How ESSA Monitoring Can Bring Benefits to School Districts
A version of this article was previously published in the December 2017 edition of the American School Board Journal.
During a state monitoring visit, Toledo Schools Administrator Scott TenEyck saw a program that transformed a school from chaos to purposeful organization and improved graduation rates. So he spread the word-and the college readiness program expanded to more than 20 buildings.
In Charlotte-Mecklenburg Schools, state monitors raised concerns about how inventory was tracked. District leadership responded by adopting an automated bar code system that labels items according to their funding source. Designed to improve inventory accuracy and enhance compliance, the system will save schools countless hours, said Kelly W. Price, executive director of Title I programs and support for the North Carolina district. And at Des Moines Public Schools, monitoring brings the school board trends with supporting data. "It helps us to identify issues before they get to the point where they will be difficult to solve," said Wilma M. Gajdel, director of federal and grant programs in the Iowa school district.
Cross pollinating best practices and identifying barriers to school success are two benefits of monitoring, a mandate for school districts that receive federal funds. Monitoring is the regular and systematic examination of an administration and implementation of a federal education grant, co tract, or cooperative agreement administered by the U.S. Department of Education.
As part of a marked shift of authority away from the federal government, the Every Student Succeeds Acts of 2015 (ESSA) contains a greater emphasis on monitoring by subrecipients, a term that includes school districts that receive federal grants through state agencies. "What they've really done is put the monitoring onto the districts," said TenEyck, assistant director of the office of compensatory programs for Toledo Public Schools.
Under ESSA, all grant recipients must properly monitor subrecipients, must notify subrecipients of their obligations to monitor, and must comply with monitoring requirements themselves. They must sign assurances that information provided in response to monitoring reviews will be truthful and accurate, and they must display in a public place the hotline number of the U.S. Department of Education Office of the Inspector General. While the law requires each grant recipient to "properly" monitor any subgrantee, it does not define the term. Nor has the U.S. Department of Education issued guidance on how monitoring should be conducted under ESSA, deferring instead to existing regulatory guidance such as the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards.
The intent is to give districts latitude in how they design their monitoring programs, allowing them to focus less on traditional compliance and more on student achievement, said Philip A. Maestri, director of risk management services for the U.S. Department of Education.
"Monitoring should look very different than it did 20 years ago when monitoring was focused on compliance," Maestri says.
Traditional compliance monitoring can entail com piling extensive documentation to prove adherence to hundreds of legal requirements, some of which may duplicate audit methodologies or be irrelevant to a school's primary mission.
The U.S. Department of Education has not defined, required, or identified specific monitoring systems or tools. "We do not tell states to do it one way or another," says Matthew Schneer, an education program specialist in the Office of Special Education Programs. "The Uniform Guidance gives a lot of flexibility."
That freedom comes as a mixed blessing to school districts. "There are good things coming, but it's unknown," TenEyck says. "There's direction, but there's not a path. It's exciting, but also nerve-wracking when we are doing our best to interpret the guidance that isn't there."
The loose parameters present a challenge, Price agrees. "While someone may say verbally we would like to see less compliance-driven monitoring and more flexibility, if we then offer that flexibility and get monitored, and there is a negative finding, it puts us in a bind," Price says, adding that the Charlotte-Mecklenburg district focuses on existing guidance to stay compliant. "We don't want to owe back the federal government for anything we do incorrectly."
The baseline requirement that expenditures be "allowable" under grant specifications and regulatory guidance will continue. "From a financial point of view, there is a right way and a wrong way," said Gajdel of the Des Moines district, who formerly worked for the Iowa Department of Education. "An expenditure is either allowable or not."
School systems increasingly turn to automation to ensure those minimum financial requirements are met. At the Charlotte-Mecklenburg district, the Title I office reviews budgeted expenditures in advance to ensure they are "allowable" under grant and regulatory requirements. But to focus on student achievement, schools have to explain how expenditures align to their needs analyses-a component of strategic planning-and how effectiveness of the funded activities will be measured, Price said.
All of this is done electronically. "Our principals don't complain as much about monitoring because we have streamlined the process so much," Price says.
Focus On Need
The streamlined monitoring and oversight process to ensure expenditures meet the baseline requirements permits the district to then focus on aligning funding to areas of need. If, for example, male African-American seventh-graders are struggling, the Title I office asks how funds are being used to support that population, Price says. "We make sure that funding streams are being used to support what the data shows is needed and to make sure there is nothing duplicative," he says. "It's a good way to capture what works and what doesn't."
The Indianapolis Public School district focuses on transparency-capturing expenditures electronically-as an important control during a dramatic transformation of the district from one that is centrally led to one that is locally governed. "We're devolving autonomy and power to the site and school level," says Mary Ann Sullivan, president of the Indianapolis Board of School Commissioners. "We're doing that pretty methodically."
The role of the central office and how the system handles traditional compliance are changing as the Indianapolis system moves to a diverse portfolio of schools such as charter, innovation, and other types of autonomous schools.
Updating technology to capture spending information will be important under the new model. "We're a rusty old system trying to catch up with modern technology," Sullivan says. "We're moving forward and away from our principals hand-delivering payroll in green envelopes."
As the Indianapolis school board grapples with balancing school freedom with the need to protect against fraud or abuse of funds, another area has caught its attention.
"We've had a lot of conversations around data integrity," Sullivan said. "Because we put such an emphasis on measurement and we haven't put such an emphasis on making sure the measures have integrity, I don't know how good that information is." Sullivan expects that new data systems and technology infrastructure will help.
Given the number of critical decisions based on data in American education today, integrity of that data is a key focus of the Office of the Inspector General of the U.S. Department of Education, according to Richard T. Rasa, director of state and local advice and assistance for that office. The office assesses reliability of data in areas ranging from graduation rates to programs for the education of migrant children.
"We believe that oversight-audits, monitoring, and technical assistance activities-should be paying close attention to data quality;' Rasa says. "Is the data accurate, reliable and complete, and does management have sufficient internal controls that are working as intended to help ensure the quality of the data that will be used for critical decision making?"
Depending on how it is designed, the monitoring process can play a significant role in verifying the accuracy of data. By introducing an independent avenue to voice concerns through monitoring visits, it can also bring to the fore information that otherwise might remain hidden.
Monitoring typically involves focus group discussions with teachers, parents, and students.
"Sometimes teachers will say things to another director or myself that's hard to say to their principal," Gajdel of Des Moines says.
Monitoring brings policymakers important perspectives from those most knowledgeable about how district initiatives fare when meeting the realities of the schools. That makes it a valuable tool in the school improvement process. "I am the eyes and ears in the buildings;' TenEyck says.
Translating that information into strategy and action plans is the next step. In Des Moines, school board members had extensive conversations about what should be in a monitoring report, Gajdel says. "Traditionally, we've gone with data, but to their credit, they're saying 'We can look at that data, but we want to know what you are doing about it."
Gathering information is important, but only a part of the process. She says, "Board members want to know: What is the plan and what does that look like in the schools?"