Requirements for Federally-funded
Comprehensive Programs and Subcontractors

Background

The Division of Adult Education awards federal dollars to providers through the Adult Education and Family Literacy Act (P.L. 105-220), Title II of the Workforce Investment Act of 1998. These dollars are awarded competitively to programs that offer adult education services or instruction below the post-secondary level to individuals who are 16 years of age, out of school, and lack sufficient mastery of basic educational skills to function effectively in society.

In Indiana, grants are made to 42 programs representing areas that approximate vocational districts as outlined in the 2000-04 Indiana State Plan for Adult Education and Family Literacy. The Department of Correction is also an award recipient. To ensure adequate coverage, a comprehensive program, may elect to fund another provider, a subcontractor, to offer educational services in the district not covered by the comprehensive program.

Comprehensive programs are expected to offer a full range of adult education services. Instruction covers adult basic and secondary education, including literacy, English to speakers of other languages (ESOL), GED preparation, secondary credit completion, and academic upgrading.

The requirements listed in the next section are effective July 1, 2005 through June 30, 2006, for comprehensive programs that elect to subcontract with other providers to offer adult education classes in the same district.

Requirements Effective July 1, 2005

1. Comprehensive programs in Indiana are responsible for administering federal dollars under the Adult Education and Family Literacy Act.

2. Cooperative and financial agreements between comprehensive programs and subcontractors must be on file with the Division of Adult Education. The term of the agreements, plus the scope of services and responsibilities between both programs must be included. Additionally, agreements must spell out financial arrangements and payment timelines to subcontractors, plus minimally contain signatures of agency heads as well as directors of adult education.

3. Comprehensive programs must make regular and timely disbursements to subcontractors as indicated in the cooperative and financial agreements.

4. Combined budgets are required for comprehensive programs that elect to use subcontractors. Subcontractors may be listed as "purchased services" in approved budgets. However, the comprehensive program must maintain an individual budget listing the separate line items for the subcontractor.

5. Changes greater than 10 percent in the approved federal budget must be submitted to the Division of Adult Education by comprehensive programs for approval. Changes in line items by subcontractors must be submitted to comprehensive programs for approval. While budget modifications may be submitted at any time, the last date for submissions in a program year is April 15.

6. The directors of adult education for comprehensive programs and subcontractors must meet individually at least two times during the program year to discuss goals, performance, and outcomes. The meetings may coincide with regional coordinating council dates. Comprehensive programs must notify subcontractors of the meetings in advance. Subcontractors are expected to be participating partners in all meetings.

7. Comprehensive programs are responsible for inviting subcontractors to assist with grant proposals. Grant opportunities and other announcements by the Division of Adult Education will be routinely sent to comprehensive programs and subcontractors when cooperative and financial agreements are on file. Comprehensive programs are responsible for sharing proposals and all signed documents generated by the Division of Adult Education with subcontractors.

8. The reporting process presents special challenges to comprehensive programs and subcontractors. Comprehensive programs and subcontractors will receive notification from the Division of Adult Education when performance and incentive awards are made. The notification will include the amount assigned to each provider for performance. Comprehensive programs must submit budget modifications for these awards in accordance with #4 above.

9. Subcontractors must submit federally-funded reports to comprehensive programs according to timelines established by the grantees. Except for final reports, comprehensive programs may submit separate reports for both programs. For final reports, however, comprehensive programs are required to submit three separate reports to the Division of Adult Education by the announced due dates. Below is an example.

A subcontractor submits an initial final or final annual performance report to the comprehensive program. The comprehensive program then submits three reports to the Division of Adult Education.

a. Subcontractors' initial final or final annual performance report
b. Comprehensive program initial final or final annual performance report
c. Combined report

(The combined initial final and final annual performance reports may be created by hand from i-STAR. Comprehensive programs and subcontractors may submit i-STAR diskettes/transmissions individually.)

The same process will be followed for all final reports. This includes the final cumulative quarterly report, which may also be created by hand from i-STAR, final fiscal report, itemization of local expenditures, final equipment inventory, institutionalized adults served, and local program survey report form.

10. Comprehensive programs and subcontractors must individually submit to the Division of Adult Education on July 31 a one-page narrative covering three points. Also, include in the narrative a brief summary of the two meetings as outlined in No. 6.

a. What is going well with the current relationship between the comprehensive program and subcontractor?
b. What issues or problems in the relationship have you encountered as a comprehensive program or subcontractor?
c. What ways can you strengthen the current relationship?