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Compliance and Monitoring

The Elementary and Secondary Act of 1965, as amended by Every Student Succeeds Act of 2015 requires State Educational Agencies (SEAs) to monitor the implementation of program requirements and the expenditure of federal funds. Monitoring is conducted at local educational agencies (LEAs) to ensure compliance with regulations as well as to assure that the quality of the program and instructional delivery is of high regard. Monitoring emphasizes accountability for using resources wisely. The monitoring process for programs administered by the Office of Federal Programs consist of the monitoring of expenditures, Single Audits, On-Site monitoring, and Desk Audits.

The Monitoring and Compliance Division conducts an annual risk assessment of all subrecipients, to determine their potential risk of noncompliance. Based on the outcome of the risk assessment, subrecipients are assigned a risk level of low, medium, or high. The risk assessment includes weighted risk indicators derived from multiple sources. The Monitoring and Compliance Division updates the risk assessment model annually to ensure risk indicators and weights accurately reflect the potential risk posed to the agency in awarding funds to each subrecipient. This assessment is used in practical terms to take a thorough look at how OFP monitors subrecipients. The assessment tool assists in the identification of conditions, situations and processes that may cause problems.


Purpose of the Annual Risk Level

The risk assessment determines the likelihood that a subrecipient may fail to comply with applicable rules. If an organization is assigned a high-risk level, it does not indicate the organization has failed to comply with the requirements of a federal grant(s). Similarly, a low-risk level does not indicate an organization is compliant with the specific requirements of federal grant programs. Only an independent auditor or an MDE monitor can determine if an organization is compliant or noncompliant.

The risk assessment is conducted annually, so an organization’s risk level can change from year to year. A subrecipient assigned a high-risk level for the current year may be assigned a medium or low-risk level the next year.

Effect of Different Risk Levels

An organization’s risk level will be used by MDE in the following ways:

  • Focused Technical Assistance. The MDE uses a differentiated support approach for federal grant applications through the risk assessment. Organizations with a medium or high-risk level are subject to special grant conditions and more focused technical support than those with a low-risk level.

  • Subrecipient Monitoring. Each year, the MDE selects subrecipients for fiscal monitoring, according to their risk levels. The higher your organization’s risk level, the more likely you are to be selected for on-site and virtual monitoring.

  • Categories for Risk assessment 

    • Risk Assessment               Criteria

      • Low Risk                          Risk Score 15 or Less

      • Medium Risk                    Risk Score between 20 & 25

      • High Risk                          Risk score greater than 25
    • Risk Assessment Indicators
      • Audit Findings
      • New Personnel 
      • Fiscal Monitoring Findings (July 1, 2021 - June 30, 2022)
      • Late Budgets
      • Late FETS
      • Application Revisions as of June 30, 2022
      • Allocation amount
      • Overpayments
      • Lapsed/Forfeited Funds
      • Last Fiscal Monitoring
      • LEA/Subgrantee Personnel Attend Division Training 
      • Question Cost Repayment
      • Financial Concerns
      • Timely Correction of Findings 
      • Timely Submission of Data
      • Data Quality

Monitoring Packet

Monitoring List