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AEP Questions and Answers

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

Fiscal

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.

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.

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.

I think we may need more information about why you believe the allocations in the CFAD to be incorrect. Do you feel that this is an internal or external error, for example?

It is impossible to reopen the CFAD once it has been certified by the consortium. They only way to reallocate money at that point is via the Allocation Amendment process. If you're concerned about making a permanent change to the base funding for your members, you will have to wait until the next CFAD, in the next fiscal year, to correct it.

Yes. Since the proposed budget includes a COLA, the CFAD should reflect that COLA as well. An amendment would only be necessary if the COLA amount changes in the Final Budget. You can confirm by comparing your number to the number listed on our website that was provided from the State. If your numbers, including the 2.43% increase, match the State’s figure, then you are all set.

Just a quick note, the State doesn’t actually publish the percentage because it’s typically not a clean number. It’s more likely to be something like 2.431287452189%, so it's always best to calculate the exact percentage based on the State-provided figures to avoid any small discrepancies.

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 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.

Payments are distributed from CDE. You can contact Lori at the email below:

Lori Zocklein, Staff Services Analyst
Adult Education Support Office
California Department of Education
1430 N Street, Suite 4202
Sacramento, CA 95814-5901
lzocklein@cde.ca.gov
http://www.cde.ca.gov/

Yes, members can take indirect on redistributed funds as members can only claim indirect on expenses. A safeguard is to ensure the member giving has not claimed indirect on those funds. If they have, they will need to reverse that as it is not allowed.

So long as consortia members agree to it, funds can be used for a consortium-level activity in the current fiscal year such as a program for Career Skills Development . It would be important to include this in the Annual Plan.

The short answer is no, they can't report more than their allocation.

From the Fiscal Guidance, page 36, Expense Reporting
No, expenditures cannot be reported with a negative balance in any of the object codes in NOVA. In addition, prior, prior year funding is the oldest funding. For example, during 19-20 fiscal year, 19-20 funding would be prior, prior year funding, and 20-21 funding would be prior year funding, and 21-22 funding would be current year funding.

From the Fiscal Guidance, page 36, FIFO and Closing Out Funds
CAEP funds have a 30-month life span NOVA tracks funds by allocation year/amount using the FIFO method until all funds are spent. NOVA expenditure information may not match local district accounting ledgers as prior year NOVA expense reports cannot be reopened for adjustments. Using the FIFO method, the State encourages accounting offices to update expenses in the next quarter to reflect accurate expenses (provided this is within the 30-month cycle/life span of the funds). Close out of funds begins after the 30-month period is over. Members will certify in NOVA if they have liquidated all funds being closed out or if they will be remitting any funds to the State. The State recapture must be finalized by June 30 (or 3 years from the release of funds).

The adult school needs to determine where these "carryover" funds originated from. Are they CAEP funds or are they other adult ed funds such as Maintenance of Effort, CalWorks, etc. that were mistakenly mixed in with CAEP funds.
One way to address this issue would be to back out the overage from the general ledger and have the District cover the carryover with District funds.
Another option might be to do an allocation amendment. Transfer funds from the consortium-level or a member-level to the adult school to cover the overage. Consider whether this is a one-time "gift" or if there will be a repayment in the current fiscal year with another allocation amendment.
Something to consider: If these are determined to be CAEP funds and they are more than 30 months old, the adult school may owe the State for funding that wasn't returned earlier.

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.

The expiration date of the funds remains the same, 2 years, or 2.5 years with a corrective action plan in NOVA.

Currently, the split between colleges and K-12 adult schools is 89% for adult schools and 11% for community colleges. That is at the statewide level and this may vary depending on how the regional consortia were set up in 2015. Most community colleges with larger noncredit programs received a larger allocation of CAEP funds. In some regions, there were no K-12 adult programs (or very little), so most of the CAEP funding went to the college. Conversely, there are a few community college districts that do not offer noncredit programs, so in those cases the college received a smaller amount or chose not to receive any CAEP funding. You can look up these amounts by going into NOVA and clicking on the various consortia to review their CFAD allocations.

Keep in mind back in 2015, that many regions, received the minimum funding of $750,000 per consortia. This was intended to help the region grow their adult education programming. Consortia that have not grown their program in these last ten years, may see drastic cuts if the new funding formula becomes reality. There is still time to grow programs and increase enrollment/outcomes.

There are now four ways in education code to reduce a member’s funding:

They don’t follow the adult ed plan
They can’t follow the adult ed plan
They are deemed ineffective and a reasonable intervention didn’t resolve the ineffectiveness
They have carryover for two consecutive years

3 and #4 have specific education code guidance that the consortium must follow if they choose to reduce a member’s allocation based on those options.

3 – the consortium would have to have a public meeting and decide what constitutes ineffectiveness. Most consortia that go this route have based it on CAEP deliverables. You cannot be ineffective for having carryover – that’s #4. Plus in this option, you have to have by-laws that lays out the process for the reasonable intervention.

4 – as we know from the various webinars, AB1491 lays out the member carryover guidance and the steps to go through. For a member’s funding to be reduced for carryover, it has to be two consecutive years, the consortium has to establish the member carryover threshold in advance of the coming year via the CFAD, and the consortium has to set up a technical assistance process to help a targeted member. Consortia can’t just reduce a member’s funding with the CFAD – that is not allowed and violates statute (is illegal).

The COLA adjustment for FY2024-25 as outlined is the Governor’s January budget proposal is $4,911,000.00 or 0.76% (0.75422%). Below is detailed publicly available information accessible in the Department of Finance for further information. However, due to rounding protocols, the field may not arrive at the same calculation.

https://ebudget.ca.gov/2024-25/pdf/BudgetSummary/HigherEducation.pdf
https://ebudget.ca.gov/2024-25/pdf/GovernorsBudget/6000/6870RWA.pdf

Allocations, including COLA's, are required to follow the consortia funding formula. The board may vote to redistribute the COLA differently and depending on your bylaws, is the process that should be followed. To keep the allocation amendment history clean, the recommendation is to follow the final allocation schedule and allocate funds based on those numbers. This ensures that no member receives less than the previous year's allocation (final). Then dependent on your bylaws, vote, etc. funds can be re-allocated as a one-time transaction.

When it comes to funding an existing or new member, this is where the CFAD is important. It is not explicit in the current Fiscal Management guide and we are working with CAEP leadership to provide steps.

New members can be voted in following ed code criteria (and CAEP general assurances along with any consortium by-laws). With board approval, new members can be funded based on the consortium by-laws. If a consortium chooses to reallocate funds via the CFAD from an existing member to a new member, if all ed code criteria has been met (removal of funding from existing members(s).

If the consortium is funding a new member via an allocation amendment during the program year, and the membership is willing to reallocate their funds, then the consortium must follow their bylaws, along with CAEP general assurances.

You can find all CAEP Allocation schedules on our website under Administrator > Funding > CAEP Allocation. https://caladulted.org/Administrators/14.

The preliminary allocations are always shared as consortium. Final allocations are completed after the May revise when final numbers are calculated and shared out. That will come post CFAD, typically.

The final allocation amount from the State is the baseline and cannot be reduced in subsequent years. Any internal reallocation of funds between members does not affect this amount. When the guidance states that a member cannot receive less than the prior year, it refers specifically to the allocation amount recorded by the State.

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.

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/.

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.

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.

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.

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.

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.

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.

CAEP Leadership has approved this plan for use of funds. Given the criteria listed in the email and after consultation with the CDE Consultants, the following criteria has been approved:

  • A member district has created a partnership with a local university to create a CTE pathway, an onlie clinical medical assistant program.
  • The district is creating an MOU that will have the adult school pay the fees for the course along with the fees for the clinical practicum site.
  • The students will be also supported by an adult school ESL teacher who will provide tutoring, scaffolding, and guidance in completing the online medical terminology course.

Tangible items that are given away become a gray area, below are areas from the fiscal guidance that would closely align to outreach materials. You want to ensure that the marketing materials are allowable to the CAEP programs – meaning only information about CAEP program areas.

Objective #4: Activities to address the gaps identified pursuant to the evaluation of regional needs and the evaluation of current levels and types of adult education programs.
Examples of allowable expenditures:
* Staff/instructor time for developing new classes/programs
* Program coordination and staff/instructor time
* Staff/instructor stipends
* Space Use Agreements
* Classroom reconfiguration
* Classroom furniture
* New program and curriculum planning and development
* Instructional materials and equipment
* Supplemental instruction and tutoring
* Counseling, Advising, and other student education planning services
* Publication and Outreach Material
* Office supplies
* Meeting supplies
* In State Travel
* Computer Hardware or Software Equipment
* Follow-up and Orientation Services
* Research and contractual services

Fiscal Guidance page 43
4000: Supplies & Material -
books, supplies for the adult education program (office), outreach, and recruitment materials. Examples: Publications and Outreach Materials - Reasonable costs to develop and produce materials to promote CAEP services and activities.

Examples include materials for orientation and assessment workshops, guides for creating an education plan, brochures about supportive services, etc.

Any activities, such as field trips, should be approved by consortium members and be part of the consortium's Annual Plan. The field trip must be tied directly to the educational goals of the course or services for ESL, ABE, CTE, AWD, or K-12 Success students. If the school can make the connection to the education goals, and the district and consortia members support it, then it would be an allowable use of funds.

You are correct. This would be a benefit to an individual and could be considered a gift of public funds. This is not an allowable expense for CAEP funds.

That said, some districts have programs or other funds that may allow them to assist with credentialing costs.

Not-for-Credit is not allowable with CAEP Funds, as it is different than non-credit.

Marketing materials are an allowable use of funds. Clothing is where things get questionable. Anything purchased and given to keep, is considered a gift of public funds. While marking materials are meant to be kept, such as pens, magnets, etc., clothing is questionable. It there is another source of funds that can be used for the shirts, or the shirts can be checked out and in, than that would be great.

This is an allowable expense, with a catch. As the non-credit office serves more than CAEP (community ed for example), the percentage of funds spent on furniture/computers must be proportionate to the extent the expenses actually benefit the objectives of the CAEP program. You can only charge in proportion to the value received by the funding source/program. An example would be that a project director works 80% on the funded program (only 80% of the salary and benefits can be charged to CAEP funding).

Also, any expense over $5000 is considered capital outlay and should follow have the following done, prior to purchase:

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.

This appears to be a capital outlay request. You will need to provide the following to the informational email:
Consortium has approved the capital outlay and expense (provide date item was aboard pproved).
The project aligns with the Three-Year/Annual Plan for the consortium
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 additional information is shared we will send to the CAEP Office and they 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.

In the fiscal guidance, (https://caladulted.org/DownloadFile/1300) on page 46, it states that CAEP funds are not allowable for Political or Professional Dues, memberships, or contributions. If your members attended a conference held by an association then that would be allowable as it supports professional development.

  1. Political or Professional Dues, Memberships, or Contributions Funds cannot be used for these activities, unless professional membership is an institutional requirement. Business, technical and professional organization or periodical memberships are allowed. Civic or community, or country club or social or dining club memberships are not allowed.

No, the State does not set any requirements for this. The State defers to local district policy, as there is usually a policy in place for purchases over certain dollar amounts.

The general rule of thumb is purchases over $5,000 is considered capital outlay and should have the information email sent to TAP. You would still report those expenses as supplies when it comes time to report.

Here are the items needed for the informational email:

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.

Per the CAEP Fiscal Management Guide and supporting education code, CAEP funds must be allocable to the seven CAEP program areas. Any CAEP funds used outside the support of the seven CAEP program areas would be unallowable. CAEP funds are restricted funds. Use of equipment purchased with CAEP funds by individuals enrolled in non-CAEP programs is non-allowable. Use of facilities paid for with CAEP funds is also unallowable.

That said, if the facilities being used for the adult programs are not otherwise designated to be used by the adult program for the summer and the facilities are paid for and owned by the district, the use of the facilities would be a district decision. The district would need to ensure any CAEP-funded equipment and supplies in the designated summer-school spaces would not be used in support of non-CAEP programs.

As for CAEP allowable expenses, generally speaking you are able to use CAEP funds for the promotion of your CAEP program in any one of the 7 areas. Below are a few highlights from the Fiscal Management Guide and Program Guidance.

Fiscal Guidance: https://caladulted.org/DownloadFile/1300

  1. Consortium Administration Function Fiscal Agent or Direct Funding
    Programmatic Activities (Page 24-25)

• Provide coordination leadership in consortia.
• Formalize the open meeting requirement to make sure decisions are approved using the agreed upon governance rules.
• Draft and merge planning narrative/information from members.
• Submit planning and student level data deliverables to the State 24 demonstrating consortium agreement (member sign off).
• Set up, organize, manage, and facilitate consortia related meetings (at various levels). Include travel, events, agendas, and preparation of reports/minutes.
• Submit program related information, best practices, and program progress reports to the State. Including developing marketing material for regional or State use.
• Facilitate relationships with members and partners.
• Assist in the implementation of planning strategies.
• Develop milestones and timelines: tracking goals, outcomes, and other deliverables.
• Respond to State inquires and requests (acting as the region’s liaison to the State).

Program Guidance: https://caladulted.org/DownloadFile/1301

  1. CAEP Program Areas (84913)
    Funds apportioned for the CAEP program shall be used only for support of the following: (Page 13)
    (1) Programs in elementary and secondary basic skills, including programs leading to a high school diploma or high school equivalency certificate.
    (2) Programs for immigrants eligible for educational services in citizenship, English as a second language, and workforce preparation.
    (3) Programs for adults, including, but not limited to, older adults, that are primarily related to entry or reentry into the workforce.
    (4) Programs for adults, including, but not limited to, older adults, that are primarily designed to develop knowledge and skills to assist elementary and secondary school children to succeed academically in school.
    (5) Programs for adults with disabilities.
    (6) Programs in career technical education that are short term in nature and have high employment potential.
    (7) Programs offering pre-apprenticeship training activities conducted in coordination with one or more apprenticeship programs approved by the Division of Apprenticeship Standards for the occupation and geographic area.

Note: CAEP funds can be used to support adult education students that are transitioning from courses in the program areas above into workforce and/or post- secondary (transfer level coursework).

  1. Course Approval Process
    Community Colleges (Page 15)

The local curriculum committee approves all noncredit courses and programs. The local curriculum committee conducting the review has been established by the mutual agreement of the college and/or district administration and the academic senate. The committee is either a committee of the academic senate or a committee that includes faculty and is otherwise comprised in a way that is mutually agreeable to the college and/or district administration and academic senate. All courses shall be submitted to the Chancellor’s Office on forms provided by the Chancellor’s Office. A clear description of the course must be published in the general catalog and/or addenda to the catalog and in the college’s schedule.

Education code referenced: Title 5 55002(c)(1)&(2), 55002(a)(1), 55100, 58102, and 58104.

This is not allowable with CAEP funds. It is considered a gift of public funds. The school can pay expenses such as WASC costs because that accreditation is for the whole school, but the credential is for one person, and they have no real ties/lasting obligation to the school. (Can get the credential and go get a different job elsewhere.) Because of this, it is not an allowable use of CAEP funds.

Yes, if the use is strictly for adult education students, this is an allowable use of funds.

Districts do run a credential check before offering a position and may make a separate determination.

CAEP funds are state apportionment and must follow all regulations, code, and credentialing requirements.

CTC provides guidance on all K-12 credentialing requirements. Please check with their support team for a response in writing.

Responses:

1.Can CAEP funds cover classes where instructors hold "personal development" credentials?

Response: CAEP funds can be used to support instruction in the seven program areas for adults over 18 years of age. The K-12 adult school must follow all CTC credentialing requirements. Please confirm with the CTC if a personal development credential is in compliance with the class you are offering.

  1. Are CAEP funds applicable for classes where instructors possess "parent education" credentials?

Response: Per the response above, CAEP funds can be used in the seven program areas – which includes K-12 Success for elementary and secondary students. The K-12 adult school must follow all CTC credentialing requirements. Please confirm with the CTC what classes an instructor that possess a parent education credential is allowed to instruct adult students.

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.

PLEASE NOTE: To safeguard state or federal funds – agencies will need to use GED Manager to provide the vouchers. That way the vouchers can’t be resold or given to another student. (Hence a gift of public funds).

If you have any questions regarding this notice, please contact the Adult Education Office, by email at adulteducation@cde.ca.gov.

This would be a benefit to an individual and could be considered a gift of public funds. Although the training could be beneficial, it is not required for consortia activities. This is not an allowable expense for CAEP funds.

Professional development is allowable as long as it helps them achieve greater program integration and improve student outcomes. In addition to the Professional Development costs leading to greater program integration and Improving student outcomes, all expenses must be reasonable and necessary. Expenses should be related to program areas and addressed in the annual plan. As stated in 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. 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).

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.

This is caused by a setting in Microsoft Edge called Tracking Prevention. When enabled, the validator is failing to access necessary APIs required by NOVA.

There are two options for this user:

1) Disable Tracking Prevention in Edge settings
2) Use Chrome browser

NOVA is developed to work with Chrome, tho it will work with other browsers. The NOVA team tests with both Chrome and Firefox. When using something other than these two, there may be complications like this one that need to be worked around.

The first recommendation should be to use the latest version of Chrome for everything NOVA.

To turn off Tracking Prevention: Select View site information on the side of the address bar. Under Tracking prevention, select Off from the drop-down menu.

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).

CAEP funds can only be used for students that live in California. This applies for the vouchers as well as enrolling in courses funded by CAEP.

The only restrictions are:

18 years and older
7 program areas
Must follow the adult ed plan
Can’t spend more than 5% of the allocation on consortium related expenses.
Member cannot exceed their approved indirect rate

The consortium can review performance (enrollment and outcomes) as certified in their plan to see if spending CAEP funding on salaries will assist them in meeting their goals/outcomes/metrics. If not – this could be grounds for an ineffective member status and a possible reduction in funding by the consortium (and member vote).

Another suggestion is to see if these salaries are administrative in nature and would go against the approved indirect rate. The cap on indirect is 5% or if K-12 whatever the CDE approved indirect rate (which could be even lower).

To safeguard state or federal funds – agencies need to use GED Manager to provide the vouchers. This ensures the vouchers aren't resold or given to another student, resulting in a gift of public funds.

Notice from CDE:

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.

In reviewing the Fiscal Management Guide (https://caladulted.org/DownloadFile/1300), under Objective #3 there is a list of allowable expenditures. You are able to cover costs that promote CAEP services and activities. These items would be promotional, meaning they would give away items to promote your CAEP program. If you are looking to purchase items that promote the school, which encompasses programs outside of CAEP funded program areas, then the costs would need to be equitably split.

Objective #3: Activities for consortium members and partners to integrate existing programs and create seamless transitions into postsecondary education or the workforce.

Examples of allowable expenditures:
* Program coordination and staff/instructor time
* Staff/instructor stipends
* Program and curriculum planning and development
* Student assessment
* Articulation * Instructional materials and equipment
* Supplemental instruction and tutoring
* Counseling, Advising, and other student education planning services
* Publication and Outreach Material
* Office supplies
* Meeting supplies
* In State Travel
* Computer Hardware or Software Equipment
* Assessment for Placement Services * Follow-up and Orientation Services
* Research and contractual services

Examples:
Publications and Outreach Materials - (Pg 43-44)
Reasonable costs to develop and produce materials to promote CAEP services and activities. Examples include materials for orientation and assessment workshops, guides for creating an education plan, brochures about supportive services, etc.

For any purchase of this amount, a Capital Outlay request needs to be made. The State will review and let you know if they have questions. If it is not allowable, they will let you know. The steps for that request are:

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 to be done or item(s) to purchase
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.

Once we have that email, we will forward to the CDE Consultant and to the CDE CAEP Leadership for review and guidance.

How you choose to set up personnel expenses for CAEP is a local decision, and you are well within your rights to determine the approach that makes the most sense for your team.

If you believe that staff members spend roughly a quarter of their time in each program area, that would be a reasonable way to allocate it. The only time this breakdown truly matters is for the annual Program Area Report, where it's helpful to estimate how much time each person supports each program. It doesn't have to be exact, and an informed estimate will be perfectly fine.

For K-12 CAEP and WIOA agencies, we allow the use of state & federal funds for student supports that help them reach their goals. This would include things like GED vouchers, and other tests or certifications required for the career pathway. But the district must control the funding for these items. The district must not “give” money to the student as that would be a gift of public funds”. Also, keep in mind, the funds would have to allocable to one of the program areas, be reasonable and necessary, and in the case of federal funds, not supplant existing funds.

Lastly, ELL HP funds may also be used if they are a grantee recipient. The key is to ensure the process does not violate Prop 98 limitations that would make it a gift of public funds. The administration of vouchers will need to be carefully managed by the district.

CAEP funds cannot be used to support credit courses supplies and materials. The college must use other funds for credit programs.

At this stage, the information needs to be submitted to the Chancellor's Office. The standard process requires that the Chancellor's Office be notified prior to the commencement of any Capital Outlay project. However, part of the project has already been completed without prior notification.

The linked Fiscal Management Guide provides the following on gift on funds.

Gift of funds is on page 47 under the Examples of Expenses not allowable (pg46). Throughout the guidance there are specific language that speaks to what is reasonable and justifiable and how the funding should be used. For example, funds for bus passes, exams, etc. are considered a gift when given to a learner. However, I know that there are vouchers provided to learners, but it must be done via the GED Manager. This ensures the vouchers can’t be resold or given to another student.

Reasonable & Justifiable (pg.12)
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.

Funding (EC 84913, 84914): (pg.17)
• CAEP funds are expended within the seven CAEP program areas, and are
consistent with each consortium adult education regional plan.
• Consortium expenditures must align with the objectives of th

  1. Examples of Expenses Not Allowed (pg.46)
  2. Clothing (pg. 47)
    Program funds may not 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.

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.

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.

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 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.

"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.

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.

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.

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.

Since there was underreporting in the Q4 report, it will be necessary to overreport in Q1 of the next fiscal year to ensure the budget balances. Please remember to attach any supporting documentation that explains the discrepancy or provides justification.

If the Q4 Expenditure Report has not been certified at the consortium level, you should be able to uncertify the Budget and Workplans and subsequent expenditure reports allowing the overage in overhead to be reduced. You will want to recertify as soon as you can after they make the changes.

If your Q4 has been certified, the adjustment can be made in Q1 Expenditure Report of the next FY. Reduce the overage from the appropriate object code and explain the reduction in the summary of activities box.

We expect the Written Expenditure Plans associated with carryover to be released in early October.

As you've yet to certify the Q4 Expenditure Report at the consortium level, you should be able to unsubmit the member district's Q4 and allow them to reduce the overage from the indirect category. The reduction in expenditure can be explained in the summary of activities box. It would be preferable to make these changes before Q4 is certified.

If you have NOT certified at the consortium level, you may be able to decertify/unsubmit a member's report and enter your changes by following the bulleted instructions below:
1. Go to the consortia members tab
2. Scroll all the way to the bottom until you reach the budget and workplan
3. Click on the agency that needs to make a revision
4. Decertify
5. Have the agency making the change update their budget and workplan and submit
6. Once the agency submits the consortia lead needs to recertify. Once that is done the agency can go back to their expenditure report and submit.
If the option is not available to decertify, the changes will need to be made in the Quarter 1 report for the next FY by reducing the overage and explain in the summary of activities box.

Have you already certified Q4 for the consortium? If so, unfortunately, once a Quarter 4 report has been certified there is no possibility of decertifying it. We are unable to reverse this process on our end either. Any changes will need to be made in your current year's Quarter 1 Expenditure Reports to align with NOVA.

If you have NOT certified at the consortium level, you may be able to decertify a member's report and enter your changes by following the bulleted instructions below.
1. Go to the consortia members tab
2. Scroll all the way to the bottom until you reach the budget and workplan
3. Click on the agency that needs to make a revision
4. Decertify
5. Have the agency making the change update their budget and workplan and submit
6. Once the agency submits the consortia lead needs to recertify. Once that is done the agency can go back to their expenditure report and submit.
If the option is not available to decertify, the changes will need to be made in the Quarter 1 report for the current fiscal year.

Review the WIOA budget and identify what caused the overage of $80,000. Take the expense(s) that caused the overage and move them over to the CAEP budget. If there was a big, one-time purchase, that's preferable to something that might be considered ongoing funds. However, know that it's also possible to move teachers, services, etc. so long as they have been pre-approved by your WIOA EPC.

The member will be unable to pay a 3-year contract. The member can only report on services/expenses that have been rendered in a given year. As far as the consoritum reporting, only one year at a time should be budgeted and expensed as services are completed.

The member should also be sure to include the activities, related to these contracts, in the consortium's annual and Three Year Plans so that members are aware of the contracts and to ensure alignment to the consortium's goals.

Q4 cannot be submitted and certified as is.
Negative numbers cannot be submitted in any object code. While NOVA won't prevent a member from submitting with negative numbers, the Fiscal Management guide has always said a negative is not allowable: (here is from 19-20, showing the language was there back then, it's still there in the current). Do not certify Q4 without fixing the negative numbers.
Jun 30: End of Q4 Note: Expenditures cannot be reported with a negative balance in any of the object codes.
The Indirect limit is 5%. Do not certify Q4 with indirect that's over 5%. Refer to the Fiscal Management guide pages 25-26 for more information.
Again, don't submit Q4 with any negative balances. Take the time in September to fix the errors. You may need to decertify earlier quarters to address these errors.
If your errors aren't cleared, don't certify your Q4, even if you're past September 30. Once you certify, no changes can be made and that only exacerbates the reporting issues.
Please note that the state will start flagging for carryover compliance on the 30th whether or not you have certified Q4.

The way NOVA is built for fiscal reporting is that each quarter is a cumulative figure. Meaning you cannot report less than the previous quarter. If the member took advantage of WIOA, the expenditure in the 4000's would then mirror Q3 with the explanation that an additional funding stream was used, etc.

For example, if the 4000's was only $1,000 in Q4 and in Q3 the total entered into NOVA was $3,000. The Q4 figure should equate to $4,000.

If there were no funds used in the 4000's in Q4, than the number reported would mirror the Q3 figure.

For example, if the 4000;s was $0 in Q4 and in Q3 the total entered into NOVA was $3000. The Q4 figure should reflect $3,000 as the fiscal reporting is cumulative.

NOVA fiscal reporting is used to report on all CAEP funding allocations. By adding in another funding stream into your quarterly report misrepresents the funds. This is especially important with Carryover Compliance (AB1491) and the impacts that can have on the consortium. If the district fiscally supported a CAEP program, than the figure that CAEP funds were used is the only figure that should be recorded into NOVA. The district fund will need to be journaled on/in your internal system.

NOVA is the system that the State uses to view fiscal and strategic plans for CAEP. The only instance that other funding streams are added into NOVA under CAEP are when you are completing the Program Area Report. This tells the state how you are braiding funds for the success and implementation of a program as well as the cost per learner the program is supporting.

Fiscal Guidance: https://caladulted.org/DownloadFile/1300

It is critical that you use your quarterly fiscal reports to only report on CAEP allocation funding.

They are flagged because the amount they entered is less than the previous quarter. NOVA is cumulative, so their Q4 expenses should be added to what the cumulative total was for Q3 and entered. To correct this, the consortium lead will have to uncertify Q3, the member will adjust, resubmit, and the consortium lead will re-certify.

Prior years cannot be opened for corrections. Any errors that happened in previous years must be corrected in NOVA in the current year. For example, if you found out that $5,000 in expenses was never reported in NOVA, your budget in NOVA is overstated by that $5,000. In the current quarter, you will take your true expenses, and increase them by $5,000, to marry the NOVA total to your district books. Your district books are the official record; however, we do need to match your NOVA to them. The same will go if you overreported your expenses in 2018-19, you would do the opposite now and reduce your current true expenses by the amount they were overreported years ago.

We do ask that you input a note in NOVA to explain the overstatement/understatement of expenses, as well as add a note in your district books. The note should say when the error occurred, what it was, and when it was resolved in NOVA. This will keep everyone up to date in the event of staffing changes.

The CAEP Office doesn't grant permission or restriction on receiving these. That is a local decision. The lead can request them from members, but they are not obligated to provide them. Ultimately, the member is responsible for the information submitted, not the lead who certifies the report.

The certification from the lead is simply certifying that it was submitted, not the data submitted.

If a consortium wishes to have these reports to verify data, that is a request they can take. If members don't object, we would suggest adding it to the Bylaws so that it is voted on and becomes a consortium rule.

There was an allocation amendment completed recently. Once that was completed, all budgets would be put back into draft status because everyone received additional funds. Members would allocate their additional funds and submit, and you would recertify. Once that is done, it should not go back into draft status. The Allocation Amendment is likely what caused them to go back into draft status, which was needed since their allocation amounts changed.

As for the error message, I am not sure why you are getting that. If that message continues to populate for you, please click on the Help button in NOVA (bottom left in the blue ribbon) and submit a support ticket for NOVA so they can troubleshoot the system.

"Carryover compliance is only based on the current year allocation. It will never take carryover from the previous year into account. However, total available funds do include that carryover. The consortium had carryover from last year. Because of this, any member with carryover will always have a different Total Available funds vs current allocation amount, and their expenditures will show a negative in the Carryover Compliance section until they have expended all carryover funds. This will also show their carryover percentage as higher because that percentage is only based on the current allocation. They have to spend all of their carryover before the current allocation begins being spent and at that point you will see that percentage begin to reduce. If you subtract their carryover from last fiscal year from their current expenditure total, you will get the portion of their current allocation they have spent. That will be the percentage NOVA is showing.

It is important to note that if you carry over 20% at the end of this year, next year you will have to spend the 20% carried over plus 80% of the new allocation to meet compliance. Same as this year, all members that had carryover from last year have to spend all that carryover plus 80% of their new allocation."

Access NOVA and click on CAEP, then Fiscal Reporting. Enter your consortium number in the Title field and change the reporting period to 23-24 Q1the reporting period you are seeking. That will populate the consortium. Click on the name and it will show you each member's expense reports.

You are able to do either. If your district has guidelines on this, then guidance is to follow local policy/regulations. If it is not explicit, then you have the ability to do what is best for your consortia.

In NOVA, Click on CAEP, then Fiscal Reporting.

From there, select your institution and change the year to the last quarter you are referencing in the fiscal year. Leave all other boxes blank in the search field.

It should populate your consortium. Click the hyperlinked consortium name to get to the actual reports.

Scroll down to your agency and click on the quarter you wish to address. If it has been submitted, click Unsubmit Report in the bottom right. If it is unsubmitted, click the tab for the previous quarters to do the same. You will want to unsubmit any quarter that requires changes. Remember that any change in Q1 will also require changes in the following quarters, as NOVA is cumulative and the total will change for Q2 and Q3 if the total in Q1 was changed. Once a quarter is ready, you will click submit and the lead will have to certify that quarter. Each quarter will have to be submitted and certified individually.

Log into NOVA and click CAEP on the left side. Then, click Fiscal Reporting. Enter your agency name and go to your agency report to enter your expenses.

Expenditures on expiring funds must be on or before 12/31 of the final year. The consortium only have until March of the following year to report on them. 

The California School Accounting Manual (CSAM) is what the adult school must follow when recording revenue. If the revenue is from multiple sources, it would be a good idea to assign each source a local fund code for tracking and reconciliation.

Example: If the member's carryover doesn’t match NOVA and they have to reconcile, having those funds tracked separately would help identify the amount.

Additionally, the Fiscal Guidance is linked with a pull out that speaks to revenue and how it should be recorded.

Fiscal Guidance: https://caladulted.org/DownloadFile/1300
Allowable Uses of Adult Education Program Funds
2 How to Use this Guide The purpose of this guide is to specify the education code and processes used to spend California Adult Education Program (CAEP) funding by regional consortia and
caladulted.org
(Page 27)-
K-12 and COEs must adhere to the following reporting requirements:
• All Adult Education Program revenue should be recorded in Fund 11, Adult Education Fund, using Resource 6391, Adult Education Program. Fund 11 is the only fund valid in combination with Resource 6391.

• LEAs that continue to formally commit LCFF revenue to the purposes of adult education should use Object 8091, LCFF Revenue Transfers, to transfer the committed LCFF revenue from their general fund to Fund 11.

• There are no statutory provisions preventing an LEA from carrying over funds, however, a consortium may change the amount of adult education funds available in future years based on actual prior fiscal year spending (see Reduction in Funding / Member Ineffectiveness).

• LEAs will use the same resource code for MOE and non-MOE funding.

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.

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.

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.

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.

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.

There is a box for indirect charges in the drop-down menu. Please use that when budgeting and booking all indirect expenses. Seven thousands (7000 - other outgo) are usually reserved for interdepartmental expenses or pass through funds.

Unfortunately, once Q4 is certified, the Budget & Workplan for that year is no longer accessible. It can be viewed on the Member's dashboard, but not changed. Quarter 4 of 23-24 has been certified, therefore the member is no longer able to make edits to their Budget & Workplan.

One member of the consortium was able to submit and certify, which indicates there is a permission issue. The member who is able to submit and certify and change the role of others in NOVA.

The Budget and Workplan for the previous FY is closed and cannot be edited. You can view yours by clicking on the left-hand side: CAEP; Consortium & Members; type in the agency name, when it populates click on the member agency and then scroll down to the 3rd section, Budget and Workplan to view the document.

The allocation is showing as doubled because Q4 is not certified. Once Q4 is certified, it will be marked as spent and then the Budget will be correct.

As these are the next fiscal year's funds, you will need to close out your Q4 Expenditure Report for the current fiscal year first. Per the CAEP Fiscal Guidance, before you submit your Q1 report for the current fiscal year, you will want to complete an allocation amendment that shows the movement from your fiscal lead to each of the members. Members will modify their budgets and allocate the new funding across the object codes in alignment with their spending plan. At the Q1 report, the carryover will right itself.

References:
Fiscal Guidance, Page 5
Allocation Amendment
The CAEP allocation amendment process allows consortia and members to change allocations outside of the CFAD process. Allocation amendments can occur throughout the year, but should be recorded in NOVA prior to the submission of the following expenditure report. Allocation amendments must be approved by all member agencies, even those agencies not directly affected by the changes. Consortia that utilize the direct funded disbursement method will need to work at the local level to transfer funds between member agencies.
Budget Changes
Budget modifications must be submitted in NOVA prior to the submission of the quarterly expenditure report. In order to submit a budget revision, the consortium primary contact must un-certify the budget and the member representative unsubmits, in order to allow changes to be made. The member representative enters their changes and re-submits the budget, upon which the consortium primary contact will need to re-certify.

Until the Q4 Expenditure Report for the previous fiscal year is certified, the Budget and Workplan for the current fiscal year will be inflated. Once Q4 certified, the Budget should reflect the current allocation plus true carryover.

To view old budget and workplans in NOVA:
Click on CAEP Consortia and Members from the Dashboard
Choose or enter in the name of your consortium
On the Consortia & Members page, scroll down to Member Agencies (under Consortium Contacts) and choose the agency you're looking for
Within the specific member's page, scroll down to Budget & Workplan and you will see all the old plans for this member.

Three-Year plan was decertified somehow and is awaiting a member to approve. Once approved, the annual plan will open.

That will be the case until Q4 is certified, September 30th. Once certified, all the previous fiscal year's funds are marked as spent and will be removed from your current fiscal yeary's Budget.

Here are the steps given as follows:

  1. Consortia Lead must decertify the Budget and Workplan for the district.
  2. The member may need to click (upper right corner) un-submit on their Budget and Workplan.
  3. The member makes the necessary changes to the Budget section.
  4. The member clicks to Submit their Budget and Workplan.
  5. Member lets the lead know they have submitted, and the lead re-certifies it.

Once that is done, any red exclamation marks in the fiscal reporting should be resolved.

With the Budget and Workplan, if there is money that needs to be moved among object codes, you will need to go through the process to de-certify and open it up and then have all members go into NOVA to approve. Below is the fiscal guidance section that speaks to the Member Workplan and Budget.

Fiscal Guidance (pg.34)
4. CAEP Member Workplan & Budget
Based on the annual plan strategies (submitted by August 15th) and the CFAD (submitted by May 2nd), each member creates a budget and work plan for the new fiscal year (July 1 to June 30). The member budget is by object code, which aligns with the member work plan to spend all active funding during that 12-month fiscal year period. Active funding includes all carry-over and new funding combined into one budget. The member work plan aligns with the strategies of the annual plan. Members will check which strategies from the annual plan they are covering with their 12- month budget. Once the member submits their work plan and budget, the consortium membership will review, approve, and certify for the upcoming year. If the member has changes to their work plan and/or budget, it will go back through NOVA using the same process of consortium membership review, approval, and certification.

You are correct. If the Q4 fiscal reports are not certified, no expenses are confirmed as spent, therefore the budget will look inflated. Once certified, it should equal the new allocation and true carryover amount.

The member is able to charge the 5%. If they didn't charge the 5% earlier in the year, they can still charge before they submit their Q4 and would need to do a budget and workplan change which is permissible under CAEP.

Per the legislative trailer amended under EC 84913, K-12 districts and COEs may use their CDE approved indirect cost rate for any CAEP/CAEP apportioned funding or 5% whichever is less.

Fiscal Guidance: Page 25-26
https://caladulted.org/DownloadFile/1300
10. Indirect Rate for Members

Effective July 1, 2018, Section 84913 of the Education Code is amended to read: For purposes of this paragraph, "indirect costs" means either of the following: (i) For consortium members that are school districts and county offices of education, the lesser of the member's prior year indirect cost rate, as approved by the department, or no more than five percent of the total funding received from the program. (ii) For community college consortium members, the lesser of the member's prior year negotiated indirect cost rate or no more than five percent of the total funding received from the program. Per the legislative trailer amended under EC 84913, K-12 districts and COEs may use their CDE approved indirect cost rate for any CAEP/CAEP apportioned funding or 5% 25 whichever is less. The CDE approved indirect cost rate varies by district and is not a set amount. Please check the CDE Indirect Rate website for each school year, at the link shown below. http://www.cde.ca.gov/fg/ac/ic/ Community College Districts (CCDs) may use up to either their approved indirect cost rate as directed in Code of Federal Regulations (CFR) 200.414 up to the development minimums amount as allowed in the CFR or 5% whichever is less. https://www.gpo.gov/fdsys/granule/CFR-2014-title2-vol1/CFR-2014-title2-vol1- sec200-414

No, members must allocate all funds. NOVA will not allow the budge to be submitted unless the remaining amount was zero. Fiscal agents are able to hold on to funds for consortium-wide activities, however they must allocate them in their budget appropriately.

It's important that the member district work within their given CAEP budget. Consortia know their approximate CAEP allocation for the following fiscal year by February of each year and can use that number to assist with budget planning. We don't advise districts when it comes to managing their funds. However, if the district is borrowing funds from the General Fund to make the adult ed payroll, there needs to be a plan for how that money can be paid back once the CAEP funding is released, while still allowing the CAEP member to work within their identified annual allocation. The member can also consider planning for a carryover from the prior year (up to 20%) to cover the time period that they won't yet have funding.

Members who choose to spend more than their allocation, are choosing to work in good faith of continued funding and also knowing they will begin next year with reduced funding.

If a member spent $100,000 over their current year budget, next year their budget will be $100,000 less than their allocation. They will still receive the same allocation, but their available funds will be reduced due to the overage spent the year before. It is not a good practice and we strongly urge against it. However, we cannot stop it. They will need to reduce their spending next year to make up for the deficit, otherwise they will always be running in the deficit, which is dangerous.

Some consortia have members that carry excess funds and in situations like this, those members choose to give some of their excess funds to the member who overspent, to bring them whole again. That is optional and not required. If you have members who are in jeopardy due to the new carryover compliance, they may wish to do that. That would be handled through an allocation amendment where one or more members give funds to the one who overspent. It is a one time transfer of funds and is not a continued reduction to the members funds who are giving some away. Permanent changes are through the CFAD. Allocation Amendments are one time transfers with no permanent effects to their base funding.

Another option is for the member who over spent to work with their district and see if the district can cover any of those expenses out of different pots of money. If they are able to do so, the expenses can be journaled and they can edit their Q3 expense report and not report what is journaled to another fund source.

Once a CFAD has been consortia approved, there is no way to uncertify it.

When completing the new budget, you will be able to add a category for each of the object codes, as well as for Indirect. You will simply select Indirect in the drop-down menu and enter the amount. Please remember the indirect you are allowed to take is 5% or state indirect rate, whichever is less.

If you do not already have the indirect category, you can click the New Budget Item (blue button) at the bottom to add it.

To give a portion of the consortium funds to various members, you will need to complete an Allocation Amendment. In the amendment (done in the appropriate year for the funds being given), you will reduce the member with the funds being given by the total amount being given. You will then increase all the members receiving funds accordingly. Once the remaining funds to be allocated equals $0, you will submit that, possibly with a short explanation of why this amendment is happening. All members will get a notification and will have to approve the amendment.

Once it is approved by all, any member who received or reduced funds will have their Budget and Workplan automatically put into draft status. Each member will need to go into the Budget and add funds to the correct object code(s) or reduce funds from the correct object code(s). Once the Budget shows they have $0 remaining to be categorized, they will click to Submit. You will then have to certify each members budget individually.

Then, the member who is giving the funds will have to cut a check to each member.

All CAEP funding is tied back to the member allocations established in 2015. That amount must stay the same unless a member reduction meets the criteria listed in education code. No consortium can change a member’s allocation in the CFAD unless it’s for one of the three causes. What you can do is after the CFAD is certified and all members receive the same percentage allocation as the prior year – you can perform an allocation amendment to move funding around without having to meet the ed code criteria. All members would have to be on board with the change.

ED code does not address leadership or consortium funds – except that it can’t be more than 5% of the total allocation for the consortium.

For changes in Fiscal Agents, consortia could say that the old fiscal agent member can’t follow the adult ed plan as cause for moving the money around. Not following the plan is one of the criteria to move funding around via the CFAD.

The Program Area Report is always runs 6 months behind. The data populated in Launchboard is older and is meant for information only. Please disregard it. The data is meant only to show you the areas you have historically had students enrolled, as a starting point for you to gather data. We advise members to use their own data source when inputting data for that report, and not use the Launchboard data.

You are welcome to revise your budget as often as needed. You will need to follow these steps:

Ask your consortia lead to uncertify your budget and workplan
Go to your budget and workplan and click to unsubmit.
Make any necessary changes.
Submit
Ask your consortia lead to re-certify it.

It is important to note that it will likely be only the Member Representative that can unsubmit and resubmit the budget and workplan. If you have access to NOVA as a contact, you will be unable to complete those two functions.

Indirect charges should be charged to the indirect category, not the 7000.

The Core Performance Report is a CASAS report and their tech support can assist with that. Here is their contact information:

Tech support
techsupport@casas.org
1-800-255-1036 option 2
6 a.m. to 5 p.m. PT and 9 a.m. to 8 p.m. ET
Monday to Friday

There is no ability to go back to a previous year's reporting and make corrections. If there is an area that requires a correction, we must make it in our current year.

At this time, your consortium should have certified Q1 and Q2. We will want any corrections from the previous year to occur in Q1. Given that, the consortium lead will need to work backwards and decertify the Q2 Fiscal Report (must be done first), then decertify the Q1 Fiscal Report. Once Q1 is decertified, the steps for your district to follow are:

  1. Unsubmit your Q1 Expense Report

  2. Decide the action that needs to be taken: if you over-reported expenses last year and are showing less carryover than you actually have, you will need to do the opposite and under-report this year. If you under-reported expenses last year and your carryover is showing more than you truly have, you will want to over-report this year. We need to marry NOVA to your district books, as your books are the record of audit and NOVA is just the CAEP reporting tool.

  3. We want to try to match the object code to the same object code that had the error last year. If you over-reported expenses in the 5000s by $2,000, you will under-report the 5000s by $2,000 in Q1. If your true Q1 5000 total is $30,000, you will report $28,000. This will then make NOVA totals match your book totals. The trouble may come if the number is a large number. If you over-reported $50,000 and your Q1 5000 total is only $30,000, you would make the 5000s zero and then reduce any other object code by the remaining $20,000. If the amount is greater than your Q1 totals all together, you will mark all zero's in NOVA for Q1. You will want to keep track of your true expenses for Q1. Let's say Q1 true expense totals are $40,000, yet you are needing to under-report by $50,000. You will mark everything as a zero and then also change your Q2 report and reduce those true expenses by the remaining $10,000. Keep in mind that NOVA is cumulative, so what it shows for Q2 is the total of Q1 and Q2. You will need to find the true Q2 expenses and reenter all numbers since we just changed Q1 to be all zeros.

  4. Under-reporting last year is easier to fix. You will simply add the amount you under-reported by to Q1 in the appropriate object code. It's much easier to add more money than to take away money in NOVA if it's a large amount.

  5. Once the correction has been made, you will submit your report and notify your lead it is ready for certification. The lead will need to certify Q1. If you made changes in both quarters, you will have to submit Q2 once Q1 is certified. You cannot submit Q2 until Q1 is complete, so there may need to be some back and forth with the lead to know when each step is done.

You will want to keep detailed notes of what the error was and when it occurred, also when, where and how it was fixed in NOVA. Keep those notes in NOVA as well as your district books so others will know what happened and when it was corrected. Otherwise someone could spend months trying to figure out why the numbers don't match the books.

For the over-reporting example of the $2,000 I gave above, the notes would resemble: In 23-24, the Q4 Fiscal Report was over-reported by $2,000 in object code 5000. To correct that, Q1 of the 24-25 year had true expenses of $30,000 reduced to $28,000 in the 5000s. The under-reporting in 24-25 offset the over-reporting in 23-24, thus marrying NOVA to the district books.

If certain object codes have significantly more funds than you anticipate spending, it's appropriate to reallocate those amounts to categories where additional funding is needed.

For example, if you expect to overspend in one area but have surplus funds in another, you can shift the budget accordingly to better reflect actual spending projections.

You are allowed to make multiple budget revisions throughout the year as needed, up until the certification of Q4. To do this, the Consortia Lead will need to decertify your Budget and Work Plan in NOVA. Once decertified, you can unsubmit, make the necessary adjustments, and then resubmit. After resubmission, please notify the appropriate contact (e.g., your CAEP Program Monitor) that it’s ready for recertification. Note that while the Budget and Work Plan are decertified, your agency will not have access to fiscal reporting.

In order to make changes to the budget the consortium's primary contact must un-certify the budget and the member representative un-submits, in order to allow changes to be made. The member representative enters their changes and re-submits the budget, upon which the consortium primary contact will need to re-certify.

Budget Revisions should be allowed any time the member needs to move money between object codes. They can do this multiple times a year up until the certification of Q4. During the fiscal reporting, if the member has a red exclamation mark (meaning they have overspent in that object code), they are advised to complete a budget revision to clear any red exclamation marks. Ideally CAEP does not want to see any overspending in object codes.

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.

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

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.

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.

There aren't separate options for CAI and the ELL Healthcare Pathway funds. Members should choose Add Another Fund under the Leveraged Funds section and then choose Add Another State Fund.

Yes, there is an annual submission for the Program Area Report, due December 1st, that includes leveraged funds.

Yes and no. You will not report the Calworks funds in the quarterly expenditure reports. You will report these in the Program Area Report, under Leveraged Funds, in December.

The courses listed sound more like workforce prep. If you were to report them as CTE, the teacher would have to hold a CTE credential. The courses also need to be linked to a CTE pathway and certification at the end of a sequence of courses. Generally, CTE courses are leading students to an identified career. At the college, the teacher would have to meet the minimum qualifications established by the college for the position they're teaching. It appears that some courses might lean towards CTE such as Medical Assistant, Early Childhood Ed, etc. that would build toward a certification and career. The classes you listed are workforce prep as they're stand alone and aren't part of a pathway.

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.

Each district is able to take 5%, or their CDE indirect rate, whichever is LESS, of their yearly allocation to be used for indirect. Indirect costs would be anything not directly tied to the program, such as an administrator who has a small portion of their salary paid which covers the time needed to approve items in NOVA.

If you have Personnel or Financial staff that touch the budgets and work for adult ed, a portion of their time (as appropriate) can be charged to the indirect. The indirect is to be taken on a quarterly basis and should be applied based on expenses. So, if you have a $5,000,000 allocation, but in Q1 you spent $100,000, the indirect claimed for Q1 would be 5% or CDE indirect rate of the $100,000 expenses.

First, identify how much 20% of your total CAEP consortium funds is. (Ex. If you had a total of 8M, 20% carryover would be 1.6M.)

Next, identify the unspent CAEP funds for each member. (One member may have 37% of 2M remaining and the other member may have 11% of 6M remaining. It's important to look at the amounts each is receiving and has spent.)

Add the member unspent funds together to determine the amount of CAEP unspent funds for the consortium. (In this example, the member with 37% of 2M has $740,000 in carryover, and the member with 11% of 6M has 660,000 in carryover. Added together, they have total unspent funds equaling 1.4M.
As the 1.4 in carryover is less than 20% (1.6M), this consortium would not be required to submit a written expenditure plan.

For member carryover (like, for one member of the consortia), the actual money totally spent and dispersed is what counts, not open POs and other expenditures which won't be paid until after Q4, even though the POs were from a prior fiscal year and just not paid or received yet?
This is correct. Anything that has not been fully spent and received would be considered carryover.

If one member is over the percentage and writes a Corrective Action Plan in NOVA, do they also need to write a letter to the Chancellor, etc?
At this time, no additional letter is required.

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.

Consortium request for extension is approved. The Consortium will want to ensure the plan is submitted and approved no later than due date. If they experience delays, please inform the Consortium Director to communicate with CAEP TAP as the consortium is already providing a 60-day extension.

There is no error with the allocations for the prior fiscal year. The negative amount you are seeing in the CFAD is due to a revised final budget from the Governor, which included a funding reduction that year. The amounts in the CFAD cannot be changed directly; instead, any adjustments are made through Allocation Amendments. The negative amount reported as over-budgeted was addressed in an Allocation Amendment, which removed the overage and effectively zeroed it out.

As for amending budgets for closed years, allocation amendments for fiscal years like the previous year must be completed before the established deadline. If you need to reallocate funds from an earlier year, this can be done through the current fiscal year's allocation, provided those funds were carried over. It's important to ensure that the receiving member has already spent their prior-year funds and is on track to spend their current allocation appropriately.

Additionally, there is no discrepancy in the totals. Please review the landing page and allocation sections in the system for confirmation.

You can find your carryover amount that needs to be expended in the fiscal reporting section of NOVA by going to the Q4 report. There will be a box at the bottom that indicates your carryover amount which should be the same as the budget remaining. To fall within carryover compliance 100% of the carryover funds from the previous fiscal year plus 80% of the current allocation will need to be expended by the end of the current fiscal year.

Below are the Capital outlay steps, however, CAEP funding cannot be the only funding source if you intend to utilize the capital outlay project with other programs, students, departments, etc. Funds are highly encouraged to be braided.

Capital Outlay Steps
Fiscal Guidance: (March 2023) https://caladulted.org/DownloadFile/1300

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.