DPI’s universal monitoring process supports all LEAs to understand the basic rules and requirements of the federal laws and regulations. There are two parts to universal monitoring: General Monitoring and ESEA Compliance Monitoring.
General Monitoring
- Assurance, Applications, Budgets, and Claims
-
DPI administers ESEA grants through its federal grants management system, WISEgrants. WISEgrants is the foundation for universal monitoring as it aligns with the 2 CFR 200 Federal Uniform Grant Guidance, the Education Department’s General Administrative Regulations, and Wisconsin’s Uniform Financial Accounting Requirements. LEAs will digitally sign assurances affirming they will comply with the provisions of all applicable statutes and regulations, as well as assurances that meet the requirements of the General Education Provisions Act (GEPA) (20 U.S.C. §1232e).
LEAs are required to develop separate budgets under a single grant for public school services and private school equitable services. LEAs must tie each detailed budget item to an ESEA allowable activity. DPI staff review each budget item to ensure that it is reasonable and necessary, as well as allocable to and allowed under ESEA grants.
LEAs may only claim funds based on DPI-approved applications in WISEgrants. DPI staff review claims for reimbursement to ensure compliance with the approved budget/allowable costs. Once claims are approved by DPI’s grant accountants and the LEA is paid, the DPI business office accountants request reimbursement from the federal government.
WISEgrants retains the Grant Award Notifications, grant applications, claims, and other data to meet state and federal regulations regarding records retention policies and procedures.
- Affirmation of Consultation with Private School Representatives
-
ESEA requires LEAs to provide equitable services to students, their families and teachers in private schools, as determined in consultation with the representatives of the private school (20 U.S.C. §6320(b) and 20 U.S.C. §7881(a)(5)).
LEAs are required to submit an Affirmation of Consultation with Private School Officials form for every private school located within its boundaries, in WISEgrants. The Affirmation of Consultation form serves as official verification that consultation occurred between an LEA and private school and indicates whether or not a private school wishes to participate and receive services under each of the Title grants. In order to ensure alignment with consultation requirements, the form includes all of the following sections: General Information, Required Consultation Topics, Uses of Funds, Participation in Services, Private School Verification, and LEA Verification.
Once the Affirmation of Consultation form is completed and signed by both the LEA and private school officials, the LEA is required to upload the form in WISEgrants. DPI staff will review each form to ensure it is completed properly. Once the LEA has submitted an acceptable affirmation form for every private school located within its boundaries, the LEA will be able to access and complete the rest of their ESEA grant applications. This ensures that a plan for services in a private school wishing to participate under a grant, has been developed and agreed upon prior to the LEA budgeting and claiming any grant funds; and therefore, that the LEA has met consultation requirements.
- Private School Equitable Service Provision
-
DPI conducts general monitoring to confirm the level to which an LEA implements equitable services. This includes identifying and ensuring:
- LEAs provide timely and meaningful consultation with each private school located within their district’s boundaries, by requiring LEAs to upload an affirmation of consultation to their WISEgrants application. WISEgrants will not let LEAs complete their application without acceptable documentation.
- The proportional share is calculated in WISEgrants based on enrollment data certified by the LEA in WISEgrants.
- Budget items for services are reasonable and necessary, and align with the intent and purpose of the specific grant.
- LEAs provide services. DPI requires all LEAs that did not claim more than 10% of the funds set aside for equitable services for each Title in the previous year. DPI will require the LEA to attend a webinar in the fall where they will discuss options and provide support if there are challenges to providing services. DPI sends LEAs required to attend the webinar notifications about the webinar through WISEgrants. If the LEA fails to attend the webinar, DPI may select LEA for Targeted Monitoring for Private School Equitable Participation in the following year.
- Equitable Distribution of Teachers
-
ESEA requires all LEAs receiving Title I funding to explain in their ESSA LEA Plan how they will ensure that low-income students and students of color are not disproportionately taught by new and out-of-field teachers (20 U.S.C. §6312(b)(2)). This includes:
- Inexperienced Teachers: teachers that have been teaching in a licensure area for three years or less.
- Out-of-Field Teachers: teachers that are teaching with a license with stipulations.
- Ineffective Teachers: teachers that do not meet the Wisconsin teaching standards.
To support this process, DPI uploads individual district reports into SAFE for LEAs to use as part of their data analysis. LEAs are encouraged to take into account local data (such as effectiveness, attendance, or other data) in their analysis and create a plan to ensure that disadvantaged students are not taught by inexperienced teachers at a higher rate compared to their peers.
Furthermore, ESSA requires DPI to ensure that students from low-income families and students of color are not taught at higher rates than other children by inexperienced, unqualified, or out-of-field teachers (20 U.S.C. §6311(g)(1)(B)). Every year, DPI will ask the LEAs that have schools with an inequitable distribution of teachers to create a plan defining how they will address and monitor the inequity identified. (More information about the data used to comply with this requirement is available on DPI’s Inequitable Distribution of Teachers webpage.) LEAs with an inequitable distribution of teachers may submit one plan per school or one plan for all schools with an inequitable distribution of teachers in the LEA. These plans will be posted on the DPI webpage.
ESEA Compliance Monitoring Process
DPI has identified a limited number of compliance requirements (Sections A - D) into an online monitoring module in WISEgrants. This makes the ESEA Monitoring process more coherent with other resources and systems within DPI that focus on and prioritize students’ social, emotional, and academic needs; ensure compliance with federal law; and minimize the administrative burden on LEAs.
Timeline for ESEA Universal Monitoring:
- Selection
-
Each year in late fall, DPI selects, notifies, and requires approximately 90 LEAs to upload documentation into the WISEgrants module for the ESEA requirements identified in Sections A - D. The list below shows which LEAs are required to upload documentation this year, and the upcoming years.
In January, WISEgrants will notify the LEAs required to upload documentation for Sections A-D and will provide them with instructions along with a deadline to upload the required documentation.
- Document Submission
-
All selected LEAs must upload documentation by the deadline identified in the notification letter. The ESEA Universal Monitoring WISEgrants technical assistance document provides step-by-step directions for the document submission process. Failure to complete the module by the deadline may result in DPI adding a risk factor identification for future ESEA Comprehensive Monitoring and/or DPI withholding payment of claims until documentation is submitted.
-
Once the document submission process begins, DPI will reach out to each LEA to schedule a mutually agreed upon date for the monitoring visit and whether it will be held in person or virtually. Comprehensive monitoring visits will be held in late winter/early spring.
The purpose of the monitoring visit is to discuss the evidence provided for each requirement, gather additional information and provide support if appropriate. LEAs should be prepared to discuss the guiding questions at the visit, although DPI staff will only ask questions that will help them better understand the LEA’s level of compliance with a requirement. DPI will not accept narrative responses to the guiding questions as submitted evidence.
It is important that LEA staff who implement the program(s) funded by ESEA grants participate in gathering and uploading required documentation, as well as speak in-depth to the programs monitored during the visit. The visit gives the LEA the opportunity to seek support where needed and to highlight and celebrate promising practices..
- Desk Review and Report Findings
-
In the spring, once the submission deadline has passed, DPI randomly selects at least 33 percent of those LEAs (~30 LEAs) for a desk review to determine compliance. Just like the initial notification, LEAs selected for the desk review are notified via WISEgrants. DPI reviews the documentation and follows up with LEAs regarding any documentation that doesn’t meet compliance, and offers support to ensure corrective action is taken to meet the intent of ESEA.
- Corrective Action and Closure
-
Once all documentation successfully meet compliance, LEAs will be notified via WISEgrants that their monitoring is complete.
-