Section 10 - Risk Assessment and Monitoring
Minnesota's Perkins V Risk Assessment and Monitoring Process
In accordance with post-federal award requirements for pass-through entities, the state must use a risk-based approach to monitor subrecipients (2 CFR 200.332(c)). 亚洲无码 and the Minnesota Department of Education will conduct an annual risk assessment for all consortia.
Quantitative and qualitative data will be used to determine the risk level of subrecipients. The risk factors assessed aid the state in ensuring consortia are:
- Using funding for authorized purposes
- In compliance with federal statutes, regulations, and terms and conditions
- Achieving state-determined performance goals (2 CFR 200.332(e))
Risk assessment will focus on the following factors contributing to the successful administration of the Perkins Federal Grant:
- Stable leadership and governance
- Unified planning and decision-making
- Data-driven decisions
- Fiscal processes and patterns
- Targets met on performance indicators
- Service to special populations
- State-recognized programs of study
State staff will use the Consortium Risk Assessment Tool to assess each consortium's risk of noncompliance as low, medium, or high. Risk levels help identify Perkins recipients with higher risk factors who may need targeted technical assistance or more in-depth monitoring. Monitoring may involve looking at one or two criteria or reviewing all six compliance criteria. Part 1 of the Assessment tool is based on quantitative data. Part 2 is based on qualitative observations of state staff, including discussions with each consortium during technical assistance meetings supporting the completion of the Local Application. Consortium leaders can use the optional Individual Meeting Check-in-Prep document to review consortium operations and identify areas where state staff can assist. All the information will be reviewed to identify consortium needs and develop an intervention plan with the consortium leaders.
A high-risk level does not necessarily mean a consortium is not meeting program requirements, federal regulations, or administrative procedures. A low-risk level does not guarantee full compliance. The risk-based assessment process identifies potential problems that could lead to noncompliance in accountability, fiscal accounting, and grant operations. The intervention plan identifies the actions that will be taken to address the areas of need.
Risk Factors
Part 1: Quantitative Risk Factors
- Time since last full monitoring of the consortium
- Perkins leadership changes in the fiscal year
- Cash management (underspending grant funds)
- Performance Indicator Targets (not meeting SDPLs)
- Combined equipment inventory (incomplete or missing)
- Corrective actions from previous monitoring (not completed)
Part 2: Qualitative Risk Factors
- Consortium Governance: secondary and postsecondary collaboration, partner engagement, and CLNA.
- Pattern of budgeting to address priorities in relation to size of program, SDPL performance, CLNA, or other, for the following:
- Programs of Study (POS)
- Salaries
- Teacher recruitment and retention
- Career exploration and work-based learning (WBL)
- Integrating academics
- Special populations
- Fiscal Health such as fiscal processes, PARs, cash management and spending funds, change in business staff, or change in platforms.
Intervention Plan
Based on the risk assessment, a plan will be developed for each consortium specifying a timeline and recommended or required actions using available data and input from consortium leaders. The recommended actions that can be incorporated into the intervention plan are based on the level of the risk.
Risk Level Determination
| Risk Level | Interventions Based on Quantitative and Qualitative Risk Levels |
|---|---|
| Low | No known programmatic, financial instability, or significant issues within the consortium. The consortium shall receive technical assistance upon request. |
| Medium | Required to receive targeted assistance based on identified need areas. Monitoring of specific areas may be needed based on the identified risk factors. |
| High | Full monitoring with a fiscal desk audit is recommended. On-site monitoring will be at the discretion of the monitoring review team. |
Monitoring Process
Monitoring may be conducted to assess compliance with Perkins V requirements and related federal regulations. Minnesota has identified six compliance criteria: Consortium Governance, Fiscal Requirements, Reserve Funds, Partnerships, Programs of Study, and Accountability. Consortia selected for monitoring will have 30 days to submit required evidence.
The criteria requirements, compliance components, and evidence to submit for monitoring include:
Consortium Governance
Criterion 1 Requirement: The consortium engages in structured and collaborative planning that benefits the consortium as a whole and is focused on local and regional resources and needs.
Compliance 1.1
Secondary and postsecondary consortium leaders work together to establish and implement a plan and budget that benefits the consortium as a whole.
- A combined secondary and postsecondary application is completed every two years, with the most recent submitted to the 亚洲无码 grant management system in May 2023. Additionally, an application and budget update is required in the year between the two-year submission if changes are needed.
- A Comprehensive Local Needs Assessment (CLNA) is updated every two years, and a summary, the CLNA Framework, is provided with the local application. CLNA results drive budgeting and programmatic decisions. The current CLNA, including all supporting documentation, is on file.
- A budget for secondary and postsecondary expenditures is submitted annually. A process for joint planning and decision-making has been established within the consortium governance structure.
- A process for funding decisions has been established within the consortium governance structure.
Evidence to submit for monitoring
- A written summary of the consortium's process for joint planning and decision-making.
- Documentation showing the consortium's process for joint planning and decision-making through one or more of the following pieces of evidence: memorandum of understanding or agreement(s), planning documents, charts or descriptions included in a local governance handbook or policy manual, funding application forms, or other consortium governance documents.
Compliance 1.2
Partners review and provide input on the consortium's annual operational plan, the Perkins V Local Application.
- Partners met within the reporting year.
- Minutes and agenda(s) documenting members attending, including their names, titles, and the constituencies they represent, and reflecting a discussion of workforce needs and Perkins performance measures as part of planning and decision-making, are on file.
Evidence to submit for monitoring
Meeting minutes and agenda with a list of attending partners, including job titles and constituencies they represent, participating in consortium planning.
Criterion 2 Fiscal Requirements
Secondary
- Financial records are maintained according to the Uniform Fiscal Accounting Recording System (UFARS).
- All expenditures must be used in approved programs taught by appropriately licensed teachers or for professional development associated with the operation of career and technical education programs, career guidance, or pre-career and technical education within an approved program of study.
- All equipment and curriculum material purchases of $1,000 or more must be pre-approved by the state.
Postsecondary
- Financial records are maintained according to cost centers.
- All expenditures must be used in eligible career and technical education programs taught by college faculty who have met the minimum qualifications.
- All equipment purchases of $5,000 or more must be pre-approved by the state.
Costs associated with administrative activities are not to exceed 5% of the grant. Equipment purchases are identified as fixed assets, and required inventory and depreciation procedures must be in place. Funds may not be used when acquisition would result in direct financial benefit to any organization representing the interests of the purchasing entity, its employees, or affiliates.
Compliance 2.1
Consortium Perkins V expenditures must comply with all legislative rules attached to those funds. For Perkins V, this includes the local uses of funds outlined in the Act and the general requirements for grant management of federal funds. Districts and colleges must adhere to the required uses of funds, Section 135 Local Uses of Funds, and the Operational Handbook when making a budget request. A fiscal desk audit is part of every monitoring review. 亚洲无码 and MDE grant accountants will review secondary and postsecondary transactions to determine compliance with statutes and policies regarding fiscal requirements.
- The consortium demonstrates good cash management by drawing funds from Basic and Reserve Allocations and Basic and Reserve Reallocations periodically throughout the year, not all at once.
- Encumbrances and payments are processed within the required timeframe.
- Equipment purchased with Perkins funds is inventoried and reconciled.
- Perkins funds are used to develop, coordinate, implement, or improve career and technical education programs to meet the needs identified in the Comprehensive Local Needs Assessment (CLNA).
- Perkins funds are used to supplement, not supplant, local funding sources.
- The consortium's use of funds is aligned with the local plan and strategic goals.
Evidence submitted by 亚洲无码 and MDE grant accountants
- Secondary fiscal desk audit results.
- Postsecondary fiscal desk audit results.
Evidence to submit for monitoring
- A summary of the process used to determine if expenditures:
- Are expended only for allowable activities;
- Are spent according to the approved budget;
- Are used to supplement and not supplant;
- Ensure no goods or services are made with a debarred or suspended party;
- Ensure no funds are used for incentives, inducements, or relocation; and
- Ensure no funds are used for lobbying.
Compliance 2.2
The consortium maintains a combined inventory of equipment purchased with federal Perkins funds, which is validated and reconciled at least every two years. All equipment purchased with federal dollars must have specially marked asset tags.
- A single consolidated inventory is on file.
- Records for each item may include:
- Date of purchase
- School, teacher, or program for which the purchase was made
- Item description
- Cost
- Current location
- A process is in place to inventory and label equipment as property of Perkins CTE.
- A process is in place to update inventory if equipment is reassigned or disposed of.
- Equipment purchases have been pre-approved per MDE and 亚洲无码 requirements.
Evidence to submit for monitoring
- Consortium Consolidated Equipment Inventory spreadsheet file.
- Pictures of two secondary and two postsecondary pieces of equipment, for a total of four different equipment pieces, showing how equipment is labeled to reflect that it is the property of Perkins CTE. Multiple pictures of each piece of equipment may be needed to show the entirety of the equipment and the tag text.
- A summary of the process used to update inventory when equipment is reassigned or disposed of.
Compliance 2.3
Personnel who are compensated in whole or in part with federal grant dollars are required to report on their duties and activities funded under the grant. Time and effort reports must be a single, certified document that reflects 100 percent of an employee's time worked in a given period. Position descriptions should align with the percentage of time reported and charged to the federal grant.
- Time and effort reports, or Personnel Activity Reports (PAR), are on file for every employee salaried partially or entirely with federal Perkins funds.
- Position descriptions defining Perkins-related duties and responsibilities for every employee salaried partially or entirely with federal Perkins funds were submitted with the most recent local application.
Evidence to submit for monitoring
- Time and effort reports, or Personnel Activity Reports (PAR), for every employee salaried partially or entirely with Perkins funds.
- Provide an update if there have been any changes to position descriptions since the local application.
Criterion 3 Reserve Funds
Criterion 3 Requirement: New in Perkins V, funds must be used to foster innovation or promote the development, implementation, and adoption of programs of study or career pathways aligned with state-identified high-skill, high-wage, or in-demand occupations or industries. Perkins V criteria continue to make funds available to career and technical education programming in the following areas:
- Rural areas
- Areas with high percentages of career and technical education concentrators
- Areas with disparities or gaps in performance identified during data reporting
Compliance 3.1
Reserve funds are used to foster innovation or promote the development, implementation, and adoption of programs of study.
- The most recent Annual Performance Report (APR) included a progress update on Reserve Funds initiative(s).
Evidence to submit for monitoring
- Provide a summary and documentation, such as meeting minutes, emails, governance procedure, or similar materials, of the consortium's decision-making process used to invest reserve funds in support of innovative consortium initiatives rather than separate and unrelated secondary and postsecondary initiatives.
- From the updates given in the most recent APR, submit documentation under one of the Reserve categories for both secondary and postsecondary showing how the funds were utilized, such as a professional development workshop agenda, program flyer or promotion, equipment purchases, or outcome report summary.
- If applicable, provide information on anything not previously submitted with the most recent APR.
Criterion 4 Partnerships
Collaboration among secondary and postsecondary partners, community-based organizations, nonprofits, business and industry, and other stakeholders promotes career and technical education program efforts.
Compliance 4.1
CTE local program advisory committees provide collaborative input from relevant partners, including industry professionals, employers, teachers, faculty, and students. The work of advisory committees informs consortium priorities.
- CTE local program advisory committees met within the reporting year to discuss performance, program quality, and local workforce needs.
- Agendas and meeting minutes with a list of attending partners, including job titles and constituencies they represent, are on file.
Evidence to submit for monitoring
- A summary of one example in which program advisory committee work contributed to the consortium's efforts, such as strategic planning, student outreach activities, career pathways development, or shared curriculum.
- Meeting minutes and supporting documentation from secondary and postsecondary advisory committee meetings.
Compliance 4.2
Students are provided experiential learning and work-based learning opportunities, including apprenticeships linked to the career and technical education program or programs of study. Consortium partnerships prioritize support for special populations and access to experiential learning and work-based learning opportunities.
- Agreements with local or regional businesses or industries are on file.
- Vocational rehabilitation services contracts are on file.
- Approved programs have been established.
- Laddered experiences are provided, such as career fairs and job shadowing, that lead to experiential learning and work-based learning.
- Secondary enrollment in course code 97, Work Experience, has been reviewed.
- Licensing of work-based learning coordinators.
- Processes are in place for recruiting students and addressing barriers to participation in experiential learning opportunities, such as inclusive promotional materials, transportation, and scheduling.
- Note that participation in CTSOs is not evidence of experiential learning.
Evidence to submit for monitoring
- If funded, provide a summary of licensing activities, including the number of work-based learning coordinators employed or licensed within the consortium.
- Description of initiatives and accomplishments or outcomes resulting from collaborations with partners such as vocational rehabilitation services, Adult Basic Education, CareerForce Center, and or in support of Workforce Innovation Opportunity Act, WIOA.
- Description and documentation, such as meeting minutes, flyers, or webpages, of efforts to recruit students and or address barriers to participation in experiential learning and work-based learning activities at secondary and postsecondary levels.
Compliance 4.3
The consortium collaborates to support the recruitment, training, and retention of teachers and paraprofessionals for career and technical education programs.
Required evidence to submit for monitoring
- Summary and documentation, such as meeting minutes, emails, or webpages, of consortium efforts and outcomes to support new teachers.
- Summary and documentation, such as meeting minutes, emails, or webpages, of consortium efforts to support continuous professional development for teachers and faculty.
Compliance 4.4
Students are provided with an opportunity to earn postsecondary credits through dual enrollment, such as articulation, PSEO, AP, IB, or concurrent enrollment.
- CTE articulation agreements are on file.
- CTE concurrent enrollment course offerings are on file.
- Other CTE dual enrollment opportunities are documented.
Evidence to submit for monitoring
- List of CTE articulation agreements.
- List of CTE concurrent enrollment courses and high schools offered within the reporting year.
- Summary of outcomes from investing funds in articulation agreements and dual credit opportunities.
- Description and documentation, such as meeting minutes, flyers, or webpages, of efforts to increase student awareness of and access to dual enrollment opportunities.
Criterion 5 Programs of Study
Criterion 5 Requirement: Programs provide a coherent sequence of courses through defined programs of study (POS) that:
- Incorporate challenging state academic standards
- Address both academic and technical knowledge and skills
- Are aligned with the needs of industry in the region
- Progress in specificity
- Have multiple entry and exit points that incorporate credentialing
- Culminate in the attainment of a recognized postsecondary credential
Programs of study meet state-recognized POS requirements and reflect continuous improvement.
Compliance 5.1
A self-evaluation of each consortium program of study is recommended to be completed annually to ensure alignment with the local labor market and between secondary and postsecondary clusters and pathways. Results from the self-evaluation should shape local planning and budgeting for program improvement.
- For each consortium program of study, a self-evaluation and supporting documentation addressing the eleven elements are on file:
- Standards-Aligned and Integrated Curriculum
- Integrated Network of Partnerships
- Course Sequencing and Credentials
- Career-Connected Learning
- Facilities, Equipment, Technology, and Materials
- Work-Based Learning
- Data for Program Improvement and Advocacy
- Student Leadership Development
- Access, Equity, and Inclusion
- Student-Centered Instruction
- Professional Development for Knowledgeable Experts
Evidence to submit for monitoring
- If a self-evaluation rubric was completed, submit:
- Self-evaluation rubric, Part C and Part D of the User Guide, for one state-recognized program of study.
- Summary of how the rubric was completed, including when and who was involved, such as meeting minutes.
- If self-evaluation rubrics have not been completed for state-recognized programs of study, submit:
- Summary of how the consortium ensures alignment with the local labor market and between secondary and postsecondary clusters and pathways to shape local planning and budgeting.
- Evidence of what was done, such as meeting minutes.
Compliance 5.2
The consortium has established six State-Recognized Programs of Study that represent at least four different career fields, with no more than one brokered with institutions outside the consortium. Each program of study must meet the seven minimum requirements for State-Recognized Programs of Study.
- S-R POS and Funding POS spreadsheet is on file and updated annually with the local application in May of each year.
Required evidence to submit for monitoring
- Summary of the consortium process to determine State-Recognized Programs of Study and Funding POS decisions.
- Documentation of implementing the process, such as meeting minutes.
Criterion 6 Accountability
Criterion 6 Requirement: The consortium, as the eligible recipient, continually makes meaningful progress toward improving performance of career and technical education concentrators.
Secondary Core Indicators of Performance
- 1S1 – Four-year Cohort Graduation Rate
- 2S1 – Academic Proficiency: Reading and Language Arts
- 2S2 – Academic Proficiency: Mathematics
- 3S1 – Post-Program Placement
- 4S1 – Nontraditional Program Concentration
- 5S3 – Program Quality: Work-Based Learning
Postsecondary Core Indicators of Performance
- 1P1 – Postsecondary Retention and Placement
- 2P1 – Earned Recognized Postsecondary Credential
- 3P1 – Nontraditional Program Enrollment
Compliance 6.1
The consortium utilizes performance indicator reports to guide the development and implementation of initiatives to address gaps in the performance of career and technical education participants, concentrators, and subpopulations.
Evidence to submit for monitoring
- A summary of the process used to identify and address performance gaps within a subpopulation or area of focus.
- Summary description and evidence of one project or initiative the consortium implemented to improve performance for one or more special populations based on identified gaps. Evidence examples may include advisory committee minutes, planning documents, project implementation documents, project charters, flyers, or project outcomes.
- If applicable, provide an update on improvement plans.
Fiscal Desk Audit Process
If necessary, a fiscal desk audit will be completed by 亚洲无码 and MDE grant accountants.
Fiscal Desk Audit Process
- Approximately 30 days prior to the monitoring visit, fiscal contacts will be notified of desk audit requests, including which transactions will be reviewed.
- The fiscal contacts will provide all supporting documents to grant accountants within ten days of the request or ten days prior to the visit, whichever is sooner.
- Supporting documents would include invoices, purchase orders, packing slips, special expense request forms, M16-A forms, employee expense forms, any notes and correspondence, and other relevant documentation related to the expenditure transactions.
- Supporting asset documentation would include system-generated inventory reports, asset reconciliation reports, physical inventory reports, and evidence of asset tags.
- The grant accountants will review the documentation and request any additional information if needed.
- Within five days, the local consortium fiscal contacts respond and provide the additional information to the grant accountants.
- Depending upon the above timeline, approximately five days prior to the visit, grant accountants will send preliminary findings to the fiscal contact, chief financial officer (CFO), and the monitoring team.
- During the monitoring visit, a member of the monitoring team reviews any questions, findings, and required corrective actions and timelines.
- Any fiscal findings and corrective actions will be included in the final monitoring visit and audit report.
- Within the timeline specified in the fiscal corrective actions, the fiscal contacts are to provide documentation of the completed corrective actions taken to the grant accountants and the monitoring team.
Fiscal Desk Audit Criteria
- Run a query of all expenditure activity, including payment of invoices and correcting entries.
- Provide a random sample of 3 to 5 percent of non-payroll transactions, depending on the volume of transactions, with a focus on larger transactions, and including at least one correcting entry.
- 亚洲无码 and MDE will review documentation provided for:
- Completed, signed, and approved required documentation
- Invoices
- Encumbrances
- Special expense forms
- M16-A forms
- Consistency with State of Minnesota statutes, 亚洲无码 Board policies, MDE policies, and GASB/GAAP
- Perkins-eligible expenses
- Potential fraud
- Comparing equipment and asset reports to transactional activity
- Cash management patterns
Policy & Procedure History
Date of Implementation: 07/01/2026
Date of Last Review: 0/0/0