Resolution No. 2019-63 Governing Board for Don Soffer Aventural High School Approval of Charter School Program Grant Policies and Procedures Manual - November 21, 2019 RESOLUTION NO. 2019-63
A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF
AVENTURA, FLORIDA, ACTING IN ITS CAPACITY AS THE
GOVERNING BOARD FOR THE DON SOFFER AVENTURA HIGH
SCHOOL, APPROVING THE ATTACHED CHARTER SCHOOLS USA
CHARTER SCHOOL PROGRAM (CSP) GRANT POLICIES AND
PROCEDURES MANUAL; AUTHORIZING THE EXECUTION OF
NECESSARY DOCUMENTS; PROVIDING FOR IMPLEMENTATION;
AND PROVIDING FOR AN EFFECTIVE DATE.
WHEREAS, the City's Don Soffer Aventura High School (DSAHS), a municipal
charter school, desires to adopt the attached Charter Schools USA Charter School
Program (CSP) Grant Policies and Procedures Manual as required by certain grant
applications; and
WHEREAS, the City Commission, acting in its capacity as the governing board of
DSAHS, finds that approval of the attached Charter Schools USA CSP Grant Policies
and Procedures Manual is in the best interest of the City.
NOW THEREFORE, BE IT RESOLVED BY THE CITY COMMISSION OF THE
CITY OF AVENTURA, FLORIDA, AS FOLLOWS:
Section 1. That the foregoing "WHEREAS" clauses are ratified and confirmed
as being true and correct and are made a specific part of this Resolution.
Section 2. That the Charter Schools USA CSP Grant Policies and Procedure
Manual, as attached hereto, is hereby approved and adopted by the City Commission of
the City of Aventura, Florida, acting in its capacity as the governing board for the Don
Soffer Aventura High School.
Section 3. That the proper City and School officials are hereby authorized to
execute the Charter Schools USA CSP Policies and Procedure Manual, in substantially
the form attached hereto.
Section 4. That the City Manager is hereby authorized to do all things
necessary to carry out the aims of this Resolution.
Section 5. That this Resolution shall take effect immediately upon adoption.
The foregoing Resolution was offered by Commissioner Shelley, who moved its
adoption. The motion was seconded by Commissioner Mezrahi, and upon being put to
a vote, the vote was as follows:
Commissioner Denise Landman Yes
Commissioner Dr. Linda Marks Yes
Commissioner Gladys Mezrahi Yes
Commissioner Robert Shelley Yes
Commissioner Howard Weinberg Yes
Vice Mayor Marc Narotsky Yes
Mayor Enid Weisman Absent
City of Aventura Resolution No.2019-63
***<‘.C.-
A CNAROTSKY, VICE 11/1 OR
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ATTEST:
ELLISA L. HORVATH, C
CITY CLERK
APPROVED AS TO L GAL SUFFICIENCY:
CITY ATTORNEY
Page 2 of 2
Charter School Program Grant
Policies & Procedures Manual
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TABLE OF CONTENTS
Preface……………………………………………………….Page 3
Conflict of Interest Policy……………………….……...……Pages 3-6
Member Annual Conflict of Interest Form…………………...Page 7
Purchasing Policy………………………..……………….......Pages 8-14
Internal Controls…………………………………………..….Pages 15-17
Accounting, Reporting, and Inventory Control………………Pages 18-25
Enrollment and Admissions Policy…………………………..Pages 26-27
Governing Board Approval of Revised Procedure Manual.....Page 28
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PREFACE
Don Soffer Aventura High School (DSAHS or “School”) is a municipal charter school of the City of
Aventura (the “City”). DSAHS is subject to the regulations of the City as applicable. DSAHS’ School
Charter with the Miami- Dade County School Board, and the City Code’s procurement and ethics
requirements, and the applicable provisions of the Miami-Dade County Ethics Code, shall be
incorporated herein. In the event of a conflict, the stricter provisions shall control and be applied.
CONFLICT OF INTEREST POLICY
City of Aventura Board of Commission
Article I
Purpose
The City Commission serves as the Governing Board of Directors for DSAHS. As members of the
DSAHS Board of Directors (“Members” or collectively the “Governing Board”), the City
Commissioners, individually and collectively, shall be subject to the provisions of Florida law
pertaining to the avoidance of conflicts of interest in holding public office, including, but not limited
to, Part III of Chapter 112, Florida Statutes, Code of Ethics for Public Officers and Employees,
as may be amended from time to time. The purpose of this Conflict of Interest Policy is to define
Member obligations and ensure Governing Board compliance with the law.
This policy is intended to supplement but not replace any applicable state and federal laws governing
conflict of interest applicable to nonprofit and charitable organizations.
Article II
Prohibited Financial Interest
1.Prohibited Financial Interest
Prohibited Financial Interests are deemed a Conflict of Interest. Members shall not have a
financial interest in the School either directly or indirectly, through business, employment,
investment, or family. Such prohibited financial interests include:
a.An ownership interest or investment in any entity with which the School has a
transaction or arrangement;
b.A compensation arrangement with the School or with any entity or individual with
which the School has a transaction or arrangement; or
c.A potential ownership or investment interest in, or compensation arrangement with,
any entity or individual with which the School is negotiating a transaction or
arrangement.
Compensation includes direct and indirect remuneration as well as gifts or favors. Soliciting gifts or
favors from vendors, entities or individuals seeking, or who are in a position to seek, business
from the School is likewise prohibited.
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This provision does not prohibit a Member from performing services for or being employed by another
governmental entity, which has a contract with DSAHS. Such employment does not necessarily
implicate a conflict. Each scenario will be subject to ethics review to receive a case-by-case
determination. Members will receive training on this topic during the Governing Board’s annual ethics
training, to be conducted by the City of Aventura.
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Article III
Procedures Conflict
of Interest
1.Duty to Disclose
In connection with any conflict of interest with an item of Governing Board action, a
Member must disclose the existence of the conflict prior to any vote on such action.
2.Recusal of Self
A Member must recuse himself or herself from involvement in any decision or discussion
regarding any action in which the Member believes he or she has a conflict of interest, and
absent him/ herself from the meeting for that item.
3.Violations of the Conflicts of Interest Policy
a.If, after hearing the Member’s response and after making further investigation as
warranted by the circumstances, the Governing Board or committee determines the
Member has failed to disclose an actual or possible conflict of interest, it shall take
appropriate disciplinary and corrective action. The Governing Board shall adhere to
applicable City rules and regulations for violations of this Conflict of Interest policy.
Article IV
Records of Proceedings
The minutes of the Governing Board shall contain:
a.The names of the persons who disclosed or otherwise were found to have a conflict
of interest relating to a Governing Board action.
b.The names of the persons who were present for discussions and votes relating to the
action, the content of the discussion, and a record of any votes taken in connection
with the proceedings.
Article V
Compensation
No Member shall receive compensation, directly or indirectly, from the School.
Article VI
Annual Statements
1.
Each Member shall annually sign a statement which affirms such person:
a.Has received a copy of the conflicts of interest policy.
b.Has read and understands the policy.
c.Has agreed to comply with the policy.
2.
The Governing Board shall regularly and consistently monitor and enforce compliance
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with this policy by reviewing annual statements and taking such other actions as are
necessary for effective oversight.
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Member Annual Conflict of Interest Statement
Name: Date:
I affirm the following (please initial):
I have received a copy of the Organization’s Conflict of Interest Policy.
(initial)
I have read and understand the policy. (initial)
I agree to comply with the policy. (initial)
Member
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PURCHASING POLICY
Procurement Standards/Expenditure of Grant Funds -
Expenditures of grant funds shall be through the
purchasing, finance or payroll department processes in place of non‐grant funds, but shall have additional
requirements as noted below to ensure full compliance with federal cost principles.
General Procurement Standards -
CSUSA shall comply with all Education Department General Administrative
Regulations (EDGAR) federal regulations in the management of federal grant awards and state‐administered
grants. All purchases of equipment, materials and supplies will be made in accordance with all applicable laws
and regulations, including state guidance where applicable (e.g., Chapter 287, Florida Statutes), 2 CFR
Governing
§200.318(a), Board policy and any school purchasing procedures. All employees involved in
purchasing are expected to be familiar with these requirements.
The CSUSA Charter Fiscal Agent will ensure that written specifications for desired products are descriptive,
clear and incorporate the quality requirements and service needs of CSUSA schools. Unless otherwise
mandated by federal or state guidance, once proper procurement protocol is adhered to, CSUSA does not require
a minimum number of bids, proposals or quotes required for the selection of vendor from whom to purchase
Governing
apparatus, goods, supplies and equipment (whether formally or informally bid). However, the
Board encourages the School Operations Administrator (SOA) or Procurement Manager to obtain at least two
(2) bids, proposals or quotes when feasible.
Governing
Except as otherwise required by law or specified by the Board, the CSUSA Director of Procurement
is delegated the authority to award contracts for the purchase of equipment, material and supplies, involving
amounts up to $100,000. Any purchases or contracts involving expenditures greater than this amount must be
Governing
approved by the Board. The CSUSA Director of Procurement and any additional staff deemed
appropriate by the director will review submissions of bids, proposals or quotes to determine if they are
responsive to the CSUSA school specifications and will make recommendations to the director. The director
Governing
will award the contract based upon such recommendations or will make a recommendation to the
Board for award of the contract.
The Grant Coordinator must approve purchases over $3,000 prior to encumbrance. The SOA and or Federal
Grant Coordinator may authorize up to $3,000 without prior approval of the director as allowed per the school’s
budget (including local, state and federal approved budgets). The Grant Coordinator may approve small local
and state purchases up to $500 per the school’s budget.
Equipment, materials and supplies are purchased in accordance with the following requirements.
Formal Bids ($90,000 or more) -
The purchase of apparatus, supplies, materials or equipment for expenditures
of $90,000 or more must be secured through the competitive bid process governed by federal and state
guidance (e.g., Section 287.057, Florida Statutes). The Procurement Manager or State Director, in consultation
with the CSUSA Director of Procurement and City Manager is authorized to determine the best method for
formally bidding a product or, as appropriate, utilizing one of the exceptions to formal bidding as provided below
in section E. The Procurement Manager will oversee the use of any purchasing method and will ensure that all
state requirements are met, including advertisement, sealed bids, maintaining records and public opening of bids.
Governing
The Board authorizes the use of newspaper advertisement, electronic advertisement or both for
formal bids; however, the Procurement Manager has the authority to determine which method will be used for a
specific purchase or categories of purchases.
Awards will be made to the lowest responsible bidder(s) whose bid/proposal meets the requirements and criteria
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set forth by CSUSA schools, taking into consideration quality, performance and the time specified in the
proposal for the performance of the contract.
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To be eligible for an award of a contract subject to federal and state guidance, the contractor and its
subcontractors, if any, must demonstrate compliance with all applicable provisions of federal and state
guidance, including the responsibility to use E-Verify. All contracts awarded must be in writing.
Governing
The Board permits the use of the following processes for contracts that require formal bidding.
1. Competitive Sealed Bids – A competitive sealed bid (or invitation to bid) may be used to request the
cost of particular goods by providing detailed specifications in advance.
2. Reverse Auction - Pursuant to federal and state guidance, (1), CSUSA schools may use reverse auctions
as an alternative to sealed bid procedures. For purposes of this policy, reverse auction means a real-time
purchasing process in which bidders compete to provide goods at the lowest selling price in an open and
interactive environment. The Procurement Manager or State Director in consultation with the CSUSA
Director of Procurement, will determine whether reverse auctions are appropriate for a specific purchase
or category of purchases. To conduct a reverse auction, the Procurement Manager may use a third party,
may use the state’s electronic procurement system or, if appropriate equipment is available, may
conduct the auction via school equipment.
3. Exceptions to Formal Bids – Any of the processes outlined below in section E can be used in lieu of
formal bidding, if all requirements of state law are met.
Informal Bids ($5,000 to $90,000) -
The purchase of apparatus, supplies, materials or equipment for expenditures
of $5,000 to $90,000 must be secured through the informal bidding process governed by federal and state
guidance. The Procurement Manager, in consultation with the State Director and City Manager is authorized to
determine the best method for informally bidding a product. The Procurement Manager will oversee the use of
any purchasing method and will ensure that all state requirements are met, including maintaining records of all
bids submitted. Awards will be made to the lowest responsible bidder(s) whose bid or proposal meets the
requirements and criteria set forth by CSUSA schools, taking into consideration quality, performance and the time
specified in the proposal for the performance of the contract.
1. Competitive Sealed Bids – Informal bid requirements may be met using sealed bids. The purchasing
officer may utilize the methods for formal competitive bids provided in section A or may determine
other appropriate methods for soliciting sealed bids. The bid specifications will include the time, date
and place for opening bids. No advertisement for bids is necessary (unless the formal bid process is
used); however, the purchasing officer may advertise for bids as he/she deems appropriate.
2. Quotations – Informal bid requirements may be met by the solicitation of quotes from prospective
vendors. Quotations may be solicited and submitted via telephone, fax, email or website. Telephone
quotes must be placed in writing before a final contract will be awarded. Written quotations must be
on the vendor’s letterhead or an official quotation.
3. Reverse Auction – A reverse auction may be used to solicit informal bids, consistent with the process
provided in Formal Bids, Reverse Auction explained above.
4. Exceptions to Informal Bids – Any of the processes outlined below in section E can be used in lieu of
informal bidding, if all requirements of state law are met.
Purchases for less than $5,000
1.
Micro Purchases 2 CFR § 200.67 - Acquisition of supplies, the aggregate dollar amount of which does
not exceed $10,000 (or $2,000 in the case of acquisitions for construction subject to the Davis- Bacon
Act or $2,500 for acquisitions involving services). Micro-purchases may be awarded without soliciting
competitive quotations but must be distributed equitably among qualified suppliers. Equitability will
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be ensured through electronic bidding, maintenance and use of various catalogs and requests for good
or services via the school website, and solicitation to various vendors, especially small, minority
women-owned businesses and labor surplus area firms.
2.
Purchases for equipment, materials and supplies costing less than $5,000, but more than $3,000,
purchases will be made under conditions, which foster competition among potential vendors. Purchase
decisions should be made after considering price, quality, suitability for specified need and timeliness
of delivery and performance.
Records of all informal bids will be kept and will be available for public inspection. Such records will include
the date the bid is received, from whom it is received, and for what item.
Electronic Bidding:
Pursuant to federal and state guidance, CSUSA schools may receive bids electronically in
addition to or instead of paper bids. If electronic bids are used for purchases that must be formally bid, procedures
for receipt of electronic bids must be designed to ensure the security, authenticity and confidentiality of the bids
to at least the same extent as provided with paper bids. The Procurement Manager, in consultation with the State
Director and City Manager, will determine whether electronic bidding is appropriate for a specific purchase or
category of purchases.
Exceptions to the Formal and Informal Bidding Requirements:
CSUSA SCHOOLS may utilize the
following purchasing options instead of pursuing competitive bidding for non-federal purchases. Formal or
informal bidding is not required if any of these processes are used. The Procurement Manager is responsible for
gathering information to document the basis for the use of any exceptions to the competitive bidding
requirements. The Procurement Manager, in consultation with the State Director, will determine whether using
one of the following exceptions is appropriate for a specific purchase or group of purchases.
1. Purchases from Other Governmental Agencies – Pursuant to federal and state guidance, CSUSA
schools may contract for the purchase, lease or other acquisition of apparatus, supplies, materials, or
equipment from any other federal, state or local governmental agency.
2. Special Emergencies – Pursuant federal and state guidance, competitive bidding is not required in cases
of special emergencies involving the health and safety of people or their property. For an emergency to
exist under the statute, the following factors must exist: (1) the emergency must be present, immediate
and existing; (2) the harm cannot be averted through temporary measures; and (3) the emergency must
not be self-created by CSUSA schools.
3. Competitive Group Purchasing – Pursuant to federal and state guidance, CSUSA schools may make
purchases through a competitive bidding group purchasing program, through which another entity uses
a competitive process to establish contracts on behalf of multiple entities at discount prices.
4. State Term Contract – Pursuant to federal and state guidance, CSUSA schools may purchase products
included in state term contracts with the state vendor for the price stipulated in the state contract, if the
vendor is willing to extend CSUSA schools the same or more favorable prices, terms and conditions as
established in the state contract.
Governing
5. Sole Source Items – Pursuant to federal and state guidance, upon approval of the
Board, CSUSA schools may purchase an item through a single/sole source contract under the
following
circumstances: (1) when performance or price competition is not available; (2) when a needed product
is available from only one source of supply; or (3) when standardization or compatibility is the overriding
consideration. When requesting a purchase under the sole source exception, the State Director will
Governing
provide the Board with documentation that justifies the use of the exception.
6. “Piggybacking” or Previously Bid Contracts – Pursuant to federal and state guidance, upon approval of
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the Board of Education, CSUSA schools may purchase from any supplier that, within the previous 12
months, has contracted to furnish the needed item to the federal government, to any state government, or
to any agency or political subdivision of the federal government or any state government. Before
recommending a purchase using the piggybacking exception, the Procurement Manager will ensure that
the following requirements are met: (1) the price and other terms and conditions of the contract are at
least as favorable as the prior contract; (2) the contract was entered into following a bid process
substantially similar to that required by Florida Statutes; (3) the same vendor is used; and (4) notice of
intent to award the contract without bidding is publicly advertised at least 10 days prior to the regularly-
Governing
scheduled Board meeting at which the contract will be approved. Before approving the
Governing
contract, the Board must determine that using the contract is in the best interest of CSUSA
schools.
Purchases of Information Technology Goods and Services – Pursuant to federal and state guidance,
CSUSA schools may purchase or lease information technology through contracts established by the State
Office of Information Technology Services. The Procurement Manager will work with the information
technology department to ensure that any such purchases meet the needs of CSUSA schools In addition,
CSUSA schools also may purchase information technology goods and services by using a request for
proposal (RFP) Pursuant to federal and state guidance,, provided that the following requirements are met:
(1) notice of the request is provided consistent with the formal bidding notice requirements and (2)
contracts are awarded to the person or entity that submits the best overall proposal as determined by the
Procurement Manager. The RFP should describe the scope of work, general terms and conditions,
specifications of the product needed by CSUSA schools, and the application process. The information
technology supervisor will assist the purchasing officer in reviewing the responsiveness of any RFP
submitted pursuant to this subsection. RFPs will be evaluated using the “best value” method as defined
in federal and state guidance, so that the school can select the most appropriate technological solution to
meet CSUSA schools’ objectives. However, in situations where the purchasing officer considers the
purchase to be highly complex or is unable to clearly determine what the optimal solution for CSUSA
Schools is, the “solution-based solicitation” or “government- vendor partnership” method may be used.
The Procurement Manager may negotiate with the proposer to obtain a final contract that meets the best
needs of CSUSA Schools, as long as the alterations based on such negotiations do not deprive
proposers/potential proposers of the opportunity to compete for the contract and do not result in the award
of the contract to a different person or entity than it would have been if the alterations had been included
in the RFP.
7. Gasoline, Fuel and Oil Purchases – Pursuant to federal and state guidance, CSUSA schools may
purchase gasoline, fuel and oil products without using formal competitive bidding. However, such
purchases are subject to the informal bidding requirements described above.
8. Used Products – Pursuant to federal and state guidance, CSUSA schools may purchase previously used
apparatus, supplies, materials or equipment without using formal competitive bidding. Before
purchasing used products, the Procurement Manager will ensure that the products are in good, usable
condition and will be sufficient to meet CSUSA school’s needs for a reasonable period.
Historically Underutilized Businesses 2 CFR §200.321:
CSUSA schools affirms its commitment to encourage
the participation of historically underutilized businesses in purchasing functions, especially small, minority,
women-owned businesses and labor surplus area firms pursuant to federal grant requirements.
CSUSA schools will take the following affirmative steps to assure the use of historically underutilized businesses
when possible:
1. Placing qualified small and minority businesses and women's business enterprises on solicitation lists.
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2. Assuring that small and minority businesses, and women's business enterprises are solicited whenever
they are potential sources.
3. Dividing total requirements, when economically feasible, into smaller tasks or quantities to permit
maximum participation by small and minority businesses, and women's business enterprises.
4. Establishing delivery schedules, where the requirement permits, which encourage participation by
small and minority businesses, and women's business enterprises.
5. Using the services and assistance, as appropriate, of such organizations as the Small Business
Administration and the Minority Business Development Agency of the Department of Commerce.
Requiring the prime contractor, if subcontracts are to be allowed, to take the affirmative steps listed in 1 through 5.
Contract cost and price 2 CFR §200.323
: For procurement subject to federal funding,
CSUSA schools will perform a cost or price analysis in connection with every procurement action in excess of
the Simplified Acquisition Threshold ($250,000) including contract modifications. The method and degree of
analysis is dependent on the facts surrounding the procurement situation, but as a starting point, CSUSA schools
will make an independent estimate before receiving bids or proposals.
The cost analysis or price analysis, as appropriate for the situation, will be documented in the procurement files.
Accordingly, CSUSA schools performs a cost or price analysis in connection with every federal procurement
action in excess of $250,000 including contract modifications, as follows:
Cost Analysis Noncompetitive Contracts
: A cost analysis involves a review of proposed costs by expense
category, and the federal cost principles apply, which includes an analysis of whether the costs are allowable,
allocable, reasonable, and necessary to carry out the contracted services. In general:
A cost analysis must be used for all noncompetitive contracts, including sole source contracts.
The federal cost principles apply.
All noncompetitive contracts must also be awarded and paid on a cost-reimbursement basis, and not on a
fixed-price basis.
In a cost-reimbursement contract, the contractor is reimbursed for reasonable actual costs incurred to
carry out the contract.
Profit must be negotiated as a separate element of the price in all cases where there is no competition.
When performing a cost analysis, profit is negotiated as a separate element of the price. To establish a fair and
reasonable profit, consideration is given to the complexity of the work to be performed, the risk borne by the
contractor, the contractor’s investment, the amount of subcontracting, the quality of its record of past
performance, and industry profit rates in the surrounding geographical area for similar work.
Price Analysis Competitive Contracts
: A price analysis determines if the lump sum price is fair and
reasonable based on current market value for comparable products or services. In general:
A price analysis can only be used with competitive contracts and is usually used with fixed-price
contracts. It cannot be used with noncompetitive contracts.
Compliance with the federal cost principles is not required for fixed-price contracts, but total costs
must be reasonable in comparison to current market value for comparable products or services.
A competitive contract may be awarded on a fixed-price basis or on a cost-reimbursement basis. If awarded on
a cost-reimbursement basis, the federal cost principles apply and costs are approved by expense category, and
not a lump sum.
A cost analysis will be completed for any noncompetitive contract over $250,000. A price analysis will be used
for all competitive contracts over $250,000. The analysis will be conducted by the CSUSA Director of
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Procurement or the designated staff member for the contract. Analyses should include prior procurements and
other market research. The analysis should yield an acceptable price range prior to receiving bids/proposals.
Administrative oversight is provided by the Chief Financial Officer.
Costs or prices based on estimated costs for contracts are allowable only to the extent that costs incurred, or cost
estimates included in negotiated prices would be allowable costs under the federal cost principles.
Rebates and credits 2 CFR §200.406
- Applicable credits refer to those receipts or reduction-of expenditure type
transactions that offset or reduce expense items allocable to the Federal award as direct or indirect costs.
Examples of such transactions include: purchase discounts, rebates or allowances, recoveries or indemnities on
losses, insurance refunds or rebates, and adjustments of overpayments or erroneous charges. To the extent that
such credits accruing to or received by CSUSA schools relate to allowable costs, they must be credited to the
Federal award either as a cost reduction or cash refund, as appropriate.
Contractor Oversight 2 CFR §200.318(b) –
CSUSA Schools strive to ensure that contractors perform in
accordance with the terms, conditions, and specifications of their contracts or purchase orders and to ensure
proper administration of contracts as follows:
Contractors 2 CFR §200.330(b) -
A contract is for the purpose of obtaining goods and services for the use
CSUSA schools and creates a procurement relationship with the contractor. A procurement relationship between
CSUSA Schools and a contractor is established when the Contractor:
provides the goods and services within normal business operations;
provides similar goods or services to many different purchasers;
normally operates in a competitive environment;
provides goods or services that are ancillary to the operation of the Federal program; and
is not subject to compliance requirements of the Federal program as a result of the agreement,
though similar requirements may apply for other reasons.
All the characteristics listed above may not be present in all cases, and therefore best judgment must be used in
classifying each agreement as a sub award or a procurement contract.
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INTERNAL CONTROLS
Internal Controls -
The CSUSA internal control procedures over financial management shall be made available
to all staff involved in the management of federal grant funds. The internal control procedures shall be included as
part of the annual audit, reviewed on at least an annual basis, and updated as appropriate. If any weakness in an
internal control is detected, the internal control procedures shall be revised to incorporate the weakness (es) at
either the annual review or as the need arises dependent upon the severity (materiality) of the weakness.
Adequate internal control is a key defense (but no guarantee) against fraud, waste and program abuse. All
CSUSA staff have a responsibility to reduce the risk of fraud, waste and program abuse by implementing
effective internal controls that adequately safeguards assets. In the event of conflict between these standards
and federal statute or regulation, the federal statute or regulation will apply. Individuals who suspect fraud,
waste, or program abuse may report the matter to the State Director.
In accordance with the Grants Management Common Rule codified by the U.S. Department of Education (DOE)
§
at 34 CFR 80, CSUSA must maintain effective internal control and accountability for all grant and sub grant
cash, real and personal property, and other assets. CSUSA staff must adequately safeguard all such property and
must assure that it is used solely for authorized purposes.
The Office of Management and Budget (OMB) Circular A-133 Compliance Supplement is a useful tool in
defining what constitutes “effective internal controls” in that it provides guidance for understanding and
evaluating internal control. The guidance in Part 6 of the OMB Circular A-133 Compliance Supplement reflects
the definition and description of internal control as published by the Committee of Sponsoring Organizations
(COSO) of the Treadway Commission in its report, “Internal Control-Integrated Framework” (COSO Report).
Components of Internal Control -
Internal controls shall be designed, implemented and evaluated based on
the ability of the controls to provide reasonable assurance for compliance with applicable requirements in a
cost-effective manner.
The OMB Circular A-133 Compliance Supplement ( the “Compliance Supplement”) provides assistance in
complying with internal control and audit requirements by identifying types of compliance requirements and
describing for each, the objective of internal control and certain characteristics of internal control that, when
present and operating effectively, may ensure compliance with program requirements. The guidance, however, is
not intended as a “checklist of required internal controls characteristics.” Judgment will need to be exercised in
determining the most appropriate and cost-effective internal control in a given environment or circumstance to
provide reasonable assurance for compliance with program requirements.
The types of compliance requirements are primarily described in Parts 3 and 6 of the Compliance Supplement.
Part 3 provides fourteen types of compliance requirements that it identifies as being generic to most federal
programs that are administered by entities subject to the audit requirements of OMB Circular A-133. Part 6
describes internal control characteristics for thirteen of these fourteen types of compliance requirements (all
except those pertaining to special tests and provisions). The five components of internal control are:
Control Environment. The control environment “sets the tone of an organization and influences the
control consciousness of its people.” It provides structure and discipline and forms the foundation for
all other components of internal control.
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Risk Assessment. Risk assessment refers to the “identification, analysis, and management of risks
relevant to the preparation of financial statements that are fairly presented in conformity with generally
accepted accounting principles \[GAAP\] (or another comprehensive basis of accounting).”
Control Activities. Control activities are the policies and procedures that help ensure that
management’s directives are carried out.
Information and Communication. The identification capture and exchange of information in a form and
timeframe that enables people to carry out their responsibilities.
Monitoring. In relation to the Committee Sponsoring Organizations of the Treadway Commission
(COSO) report and Statements on Auditing Standards (SAS) 78, monitoring refers to the process used to
assess the quality of internal control performance over time.
Fraud, Waste or Abuse -
Fraud, program abuse, including waste, possible illegal expenditures, unlawful
activity, violations of law, rules, or policies and procedures occurring under any grant are prohibited. Suspicion
of such misuse must be reported to the State Director or designee no later than five business days from the date
of discovery of such act.
Following internal investigation, CSUSA may elevate any report to the appropriate federal or state authority for
action including, but not limited to:
Further investigation
Referral for prosecution under the federal or state laws
Other corrective action, as may be appropriate
CSUSA shall ensure the confidentiality of all reports of violations as listed above except as provided by law or
court order. No retaliation shall be taken against any person filing a report.
Payment -
Payments to vendors shall be made promptly in accordance with federal regulations and state law.
If the LEA receives an advance payment from a federal granting agency, the Grant Coordinator shall ensure that
the advanced funds are expensed in a timely manner. Excess funds may earn interest, which may require return
to the federal granting agency if the interest meets the federal threshold.
The LEA or schools shall always seek reimbursement for federal grants. The Grant Coordinator shall coordinate
with the LEA or schools to prepare and submit a “drawdown” of federal grant funds only after the payments
have been made and distributed to the vendor via mail, e‐payables or other delivery method. The drawdown of
expended funds shall be net of all rebates, refunds, contract settlements, audit recoveries and interest earned, as
appropriate. The Grant Coordinator working with the SOAs shall be responsible for preparing the drawdown of
federal grant funds. All drawdowns shall be reflected on the grant financial management ledger and recorded
on the general ledger as a receivable when the drawdown process is complete, and funds are received. Upon
receipt the funds will be posted to the cash account.
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Cost sharing or matching funds -
The Grant Coordinator over each federal grant award shall ensure that
requirements for cost sharing and/or matching funds are approved through the grant approval process prior to
the submission of the grant. At a minimum, the Grant Coordinator, Director of Finance, and /State Director (or
designee) must approve the commitment of all cost sharing and matching grant funds.
If cost sharing or matching funds are required as part of a federal grant award, the required direct or in-kind
expenditures should be recorded and tracked on the grant financial management ledger. If matching grant funds
are required in the General or Operational Fund, the LEA or school shall utilize a sub‐object to separately track
the expenditures for reporting and compliance purposes.
All staff paid with cost sharing and matching funds, shall be subject to the Time and Effort Documentation
requirements.
Cost sharing and matching funds that are as a result of donated services or supplies, shall be recorded and tracked
in accordance with the federal regulations (2 CFR §200.306).
Program Income
- The LEA or school will not generate any program income as part of a federal grant award.
The LEA or school will not retain any program income earned through a federal grant program.
Period of performance (Obligations) -
All allowable grant expenditures shall be incurred during the grant
period of performance (i.e. formal approval or begin date and end date/last date of expenditures) of the federal
grant award as designated on the Notice of Grant Award (NOGA) issued by the state or district. The Grant
Coordinator shall notify the State Director, School Principals, SOAs and the Directors of Finance and
Accounting of the grant periods for each federal grant award to ensure compliance as noted below:
No employee shall be hired and paid from federal grant funds except during the federal grant period.
No purchase obligation shall be made from federal grant funds except during the federal grant period.
No payroll or non‐payroll expenditures shall be made from federal grant funds except during the
federal grant period.
All obligations with federal grant funds must occur during the grant period of performance. Obligations that
occur before or after the grant period of performance are not allowable costs. The obligations must be
liquidated in accordance with the grant deadlines, especially as they relate to the final drawdown of federal
grant funds.
The Grant Coordinator shall monitor the expenditures during the grant period of performance to ensure that the
funds are spent in a systematic and timely manner to accomplish the grant purpose and activities.
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ACCOUNTING, REPORTING, AND INVENTORY CONTROL
Financial Management:
The grant financial management ledger will be used track budgets, commitments,
obligations and expenses for all federal, state, local and private sector grant expenditures. The grant financial
management ledger shall be maintained in a manner that provides adequate internal controls over the data
integrity, security and accuracy of the financial information.
The information maintained shall include all grant allotments, periods of performance, grant type, LEA or school
name and location, authorizations, obligations, unobligated balances, assets, expenditures, income and interest
and be supported by source documentation. All expenditures of federal grant funds shall be in managed in
accordance with CSUSA’s written procedures such as cash management, accounts payable, purchasing, travel,
allowable costs, capital asset tracking, contract management, and other procedures, as appropriate.
The financial management system shall be utilized to store, maintain, and report all required federal grant
information. Consequently, the Grant Coordinator shall ensure that access to the data is restricted to authorized
individuals in accordance with the grant focused data and access requirements specified in this manual. In
addition, the Grant Coordinator shall retain all federal grant records in accordance with the records retention
requirements also set forth in this manual. The Grant Coordinator shall be responsible to ensure that all grant
records are retained, stored and accessible, as appropriate.
A list of all federal grant awards shall be maintained to include all EDGAR required data and LEA or school‐
required information listed below:
The Catalog of Federal Domestic Assistance (CFDA) title and number
Federal award identification number and year
Name of the Federal or state agency issuing the grant
Name of the pass-through entity issuing the grant, if applicable
On at least a quarterly basis, the State Director, School Principal, SOA and Grant Coordinator shall review the
status of each federal, state or private sector grant fund. The review shall include a comparison of budget to
expenditures.
Grant Tracking and Financial Reporting -
Grant expenditures will be separately identified from operating
fund expenditures through the use of designated general ledger subaccounts. Each subaccount represents a
separate, segregated fund for the recording of all applicable revenues and expenditures for each fund.
Drawdown of Grant Funds:
The Grant Coordinator working closely with the SOAs shall on at least a quarterly
basis, or as allowed or required by the State or District guidelines, drawdown grant funds that have been expensed
in accordance with the State or District grant guidelines. The drawdown shall be for all expenditures to date, less
grant funds received to date, as verified using a grant financial management ledger. The expenditures shall be net
of all refunds, rebates, discounts, credits, and other adjustments, if any. If the LEA has opted to operate under the
cash reimbursement program guidelines, the LEA shall submit a drawdown of federal grant funds only when an
expenditure has been made as evidenced by distribution of a paycheck to a grant funded staff member or mailing,
e‐paying, or delivering a payment to a vendor. At no time shall the Grant Coordinator or SOA drawdown any
“advanced” cash payments, unless specifically allowed by the granting agency. The drawdown of grant funds
from the granting agency shall be initiated by the Grant Coordinator or SOA. A detailed summary grant financial
management ledger of each grant fund should be generated to determine if the LEA is entitled to drawdown funds
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(i.e. if the granting agency owes the LEA any funds). If the LEA has funds available for draw‐down, a detailed
general grant financial management ledger should be generated initiated by the SOA and validated by the Grant
Coordinator for review and approval. If a grant has a matching requirement, the LEA shall draw‐down only the
allowable amount after verifying compliance with the level of matching expenditures. The Grant Coordinator
review shall consist of the following:
A review of the detailed grant financial management ledger for any unusual charges or reclassification
of expenditures.
A test sampling of either unusual or large expenditures to ensure that the expenditures are allowable
and were reviewed and approved by all designated staff within the approved grant period of
performance.
Monitor the percentage of expenditures‐or utilization rate to‐date to ensure that the grant funds are
expensed on a timely basis throughout the grant period. The Grant Coordinator may disallow grant
fund expenditures that appear to be made outside of the grant period of performance or so late in the
grant period that the LEA and its student did not benefit from the delayed expenditure.
Authorize, in writing, the SOA to drawdown the available grant funds. Upon approval from the Grants
Coordinator and the SOA shall prepare the paper or electronic drawdown request. The amount of the
receivable shall be recorded on the grant financial management ledger and a copy of all supporting
documentation such as the detailed grant financial management ledger and other supporting
documentation shall be filed for audit purposes. The Directors of Finance and Accounting shall review
the drawdown documentation and the grant financial management ledger and shall compare the
documentation to the receipts from the State/District. Following this review, the Directors of Finance
and Accounting will post the grant receipts to the general ledger.
The Grant Coordinator and SOAs shall be responsible to ensure that the requested drawdown amounts do not
exceed a grant‐specific budgeted line item. The final draw‐down of grant funds from the granting agency shall
be made within the allowable or specified timeframe. The grant liquidation guidelines shall be adhered to in
making final payment for all goods and services received and placed into service before the end of the grant
period. The draw down process shall be the same as a monthly or periodic draw down, except that all refunds,
rebates, credits, discounts or other adjustments to the grant financial management ledger must be recorded prior
to submitting the final draw down request. There shall be no outstanding purchase orders or pending liquidations
at the time of the final drawdown of grant funds. The final draw‐down shall be reviewed and approved in the
same manner as a periodic drawdown.
Federal regulations (2 CFR §200.415) requires that the LEA certify the accuracy of the annual and fiscal
reports or vouchers requesting payments be signed by the authorized individual(s). The Grant Coordinator,
School Principal, and State Director shall jointly certify every draw‐down of funds, including the final
expenditure report. If a manual entry is required, the following statement will be added following signatures:
“By signing this report, we certify to the best of our knowledge and belief that the reports are true,
complete and accurate, and the expenditures, disbursements and cash receipts are for the purposes and
objectives set forth in the terms and conditions of the federal award. We are aware that any false, fictitious, or
fraudulent information or omission of any material fact, may subject us to criminal, civil, or administrative
penalties for fraud, false statements or false claims.”
If a final draw‐down deadline is missed, the Grant Coordinator shall contact the granting agency to determine if
a process exists to request a filing deadline extension. The receivable from the granting agency shall be recorded
in the accounting general ledger. The same process for preparation and posting of the general ledger entry as a
periodic drawdown shall be adhered to. The revenues realized and the expenditures should be equal at the time
of the final drawdown of grant funds.
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Receipt of Grant Funds
- All CSUSA staff, especially those assigned with federal grant duties, shall adhere to
the Cash Management Procedures. Specifically, all cash received shall be deposited, recorded reconciled by
multiple individuals to ensure segregation of duties. The Director of Accounting and Finance shall record all
grant fund receivables upon receipt from the granting agency. The receipt of grant funds shall be posted to the
general ledger to the appropriate receivable account code. In the event that the grant funds received do not match
the recorded receivable, the Director of Finance shall coordinate with the Grant Coordinator who in turn shall
resolve the discrepancy or contact the granting agency to determine the discrepancy. If the granting agency has
reduced and/or increased the grant funds paid to the LEA, a general ledger adjustment shall be posted to the
appropriate revenue and receivable accounts. The Director of Accounting and Finance shall prepare the
adjusting journal ledger entry and shall post the entry to the finance general ledger. The LEA will not maintain
grant funds in a separate bank account.
Tracking and Recording Receivables
- On at least a monthly basis, the finance department, Accounting
Coordinator, shall review all pending receivables. Aged receivables, defined as greater than 60 days from the
date of recording, shall be investigated and resolved by contacting the Grants Coordinator who in-turn will
contact the granting agency. At the end of the fiscal year, all known and measurable receivables shall be recorded
to the general ledger to the appropriate grant code. The Director of Accounting shall prepare the journal ledger
entry and shall post the entry to the general ledger.
Grant Compliance Areas:
The Grant Coordinator shall ensure that LEAs and schools are compliant with all
provisions and assurances of all grant programs. In addition, the all shall comply with grant requirements such
as supplement not supplant, indirect cost, and maintenance of effort spending levels.
Supplement Not Supplant -
The term supplement, not supplant is a provision common to many federal statutes
authorizing education grant programs. There is no single supplement, not supplant provision. Rather, the
wording of the provision varies depending on the statute that contains it. Although the definition may change
from statute to statute, supplement not supplant provisions basically require that grantees use state or local funds
for all services required by state law, state DOE rules, or local policies and prohibit those funds from being
diverted for other purposes when federal funds are available. Federal funds must supplement—add to, enhance,
expand, increase, extend—the programs and services offered with state and local funds. Federal funds are not
permitted to be used to supplant—take the place of, replace—the state and local funds used to offer those
programs and services. The LEA process to ensure that all grant-funded activities are supplemental shall be a
collaborative effort between the Grants Coordinator, State Director, School Principal, SOA and other
appropriate departments. All person shall be aware of the supplement not supplant provisions.
The Grants Coordinator shall review and approve all purchase orders (and non‐purchase order payments). The
Grant Coordinator review shall include a determination if the planned purchase and/or expenditure meet one of
the following guidelines:
The grant funds will be used to enhance, expand, or extend required activities. Examples may include
before/after tutoring, additional research‐based instructional programs, or other supplemental
expenditures not required by state law or local policy.
The grant funds will be used for specific grant activities included the grant application that are above
and beyond the activities funded with local funds.
The grant funds will be used to supplemental grant activities as noted on the school-wide plan, school
strategic plan or school improvement plan.
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Program specific supplement not supplant provisions shall be complied with in addition to the overall federal
fund’s requirements.
Reporting Requirements -
The Grant Coordinator shall ensure that all reporting requirements for grant
programs are met within the established timelines. Completion of the reports may require the collaboration of
several departments, such as noted below:
Programmatic reports such as activity, progress and evaluations – Grants Coordinator, School
Principal, SOA
Expenditure reports such as interim, draw down and final expenditure reports – Grants Coordinator,
School Principal, SOA, Accounting and Finance departments, and Accounts Payable Department
Compliance reports such as Comparability, Maintenance of Effort, Indirect Cost, etc. – Grants
Coordinator, School Principal, SOA, Accounting and Finance departments
Special Staff reports – Grants Coordinator, School Principal, SOA
The Grant Coordinator shall ensure that all reporting requirements have been completed by the appropriate LEA,
school, or CSUSA staff member.
Grant Monitoring and Accountability -
The LEA shall ensure that all grant funds are consistently monitored
throughout the grant period. The monitoring shall include, but not be limited to:
Compliance with federal requirements such as cost principles, audit, reporting requirements, etc.
Monitoring of grant expenditures are properly documented and meet all allowable costs
Monitor grant performance such as internal controls, audit findings, over/under expenditures, etc.
Implement strategies to deter, mitigate and eliminate waste and fraud in the expenditure of grant funds
The Grant Coordinators for each federal, state and local grant, working with the State Directors, school
Principals and the Accounting and Finance Departments, shall be responsible for the programmatic and
evaluation and financial compliance.
The Grant Coordinators shall monitor the timing of grant activities throughout the grant period, especially as they
relate to the desired outcomes. The Grant Coordinators, school Principals, SOAs collectively shall monitor the
timing of grant expenditures, especially as they relate to the period of availability of grant funds. If either the
grant activities or grant expenditures reflect that the LEA or school will not accomplish the grant activities during
the grant period, the Grant Coordinators shall work collaboratively with the appropriate activities to develop an
action plan to ensure that the federal grant goals are met. The oversight of grant activities and expenditures shall
include, but not be limited to, the following:
Cost overruns or high unit costs
Construction projects – certification of project completeness (as evidenced and approved by the
oversight activity)
Significant developments that may result in an inability to complete the grant activities
The Grant Coordinator with the LEA shall maintain documentation to support all grant expenditures and provide
the documentation upon request to the LEA’s external auditors, granting agency or other oversight agency, as
appropriate.
Audit findings or deficiencies shall be addressed in a timely manner upon receipt of the notification. The Grant
Coordinator, State Director, School Principal shall work collaboratively to develop and implement a Corrective
Action Plan to resolve the findings or deficiencies. The State Director, or designee shall approve the Corrective
Action Plan and monitor the timely implementation of corrective strategies.
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The Grant Coordinator in coordination with the LEA shall disclose to the granting agency if any federal grant
funds have been subject to fraud or theft. Corrective actions, as appropriate, shall be implemented to remedy the
loss of grant funds due to fraud or theft.
Remedies for Non‐Compliance -
CSUSA, specific LEA and schools may be subject to consequences due to
non‐compliance with federal regulations. All Grant Coordinators, LEAs and schools shall strive to maintain
compliance, but shall respond appropriately to all notifications of noncompliance from the federal or state
granting agency or pass through agency. CSUSA shall notify the City Manager of all notifications of
noncompliance.
Grant Closeout Procedures -
The Grant Coordinators shall submit all grant closeout documents to the State
DOE, granting agency or pass‐through agency, as appropriate. Grant closeout procedures shall include, but
not be limited to:
Ensure that no obligations are made after the grant period end date
Liquidate all obligations incurred during the grant period
Submit the final grant program performance report as required
Submit the final grant expenditure report as required
Drawdown all the expensed grant funds
Match the grant expenditure draw‐downs with the supporting financial records
Certify that the final drawdown of federal grant funds is accurate
Refund any excess grant funds, interest, or other payables to the granting agency or pass-through
agency
Account for any real and/or personal property on hand at the end of the grant period
§
Grant Funded Equipment Property Records 2 CFR 200.313(d)(1) -
CSUSA Schools will maintain property
records for all grant funded and operational funded equipment and computing devices/ technological items that
:
include
• Description of the property
• Serial number or other identification number
• Source of funding for the property (grant type)
• Grant tag number
• Title Holder of Equipment
• Acquisition date
• Cost of the property
• Percentage of Federal participation in the project costs for the Federal award under which the property
was acquired
• Equipment of location
• Use of the property
• Condition of the property
• Disposition data including the date of disposal and sale price of the property.
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The SOA, the School Principal, the Information Technology (IT) Technician and the Grant
Coordinator will maintain a combined property record, which includes all information listed above.
The information, including entering property into the fixed asset inventory and making adjustment to
the inventory, is accomplished by the SOA, the School Principal, the IT Technician and the Grant
Coordinator. CSUSA will provide the City Manager a copy of the property records
When inventory is received, it is inspected by the SOA, the School Principal, the IT Technician and
the Grant Coordinator to determine whether the inventory is in good condition and that it matches the
purchase order, and the corresponding invoice. The equipment shall immediately be placed in a
secured area. Inventory of all equipment must be completed within two working days following the
receipt of the equipment. The SOA, the School Principal, the IT Technician and the Grant Coordinator
logs the inventory into the property management system. The inventory control sheet is kept with the
SOA, the School Principal, the IT Technician and the Grant Coordinator. CSUSA will provide a copy
of the inventory control sheet to the City Manager.
All inventoried equipment including computing devices and other highly desirable mobile devices such
as laptops, smart phones, and tablets are to be tagged and tracked. The SOA, the School Principal, the
IT Technician and the Grant Coordinator will be responsible for ensuring equipment is tagged.
Physical Inventory -
A physical inventory of the property is taken, and the results reconciled with the
2 CFR§200.313(d)(2)
property records at least once every two years. . The SOA, the School Principal,
the IT Technician and the Grant Coordinator assigns the physical inventory to teachers in the
classrooms where the equipment is located. The inventory will be performed at the end of every school
year and signed off by the State Director or designee when completed. The results of the inventory
will be reported to the SOA, the School Principal, the IT Technician and the Grant Coordinator.
The SOA, the School Principal, the IT Technician and the Grant Coordinator reconciles discrepancies
between the inventory and the property records by updating the property records as needed and
documenting any property that is damaged or missing for identification, repair or replacement as
needed. They will maintain documentation of the physical inventory and reconciliation and sign off
when the reconciliation is completed.
Safeguarding Property Equipment -
The SOA, the School Principal, the IT Technician and the Grant
Coordinator will set up and manage a control system to insure adequate safeguards to prevent loss,
2 CFR
damage, or theft of the property. Any loss, damage, or theft will be investigated.
§200.313(d)(3)
.
Property may be taken off campus by students or staff. The person taking the property off site must
coordinate with the School Principal and the SOA and sign and date a receipt statement upon departure
and return. If student or staff takes property off campus and the item is lost or stolen while in their
possession, said student or staff shall be responsible to repair or replace the lost or stolen item. The
computing devises are tagged with the appropriate CSUSA identification and grant tag. Equipment that
is lost or stolen is reported to the SOA, the School Principal, the IT Technician and the Grant
Coordinator. They are then required to report it to the SOA, the School Principal, the IT Technician
and the Grant Coordinator, where they or their designee will complete an investigation on the lost or
stolen property. Interviews will be conducted, and/or a police report will be filed under the discretion
of the State Director or City Manager and coordinated with the School Principal, and the Grant
Coordinator, as part of the investigation process. A report regarding lost or stolen property will
be completed by the person doing the investigation. The report will be filed with the property
inventory records as well as with the grant records. In addition to possible criminal action the State
Director or designee will determine what, if any, additional action is necessary. Replacement of
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equipment will be obtained through the normal procurement functions, meet or exceed equipment
specifications of the lost/stolen items. Replacement costs will be incurred through non-grant school
funding.
Disposition of property will be listed by the SOA, the School Principal, the IT Technician and the
Grant Coordinator in the property records in the event the property is sold, lost or stolen, or cannot be
repaired.
Property that is sold, identified as lost or stolen, or cannot be repaired will be listed in the property
records for three (3) years after the lost/stolen date.
Maintaining Property Equipment -
Staff to whom property equipment is assigned will monitor and
maintain these items in good condition while in their possession.
The SOA, the School Principal, the IT Technician and the Grant Coordinator should be contacted if an
item is broken or not working properly. Equipment in need of repair is assessed by the SOA, the
School Principal, the IT Technician and the Grant Coordinator to determine whether to repair or
salvage. As part of this process the SOA, the School Principal, the IT Technician and the Grant
Coordinator will determine if a warranty will apply to the repair, if not, they will obtain repair cost
estimates. Generally, if the cost of repair exceeds half the cost of the restored value, then the equipment
may be salvaged or donated. Other factors such as availability of the damaged item can be considered
when determining whether a repair is appropriate.
Disposition of Grant Funded Equipment – 2 CFR §200.313(e)
- When original or replacement
equipment acquired under a Federal award is no longer needed for the original project or program or
for other activities currently or previously supported by a Federal awarding agency, except as
otherwise provided in Federal statutes, regulations, or Federal awarding agency disposition
instructions, CSUSA Schools will dispose of the equipment as follows:
• Items of equipment with a current per unit fair market value of $5,000 or less may be
retained, sold or otherwise disposed of with no further obligation to the Federal awarding
2 CFR §200.313(e)(1)
agency. .
• Items of equipment with a current per-unit fair-market value in excess of $5,000 may be
2 CFR §200.313(e)(2).
retained by CSUSA Schools or sold.
• The Federal awarding agency is entitled to an amount calculated by multiplying the current
market value or proceeds from sale by the Federal awarding agency's percentage of participation
in the cost of the original purchase.
• If the equipment is sold, the Federal awarding agency may permit CSUSA Schools to deduct
and retain from the Federal share $500 or 10 percent of the proceeds, whichever is less, for its
selling and handling expenses.
The SOA, the School Principal, the IT Technician and the Grant Coordinator with approval from the
State Director or City Manager are responsible for determining how equipment will be disposed of.
Any equipment owned exclusively by the City will be disposed pursuant
to City’s surplus property rules. Possible sales procedures include on-site and
govdeals.com auction. Auctions will be advertised online or in the local newspaper to ensure the
highest level of exposure. If not being sold by auction the sale of the item will also be advertised online
or in the local newspaper to ensure the highest level of exposure and there is no limit to the number
of purchase offers that will be considered. The highest offer received in a reasonable amount of time
will be accepted. All sales procedures will be performed in a manner to ensure the highest possible
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return. 2 CFR §200.313(d)(5).
CSUSA Schools will determine if the various state departments of instruction or education have
specific equipment disposition forms required. If so, our schools will utilize these forms and ensure
that are completed by the SOA, the School Principal, the IT Technician and the Grant Coordinator and
kept on file with the SOA.
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ENROLLMENT AND ADMISSIONS POLICY
DSAHS will admit students of any race, color, nationality and ethnic origin, religion, sexual orientation,
or gender. Pursuant to § 1002.33(10)(b), Fla. Stat., DSAHS will enroll an eligible student who submits
a timely application unless the number of applications exceed the capacity of a program, class, grade
level, or building. In such cases, all applicants who submit an application by the enrollment deadline will
have an equal chance of being admitted through a random selection process. In addition, all applicants
will need to submit the required documentation listed in the Student Progression Plan. Enrollment also
follows § 1002.33(7)(a)8, Fla. Stat., which includes enrolling students according to racial/ethnic balance
provisions. However, DSAHS will comply with the Controlled Open Enrollment statute (F.S.
1002.31(2)(a)), which allows a parent from any school district in the state whose child is not subject to
a current expulsion or suspension to enroll his or her child in and transport his or her child to the school,
as long as the school has not reached capacity.
In accordance with § 1002.33(10)(d), Fla. Stat., DSAHS may give enrollment preference to the following
populations:
Students who are the children of an active-duty member of any branch of the US Armed Forces.
Students who are siblings of a student enrolled in DSAHS. If siblings apply together and one
sibling receives an offer, the other sibling will also receive an offer as long as there is room in
their grade level. If there is no room in the sibling's grade level, they will be given preference on
the waiting list. Sibling is defined as individuals who share both guardianship and residency.
Students who reside in the City of Aventura.
Students who reside in Miami-Dade County.
Students who are the children of a CSUSA employee that is employed at DSAHS.
All preference categories are published prior to conducting the lottery, and applicants entitled to receive
a placement preference are identified prior to the lottery. Preferences granted are subject to review and
verification, and DSAHS reserves the right to rescind acceptance offers if the preference status is not
verified or validated. Siblings who are applying for the first time receive preference only after one of the
siblings has been selected in the lottery and accepts their offered seat.
Student applications are made available online through the enrollment management system (accessible
on DSAHS's website). The enrollment management system accepts student applications and monitors
the number of applications submitted for each grade level. The enrollment management system manages
all aspects of the enrollment process, including online applications, application verification, sibling
applicant record linking, admission preference management, manual and computerized lottery options,
waitlist management, data exports, and statistical reporting. Parents with limited technology or internet
access will be given the opportunity to use the resources available at DSAHS to submit an application.
If they cannot travel to DSAHS, they will have the option to call the school and allow a staff member to
assist them with completing an application.
Upon submission of an application, the applicant's age, sibling linking (if applicable), and preferences
are verified. At each phase of the admission process, the appropriate correspondence is generated and
communicated to each applicant either via email, phone, or mail if necessary. The data is monitored and
reports are created to determine the need for a lottery, waitlists, and letters of acceptance. If at the end of
the open enrollment period there is an over subscription for any grade level, a lottery is conducted. The
number of seats available is determined by the capacity minus the number of students who re-commit.
This is in compliance with § 1002.33(10)(b), Fla. Stat. The lottery is system generated and will be
conducted for all grades in which the number of applicants exceed the number of available seats.
26
Once all open seats have been randomly filled, the remaining applicants are placed on the waitlist in
order of the lottery results and in accordance with assigned preferences. All offers of enrollment are
made in the order of the lottery results and the established waitlist. Applicants selected through the lottery
will have seven (7) days after the offer of enrollment is made to accept the offer. Should an applicant not
accept the offer of enrollment within seven (7) days, the offer will be rescinded. Thereafter, an offer will
be made to the next eligible applicant. Offers are not made to a student who is not properly entitled to
the next available seat. Applicants who submit an application after the enrollment deadline are placed on
the waitlist in order of preference and submission date. If an accepted applicant decides not to attend
DSAHS, the slot is given to the first eligible applicant on the waiting list. All accepted applicants are
provided with registration requirements. Documentation required by Miami-Dade County Public
Schools will be collected for review and verification.
In the event that an applicant was not included in the lottery but should have been, an adjustment will be
made in placement on the waitlist or an offer of an enrollment. In the event an applicant was offered a
seat in the lottery and provided incorrect information that led to a selection, the applicant's offer is
rescinded and the applicant is placed on the waitlist according to the lottery pool number.
Application submissions are accepted on an ongoing basis and a confirmation of the submission is sent
to parents within 24 hours. Communication with prospective students is generated as appropriate. In
addition, DSAHS will conduct entrance interviews with students after enrollment and registration is
completed.
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CERTIFCATION OF GOVERNING BOARD RESOLUTION
The undersigned duly elected Mayor or Vice Mayor of City of Aventura certifies that the
Commission at a duly held meeting, which was held on the_date listed_below,at which a
quorum was present,approved the CSP(Charter Schools Programs) Grant Policies and
Procedures Manual.
I certify that this Resolution was duly adopted by the City of Aventura Commission as the
Governing Board of the School on the 21'day of November, 2019.
11/26/2019
Dated
44
Mayor or Vice Mayor
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