If the member agency has other Member Representatives, any of them can approve the CFAD. If the agency has others in NOVA as contacts, but only one Member Representative, only that Member Representative will be able to approve.

Anyone approving the CFAD on behalf of an agency, must be Board approved by that agency to vote/act on their behalf. They will need to get a secondary Member Representative added to their next district Board meeting agenda and vote on approval for that person to carry out actions for the agency. Once that is done, the alternate member representative can be added in NOVA.

Unfortunately, there is no work around for this. Page 7 of the CAEP Program Guidance states: A member of the consortium shall be represented only by an official designated by the governing board of the member (84905 (c)).

We strongly urge all members to have a secondary pre-approved Member Representative to act on their behalf if something arises.

Distribution of COLA to members should be based on the consortium funding formula. Every member is entitled to receive a COLA. Consortia are not allowed to distribute differently.

You can attach both documents in the Supporting Documents section of NOVA, below the Annual Plan section. Please be sure to title them with a name that will identify they are part of the CFAD for this year.

The Member Agency section in NOVA will show all members, past and present. They are not listed in the Agency and Certifiers section, so they will not be required to approve the CFAD.

Question 13 on the CFAD Guidance, pertains to how the consortia approval of distribution process. While there is Ed Code that states no member can receive less than the prior year, there may be decisions made about the consortia pot, or a member no longer receiving funds (opt out/cannot provide service) or if there is a bylaw that allows for reallocation of carryover. This section is where you would provide how your consortia handles that.

Once the CFAD is approved and certified, it is a completed document that cannot be changed. The amendment will be an Allocation Amendment, to account for the addition/reduction in monies per member. The Allocation Amendment can be found on the main consortium page in NOVA, in the Allocation section (just below the CFAD section). Under the current year, there is a blue button that says "Start Amendment". If you would like to see all amendments that have been done, in the lower left of the Allocation box there will be a button that says "View Amendment History"

The CFAD is a document that can not be changed. What will have to happen is an allocation amendment. While the consortium lead will be the one to complete the allocation amendment, all member agencies will have to log in and approve it.

The red numbers will stay. The CFAD can't be changed. It is based on initial allocation amounts, prior to the May Revise. The reduction will be reflected in the allocation amendment that you completed.
The amounts in the Budget and Workplan include carryover, which is why they differ from the original Allocations.

Last year's CFAD still reflects the reduction in COLA because the CFAD was already approved prior to notification of the reduction. Your consortium completed an allocation amendment to reflect the COLA adjustment. That can be found in the Allocation section and then by clicking View Amendment History.

Consortia can add new member agencies to the CFAD once it is made available in NOVA.

Last year the COLA was reduced after the CFAD was completed. Because the CFAD is a governing document, once it is signed and certified, it is unable to be changed. Members completed an allocation amendment in June to account for the COLA reduction. The amendment took care of the COLA reduction, however since we are unable to change the CFAD, it will always show as a negative. It does not affect you going forward. You can disregard the negative it shows.

In January 2019, CAEP received a preliminary allocation, with a COLA, based on the Governor's draft budget. However, when the Governor signed the budget, CAEP received a reduction in COLA. Since the CFADs had already been submitted and certified, and we are unable to make changes, each consortium completed an allocation amendment to account for the reduction in COLA. Your consortium completed the allocation amendment to account for the reduction in COLA. As a result, there are no further changes to be made.

Your voting structure for approval is whatever is laid out in your by-laws for approval of a vote (majority, two-thirds, or unanimous).

Please check your consortium by-laws. Each consortium was able to select how voting was approved. Since members approved the By-Laws, that will be the direction you can follow.

The negative difference in the CFAD should equal the reduction in COLA that occurred last year after the CFADs were finalized. You completed an Allocation Amendment in June to reflect the reduction in COLA for accounting purposes.

Because the May Revise with reduced COLA came out after the CFAD closed, and the CFAD is a final document that can't be changed, all consortia will see a negative balance equaling their reduction in COLA. It will not affect you. We are working with NOVA regularly to make sure all numbers are accurate. Unfortunately the only way NOVA could account for the reduced COLA was to show it as a negative in the system.

You're correct - NOVA is pre-populating last year's allocations; however, you will enter members' total allocations, including the proposed COLA, to equal the consortium's total preliminary allocation. Once you do this, your Total Allocated to Members will increase to equal the Total CAEP Funds and the Total Remaining will equal zero.

Based on what I am seeing - you are over allocating for 2020-21.The allocations that were pre-populated in NOVA included last year's reduced COLA. For this year, all you will need to do is add your consortium's allocation with this year's 2.29 percent COLA.This will bring your Total Remaining down to zero.

Based on what I am seeing - you are over allocating for 2020-21.The allocations that were pre-populated in NOVA included last year's reduced COLA. For this year, all you will need to do is add your consortium's allocation with this year's 2.29 percent COLA. This will bring your Total Remaining down to zero.

The Consortium Lead forwarded the email sent to them, to all members as a reminder. The link in that email was specific to the Consortium Lead, so when other members clicked on it, NOVA recognized them as the lead and put that name as the certifying authority. NOVA will allow you to send reminder emails through the system to all members. No lead should ever forward their email and link to others.

All members must certify the CFAD (funded or not). But if you followed your decision making by-laws, and the member is not going along with the agreed decision, we can go into NOVA and certify the CFAD for that member (or override). We would just need the minutes from the public meeting, and the by-laws that you followed to make the decision for documentation purposes.

You should zero out for the current year. Your previous year will remain unchanged, with the negative balance.

As for the COLA, for this year you will calculate that yourselves. The calculation will equate to the percentage of the total allocation each member receives. You will use that same percentage to divide the COLA amongst all members. Unless your By-Laws specifically state the COLA be divided differently.

The negative balance from 2019-20 will remain and is not impacting 2020-21.

For 2020-21, the base allocations are pre-populated - they are your 2019-20 allocations with the reduction in COLA. All that is left for you to do is distribute the 2020-21 COLA based on the consortium's funding formula. Once the COLA has been distributed, your Total Remaining CAEP Funds for 2020-21 will be zero.

These funds would need to be given via an allocation amendment, thus making it a one-time transfer of funds. The member agency receiving the monies and providing the instruction would reports hours of instruction, etc. in TE and on their program area report. Your agency would not report anything since you no longer have the money for the year, and you do not offer instruction.

You are unable to give the new member money until July 1st, when the CFAD marking them as funded goes into effect. Once they are funded (July 1), you can do an allocation amendment to give them a one-time additional pot of funds. You can give it from the oldest pot available, which may be the 21/22 funds (if you've spent all your 20/21 funds).

You would do an allocation amendment to give the member extra money. An allocation amendment is a one time move of funds. The funds would be automatically added to their Budget but you will need to un-certify for them so they can go in and assign the extra money to object codes. They then submit and you re-certify.

You will be able to find the consortium allocation on the website at
https://caladulted.org/Administrators/14 (HOME > ADMINISTRATORS >FUNDING >ANNUAL >CAEP ALLOCATION) The breakdown for each member is not determined by the state. Please review NOVA, specifically the CFAD, to see the member allocation per year. It is important to look at the Allocation Amendments for each year; any moving of money after the CFAD was certified will be recorded there. If you scroll to the Allocation section in NOVA and click on view Amendment History, there will be a list of all amendments and that will show your true and final allocation for the year. Please note that multiple amendments can be done within a year so look for the last updated amendment.

The COLA is divided across all consortia members based on the state-identified funding formula. Employee salaries and benefits are negotiated items determined by each district, county office, or Joint Powers Authority (JPA). Individual member agencies cannot decide to pass down the cola increase to employees' salaries. The agencies must use the district’s process to negotiate and approve salary increases.

Yes - all members who have soon-to-expire funds remaining will need to spend down by December 31st or return the remaining balances to the State. The state will be conducting an audit of end-of-life-cycle balances soon. Although the members balances say they have funds remaining, the FIFO chart shows the consortium no longer has those funds available. If you think something is incorrect, please ask you member to verify with their district that all their soon-to-expire funds have been spent.

Yes, the two members will need to approve the prior allocation amendment for NOVA to update the totals to start the next amendment.

A new Allocation Amendment will need to be done for the July increase. The amendment summary can be updated in the new amendment.

The allocation information is in the NOVA fiscal management system. Each consortia member allocations are listed.

Prior year allocations can be found on the CAEP website, caladulted.org. You will click on Administrators, Funding and then Annual CAEP Allocations. There you will find the allocation schedules by year.

Below are a few options to support your request:

1. Consortium with member agreement can always make one-time allocation amendments during the year. This means going into NOVA and moving funds from one district to another. Since your consortium is direct funded – you would have to physically transfer money around among members. Allocation amendments have no impact on the annual allocations via the CFAD (which by statute is based on prior year amounts). But you can use whatever mechanism you want for the reallocation adjustment discussion following your by-laws for one-time re-allocations.

2. Now, if the consortium wanted to adjust the annual allocations via the CFAD – there is specific education code that must be followed. This cannot be superseded by by-laws. Rules under EC 84914 (a) Member gets the same amount as they did in the prior year. (b) For the COLA – member receives the same proportional share based on prior year funding. (c) Member annual allocation amounts maybe reduced as follows (1) the member no longer wishes to do what they said they were going to do, (2) the member can’t do what they said they were going to do, or (3) member is ineffective.

Link to the education code: https://leginfo.legislature.ca.gov/faces/codes_displaySection.xhtml?lawCode=EDC&sectionNum=84914.

If the consortium wants to change the amounts for the upcoming year, you must have members that no longer wish to provide services according to the 3 year/annual plan, or can’t provide the services, or are ineffective and reasonable intervention have not resulted in improvements.

The coming year's allocations are posted in the CFAD section of NOVA. Once the consortium certifies the CFAD, the allocations will move to the Allocations section of NOVA.

If the consortium wants to fund new members that have no prior year funding, they should use the allocation amendment process after the CFAD is submitted to reallocate consortium funds to the new member.

The best explanation is in our fiscal management guide Section 2.

Here is the folder on the website with the detailed formula

The CFAD is the official allocation document for each year. We advise consortia if they are going to do a one-time allocation, to do this using the allocation amendment process after the CFAD is submitted. Per State regulations, the member may receive no less than the prior year’s CFAD unless there is cause to reduce their allocation (EC 84914).

So if that member received a 1% COLA on the CFAD, than that increase would be reflected in this year’s calculation. Using the current years official CFAD, all members would receive an allocation amount proportional to the percentage they received last year.

If the 1% was given via an allocation amendment and not the CFAD, then you will not be required to give it again this year.

There is no way to discern this information in NOVA. In NOVA, you can use the FIFO chart to see the remaining funds, by FY, for the member who is holding the common consortium funds. However, the member would have to determine of their available funds, how much is the common consortium funds.

Yes - you will complete an allocation amendment based on the fund year you are re-allocating the monies. For example, like I used in the webinar, if a member will not use all of their 2018-19 funding by the expiration date, you would complete an allocation amendment for 2018-19 to move monies from one member to the next.

Based on CAEP policy:

1. Allocation decisions and any consortium decision must be discussed via a public meeting (per CAEP ed code).
2. Members must receive the same amount as in the prior year (EC84914)
3. Only members that meet one of the three criteria in EC84914 can have their prior year amount reduced.
4. For 20-21 – all members are eligible for the COLA – unless the consortium invokes EC84914.
5. Voting on who gets the COLA is not allowable. Everyone is eligible for the COLA (unless you invoke EC84914).

Q: Do member allocations for the May 2nd due date require 100% member participation?
A: Yes – all members must be at a public (virtual) meeting to discuss & decide on the CFAD that is due 5/2. Decision making & public meetings are mandated in the CAEP ed code. All members must certify the CFAD in NOVA after the public meeting & decisions are made by the members.

Q: Does approval require consensus?
A: Approval requires certification via NOVA by each member. How the consortium comes to an allocation decision is based on their by-laws. But – under ed code 84914 – each member receives the same amount as the prior year. Per CDE/Chancellor’s Office (official guidance for 20-21) – all members are eligible to receive the COLA – based on the proportional share from the prior year allocation. So the members are kind of lock in on the decision making unless a member invokes EC84914 to reduce their allocation amount.

Q: We are not looking to reduce the prior year’s allocation just reserve COLA with the fiscal agent.
A: Since State guidance says all members must receive a proportional share of the COLA, in order to reduce a member’s COLA from their proportional share – you must cite cause under EC84914. If you invoke 84914, you must cite that in you CFAD narrative and all members must agree to it by certifying.

Q: Additionally, we are amending 19-20 allocations to increase one of our members. Does that require a vote at a public meeting or just approval in NOVA?
A: Any decisions by the consortium must be done in a public meeting setting per the CAEP education code. Once approved via the public meeting, all members must certify the allocation amendment in NOVA (along with the new budget and any change to the member’s plan).

Q: Can member A just email and request the fiscal agent reduce their allocation to fund member B and then approve in NOVA?
A: You must have public meeting minutes to track all decisions for the consortium. Plus all members must approve/certify in NOVA.

With a corrective action plan, the consortium can extend from June 30th and have a new spend down date of December 31st for the remaining funds.

You can always invoke Ed Code 84914 to reduce a member below their proportional amount if it qualifies under at least one of the three criteria of 84914. That could be one way of reducing consortium held funds. But members would have to agree that it would meet at least one of the criteria under EC 84914 and certify the change in NOVA. If the criteria for reducing an allocation does not fit, there is another way. The reduced amount has been applied to each agency in NOVA. So while that must stay the way it is, there is a way for you to give funds to them to recoup what they were reduced by. It will take a little more work on the college's part. 1. First, all members who will receive an allocation for 20-21, including the college, must all submit an allocation amendment for the May Revise reduction. 2. The college can then do one allocation amendment for each member to move the same amount that was just reduced, over to the member. If they funds being moved are from 19-20, then the allocation amendment will need to happen in the 19-20 Allocation section. This is more work on the college. If you have 5 members, you will have to do a total of 6 amendments; one for 20-21 May Revise and then one for each member.

It is advised that members meet to discuss the May Revise reductions; however, consortia should check with their districts to see if a public meeting, including a vote, is required.

It is also advised for consortia upload their meeting minutes or discussion notes in the Supporting Documents section in NOVA.

When you met last month, that was to certify the original allocations, before the reduction, correct?

If so, it will be a district decision if another meeting/vote is required.

If it is not required, you will still want to upload the minutes from the previous meeting where the vote was held to approve the allocation.

Per the Fiscal Management Guide, it states, CAEP funds cannot be co-mingled with fee-based programs. In this case, since the truck is proposed to be used as part of a fee-based service, the truck cannot be used. See except below. Unfortunately, per the Fees Policy section in the Fiscal Management Handbook on pages 15 and 16:

1. Program Fees

... In addition, community college community education fee based programs (community education and contract education) cannot be co-mingled, leveraged or braided with CAEP funds. Title V regulations, and education code prevent community college fee based programs to be combined with any state apportioned program (like CAEP). However, these programs can work with regional consortium for student referrals to meet regional needs.

You can view the Fiscal Management Guide here: https://caladulted.org/DownloadFile/1300

We suggest using other funding sources because this could be considered a gift of public funds, which is against the funding rules for AEBG/CAEP.

CAEP covers only noncredit and K-12 adult education. Using CAEP funds for not-for-credit (aka community service / community education) is not allowable. Not-for-Credit has its own education code and they can charge fees, they don’t need Chancellor’s Office approval, but they have to be self-sustaining (meaning they can’t use general funds (like noncredit apportionment or CAEP funds)).

Noncredit rules do not apply. Community Ed/Services or Not-for-Credit rules or ed code will apply in this case (EC 78300)

Not-for-credit courses can charge a fee, but any fee cannot exceed the cost of maintaining the class (EC 78300).

This is not an allowable use of funds. This would be considered a gift of public funds. The best solution would be to find another funding source that is able to cover the expenses.

Some notable points to consider to determine if this is an allowable expense:

· Since CAEP is restricted funding, the CAEP office would need more specifics about the student worker position/duties to determine if its allowable.

· Would need to specify what the student worker role/duties would entail and the specific program it would work under.

· Not all noncredit programming is covered by CAEP so that would be a red flag.

· CAEP funds would have to be restricted to only CAEP programming.

This language is from the CAEP Fiscal Management Guide. The funds could be used to pay for staff who work to support CAEP and within the seven program areas. However, student worker positions in community colleges can depend on the specific factors listed above. Along with it being listed in their 3 year plan, annual plan, and the position works to support CAEP programming directly.

CAEP Fiscal Management Guide reference:

(Pg 11)

• Funds may only be expended within the seven program areas as prescribed in the CAEP education code (Section 84913).

• Each regional consortium must have an approved 3-year consortia plan that includes any amendments (submitted in Year 1 – 19/22).

• Expenditure of CAEP Funds must align with the annual plan as approved by the regional consortium for that specific year.

• All CAEP expenditures must be reasonable and justifiable. “Reasonable” means that expenditures will be made prudently and with every effort to utilize funds efficiently. “Justifiable” means that expenditures are consistent with CAEP program goals and activities related to the seven program areas as identified in the CAEP Program budget language.

(Pg 12) All allowable costs must meet three primary criteria:

• Substantiate that the cost was necessary and reasonable for proper and effective administration of the allocations.

• The cost must be allocable to the funding source activities.

• The cost must not be a general expense required to carry out the consortia member’s overall responsibilities (i.e. not supplanting).

• However, even if the costs meet the prior three criteria, the costs must be approved within the 3-year consortia plan and the annual plan template of the regional consortia as agreed upon by its membership.

Examples of Allowable Expenses by CAEP Types of Activities

(Pg 45)

Supplemental instruction and tutoring: Purchase of a web-based interactive program of supplemental instruction for CAEP. Purchase of training videos, or online training videos, or similar that supplement CAEP instruction. Direct tutoring to adult education students in CAEP areas. Supplemental instruction for CAEP students. Salary of teaching assistants assisting CAEP instructors.

Coordination: Salary of CAEP coordinator, or assistants, or project leads for hours of service provided, not to supplant a teaching salary. Cost of seminars to raise CAEP awareness among faculty. Cost of a consultant providing services to create, coordinate, and implement CAEP programs.

Example of Expenses Not Allowed or that Need Prior Approval (specific to CAEP) include, but are not limited to:

1. Other Staff Salaries and Benefits
   Program funds cannot be used to pay for any staff that does not directly support the CAEP services described in the consortium’s approved plan.

Based on the notable points, more information is needed and input acknowledging that the Fiscal Management Language is being met.

All capital outlay requests require an informational email stating the following has/promise it will, occur:

1. Consortium has approved the capital outlay and expense (provide date item was approved)
2. The project aligns with the Three-Year/Annual Plan for the consortium
3. Provide the quote for work done
4. 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.

Once the expense is approved and aligns with the consortium plans, the consortium lead will need to submit an informational email/request via the Support Ticket system to CAEP TAP. Please attach the quote, if one is available, and acknowledgement of item #4.

The CAEP Office will review and reach out if they have any further questions. The email is informational only, so if CAEP does not reach back out with questions, you are welcome to move forward with the planning of the project.

Yes – using the NOVA allocation amendment, you can move funding to the Adult School.

Hopefully, the cost the adult school is paying for the roof replacement covers their share of the facility – meaning the CAEP funds used are benefiting only CAEP programs. The CAEP Office cannot allow CAEP funds to benefit non-CAEP programs.

They must use their districts procurement policies and procedures.
Since you are moving carry-over or prior year funds in NOVA via the allocation amendment, the fiscal agent will have to facilitate the transfer of actual funds from one member to the adult school. NOVA tracks, records, updates, and displays – but the members have to move the money physically from one member to the other member.

Per the CAEP Fiscal Management Guide, Section 8 on Capital Outlay Guidance “Capital outlay expenditures need to be submitted by the requesting Member-district to the consortium’s governing board for review and approval. Once the consortium has reviewed, approved, and established that the expenditures are aligned with the Consortium’s three-year plan, the consortium will send an informational email to the CAEP Office to inform them of the proposed expenditures.”

Once the amendment is complete, the adult school will update their member work plan and budget to reflect the additional funds (and their use). They will handle all reporting of these funds.

CAEP does not stipulate how expenditures are classified. The only stipulation CAEP has is that expenditures for construction/remodeling/and the like is a Capital Outlay (6000 object code) expense. For expenses that may be over a certain dollar amount, please defer to the district policy for how those expenses are categorized internally. CAEP reporting lists all 6000s as one, no matter the dollar amount.

In response to your inquiry of using CAEP funds to buy food to run the ESL café and offer a related CTE contextualized course:

Current education code and existing guidelines….

CAEP funds are restricted funds and cannot be used to purchase food.
CAEP funds can be used to purchase material and supplies for courses in the seven CAEP program area (ABE/ASE, ESL/Civics, CTE (vocational, workforce prep, & pre-apprenticeship), Adults with Disabilities, and K-12 Success).
When using CAEP funds, districts must follow their procurement policies and procedures.
Fund 11, which is set up for Adult Education, typically cannot be used to account for business type transactions.
The district would need to use a revolving fund (or some other approved mechanism) to account for the ESL Café operations, which typically involves the districts policies and procedures, and perhaps their governing board, on how and where to account for these transactions.

Recommendation: The CDE Adult Education Office recommends that the Adult School be allowed to use CAEP funds for materials and supplies related to its CTE and/or contextualized courses. The ESL Café should be operated separately by the district, and would not be allowed to use CAEP funds in its operation. The district must manage this partnership and create a fiscal firewall between the CTE/contextualized course(s) and the operation of the ESL Café. Adult Education (Fund 11) cannot be used to account for business transactions. The district would need to follow its current policies and procedures to account for the ESL Café operations expenditures and income through a revolving fund (or other approved mechanism).

Should the district need accounting transactions guidance, they can contact our CDE School Fiscal Services sacsinfo@cde.ca.gov.

Upon reviewing the appropriate documents, this would not be an appropriate use of CAEP funds. Covering the costs of student fingerprinting, providing them free supply kits that leave the program – are considered a gift of public funds – and not allowable under CAEP. There is no fee waiver for such costs in the community college student fee handbook

What would be allowable is if they loan students items that could be checked and returned at the end of the semester. In this case, fingerprinting and a cosmetology supply kit, wouldn’t be something that could be loaned out (like a textbook would). Some community colleges are using CARES/HEERF grants to students to pay for health career education classes (CNA, EMT, Med Asst., etc.). In addition, some colleges have sent students to the AJCCs (America’s Job Center of CA) to obtain training funds to pay for such costs.

In summary, CAEP funds would not be an allowable use is this case.

This is an allowable use of CAEP funds, as long as you aren't using CAEP fund to pay the students. All the materials & supplies will stay with the program (so no gift of public funds) and you are serving 18 year old students and above that have graduated from HS.

This is allowable and you can move forward with the partnership.

Those activities are not allowable with CAEP funds. It would be considered a gift of public funds. The guidelines/policies can be found in the Fiscal Management Guide on the CAEP website here https://caladulted.org/DownloadFile/1300.

Yes – that’s fine. If you didn’t receive the funds during the time period July 1, 2017 to June 30, 2018, then please do not report those expenses.

Please check the California Commission on Teaching Credentialing for the requirements. You can visit their website here https://www.ctc.ca.gov/.

Please prorate the class expenses to reflect the share of the AE students.

While there is no specific language that states LEAs are not required to approve each individual expenditure, language is there that says all expenditures must be laid out in the Annual and 3 Year Plan, which the members approve. If the cost is not in the Annual/3 Year Plan, it is not approved and cannot be expended. If it is in the plan(s), approval was already received when they approved the plan(s) and no further approval is needed.

The Allowable Uses of Adult Education Block Grant Funds section of the Fiscal Management Guide:

All allowable costs must meet three primary criteria:
1) Substantiate that the cost was necessary and reasonable for proper and effective administration of the allocations.

The CHSPE is valid in the state and considered equivalent to a high school diploma, which allows CAEP funds to be used.

Depending on the learners goals there are some considerations when advising them on next steps:

The CHSPE is only a test offered in CA. A learner that is 18 or older should probably take the GED or HiSET based on how well known these tests are outside of CA

Some adult learners may want to take the CHSPE because there is no maximum age and only has Math and ELA sections, where the GED/HiSET include history, social studies, and science.

Regarding using CAEP funds for GED testing, depending on how the district processes the request, it could be a gift of public funds. Please check if your district has policies and procedures to assist students on paying for testing. The district would have to follow some equitable arrangement to see if the most in need receive the service. It is advised to get the district approval in writing and keep it on file.

Per the CAEP Fee's Policy, career and technical education
(CTE) programs include the following: 1) Short term CTE with high employment potential; 2)Adults, including but NOT limited to older adults, entering or re-entering the workforce; and
3) Pre- apprenticeship conducted in coordination with one or more DAS approved apprenticeship programs.

Career and technical education programs offered by K12 adult
schools are considered part of the CAEP program, but K12 adult school providers are allowed to charge fees for these programs. K12 adult CTE programs are subject to all state requirements under CAEP including course approval, credentialing, andstudent data reporting. The K12 adult CTE student fee structure must be included in the consortia annual plan.

The Fiscal Management Guide and CAEP Fees Policy can be found on the CAEP website at https://caladulted.org/Administrators/20

This is not an allowable use of CAEP Funds. Although the Fiscal Management Guide does not list legal fees specifically, it is classified the same as Fees and Penalties, which is item# 7 on the last page of the Guide. It states:

Fines and Penalties Costs resulting from violations of, or failure of the institution to comply with, Federal, State, and local or foreign laws and regulations are unallowable, except when incurred as a result of compliance with specific provisions of the sponsored agreement, or instructions in writing from the authorized official of the sponsoring agency authorizing in advance such payments

Additionally, on page 12 it states: all CAEP expenditures must be reasonable and justifiable. “Reasonable” means that expenditures will be made prudently and with every effort to utilize funds efficiently. “Justifiable” means that expenditures are consistent with CAEP program goals and activities related to the seven program areas as identified in the CAEP Program budget language.

Legal fees pertaining to a former employee are not considered reasonable or justifiable, per CAEP Statute.

Per the guidance from the State, the proposed expenditure of mileage reimbursement for students appears to be a gifting of public funds, which is nonallowable under CAEP.

Please note that ultimately CAEP regional consortia members are responsible for allocation decisions. CAEP expenditures must be reasonable and justifiable. In this context, “reasonable” means that expenditures will be made prudently and with every effort to utilize funds efficiently, and “justifiable” means that expenditures are consistent with CAEP program goals and activities related to the seven program areas as identified in the CAEP Program budget language.

As outlined in the CAEP Fiscal Management Guidance, ensuring all allowable costs must meet three primary criteria (p. 12):

1) Substantiate that the cost was necessary and reasonable for proper and effective administration of the allocations.
2) The cost must be allocable to the funding source activities.
3) The cost must not be a general expense required to carry out the consortia member’s overall responsibilities (i.e. not supplanting).

Indirect is used for any costs that do not directly touch the program, such as business office staff time, possibly an overseeing administrator's time, etc. Direct program costs are the principal, teachers, materials, etc. Indirect costs are all the items behind the scenes. They should use indirect for that staff time, not pull it from the general CAEP funds.

Each member is allowed to put 5% of their allocation, or their approved indirect rate, whichever is LESS, towards indirect expenses. They will budget for that in the Budget and Workplan. Please keep in mind that the amount of indirect budgeted is pulled from their allocation. It is not additional funds given.

Districts have the authority to pay student fees using California College Promise (AB 19) funds. The payment of student fees would definitely meet the goals of the legislation.

Individuals with disabilities must be served by a school district until age 22. This would apply for any program, for any student under 22.

This is an allowable expense as long as there is a formal process in place for students to check the books in and out, and the student agrees to return the books. Some agencies have created formal agreements for students to sign as an example.

Books are to be loaned to students, unless it is a consumable workbook. There should always be an expectation that the books will be returned. If they are not then that is up to the agency to determine their process for lost materials.

Per the CAEP Office, this request is considered furniture and space improvement. Furniture and space improvement is an allowable expense under CAEP. CAEP advises you to follow the part in the fiscal guidance that says ""reasonable and necessary."" In addition, the CAEP advises you to follow the district's process for requesting a reasonable accommodation - like a medical note, etc.

One question to keep in mind is - what happens if that employee moves on to another office within the district and is no longer working with adult education - does the desk follow the employee? What's the district's policy for this scenario? Please refer to the district's policy if its a reasonable accommodation.

Student supports are allowable with CAEP funds, but you must follow district policies & procedures to ensure that their use is equitable & efficient. Gift of public funds is not allowed. Please find another fund source for incentives.

As long as the CAEP funds are being used in the seven programs areas, and you’re following the CAEP rules – you can purchase equipment.

But if these are new to your plan (and the consortium didn’t approve them), you should have these approved in a public meeting.

There are certain requirements that are essential for using adult education funds.

1. Adult Education funds can only be used on students 18 years or older (so you can't serve continuously enrolled high school students).
2. Members must report student data & outcomes in the TOPSPro system (if K12 adult or County Office).
3. Members must participate in the planning & budgeting process via NOVA (3 year plan & annual plan).
4. Member funds must be expended in the seven program areas, and services provided must be consistent with the annual & 3-year plan.
5. Member expenditures of adult ed funds must match the objectives and activities included in the Annual Plan.
6. Members must participate in consortium/public meetings and be a part of the decision-making process.
7. Members must share information on programs offered, and the resources being used to support the programs.
8. Members must provide services that address the needs identified in the annual & 3-year plan.
9. Members must file quarterly expense reports, and certify consortium fiscal processing of funds (CFADs, amendments).

So provided that you are following all these requirements, you are allowed access to adult education funds.

Please note: if the construction shop or other CTE programs are used by both HS students and adult students, than the use of adult education funds would have to be pro-rated based on enrollment numbers as to what is an allowable use of funds (we would want to avoid supplanting funds). No sure the cost of the expansion, but would you be able to offer courses during the renovations?

There are certain requirements that are essential for using adult education funds.

1. Adult Education funds can only be used on students 18 years or older (so you can't serve continuously enrolled high school students).
2. Members must report student data & outcomes in the TOPSPro system (if K12 adult or County Office).
3. Members must participate in the planning & budgeting process via NOVA (3 year plan & annual plan).
4. Member funds must be expended in the seven program areas, and services provided must be consistent with the annual & 3-year plan.
5. Member expenditures of adult ed funds must match the objectives and activities included in the Annual Plan.
6. Members must participate in consortium/public meetings and be a part of the decision-making process.
7. Members must share information on programs offered, and the resources being used to support the programs.
8. Members must provide services that address the needs identified in the annual & 3 year plan.
9. Members must file quarterly expense reports, and certify consortium fiscal processing of funds (CFADs, amendments).

So provided that you are following all these requirements, you are allowed access to adult education funds.

Please note: if the construction shop or other CTE programs are used by both HS students and adult students, than the use of adult ed funds would have to be pro-rated based on enrollment numbers as to what is an allowable use of funds (we would want to avoid supplanting funds).

As long as those students are 18 years old and separated from the high school - and you get consortium approval (and share those renovations through the State CAEP Office) - you're good.

Here's the fiscal guide on capital outlay.

1. Capital Outlay
   Any capital outlay (including building improvements, rental space, leases, construction, etc.) will also be closely scrutinized. It will require that you notify the CAEP Office of your consortium’s (including any member in that consortium) intent. This is an informational e-mail only. The CAEP 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.

Procedure:
Capital outlay expenditures need to be submitted by the requesting Member-district to the consortium’s governing board for review and approval. Once the consortium has reviewed, approved, and established that the expenditures are aligned with the Consortium’s 3-year plan, the consortium will send an informational email to the CAEP Office to inform them of the proposed expenditures.

Yes – supportive services are allowable for students enrolled in the CAEP seven program areas. It should be noted in the approved annual plan and budget.

Please see the CAEP policy on fees. The CAEP policy on fees only covers CAEP program areas. Older adults, community education, and some parent education are not covered under CAEP therefore CAEP funds cannot be used for these programs, with the exception parent education, which could fall under K12 Success.

The CAEP memo only covers tuition, not material fees. Providers are advised to check with CDE for material fees questions.

Please see the current CAEP policy on fees.

But to find out about material fees - please see the Community College Student Fee Handbook.

No – CAEP funds cannot be used for non-CAEP programs. CAEP has not been flexed – so they are still restricted funds for K12 adult /noncredit use. No language nor legislation has been passed by the legislature and signed by the governor that allows for this flexibility.

CAEP funds can be used as long as the building is used by CAEP programs. If there are other non-CAEP programs at the site (community ed, older adults, credit community college, etc.) – then it must be a shared cost/split funded.

CAEP funds can be used to provide support services (like childcare) for adults attending CAEP classes in the CAEP program areas. The childcare would be limited to those hours that the adult is attending a CAEP funded class.

Contract Ed is not Non-Credit and would not be an allowable expense. Non-Credit is okay. Not-For-Credit is not allowable. Community Ed or Contract Ed are NOT the intent of CAEP funding.

Please refer to Program Fee Policy / Fiscal Management Guide (Page 15) for fee-related queries. There is a K-12 Adult School exception for CTE – but please go to the website and review the policy. Providing the medical assistant program fits into your CTE offering than you should be able to collect fees and use CAEP funds. Fiscal Management Guide (Updated March 2023) https://caladulted.org/DownloadFile/1300 . Program Fees Current fee policy for CAEP is identified in CDE’s Management Bulletin Management Bulletin AEFLA-02-2013 (for K-12 district and County Office of Education), and the Community College Student Fee Handbook (for community college districts). In addition, community college community education fee-based programs (community education and contract education) cannot be co-mingled, leveraged or braided with CAEP funds. Title V regulations, and education code prevent community college fee-based programs to be combined with any state apportioned program (like CAEP). However, these programs can work with regional 15 consortium for student referrals to meet regional needs. Effective July 1, 2018, please reference the CAEP fees policy on the CAEP website. The policy states that no tuition may be charged or collected in the following CAEP program areas by either community colleges or K12 adult schools (ABE, ASE, ESL, AWD, and K-12 Success). There is a K-12 Adult School exception for CTE – but please go to the website and review the policy. CAEP Fee Policy https://caladulted.org/DownloadFile/178

Please refer to Program Fee Policy / Fiscal Management Guide (Page 15) for fee-related queries. There is a K-12 Adult School exception for CTE – but please go to the website and review the policy. Providing the medical assistant program fits into your CTE offering than you should be able to collect fees and use CAEP funds. Fiscal Management Guide (Updated March 2023) - Program Fees Current fee policy for CAEP is identified in CDE’s Management Bulletin Management Bulletin AEFLA-02-2013 (for K-12 district and County Office of Education), and the Community College Student Fee Handbook (for community college districts). In addition, community college community education fee-based programs (community education and contract education) cannot be co-mingled, leveraged or braided with CAEP funds. Title V regulations, and education code prevent community college fee-based programs to be combined with any state apportioned program (like CAEP). However, these programs can work with regional 15 consortium for student referrals to meet regional needs. Effective July 1, 2018, please reference the CAEP fees policy on the CAEP website. The policy states that no tuition may be charged or collected in the following CAEP program areas by either community colleges or K12 adult schools (ABE, ASE, ESL, AWD, and K-12 Success). There is a K-12 Adult School exception for CTE – but please go to the website and review the policy.

When it comes to fees, Please find below the program fees policy and a link to the fiscal management guide where you can view program fees on page 15. There is a K-12 Adult School exception for CTE – but please go to the website and review the policy. Providing the medical assistant program fits into your CTE offering than you should be able to collect fees and use CAEP funds. See references below.

Fiscal Management Guide (Updated March 2023) https://caladulted.org/DownloadFile/1300

1. Program Fees Current fee policy for CAEP is identified in CDE’s Management Bulletin Management Bulletin AEFLA-02-2013 (for K-12 district and County Office of Education), and the Community College Student Fee Handbook (for community college districts). In addition, community college community education fee based programs (community education and contract education) cannot be co-mingled, leveraged or braided with CAEP funds. Title V regulations, and education code prevent community college fee based programs to be combined with any state apportioned program (like CAEP). However, these programs can work with regional 15 consortium for student referrals to meet regional needs. Effective July 1, 2018, please reference the CAEP fees policy on the CAEP website. The policy states that no tuition may be charged or collected in the following CAEP program areas by either community colleges or K12 adult schools (ABE, ASE, ESL, AWD, and K-12 Success). There is a K-12 Adult School exception for CTE – but please go to the website and review the policy.

CAEP Fee Policy
https://caladulted.org/DownloadFile/178

When it comes to fees, please refer to Program Fee Policy / Fiscal Management Guide (Page 15). There is a K-12 Adult School exception for CTE – but please go to the website and review the policy. Providing the medical assistant program fits into your CTE offering than you should be able to collect fees and use CAEP funds. See references below. Fiscal Management Guide (Updated March 2023) https://caladulted.org/DownloadFile/1300 5. Program Fees Current fee policy for CAEP is identified in CDE’s Management Bulletin Management Bulletin AEFLA-02-2013 (for K-12 district and County Office of Education), and the Community College Student Fee Handbook (for community college districts). In addition, community college community education fee based programs (community education and contract education) cannot be co-mingled, leveraged or braided with CAEP funds. Title V regulations, and education code prevent community college fee based programs to be combined with any state apportioned program (like CAEP). However, these programs can work with regional 15 consortium for student referrals to meet regional needs. Effective July 1, 2018, please reference the CAEP fees policy on the CAEP website. The policy states that no tuition may be charged or collected in the following CAEP program areas by either community colleges or K12 adult schools (ABE, ASE, ESL, AWD, and K-12 Success). There is a K-12 Adult School exception for CTE – but please go to the website and review the policy. CAEP Fee Policy https://caladulted.org/DownloadFile/178

Yes, you can. As long as the purchase is for a CAEP Program Area and will only benefit CAEP students. If the lab will be shared by credit and non-credit, the price of the project will need to be split according to the usage split. If only CAEP funds are used, the district will need to acknowledge that it is only for use of CAEP students. You will need to follow the Capital Outlay steps defined by CAEP: All capital outlay requests require an informational email stating the following has/promise it will, occur: Consortium has approved the capital outlay and expense (provide date item was approved). The project aligns with the Three-Year/Annual Plan for the consortium, Provide the quote for work done, 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. Once the expense is approved and aligns with the consortium plans, the consortium lead will need to submit an informational email/request via the Support Ticket system to CAEP TAP. Please attach the quote, if one is available, and acknowledgement of item #4. The CAEP Office will review and reach out if they have any further questions. The email is informational only, so if CAEP does not reach back out with questions, you are welcome to move forward with the planning of the project.

All capital outlay requests require an informational email stating the following has/promise it will, occur:
*Consortium has approved the capital outlay and expense (provide date item was approved)
*The project aligns with the Three-Year/Annual Plan for the consortium
*Provide (attach) the quote for work done
*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. Once the expense is approved and aligns with the consortium plans, the consortium lead will need to submit an informational email/request via the Support Ticket system to CAEP TAP. Please attach the quote, if one is available, and acknowledgement of item #4. The CAEP Office will review and reach out if they have any further questions. The email is informational only, so if CAEP does not reach back out with questions, you are welcome to move forward with the planning of the project.

The CAEP Fiscal Management Guide (2023) states: Food and Beverages - funds can be used to provide food or non-alcoholic beverages for students or staff, provided that there is no local board policy prohibiting these costs. Food and beverage costs must be for activities or functions consistent with the objectives of the CAEP 3-year Consortia Plan and the Annual Plan. Funds cannot be used to pay for general activities such as open houses or other events not directly related to CAEP. Generally, if you have a sign-in sheet and an agenda that includes CAEP-specific items, this would be approved. For students, this might be an exit survey or focus group around CAEP programming. For staff, this might be a planning meeting, a PD Day, etc.

You would send the Capital Outlay request to us via an email or support request, and we forward for review to the CAEP leadership. All capital outlay requests require an informational email stating the following has/promise it will, occur: - Consortium has approved the capital outlay and expense (provide date item was approved) - The project aligns with the Three-Year/Annual Plan for the consortium - Provide the quote for work done (you have, but just reattached to the new email) - 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. - Once the expense is approved and aligns with the consortium plans, the consortium lead will need to submit an informational email/request via the Support Ticket system to CAEP TAP. Please attach the quote, if one is available, and acknowledgement of item #4. - The CAEP Office will review and reach out if they have any further questions. The email is informational only, so if CAEP does not reach back out with questions, you are welcome to move forward with the planning of the project.

"Yes, these items would be permissible so long as the items would be used for outreach, deemed ""reasonable"" (according to CAEP Fiscal Guidance 2023), and are part of your consortium annual and three-year plans.

Alternatively, it is not permissible for funds to be used to purchase clothing for individual students such as jackets, sweatshirts, or tee shirts (gift of funds). However, clothing for a classroom is permissible – i.e. aprons for a culinary class, welding helmets, etc.

Refer to the CAEP Fiscal Guidance 2023 for more information.

As CAEP, we want to help students achieve their goals (such as high school diploma). Helping the student obtain their transcripts would be an appropriate support service (see CDE email below). Make sure the adult school does not give the student any funds, but works out the transcript request with the other district. That way the student doesn’t receive any state funds that could be considered a gift. The adult school should also be sure to follow district policies and procedures on how students would qualify for this type of financial assistance.

As you are aware, California has two approved high school equivalency tests (GED® and HiSET®) for adult education students for the purpose of receiving a California High School Equivalency Certificate. The California Department of Education (CDE) Adult Education Office (AEO) has received questions regarding the use of the Workforce Innovation and Opportunity Act, Title II: Adult Education and Family Literacy Act (WIOA, Title II: AEFLA) funds for costs related to GED® and HiSET® Testing (e.g., non-monetary GED® vouchers).

California Education Code Section 84913(a) provides that California Adult Education Program (CAEP) funds shall be used to support programs leading to a high school equivalency certificate. As a result, the AEO recommends using CAEP funds for the costs of GED® and HiSET® testing, prior to considering WIOA, Title II: AEFLA funds.

If CAEP or other allowable funds are not readily available, WIOA, Title II: AEFLA funds may be used to meet the identified need of costs for GED® and HiSET® testing, until other resources become readily available. However, the agency should maintain documentation to demonstrate any efforts to obtain funds from other programs prior to using WIOA, Title II: AEFLA funds. The documentation should be available for review upon request of the CDE Consultant and include such items as financial records, meeting minutes, communication with the AEO, and any other supporting documentation. Additionally, as with any use of WIOA, Title II: AEFLA funds, the costs must comply with the factors affecting allowability in accordance with 2 CFR 200.403.

Hiring a teacher to teach teachers Spanish could potentially be an indirect cost (limited to 5%). It's not clear how the Spanish teacher is directly serving students in one or more of the 7 approved program areas, which is a requirement for using the CAEP funding.

You may want to approach this from more of a PD lens. Is there a Spanish GED teacher on staff or another teacher on staff that knows Spanish and could teach and offer a limited PD series to staff that would include basic greetings, a few common phrases, etc? That feels reasonable and justifiable.

Keep in mind that all allowable costs must meet three primary criteria:
1) Substantiate that the cost was necessary and reasonable for proper and effective administration of the allocations.
2) The cost must be allocable to the funding source activities.
3) The cost must not be a general expense required to carry out the consortia member’s overall responsibilities (i.e. not supplanting).

However, even if the costs meet the prior three criteria, the costs must be approved within the 3-year consortia plan and the annual plan template of the regional consortia as agreed upon by its membership. Otherwise, they are not allowable within that year. In addition, the State has the discretion to impose special conditions beyond the funding source that would also determine allowability of cost.

It is best if the member would back out the $47K until the expense hits the districts books. As much as we can control, it's best for members' expense reports to marry their districts reports.

All of your members listed 25% for Q1, 25% for Q2, 25% for Q3 and 25% for Q4. Those estimates are cumulative so if they planned to spend 25% per quarter, the 1st quarter should be 25%, the 2nd quarter should be 50%. This can be adjusted by opening up the Budget and Workplan and having your members go in and adjust those percentages. As a reminder, all of the figures, although cumulative, are entered manually. NOVA will not add them to the previous quarter automatically.

NOVA will not allow a lower Q4 than Q3. NOVA is cumulative so all amounts must be equal or more than the previous quarter. Please contact CAEP TAP for assistance on how to resolve this error.

We are reporting dollars received and spent/expensed between July 1, 2017 and June 30, 2018. For example, if you collected $100,000 dollars in fees for an adult education program, we are assuming those fees were expended. In general, all collected fees, during the period, should be reported in NOVA for this exercise. Note: community education, community services, and contract education are fee-based programs, but are outside of the California Adult Education Program.

Please report the seven adult education noncredit program areas regardless of funding. So. any expenses related to noncredit ESL, ABE/ASE, AWD, K12 Success, CTE, Workforce Reentry, and/or Pre-Apprenticeship courses must be submitted in NOVA for this exercise.

If monies were moved from Q3 after it was reported, the Q3 fiscal report will need to be updated. NOVA is cumulative. No quarter can be less than the previous quarter. The Consortium Lead will have to un-certify the Q3 expenditure reports. The member would then un-submit, make their adjustments, and re-submit. The Lead would then re-certify. Once the Q3 expenditure reports are re-certified, members will be able to submit Q4.
Please note - after changes have been made to Q3, if there are still exclamation points, a budget revision will have to be completed.

At a minimum, we will be required to report state funded expenses for the prior state fiscal program year by program area. Estimates would be due in September, with actuals to be certified in December. More details later this year.

If Q4 has been certified, no changes for last fiscal year are possible. If Q4 has been certified and a member overspent last year, they will start the next fiscal year with reduced available funds. If Q4 has not been certified, the member will need to adjust their Budget and Work Plan by moving money from one budget category to the overspent category. To do this, the consortium lead will need to uncertify the Budget and Work Plan. The member will then go and make the changes and resubmit. Then the consortium lead will recertify the Budget and Work Plan.

No, please do not include them. Only included expenses for the 7 AEP program areas.

Please have the member check to make sure the email address showing in NOVA under their Member Representative account is the email address they are using to sign in. In some cases people have multiple email addresses and may be signing in with the incorrect email. The second thing to check is that they are the first Member Representative listed. Only the top Member Representative listed has the authority to submit on behalf of their agency.

As long as Q4 has not been certified,Q3 can be uncertified and the correction can be made. Once it is made, the member will resubmit and the consortium lead will re-certify.

It would be your cost, plus the in-kind cost the other member paid or reduced.

For Q4, there is a small checkbox under the totals that members must click certifying that they did not exceed the allowed indirect rate as directed in the Adult Education Program Guidance. This is only required for Q4 submissions. Please check to make sure that box is checked. Once it is checked, the Submit button should be available.

Yes - the leveraged funds area report is the correct field to record this expenditure.

Because NOVA is cumulative, no quarter can be less than the previous reported quarter. If your previously reported expenses for Q3 were reduced due to an error in reporting or a credit, you will need to have the consortium lead uncertify Q3. Once Q3 is uncertified, you can go in and make the corrections, then re-submit. The consortium lead will have to re-certify Q3.

If it is a K12 school, CDE prohibits moving funds out of Fund 11. Please contact your consultant at CDE.

If the consortium can make the connection from hours of instruction to other non-teaching expenses that contributed to that cost of offering the instruction – than they can include supports, counseling, overhead, etc. However if they have zero hours of instruction in a program area– than there should not be any expenses associated with that program area reported (and vice versa). For example – 500 hours of CTE instruction cannot be reported and no expenses reported. Likewise, $60,000 in CTE funds cannot be reported and no hours of instruction.

FIFO pulls the money as soon as it's entered in the expenditure report, whether entered, submitted or certified.

If members have pre-populated numbers but have not submitted, those figures have already been marked as expended in the FIFO.

We advise consortia and members to complete budget revisions to correct any negative remaining balances prior to certification. NOVA will technically certify negative remaining balances however we strongly encourage budget revisions prior to certification.

Since the indirect costs were not reported in 2019-20, they will be carried over to your 2020-21 available funds in the budget and work plan. Go ahead and budget for double the indirect costs so that you can report the indirect costs in the 2020-21 program year. In the budget and work plan, in the budget summary, please notate the doubling of the indirect costs for 2020-21 since the costs were not reported in 2019-20. In the first quarter expenditure report, please report the 2019-20 indirect costs. In the summary of activities for the expenditure report, please notate the inclusion of the 2019-20 indirect costs.

Reducing next year will work. Please document this action in the summary of activities since the Q4 expenditure report is still open. Additionally, please document this action in the 2020-21 budget and work plan and ensure the member includes the reduced amount prior to certifying.

Once Q4 is certified, no changes are able to be made.

"NOVA is programmed to require all agencies who fall below their expected expenditure target to complete a corrective action plan. The corrective action plan is a concise explanation of how you plan to ensure you meet the target in future quarters.

The only workaround to take immediate action is to revise your expenditure targets in your budget and work plan. This would require uncertifying and unsubmitting the budget and work plan to include targets that align with where you are at this time."

The previous years' budgets are embedded in the previous years' fiscal reports. Each member's budget, by object code, is provided in column four. The last column provides the budget remaining.

You can access these reports in the Supporting Documents section in NOVA. This section is located on the Consortium Details page. The documents are titled, Quarter 'X' Fiscal Report Certification.

Reporting expenditures of WIOA, Title II: AEFLA programs is a grant requirement under Sections 222 and 241 of Public Law 113-128. Report quarterly the total fiscal funds received from the state and local governments used to support these programs. Under “Other Non-Federal and/or In-kind,” report contributions such as:

• Cash and designated foundation grants or other non-federal awards used for AEFLA programs

• Buildings, land, and donated property–classroom space must be valued at the fair rental rate of the space

• Volunteer services valued at rates paid for similar work in the local agency

• Donated books and supplies valued at the market rate

• Utilities and property maintenance valued at the market rate

• Cost sharing of equipment valued at the fair rental rate

All resources must be verifiable from the local agency records. Additional details are provided in The Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards. (2 CFR 300.306)

If a community college does not offer non-credit courses, then they would report zero hours. For expenses, they would report any expenses that assisted K12 adult or noncredit students or the consortium in general (along with the fund source). For example, any travel/time/supplies at consortium related meetings/events; professional development, marketing, etc. would be reported as operating expenses (by fund source) for that member.

Please DO include the California Adult Education Program consortium related costs in this exercise.

For Q4, there is a small checkbox under the totals that members must click certifying that they did not exceed the allowed indirect rate as directed in the Adult Education Program Guidance. This is only required for Q4 submissions. Please advise the member to check that box. Once checked, they will be able to submit.

Consortia are unable to change previous year's fiscal reports. The previous year is locked and we are unable to edit. If changes are needed in the current year we can assist with that.

If the changes are in fact needed for the previous year, you will have to rectify the changes in the current year. Please contact TAP for assistance.

You are correct. You will need to uncertify Q1, have her make the changes, and then submit and recertify Q1. Once that is done her Q2 should be accessible for her.

The reason your member is unable to submit their expenditures is because they are reporting ""0"" indirect this quarter; however, last quarter, they reported $302.

Fiscal Reporting in NOVA is on a cumulative system - expenditure cannot be bless than the previous quarter. If there are no indirect expenditures for Q2, the amount will remain $302.

In addition, the member will need to complete a corrective action plan since expenditures are less than forecast. Please be sure to complete this as well.

No, it's not required, but encouraged for record keeping and a snapshot of activities.

Yes - the allocation amendment allows consortia to designate which fund year they are reallocating funds. The Consortium Lead would select fund year '2018-19' when they select 'Start Amendment.'
Yes - the site receiving the funds will invoice the site providing the funds.

In order to make a budget revision, the consortia lead will have to uncertify all Budget and Workplans. The lead will then need to specifically reject your agency's Budget and Workplan. This will prompt you to make changes. Once the necessary changes are made, you will click Submit. The Lead will then recertify.

For CAEP you do have flexibility, but we can’t allow a gift of public funds. We would be ok if the district had an equipment loaner policy. The Governor and the State Superintendent are looking for companies to donate computers.

When you complete the Q3 expenditure report, you will complete the corrective action plain if your expenditures fell below target. This report is in NOVA

"Q1 Fiscal reporting will not unlock until the Budget and Workplan is certified. All members have submitted except one. They are in draft status. Once you certify everyone, they will be able to complete their fiscal reporting. The remaining member needs to submit theirs. Once submitted, you will have to certify theirs also.

Q1 fiscal reports will not be unlocked until all the members Budget and Workplan are certified. The member's Budget and Workplan is submitted but not certified. Their Q1 will populate as soon as you certify it.

You are correct that all funds are FIFO and are good for 30 months. However, it looks like the snapshot of the 23-24 funds were submitted with those numbers on August 29th, 2024. From what we can see, you have spent a portion of the 2024-25 funds as well and perhaps expended post 8/29/2024. We suggest you look into the quarterly expenditures.

This process should mimic that of an Allocation Amendment or CFAD, in which you will submit and then all members will get an email to approve the plan.

They will not be able to approve until you submit it to them for their review and approval.

The only way to correct under-reporting in previous years is to over-report now. I'm going to make up numbers to give you an example.

Let's say, in total, they have under-reported $100k in the 5000s and $200k in the 1000s.

Scenario:
19/20, under reported $50k in the 5000s
20/21, under reported $50k in the 5000s
19/20, Under reported $25k in the 1000s
21/22 under reported $175k in the 1000s.

Solution:
24-25, Q1 expenditure report
True expenses of $30k plus under reported sum of $100k in the 5000s, will enter $130k for Q1 expenses.

True expenses of $50k plus under reported sum of $200k in the 1000s = will enter$250k in Q1 for the 1000s.

They will want to over-report in the same object code, if at all possible. If not possible, they can choose an object code to report it in.

They will want to add a note in NOVA, something similar to:
19/20, under reported $50k in the 5000s
20/21, under reported $50k in the 5000s
19/20, Under reported $25k in the 1000s
21/22 under reported $175k in the 1000s.
Over Reported now in Q1 in the same object codes to match NOVA to the district books.

Then in the district books, they will want to add a note there to identify where/when the problem occurred and where/when it was fixed in NOVA.

That way if staff changes in 5 years, new staff can follow what happened.

In the fiscal guidance, it states to indicate in NOVA under fiscal declaration if there are changes. When in NOVA, in the CFAD changes to fiscal agent, structure, and allocations can be made and they would need to indicate a change and then add a description of what change is happening and why.

When you indicate a change this will trigger CAEP to fund appropriately.

Please see the CCC Budget & Accounting Manual and the CAEP Fiscal Management Guide Section 12, page 22 ( the college info is on page 24) . Community College Districts must adhere to the following reporting requirements:

The following requirements address the appropriate accounting for community college districts receiving CAEP 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
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 CAEP, 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 CAEP 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.

Yes - you are able to complete an allocation amendment for last year today. You are able to make allocation amendments on fund years at anytime until the funding expires.

The rules are everyone gets COLA unless you have cause under EC 84914 for them not to get the COLA. Having a fiscal agent doesn’t affect the COLA requirement. It just makes it easier to move money around. So as long as you have the discussion about who gets COLA, and who doesn’t – and if everyone gets it – the CFAD will show that documentation.

The one issue with having the fiscal agent “hang on” to the money is that trailer bill language (which is now code) mandates that fiscal agents must release the funds within 45 days of receipt. So the fiscal agent can’t hold the funds. But the consortium could make a decision to fund future projects (with everyone pitches in X amount), and then when those expenses come due, the fiscal agent deducts or pays that amount from what should be going out that month. It’s a little complex because there could be delays in payment from the state. So it could work – but it’s a lot of work for the fiscal agent. And you would have to figure out who is paying for the future projects (who gets the invoice), how that is deducted from the member allocations, and make sure the fiscal agent actually has the funding in their account (and hasn’t violated the 45 day hold requirement).

A better solution – go through the CFAD process. Then after its submitted agree to hold X amount for consortium projects. Also agree upon who will pay for these projects (fiscal agent or another member). Then do an one-time allocation amendment to move funds to the agreed upon member and they pay the bills. This method will keep you from violating the 45 day rule.

Per the CAEP Office, the pass through for a fiscal agent is limited to 45 days upon receipt of funds. They can charge up to 5% indirect, but that is negotiable. Some fiscal agents charge nothing, some charge a small amount, and some charge more. So – it varies.

The fiscal agent must follow the fiscal education code for CAEP.

Plus a community college fiscal agent must follow the Budget and Management Manual.

An in-kind contribution is a non-monetary contribution. Goods or services offered free or at less than the usual charge result in an in-kind contribution.

Donations – would be a monetary contribution.

It includes any non-monetary contribution – goods or services. You should generally determine the cost using the fair market value and it should be based on standard objective sources rather than best guesses. You should document the basis for determining value of personal services, material, equipment, building, and land.

This year's Budget and Work Plan are not due until September 30. It is the Annual Plan that is due August 15. Once the Annual Plan is submitted and approved, this year's Budget & Work Plan will be accessible.

The discrepancy is because Q4 expenses have not been certified. Once Q4 expenses are submitted and certified, that amount will be deducted from the total Budget for this year. Until then the total allocation is doubled.

The previous year's carryover is automatically included in this year's budget. The carryover is included in your Total Available Funds. Please note, the correct carryover amount will not appear in your Total Available Funds until the consortium has certified the previous year's expenditure reports.

Last year's Budget and Work Plan can be uncertified to allow members to make adjustments as long as Q4 Expense Reporting has not been certified. However, please note, if the Budget and Work Plan are open, members will not be able to submit their Q4 expenditure reports. They will be able to save their entries, just not able to submit until the Budget and Work Plan are back in certified status.

The 'Delete' button at the bottom of the budget item is where you can delete a budgeted item. Please note - if you delete this budget item and have reported expenditures in this object code for the program year, the expenditures will be deleted as well.

Yes - The members will need to complete a budget revision. They can notate the budget revision reason in the budget summary area.

If you do not have a percentage laid out in your planning, you can use the suggested precents listed in that section. A percentage must be entered, but it is up to you what that percentage is.

Regarding the forecast example provided - the total is intentionally not adding up to 100%. The forecasts are cumulative; however, the logic behind ending Q4 with 60% is the member is planning to carry over 40% of their budget for that object code. If the member is planning to expend all funds in an object code, the forecast percentages for that object code should equal 100%.

Because CAEP funding is based on regional need, the allocations are not impacted by attendance or teacher load. The State CAEP Office understands that there could be a drop in enrollment, and outcomes as a result of the virus school closures, and student decisions not come to school. As far as we can see, this will not affect your CAEP funding.

A detailed narrative is strongly advised by the CAEP Office for transparency purposes. To amend your budget and work plan, please ask your consortium lead to 'Reject' the budget and work plan. Your budget and work plan would then go back to 'Draft' status. Once in 'Draft' status, you will be able to make edits.

Yes, you are welcome to do Budget Amendments as often as needed to move money between categories within a member agency. If money is needing to be moved between members, then an Allocation Amendment would be done. There is no limit for either of those items. Any notes related to a Budget Revision should be placed in the Description of Expenditures section for each object code and/or the comment section once the Budget and Workplan is ready to be re-submitted.

There are multiple layers here.

The first submitting and approving fiscal reports with expenditures that include a negative balance. This is not allowable and the budget and workplan should have been opened up and funds moved so the negative didn't occur. If the member did not have funding, then these expenditures should not have been approved.

Given that the CAEP structure is set up differently including NOVA, CAEP Leadership still wants to hold the field accountable for this requirement that is also outlined in the CAEP Fiscal Management guide in pg 36.

Both the consortium member and the lead certifying this negative balance need to be aware of this requirement for CAEP. Additionally, if a negative is not avoidable, it is necessary to provide a detailed narrative justifying why there was a negative balance reported and approved.

It is critical to ensure district ledgers reflect actual amount expended, and vice versa, budgets reflect amount available based on their allocation for that year, while also accounting for their FIFO carryover in available funds.

Finally, NOVA is accurately capturing what the state has allocated in funds for each budget year and is also tracking carryover funding accordingly. Carryover is calculated with the fiscal year allocation and the fiscal year expenditures. Carryover compliance does not use available funds to calculate the carryover percentage. We want to ensure NOVA is also accurately tracking the financial records and allocations that the state makes on annual basis. It will be the fields responsibility to ensure they are following local and state fiscal policies and reporting requirements.

The Budget and Workplan is not automatically certified on the due date. The Primary Contact is the only role that can certify the Budget and Work Plan. You can always find this by clicking on the member agency, scrolling down to the Budget and Workplan and clicking on the PDF version of it. It will have a stamp with date/time/approved by at the top of when it was certified.

You are correct. You may notice that one Member is not currently listed, as their Budget and Workplan for 2024–2025 is still in draft form. Once all members have submitted and certified their documents, the full list should be visible.

The 17-18 budget bill requirement is to report on those seven program areas that fall under adult education as defined by AB104. This would mean the adult education program area has credentialed teachers, follows existing education code and regulations, and is NOT a community education, community service or contract education program. These fee-based programs are outside of the California Adult Education Program (formerly known as AEBG). Finally, to clarify, K12 or County Office CTE fee-based programs that have credentialed teachers and follow all applicable education code would be considered part of this reporting exercise.

Yes. Please account for all expenses in the seven program areas regardless of fund source. If noncredit apportionment is paying for the cost of faculty, and they are teaching in an of the seven program areas, please include their salary costs for the AEP courses.

As long as those hours are reported correctly elsewhere - don't be concerned about having no workforce reentry leveraged funds. There is no penalty.

Please work with your Business Office or Accounting staff to obtain a general overhead cost for your AE program. This would be a fixed program cost for any overhead/operating costs (facilities, custodial, safety, utilities, etc.).

We know this is not an exact science. Please work with accounting staff or your business office to come up with an in-kind amount.

Please work with your accounting staff or business office to come up with a fixed overhead cost that you can use for all 30 sites.

There must be a correlation between hours of instruction and expenses. So if they report hours of instruction in ESL, there must be a dollar amount associated with ESL in the expenses table. They cannot report X amount of instructional hours in the Program Area, and leave the expenses for that Program Area blank (or vice versa). This is what we mean by no zero entries. If you report hours of instruction in a program area it must be matched by a dollar amount in that program area on the expense table. For example – last year an adult school reported hours of instruction in ESL, but no expenses. Also, they reported expenses in pre-apprenticeship, but no hours of instruction. This skews the statewide data, and hampers the ability to get an accurate hourly cost.

Fees are not part of NOVA expenditure reporting – only CAEP state allocated funds. You may show these fees in the Program Area report. Interest is also not tracked in NOVA.

Your leveraged funds section is locked until the Program Area Hours section is complete. Since there can be no expenses without hours, entering the hours is what unlocks the funds portion.

CAEP has 7 program areas. This report is going to ask you to report all student hours in those 7 program areas, and the costs associated with supporting those student hours (admin, faculty, books, etc). The funds may be from multiple sources (Noncredit, CalWorks, LCFF, ELL Healthcare, CAEP allocation, other state grants, etc.) You can view the previous years' Program Area Report in NOVA here: https://nova.cccco.edu/caep/program-area-reports/4069/129/2023/v2/preview This may give you a good starting point to work from. In 22-23, your college only had ABE and ESL as CAEP programs. That may have changed, may not have. CC TAP is the TAP that specializes in Community Colleges. You are welcome to reach out to them for support, if further support is needed. Their direct email is ccctap@noce.edu

If an agency is leveraging ELL Pathway funds for program areas in the Program Area Report, you would do exactly as you say. Choose Add Another Fund and choose Other State Grants. For your second question, only report in the program areas where money was expended.

The Member is listed in NOVA as a contact. That may explain why it is greyed out for him. I see that CTE is able to be reported on. Currently, your colleague is the only person with the Member Representative rights in NOVA. Short Term CTE currently has certain hours reported for your consortium. No member will be able to submit expenses for a program area until hours are entered. It may be that Member went to the funding section first and realized it, then corrected by adding the hours, thus unlocking the funding.

For the Program Area Report, report the ELL Healthcare Pathways as Other State Grants. This funding is not considered CAEP funds.

You can include the indirect as part of the program fees as appropriate. The purpose of the Program Area Report is to capture the overall hard costs and the leveraged costs that support adult education in California and to know how agencies are allocating and using their funds.

We will note these hardships in our report to the legislature.

If smaller districts are overwhelmed by this exercise, please tell them to do the best they can, knowing that some of this data may be used for policy decisions. There is no penalty for zero reporting, but it doesn’t help us move the program forward.

Funds are scheduled to be released per the CDE schedule that was posted. A list of K12/COE Fiscal Agents and Direct Funded agencies, their entitlements and the apportionment payment schedule can be viewed on the California Department of Education CAEP Funding Results web page. A list of Community College Fiscal Agents and Direct Funded Community College agencies can be viewed on the California Community College Chancellor’s Office Apportionment Reports web page.

There are a few ways to receive various adult education fund streams…

1. WIOA II – apply through CDE to obtain federal literacy funds serving adult students.
2. LCFF – review the county LCAP and see if any local control formula funding has been set aside for adult education.
3. CAEP – contact your regional adult education consortium and become involved in the regional planning process for adult education. The consortium makes the funding decisions.
4. CalWORKs – check with county social service if they have employment & training dollars for their clients that the county office could run instructional programs to meet their needs.
5. Perkins – check with local K12 district in the county/region about the availability of adult education Perkins dollars.

There is no set aside pot of adult education funds for K12 districts or county offices unless they go through the fund sources above (and the process to apply for the funds).

If they are a member and just curious where to find their allocation:

The money should come from the County Treasury if they are a K-12 direct funded.

Once received, the money should be put into a Fund 11 with a resource code of 6391.

In your CFAD you indicated that NOVA would track member carryover. If an agency is not meeting the current quarterly carryover NOVA will require a corrective action plan to be completed.

There are no separate member plans. There is a consortium-level plan that should address the carryover as a whole. All members will have to individually approve the Written Expenditure Plan. The Plan is due November 14 in NOVA.
Guidance from the CAEP Newsletter: Consortium carryover is one or more prior fiscal years exceeding 20% and is assessed and acted upon annually. Consortium carryover includes the carryover of all its members. State leadership identified consortia with 20% or more carryover as of September 30, 2024, with the Quarter 4 Expenditure report submission.

Consortia with 20% or more carryover must submit a written expenditure plan to the State showing how the consortium will work to reduce their carryover below the 20% threshold.

The Written Expediture Plan in now live in NOVA. Consortia who have exceeded 20% carryover will have 45 days (Oct 1-Nov 14) to complete the plan at the consortium level. Consortia will be submitting one jointly developed written expenditure plan. Members will review and approve the written expenditure plan once it has been submitted by the consortium lead.

Consortia who exceeded 20% carryover and are required to do a Written Expenditure Plan are encouraged to reach out to the TAPS for any additional assistance that is needed. The consortium will have to do an allocation amendment to address the additional money allocated to the members from the COLA. Let us know if you have questions about how to do an allocation amendment.
https://caladulted.org/DownloadFile/1355

The question you are referring to:
"9. Please provide the name and contact information of the lead and co-lead representative for this plan.
If there is a single lead (no co-lead), type “n/a” or “0” throughout the co-lead column."

This question is asking who is the lead that enters in the written expenditure plan. If there is a member that has worked with, the consortium lead, then it would be appropriate to list their information.

The written expenditure plan is a collaborative plan that should involve all members, and the lead is responsible for entering into NOVA, while the membership reviews and approves.