Finding 2025-063 Special Education Cluster (IDEA), ALN 84.027 and 84.173 Management Views MDE disagrees with the finding. MDE maintains that its current monitoring approach satisfies federal requirements. The MDE Office of Special Education’s (OSE) monitoring framework is consistent with the risk-ba...
Finding 2025-063 Special Education Cluster (IDEA), ALN 84.027 and 84.173 Management Views MDE disagrees with the finding. MDE maintains that its current monitoring approach satisfies federal requirements. The MDE Office of Special Education’s (OSE) monitoring framework is consistent with the risk-based requirements of the Uniform Guidance (2 CFR 200.332). The Uniform Guidance does not require routine review of underlying supporting documentation for every subrecipient in every monitoring cycle. Rather, source documentation review is one available monitoring tool, which MDE OSE uses, when warranted, based on risk, audit results, identified concerns, or other relevant information. MDE OSE’s monitoring activities include budget review and approval, budget-to-actual analysis, review of expenditure activity, direct engagement and technical assistance with subrecipients, review of single audit reports, issuance of management decisions (when applicable), and enhanced review procedures for higher-risk subrecipients. These activities collectively provide reasonable assurance that funds are used for authorized purposes and in compliance with applicable requirements. MDE OSE also notes that subrecipient single audits have not routinely identified questioned costs or significant noncompliance, which supports the effectiveness of the existing monitoring framework. Planned Corrective Action MDE disagrees with the finding and does not believe corrective action is required to resolve noncompliance. However, MDE OSE will update its internal monitoring procedures to document the circumstances under which expenditure sampling may be performed for medium- and low-risk subrecipients to enhance clarity of MDE OSE procedures. Anticipated Completion Date September 30, 2026 Responsible Individual(s) Sean McLaughlin, MDE