[nfbmi-talk] finding ref of our resolution

[joe harcz Comcast]

Finding 6:  MCB has entered into many agreements, known as “cash match agreements,” with local school districts in MI for the purpose of providing non-Federal match funds for the VR program.  One of these “cash match” agreements is with the Macomb ISD.  The Macomb ISD receives $9,000 in funds earmarked as match funds for the VR program from New Horizons, a local private CRP.  New Horizons provides job placement services to MCB’s eligible consumers as a fee-for-service vendor.  Thus, New Horizons gives the Macomb ISD $9,000 to give to MCB for non-Federal match purposes; MCB, in turn, pays New Horizons to provide VR services.

  

Federal regulations governing the VR program permit private entities, such as New Horizons, to contribute funds to a State VR agency to assist it in satisfying its non-Federal share requirements so long as the donor does not benefit from the expenditure of those funds (34 CFR 361.60(b)(3)).  In this case, New Horizons benefits directly from the expenditures of its donated funds because MCB, in turn, pays New Horizons to provide VR services on a fee-for-service basis rather than under a contract awarded under the State’s regular competitive process.  Accordingly, MCB has failed to comply with the requirements of 34 CFR 361.60(b)(3) for the use of contributions from private entities for matching purposes.  

 

Corrective Action:  MCB must:

6.1       cease using Title I funds, including the match funds it receives from New Horizons for match purposes, in a manner that inappropriately benefits New Horizons as required by 34 CFR 361.60(b)(3);

6.2       submit a written assurance to RSA within 10 days of receipt of the final monitoring report that it will no longer use Title I VR funds and its matching funds to benefit private donors of those matching funds;

6.3       develop and implement policies and procedures to prohibit reversion of funds to benefit private donors; and

6.4       complete and submit the following source of match spreadsheet entitled, “Macomb ISD Cash Match/New Horizons,” that provides summary information on the total amount of funds Macomb ISD received from New Horizons for match, and the total amount used by MCB for State VR Services Program match in FYs 2005 through 2009: