[nfbmi-talk] oh peckham and state plan in here

[joe harcz Comcast]

Good afternoon Craig,

I reviewed the recent inquiries you made regarding the CAP (2.1, 2.2, 2.4, & 2.5).  The 2.1 corrective action stated that MCB discontinued developing certified
match July/August of 2009; although there were funds captured for FY 2008 and 2009.  The explanation is that July/August of 2009 concluded the activities
for FY 2009.   The ceasing referred to here meaning that there were no certified match agreements entered into for FY 2010.  Again, the agreements were
concluded, ended at the time period mentioned above.

In regards to corrective action 2.2, MCB has discontinued certified match agreements with the intermediate school districts (ISD’s) as of July/August 2009.
The certified match agreements were the salaries of the staff where non-federal dollars were used for match by MCB to provide expanded services outlined
in other agreements with the ISD’s.

For corrective action 2.4, MCB did not enter into any certified match agreements during the FY 2004 – 2007, so therefore the table is correct for 0 amounts.
 For FY 2008, MCB had three certified match agreements, although, the  specific amounts that were able to be used as certified match in accordance with
the percentage of instructional time for the number of students eligible MCB services, resulted in a reduced amount.  MCB eliminated the travel and supplies
from these agreements.  MCB eliminated Eaton ISD from the certified match agreements because the agreement only had travel and supplies leaving Ingham
and St. Clair ISD’s.  The total amounts of match for the two ISD’s are $252,642.16.  In FY2009, MCB had certified match agreements with Ingham and Eaton,
although the travel and supplies in Eaton’s agreement was eliminate; therefore, there was no certified match for Eaton.  The agreement with Ingham reflects
the percentage of time as noted in the document provided by the staff to eligible students resulted in the total match amount of $184,460.40 that was utilized
by MCB for match.

The adjustment in the CAP reflects the requested changes and the explanations of the match funds that were utilized.  If you have additional questions,
please contact me so that we may establish a phone conference to discuss any concerns. Thank you.

________________________________
From: McManus, Craig [mailto:Craig.McManus at ed.gov]
Sent: Friday, October 14, 2011 3:27 PM
To: Jones, Leamon (LARA)
Cc: Cannon, Patrick (LARA); Luzenski, Sue (LARA); Sadler, Charles
Subject: RE: CAP Follow Up

Good afternoon Leamon,

After reviewing the recently submitted documentation from the Ingham and St. Clair ISDs, the Eaton document, as well as the certified expenditure agreements,
the team has determined that there are some inconsistencies between the corrective actions from the finding, MCB's corrective action responses, and the
information from the three ISD documents and agreements.

The corrective actions for the Certified Expenditure finding are as follows:

Corrective Action:  MCB must:

2.1              cease reporting non-Federal expenditures as match funds under the VR program when those non-Federal expenditures fail to comply with 34
CFR 361.28 or 34 CFR 361.60(b);

2.2              amend those agreements that will be used by MCB as a source of non-Federal expenditures for meeting its non-Federal share obligation under
the VR program to ensure they comply with 34 CFR 361.28;

2.3              submit a written assurance to RSA within 10 days of receipt of the final monitoring report that:  1) all future third-party agreements,
for purposes of meeting MCB’s non-Federal share under the VR program, will comply with 34 CFR 361.28; and 2) MCB will not use in-kind contributions for
meeting its non-Federal share under the VR program in accordance with 34 CFR 361.60(b); and

2.4              complete and submit the following source of match spreadsheet entitled, “Certified Expenditure Agreements,” that provides summary information
on the total amount of certified funds MCB received from the public agencies through these agreements and the total amount used by MCB for VR program match
in FYs 2005 through 2009 (Chart not provided here); and

2.5       MCB must submit written documentation to support the amount of certified expenditures reported in the above chart as being allowable under the
VR program.  The supporting documentation must demonstrate that the expenditures were incurred during the provision of allowable VR services to MCB consumers.

MCB responded as follows to the Corrective actions:
2.1      MCB has discontinued the practice of establishing certified match agreements with the school districts for the purpose of obtaining additional
funds for match.  In accordance with 34 CFR 361.28 or 34 CFR 361.60(b) third party agreements ceased in July/August 2009.
2.2      MCB has reviewed its activities as it relates to the findings of the certified agreements that RSA monitoring report identified as the normal activities
that the school districts provide to customary students.  MCB agreements with the school districts specified specific transition activities that are above
and beyond the regular curriculum.  It includes the expanded core curriculum as well as the vocational and pre-employment activities.   These are services
that are not normally provided by the school districts.  Therefore, the staff that provided instructions in these activities was included in the certified
match.
2.3      MCB has already submitted the written assurance to RSA within 10 days of the monitoring report.  Further, MCB is aware that in-kind contributions
can not be used for match for the VR program.
2.4

Certified Expenditure Agreements

(FYs 2005 through 2009)

FY 2005

FY 2006

FY 2007

FY 2008

FY 2009

Total certified funds MCB received from public entities for match

$0

$0

$0

$252,642.16

$184,460.40

Total certified funds from these agreements used for match  in specified FY

$0

$0

$0

$252,642.16

$184,460.40

Total certified funds from the agreements, incurred in the provision of allowable services to eligible individuals in accordance with 34 CFR 361.28, used
for match  in specified FY

$0

$0

$0

$252,642.16

$184,460.40

Our concerns are specific to MCB’s responses to corrective actions 2.2 and 2.4, in conjunction with the documents submitted per corrective action 2.5.

Corrective action 2.2 requires MCB to amend any agreements that MCB intends to use as a source of non-Federal expenditures for meeting its non-Federal share
obligation under the VR program to ensure they comply with 34 CFR 361.28.  MCB responded in 2.1 that it has discontinued the practice of establishing certified
match agreements with the school districts for the purpose of obtaining additional funds for match, and that in accordance with 34 CFR 361.28 or 34 CFR
361.60(b), third party agreements ceased in July/August 2009.  Therefore, we were confused about MCB’s response in 2.2 indicating that the agreements have
been reviewed and were determined to provide curriculum above and beyond the usual or customary services of the ISD, since these agreements have been discontinued.

Corrective Action 2.5 asked MCB to submit supporting documentation regarding the certified expenditures in the chart from 2.4.  The written information
including the three documents sent from the ISDs do not provide any information related to vocational or pre-employment activities, but refer only to staff
time and students served.  The Eaton agreement vaguely references O&M instruction, but does not identify vocational or pre-employment activities.  Our
review of the one-page agreements did not in fact provide any information at all regarding the nature of services provided under the agreements.  This
information does not support MCB’s response to 2.2.

Additionally, 2.4 requested that MCB complete the chart including the “Total certified funds from these agreements used for match in specified FY,” as well
as the “Total certified funds from the agreements, incurred in the provision of allowable services to eligible individuals in accordance with 34 CFR 361.28,
used for match  in specified FY.”  After a review of all submitted documentation, the information in the chart that indicates the $523,838 and $239,230
for FYs 2008 and 2009 (respectively) under the “Total certified funds from these agreements used for match in specified FY,” is also listed under the “Total
certified funds from the agreements, incurred in the provision of allowable services to eligible individuals in accordance with 34 CFR 361.28, used for
match in specified FY.”  However, the submitted documentation does not support that the $523,838 and $239,230 for FYs 2008 and 2009 were in fact allowable
as certified match.

In summary, the submitted documentation does not support that the $523,838 and $239,230 certified as match for FYs 2008 and 2009 was allowable; therefore,
the chart must be revised to state $0 for all five years of the third row (“Total certified funds from the agreements, incurred in the provision of allowable
services to eligible individuals in accordance with 34 CFR 361.28, used for match in specified FY”) since the submitted documentation does not support
that they were allowable under 34 CFR 361.28.  Additionally, MCB’s corrective action response for 2.2 must be revised in a manner consistent with 2.1 that
indicates MCB has discontinued its certified match agreements and that amending them is not required.

Please feel free to contact me with any questions or concerns.  We look forward to your updates.

Thanks, Craig

Craig McManus

Financial Management Specialist

Rehabilitation Services Administration

550 12th Street, S.W. Room 5004

Washington, D.C., 20202

202-245-6579

craig.mcmanus at ed.gov

-----
Original Message-----
From: Jones, Leamon (LARA) [mailto:jonesl2 at michigan.gov]
Sent: Tuesday, October 04, 2011 2:39 PM
To: McManus, Craig
Cc: Cannon, Patrick (LARA); Luzenski, Sue (LARA)
Subject: RE: CAP Follow Up
Importance: High

Hi Craig,

Please find the letters of support from St. Clair and Ingham ISD regarding the certified match. As you indicated that these are the last two documents being
requested in order to complete the information on the CAP.  I trust that these documents will provide you with the information necessary to answer the
questions regarding the certified match.  If you have further questions, please let me know. Thank you.

-----Original Message-----

From: McManus, Craig [mailto:Craig.McManus at ed.gov]

Sent: Thursday, September 01, 2011 7:27 AM

To: Jones, Leamon (LARA)

Cc: Cannon, Patrick (LARA)

Subject: CAP Follow Up

Good morning Leamon,

Trying to tie up a few loose sends.  Just checking on the progress of supporting documentation from the other ISDs related to the certified match agreements.
 The last paragraph in the below email relates to that and I will summarize here as well:  Attached is a PDF of the 3 agreements with Eaton, St. Clair,
and Ingham, a timesheet document for an individual named Nichole Ellwanger that is affiliated with Peckham but was sent under the impression that it was
someone involved in one of these three agreements, and finally the Eaton Letter.  Please provide supporting documentation similar to Eaton for Ingham and
St. Clair, as this information should be the missing link to close the loop, and clarify the agreement for which Nichole Ellwanger is affiliated.

Thanks,

Craig McManus

Financial Management Specialist

Rehabilitation Services Administration

550 12th Street, S.W. Room 5004

Washington, D.C., 20202

202-245-6579

craig.mcmanus at ed.gov

-----
Original Message-----

From: McManus, Craig

Sent: Thursday, June 09, 2011 2:54 PM

To: 'Jones, Leamon (DELEG)'

Cc: Cannon, Patrick (DELEG)

Subject: RE: Public Comments, PIP and CAP

Good afternoon Leamon,

I was hoping to get back to you sooner, but have not had the opportunity as I am in between two monitoring visits right now.

Regarding the State Plan requirements, we are following up with the VR Unit Chief to get guidance on how you should best proceed.

Regarding the PIP, thank you for your submissions.  Keep in mind a couple issues:  since you decided to provide your updates to the strategies and goals
by embedding them throughout the report, please identify and label each comment by date and quarter so that it will be easier to track chronologically
since multiple quarterly submissions will be required before the PIP is resolved; also, please move your quarterly PIP submission dates to the 15th of
the month following the end of each fiscal quarter (i.e. July 15, October 15, January 15, and April 15).

Finally, regarding the CAP, I reviewed the attached information which is a compilation of information you have provided on this over the past year or so.
 There is a PDF of the 3 agreements with Eaton, St. Clair, and Ingham, a timesheet document for an individual named Nichole Ellwanger that is affiliated
with Peckham but was sent under the impression that it was someone involved in one of these three agreements, and finally the Eaton Letter.  Please provide
supporting documentation similar to Eaton from Ingham and St. Clair, as this information should be the missing link to close the loop, and clarify the
agreement for which Nichole Ellwanger is affiliated.

Thanks,

Craig McManus

Financial Management Specialist

Rehabilitation Services Administration

550 12th Street, S.W. Room 5004

Washington, D.C., 20202

202-245-6579

craig.mcmanus at ed.gov

-----
Original Message-----

From: Jones, Leamon (DELEG) [mailto:jonesl2 at michigan.gov]

Sent: Thursday, June 09, 2011 10:46 AM

To: McManus, Craig

Subject: Public Comments, PIP and CAP

Importance: High

Good morning Craig,

The Michigan Commission for the Blind is conducting public meetings regarding its draft State Plan attachments.  The comments will be compiled from the
three meetings scheduled in Grand Rapids on June 16; Escanaba - June 20; and Detroit - June 23, 2011.  According to the Rehabilitation Act, it states that
a summary of the comments are suppose to be sent with the State Plan attachments.  Upon the compilation and summary of the comments, what section should
they be included in the draft State Plan?

On 5/6/2011, MCB submitted the PIP for the first and second quarter.  I'm just following up to see if you have any questions in regards to the submission
and its content.

Please let me know so that I will be able to make adjustments in the PIP report for the quarter ending June 20, 2011.

MCB submitted the corrective action that you had requested regarding MCB's certified match with Eaton ISD.  MCB's Commission meeting is June 17 and if you
could please give me an update in regards to the status of our CAP so that I could report to the Board, it would be highly appreciated.