Per 2 CFR 200.331(b), the Office of Adult Education Initiatives (AEI) must conduct a risk assessment at the beginning of each program year, using established criteria, to evaluate each grantee’s risk for the purpose of determining a monitoring plan. It is important to note that a grantee deemed high risk should not be interpreted as a negative reflection of the grantee.
At the beginning of each program year, AEI will score the below elements for each grantee. Each grantee will receive a copy of their results once it is completed.
Elements are weighted between 1-5 points. An element that is weighted as a 5 means the element puts the program at higher risk than an element weighted at a 4 and so on. If the element does not pertain to the program an “N/A” will be entered. If the program is not at risk for that element, a “0” will be entered.
Per the Workforce Innovation and Opportunity Act (WIOA) Colorado State Plan, AEI will conduct on-site reviews of at least 25% of grantees each year. Programs determined to be higher risk will receive on-site review first. Every grantee will receive an on-site review during the three-year grant cycle, however grantees in the top 25% will always receive an on-site review. This means that a grantee may receive more than one on-site visit during the three-year grant cycle.
All grantees, regardless of whether or not they are receiving an on-site visit, will be monitored monthly for data quality by their AEI Program Coordinator, provide a quarterly progress update, submit an Annual Performance Report, and be required to submit a self-evaluation, or continuation, application in non-competition years.
Grantees receiving an on-site visit may be required to submit additional interim financial reports and/or receive additional monitoring calls from the AEI Program Coordinator.
|1||Program did not receive AEFLA funding in the previous fiscal year.||5||2016-17 AEFLA grantee list|
|2||The AEFLA and/or IELCE grant awards total over $250,000.||5||2017-18 AEFLA and IELCE GAN|
|3||The program has a new fiscal contact for the AEFLA grant.||5||2016-17 continuation application and 2017-18 AEFLA application|
|4||Addition of new services (example: ESL or IET) or expansion of services into another Local Workforce Development Area.||3||LACES database, 2016-17 continuation application and 2017-18 AEFLA application|
|5||Other entities (state/federal grant managers, partner agencies, auditors, staff employed by the program, etc) have alerted the AEI office of potential risks.||4||AEI grantee notes|
|6||Program proposal or continuation application needed to be significantly altered due to required changes after the competition.||5||2017-18 AEFLA application and required changes|
|7||There was a 50% or more increase or decrease in AEFLA funding from the previous program year.||5||2016-17 and 2017-18 approved budgets|
|32 Possible Points|
Items included in Year 2 and Year 3 Risk Assessment (N/A for Year 1):
|8||Grantee has missed the deadline for submission of more than three (3) AEFLA deadlines or grant requirements in the last fiscal year.||4||AEI grantee notes|
|9||25% or less of participants made an Educational Functioning Level Gain.||5||2017-18 NRS Table 4|
|10||The grantee did not meet enrollment projections by 10% or more last year.||3||2017-18 application and 2017-18 NRS Table 4|
|11||In the last program year, grantee did not meet data entry requirements or did not remediate data errors or incomplete data after receiving technical assistance from their AEI program coordinator. The grantee did not adhere to the plan agreed upon with the AEI program coordinator or stay in communication if the plan needed to be adjusted.||4||AEI program notes|
|12||The program’s most recent audit reveals areas of concern (AEI will document concerns).||5||Audit review|
|13||The program collects fees or deposits from students.||1||Program Income Policy|
|14||Program that was funded last year had turnover in the program director or key personnel within the last twelve (12) months.||5||2017-18 AEFLA application and 2018-19 continuation application|
|15||Agency returned 10% or more of grant funding in previous year.||4||2017-18 budget vs 2017-18 Annual Financial Report|
|16||The program submits requests for reimbursement less than quarterly.||3||CDE Grants Fiscal drawdown tracker|
|17||CDE’s Grants Fiscal documented concerns with the grantee’s last Annual Financial Report filed.||5||CDE Grants Fiscal grantee notes|
|18||The grantee failed to follow through with the stated fiscal remediation plan after targeted technical assistance from the AEI Program Coordinator and Grants Fiscal.||4||AEI Program Coordinator and CDE Grants Fiscal grantee notes|
|19||Cost per learner is more than two times higher than other programs in a similar geographic area.||3||Comparison by AEI of cost per learner with grantees in the same or surrounding areas based on projected learners in the 2017-18 AEFLA application application and amount awarded.|
|75 Total Possible Points|