Tools & Curriculum
Return to Tools & Curriculum
New Directors' Orientation Tutorial
The New Directors' Orientation Tutorial is made up of 14 self-paced modules to assist in learning basic program requirements. Each module is designed to be utilized based on a Director’s specific needs; there is not a set sequence for the tutorial to be completed. We encourage Directors to jump to the module that best fits their needs. Select a module below to view or download the corresponding materials.
Modules
4. Migrant Education Program Subgrant Procedures
Module 4. Migrant Education Program Subgrant Procedures
All Module Materials
Overview
Supporting Materials
Section 1: Getting Started
Getting Started
In This Section
• Tutorial Objectives
• How to Use the Tutorial
• Icons to Guide You
• Key Readings and Resources
3
Tutorial Objectives
Module 4 will enable new state directors to
1. understand which entities are eligible for state migrant education
program (MEP) subgrants,
2. understand the responsibilities of state education agencies (SEAs)
for establishing subgrant procedures,
3. understand common approaches to determining subgrant amounts,
4. make subgrant determinations, and
5. refine your subgrant process with actionable milestones.
4
How to Use the Tutorial
For optimal benefit from the tutorial, you should
• allow sufficient time to read the slides, reflect on the information, and
complete all activities on the slides or on the Quick Resource and
Reflection Sheets (QRRS) that can be downloaded as worksheets;
• read each slide, as well as the information referenced in the slides;
• engage with the “What Do You Think?” slides to facilitate interaction
with the information (Answers will be provided directly following each
of these slides.);
5
How to Use the Tutorial
For optimal benefit from the tutorial, you should (continued)
• pause to reflect on your state program at the “Check-in” slides
(A QRRS document will typically accompany these.);
• complete the “Pop Quiz!” slides to reinforce key concepts;
• review your state’s MEP documents and reports as directed;
• develop an action plan using the worksheets provided;
• add actionable items to your MEP planning calendar (See QRRS
14.2.); and
• contact your OME Program Officer for follow-up questions.
6
Icons to Guide You
The following icons will guide you in making the best use of this tutorial:
What Do You Think?
Check-in
Pop Quiz!
Quick Reference and Reflection Sheet (QRRS)
Action Planning
Calendar Item
7
Key Readings and Resources
You should have these documents readily available while completing
the module, as the module will refer to these documents for more
complete information on various topics.
• MEP Guidance on Education of Migratory Children under Title I, Part C
of the Elementary and Secondary Education Act of 1965, Chapter XI –
State Administration
• Your state Consolidated State Application (CSA)
• Your state Comprehensive Needs Assessment (CNA)
• Your state Service Delivery Plan (SDP)
• Your state law and/or policies related to subgranting
8
Section 2: Migrant Education Subgrant Overview
Migrant Education
Subgrant Overview
In This Section
• Overview
• MEP Subgrant Eligibility
• Local Operating Agencies
• State Subgrant Requirements
• State Director Responsibilities
9
Overv iew
The MEP is designed to supplement the educational services that
districts provide to eligible migrant children. One way of doing this is by
subgranting MEP funds to districts or to other entities that can provide
direct services to migrant children.
Issues migrant children face that can affect their ability to do well in
school.
• Educational interruptions
• Low household income
• Cultural & language barriers
• Social & community isolation
• Health-related problems
10
Overv iew
SEAs may choose to deliver MEP services directly, or through a subgrant
process to eligible LOAs.
• A subgrant is an award of financial assistance, in the form of money,
made under a grant by a grantee (the SEA) to an eligible subgrantee
(the LOA).
Section 1302 of the ESEA, as amended
EDGAR - § 76.770 and 80.3
11
Overv iew
• Whether the SEA chooses to deliver MEP services directly or through
LOAs, the SEA remains responsible for the overall administration and
operation of the MEP in the state.
o The SEA must ensure that LOAs receiving subgrants comply with
all applicable statutory and regulatory requirements.
• The SEA has the sole authority for determining which LOAs receive
subgrant awards.
o No LOA is entitled to receive an MEP subgrant.
Section 1302 of the ESEA, as amended
EDGAR- § 76.770 and 80.3
12
Migrant Education Program Subgrant Eligibility
Eligible LOAs are defined as:
• Local education agencies (LEAs),
• Public or nonprofit private agencies, or
• The SEA, if the SEA operates the MEP directly.
Section 1309(1) of the ESEA, as amended
EDGAR § 77.1
13
What Do You Think?
• What are the advantages/disadvantages of having few/many
subgrantees in your state? Consider:
o The size of MEP staff at the SEA.
o How the migrant child population is distributed in your state.
14
What Do You Think? – Reflection
An SEA with a
large MEP staff
might choose to provide
mostly
direct services
and award fewer
subgrants
.
An SEA with a
small MEP staff
might choose to provide
services
mostly through LOAs
and award
several
subgrants.
If
large numbers of migrant
families reside in a few areas
of
the state, the SEA might choose
to
award fewer subgrants, but
at
larger amounts.
If
the distribution of migrant
families is throughout the state
,
the SEA might choose to award
subgrants
to regional entities, in
larger amounts
.
What are the advantages/disadvantages of having few/many
subgrants in your state?
15
Local Operating Agencies
• In some states the LEA operates as the LOA.
• In some cases, two or more LEAs or other entities may partner to form
an LOA to provide services to migrant children across multiple
districts.
• In some states, institutions of higher education and non-profit entities
may provide services and/or ID&R across multiple districts.
• In some states with small migrant child populations or with migrant
families that remain in the state for short periods (reducing the time
services are needed), the state may opt to provide services directly.
16
State Subgrant Requirements
States must have a plan on file with ED (contained within their
Consolidated State Applications) describing how:
• The SEA will determine the amount of any subgrants they will award to
LOAs, taking into consideration:
o The numbers of migrant children,
o The needs of migrant children,
o Priority for Services (PFS) migrant children, and
o The availability of funds from other federal, state, and local
programs.
Section 1304(b)(5) of the ESEA, as amended
17
State Director Responsibilities
The state MEP director is responsible for ensuring that the SEA has:
• Established procedures to determine which, if any, entities are eligible
to receive a subgrant; and
• Taken steps to ensure that LOAs comply with all applicable statutory
and regulatory requirements.
18
State Director Responsibilities
When deciding which LOAs will deliver services to migrant children most
efficiently and effectively, the state director will need to consider:
• CNA results;
• Types of services necessary to address the needs of migrant children,
including the needs of PFS children; and
• The capacity of the LOA to provide services.
19
State Director Responsibilities
• The state director should be familiar with common MEP subgrant
approaches and the state’s policies regarding subgrants.
o States may have specific requirements related to the process by
which funds are awarded; therefore, it is important to ensure that
the SEA administration and budget officers understand the intent
of, and legislative requirements for, MEP subgranting.
20
Check-in
What policies are in place in your state for the MEP subgrant process?
See QRRS 4.1 – State MEP Subgrant Process
21
Section 3: Factors for Determining Subgrant Amounts
Factors for
Determining
Subgrant
Amounts
In This Section
• Factors for Determining Subgrant Amounts
• Factor 1: Number of Migrant Children
• Factor 2: Needs of Migrant Children
• Factor 3: Priority for Services Requirement
• Factor 4: Availability of Funds from Other
Programs
• Other Factors
• Types of Programs Subgranted to Local
Operating Agencies
22
Factors for Determining Subgrant Amounts
There are four factors that the SEA must consider when determining the
amount of a subgrant:
1. Numbers of migrant children;
2. Needs of migrant children;
3. Statutory priority to serve children who are failing, or most at risk of
failing, to meet the state’s challenging academic content standards,
and whose education has been interrupted during the regular school
year; and
4. Availability of funds from federal, state, and local programs.
23
Factor 1: Number of Migrant Children
SEAs must consider the number of migrant children in the area to be
served when determining amounts for subgrants, but have
considerable latitude in deciding how to include this factor in the
subgrant process. SEAs may consider the number of migrant children
who:
• Reside, or are expected to reside, in the project area and/or
• Are served by, or are expected to be served by, the project.
24
Factor 1: Number of Migrant Children
For example, the SEA might implement a weighted scale based on:
1. The number of eligible migrant children who reside, or are expected
to reside, in the project area;
2. The number of students who are served by, or will be served by a
project;
3. The number of students who are/will be served relative to the total
number of eligible migrant children who reside, or are expected to
reside, in the project area;
4. A combination of 1-3; or
5. Other ways of considering the number of migrant children in the
project area.
25
Factor 2: Needs of Migrant Children
Consistent with the CNA process, the SEA will identify the needs of
migrant children and develop an SDP to address those needs. The SEA
is required to consider these needs in determining the amount of
subgrants. However, the SEA:
• Is not required to take into account all of the identified needs of
migrant children in its subgrant process, and
• May choose to fund a project that proposes to address additional
needs of migrant children (needs that were not identified in the
statewide CNA, but which were identified in a particular project area)—
if services are not available from another funding source.
26
Factor 2: Needs of Migrant Children
In addition to understanding the needs identified in the statewide CNA
and the strategies for delivering services as outlined in the SDP, the SEA
will benefit from having a clear understanding of the effectiveness of
the programs (impact on migrant children’s educational outcomes). This
will help SEAs prioritize and consider ongoing needs when determining
future subgrant amounts.
27
Factor 3: Priority for Services (PFS)
The SEA must consider the PFS requirement when determining the
amount of a subgrant. Students who are eligible for PFS are those
migrant children who are:
• Failing, or most at risk of failing, to meet the state's challenging state
academic content standards and challenging state student academic
achievement standards and
• Whose education has been interrupted during the regular school year.
Section 1304(d) of the ESEA, as amended
28
Factor 4: Availability of Funds from
Other Programs
In determining the amount of a subgrant, the SEA must consider the
availability of other funds that an LOA may leverage to provide services
to migrant children. The SEA may:
• Examine the funding levels of programs that the LOA implements and
that are available to migrant children, or
• Evaluate the availability of other federal, state, or local funds by
collecting data on per-pupil expenditures.
29
Check In
There are four requirements that the SEA must consider when
determining the amount of subgrants. How is your state factoring in the
four requirements to determine subgrants in your state?
See QRRS 4.2 – Addressing the Four Required Factors
30
Additional Factors
In addition to the four required factors, the SEA may also consider
additional factors when determining amounts for subgrants, such as:
• Nature, scope, and cost of the projects to be implemented and
• State CNA and SDP priorities.
31
What Do You Think?
What are some of the factors, other than the four required factors, you
might include when considering subgrant amount determinations?
32
What Do You Think? – Reflection
In addition to the four factors required for making subgrant amount
determinations, consider the nature and scope of the project, migratory
patterns, and how MEP funds can be maximized.
• Nature and scope of the projects to be funded
o How many migrant students will be served during the regular
school year and/or summer session?
o How many staff members will be required to implement the
project, and how much professional development will staff need?
o What local resources will be leveraged to provide services to
migrant children in the project area?
33
What Do You Think? – Reflection
• Migratory patterns
o Are migrant families frequently moving in and out of the state or
within the state?
o What districts or regions are migrant families moving to/from and
when?
• Project costs
o Are costs associated with operating the project necessary,
reasonable, and allocable?
o What percentage of the project funds are dedicated to
administrative functions and overhead that are not really needed
versus providing services to migrant children?
34
Types of Programs Subgranted to Local
Operating Agencies
Examples of the type of programs that might be subgranted to LOAs to
address the needs of migrant children in the areas the LOAs serve
include:
• Academic programs to meet state academic standards,
• Health programs,
• Preschool programs,
• Parental involvement,
• Summer school programs,
• Supplemental services for secondary education (e.g., secondary credit
accrual, dropout prevention, alternative education programs), and
• Information dissemination activities (e.g., assist migrant families in
understanding services and resources available).
35
Section 4: Approaches to Subgrants
Approaches to
Subgrants
In This Section
• Determining Amounts Available for
Migrant Education Program Subgrants
• Subgrant Funding Approaches
o Formula Approach
o Proposal and Negotiation Approach
o Combination Approach
36
Determining Fund Amounts Available for
Migrant Education Program Subgrants
When determining the amount of funds available for subgrants, the SEA
should consider
• Current FY MEP grant award (+),
• Set aside for general state administration (up to 1%) (-),
• Carryover funds from previous grant award (+), and
• Unique SEA program function costs (-).
July 1, 2014
Amount
State MEP Allocation for 2015
+ $6,500,000
State
MEP General Administration set-aside –
$65,000
Carryover
Funds from FY 2014
+ $150,000
Unique MEP Program Functions
– $
195,000
Total amount
remaining for delivery of services – either by SEA and/or
by LOAs through subgrant process
$6,390,000
37
Subgrants – Funding Approaches
As previously discussed, the SEA has flexibility in how the four required
factors will influence the subgrant process. Similarly, the SEA has
flexibility in identifying how funding amounts will be determined. The
most common approaches are:
• Formula,
• Proposal and negotiation,
• A combination of formula/proposal and negotiation, or
• Another reasonable alternative process.
38
Formula Approach
In the formula approach, the SEA determines the amount of MEP funds
available for award to each eligible LOA by:
• Using quantitative data to generate a total number of points for each
LOA.
o The proportion of an LOA’s points of the grand total of points is used to
determine the amount of funds the SEA will award to each LOA.
• In the formula approach, the SEA typically applies weights to each
factor, so some factors will produce a higher number of “points”.
• While the four required factors must be included in the formula, the
SEA has flexibility in determining what data will be used for calculating
these factors and how much weight each factor will receive.
39
Example Formula Approach
An example of a state migrant formula allocation worksheet reflecting
formula factors, sources of data, and possible weighting of factors
Formula Factors Data Source Weight *
Number of Migrant Students – Total of
• Served during the Regular School Year
• Served during the Summer
• Migrant Eligible, not served
• Student demographic data
(Determine how eligible migrant child data is used for this
calculation, e.g., Category 1 and Category 2 of Child
Counts)
Highest % of
weight
(e.g., 75%)
Migrant Student Needs – Total of
Numbers of migrant students in need of services aligned to
the CNA and SDP, such as
• Academic performance, e.g., math, reading, science
• Students retained during the school year
• Limited English Proficient
• Out-of School Youth
• Early Childhood
• Special Education
• Students experiencing homelessness
• State assessment data
• Student demographic data
• Student End of Year status
(Identify migrant student data codes)
Somewhat
less % weight
than PFS
(e.g., 8%)
Priority for Services
• Migrant Priority for Services (PFS)
(There may be some PFS overlap with the student needs
descriptions above – the important distinction is that PFS
eligibility requires a school interruption)
Migrant Status
(Use migrant student data codes identifying students who
meet PFS eligibility)
Higher % than
overall
student needs
(e.g., 15%)
Availability of Other Funds
• District’s Per Pupil Expenditure (PPE) compared to the
State Average PPE
Prior year’s PPE for both the district and the state.
[States may decide to weight this category if the district’s
PPE is considerably lower (set a % determination) than the
state’s average].
Least % of
weight
(e.g., 2%)
* For example purposes only.
40
Example Formula Approach
Many SEAs use the total number of eligible migrant children as part of
their Numbers of Migrant Children factor. In the example on Slide 40:
• The count of total eligible migrant children is taken from Category 1
and Category 2 Child Counts data and
• Is given a fairly heavy weight as a starting base for funding projects.
41
Example Formula Approach
The SEA has flexibility in deciding which Migrant Student Needs to
factor in when determining subgrant amounts. Additionally, the SEA can
decide to weigh some needs more than others. Some considerations
reflected in the example on Slide 40 include:
• Gaps in services identified in the SDP,
• Changes in migrant children populations (demographic data),
• Changes in proficiency on state or other assessments scores, and
• Whether academic needs are statewide or limited to specific areas.
42
Example Formula Approach
When considering how the Needs of Migrant Children factor will be
used in determining subgrant amounts, the SEA may choose to count a
migrant child:
• Only once regardless of the number of times she/he fits into a needs
category (unduplicated counts), or
• Each each time she/he fits into a needs category.
o For example, Juan is counted a total of three times because he fits three
separate needs categories: he is considered limited English proficient
(LEP), he is below proficient in reading, and he is below proficient in math.
o If the SEA allows children to be counted for each need category, then the
number in the Needs of Migrant Children factor could potentially exceed
the Number of Migrant Children factor.
43
Example Formula Approach
In some cases, the Priority for Services (PFS) factor might overlap with
the Needs of Migrant Children factor.
• For example, a child might be considered PFS based on the fact that
he/she has experienced an educational interruption during the
regular school year, and scored less than proficient on the state
mathematics assessment. If less than proficient scores on the
mathematics assessment is also one of the Needs of Migrant
Children, then the child would be counted under both factors.
• Because of the high risk of failure of PFS students, SEAs may choose
to allow this overlap in numbers for purposes of determining subgrant
amounts.
44
Example Formula Approach
When considering the Availability of Other Funds, the SEA may choose
to:
• Examine the funding levels of programs that the LOA implements and
that are available to migrant children, or
• Evaluate the availability of other federal, state, or local funds by
collecting data on per-pupil expenditures.
45
Example Formula Approach Spreadsheet
Below is a spreadsheet reflecting the application of weighting from the
example worksheet shown on Slide 40.
46
Proposal and Negotiation Approach
In the proposal and negotiation approach, the SEA:
• Defines how the four required factors and any additional factors will
be applied in the subgrant process,
• Reviews a description of the proposed activities and the budget
request submitted by a LOA, and
• Determines the final subgrant amounts based on the quality of the
proposal and any negotiated adjustments.
47
Proposal and Negotiation Approach
The proposal and negotiation approach differs from the formula
approach in that the SEA has not established (by formula) a
predetermined amount that each eligible LOA may receive. Rather, in
this approach:
• The SEA establishes a Request for Proposals (RFP) or application
process.
o The proposal and negotiation may result in more than one entity
submitting a proposal to serve the same district or area, or might
allow for consortia to submit proposals to serve children across
multiple districts or areas.
48
Proposal and Negotiation Approach
• The SEA may contact the LOA to negotiate changes to the
proposal/application, such as:
o Revisions to strengthen proposed services to migrant children,
o Requesting addition of services, or
o Budget adjustments.
49
Combination Approach
As the name suggests, the combination approach will involve the SEA
using a two-pronged approach to award MEP funds to LOAs:
1. The SEA may establish a base amount by formula for which all
eligible LOAs apply through the application process.
• The SEA may apply weights to each factor, as described in the
formula approach on slides 39-46.
2. The SEA may negotiate final subgrant amounts with each LOA based
on the quality of the applications submitted.
• For example, the SEA may apply bonus points for addressing
certain high priority issues or subtract points for services not
included.
50
State Education Agency Flexibility and
Responsibility
It is worth repeating that the SEA:
• Has a great deal of flexibility in determining the amount of funds to be
subgranted to LOAs;
• Has the sole authority for determining which LOAs receive subgrant
awards; and
• Remains responsible for the overall administration and operation of
the MEP in the state, including for ensuring that all MEP funds are
properly spent, whether delivering services directly or through the
LOAs.
Section 1302 of the ESEA, as amended
EDGAR - § 76.770 and 80.3
51
What Do You Think?
Under what circumstances might an SEA choose one approach over
another for determining subgrant amounts?
52
What Do You Think? - Reflection
• In a state in which the needs of migrant students are similar across all
LOAs, the SEA might choose to use a formula approach to determine
subgrant amounts.
• In a state in which there is large variation in the needs of migrant
children, and thus the services provided, from LOA to LOA, the SEA
might choose to use a proposal and negotiation approach.
• In a state in which the migrant child population is distributed across
broad regions, or where there may be multiple LOAs providing
services, then the SEA might choose to use a combination approach.
53
What Do You Think? - Reflection
• In a state in which some specialized services may be required on top
of those already funded, the SEA may choose to set aside funds for
“special projects”, based on a proposal and negotiation approach to
target these special services.
• These special projects may be funded by contract or, if State
procedures permit, by subgrant. They are not traditional MEP
subgrants to which the four factors apply (see slide 23) because the
LOAs receiving the awards will not be operating projects only in the
project it serves.
54
Section 5: The Subgrant Process
The Subgrant
Process
In This Section
• Overview of the Subgrant Process
• Refining the Subgrant Process
• Quality of the Local Operating Agency
Application
• Subgrant Oversight
• Carryover and Closeout of Local
Operating Agency Funds
55
Overview of the Subgrant Process
Whichever approach the SEA takes for determining subgrants, LOAs will
need to submit an application or a proposal providing specific project
and budgetary information as required by the SEA. Therefore, it will be
necessary to have some basic processes and procedures in place to
ensure that subgrant recipients are aware of all requirements and
expectations in order to fulfill the goals, objectives, and measurable
performance outcomes (MPOs) of the state MEP.
Activities
Strategies
Objectives
Goals
MPOs
56
Overv iew
SEAs will need to provide information to eligible LOAs about:
• The process to be used to award subgrants, including how fund amounts will
be determined (e.g., formula, proposal & negotiation, combination, or other);
• State MEP goals, objectives, and MPOs;
• Highlighted priorities;
• Allowable activities;
• The application or request for proposal package;
• The timeline for submitting applications or proposals;
• The criteria for evaluating the quality of applications or proposals; and
• Timeline and process for issuing awards.
See QRRS 4.3 – Subgrant Application/Request for Proposal Package
57
Refining the Subgrant Process
The subgrant process is an important aspect of the SEA’s MEP
responsibilities. Having a well-planned timeline for each step of the
subgrant process will help ensure that the process stays on schedule.
Consider the time it will take your staff to do the following:
• Review and revise the current subgrant process, including:
o Determining which approach(es) will be used,
o Reviewing subgrant criteria, and
o Reviewing subgrant formulas.
• Review and revise the LOA application.
o (See MEP Guidance, Chapter XI, for a suggested list of information
LOAs should include in their application.)
• Review and revise the request for proposal.
58
Refining the Subgrant Process
• Provide pre-application or pre-proposal technical assistance to LOAs.
o The time spent helping LOAs understand the expectations of the
subgrant program and develop quality applications/proposals will
pay off when applications/proposals reflect an understanding of
the program and provide a clear picture of what the LOA plans to
do with the funding.
o Training and technical assistance levels the playing field among
LOAs, some of whom have experienced grant writers available, but
most of whom do not.
59
Refining the Subgrant Process
• Announce the subgrant approach, process, and requirements.
o Making the following available will assist LOAs in submitting
applications/proposals that align with the state MEP goals and
expected outcomes:
§ Comprehensive Needs Assessment,
§ Service Delivery Plan,
§ State MEP Evaluation,
§ Relevant statutes and regulations, and
§ Relevant state-level policies and guidance.
o Review your state MEP website to see if the most current version
of this information is already available.
60
Refining the Subgrant Process
• Review and revise the application review process.
o A carefully planned application review process will help ensure that
decisions for subgrant awards are objective and fair.
o In terms of review criteria,
§ A strong rubric will assist reviewers in assessing the quality of the
information included in the LOA’s subgrant application.
§ The rubric should be provided to the applicant to assist them in writing
to specific criteria defined by the SEA.
o Many states have requirements for the review process for discretionary
grants, such as requirements for the number and types of reviewers, the
type of rubric or criteria, and documentation of the review process.
§ State directors should be familiar with their state’s policies for the
review of grant applications.
See QRRS 4.5 – Sample
Subgrant Rubric
See QRRS 4.4 – Tips for
Developing a Subgrant Rubric
61
Refining the Subgrant Process
• Provide technical assistance on subgrant implementation to address
common issues that have arisen from prior years’ LOA monitoring
visits and to clarify definitions.
o As programs and services (whether federal, state, or local)
sometimes overlap, LOAs may need assistance in understanding
which MEP services are allowable. Provide examples of allowable
(and non-allowable) activities.
o Understand and ensure compliance with the state’s processes for
grant approval and disbursement of funds to grantees.
62
Refining the Subgrant Process
States are likely to have some established practices in place to guide
your MEP subgrant process. A carefully planned subgrant process that
conforms with the statute, regulations, and MEP guidance and is
aligned with the CNA and SDP will help to ensure that the educational
needs of migrant children are being addressed in an effective and
efficient manner.
See QRRS 4.6 – Planning Your Subgrant Calendar
63
Quality of Local Operating Agency
Applications/Proposals
The SEA will want to do a comprehensive internal review of the LOA
applications to ensure:
• The Needs are stated and aligned with the CNA,
• The Project Design is aligned with the SDP,
• The Budget Narrative links expenditures to specific
goals/objectives/strategies and activities described in the Project
Design Narrative,
• All Program Partnerships are identified,
• The Evaluation provides an explanation of how the program will be
evaluated both in terms of implementation and outcomes, and
• All Other Requirements of the application/proposal are satisfied.
64
Subgrant Oversight
SEAs have a responsibility to monitor LOA subgrants, and should have
several means to ensure that LOAs serve migrant children effectively
and spend funds in allowable and strategic ways. State directors
should:
• Require subgrantees to maintain documentation of project activities,
• Require subgrantees to conduct an evaluation of project activities that
includes both implementation (process) and outcomes (impact) review
and data,
• Require an end of year (EOY) report and budget sheet reflecting actual
expenditures, and
• Monitor program subgrantees at least once during the funding cycle.
65
Subgrant Oversight
• Requiring an end-of-year report from each subgrantee is an effective
way to desk monitor the implementation of their project.
• Developing the report enables the LOA to review the year’s actual
activities against the proposed activities and reinforces accountability.
o Some states require LOAs to submit mid-year reports on the status
of their program implementation to ensure:
§ Fidelity of implementation of proposed program activities and
§ Expenditures are on track with program implementation.
• The report format should strike a balance between including enough
detail to depict the status of the program and avoiding burdening the
project director in a way that unduly detracts from providing services.
66
Carryover and Closeout of Local Operating
Agency Funds
The SEA has sole discretion as to whether LOAs will be allowed to
carryover MEP funds not used during one grant period into the
following grant year. In some cases,
• The SEA may allow the LOA to carryover funds for an additional period
following the end of the subgrant period, or
• The SEA may require all unused funds to revert back to the state at
the end of the subgrant period.
o The SEA can choose to use the reverted MEP funds in a number of
ways. Some examples, include redistribution to:
§ Supplement summer MEP programs,
§ Fund special MEP activities to address high priority needs, or
§ Be included in the next year’s subgrant allocations.
67
Section 6: Wrapping Up
Wrapping Up
In This Section
• Key Points
• Action Planning
• Resources
68
Key Points
• SEAs may choose to deliver MEP services directly or through eligible
LOAs through a subgrant process.
• The SEA remains responsible for the overall administration and
operation of the MEP and for
o Establishing procedures to determine which eligible entities will
receive a subgrant and
o Ensuring that LOAs comply with all applicable statutory and
regulatory requirements.
69
Key Points
• When determining the amount of a subgrant, the SEA must consider
1. Numbers of migrant children;
2. Statutory PFS children who are failing, or most at risk of failing to
meet the state’s challenging academic content standards, and
whose education has been interrupted during the regular school
year; and
3. Availability of funds from federal, state, and local programs.
70
Action Planning
Consider the following questions:
• When do you need to begin the next subgrant cycle?
• How has the state migrant population changed in your state since the
last subgrant cycle?
• How have the needs of migrant children changed in your state since
the last subgrant cycle?
• What funds are available for this subgrant cycle?
• How many subgrants do you envision awarding?
• What planning needs to occur prior to announcing the application
process for subgrants?
Revisit QRRS 4.6 – Planning Your Subgrant
Calendar - to complete the milestones
See QRRS 4.7 – MEP Subgrant
Action Planning
71
Resources for Migrant Education Program
Subgrant Procedures
• MEP Guidance on Education of Migratory Children under Title I, Part C
of the Elementary and Secondary Education Act of 1965, Chapter XI –
State Administration – Explanation of guidelines to implement the
laws and regulations related to the MEP
• Consolidated State Application – Includes state’s subgrant processes
72
