Administrators

Leadership isn’t about a title. It’s about impact, influence and inspiration.

–Susan Lytle Gilmore, Ph.D., Director of Adult Education, Sacramento City Unified School District

AEP Questions and Answers

This is a collection of questions that are most frequently asked of the AEP Office. They are organized by topic area and will be updated as needed.

Funding

Yes, at this time, there is no change but we are proposing improvements (quarterly, biannual or even annual distributions) to the legislators in order to streamline the process of use of funds and implementation of efforts.

Nothing in the bill says you cannot do a pass-through model on a quarterly basis. However, please refer to the next question.

Yes, pursuant to the LEA’s approved indirect cost rate.

It is in the online system under the Budget Change feature, just like it was under AB86. Please note, the June 20th due date for misweb budget revision is for your AEP budget changes prior to the expense report due in July. If you have made changes, you will need to update your misweb budget.

The online system expenditures must reflect actual amounts for each 6 month reporting period (it’s a cumulative reporting system).

There is no portal for budget revisions. We use the Online Financial System (misweb), which is based on the CC Chancellor’s Office system. Contact Neil if you have trouble getting into the Online Financial System. We can put a link to the Online Financial System from the portal. We intend to move to a single system eventually, but we are not there yet.

Yes. You can carryover 15/16 funding into 17/18.  Activities must end (for 15/16) BY 12/31/17.

It depends. There are many levels of transfers (see previous questions). For carry over funds, please check with your local accounting office if you wish to carry over funding into the next year. The State does not need to approve carry over funding into the next year, however 15-16 annual plans for those funds must be current.

Such program changes need to be documented in a plan revision as an amendment to your plan, as well as a budget revision. As you point out, this is not only a question of accounting, but also of intent.

No, nothing more as long as the budget change does not necessitate a plan change.

Yes, the bottom lines for Program Area, Objective, and Object Code should all be the same.  However, the online misweb financial system does not track by objectives - just object codes.

Reports of Expenditures, by Program Area and Objective, should include indirect / administration fees charged and / or anticipated. In general, Member agencies whose districts have elected to levy indirect fees against AEP allocations should spread these costs proportionally across Program Areas and Objectives, as appropriate. Consortium administration costs (subject to the 5% cap) may be reflected in a number of different ways. It is the responsibility of each Consortium to ensure the numbers submitted are an accurate and equitable reflection of the costs to administer AEP programs and services for both Members and the Consortium as a whole.

Yes, the bottom lines for Program Area, Objective, and Object Code should all be the same amounts.

MOE budgets are entered into the CDE system (SACS), and Consortium Allocations through the AEP system. Regardless of the fund name, all activities supported by AEP funds (MOE and Consortium Funds) are required to be addressed in the Three Year Plan and the Annual Plans.

Yes - even though your data and accountability work plan and budget were approved by the AEP Office - you still must enter the budget into the online miswebex system (and have it certified).

For the remaining 15-16 carry over funds - use the online expense and reporting system to revise your budget going into next year, and update your 15-16 annual plan to reflect how those funds will be spent.

Yes, fiscal agents are allowed to take a 5% indirect for consortium level activities. And yes, that 5% does include all consortium level administrative costs. Administrative costs are generally fiscal in nature.

The new fiscal system roll out will be over the course of October. You can learn about it through this webinar scheduled for October 20. 17/18 budgets won’t be due until early December. Your members will have a few months to get used to the new system. Because of the new system – we will not enforce 10/31 deadline.

We are excited to announce the soft launch of NOVA, the new platform we will use to manage the AEP fund. The AEP Office's Neil Kelly will walk through the fiscal-management system during a webinar on Oct. 20, from noon to 1 p.m. This is the registration link: https://register.aebg.org/index.cfm?fuseaction=detail&id=110

Learning how to use NOVA is critical because this is the system that each consortium member that receives AEP funds will be required to use to submit the 2017-18 budget, due in early December, provide member updates to the AEP database, and starting next year, allow members and consortia to enter and certify quarterly expense reporting. This new system, once it's up and running, will replace the AEP portal. NOVA is an end-to-end platform designed to manage state funding streams.

A team of beta users have received an email announcing the soft launch. Those of you who are not part of the test group will receive an email at the end of October, when the system officially launches, providing you with access. The following release of functionality will be AEP fiscal reporting and CFAD management, making NOVA the centralized platform for all things AEP.

Please note: AEP 2015-16 implementation funding, 95 percent of which has been spent, will be closed out in the old system in January/February 2018. AEP data and accountability funding will also remain in the old system and will be closed out in January/February 2019.

Here is the response from CDE Fiscal…..

There are no statutory provisions preventing an LEA from carrying over funds, however, a consortium may change the amount of adult education funds available in future years based on actual prior fiscal year spending.

https://www.cde.ca.gov/fg/aa/ca/adultedbgfaq.asp

This means that can hold on to the MOE portion of the AEP funds (and carry them over), per CDE, but when the State AEP Office looks at SACS to see if MOE funding has been spent in order to allocate additional funds, the consortium may be penalized for not spending.

BTW – the 15/16 AEBG implementation funds (Consortia Funds) need to be spend down by 12/31/17 – this cannot be carried over. A final report is due by 1/31/18 and the close out report by 2/25/18.

The Data and Accountability funding has been extended to 12/31/18 – with a final report due by 1/31/19 and a close out by 2/25/19. There is a midterm expense report due 1/31/18.

In NOVA, only members report their indirect. If a fiscal agent is performing activities of a fiscal nature for the consortium, those expenses can be added to the member’s indirect line item.

So if the consortium is the fiscal agent, and is also a member – then the consortium would enter their program budget 1000s to 6000s – along with their member indirect. In addition, if the consortium is also paying for the consortium fiscal activities – then you would include that budgeted item under indirect as well.

In addition, if the consortium is also paying for consortium programmatic activities – they should be budgeting in the 1000s – 6000s of the member budget. Same would hold if another member is also paying for consortium level activities.

For validating a district’s expenses – please use the agreed upon district accounting process under the Budget & Accounting Manual for community colleges.

At the consortium level – the members must develop an agreed upon consortium oversight process for certifying the member’s budget & expenses to the state.

Suggestion:

Hire an outside auditor
Have a fiscal agent
Have a peer to peer review
Look at other options

But it has to be a member agreed upon process and if audited, you will have to show how the consortium is following their agreed upon process.

In November, the AEP Office will host a webinar on the topic.

Can these funds be carried over?

There are no statutory provisions preventing an LEA from carrying over funds, however, the state or the consortium may change the amount of adult education funds available in future years based on actual prior fiscal year spending.

https://www.cde.ca.gov/fg/aa/ca/adultedbgfaq.asp

This means that can hold on to the MOE portion of the AEP funds (and carry them over), per CDE, but when the State AEP Office looks at SACS to see if MOE funding has been spent in order to allocate additional funds, the consortium may be penalized for not spending.

BTW – the 15/16 AEP implementation funds (Consortia Funds) need to be spend down by 12/31/17 – this cannot be carried over. A final report is due by 1/31/18 and the close out report by 2/25/18.

The Data and Accountability funding has been extended to 12/31/18 – with a final report due by 1/31/19 and a close out by 2/25/19. There is a midterm expense report due 1/31/18.

Last year’s trailer bill language said that all funds must be pass through to members within 45 days. You cannot use sub agreements unless you are a member that received their pass through and is contracting with another provider. The fiscal agent should not be holding any sub agreements. The chancellor’s office issued the following memo on how to pass through funds to members.

http://aebg.cccco.edu/LinkClick.aspx?fileticket=Cw-O6gUujhQ%3d&portalid=1

The legislation states that each member gets no less than the prior year. In the legislation, we release a two year budget – one for the fiscal year, and a preliminary projection for the next year. In the 17-18 & 18-19 AEBG budget, the amount for 17/18 & 18/19 were the same amount for each year.

  1. The chancellor and the Superintendent shall, when approving a schedule of allocations for a fiscal year, also present preliminary projections for the amounts that would be allocated in the subsequent two fiscal years. This preliminary presentation shall not constitute a binding commitment of funds.

If you have any 15-16 funding that is unspent – you will still need to work with your consortium lead on any budget revisions.

For 16-17 carry over and 17-18 new funds in the AEP NOVA system, we are still working on the policy for budget changes that would allow members to do without consortium approval, and budget changes that would require consortium level approval. We are looking at various cut offs / percentages of the change as we decide on the policy. Guidance will be released soon.

Yes – your consortium will be scheduled for targeted technical assistance if you miss any deadlines this year. The 12/15/17 deadline, the 1/15/18 deadline, and any other deadlines. The legislature wants us to have more accountability in the program, especially with reporting student enrollment data, financial reporting, outcomes, and cost per student.

We have had hundreds of webinar participates these past few months – more so than ever before – as we provide plenty of TA to get everyone on board. Now that we have AEP TAP– targeted TA can go forward – and the State can act on AB104 legislation if members or consortia become ineffective. I would strongly suggest to your members that they attend the various webinars or listen to the ones from the prior months, lest they get caught up missing deadlines and scheduled for targeted TA.

I would advise you use an allocation process based on some time of verifiable information from a neutral source - such as: census data, American community survey data, TOPSPro student data, MIS student data, Launchboard data (when available), EDD labor market information, etc.

The models that people used last year did not use reliable data. Some used self-reported data that caused many problems.

We have recommended an incentive funding formula to the legislature in our recent preliminary report – you may want to look at that also.

Create a $30 million performance-based incentive fund for adult education consortia:

The CDE and the CCCCO recommend that the Legislature allocate an additional $30 million for adult education to administer a performance-based incentive fund. This funding would not impact the $500 million AEP baseline investment. This strategy was a recommendation posited in the study by the Center for Law and Social Policy entitled Prosperity Through Partnership. It specifically recommends a “targeted performance bonus system to give consortia incentives to improve services to their community of need.” Although consortia are actively investing in and implementing new strategies that target their core communities, as illustrated by some of the innovations referenced earlier in this report, they face challenges with balancing investments in new programs with the need to maintain baseline levels of service in a reduced-funding environment. An incentive fund would accelerate the adoption of new integrated pathway models, support service strategies, and greater support for transition of adult education students into postsecondary education and the workforce. To support this, the AEP Office would explore and create analytics for distribution of incentive funding to consortia based on how services are targeted to a community of need and outcomes are improved. The definition of this community of need could be based on (a) combination of the traditional adult education target population definition (unemployed, no diploma, impoverished, lack of English language fluency) and (b) population barriers to employment in the WIOA (long-term unemployed, formerly incarcerated, within two years of exhausting Temporary Assistance for Needy Families, etc.). The CDE has had in place a method for determining incentives for performance since 1999 for agencies making positive progress on outcomes related to federal targets. The CCCCO recently embarked upon a field committee process to define the performance-based criteria, for the 17 percent funding, under the Strong Workforce Initiative. As a result, the AEP Office would use the same process to analyze and build the metrics for this fund.

This is still in development phase – so until we have better student data & outcomes – I can’t give you a definitive answer. Check back next summer – by then will have two quarters of data match and better idea of tools to use for your 3 year planning process.

Link to information:

http://aebg.cccco.edu/Resources/FAQ-Funding-LEA

http://aebg.cccco.edu/Portals/1/docs/Guidance%20and%20Instructions/AEBG%20Fiscal%20Management%20Guide%20112917%20FINAL.pdf

……see Section 12 – page 21

The amount that is reported as 16-17 carryover in NOVA should match what was reported in the old MIS system as of the June 30, 2017 report. You should adjust your expenditure report accordingly. In NOVA, the expenditure report for the period of July 1, 2017 – December 31, 2017 will be due on March 1, 2018. Consortium leads will need to certify by March 31, 2018.

Feel free to submit a budget change to correct 16/17 Q2 that was reported in July 2017.

The carry over amount has to match the July 2017 report for 16-17 (remaining balance).

We are not accounting year 1, year 2, year 3 anymore.

As we move to NOVA – we will have prior year carry over, and current year in one budget, one expenses report (for each quarter), and one work plan for each member for the program year in addition to the annual plan.

If your July 2017 16/17 expense report remaining balance doesn’t match the carryover of the consortium members in total – we will not approve it.

You will need to enter your entire budget, which includes your 16-17 carryover funds as well as your 17-18 allocation.

In NOVA, only members report their indirect. If a fiscal agent is performing activities of a fiscal nature for the consortium, those expenses can be added to the member’s indirect line item.

So if the consortium is the fiscal agent, and is also a member – then the State Center CCD would enter their program budget 1000s to 6000s – along with their member indirect. In addition, if State Center CCD is also paying for the consortium fiscal activities – then you would include that budgeted item under indirect as well.

In addition, if State Center CCD is also paying for consortium programmatic activities – they should be budgeting in the 1000s – 6000s of the member (State Center CCD) budget. Same would hold if another member is also paying for consortium level activities.

You will not be able to certify the member budget until the member agency submits it. Only member agency level contacts will be able to access the submit button for their agency’s workplan and budget. The member agency submits their budget and workplan, and the consortium primary contact certifies the budget and workplan (consortium primary contacts are the only users that have the ability to certify the workplans and budgets). The member agency will see the un-submit button (only after they click on submit). The consortium primary contact will only see the certify button, which will not be available until the member submits their workplan and budget.

Although we have yet to program NOVA for the end of the year exercise related to other fund sources (which includes fees), the plan is to have all members for their final NOVA expense report (Q4) – estimate the amount of funds leveraged from other adult ed related fund sources (WIOA II, CalWORKs, Perkins, Apportionment, etc.) by AEP program area. There will also be a section for fees collected in the various program areas. That’s about the extent of the discussion so far.

Members must use the indirect line item in NOVA – not object code 7000 for reporting indirect. This allows the state to calculate if the member is using the appropriate indirect rate.

The Allocation Schedule for each Consortium from the state budget will be posted within 45 days of the day the Governor signs the budget. Per AB104, only 1/12 of the allocation can be dispersed each month to consortia. We have been working with legislative staff to highlight how this hinders program roll-out and management of expenditures. We are hopeful this stipulation may change but at this point, consortia will receive 1/12 of their allocation per month whether direct funded or using a fiscal agent.

The AB104 legislation, Section 84914 does allow a consortium to reduce funding for ineffectiveness. Per the legislation, if the member has been consistently ineffective in providing services that address the needs identified in the adult education plan and reasonable interventions have not resulted in improvements, the consortium can reduce their funding. Consortium must document the reasonable interventions, and the member responses to these interventions. The consortium must share these activities with its members at a public meeting, and if a reduction is to take place that must also be documented in the meeting minutes and be agreed to by members using their governance plan.

Both MOE and Consortia Allocations have always been from the same place: the AEP. Both were always intended to carry out the approved Three-Year and Annual Plans for AEP. In the first year only, MOE was called out separately. It will not be called out separately going forward. Allocations will only be made as AEP Consortia Allocation. Starting in 16/17, there is no longer MOE - it now called Consortium funding.

On the AEP website, on the For AEP Grantees tab: http://aebg.cccco.edu/For-AEBG-Grantees

AB104 has a provision that requires that all members receive at least the same allocation every year, unless each member agrees and signs off on the allocation schedule to a different amount.

See Program Guidance for a detailed breakdown on life of the funds and reporting deadlines. The AEP Office encourages all consortia to spend the funding in the year it is received, knowing in some cases funds may need to be carried over. However, keep in mind, that the State is tracking student enrollment and outcomes on a year-to-year basis. If funding is not spent and the program is not meeting the needs of the region, your consortium and members may be deemed ineffective and funding may be reduced as a result.

All members will need to sign the CFAD, which that allocation schedule is part of. In addition, you should keep meeting minutes and attendance sheets to document that you followed the Governance Plan for your Consortium in order to reach this agreement.

No. The funds must all be allocated by May 2nd. The detail of how they will be expended, and the chance to sub-contract if needed will be due in July with the Annual Plan.

Yes. AB104 ensures no less than the prior year’s allocation.

Per AB104 legislation, the consortium is permitted to use up to 5% for administration of the consortium. This does not mean that the fiscal agent “has to” receive 5%, but instead can use up to 5%. Those activities are mostly fiscal in nature. If the MOE and Non-MOE funds are combined in 16-17, then yes, the consortium totals are larger and the potential for more administrative costs is greater. However, consortium administrative activities and their cost should be discussed and understood by the consortium members.

The AEP Office has not received a sample non-financial MOU, but as soon as it becomes available, it will be posted on the AEP website, under the Resources tab.

Community College Community Ed or Community Service Program cannot be co-mingled with AEP state funding. Community College Community Education has regulations that prevent it from using AEP funds.

Yes - if consortium members are in agreement as they move/transfer funding.  It is important that students’ needs are met to the fullest extent enabled by the funding resources, regardless of which member provides the services. That can mean sub-contracting with another member or returning the funds to the consortium for redistribution, if a member cannot utilize the money they were allocated for AEP purposes. As these are state funds, they can be rolled over for one year after the year of disbursal. See the Program Guidance for more information.

Yes. And the gap in services left by the member who is departing should be addressed by the consortium, as the money is available to support the implementation of your AEP plan.

Yes, they could. It would take a unanimous agreement from the consortium membership to do so, since no consortium member shall receive no less funding than the prior year, unless all agreed to it.

The guarantee of “no less funding than the prior year” unless otherwise agreed to is in legislation already, but if it helps to manage discussions at the local consortium level, you can certainly put that in your bylaws too.

Yes, they would receive the same amount unless the member and the rest of the consortium agree otherwise. However, if they still receive the same funding once the curriculum development is finished, their funds are still obligated to the implementation of your AEP plan and achieving the plan goals.

It is important to have the means to stabilize programs in order to consistently serve regional needs, address gaps and meet other objectives. Implementation of student-focused best practices should drive decisions in use of funds as the system seeks stability and, hopefully, future growth.

Unspent MOE funding for 15-16 would have to be subcontracted with another adult education provider within the consortium or returned to the State. If returned to the state, this money will go back into the $500 M Consortia pot for statewide redistribution. MOE money was released in 15-16, and had its own certification process. That is why MOE funds cannot revert to the consortium if unspent. In 16-17, MOE funding is rolled into the consortium allocation, and if a member is not spending their consortium allocation, it can be reallocated by the consortium using subcontracting methods. Both MOE and Consortia Funding are governed by the AEP rules and AB104 legislation.

Not necessarily, as the consortium would still need to cost out the time and effort it takes to administer the consortium level activities. Even if your consortium opts for direct funding, the State still only wants one report per consortium. The consortium would have to designate a coordinator position and resources to cover these activities. See Program Guidance for specifics on the consortium administration activities.

The “prior year” allocation figure for Year 2 is based on the total of MOE and/or Consortium Allocation in 2015-16. As a consortium, you can agree to shifts in amounts as needed if you are all in agreement.

When completing the CFAD form, consortium members must decide how to fund their consortium coordinator and other supporting staff and resources. In 15-16, the consortium coordinator was funded by various means – using either a fiscal agent structure, pooling resources from various members, or other alternatives. Whatever funding mechanism you used, that member (or members) will receive the same amount in 16-17 (using the AB104 legislative language). Please consider this when discussing how to pay for the coordinator activities in 16-17.

Yes, though other decisions can be made according to your local governance plan and any by-law agreement, decisions regarding allocation amounts have to be agreed upon by all members.

Yes, it most likely would, but be aware that a reimbursement process is NOT the model the Legislature intended. Legislative staff are stressing the intent of the fiscal agent is to run a pass-through process. The funds should be distributed directly to members and NOT provided through a reimbursement process. Please check with your fiscal staff for the most appropriate MOU or sub-agreement to pass-through funding.

It depends on many things – but it’s up to the members of the consortia to determine whether or not these partners receive funding.

Each year of AEP funding will be tracked separately – 15-16 will have code 15-328-XX in the online system. The 16-17 funding will have code 16-328-XX, and so on. Each year will be tracked online through the life of the funding – even if it’s carried over into the next year. Just don’t co-mingle 15-16 funding with 16-17 funding – the budget and expenses are to be tracked, and reported separately. We are developing a new fiscal system that will come online in 17/18.  Stay tuned for changes.

The Consortia Allocation calculation is based on the demographic data for each consortia region to determine level of need, so it already factors in the data for all areas within each region. It is a local consortia decision to determine whether the new program receives consortia funds from the amount being allocated to that region.

Mini-grants to members can be included their allocations in the CFAD, or they can be part of sub-contracting between partners. The 3-Year plan is a high level view of what your consortium hopes to achieve in this 3-year window. More detailed information is contained in each of the Annual Plans. Financial reports provide an even more detailed look into where funds were spent on what activity.

You can use existing 15-16 funding from members and subcontract for services. If you have already allocated your 16-17 funding, you can still subcontract with members for services. Remember, if the new member did not receive a direct allocation from the fiscal agent (or was direct funded), but rather receive the funding via a subcontract using another member’s funding, they are not entitled to funding in the next year. They would be treated just like any other adult education provider that has a subcontract with a member.

Yes, the Final Allocation Schedule from the state will be released within 15 days after the Governor signs the state budget. It will be posted on the AEP website. It is unlikely there will be any big changes. If you see a discrepancy, please let us know ASAP.

Consortium Funds and MOE funds were always available for all allowable activities necessary for the implementation of your Three-Year and Annual Plans. In other words, you have always been able to use Consortium Funds for operational and instructional costs, and that will continue to be the case. It is always good to enhance your funding through seeking grants and leveraging, but it is not impacted by the unification of MOE with Consortium Funds into one fund. For information on tracking expenditures, see the updated AEP Program Guidance on the Policy Guidance web page.

In the case of a K-12 adult school that didn’t have dedicated funding in prior years, this would not be considered supplanting. However, if that school is also receiving Perkins, CalWORKS, WIOA, or other fund sources – and replaces that with AEP funds – then there could be a supplanting issue. In the case of a community college that has received apportionment for courses in the seven AEP program areas, and replaces that apportionment with AEP funds - then there could be a supplanting issue.

However, if in 15-16, the member used only reserves and received no MOE or Non-MOE funding, it may be difficult to receive AEP funding in 16-17 unless other consortium members agree to give them funding from their allocations.

In the case of a K-12 adult school that didn’t have dedicated funding in prior years, this would not be considered supplanting. However, if that school is also receiving Perkins, CalWORKS, WIOA, or other fund sources – and replaces that with AEP funds – then there could be a supplanting issue. In the case of a community college that has received apportionment for courses in the seven AEP program areas, and replaces that apportionment with AEP funds - then there could be a supplanting issue.

However, if in 15-16, the member used only reserves and received no MOE or Non-MOE funding, it may be difficult to receive AEP funding in 16-17 unless other consortium members agree to give them funding from their allocations.

Yes – the consortia amounts will be larger in 16-17. AB104 legislation allows for a 5% cap related to consortium administrative activities (mostly fiscal type). Members that receive funding will also be able to charge their indirect rate. See the FAQs and link to the indirect rate and its definition. The AEP Office advises that each consortium discuss the activities and administrative costs of the consortium before making a decision on who is responsible and how much that amount will be. For more information, see the updated AEP Program Guidance.

As long as it is a unanimous consortium agreement, yes. The allocation schedule could be different year to year, depending on your consortium agreements, but the 5% total administration cap for the consortium level activities still applies.

According to AB104, the total amount received by a consortium member in the prior year is what they would receive in the following year, unless the consortium is in agreement to change it. Since fiscal agent costs are not broken out separately in the Allocation Schedule, there is no formal way to differentiate that amount. Whatever amount a member receives, it has to go to implementing your AEP plan and meeting your goals. Keep in mind, fiscal agent or not, the members are responsible to fund the consortium administrative activities and provide a point of contact to the State.

Members receive the same amount of AEP funds as they received in the prior year. If a member received funding in 15-16 to administer the consortium and now that has changed – those funds are now available to be used for AEP program related activities. If the consortium has agreed to make changes regarding Fiscal Agent or “AEP coordinator,” it is allowable if all membership agrees to this change.

Yes, that is possible. However, we need to maximize resources that go directly to students if we want to achieve the goals of AEP and keep, or even grow the funding. While having adequate administrative resources to operate the program is necessary, it is important that the maximum amount possible goes to direct services to students.

Please see the updated program guidance on this topic at: http://aebg.cccco.edu/For-AEBG-Grantees/Guidance-Regulations (updated 3/17/16, pages 13 and 14). Make sure you don’t confuse the administrative cap of 5% at the consortium level with the indirect rate allowed by members to be charged on AEP funds received – we are discussing two different levels. One level is at the consortium level, for consortium administrative activities (as referenced in the AEP program Guidance), and the other level is at the member level. When a member receives AEP funds for activities put forth in the annual plan, the member district can charge the approved indirect rate.

Only administrative activities can be charged to administration. Almost all duties defined as “administrative” are considered fiscal type activities per the AB104 program guidance. Who performs these duties is not relevant. A project director, or co-lead, or part-time staff might also have other programmatic duties and those cannot be charged to administration. You will have to keep track of time and effort for administration charges based on allowable administrative activities for all staff who perform them. Please review the Program Guidance for details

No – consortium administrative activities are limited to the 5% cap whether you have a fiscal agent or are direct funded. If you are going direct funding, you will still need a person to administer the activities of the consortium per the program guidance. Your consortium will have to figure out how to pool resources to pay for those consortium level activities. A member’s indirect cost is to be used at the member level for those indirect type activities. Be careful not to confuse consortium administrative costs with a member level indirect costs. Please review the Program Guidance for additional information.

This would depend on the consortium coordinator activities. In some cases, the consortium coordinator may be responsible for some administrative type activities. Please see Program Guidance for a complete list of consortium administrative activities, and a list of consortium coordinator activities. Each consortium operates differently, so there may be overlap.

Depends on what activities you are claiming as administrative. Please see the updated Program Guidance (starts on page 13) for what you can claim as administrative activities (which are mostly fiscal in nature). Here is the link to the program guidance documents: http://aebg.cccco.edu/For-AEBG-Grantees/Guidance-Regulations

The Preliminary Allocation for 16-17 and 17-18 will be the only document with the allocations listed until the final allocations are released 15 days after the Governor signs the budget. We do not anticipate any changes between the preliminary allocation and the final allocation. Apportionment schedules will be released 30 days after the final allocations are posted. We encourage AEP consortium members and fiscal agents to obtain local board approval now so that AEP funding can be allocated locally when the 16-17 school year begins.

We ask that if the consortium wishes to change a member allocation, they refer to the AB104 legislation for restricting funding to members (see section 84914). If the three criteria listed in the AB104 legislation are not applicable to your member’s situation because the consortium wishes to pool resources for consortium wide activities, or shift member funds around from the prior year to meet current year needs, the State request that all members be in agreement for these types of changes. Evidence showing member agreement would be a signed CFAD.

Yes - Consortium members and/or fiscal agents may use their agreed upon subcontracting process for moving funding among members after the CFAD is submitted on May 2, 2016. Please refer to your consortium MOU that is in place among consortium members. If you do not have a consortium MOU, it is strongly recommended that you put one in place to define the responsibilities (financial and programmatically) of each of your members and how the consortium will operate per the State guidelines.

Please refer to the CDE Fiscal Division for questions related to MOE expiration. Non-MOE funding activities must end by 12/31/17. Final expenditure reports for AEP 15-16 Non-MOE funding are due 1/31/18 with close processing through February/March 2018.

Yes. That is correct for 16-17 funding. MOE funding from 15-16 can be carried over into the next year. All AEP funding is restricted funding (MOE & Non-MOE) and must follow the AB104 legislation related to program areas, member decision making, annual planning, 3 year planning, etc.

The AEP Office is working on a process. For now, funding will be disbursed to fiscal agents and direct funded members with instructions for planning documents. The submission of the planning documents will come later in the year and will require member approval and public comment. Funding will be apportioned by June 30, 2016. Funding must be expended by December 31, 2017. More details will be out soon.

It can be used to launch a system but you are correct, it is one-time money and on-going operations should be based on on-going fund sources.

Yes. It was a small amount and it was added to the Data and Accountability fund (D&A). It was the only way the AEP Office was able to get the $4.8M out to consortia without having to completely redo the CFADs. The two columns of funding on the D&A Allocations are Unspent & D&A funds – both will goes towards Data & Accountability objectives and activities.

We ask that if the consortium wishes to change a member allocation that they refer the AB104 legislation for restricting funding to members (see section 84914). If the three criteria listed in the AB104 legislation are not applicable to your member’s situation because the consortium wishes to pool resources for consortium wide activities, or shift member funds around from the prior year to meet current year needs, the State request that all members be in agreement for these types of changes. Evidence showing member agreement would be a signed CFAD.

If you are direct funded, you will receive your apportionment in the first 12 months of the state fiscal year. If you wish to alter or revise the amount you received, you may do so through the subcontracting process. If you have a fiscal agent, they will receive the consortium apportionment in the first 12 months of the state fiscal year. If the fiscal agent wishes to alter or revise the amount being allocated to members, they may do so, with member agreement, through the subcontracting process.

Your tables will show remaining funds from prior year allocations. The tables will also show projected funding for the upcoming year. It is critical that consortia keep those tables separate – don’t co-mingle fund years in your tables even though they might be spent on similar activities. Track the funds separately - use separate annual plans and separate reporting.

Yes – your fiscal agent for 15-16 will be responsible for tracking the 15-16 expenses until these funds are exhausted. That means filing online reports for the 15-16 funds, providing progress updates, and closing out the account in the spring of 2018. This is their responsibility, even if in 16-17 you are direct funded.

For 2015-16, the Adult Education Block Grant distributes $500 million, as follows:
$336.9 million for maintenance of effort (MOE) funding to eligible county offices of education and school districts based on 2012-13 General Fund expenditures on adult education programs. This funding is distributed directly to the local educational agency (LEA).
$163.1 million for consortia funding (also known as non-MOE funding) to adult education consortia based on a region’s share of statewide adult education need. This funding may be distributed directly to consortium members or to a fund administrator designated by the consortium.

Starting in 16-17, 17-18, and beyond the AEBG funding continues at $500M per year.  The funding is ongoing.

Not quite. AEP Funds are to be released no later than 45 days after the state budget is signed by the Governor. Also take into account processing time by State Controller’s Office, and County Offices of Education in the funding release time. Keep in mind, the State can withhold funding if a consortium has not submitted its deliverables.

There are no statutory provisions preventing an LEA from carrying over funds; however, a consortium may change the amount of adult education funds available in future years based on actual prior fiscal year spending.

Per California Education Code Section 84912, funds are apportioned in twelve equal payments to each LEA on a monthly basis.

The AEP Apportionment funding comes from the state general fund, but are earmarked for the specific purposes described in AB104 for the AEP. They are not part of general funds coming to the k-12 school districts or the community colleges.

Members can take their state approved indirect or for colleges the negotiated indirect rate for their member allocation.

Consortium fiscal agents - taking care of only consortium fiscal activities - can take up to a 5% administration or indirect for consortium level activities. 
5% admin is taken on the entire consortium allocation. But is restricted to fiscal activities only. 
The indirect at the member level is limited to that member's allocation. So you would have to look at what Yuba CCD was allocated by the consortium for programmatic activities - and they could take their indirect on that amount. 
Indirect activities are listed in the program guidance.

The amount of funds to be distributed to a member of that consortium shall be equal to or greater than the amount distributed in the prior fiscal year, unless the consortium makes at least one of the following findings related to the member for which the distribution would be reduced:

(A) The member no longer wishes to provide services consistent with the adult education plan.
(B) The member cannot provide services that address the needs identified in the adult education plan.
(C) The member has been consistently ineffective in providing services that address the needs identified in the adult education plan and reasonable interventions have not resulted in improvements.

(a-b) If a member no longer wishes to provide services or cannot provide services, if possible, reallocate their funds to other members in the consortium. The consortium membership should amend planning documentation to ensure services are being covered in the region (as a result of a member that no longer wishes to provide services or cannot provide services). The consortium must also notify the AEP Office and update the CFAD allocation schedule for 17-18.

(c) If a consortium decides that a member has been consistently ineffective in providing services that address the needs identified in the adult education plan, and is not following the member requirements as listed in the AEP Program Guidance Section 5, and the Annual Plan General Assurances, the consortium must take the following steps:

1, Document the member’s ineffectiveness (what requirements are they not meeting, etc.)
2. Notify the member that they are being monitored for effectiveness and their funds could be reduced as a result.
3. Notify AEP TAP for technical assistance for the member.
4. Provide the information in #1-#3 to the AEPOffice.
5. Work with AEP TAP and the AEP Office to determine if reasonable interventions have not resulted in improvements.
6. If no improvements after steps #1-4, reduce the member’s funding and update the CFAD allocation schedule for 17-18. Copy the AEP Office on all correspondence related to member funding reduction.

The members of the consortium may decide to designate a member to serve as the fund administrator to receive and distribute funds from the program. If a member is chosen to be the fund administrator, the member shall commit to developing a process to apportion funds to each member of the consortium pursuant to the consortium’s adult education plan within 45 days of receiving funds appropriated for the program. This process shall not require a consortium member to be funded on a reimbursement basis.

We anticipate the 2017-18 apportionments to be released by CDE Accounting possibly the first week of October. Once the State Controllers releases, it will be approximately three weeks until payment is received by the agency.

If you have a fiscal agent, changes can be made to the CFAD throughout the current year. The cutoff date is May 2nd. As we move into the new system, the AEP Office will evaluate an updated process.

Consortium Director, with 100% agreement by the members, would reallocate funding. The AEP Office would need to be notified as well. Previously this was done with an updated CFAD with all members signing off. Once the reallocation is approved – the fiscal agent would have to work out the transfer of funds among members. This may be difficult if the members has already encumbered the funds. Before starting down the path to transfer funds/update the CFAD – check with your fiscal agent to see if it’s even possible at the local level.

We are moving to a new system. The new system will be tracking current year and prior year funding. There will not be any codes used, just fiscal years. More details will be released later this fall.

If a Consortium Member would like to reallocate funds, the Consortium Director, with 100% agreement by the members, can reallocate the funds. The Consortium would need to notify the AEP Office of the change. Once the reallocation is approved – the fiscal agent would have to work out the transfer of funds among members. Prior to starting this process, the Consortium Director should check with the fiscal agent to see if this is possible because the funds may have been encumbered already.

If this moves forward, you would be required to work with the AEP Office to update your CFAD reflecting the change.

We are moving to a new system. The new system will be tracking current year and prior year funding. There will not be any codes used, just fiscal years. More details will be released in a few weeks.

Last year’s trailer bill language said that all funds must be pass through to members within 45 days. You cannot use sub agreements unless you are a member that received their pass through and is contracting with another provider. The fiscal agent should not be holding any sub agreements. The chancellor’s office issued the following memo on how to pass through funds to members.

http://aebg.cccco.edu/LinkClick.aspx?fileticket=Cw-O6gUujhQ%3d&portalid=1

Consortia that need to adjust their 16-17 and/or 17-18 allocations will need to update the allocation amounts in NOVA and submit a revised signed CFAD document. Here are the steps to do that:

Changing allocations for your consortium members requires submitting a revised CFAD and obtaining signatures from all of your members that indicates agreement/approval of the allocation changes. You will need to submit a revised CFAD document with signatures based on the updated amounts. You should upload this document to the document library and select the box for “Amendment”. We are working on creating a template for the CFAD updates, but in the meantime please print a copy of your CFAD and handwrite the changes, sign and scan to upload as an amendment.

For FY 16-17 allocation changes, the revised amounts should be reflected in the 16-17 carryover line of the member budgets. You will also need to submit a revised 16-17 CFAD document with signatures based on the updated amounts. Please follow the same process as outlined above for submitting a revised CFAD document.

You can edit the member allocations by clicking on Allocations (located on the blue navigation pane on the left side of the screen). Please see screenshot below.

Here is the process as Neil has described it:

Amending the CFAD might take some time (getting signatures). You can always adjust you budget later in the pending quarter or the following quarter.

Members expenses & budget changes are due 3/1/18. Consortium certification will be due by 3/31/18. You could attempt to have your CFAD submitted and approved prior to the 3/1/18 member expenses report (and budget changes). The member allocations can be adjusted at that point.

For 16-17 allocation changes, you should reflect these changes when members report their 16-17 Carryover Amounts when submitting their budgets. You will need to submit a revised CFAD document with signatures from your members that indicates agreement/approval of the allocation changes based on the updated amounts for 16-17. You can hand write in the changes, sign and scan to upload them as an amendment. The system should allow you to submit 16-17 carryover amounts that do not match the CFAD. You should upload these documents to the document library and select the box for "Amendment."

The AEP Office is unlikely to approve expenditures for light refreshments and entertainment. We would need to know more about what you are proposing. Please email the AEP Office with more detail.

No. The focus must be on AEP planning and implementation activities.

USIS will assist with payment for low income citizenship and naturalization applicants. They have a sliding scale. There are also other resources out there that may be offered by other partners in your region.

If the meeting involves AEP planning and the implementation of activities – it would be allowable to purchase meeting supplies.

Some have ordered a block of GED voucher codes and the teachers distribute them to students who are ready to take practice tests. They have pre-purchased the vouchers and established a procedure/process for "awarding" the voucher to the student so no cash goes to students. Some use private foundation grants and other county resources to support the students who cannot afford to take GED and Industry Certification tests.  But as always - local district policies and procedures will have the final say so.  If your district considers this a gift of public funds - we can't over-ride your local policies.

We are setting up a chat feature on the AEP website where you will be able to pose questions like this to colleagues in other consortia around the state. Supportive services are allowable provided they do not violate any existing State regulation, or local policy and procedure of the member district. Also, any expense of AEP funds must be agreed to by members at a public meeting, and included in your annual plan reflecting the 3 year vision of that effort.

There would be an issue if the district is supplanting AEP funds that were used last year by another fund source. Also, there may be an issue if the district is violating the State policy on fees or any local policy and procedures. Finally, any expense from AEP funds must be agreed to by members at a public meeting, and included in your annual plan reflecting the 3 year vision of that effort. Please keep in mind that AEP students must be 18 years old or older.

Yes, you can retain funds for common consortium level costs. How you do that is controlled locally. Some consortia add the dollar amount to the member’s allocation and track that amount separately e.g. through an Excel spreadsheet.

The state system does not have a feature to show encumbered but un-expended funds in the year-end report. You can identify encumbered funds carried over from Year 1 being utilized when submitting your Year 2 Plan.

AEP has an online system that allows consortia to report expenditures and progress every 6 months. The primary lead has the password to access these online forms. AEP also has an annual reporting process that allows consortia to report individual consortium and member annual expenditures by program, by objective, and by object code. The annual plan for Year 2 has been posted to the AEPwebsite.

Counseling services to students are direct services and are considered a program expense, not administration. That would be a cost shared between the consortium members.

Supplanting is not a dead issue. It can be an issue and it doesn’t matter whether the funds are coming through a fiscal agent or through direct funding. Supplanting could happen if you are replacing programs that were funded were other fund sources (like WIOA, Perkins, CalWORKS, Apportionment, etc.) with AEP funds.

Please check the AEP Program Guidance and Allowable Uses on the AEP website.

Yes, you have to spend them on 2015-16 activities. If 2015-16 funds are spent on additional/new activities, your consortia’s 2015-16 Annual Plan needs to be revised or amended to reflect such changes.

The use of MOE funding for AEP purposes is not considered supplanting. The issue of supplanting may occur when members use AEP funds to supplant an existing fund source (like apportionment, CalWORKS, Perkins, WIOA, SSSP, etc.). Please see the first section of the AEP Allowable Uses Guide posted on the AEP website.

Data for all students enrolled in AEP program areas at the Capital Outlay site need to be collected and reported to the AEP Office.

If any AEP funds (regardless of the percentage) are used for instruction, support, and/or services in an AEP program area, then the member would need to report those students into TOPSPro Enterprise.

No – marketing and outreach events to potential students do not require a member to collect student information and report it. The State AEP Office requires you to collect student information once the student begins the enrollment process.

Consortia wide marketing, outreach, teacher/faculty meetings, member meetings, are examples of activities that benefit the consortium as a whole, and do not need to be tracked. If the curriculum was developed, using AEP funds, with the intent to be used for a specific community college course, then they would need to report the students into TOPSPro Enterprise.

AEP funds are available to address gaps in services, either current or emerging. They can be used to stabilize services as efforts are made to improve them through implementation of the innovative approaches outlined in AB86 and AB104. These aspects work together – stabilizing and expanding services AND improving the impact of services for better student outcomes in alignment with AEP goals.

The use of MOE funding for AEP purposes is not considered supplanting. The issue of supplanting may occur when members use AEP funds to supplant an existing fund source (like apportionment, CalWORKS, Perkins, WIOA, SSSP, etc.). Please see the first section of the AEP Allowable Uses Guide posted on the AEP website.

Yes – fiscal agents for Data and Accountability funds can use their approved indirect rate. Budgets & Workplans will be due December 20, 2016.

Our best hope for keeping and growing this funding is documented success. As long as consortia throughout the state implement best practices for helping students meet the goals of AEP, objectively track outcomes to document program improvement and student achievement, and coordinate, leverage and expend resources responsibly, we anticipate that this funding will continue well beyond the Three Year Plan.

Student services are described as orientation, assessment, academic, and/or career counseling/referrals.

Now that there is again a restricted revenue source for adult education, it may no longer be necessary for LEAs to formally commit general purpose LCFF revenues to the purposes of adult education in order to justify the use of a special revenue fund in accordance with Generally Accepted Accounting Principles (GAAP). LEAs that continue to formally commit LCFF revenue to the purposes of adult education should use Object 8091, LCFF Revenue Transfers, to transfer the committed LCFF revenue from their general fund to Fund 11.

All funds are subject to a financial audit; however, there are no specific compliance procedures for the Adult Education Block Grant in the current state audit guide.

The intent is that AEP serve students only 18 years and over. Therefore, should an Adult Ed provider wish to serve someone under 18 years of age, they would need to use another funding source (e.g., LCFF). This would ensure “moneys in the Adult Education Fund to be expended only for adult education purposes.”

It would be reasonable and allocable if they charged you rent based on space. How are they costing out the rent from the various programs? Square footage? What we don't want to have happen is the AEP consortium has 15% of the space, but is paying for 70% of the base. These details will help answer the reasonable and allocable questions.

AEP MOE & Non-MOE funds can only be used in the seven AEP program areas. If the class is not in one of the seven program areas – then you cannot use AEP funds.

Yes – as long as the students are 18 years and enrolled in an AEP program area – it doesn’t matter who offers the classes – as long as they meet their K-12 or college education code and regulations. K-12 falls under adult education regulation administered by CDE (and teacher qualification regs under the CA Teacher Credentialing Commission), and the colleges fall under Title V & noncredit education code. I hope this helps.

AEP has certain program requirements. In this case I would highlight the following:
Funds can only be used within the seven AEP program areas.
For colleges, only noncredit students will be tracked and reported.
A member has to be in good standing (reporting, participation, etc.) – meaning meeting the member requirements.
Activities have to be included in the annual plan and approved by members.
Members can leverage and braid various fund sources (including noncredit apportionment). But colleges cannot use, leverage or braid any fee based programs – like community education or contract education.
If a community college wants to leverage & braid noncredit apportionment, they must follow the recently released guidance from the Chancellor’s Office on use of AEP funds (state funds) and FTES (noncredit apportionment).
Here is the guidance on using AEP funds and noncredit apportionment:
It is allowable to claim apportionment for a course, even if the instructor's salary and benefits are paid for using AEP funding, as long as some portion of the overall direct education costs for the course are paid for using district unrestricted general fund dollars (as indicated in prior legal opinions, this portion should be more than a trivial amount) and the course is allowable under the particular categorical program (in this case AEP). If there are no other direct education costs for a particular course beyond the instructor's salary and benefits, then the district would have to pay for a portion of the salary and benefits of the instructor using district unrestricted general fund dollars in order to claim apportionment for the course. The term "direct education cost" includes all expenses specifically traceable to a class, such as the salaries and benefits of the instructor, instructional assistants or aides, and non-instructional staff directly supporting the class (e.g., proctors); instructional materials and supplies and equipment, along with any other direct expense or cost required for the particular class in question. Please also note that all other applicable apportionment eligibility requirements would also need to be met, including as provided by Title 5 Section 58050.
We advise that districts have a policy in place that outlines what portion of the direct education costs for a course will be paid using unrestricted general fund dollars where a district intends to claim apportionment for courses that are partially funded from state categorical funds or that are conducted as part of instructional services agreements; ideally, these decisions would be made in the context of an established district policy. Please also recall that the Q&A document advises a prudent approach in determining what portion will be paid from district unrestricted general fund dollars.
This is a link to the document on the Chancellors Office website: http://extranet.cccco.edu/Portals/1/CFFP/Fiscal_Services/Attndc_Acctg/ISA/Title%205%20Section%2058051.5%20and%20Direct%20Education%20Costs%20Definition%201-10-17%20FINAL.pdf
Contact Person on AEP:

tap@aebg.org 

Contact Person on FTES:

Natalie Wagner California Community Colleges Chancellor's Office
1102 Q Street
Sacramento, CA 95825
(916) 327-1554

AEP legislation encourages the leveraging and braiding of other state and federal funding sources as stated in education code Section 84905 (b).

  1. The chancellor and the Superintendent, with the advice of the executive director, shall approve, for each consortium, rules and procedures that adhere to all of the following conditions: (b) As a condition of joining a consortium, a member shall commit to reporting any funds available to that member for the purposes of education and workforce services for adults and the uses of those funds.

AEP legislation goes on further to list the state and federal fund sources that are required to being a member of a consortium Section 84916.

  1. In order to maximize the benefits derived from public funds provided for the purpose of addressing the educational needs of adults and to ensure the efficient and coordinated use of resources, it is the intent and expectation of the Legislature that any community college district, school district, or county office of education, or any joint powers authority consisting of community college districts, school districts, county offices of education, or a combination of these, located within the boundaries of the adult education region shall be a member of a consortium pursuant to this article if it receives funds from any of the following programs or allocations:

(a) The Adults in Correctional Facilities program.
(b) The federal Adult Education and Family Literacy Act (Title II of the federal Workforce Innovation and Opportunity Act).
(c) The federal Carl D. Perkins Career and Technical Education Act (Public Law 109-270).
(d) Local Control Funding Formula apportionments received for students who are 19 years of age or older.
(e) Community college apportionments received for providing instruction in courses in the areas listed in subdivision (a) of Section 84913.
(f) State funds for remedial education and job training services for participants in the CalWORKs program

Note: AEP funds cannot be used to create an 18-22 year old certificate program for Special education students since service of those students by LEAs has been expected for years and districts only had LCFF money.

Any capital outlay (including building improvements, rental space, leases, construction, etc.) will be closely scrutinized. It will require that you notify the AEP Office of your consortium’s (including any member in that consortium) intent. This is an informational e-mail only. The AEP Office reserves the right to ask questions regarding any purchase and can prohibit any activity that it deems not meeting the reasonable and justifiable criteria.

The member must follow all state & local policies and procedures related to capital outlay. This would include district facilities approval, following procurement processes, and notification of state agency facility departments.

Regardless of whether you choose a fiscal agent or a direct funded structure, consortium must use their administrative funding to ensure that member fiscal information (budget, expenses, etc.) is valid. That may include, but not limited to, an outside audit, an agreed upon certification process, a peer-to-peer member review, a fiscal agent certification, or a combination of options (or other options). The consortium membership will determine how best to audit their members, and consortium level financial budgeting, and expenditure reporting. The 5% administrative cap for consortium oversight is established for that specific purpose.

Funds apportioned for the AEP program shall be used only for support of AEP program areas as described in this section. If a consortia or member would like to offer programs outside of the AEP defined program areas, it may do so with another fund source (if it is allowed by that fund source).

Consortia are required to complete an Out-of-State Travel Request Form and submit the form to the AEP Office for prior approval. Such travel must also be disclosed in the Annual Plan template, reported in the AB104 online grant budget, as well as in the expenditure & progress reports. Out-of-State Travel Request forms are posted on the AEP website under resources. In the request, consortia must explain how the approved travelers and the consortia will disseminate the information to other district staff, administrators, faculty, and teachers when they return. AEP TAP will be notified of Out-of-State Travel requests to attend conferences. By notifying AEP TAP of national conferences, it allows them to support a focused conference participation effort. In addition, AEBP TAP will follow up after the event on coordinated professional development offerings.

The state reserves the right to limit Out-of-State travel. See link to the travel form.
http://aebg.cccco.edu/Resources 

AEP TAP will work with the adult education professional agencies: ACCE, ASCA, CCAE, CCCAOE, etc. to obtain a list of AEP attendees. This will allow AEP TAP to find out what professional development is taking place around the state, and follow up after the event on coordinated professional development offerings.

No - noncredit courses are funded by state apportionment (FTES). If the next question is if they can leverage noncredit FTES (state apportionment) and WIOA II – that would go back to CDE.

No – fee based community college programs – called community service programs must be self-sustaining on fees only per education code and community college regulations.

Many community colleges do not combine credit & noncredit as the courses have different expectations centered around the rigor of work, the amount of homework, and the assignment of a letter grade in a credit class.

Both credit and noncredit departments are provided a supply budget. Many community colleges purchase books for noncredit students because these students cannot afford to buy them. This would be ok for a noncredit class to use AEP funds if the class is in one of the seven program areas.

As far as buying chromebooks for credit ESL students and using AEP funds to subsidize the purchase, we would recommend you look at using all other fund sources (credit, basic skills, and other fund sources) before using AEP funds. The consortium should ensure that the community college is using all other available resources before it uses AEP funds as these credit students are not being counted in the AEP enrollment and outcome numbers. You may make a case if these credit student were transitioning from an adult school or noncredit course – but to use AEP funds to purchase equipment for credit students that have no connection to AEP/adult education – would not be advisable.

They really should restructure the class if they want to use AEP funds to buy equipment.

It is unclear to the AEP Office how the field trip to the aquarium ties into the educational goals of the course or services ESL, ABE, CTE, AWD, or K12 Success students. If the school can make the connection to the educational goals, and the district support it - then it would be an allowable use of funds. Please let me know if you have any additional questions.

The AEP Office doesn’t set the rules on determining what is or what an expenditure isn’t. The AEP Office suggests you work that out with your accounting office. The close out for 15/16 funds is 2/25/18. So after the final report due 1/31/18. You have another short period of time to certify any additional expenses.

The AEP Office is fine with whatever you work out with your accounting office on the certification of expenses. We assume they follow their district/agency accounting processes & regulations.

There may be K12/CDE education code that covers this. Please refer over to CDE. There isn’t anything in AEP legislation that covers that question.

There should be some LCCF funding set aside to pay for K12 elementary & secondary teacher professional development as part of the LCAP in dealing with English Language Learners in the K12 system. However, if this was for an AEP K12 Academic Success program geared toward LEP parents and their children enrolled in the K12 system - then AEP funds could be used to pay for professional development for the adult school teachers ONLY.

Supportive services like HiSET are allowable provided they do not violate any existing state regulation or local policy/procedure of the member district. Also, any expense of AEP funds must be agreed to by members at a public meeting and included in your annual plan reflecting the three year vision of that effort. Also keep in mind that you have to follow your local district policy and procedures on how provide the stipend or support service to a student.

Yes, you can. The choice you make will apply to all the funds the consortium receives from AEP.

The decision has to be made according to the decision-making structure in your Consortium Governance agreement. If you have no special structure for such decisions, the fallback is consensus. In any case, the decision submitted on your Consortium Fiscal Administration Declaration (CFAD), which is due May 2, is binding for all consortium members for the entire program year. It will apply to all AEP funds distributed.

Yes. If the consortium chooses to have a Fiscal Agent, all AEP Allocations will go through that entity.

No, you must select either “Direct Funding” or “Fiscal Agent” for all the Consortium Funds.

Yes. Members can receive direct allocations provided they spend the AEP funds in the seven program areas, based on a plan approved by members at a public meeting.

No, according to AB104 legislation, a consortium may use up to 5% for the administration of the consortium. Administrative activities are mostly fiscal in nature. There is no guaranteed fiscal agent funding as those administrative costs must be discussed by members when making the decision on who will be responsible for the administration of the consortium and the cost associated with those activities. Also, the consortium can decide to hire a different fiscal agent or opt for direct funding, which in turn may change the cost of administrating the consortium.

In the direct funding model, members would have to decide how they will manage the administration of the consortium. Who is going to manage the program side? Who will be responsible for those fiscal activities at the consortium level? How will the consortium report to the State? In some cases, members in the consortium have agreed to take on those responsibilities (along with funding to support it). A non-financial MOU would be important to have in place in order to have member agreement on who is responsible for what activities, the requirements, and deadlines.

In some instances, Direct Funding is quicker in getting the funding directly to consortia members. However, some State officials and some consortia state that having a common fiscal agent has encouraged better collaboration within the consortia and are satisfied with this process. Both models, Direct Funding or Fiscal Agent, require a MOU (financial or non-financial) in order to clarify the fiscal and programmatic responsibilities of the consortium and its members. Our goal is to both get funds “on the ground” to programs that benefit students as quickly as possible AND to foster collaboration between providers to improve coordination and alignment of services.

No, you will use your governance plan and agreed upon decision making process when making consortium decisions. Only changes to member allocations needs to be unanimous, per AB104.

No – consortia can only opt for one of two fiscal models – direct funding or a fiscal agent model. A consortium cannot vote to have MOE funds be directly funded to K-12 and consortium funds be allocated through the fiscal agent. Two things to keep in mind- 1) the "no less than prior year" rule for funding consortium members (unless changes are unanimously agreed to) continues into Year 2, and 2) there is no longer a distinction between MOE and consortia funds. MOE and consortia funds were always all AEP funds and the distinction was a Year 1 phenomenon only. Neither the CFAD nor the role of the fiscal agent have an effect on this.

Once the CFAD is submitted (no later than May 2 at 11:59 pm) the choice is fixed for the year. Your consortium will have to wait to make changes until the following year.

Allocations to consortia members from the State are set via the CFAD, but consortium members can move funds, as needed. This is the case regardless of whether the consortium has chosen Fiscal Agent or Direct Funding.  The methods may vary. 

To be clear, we at the State are not using the term “Certifying Agent.” There may be many people that help roll up the member’s expenditure and budget information, but there should be one Fiscal Agent or Fiscal Coordinator (for those doing Direct Funding) for the consortium. On the CFAD, you may list more than one person, but realize that the State really wants one person to talk to about fiscal matters at the consortium level. Keep in mind, that depending on how your consortium is structured, you may or may not have a Fiscal Agent. You may only need a Fiscal Coordinator for the consortium, while each member has its own certifying Fiscal Agent separately in their organization. This will vary from region to region.

The amounts for administration and indirect are outlined in the updated AEP Program Guidance on the AEP Resources webpage. “Indirect” is for membership level and “administrative” applies to the Fiscal Agents or the entity/person that will be responsible for the consortium level administrative activities. Don’t confuse consortium administrative activities with indirect – different rules, different definitions. See the 2016-17 AEP Program Guidance on the AEP Resources webpage.

Yes, it can. That is the case whether you have chosen a Fiscal Agent or Direct Funding. But once received via apportionment, you would have to use a subcontracting or MOU process to move the funding among members. More details will be released soon.

Fiscal Agents are not necessarily “guaranteed” the same amount every year as stated in the legislation for members of a consortium. In other words, Fiscal Agents are not “protected members” of a consortium. These individuals and the amounts they receive can change (if the consortium votes on this change) and the percent negotiated for their services may also vary – it can be up to 5%, but does not “have” to be the full 5%. The amount paid to the Fiscal Agent would depend on the services rendered and terms and conditions negotiated with consortia.

Note that if you go to Direct Funding, the consortium members would need to pull their resources together to pay the Primary Contact or designee for the cost of administering the consortium (which is still required under Direct Funding per all the State level deliverables). See Program Guidance for the list of those activities.

Consortia must focus on and agree to a process that will allow them to meet the AEP requirements. Consortia may elect a different Fiscal Agent if the current one fails to meet AEP requirements. However, AEP revision timelines and processes need to be followed when making such changes.

Regarding data and accountability funds – those that went straight to the fiscal agent – no pass through - the fiscal agent has the responsibility to oversee any funds their district receives directly. This would also apply to any AEP funds allocated to the fiscal agent (as the district has oversight) – but would not apply to the pass through.

Last year, the 2016-17 trailer bill was passed with language to limit the holding of funds to 45 days. Additionally, fiscal agents must use a pass through mechanism to disburse funds to members. To provide further clarification, an addition to AEP was included in the 2017-18 draft Trailer Bill language released by the California Department of Finance. The portion released pertaining to the Adult Education Block grant builds upon the existing legislation. The 2017-18 trailer bill language addition states that "program funds received by a participating school district shall be deposited in a separate fund of the school district to be known as the Adult Education Fund. Moneys in an Adult Education Fund shall be expended only for adult education purposes". Please go to the website under "About" and click on Adult Education Block Grant legislation.

Yes - here is the main part of the memo......Subject: Accounting Advisory: Adult Education Block Grant Funds

This accounting advisory addresses the appropriate accounting for districts receiving Adult Education Program (AEP) funds either as a fiscal agent, as a participant/provider, or both. The treatment of funds received as the fiscal agent for disbursement to other participants is different than for funds received by the district for the direct costs of providing adult education services.
Fiscal Agent
Funds received from the State under a fiscal agent agreement that are then disbursed within 45 days to other adult education providers should be recorded in the restricted General Fund as 8900 "Other Financing Sources" using revenue object code 8970 "Fiscal Agent Pass Though". Disbursements should be coded to "Other Outgo-Other Transfers" using expenditure object code 7400 "Other Transfers", excluding indirect cost recovery. Under AEP, districts have no fiduciary requirement regarding the use of the funds by the other participants. The only obligation of the fiscal agent is to disburse within 45 days.
Participant/Provider
If a portion of the funds received as a fiscal agent are for the district's own adult education program, then those funds should be recorded initially as described above. A transfer (other outgo) will be recorded to the fiscal agent funds for the district's share. The district will recognize its share of the funds in the restricted General Fund using revenue object code 8620 "General Categorical Programs". Expenditures should be recorded in expenditure object codes 1000-6000 as appropriate. Likewise, if the district is not the fiscal agent and is receiving AEP funds, those funds should be recorded to the restricted General Fund using revenue object code 8620 "General Categorical Programs" and expenditure object codes 1000-6000 as appropriate.
Note the newly created object codes are not currently reflected in the California Community College Budget and Accounting Manual. This guidance will be incorporated at the next opportunity.