I received a note from a colleague, working with an LEA, asking if there have been any audits by the US Department of Education (ED) finding LEAs out of compliance with the School Improvement Grant’s (SIG) terms and conditions. Apparently, the superintendent of this LEA is drastically changing how the grant is being implemented-to the point that the work being performed no longer resembles what was described in their application. My colleague advised the superintendent about needing approval before making significant changes to the project; the superintendent’s position is that no matter what he does, “they won’t take [the grant] away.”
Unfortunately, and realistically, the superintendent might be right (in his thoughts, not his actions). SIG funds are granted to SEAs that turn around and grant funds to LEAs through a competitive process. It’s on the SEAs to monitor the LEAs compliance. As we know, most SEAs have too few program staff to effectively monitor all of their grantees. Unless and SEA can regularly send people on site to compare an LEA’s application to their actual implementation, the SEAs rely upon annual progress reports to be an accurate reflection of the grant’s implementation. The US Department of Education conducts monitoring visits with the SEAs but ED will visit only a few of the larger LEAs for their on site focus groups and documentation reviews. Smaller LEAs fly under the radar; odds are changes will not be immediately discovered.
Just because one might not get caught, doesn’t justify one’s actions. Let’s assume the changes made by the superintendent above are permissible, his LEA still needs approval from the SEA before implementing the changes. Obtaining prior approval is not complicated. State and federal funders want to approve change requests when the change(s) benefit all parties (i.e., grantor, grantee and beneficiary). Take the extra step-a couple Emails, a couple phone calls-and receive prior approval when it’s required.
