor/contractor submittal, MCCS finance staff makes the decision to give the award to the most responsible price.