Federal BEdA Reporting and Compliance
The federal government requires Basic Education for Adults programs to submit reports and meet compliance measures to ensure programs meet standards set forth by law and grant-providers.
Adult Basic Education is authorized and regulated in federal law as Title II of the Workforce Investment Act (WIA), generally referred to as the Adult Education and Family Literacy Act of 1998. Federal policy related to the funding and carrying out of the law is delegated to the U.S. Department of Education, Office of Vocational and Adult Education.
The Workforce Innovation and Opportunity Act replaces the Workforce Investment Act (WIA) as the federal law reauthorizing and regulating basic adult and literacy education. Adult education continues to be detailed in Title II: Adult Education and Literacy.
The law was signed July 22, 2014 and took effect July 1, 2015. Implementation is guided by the Department of Education and the Department of Labor.
The NRS is the federal reporting project for WIOA Basic Education for Adults programs managed by the American Institutes for Research (AIR). It is an outcome-based reporting system for state-administered, federally funded adult education programs, and in Washington State this includes Correctional Education programs. The impacts of instruction are measured through the use of valid and reliable standardized assessments. The data collected from these standardized assessments are aggregated and reported yearly to the Office of Career, Technical, and Adult Education (OCTAE) through the NRS. This data includes student demographics, schooling and employment status at intake, periods of participation, educational gain, and transition beyond BEdA. Public access to annual federal reports by state are available on the OCTAE-NRS reporting website.
The LACES (Literacy, Adult and Community Education System) online application helps organizations report data for Basic Education for Adults (BEdA) programs. The application and its relational database were created to meet all state and federal data collection, review, and reporting requirements. Federal Reports may be viewed quarterly at the program level in LACES.
BEdA-SBCTC is required to submit annual reports to the Department of Education (DOE) to comply with reporting requirements for active Adult & Family Literacy programs. These statistical, narrative, and fiscal reports are required by Title II of the Workforce Investment Act. Each program must submit a narrative report (including a Financial Status Report) and a completed Data Quality Checklist in September each year. Statistical data are collected from each program in WABERS+ throughout the year and are aggregated at the state office to be reported to DOE.
Guidance on Career & Training and FFR completion
The Adult Education and Family Literacy Act (AEFLA), the Adult Education section of WIOA, makes accountability for student results a central focus, setting out new performance accountability requirements for state and local programs that measure program effectiveness on the basis of student academic achievement and employment-related outcomes.
BEdA-funded providers set annual performance targets based on negotiated state performance targets with OCTAE. Providers that do not meet a target but achieve at least 90% of it, will create a program improvement plan to submit with their end of year federal report and BEdA staff will follow up to provide technical assistance. Any provider not meeting at least 90% of a target for two consecutive years will complete a corrective action plan and participate in additional technical assistance and performance monitoring.
Maintenance of Effort (MOE) is calculated on the previous years’ non-federal expenditures and reported in the annual year-end report to SBCTC each year. SBCTC must demonstrate to the federal government that the total statewide expenditure of non-federal funds for basic skills programming is the same each year as in prior years. If SBCTC were not able to demonstrate that the state of Washington was maintaining the same fiscal effort as before, the SBCTC would permanently lose part of its federal Adult Education and Family Literacy Act allocation. If that were to happen, the reduction in federal Basic Education for Adults (BEdA) funds would be covered by reducing the grants to local BEdA providers which had reported reduced expenditures.
At fiscal year-end, all grant recipients are required to complete a Financial Status Report (FSR) to include all federal BEdA and non-federal resources used to support this program.
Maintenance of effort is not the same as required matching funds. See Match section for more information.
Federal grant funds must supplement and not supplant state or local public funds of the agency. Federal funds may not result in a decrease in state or local funding that would have been available to conduct the activity had federal funds not been received. In other words, federal funds may not free up state or local dollars for other purposes but should create or augment programs to an extent not possible without federal funds.
BEdA grantees must provide a non-federal contribution in an amount equal to 25 percent of the total amount of funds expended for adult education and literacy activities supportable by the WIA Act, Title II. Match can be in the form of cash or in-kind (fairly evaluated) and shall include only non-federal funds used for adult education and literacy activities that are consistent with the purposes of the Adult Education and Family Literacy Act (AEFLA). Examples for Calculating Minimum Match
$75,000 grant award amount x 1/3 = $25,000
OR
$75,000 grant award amount ÷ 3 = $25,000
A BEdA provider with a $75,000 grant award must spend at least $25,000 from non-federal matching funds on adult education and literacy activities. This means a total of $100,000 must be spent: 75 percent from the grant and 25 percent from non-federal matching funds.
In grant applications, grantees must describe how their 25 percent matching funds will be spent. Grantees do not need to explain how their entire maintenance of effort funding will be spent in the grant application.
BEdA grant recipients must complete time and effort reports for all faculty or staff who are compensated, in whole or in part, by a federal grant or whose efforts are used to satisfy a required or voluntary match for a federal grant. Time and effort reports are after-the-fact reports that reflect how faculty or staff spent the time for which they were compensated at the college or Community Based Organizations.
For complete information and requirements, see the College Time and Effort Reporting Guidelines.
BEdA monitors and evaluates all BEdA providers through Program Review and Technical Assistance Visits and desk audits in a regular rotation.
Our program review process is designed to meet the requirements described in the Workforce Investment and Opportunity Act (WIOA) and the Adult Education and Family Literacy Act, the National Reporting System (NRS), our Washington State Adult Education 4-year Plan 2020-2023, the BEdA Master Grant, and other state compliance requirements for providers receiving funding from SBCTC – Basic Education for Adults (BEdA).
The fiscal monitoring for Basic Education for Adults grants follow the guidance as presented in 2 CFR Part 220 (OMB Circular A-21), OMB Circular A-110, OMB Circular A-122, OMB Circular A-133, SBCTC College Time and Effort Reporting Guidelines, March 2004 State Board Resolution 04-03-03, WAC 131-28-026 (4)(a), and applicable grant program and fiscal guidelines.
Fiscal audits conducted by SBCTC will review and ensure that:
- Every expenditure is substantiated by documentation and a well-defined audit trail that reflects the expenditure and its relationship to the approved grant budget(s).
- All state, federal, and program rules and regulations have been followed when making expenditures and procuring equipment.
- All salaries charged to a federal BEdA grant or funding sources used as match for a federal BEdA grant are substantiated by time and effort documentation.
- The organization has policies and procedures that govern the administration of all grants, including the issuance of tuition waivers. The organization must document the criteria used in determining the decision to issue tuition waivers.
- Maintenance of effort (MOE) is essential to ensuring that the state in general is not penalized for not keeping up its spending effort on adult education programs.
Note for Community Based Organizations (CBOs)
In compliance with OMB Circular A-133, CBOs that expend $500,000 or more in federal awards from all sources within a fiscal year, there is an additional audit requirement. If there is a finding related to federal funds passed-through from the SBCTC on the CBO’s Single Audit, the CBO must submit a copy of the audit report to SBCTC within nine (9) months following the audit period.