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AEP Questions and Answers

This is a collection of questions that are most frequently asked of the AEP Office. They are organized by topic area and will be updated as needed.

Use of Funds

The AEP Office is unlikely to approve expenditures for light refreshments and entertainment. We would need to know more about what you are proposing. Please email the AEP Office with more detail.

No. The focus must be on AEP planning and implementation activities.

USIS will assist with payment for low income citizenship and naturalization applicants. They have a sliding scale. There are also other resources out there that may be offered by other partners in your region.

If the meeting involves AEP planning and the implementation of activities – it would be allowable to purchase meeting supplies.

Some have ordered a block of GED voucher codes and the teachers distribute them to students who are ready to take practice tests. They have pre-purchased the vouchers and established a procedure/process for "awarding" the voucher to the student so no cash goes to students. Some use private foundation grants and other county resources to support the students who cannot afford to take GED and Industry Certification tests.  But as always - local district policies and procedures will have the final say so.  If your district considers this a gift of public funds - we can't over-ride your local policies.

We are setting up a chat feature on the AEP website where you will be able to pose questions like this to colleagues in other consortia around the state. Supportive services are allowable provided they do not violate any existing State regulation, or local policy and procedure of the member district. Also, any expense of AEP funds must be agreed to by members at a public meeting, and included in your annual plan reflecting the 3 year vision of that effort.

There would be an issue if the district is supplanting AEP funds that were used last year by another fund source. Also, there may be an issue if the district is violating the State policy on fees or any local policy and procedures. Finally, any expense from AEP funds must be agreed to by members at a public meeting, and included in your annual plan reflecting the 3 year vision of that effort. Please keep in mind that AEP students must be 18 years old or older.

Yes, you can retain funds for common consortium level costs. How you do that is controlled locally. Some consortia add the dollar amount to the member’s allocation and track that amount separately e.g. through an Excel spreadsheet.

The state system does not have a feature to show encumbered but un-expended funds in the year-end report. You can identify encumbered funds carried over from Year 1 being utilized when submitting your Year 2 Plan.

AEP has an online system that allows consortia to report expenditures and progress every 6 months. The primary lead has the password to access these online forms. AEP also has an annual reporting process that allows consortia to report individual consortium and member annual expenditures by program, by objective, and by object code. The annual plan for Year 2 has been posted to the AEPwebsite.

Counseling services to students are direct services and are considered a program expense, not administration. That would be a cost shared between the consortium members.

Supplanting is not a dead issue. It can be an issue and it doesn’t matter whether the funds are coming through a fiscal agent or through direct funding. Supplanting could happen if you are replacing programs that were funded were other fund sources (like WIOA, Perkins, CalWORKS, Apportionment, etc.) with AEP funds.

Please check the AEP Program Guidance and Allowable Uses on the AEP website.

Yes, you have to spend them on 2015-16 activities. If 2015-16 funds are spent on additional/new activities, your consortia’s 2015-16 Annual Plan needs to be revised or amended to reflect such changes.

The use of MOE funding for AEP purposes is not considered supplanting. The issue of supplanting may occur when members use AEP funds to supplant an existing fund source (like apportionment, CalWORKS, Perkins, WIOA, SSSP, etc.). Please see the first section of the AEP Allowable Uses Guide posted on the AEP website.

Data for all students enrolled in AEP program areas at the Capital Outlay site need to be collected and reported to the AEP Office.

If any AEP funds (regardless of the percentage) are used for instruction, support, and/or services in an AEP program area, then the member would need to report those students into TOPSPro Enterprise.

No – marketing and outreach events to potential students do not require a member to collect student information and report it. The State AEP Office requires you to collect student information once the student begins the enrollment process.

Consortia wide marketing, outreach, teacher/faculty meetings, member meetings, are examples of activities that benefit the consortium as a whole, and do not need to be tracked. If the curriculum was developed, using AEP funds, with the intent to be used for a specific community college course, then they would need to report the students into TOPSPro Enterprise.

AEP funds are available to address gaps in services, either current or emerging. They can be used to stabilize services as efforts are made to improve them through implementation of the innovative approaches outlined in AB86 and AB104. These aspects work together – stabilizing and expanding services AND improving the impact of services for better student outcomes in alignment with AEP goals.

The use of MOE funding for AEP purposes is not considered supplanting. The issue of supplanting may occur when members use AEP funds to supplant an existing fund source (like apportionment, CalWORKS, Perkins, WIOA, SSSP, etc.). Please see the first section of the AEP Allowable Uses Guide posted on the AEP website.

Yes – fiscal agents for Data and Accountability funds can use their approved indirect rate. Budgets & Workplans will be due December 20, 2016.

Our best hope for keeping and growing this funding is documented success. As long as consortia throughout the state implement best practices for helping students meet the goals of AEP, objectively track outcomes to document program improvement and student achievement, and coordinate, leverage and expend resources responsibly, we anticipate that this funding will continue well beyond the Three Year Plan.

Student services are described as orientation, assessment, academic, and/or career counseling/referrals.

Now that there is again a restricted revenue source for adult education, it may no longer be necessary for LEAs to formally commit general purpose LCFF revenues to the purposes of adult education in order to justify the use of a special revenue fund in accordance with Generally Accepted Accounting Principles (GAAP). LEAs that continue to formally commit LCFF revenue to the purposes of adult education should use Object 8091, LCFF Revenue Transfers, to transfer the committed LCFF revenue from their general fund to Fund 11.

All funds are subject to a financial audit; however, there are no specific compliance procedures for the Adult Education Block Grant in the current state audit guide.

The intent is that AEP serve students only 18 years and over. Therefore, should an Adult Ed provider wish to serve someone under 18 years of age, they would need to use another funding source (e.g., LCFF). This would ensure “moneys in the Adult Education Fund to be expended only for adult education purposes.”

It would be reasonable and allocable if they charged you rent based on space. How are they costing out the rent from the various programs? Square footage? What we don't want to have happen is the AEP consortium has 15% of the space, but is paying for 70% of the base. These details will help answer the reasonable and allocable questions.

AEP MOE & Non-MOE funds can only be used in the seven AEP program areas. If the class is not in one of the seven program areas – then you cannot use AEP funds.

Yes – as long as the students are 18 years and enrolled in an AEP program area – it doesn’t matter who offers the classes – as long as they meet their K-12 or college education code and regulations. K-12 falls under adult education regulation administered by CDE (and teacher qualification regs under the CA Teacher Credentialing Commission), and the colleges fall under Title V & noncredit education code. I hope this helps.

AEP has certain program requirements. In this case I would highlight the following:
Funds can only be used within the seven AEP program areas.
For colleges, only noncredit students will be tracked and reported.
A member has to be in good standing (reporting, participation, etc.) – meaning meeting the member requirements.
Activities have to be included in the annual plan and approved by members.
Members can leverage and braid various fund sources (including noncredit apportionment). But colleges cannot use, leverage or braid any fee based programs – like community education or contract education.
If a community college wants to leverage & braid noncredit apportionment, they must follow the recently released guidance from the Chancellor’s Office on use of AEP funds (state funds) and FTES (noncredit apportionment).
Here is the guidance on using AEP funds and noncredit apportionment:
It is allowable to claim apportionment for a course, even if the instructor's salary and benefits are paid for using AEP funding, as long as some portion of the overall direct education costs for the course are paid for using district unrestricted general fund dollars (as indicated in prior legal opinions, this portion should be more than a trivial amount) and the course is allowable under the particular categorical program (in this case AEP). If there are no other direct education costs for a particular course beyond the instructor's salary and benefits, then the district would have to pay for a portion of the salary and benefits of the instructor using district unrestricted general fund dollars in order to claim apportionment for the course. The term "direct education cost" includes all expenses specifically traceable to a class, such as the salaries and benefits of the instructor, instructional assistants or aides, and non-instructional staff directly supporting the class (e.g., proctors); instructional materials and supplies and equipment, along with any other direct expense or cost required for the particular class in question. Please also note that all other applicable apportionment eligibility requirements would also need to be met, including as provided by Title 5 Section 58050.
We advise that districts have a policy in place that outlines what portion of the direct education costs for a course will be paid using unrestricted general fund dollars where a district intends to claim apportionment for courses that are partially funded from state categorical funds or that are conducted as part of instructional services agreements; ideally, these decisions would be made in the context of an established district policy. Please also recall that the Q&A document advises a prudent approach in determining what portion will be paid from district unrestricted general fund dollars.
This is a link to the document on the Chancellors Office website: http://extranet.cccco.edu/Portals/1/CFFP/Fiscal_Services/Attndc_Acctg/ISA/Title%205%20Section%2058051.5%20and%20Direct%20Education%20Costs%20Definition%201-10-17%20FINAL.pdf
Contact Person on AEP:

tap@aebg.org 

Contact Person on FTES:

Natalie Wagner California Community Colleges Chancellor's Office
1102 Q Street
Sacramento, CA 95825
(916) 327-1554

AEP legislation encourages the leveraging and braiding of other state and federal funding sources as stated in education code Section 84905 (b).

  1. The chancellor and the Superintendent, with the advice of the executive director, shall approve, for each consortium, rules and procedures that adhere to all of the following conditions: (b) As a condition of joining a consortium, a member shall commit to reporting any funds available to that member for the purposes of education and workforce services for adults and the uses of those funds.

AEP legislation goes on further to list the state and federal fund sources that are required to being a member of a consortium Section 84916.

  1. In order to maximize the benefits derived from public funds provided for the purpose of addressing the educational needs of adults and to ensure the efficient and coordinated use of resources, it is the intent and expectation of the Legislature that any community college district, school district, or county office of education, or any joint powers authority consisting of community college districts, school districts, county offices of education, or a combination of these, located within the boundaries of the adult education region shall be a member of a consortium pursuant to this article if it receives funds from any of the following programs or allocations:

(a) The Adults in Correctional Facilities program.
(b) The federal Adult Education and Family Literacy Act (Title II of the federal Workforce Innovation and Opportunity Act).
(c) The federal Carl D. Perkins Career and Technical Education Act (Public Law 109-270).
(d) Local Control Funding Formula apportionments received for students who are 19 years of age or older.
(e) Community college apportionments received for providing instruction in courses in the areas listed in subdivision (a) of Section 84913.
(f) State funds for remedial education and job training services for participants in the CalWORKs program

Note: AEP funds cannot be used to create an 18-22 year old certificate program for Special education students since service of those students by LEAs has been expected for years and districts only had LCFF money.

Any capital outlay (including building improvements, rental space, leases, construction, etc.) will be closely scrutinized. It will require that you notify the AEP Office of your consortium’s (including any member in that consortium) intent. This is an informational e-mail only. The AEP Office reserves the right to ask questions regarding any purchase and can prohibit any activity that it deems not meeting the reasonable and justifiable criteria.

The member must follow all state & local policies and procedures related to capital outlay. This would include district facilities approval, following procurement processes, and notification of state agency facility departments.

Regardless of whether you choose a fiscal agent or a direct funded structure, consortium must use their administrative funding to ensure that member fiscal information (budget, expenses, etc.) is valid. That may include, but not limited to, an outside audit, an agreed upon certification process, a peer-to-peer member review, a fiscal agent certification, or a combination of options (or other options). The consortium membership will determine how best to audit their members, and consortium level financial budgeting, and expenditure reporting. The 5% administrative cap for consortium oversight is established for that specific purpose.

Funds apportioned for the AEP program shall be used only for support of AEP program areas as described in this section. If a consortia or member would like to offer programs outside of the AEP defined program areas, it may do so with another fund source (if it is allowed by that fund source).

Consortia are required to complete an Out-of-State Travel Request Form and submit the form to the AEP Office for prior approval. Such travel must also be disclosed in the Annual Plan template, reported in the AB104 online grant budget, as well as in the expenditure & progress reports. Out-of-State Travel Request forms are posted on the AEP website under resources. In the request, consortia must explain how the approved travelers and the consortia will disseminate the information to other district staff, administrators, faculty, and teachers when they return. AEP TAP will be notified of Out-of-State Travel requests to attend conferences. By notifying AEP TAP of national conferences, it allows them to support a focused conference participation effort. In addition, AEBP TAP will follow up after the event on coordinated professional development offerings.

The state reserves the right to limit Out-of-State travel. See link to the travel form.
http://aebg.cccco.edu/Resources 

AEP TAP will work with the adult education professional agencies: ACCE, ASCA, CCAE, CCCAOE, etc. to obtain a list of AEP attendees. This will allow AEP TAP to find out what professional development is taking place around the state, and follow up after the event on coordinated professional development offerings.

No - noncredit courses are funded by state apportionment (FTES). If the next question is if they can leverage noncredit FTES (state apportionment) and WIOA II – that would go back to CDE.

No – fee based community college programs – called community service programs must be self-sustaining on fees only per education code and community college regulations.

Many community colleges do not combine credit & noncredit as the courses have different expectations centered around the rigor of work, the amount of homework, and the assignment of a letter grade in a credit class.

Both credit and noncredit departments are provided a supply budget. Many community colleges purchase books for noncredit students because these students cannot afford to buy them. This would be ok for a noncredit class to use AEP funds if the class is in one of the seven program areas.

As far as buying chromebooks for credit ESL students and using AEP funds to subsidize the purchase, we would recommend you look at using all other fund sources (credit, basic skills, and other fund sources) before using AEP funds. The consortium should ensure that the community college is using all other available resources before it uses AEP funds as these credit students are not being counted in the AEP enrollment and outcome numbers. You may make a case if these credit student were transitioning from an adult school or noncredit course – but to use AEP funds to purchase equipment for credit students that have no connection to AEP/adult education – would not be advisable.

They really should restructure the class if they want to use AEP funds to buy equipment.

It is unclear to the AEP Office how the field trip to the aquarium ties into the educational goals of the course or services ESL, ABE, CTE, AWD, or K12 Success students. If the school can make the connection to the educational goals, and the district support it - then it would be an allowable use of funds. Please let me know if you have any additional questions.

The AEP Office doesn’t set the rules on determining what is or what an expenditure isn’t. The AEP Office suggests you work that out with your accounting office. The close out for 15/16 funds is 2/25/18. So after the final report due 1/31/18. You have another short period of time to certify any additional expenses.

The AEP Office is fine with whatever you work out with your accounting office on the certification of expenses. We assume they follow their district/agency accounting processes & regulations.

There may be K12/CDE education code that covers this. Please refer over to CDE. There isn’t anything in AEP legislation that covers that question.

There should be some LCCF funding set aside to pay for K12 elementary & secondary teacher professional development as part of the LCAP in dealing with English Language Learners in the K12 system. However, if this was for an AEP K12 Academic Success program geared toward LEP parents and their children enrolled in the K12 system - then AEP funds could be used to pay for professional development for the adult school teachers ONLY.

Supportive services like HiSET are allowable provided they do not violate any existing state regulation or local policy/procedure of the member district. Also, any expense of AEP funds must be agreed to by members at a public meeting and included in your annual plan reflecting the three year vision of that effort. Also keep in mind that you have to follow your local district policy and procedures on how provide the stipend or support service to a student.