Finding Number: 2024-025 Finding Name: Inadequate Monitoring of 21st Century Subrecipients Finding Condition(s): The Illinois State Board of Education (ISBE) did not adequately monitor and document program monitoring procedures performed over subrecipients of the 21st Century Community Learning Cent...
Finding Number: 2024-025 Finding Name: Inadequate Monitoring of 21st Century Subrecipients Finding Condition(s): The Illinois State Board of Education (ISBE) did not adequately monitor and document program monitoring procedures performed over subrecipients of the 21st Century Community Learning Centers (21st Century) program. Additionally, ISBE’s internal controls over subrecipient on-site monitoring are not designed at an appropriate level of precision to ensure monitoring of subrecipients is completed, documented, and retained as required by ISBE’s policies and procedures. Name of Contact Person(s): • Jeffrey Judge, Director – Illinois State Board of Education, Wellness and Student Care Management Department • Nehemiah Ankoor, Supervisor; 21st Century Community Learning Centers (CCLC) State Education Agency Coordinator – Illinois State Board of Education, Wellness and Student Care Management Department Corrective Action(s): To ensure that 21st Century Community Learning Centers (21st CCLC) subgrantees’ progress and performance are monitored in accordance with 2 CFR 200.331(d), 2 CFR 200.331(b), and 2 CFR 200.303, Wellness and Student Care Management and the 21st CCLC team developed processes and structures to facilitate the procedures, protocols, and efficacy of subgrantee monitoring. Components of this work included, but were not limited to: • Evaluating and revising the program’s subgrantee risk analysis procedures and tools to ensure that they are relevant and accurately reflect the items/actions that suggest higher levels of subgrantee risk (2 CFR 200.331(b)). Complete. After careful examination, we have revised the risk analysis procedures and tools and have begun using them to inform our fiscal year 2026 monitoring. • Reviewing and revising the procedures and/or documentation that is collected for all three tiers of subgrantee monitoring to ensure that all processes are relevant; are not simply perfunctory; ensure compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that the subaward performance goals are achieved (2 CFR 200.331(d)). Complete. We have determined which of the documents we have historically collected meet those requirements, and we have evaluated all remaining documents (extraneous to ED requirements) to determine which we feel are most necessary to keep and what we are able to discontinue requiring. • Establishing and implementing specific processes and protocols to ensure that all components of subgrantee monitoring are timely, that management reviews and provides approval for key components of the process, and that accurate and complete documentation is produced and maintained (2 CFR 200.303). Complete. The expectations herein have been communicated to staff and have begun to be implemented (i.e. management approval, maintaining documentation, etc.). We still need to ensure that we precisely document these expectations and protocols, but through meetings and less formal communications, the required changes to our practices have been implemented. Proposed Completion Date: December 31, 2025 - Completed