Background: A County School District (CSD) was awarded $224,875 in 21st Century Community Learning Center (21st CCLC) grant funding for both fiscal years 2008-09 and 2009-10. The 21st CCLC Program was created as the only federal funding source dedicated exclusively to after-school programs. The program was established to provide a wide range of high-quality out-of-school services specifically focused on helping students meet state and local academic achievement standards in core academic subjects. Services are targeted to low-income students attending low-performing schools, and include both academic enrichment and additional services that reinforce and complement the regular school day. Programs also bolster communities by offering opportunities for literacy and related educational development to families of active program participants. By law, 21st CCLCs provide services only during non-school hours or periods when school is not in session. Programs funded with 21st CCLC grants must meet the following minimum performance standards: serve proposed numbers of targeted student participants; meet proposed levels of program operation; and provide the requisite hours of operation. Programs must demonstrate sufficient progress toward accomplishing program objectives by submitting semi-annual data. Funding levels are based largely upon proposed student attendance levels and hours of operation. Federal guidelines stipulate that failure to perform at operational levels as proposed in the approved grant application may result in reduced levels of funds.
Findings: Records obtained from the 21st CCLC program in the CSD indicate that the average number of students in attendance for the month of May 2010 was only 24.35, a figure substantially less than the proposed daily level of 100 students. Summer attendance levels forecasted in the contract indicated that an average of 90 students would be served daily, to include 60 students with disabilities. However, the average attendance for the month of June 2010 was only 39.92 students. End of year self-report data submitted to the Department indicated an average daily attendance of 12 during 2009-10. According to the program management, the CSD program started late during the first year and reported improved attendance levels during the summer of 2009 (53 students per day). Consequently, the Department decided not to reduce funding for the second year. However, the Department appropriately reduced the maximum award for the third year because the CSD fell short of meeting the “80% threshold rule for daily attendance in 2009-10” and the CSD County dissolved the program.
In terms of program operation, the CSD did not fully comply with the legal and regulatory requirements that stipulated that 21st CCLC programs must provide opportunities “to help student achievement … meet state and local student achievement standards in core academic subjects, such as reading and mathematics.” The 21st CCLC grant requires that providers must offer remedial education and academic enrichment, to include a strong reading, mathematics, and science component delivered by ce11ified teachers. During the months of November 2009 and March 2010, an examination of the CSD’s lesson plans revealed that an insufficient amount of time was spent teaching core competencies. A disproportionate amount of time was devoted to the instruction of art, music, recreation, and entrepreneurial education in the after-school program. Although a computer lab was available to students in the after-school program, the extent to which students were utilizing the reading and math software to further remediate in core content areas was unclear.
Additionally, the grant program required that after-school programs must afford students 12 full hours of impact programming per week. It is apparent that only 1 to 2 hours per day of programming was offered based on the CSD data. The State OIG recommended that consideration be given to providing funds to higher risk sub-recipients on a reimbursement basis only. More stringent reporting requirements would help detect problems sooner.
Our focus in this course has been on foundation grants but grant management requirements of the federal government will play a role in your management experience.This case study is a true event taken from the Office of Inspector General public audit reports. Even the best grant manager will make mistakes that have to be addressed during the annual audit. When the Inspector General conducts an audit it means that something has gone wrong beyond the average management mistake. As Christians, we are called to be good stewards of the resources we are given. In a 2-3 page paper address the questions below. Based on what you have learned in this course how could this situation have been avoided?
1.What additional guidance and support could the Department have provided to this grantee?
2. What internal controls need to be strengthened at the CSD?
3. What could the CSD have done about their low student attendance?
4. What documentation could have been used to demonstrate their core content offerings?
5. How could this have been avoided?
OIG Audit Reports: https://www2.ed.gov/about/offices/list/oig/rpauditinvestmainpage.html