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of 3 March 2014 Minutes

Early Learning Coalition of Brevard County, Inc.

Minutes: Board of Directors Meeting Date/Time: Tuesday, March 18, 2014 at 4:00 p.m. Location: Early Learning Coalition 1018 Florida Ave, Rockledge, FL 32955 Members Present: Terri Barlow, Cathy Beam, Alan Bergman, Susan Bragonje, Marci Brilley, Mark Broms,

Bridget Chiuchiolo, Priscilla DeNino, Lori Duester, Ian Golden, Nancy Grzesik, Jeffery Harrison, Beth Mills, Mica Layne, Tom Peer, Althea Puzio and Myrna Shimei

Excused Absent members: Mike Durante, Paul Hilburn, and Natalie Jackson

Unexcused Absent Members: N/A Staff Present: Sky Beard, Ann Beecham, Jessica Beecham, Gwen Hertlein-Haber, Sue Falcioni, LaShaundra

McGhee, and Cathie Odom Guest/Public: N/A

Called to order: Alan Bergman called the meeting to order at 4:08 p.m. Introductions were conducted. Quorum was established before approval of the consent items.

Agenda Item Summary/Discussion Action/Follow-up Consent Items

a. Minutes: February 18, 2014 b. Directors Report c. Office of Early Learning Budget Summary d. Governor’s Press Release e. OEL Accountability Monitoring Report of ELC of

Brevard

Tom Peer motioned for the Consent Items to be approved. Susan Bragonje seconded the motion. The motion passed unanimously by all Board members.

Committee Reports:

Executive/Finance Committee:

• Committee Membership

Alan Bergman request that Sky Beard report to the Board that the Executive/Finance Committee met on March 10, 2014 meeting agenda Items included:

o To be discussed under Revisions to Bylaws • Addition of new Board Chair to accounts

o Alan Bergman was added to all BankFIRST accounts

• Strategic Planning follow up o To be discussed under Strategic Planning

Following Up • De-ob Letter to OEL

o Alan Bergman signed the letter to be sent to OEL regarding the Board approved de-obligated amount of $800,000

• OEL Accountability Reports o The Committee reviewed the Management

Addendum to Accountability Report AS13-14 • Related Party Transactions Policy update

o The Committee reviewed the updated Related Party Transactions policy

Old Business Finance Report and Waiting List/New Enrollment Update:Cathie Odom reviewed with the Board the Utilization Reports and Graphs (see attached). Currently funds are underutilized, but enrollment numbers are up. The reports do not reflect the Board approved changes to enrollment or the amount to de- obligated to OEL.

No Action/Follow-up Required


Gwen Hertlein-Haber reported to the Board that as of March 18, 2014 there are about 788 children on the waitlist. Preliminary Waitlist Documentation Statistics were reviewed with the Board (see attached). Legislative Update:

Sky informed the Board that the Early Learning House bill has been submitted, but at this time, there is not a corresponding Senate bill at this time. However, the committees are meeting this week to discuss the bill.

Strategic Planning Following Up: Finalize Key Result Areas and Priorities

After some discussion, it was decided that the Community Collaboration will no longer be a committee, but a major component of both the Parent Education and Diversified Funding key result areas. Mica Layne will be on both committees.

: Sky supplied the Board with a handout of the feedback of the recommendations and timeline of the Key Results areas (see attached). Althea Puzio reviewed the submitted timeline of the Quality Initiative area. Nancy Grzesik reviewed the handout created of the Board Members and all positions (see attached). Nancy asked that all member email Sky with “how they can contribute” to the Board.

Fraud Update:

Sky informed the Board that at this time OEL is currently working on creating a template for all policies and procedures. The Board will be kept up to date of the progress of this form.

New Business VPK Readiness Rates:

Sky presented the Board with a PowerPoint regarding the VPK Readiness Rates just released (see attached). Sky informed that Board that only 16 of the VPK providers in Brevard received scores under 70%; only 8% are Providers on Probation. There was much discussion of the different factors of the test used to determine the VPK Readiness Rates.

Fiesta Brevard: Sky informed the Board that the 10th

annual Fiesta Brevard would be on Friday, April 25, 2014. More information will be emailed out to the Board.

CDBG Funding:

• City of Titusville – Award not yet announced

Sky reported to the Board the current status of the different CDBG funding updates:

• City of Cocoa – $7670 awarded • City of Melbourne – $12,000 awarded • City of Palm Bay – $13,500 awarded • Brevard County – Application not yet released


March 2014 Board of Directors Minutes Approved: Respectfully Submitted, Approved

__________________________________ _________________________________________

Signature Date Signature Date Executive Coordinator Executive Director

Revisions to Bylaws:

“5.2.5 In the event that any office of the Executive Committee (Chairman, Vice-Chairman, Treasurer, Secretary) becomes vacant and is seated with an interim position, the interim position is to be maintained as an officer until the next annual election, or until deemed necessary by a majority vote, at which time a new member may be elected.”

The Bylaws were revised after some discussion at the Executive/Finance Committee regarding the interim Board positions. The change was to the following:

Mica Layne motioned for the approval of the revised Bylaws. Marci Brilley seconded the motion. The motion passed unanimously by all Board members.

Board Updates Providers:

Priscilla Denino wanted to thank Coalition staff for the email regarding the availability for providers to have a table at the VPK round ups. Also, asked for some clarification of what a mandatory meeting is and what to do if a provider is not able to make the meetings. If a provider is not able to make it to a mandatory meeting, they need to contact the Coalition.

Bridget Chiuchiolo informed that Board that her last meeting will be in May; she is leaving her current provider and will be working at a provider that is not contracted with the Coalition. Licensing:

No Action/Follow up Required

Tom Peer passed out a flyer from the American Academy of Pediatrics with recommendations about baby sleeping. In addition, Tom informed the Board that DCF will be emailing the providers in regards to the necessary USDOT number required when transporting children in a nine or more passenger van.

Public Comment

Lori Duester informed the Board of the World’s Greatest Baby Shower that will be held on May 3, 2014 in Titusville. Sky presented Bridget Chiuchiolo with a certificate for attending the Rollins Certificate in Board Orientation in July 2013.


Adjournment The meeting was adjourned at 5:31 p.m.

Next Meeting April 15, 2014

Board of Directors Meeting Tuesday, March 18, 2014 4:00 pm

AGENDA

I. Call to Order

II. Coalition Roll Call by Self Introduction

III. Consent Items a. Minutes: February 18, 2014 b. Director’s Report

c. Governor’s Press Release d. OEL Accountability Monitoring Report for ELC of Brevard

IV. Committee Reports a. Executive / Finance Committee

V. Old Business

a. Finance Report and Waiting List/New Enrollment Update b. Legislative Update c. Strategic Planning Follow Up: Finalize Key Result Areas

and Priorities d. Fraud Update

VI. New Business

a. VPK Readiness Rates b. Fiesta Brevard c. CDBG Funding d. Revision to Bylaws

VII. Board Updates

a. Providers b. Licensing

VIII. Public Comment

IX. Adjourn

Next Meeting: April 15, 2014

EARLY LEARNING (OALITION

OF BREVARÞ (OUNTY, IN(Board of Directors Meeting

Tuesday, February L8,2OL4 at 4:00 p.m.

Early Learning Coalition 1018 Florida Ave, Rockledge, FL 32955

Terri Barlow, Cathy Beam, Alan Bergman, Susan Bragonje, Mark Broms, Priscilla DeNino,

Mike Durante, Nancy Grzesik, Jeffery Harrison, Paul Hilburn, Mica Layne, Beth Mills, Tom

Peer, Althea Puzio and Myrna ShimeiMarci Brilley, Bridget Chiuchiolo, Lori Duester, and Mike Durante

lan Golden and Natalie Jackson

Sky Beard, Ann Beecham, Jessica Beecham, Kevin Carraro, Dennise Corder-Sarnese,

Michelle Dockery, Chris Donato, Gwen Hertlein-Haber, Sue Falcioni, Cathie Odom and

Jennifer ShieldsN/A

Nancy Grzesik called the meeting to order at 4:O4 p.m. lntroductions were conducted.

Quorum was established before approval of the consent items.

'rfNUtES:

'AlEtTll:llÊ.:LO(ATION:

IIEIIBERS PRESENT:

Ð((USED ABSENT MEMBERS:

UNÐ((USED ABSENT MEIVItsERS:

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(ÂtIEÞ TO ORDER:

AGÉIDA ITEIII suìüilARY/Drs(rJ9gqr A(TION/FOIIOW.UP

Consent ltems a. Minutes: January 2I,2OI4b. Directors Reportc. Office of Early Learning Budget Summary

Tom Peer motioned for the ConsentItems to be approved. Althea Puzioseconded the motion. The motionpassed unanimously by all Boardmembers.

Executive/Finance Committee: Nancy Grzesik reported to theBoard that the Executive/Finance Committee met on FebruaryLO,2013 and February 18,2OI4.February meeting agenda ltems included:

¡ Audit Reporto An extension for the 990 has been filed and will be

done once the audit report is received andreviewed.

¡ ELCB Credit Card Policyo Coalition staff will be making recommended

changes and will bring to the full Board for finalapproval

o Previous Board Chair name removal from all BankFirst

accountso Remainder of fiscal year options

o The Committee recommends the following to theBoard for approval

. Being enrollment of siblings from the waitinglist, up to 6th grade, when there is an eligiblebirth to 5 year old child.

. A provider reimbursement rate increase ofabout 5%; subject to OEL approval

. 5800,000 de-obligation back to OEL to be used

by other Coalitions in need of fundsAfter discussion, the board voted to approve therecommendation from the Executive/Finance Committee.

Tom Peer motioned for theapproval of the enrollment ofsiblings from the waiting list, up to6th grade, when there is an eligiblebirth to 5 year olds child; a providerreimbursement rate increase ofabout 5%, subject to OEL approval;and the s800,000 de-obligationback to OEL.

Myrna Shimei seconded themot¡on. The motion passed

unanimously by all Board members.Priscilla Denino, For-profit ProviderRepresentative and Beth Mills,Brevard Public SchoolsRepresentative abstained from thevote (see attached Form 8B).

Committee¡ports:

PaRe I of3 Februarv 2014 Minutes

Old Business Audit Presentation: Cathie Odom, Director of Business

Operations, introduced Ed Moss from Moss Krusick and

Associates LLC. Ed Moss reviewed the Early Learning Coalitionof Brevard County, lnc. Financial Statements and

Supplemental lnformation with the Board (see attached).Cathie informed the Board that the Coalition's 990 will be sentto the Board via emailfor review.

Finance Report and Waitins List/New Enrollment Update:Cathie Odom reviewed with the Board the Utilization Reportsand Graphs (see attached). The required mat amount is

projected to be met this fiscal year.

Legislative Update: Sky Beard, Executive Director, reviewed a

PowerPoint presentation regarding legislative updates withthe Board (see attached). The House Education Committee has

filed PCB EDC 14-01 the draft will be emailed out to the Boardfor review. Sky will continue to keep the Board posted on anyupdates.

Stratesic Plannins Followine Up: Committee Reports:

The Champions of the Key Result Areas reviewed the notes

from the Committee Assessment Relays that took place at the

January Board meeting (see attached).

Nancy asked that each of the Board members come to the

March Board meeting prepared to discuss the following:¡ Recommendations for combined committees

o Champions next steps and timelines

Fraud Update: There are no updates at this time

No Action/Follow-up Required

New Business lntroduction of the new Chairman of the Board: NancyGrzesik, the current lnterim Board Chairman, introduced AlanBergman, the newly Governor Appointed Board Chairman. Mr.Bergman introduced himself and provided backgroundinformation.

School Readiness Elisibilitv Processes: Sky and Gwen Hertlein-Haber, Director of Program lnitiatives, reviewed the updatedSchool Readiness (SR) priorities with the Board after receivingguidance from OEL.

ln regards to the SR eligibility priorities for families alreadyenrolled in services, Michelle Dockery, Family Services

Administrator, explained to the Board the process used for at-risk children with a DCF Protective lnvestigation (Pl) referralun. Currently, the families that receive a DCF Pl referralreceive only two months of SR services and do not transfer toanother funding group. With DCF's new discussion makingmodel the DCF investigators will be spending more time withthe families to determine the safety of the child and if a

referral is truly necessary. Coalition staff is recommending a


Mark Broms motioned for theapproval of families that havereceived services on a DCF Pl

referral (Priority ll.1) and meeteligibility requirements to be

transferred to the economicallydisadvantaged funding category(Priority lll.1) when the two-monthreferral ends, if the wait list has athree (3) month or less waitingperiod. Susan Bragonje seconder'the motion. The motion passed ,/unanimously by all Board members.

Pase 2 of 3 Februarv 2014 M¡nutes

change to the current SR rollover process to allow familiesthat have received services on a DCF Pl referral (Priority ll.1)

and meet eligibility requirements to be transferred to theeconomically disadvantaged funding category (Priority lll.1)when the two-month referral ends, if the wait list has a three(3) month or less waiting period.

Board Updates Providers: Priscilla Denino, For-Profit Provider Representative,informed the Board that providers have voiced concerns

about VPK registration and they feel the providers "hosting"the round-ups may have an advantage. Priscilla inquired if anyproviders are allowed to attend the round-ups to representtheir centers. ln addition, providers have questions aboutMandatory Provider meetings and what is classified as

"mandatory."

Licensins: N/A


PublicComment

N/A No Action/Follow up Required

Adjournment The meeting was adjourned at 5:55 p.m

Next Meeting March 18,20L4

February 2Ot4 Board of Directors Minutes Approved

Respectfully Submitted,

S Date

Executive Coordinator

Approved

SignatureExecutive Director

Date

Paee 3 of 3 Februarv 2014 Minutes

Director’s Report March 2014

State and Office of Early Learning (OEL) Update:

• Sky Beard attended a series of meetings in Tallahassee on March 6 - 7, 2014. Meetings consisted of the Association of Early Learning Coalitions and the Executive Directors’ meeting with OEL staff. On March 7, Sky Beard and Alan Bergman attended the Early Learning Advisory Council (ELAC).

• The Office of Early Learning is moving forward with rule promulgation in a few key areas. A rule workshop was held on February 26, 2014 to obtain input on the School Readiness curriculum approval process. A workshop regarding the required Fraud Plan to be submitted by Coalitions has been scheduled for March 20. A workshop has not yet been noticed for the School Readiness Provider Contract.

• ELC of Brevard will be involved in a fiscal monitoring conducted by Carr, Riggs and Ingram the week of March 31, 2014. The Office of Early Learning contracts with CRI to conduct an annual onsite fiscal monitoring of Coalitions.

Coalition Update:

• ELC staff is awaiting a new trial period for the alleged child care provider fraud case.

• The Coalition hosted its 5th Annual Child Care Provider Conference on February 21 – 22 at the Hilton Rialto in Melbourne. Feedback from those that attended was positive and the conference was well attended. On Friday, 91 owners and directors attended the conference. On Saturday, 157 early learning professionals attended as well.

• The Coalition has submitted its application to United Way of Brevard through the annual allocation process. Local funding from United Way is applied to the Coalition’s required match amount. ELC will be participating in a site visit and presentation to the allocation panel on April 29, 2014.

• The Coalition’s Leadership Team will be participating in a professional development

session on March 20, 2014 centered on the topic of performance management and coaching. The training will be conducted by an outside facilitator and will provide support to the Leadership Team in these important areas. The Coalition has made this a priority area the last few years and tremendous growth has been seen in the performance management process.

• Sky Beard and Jennifer Shields, Provider Services Administrator will be attending a Quality Supports Symposium in Tampa on March 27, 2014. Hosted by the ELC of Hillsborough, the symposium is designed to share best practices and the most recent research in the area of technical assistance and quality enhancements related to the field of early learning.

file:///U|/...rd Meetings/March 2014/GOVERNOR RICK SCOTT TOUTS CONTINUED VPK GAINS AMONG FLORIDA'S YOUTH.htm[3/12/2014 11:00:01 AM]

From: Cynthia Sucher [[email protected]]

Sent: Saturday, March 08, 2014 9:21 AM

To: Coalition Chairs; Coalition Executive Directors

Subject: GOVERNOR RICK SCOTT TOUTS CONTINUED VPK GAINS AMONG FLORIDA'S YOUTH

From: Governor's Press Office [mailto:Governor'[email protected]] Sent: Friday, March 07, 2014 4:52 PMSubject: GOVERNOR RICK SCOTT TOUTS CONTINUED VPK GAINS AMONG FLORIDA'S YOUTH

For Immediate Release March 7, 2014

Contact: [email protected]

(850) 717-9282

GOVERNOR RICK SCOTT TOUTS CONTINUED VPK GAINS AMONG FLORIDA’S

YOUTHReport demonstrates 10 percent increase in VPK readiness over five years

Tallahassee, Fla. – Today, Governor Rick Scott highlighted a report that shows for the fifth consecutive yearFlorida students who completed the Voluntary Prekindergarten (VPK) Education Program were betterprepared for kindergarten than those who only attended part of the program or did not participate in VPK atall. Governor Scott’s 2014-15 “It’s Your Money Tax Cut Budget” calls for investing more in VPK. This wouldbe the first increase in the VPK student allocation in three years. Governor Scott said, “This kind of year-after-year improvement among Florida’s children shows the resultsof focusing on factors that help young child learn what they need to know to be ready to start kindergarten. Icongratulate Florida’s early childhood educators for their hard work and am proud to recommend an increasein funding to boost in the base student allocation by $100 per child for both the school-year and summerprograms.” Florida ranks first in the nation with regard to prekindergarten access. Close to 80 percent of Florida’s four-year-olds—more than 174,000 children—were enrolled in VPK in the 2012-13 program year. The program isfree for children who are Florida residents and will be 4 years old by September 1 of the year they wouldenroll. Shan Goff, executive director of the Office of Early Learning, said, “Florida is a leader in early learning; weoffered four-year-olds universal access to prekindergarten ahead of other states. More importantly, we areproving this commitment works as the percentage of children completing VPK who are ready forkindergarten continues to rise each year.” The results of the 2013 Florida Kindergarten Readiness Screener (FLKRS) showed that almost 82 percent ofchildren who completed a VPK program were ready for kindergarten, compared to about 53 percent of thosewho did not participate in VPK. Florida’s children who attended some VPK fared better than those who didnot attend at all. Approximately 66 percent of those who attended some VPK were kindergarten-ready.

mailto:[email protected]

file:///U|/...rd Meetings/March 2014/GOVERNOR RICK SCOTT TOUTS CONTINUED VPK GAINS AMONG FLORIDA'S YOUTH.htm[3/12/2014 11:00:01 AM]

Public schools are required to give FLKRS to children within the first 30 days of kindergarten. Privatekindergartens may choose to participate. Screening results help kindergarten teachers plan how they teachin their classrooms. The results are also used to calculate VPK provider kindergarten readiness rates.Beginning with the 2010-11 year, the state adopted 70 as the minimum acceptable readiness rate for a VPKprovider, indicating that 70 percent of that provider’s students who substantially completed the programscreened ready on FLKRS.

2013 Florida Kindergarten Readiness Screener (FLKRS)

###

Part of the Florida Department of Education, the Office of Early Learning administers Florida’s VoluntaryPrekindergarten Education, School Readiness, and Child Care Resource and Referral programs through 30 localearly learning coalitions to ensure Florida’s children are emotionally, physically, socially and intellectually preparedto enter school and ready to learn. More than 350,000 children from birth to school age are enrolled in voluntaryprekindergarten and school readiness programs in Florida. To learn more, visit www.FloridaEarlyLearning.com orcall 850-717-8604.

http://www.floridaearlylearning.com/

250 Marriott Drive, Tallahassee, Florida 32399

Telephone: (850) 717-8550 Fax: (850) 921-0026 Toll Free Line: 1-866-FL-Ready (357-3239)

www.FloridaEarlyLearning.com

An equal opportunity employer/program. Auxiliary aids and services are available upon request to individuals with disabilities. All voice telephone numbers on this document may be reached by persons using TTY/TDD equipment via the Florida Relay Service at 711.

STATE OF FLORIDA GOVERNOR RICK SCOTT

DEPARTMENT OF EDUCATION COMMISSIONER OF EDUCATION

PAM STEWART

OFFICE OF EARLY LEARNING

(850) 717-8550

EXECUTIVE DIRECTOR

SHAN GOFF

DEPUTY DIRECTOR OF

OPERATIONS STEPHANIE L. GEHRES, CPA

PROGRAM INTEGRITY MANAGER

REGINAL WILLIAMS

REVIEW SUPERVISOR

ANDREA WARD

REVIEW TEAM LEAD

JUNIOR TAIT

REVIEW TEAM

ROYAL LOGAN

LORA LEE-TURNER

SHEILA NOBLES

ANDREA BARBER

WRITER

CATHERINE ALTMAIER

RENEE LISS

REPORT AS13-14.01

JANUARY 2014

ACCOUNTABILITY MONITORING REPORT FOR THE

EARLY LEARNING COALITION OF BREVARD COUNTY

The Florida Department of Education’s Office of Early Learning (OEL)

conducted an early education and care accountability review for the Early

Learning Coalition of Brevard County (the Brevard Coalition, the coalition).

The coalition is incorporated as a not-for-profit organization, which is tax

exempt under 26 USC s. 501(c)(3).

All early learning service providers who expend state and federal funds shall

operate early education and care programs in a manner that complies with state

and federal rules, regulations and laws. The team conducted the review to

ensure the coalition’s overall administration and implementation of early

learning programs (Coalition Governance (CG), Operations and Program

Management (OPM), Educational Services Delivery (ESD), Data Accuracy

(DA), School Readiness (SR), Voluntary Prekindergarten (VPK), and Child

Care Resource and Referral (CCR&R)) meets or exceeds service delivery and

operational requirements.

The onsite and desk review occurred on Sept. 30, 2013, through Oct. 2, 2013.

The accountability review team examined files and documentation for services

the coalition delivered from April through June 2013 and the coalition’s

operations from July 1, 2012, through Sept. 30, 2013.

In this report, a YES indicates a criterion that complies with the review

requirements, a NO indicates a criterion that does not fully comply with

requirements and N/A indicates a criterion that OEL did not review or did not

apply to the reviewed coalition.

The Early Learning Grant Agreement requires the coalition to take corrective

actions for each NO response. The report notes corrective action examples to

help the coalition effectively deliver program services.


Early Learning Coalition of Brevard County

Report AS13-14.01

Page 2 of 32

I. Authority

Federal and Florida laws, rules and regulations mandate that OEL administer early learning programs in Florida, as

well as monitor and evaluate each coalition’s performance in administering the early learning programs and

implementing the coalition’s SR plan (Title 45, Code of Federal Regulations (CFR); ss. 98.1(b)(6), 1002.82(2)(p) and

1002.75(1), Florida Statutes (F.S.)). The monitoring and performance evaluations must include, at a minimum, onsite

monitoring of a coalition’s finances, management, operations and programs. OEL may also identify best practices for a

coalition to improve the outcomes of the early learning programs.

II. Scope and Methodology

OEL developed performance criteria to provide a framework for measuring a coalition’s effectiveness in implementing

early learning programs. The performance criteria include indicators about compliance with federal and state laws,

rules and regulations to assist the coalition in maintaining high quality in CG, OPM, CCR&R, ESD, SR eligibility,

VPK child eligibility (VPKC), VPK provider eligibility (VPKP), SR payment validation (SRPV), VPK payment

validation (VPKPV) and DA.

Coalitions/statewide contractors that OEL reviewed during FY 2012-2013 for compliance with the now repealed

Chapter 411.01, F.S., will receive modified desk reviews for FY 2013-2014. This will include file samples for SR and

VPK child eligibility and payment validation, VPK provider eligibility and DA to validate the coalition implemented

House Bill (HB) 7165 SR and VPK requirements enacted on July 1, 2013.

For FY 2013-2014, OEL will conduct an onsite review of all performance criteria (full accountability review) for

coalitions/statewide contractors with services delivered in-house that OEL did not review during FY 2012-2013. OEL

will conduct a full desk review for coalitions/statewide contractors with contracted services that OEL did not review

during FY 2012-2013. This review will consist of all performance criteria and validating the coalition’s subrecipient

monitoring for SR and VPK child eligibility and payment validation and VPK provider eligibility. OEL will conduct a

full accountability onsite review for coalitions that OEL did not review during FY 2012-13 that deliver services both

in-house and via contract. The 2013-2014 accountability review period will occur from July 2012 through each

coalition’s review commencement month.

OEL conducted a full accountability review for the ELC of Brevard for this review cycle.


Report AS13-14.01

Page 3 of 32

III. Coalition Background Information

Provider type and children served – The following is a list of the number of provider types and the number of

children served by program type. The number of children served includes eligible children birth through 12 years of

age and children with special needs up through the age of 18.

Type of Providers Number of SR

Providers

Number of VPK

Providers

Number of School

Readiness Children

Number of Voluntary

Prekindergarten

Children

Faith-Based Providers1 N/A 44 N/A 1,300

Family Child Care Homes 12 2 84 13

Private Centers/Schools 111 146 3,573 3,581

Public School Providers 41 35 102 900

Informal Caregivers 0 N/A 0 N/A

Total (unduplicated)2 251 183 3,677 4,480

Source – OEL Fact Book FY2013-2014 (as of Nov. 25, 2013).

Organization and staffing – The coalition has a staff of 63 full-time employees who implement the programmatic

aspects of the coalition’s board of directors’ mission.

Board governance – The coalition’s board of directors serves as the coalition’s policy-making entity and delegates

authority to the coalition’s executive director. At the time of the review, the board consisted of 19 members

representing Brevard County. Membership composition includes representatives from both the private and public

sectors. The standing committees, established according to the coalition’s bylaws, that support the board are the

Executive and Nominating committees.

1 Distinct count of providers. The provider type counts include faith-based providers, which OEL does not consider a separate

provider type. OEL does not require that a coalition identify faith-based providers in the SR Program.

2 The sum of coalition data does not equal the statewide total. More than one coalition may serve these children.


Report AS13-14.01

Page 4 of 32

Scope of services –

During the review period, the coalition provided the following early learning services –

SR child eligibility determinations Coalition Contractor

VPK child eligibility determinations Coalition Contractor

VPK provider eligibility determinations Coalition Contractor

SR provider reimbursements Coalition Contractor

VPK provider reimbursements Coalition Contractor

CCR&R Coalition Contractor

Parent support Coalition Contractor

Health screening Coalition Contractor

Developmental screening Coalition Contractor

SR provider recruitment Coalition Contractor

VPK provider recruitment Coalition Contractor

SR provider training Coalition Contractor

VPK provider training Coalition Contractor

EFS management Coalition Contractor

Information Systems Security Coalition Contractor

The coalition’s allocations for the SR and VPK programs in the fiscal year ending June 30, 2014, totaled approximately

$29,088,801. Expenditures3 totaled approximately $8,463,723.


Reported SR and VPK Allocations and Expenditures

Services Allocation FY 2013-2014 Expenditures (Oct. 31, 2013)

School Readiness $16,948,979.00 $5,006,835.00

CCEP $110,000.00 $21,815.00

Total SR $17,058,979.00 $5,028,650.00

Voluntary Prekindergarten $11,541,630.00 $3,300,325.00

Administration $461,665.00 $131,512.00

Total VPK $12,003,295.00 $3,431,837.00

Outreach, Awareness and Monitoring Initiative

Outreach and Awareness $12,396.00 $1,862.00

Monitoring $14,131.00 $1,374.00

Total OAM $26,527.00 $3,236.00

Total All Programs $29,088,801.00 $8,463,723.00

Source – SR Notice of Award Nov. 12, 2013; VPK Notice of Award July 1, 2013; OAMI Notice of Award July 1, 2013; and OEL Expenditure Worksheet Oct. 31, 2013

3 Expenditures in the table represent cost categories that support the scope of the accountability review and are not all-

inclusive.


Report AS13-14.01

Page 5 of 32

IV. Review Criteria Findings and Recommendations

The following report summarizes compliance issues that the accountability review analysts observed during the

monitoring review. Under the terms of the Early Learning Grant Agreement between OEL and the coalition, the

coalition must submit a corrective action plan for all compliance issues within 30 days of receiving the published

report. Each issue and its associated recommendation in this section has a reference number. The numbered statements

contain the review observations on criteria that did not comply with state or federal requirements. Some files may

contain more than one finding type. The file numbers cited in each finding refer to the file(s) listed on the monitoring

review spreadsheets or scorecards. The recommendations address steps the coalition should take to correct the

observed noncompliance. A corrective action plan should identify the initial finding’s cause and how the

coalition will correct the finding and continue compliance.

V. Coalition Governance

For SR, VPK and CCR&R program success, a coalition must have an effective executive leadership structure. The

board should be the policymaking entity for the coalition, and the executive director should have the primary

responsibility for implementing and managing the coalition’s policies.

Each coalition establishes its own bylaws, including selecting a method of parliamentary procedures to provide

structure and organization for board business and operations. The Brevard Coalition’s bylaws set The Modern Rules of

Order as a standard for parliamentary procedure for voting members. A coalition’s approach to governance is important

to avoid possible legal challenges to board actions.

In addition, in order to allow public input and provide timely information, the coalition board must comply with Florida

Sunshine Law. Compliance includes noticing meetings and holding them at times and in places accessible to the public,

as well as promptly recording meeting minutes and making them available to the public.

CG-A. Board Governance

1. NO Does the coalition adhere to statutory and program requirements regarding board

membership? (ss. 286.011 and 1002.83(2)-(11), Florida Statutes (F.S.); Article I, Section 24,

Florida Constitution)

Statute requires that private sector members make up more than one-third (more than 33 percent)

of coalition boards. The Brevard Coalition’s board of directors had only six private sector

members (31.6 percent) for 10 months of the 12 that OEL reviewed.

2. YES Does the full board and committee meeting process include decision-making by quorum? (s.

1002.83(6), F.S.)

3. YES Does the coalition require that any board member who discloses a potential conflict of

interest, if known, completes and signs a conflict-of-interest memorandum when initially

joining the board? Does each board member with a disclosed conflict of interest abstain

from voting in accordance with statute? (ss. 112.3143 and 1002.83(8), F.S.)

4. YES Do the board members adhere to the standards of conduct that the Florida Statutes

prescribe? (ss. 112.313, 112.3135, 112.3143 and 1002.83(8), F.S.)

5. YES When applicable, do the coalition’s bylaws align with s. 1002.83(2)-(11), F.S., to provide

sufficient guidance that enables the board to operate as a corporate governing board? (s.

1002.85(2)(a), F.S.)


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OEL REQUIRES NO FURTHER CORRECTIVE ACTION. The coalition has completed the

following corrective actions –

The coalition changed the status of its two optional board members to private sector members, bringing the

coalition into compliance with the more than one-third private sector board member requirement.

CG-B. Board Meeting Accessibility and Sunshine Law

1. YES Did the coalition notice and conduct board and committee meetings and workgroups

according to the Florida Sunshine Law, including notification requirements and written

meeting minutes? (s. 286.011(1), (2) and (6), F.S.; 2012 Government in the Sunshine Manual;

Plan 0.1.1)

CG-C. Previous Corrective Actions

1. NO Did the coalition implement CG corrective actions that the previous OEL-issued

Accountability Section review report lists? (Early Learning Grant Agreement (8) and (31))

Statute requires that private sector members make up more than one-third (more than 33 percent)

of coalition boards. In the coalition’s 2009 accountability review, the coalition was out of

compliance with this requirement and has remained so for 10 of the last 12 months. In its 2009

accountability review corrective action plan, the coalition stated that it hired a partnership

development manager to assist with board recruitment. The coalition recently commuted its

optional members to private sector status, satisfying this requirement. However, OEL has not

received documentation of the coalition’s board recruitment efforts since 2009.




coalition into compliance with the more than one-third private sector board member requirement. The

coalition reported that it no longer employs a partnership development manager because it concluded that the

position was unfeasible and ineffective for board member recruitment.

VI. Operations and Program Management

OEL reviews the coalition’s OPM performance for a clearly defined organizational structure, including

procedures to effectively manage coalition personnel; adherence to customer complaint resolution processes;

maintaining internal controls over federal programs, consistent with laws, rules and policies; processes to

accurately and promptly report improper payments; and policies and procedures to monitor all subrecipient and

child care provider contracts’ administrative, programmatic and eligibility aspects.

OPM-A. Operations, Human Resources and Internal Controls

1. YES Do the coalition’s procedures forbid discriminatory employment practices, as federal laws

outline? (Title VI of the Civil Rights Act of 1964 (Public Law (P.L.) 88-352); 29 U.S. Code

(USC) s. 794; s. 760.10, F.S.; OEL Grant Agreement, Assurances and Certification, sections

(A)(6) and (Q))

2. YES Does the coalition have human resource policies and procedures that guide personnel

decisions for hiring staff to effectively operate the SR Program? (s. 1002.89(5), F.S.)

3. YES Does the coalition or its contractor have grievance policies and procedures for parents, and,

if applicable, did the coalition follow up on complaints from a parent regarding

discrimination or violation of civil rights laws within the last year using its approved


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grievance policies and procedures? (45 Code of Federal Regulations (CFR) 98.32; s.

1002.85(2)(h), F.S.; CCDF State Plan 2.6.5)

4. YES Have the coalition and its contractors implemented drug-free workplace policies in

compliance with state and federal law? (Drug Free Workplace Act of 1988; 45 CFR Part 82;

OEL Grant Agreement, Assurance and Certifications, section D; s. 112.0455, F.S.)

5. NO Have the coalition and its contractors implemented background screening procedures, as

set forth in the OEL Grant Agreement and applicable laws? (ss. 435.03, 435.04, 943.052 and

1002.84(9), F.S.; Early Learning Grant Agreement (45))

Though the coalition’s policies and procedures do comply with s. 435.03-04, F.S., and Early

Learning Grant Agreement background screening requirements, the coalition’s practices do not

comply with its policies and procedures. OEL sampled nine coalition employees and three

employees with CMIT, which the coalition contracts for IT services. The three CMIT employees

were out of compliance –

Three CMIT employees with FDLE and FBI screenings from Sept. 23, 2013, have hire dates

of July 1, 2012, and July 1, 2013 (which are the CMIT contract dates). The screenings were

not completed in accordance with grant agreement timelines.

6. YES Does the coalition comply with the statutory exemptions for information for VPK and SR

records involving individual records of children enrolled in these programs? (Early Learning

Grant Agreement (24)(b); ss. 1002.72 and 1002.97, F.S.)

7. YES Does the coalition maintain policies, procedures and priority rules that do not discriminate

against children or their families on the basis of race, national origin, ethnic background,

sex, religious affiliation or disability? (45 CFR subpart C, 98.20(b)(1); Early Learning Grant

Agreement, Assurances and Certification (A)(6))

8. YES Does the coalition have appropriate separation of duties to ensure that personnel

performing duties relating to parent/child application intake and eligibility determination

and approval do not perform duties relating to accounting and reimbursement, unless the

coalition has implemented sufficient internal controls for proper reimbursement

process/procedures oversight? (Office of Management and Budget (OMB) Circular A-133, Part

6; OMB A-133 Subpart C – Auditees§___.300 ; 45 CFR part 74.21(b)(3); Early Learning Grant

Agreement, Internal Controls Assurance section)

OEL recommends corrective action for noncompliance with operations and program

management criteria (OPM-A). For all uncorrected findings, the coalition should take the

following corrective actions to comply with all applicable statutes, rules and recommendations –

Develop and submit to OEL a process that indicates the coalition will complete, at minimum, the level 1

background screening process for contracted service staff within the timeframes the Early Learning Grant

Agreement outlines.

OPM-B. Improper Payments

1. YES Does the coalition have policies and procedures in place to support reporting improper

payments? (45 CFR 98.100; ss. 1002.84(17), 1002.87(4) and 1002.91, F.S.; Rule(s) 6M-

4.202(2)(b), 6M-4.203(2)(b), 6M-4.205(2)(b) 6M-4.503, 6M-8.204(2)(d) and 6M-8.204(6) FAC;

CCDF State Plan 1.3.5; VPK Provider Agreement, Section 26; Early Learning Grant Agreement,

Sections 9(c) and 13(a)and(b))

OPM-C. Monitoring of Subrecipients and Child Care Providers


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1. YES Does the coalition conduct subrecipient monitoring for all early learning programs that are

contracted, including SR, VPK and CCR&R? (ss. 1002.84(14)-(15) and 1002.85(2)(h), F.S.;

Early Learning Grant Agreement (8) and Internal Controls section)

2. YES Does the coalition have a monitoring process to verify that SR child care providers are (1)

maintaining the required child and staff documentation, (2) fulfilling their provider

agreement outline obligations and (3) implementing effective programs? (45 CFR 74.51; s.

1002.82, F.S; CCDF State Plan 1.3.2; OMB Circular A-133, Compliance Supplement, part 6,

section M; Early Learning Grant Agreement (8))

3. YES Does the coalition have a monitoring process and tool for onsite monitoring of VPK child

care providers based upon the VPK Outreach, Awareness and Monitoring Initiative Grant

requirements? (45 CFR 74.51; OMB Circular A-133, Compliance Supplement, part 6, section

M; VPK Outreach, Awareness and Monitoring Initiative Grant; Early Learning Grant Agreement

(2) and (8); OEL-VPK 20)

4. YES If the school district notified the coalition that it will monitor its providers for compliance

with the VPK Program, has the coalition requested and received the monitoring reports

from the school district? (Early Learning Grant Agreement (8); VPK Outreach/Awareness and

Monitoring Initiative Grant; OEL-VPK 20)

OPM-D. OPM Previous Corrective Actions

1. YES Did the coalition implement OPM corrective actions that the previous OEL-issued


VII. Child Care Resource and Referral

CCR&R serves as the front door to all services the coalition or its contracted service provider offer. Rule 6M-9.300,

Florida Administrative Code (FAC), requires a coalition to offer a parent assistance with locating child care and

information – which will help the parent make an informed decision – as well as additional information and community

resources as appropriate.

A coalition shall follow the minimum standards required to guide the coalition in delivering CCR&R services to a

family. CCR&R requirements address issues such as customer service criteria, staff training and certification, consumer

services and information, and database maintenance. Each CCR&R specialist should be able to explain various types of

legally operating early learning and school-age child care providers (including all licensed and license-exempt centers;

faith-based providers; licensed, registered and large family child care homes; school-age care providers; SR providers;

VPK providers; Head Start providers; Early Head Start providers; nanny/au-pair agencies; and summer camp

providers). When offering CCR&R services, a coalition must provide a family with options and resources in addition to

wait list placement. A family enrolling a child in the VPK Program may request a complete list of all area VPK

providers or receive a customized list of area VPK providers that best matches the family’s needs. The Child Care and

Development Fund (CCDF) plan states that all Florida families should have access to CCR&R services. CCR&R

services support families in becoming self-sufficient and making informed decisions about child care.

CCR&R-A. Delivery of CCR&R Services

1. NO Does the coalition adhere to Quality Assurance Assessment requirements for CCR&R

services? (s. 1002.92, F.S.; Rule 6M-9.300, FAC)

OEL made two Quality Assurance calls and one online request to the coalition’s offices. OEL

used the 2013-2014 Quality Assurance Assessment Forms to determine compliance with this

indicator. One call and the online request met all requirements, and one call did not –


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Call No. 1, placed on Sept. 12, 2013, did not meet element No. 4. The specialist asked for the

caller’s race and for the caller’s employer’s telephone number. The specialist told the caller

that if the caller did not provide the employer’s telephone number, the specialist would end

the interview. Specialists are not allowed to ask either question or demand the information

from callers seeking CCR&R services.

The online request, placed on Sept. 17, 2013, met all requirements.

Call No. 3, placed on Oct. 17, 2013, met all requirements.

2. YES Does the coalition provide CCR&R services without cost to the individual requesting

services within three business days of the individual’s request for services? (Rule 6M-

9.300(1)(c), FAC)



The coalition submitted to OEL evidence of completed staff training emphasizing the importance of meeting

required CCR&R program elements, especially only requesting required information during a CCR&R

interview.

CCR&R-B. Informational Packet

1. YES Does the coalition provide an informational packet to each individual requesting service

within six business days after the individual requested services, and does the coalition verify

that each informational packet contains the minimum information? (s. 1002.92(3)(a)-(b),

F.S.; Rule 6M-9.300(3), FAC)

CCR&R-C. Consumer/Community Services

1. YES Does the coalition adhere to requirements and OEL recommendations about

consumer/community activities? (s. 1002.92(1) and (3)(h), F.S.; Rule 6M-9.300(4), FAC; Plan

2.2.3)

CCR&R-D. Provider Information

1. NO Does the coalition provide the minimum information about each organization using the

provider update process? (s. 1002.92(3)(a), F.S.; Rule 6M-9.300(5), FAC)

OEL sampled five provider profiles in EFS. One provider profile contained errors.



The coalition submitted to OEL evidence verifying the most recent provider update forms match the

information in EFS.

CCR&R-E. CCR&R Previous Corrective Actions

1. YES Did the coalition implement CCR&R corrective actions that the previous OEL-issued


VIII. Educational Services Delivery

During the review, the team looked at the required components for implementing a local comprehensive program of

school readiness program services in accordance with statutes and OEL-adopted rules that enhance the cognitive,

social, and physical development of children to achieve the performance standards. The components include verifying


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provider use of developmentally appropriate curricula, implementing developmental screenings and assessments for

children participating in the program, coordinating staff development and provider training, improving child care

quality and availability, and fostering parental support and involvement.

ESD-A. Staff Development, Training and Teaching Opportunities

1. NO Does the coalition demonstrate compliance with its SR plan for coordinating staff

development, training and teaching opportunities? (s.1002.83(13), F.S.; coalition plan section

2.4.1)

The coalition provided evidence it is coordinating staff development, training and teaching

opportunities as well as conducting curriculum training, developmental screenings training, pre-

and post-assessment training, and warm line services training.

However, the coalition is not in compliance with its current plan. One of the outcome measures

for plan section 2.4.1 states that the coalition expects SR and VPK instructors to use coalition

scholarships to complete continuing education courses. Though the coalition collaborates with

other entities to provide training and credentialing opportunities, it no longer provides scholarship

funds for this purpose.

OEL recommends corrective action for noncompliance with educational service delivery criteria

(ESD-A). For all uncorrected findings, the coalition should take the following corrective actions

to comply with all applicable statutes, rules and recommendations–

Review plan section 2.4.1. Develop and use a tracking tool for the stated outcome measures or submit a plan

amendment that reflects the coalition’s current practices. If the coalition submits a plan amendment, the

coalition must also track the new outcome measure(s) once OEL approves the amendment(s).

ESD-B. Selection and Use of Developmentally-Appropriate Curriculum and Character Development

Programs

1. YES Does the coalition verify that SR providers use developmentally-appropriate curricula with

a character development component? (ss.1002.86 and 1002.88(f)-(g), F.S.; Rule 6M-4.710,

FAC; coalition plan section(s) 4.3.1, 4.3.2 and 4.3.3)

2. YES Does the coalition have an effective process for assisting providers with selecting and

implementing developmentally-appropriate curricula that include developmentally-

appropriate character development programs? (ss.1002.84(1) and 1002.88(f)(g) F.S.;

coalition plan section(s) 4.3.1 and 4.3.2)

ESD-C. Age-Appropriate Developmental Screenings

1. YES Did the coalition verify that all children from birth to 5 years of age in SR programs receive

age-appropriate developmental screenings? (s.1002.84(5), F.S.; Rule 6M-4.720, FAC;

coalition plan section 4.2.1)

2. YES Does the coalition use a screening instrument(s) that adheres to Rule 6M-4.720(3)(a)-(h),

FAC? (Rule 6M-4.720(3)(a)-(h), FAC)

3. YES Does the coalition have policies and procedures to verify that children receive appropriate

developmental screenings within 45 days of enrollment and that the parents receive

screening results in writing? (s.1002.84(5), F.S.; Rule 6M-4.720(2)(b)-(c), FAC)

4. YES Does the coalition have a process to verify that a parent who has declined to have his or her

child screened has submitted a completed form OEL-SR24 to the coalition/provider? (Rule

6M-4.720(2)(d), FAC)


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5. YES Does the coalition have a process to guarantee that children who showed concerning

screening results receive individualized supports as Rule 6M-4720(5), FAC, describes? (Rule

6M-4.720(5), FAC)

6. YES Does the coalition have a process in place to enter all required child screening data into an

electronic system no later than 60 calendar days after screening and no later than 30

calendar days after initiating individualized support? (s.1002.88(1)(h), F.S.; Rule 6M-

4.720(6)(a)-(b), FAC; coalition plan section 4.2.1)

ESD-D. Strategies to Improve the Quality and Availability of Child Care Services

1. NO Does the coalition demonstrate compliance with its coalition plan for improving child care

service quality and availability? (s. 1002.85(2)(d), F.S.; coalition plan section(s) 5.1.1, 5.2.1,

5.3.1 and 5.4.1)

Plan section 5.3.1 states, “85% of providers and parents participating in educational opportunities

will express a gain in knowledge on the developmental needs of infants and toddlers.” The

coalition provided evidence to OEL that it offered training to providers on infants and toddlers

and administered knowledge gains surveys to providers based on the trainings. The coalition also

submitted a parental education and engagement policy, which includes a requirement to provide

parents with educational materials and resources. The coalition submitted to OEL examples of

pamphlets to be distributed to parents and a list of library resources available to parents, which is

in compliance with coalition policy.

However, the coalition did not provide to OEL any evidence that it surveys parents participating

in educational opportunities or evidence of a tracking system that incorporated information from

the completed surveys to determine whether the coalition met the related outcome measure.


(ESD-D). For all uncorrected findings, the coalition should take the following corrective actions

to comply with all applicable statutes, rules and recommendations –

Review plan section 5.3.1 and complete one of the following –

Survey parents to evaluate the outcome measure related to this plan element. Develop and use a tracking

tool to evaluate surveys providers and parents complete. Update or develop a process to include in the

coalition plan activities and performance measures that align with the outcomes the coalition plan states.

Submit a plan amendment that reflects the coalition’s current practices. If the coalition submits a plan

amendment, the coalition must also track the new outcome measure(s) once OEL approves the

amendment.

ESD-E. ESD Previous Corrective Actions

1. YES Did the coalition implement ESD corrective actions that the previous OEL-issued


IX. School Readiness Eligibility

OEL reviewed SR eligibility applications, referrals, redeterminations, hours of care, rights and responsibilities/terms

and conditions, parental choice, immunization, child’s age, definition of a parent, residency, citizenship/immigration

status, family unit size and income, parent copayment, purpose for care, billing group eligibility, qualifying care and

provider arrangements, and EFS information accuracy.

The review team examined 33 SR child files for compliance with the SR Program under Title 45 CFR, parts 98 and 99;

CCDF plan Part 2; s. 1002.87, F.S.; and Rule 6M-4, FAC. Two of the reviewed files contained one or more findings.


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SR-A. Eligibility Application Process

An SR child file must include a completed application and child care (payment) certificate that the parent has

signed and dated. A parent should sign an application at the initial eligibility determination and at each

subsequent redetermination, and, at a minimum, annually. A parent may submit an application via mail, facsimile

or electronically.

The child care (payment) certificate is an authorization for services for eligible child(ren) at eligible providers.

The certificate identifies the child(ren) for whom a coalition authorized child care, the provider the family

selected, the assessed parent copayment for each eligible child(ren) and the authorized begin and end dates.

1. YES Does the coalition have a completed, signed and dated application for each child? (45 CFR

98.20(b); ss. 1002.84(7) and 1002.89(6)(c), F.S.; Rule 6M-4.100, FAC; CCDF State Plan 2.2.9)

2. YES Does the coalition have a completed, signed and dated payment certificate for each child?

(45 CFR 98.2; s. 1002.82(6)(c), F.S.; Rule(s) 6M-4.100(3) and 4.200(4), FAC; CCDF State Plan

2.6.1)

SR-B. Child Care Application and Authorization Forms (Referrals)

Several child care eligibility categories for SR services require a documented child care application and

authorization form (referral) as the OEL Standard Codes note. For all partner referral programs, a coalition shall

have a documented child care referral and approve child care for the period the referral authorizes, if the

authorized period is within program guidelines and the child meets SR Program requirement.

This section only applies to families receiving child protection services, families participating in the Welfare

Transition Program (WTP), and families receiving services from a designated homelessness program or a certified

domestic violence program. It may also apply to children in the Relative Caregiver (RCG) Program if there is a

child care referral.

1. YES Does the coalition have a complete and valid child care referral for each applicable child?

(45 CFR 98.20(b); Rule(s) 6M-4.201, 4.202, 4.204, 4.206 and 4.207, FAC)

2. YES Is the authorized eligibility period on the referral the correct length? (Rule(s) 6M-4.201 and

4.202, FAC; CCDF State Plan 2.3.6(b))

3. YES Did the coalition authorize SR services within the authorized child care period on the

referral? (Rule(s) 6M-4.201 and 4.202, FAC)

SR-C. Timely Delivery of Services for Priority Groups

A coalition’s eligibility determination shall be timely, within 10 days from receipt of the Child Care Application

and Authorization (referral) form for TANF/TCA and at-risk programs. For priority groups, the coalition must act

upon services within 10 calendar days from receipt of the referral.

This section only applies to families receiving child protection services and families participating in WTP, a

designated homelessness program or a certified domestic violence program. It may also apply to children in the

RCG Program if there is a child care referral.

1. YES Did the coalition act upon the child care referral for each applicable client within 10

calendar days from receipt of the referral? (s. 1002.87(1), F.S.; CCDF State Plan 2.2.10;

Early Learning Grant Agreement (39))

2. N/A If the coalition did not act upon the child care referral within 10 calendar days from

receiving the referral, did the coalition submit written notification to the referring agency

and the OEL Child Care Service Priority Referrals SharePoint site no later than close of

business 11 calendar days from receiving the referral? (Early Learning Grant Agreement

(39))


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SR-D. Authorized Hours of Care

Authorized hours of care for all SR services shall meet the definition of a unit of care. The amount of care is

related to purpose for care plus reasonable travel time. The definition of full-time care is at least six hours but not

more than 11 hours of child care or early childhood education services in a 24-hour period. Although full-time

employment or training will most often require authorization for full-time care, there are situations in which

families will need only part-time care (such as for a child who is in school and only needs before or after school

care). The definition of part-time care is less than six hours of care or early childhood education services in a 24-

hour period.

1. YES Did the coalition authorize the appropriate hours of care based upon the amount of care the

family needed? (ss. 1002.81(10) and (13), F.S.; Rule(s) 6M-4.100(12) and (19), FAC; CCDF

State Plan 2.3.3 and 2.3.4)

SR-E. Eligibility Period and Redetermination

A coalition must provide SR services to a family within the eligibility period. Eligibility begins only after a

coalition has established all factors of eligibility. At a minimum, a coalition should redetermine eligibility

annually for every family that receives SR services. A coalition must also conduct redetermination twice a year

for an additional 50 percent of a coalition’s enrollment through a statistically valid random sampling (this also

applies to RCMA). A coalition must discontinue a family’s funding at the redetermination due date if the coalition

has not yet fully reestablished the family’s eligibility in accordance with eligibility requirements. A coalition must

document why a child is no longer eligible for the SR Program according to OEL’s standard codes.

1. YES Did the client receive SR services within the correct authorized eligibility period? (s.

1002.84(7), F.S.; Rule 6M-4.209, FAC; CCDF State Plan 2.3.6)

SR-F. Parental Rights and Responsibilities/Terms and Conditions

An SR child file must have a signed and dated Rights and Responsibilities/Terms and Conditions notice that

includes the required minimum information as criterion SRV-4 in the SR Standard Eligibility Review Program

Guide. The parent should sign the document at least annually or when content on the form has changed.

1. YES Is there evidence that the coalition notified the parents of their rights and responsibilities?

(45 CFR 98.30-34, 46 and 60; Rule(s) 6M-4.202(2)(b), 4.203(2)(b), 4.205(2)(b) and 4.401, FAC)

SR-G. Parental Choice

A coalition must allow parents to choose from a variety of child care categories, including center-based care,

family child care and informal child care to the extent authorized in the state’s CCDF Plan that the United States

Department of Health and Human Services approved pursuant to 45 CFR 98.40.

A coalition must retain documentation showing that it explained and offered parental choice to the parent. A

coalition shall ensure that each applicant receives information that allows for informed parental choice decisions

related to selecting a child care provider.

1. YES Is there evidence that the parent received information about parental choice? (45 CFR

98.30; s. 1002.82(2)(b), F.S.; CCDF State Plan 2.6)

SR-H. Immunization and Health Requirements

In accordance with s.1002.88(j), F.S., program providers must obtain information about a child’s immunizations,

physical development and other health requirements as necessary, including appropriate vision and hearing

screening and examinations, within 30 days after enrollment. Early learning coalitions must collect a Health and

Safety Checklist from non-public school, religious exempt and informal providers to validate that the provider’s

immunization practices adhere to statute.


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For a child care provider licensed by the Department of Children and Family Services (DCF), the provider’s

compliance with s. 402.305(9), as verified pursuant to s. 402.311, shall satisfy this requirement.

1. N/A Does the coalition collect a health and safety checklist from non-public school, religious

exempt and informal providers to validate that the provider maintains and keeps child

immunization and required health examination records current? (ss. 1002.82(2)(i),

1002.88(1)(c) and 1002.88(1)(j), F.S.)

SR-I. Child Age Requirements

Effective August 1, 2013, state regulations require a child to be younger than 13 years of age to be eligible for the

SR Program.

1. YES Is each child younger than 13 years of age? (45 CFR 98.20; s. 1002.87, F.S.; CCDF State Plan

2.2.9 and 2.3.2)

SR-J. Definition of a Parent

Federal regulation provides the definition of a parent for the purpose of establishing a child’s eligibility for SR

services. A parent means a parent by blood, marriage or adoption and also means a legal guardian or a person

standing in loco parentis. In loco parentis is a person who acts in place of a parent, assuming care and custody of

a child by a formal or informal agreement with the child’s parent. Florida law states that a parent is either or both

parents of a child, any guardian of a child, any person in a parental relationship to a child or any person exercising

supervisory authority over a child in place of the parent.

1. YES Does each applicant meet the definition of a parent? (45 CFR 98.2; s. 1000.21(5), F.S.; Rule

6M-4.100(18), FAC; CCDF State Plan 2.2.9 and 2.3.1)

SR-K. Residency Requirements

A coalition should ensure that an SR child file includes documented evidence that the family currently resides in

the state of Florida. A coalition shall verify residency information with documentation that includes an in-state

physical address. There is no minimum length of time a person must reside in Florida to obtain benefits. A family

member may also be a temporary resident in a domestic violence or homeless shelter in Florida or authorized

emergency management location. A client must be a Florida resident to receive TANF benefits, which the

referring agency verifies during the TANF/TCA application process (s. 414.095(2)(a), F.S.).

1. YES Is each applicant a Florida resident? (45 CFR 98.20(2) and (3)(i))

2. YES Did the coalition authorize child care by parent’s county of residence? (ss. 1002.83(1) and

1002.89(5), F.S.)

SR-L. U.S. Citizenship

A child must be a U.S. citizen or a qualified alien to be eligible for SR services. If a child was born outside of the

U.S., a coalition must ensure that documentation exists in the SR child file to support the child’s legal status.

1. YES Is each child a U.S. citizen or a qualified alien? (Title IV of the Personal Responsibility and

Work Opportunity Reconciliation Act of 1996 (PRWORA); 62 Federal Register (FR) 61344;

CCDF-ACF-PI-2008-01; CCDF State Plan 2.2.9; Early Learning Grant Agreement (34))

SR-M. Family Unit Income

An SR child file shall include a completed SR Income Worksheet for Eligibility and Parent Copayment (SR-100)

to determine a child’s eligibility and establish the applicable parent fee based on the sliding fee scale included in

an OEL-approved coalition plan. When the mother and father (legal or biological), married or unmarried, reside

together in the home, a coalition must include any income both parents receive in the total family income. If a


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parent lives in the same dwelling unit with a roommate, friend or relative who is not the biological or legal parent

of the child, then these household members are optional and a coalition does not have to count their income as

part of the total family income. OEL rules provide guidelines for verifying employment and income.

1. YES Is there a completed, signed and dated SR Income Worksheet for Eligibility and Parent

Copayment (SR-100) for each applicant? (Rule 6M-4.208(1), FAC; CCDF State Plan 2.2.9 and

2.3.5)

2. YES Is there appropriate documentation to fully support gross earned and unearned family

income on the SR-100? (Rule 6M-4.208, FAC; CCDF State Plan 2.2.9 and 2.3.5)

3. NO Did the coalition correctly calculate gross earned and unearned family income on the SR-

100? (s. 1002.81(8), F.S; Rule 6M-4.208, FAC; CCDF State Plan 2.2.9 and 2.3.5)

The following file(s) did not comply with all applicable statutes, rules and recommendations – #2



The coalition corrected the following file(s) – #2

SR-N. Family Unit Size

Use family unit size in conjunction with the family’s gross annual income to determine if the family meets the

income threshold for a family to initially qualify for SR services. A family may consist of a parent or parents

living together, a parent’s minor child and any other minor child for whom the parent is legally responsible. A

family may also include any other adult whom the parent considers part of the family, such as a grandparent

whom the family supports. Statute defines family or household members as “spouses, former spouses, persons

related by blood or marriage, persons who are parents of a child in common regardless of whether they have been

married and other persons who are currently residing together in the same dwelling unit as if a family” (s.

1002.81(9), F.S.)

1. NO Did the coalition accurately determine family unit size and relationship? (s. 1002.81(9), F.S.;

Rule 6M-4.100(9), FAC; CCDF State Plan 2.2.9)





SR-O. Maximum Family Unit Income Threshold

In order for the coalition to approve a family for a service, the family applying must meet income eligibility

requirements to receive approval unless the service is available without regard to income. OEL rules provide

guidelines for verifying employment and income. An applicant must fully declare household circumstances and

income on the application.

1. YES For income-eligible clients, do family unit size and income meet the income threshold

requirement? (45 CFR 98.20(a)(2); s. 1002.87(1)(c) and (f), F.S.; Rules 6M-4.203, 4.205 and

4.208, FAC; CCDF State Plan 2.2.9)

SR-P. Parent Copayment

For each parent who receives SR services, the coalition shall assess a copayment based on family size and the

family’s gross annual income according to the sliding fee scale included in the OEL-approved coalition plan.


Report AS13-14.01

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1. YES Did the coalition correctly assess the parent copayment? (45 CFR 98.42(a) and (b); s.

1002.84(8), F.S.; Rule 6M-4.400, FAC; CCDF State Plan 2.4)

SR-Q. Parent Copayment Fee Waiver

A coalition may, on a case-by-case basis, waive the copayment for an at-risk child or temporarily waive the

copayment for a child whose family experiences a natural disaster or an event that limits the parent’s ability to

pay. Under the standard process for waiving a copayment, the referring case manager may indicate the waiver on

the referral or provide other written documentation requesting the fee waiver. A coalition may, on a case-by-case

basis, waive the copayment for a child in a family whose income does not exceed 100 percent of the FPL and

whose family experiences a natural disaster or an event that limits the parent’s ability to pay (e.g., incarceration,

residential treatment, homelessness, an emergency situation or the parent’s participation in a parenting class).

1. N/A If applicable, did the coalition document the request for a temporary fee waiver? (45 CFR

98.42(c) and 98.20(a)(3)(ii)(A); s. 1002.84(8), F.S.; Rule 6M-400(1) and (2), FAC; CCDF State

Plan 2.4.5.)

2. YES Did the coalition identify the reason for the fee waiver? (s. 1002.84(8), F.S; Rule(s) 6M-

4.400(1)-(2), FAC; CCDF State Plan 2.4.5.)

SR-R. Purpose for Care

A family’s eligibility for SR services depends on an established purpose for care. A coalition must ensure that any

parent who requests funding has a purpose for care.

1. YES Does each family have a documented and valid purpose for care? (45 CFR 98.20(a)(3)(i) and

(ii); Rule(s) 6M-4.200-4.207, FAC; CCDF State Plan 2.3.3 and 2.3.4)

SR-S. Billing Group Eligibility

Each family unit shall meet the state requirements for the approved eligibility and billing group. Each OCA

standard code provides definitions for each billing group’s purpose for care. The same codes also act as guidance

when a coalition should use the income of the “child only” to calculate eligibility. OEL has established standard

codes (OEL Standard Codes) to categorize specific eligibility groups that are critical to the ability of OEL and its

stakeholders to properly report on federal programs. Additionally, federal law requires a parent to have a purpose

for care to receive the funding. OEL standardization of codes ensures uniform and accurate data reporting on

local, state and federal reports. A coalition’s incorrect use of codes affects the accuracy of reporting, payments

and reimbursements.

1. YES Is the billing group correct based upon SR Program requirements? (45 CFR 98.20; Rule(s)

6M-4.100-4.207, FAC)

SR-T. Qualifying Care and Provider Arrangements

To receive SR funds for providing child care services, a provider must be eligible to legally provide child care

services and must have a fully executed SR provider agreement with the coalition. A parent may choose from a

variety of eligible child care types, including licensed, licensed exempt, registered or informal care.

1. YES Did only legally operating providers who met regulatory requirements provide SR services?

(45 CFR 98.2 and 98.41; s. 1002.88(1)(a), F.S.; CCDF State Plan 3.1.1)

2. YES Did the coalition have a fully executed SR Provider Agreement in place with each provider

prior to making any payments? (s. 1002.88(1)(p), F.S.)

3. YES Were the applicable protective services families enrolled in a DCF-approved child care

facility? (Rule 65C-13.030(4)(f), FAC; CCDF State Plan 2.6.4)


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SR-U. Statewide Information System (EFS) Accuracy

The Early Learning Grant Agreement requires a coalition to use the most current release of OEL Single Statewide

Information System, currently known as the Enhanced Field System (EFS). A coalition must use the EFS

database to establish eligibility for child care funding. EFS data must accurately reflect the most current

household circumstances that the applicant presented to the coalition. EFS data is the basis for reimbursement and

federal and state reporting.

The review shall consist of comparing SR child eligibility files against the EFS database records for accuracy of

entry, timeliness of processing actions, case history note narrations and data security.

1. YES Does the information in each SR child file match the information in EFS? (s. 1002.82(2)(n),

F.S.; Early Learning Grant Agreement (11))

SR-V. Eligibility Policies, Priorities and Disenrollment

Effective August 1, 2013, or upon reevaluation of eligibility for children a coalition is currently serving,

whichever is later, each early learning coalition shall base priority for participation in the SR Program in

accordance with s. 1002.87, F.S.

Disenrollment means the removal, either temporary or permanent, of a child from participation in the SR

Program. A coalition may remove a child from the SR Program based on a reduction in available SR Program

funding, a participant’s failure to meet eligibility or program participation requirements, fraud or a change in local

service priorities.

1. NO Does the coalition have clearly defined and written wait list procedures and eligibility

enrollment procedures that reflect the mandated eligibility priority categories for serving

children in the SR Program? (s. 1002.87(1) and (3), F.S.; Rule 6M-4.300, FAC)

The coalition is out of compliance with the following criterion –

The coalition appears to only place children who are 5 years old or younger on the wait list.

Although its policy states, “Each parent’s SR application meets preliminary eligibility

requirements in order to be placed or remain on the UWL,” the coalition’s practice is to

verify that it only places children birth through kindergarten age on the wait list. The

coalition does not include all eligibility categories.

2. NO Does the coalition have written policies and procedures that comply with s. 1002.87(7), F.S.,

and the Early Learning Grant Agreement for disenrolling children from SR services? (s.

1002.87(7), F.S.; OEL-FG-240.04; Early Learning Grant Agreement 12(e))

The coalition’s policy ELCB-SR-0006-08 does not fully comply with the 2012-2013 Early

Learning Grant Agreement and OEL-FG-240.04 requirements. The policy does not specifically

address

The requirement to notify OEL at least 48 hours prior to the board initiating formal

consideration to disenroll a group of children from early learning programs due to a projected

funds deficit.

The coalition must provide written notification to OEL at least five business days prior to

taking action to notify the provider or families of a determination to disenroll a child from

early learning programs due to a projected funds deficit.

3. YES Do the coalition’s written eligibility determination policies and procedures align with rules

and statutes? (ss. 1002.81 and 1002.87, F.S.; Rule 6M-4, FAC)

4. YES Did the Rights and Responsibilities/Terms and Conditions notification contain the required

minimum information?


Report AS13-14.01

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OEL recommends corrective action for noncompliance with SR eligibility criteria (SR-V). For

all uncorrected findings, the coalition should take the following corrective actions to comply

with all applicable statutes, rules and recommendations –

Submit a revised wait list procedure adhering to the eligibility priorities that s. 1002.87, F.S., establishes,

and permit staff to add children who qualify for school readiness services to the wait list according to

Rule 6M-4.300, FAC.

Conduct and submit to OEL evidence (e.g., agenda or sign-in/out sheet) of staff training on wait list

placement practices.

Develop a process that aligns with Rule 6M-4.300, FAC and includes validating each name on the wait

list every six months by response to a letter, by phone or in person. Notification of such validation must

give the parent a specific timeframe in which to contact the coalition with updated information to

maintain wait list eligibility. Submit new process and an updated SPE UWL report to OEL.

OEL-FG 240.04 states that “a coalition shall adopt a written policy that, at a minimum, provides for the

following…”Revise policy ELCB-SR-0006-08, in accordance with the 2012-2013 Grant Agreement and

OEL-FG 240.04 dated Aug. 6, 2013, to explicitly state

The coalition shall make written notification to OEL at least 48 hours prior to the initiation of formal

consideration by the board to disenroll a group of children from early learning programs due to a

projected funds deficit.

The coalition shall make written notification to OEL at least five business days prior to taking action

to notify provider or families of a determination to disenroll a child from early learning programs due

to a projected funds deficit. The coalition shall submit the notification to OEL with a copy of the two

most recent monthly use analyses and identify the enrollment priority group from which the coalition

plans to disenroll children due to a projected funds deficit and the projected number of children the

coalition plans to disenroll within the enrollment priority group.

The coalition shall make written notice, which includes the effective date of the child’s disenrollment,

to any affected child’s parent or guardian at least two weeks before the coalition disenrolls the child

from the School Readiness Program due to a projected funds deficit.

The coalition has established enrollment priorities among the subsequent priority eligibility groups in

descending order, beginning with the highest enrollment priority, in accordance with s. 1002.87(1),

F.S.

The coalition prohibits the disenrollment of groups of children for any reason other than preventing a

deficit or the children’s failure to comply with eligibility requirements.

The coalition disenrolls children in the order s. 1002.87(7), F.S., states. The policy may allow for the

disenrollment of a distinct subgroup within an enrollment priority (e.g., a school-age child older than

a specific age).

Submit a plan amendment, if applicable, to OEL. The coalition must receive written approval of the

submitted plan amendment from OEL prior to disenrolling children.

SR-W. Previous Corrective Actions

A coalition must submit a corrective action plan (CAP) response to OEL’s written notices of findings of non-

compliance within 30 days and implement the CAP response.

1. YES Did the coalition implement SR corrective actions that the previous OEL-issued


SR-X. School Readiness Subcontractor Monitoring

The Early Learning Grant Agreement, section 8, requires coalitions to have and implement an annual monitoring

plan documenting the coalition’s planned monitoring procedures for all contracts, grants, agreements and

programs. The plan must include quarterly monitoring that addresses, at a minimum, the requirements listed in the


Report AS13-14.01

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School Readiness Standard Eligibility Review Program Guide, including use of all required elements and sample

sizes.

The coalition certifies that it has established and shall implement a monitoring plan, which includes, at a

minimum, monitoring or testing of coalition subrecipient activities, reporting, corrective action resolution and

tracking.

1. N/A Did the coalition’s monitoring of its subrecipient(s) include each criterion the SR Standard

Eligibility Review Program Guide lists? (Early Learning Grant Agreement (8))

2. N/A Did the coalition follow the sample size guidelines during monitoring of its subrecipient(s)

for SR child eligibility and payment validation? (Early Learning Grant Agreement (8))

X. School Readiness Payment Validation

The OEL team reviewed 33 SR child files for payment validation for April, May and June 2013. The team also

evaluated the records for absences based on OEL attendance rules. The team compared attendance records and

noted any discrepancies. See the attached payment validation spreadsheet for specific record detail.

SRPV-A. Attendance Monitoring

A coalition shall have well-defined procedures for attendance monitoring and provider payments. An SR provider

must maintain daily attendance documentation, which, at a minimum, shall include a sign-in/sign-out process that

a coalition approves to validate the attendance data. A coalition must implement a records retention policy to

ensure that it maintains all documentation according to sub-grant award provisions.

Additionally, Rule 65C-22.001(10), FAC, Child Care Standards General Requirements, requires that “daily

attendance of children shall be taken and recorded by the child care facility personnel, documenting the time when

each child enters and departs a child care facility or program. The custodial parent may document the time when

their child(ren) enter and depart the child care facility or program. However, child care facility personnel are

responsible for ensuring that attendance records are complete and accurate.”

1. YES Does the coalition have an Enrollment/Attendance Certification for each child enrolled in

the SR Program? (ss. 1002.82(2)(p); 1002.84(9)-(10) and 1002.89(6)(c)4, F.S.; Rule(s) 6M-

4.502 and 65C-22.001(10), FAC)

2. NO Does the Enrollment/Attendance Certification report match the parent’s sign-in/sign-out

sheets, and did the provider complete both according to rule? (ss. 1002.82(2)(p) and

1002.89(6)(c)4, F.S.; Rule(s) 6M-4.502 and 65C-22.001(10), FAC)

The following file(s) did not comply with all applicable statutes, rules and recommendations – #3,

8, 11, 25, 32

3. YES Did the provider correctly document absences, holidays and temporary emergency

closures? (Rule(s) 6M-4.500 and 4.501, FAC)

4. NO Does the Final Provider Reimbursement Report match the Enrollment/Attendance

Certification? (s. 1002.82(2)(n) and (p), F.S; Rule 6M-4.500-501, FAC)

The following file(s) did not comply with all applicable statutes, rules and recommendations –

#27



The coalition corrected the following file(s) – #3, 8, 11, 25, 27, 32


Report AS13-14.01

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SRPV-B. Provider Reimbursement

Each coalition is responsible for implementing a records retention policy to ensure the coalition maintains all

documentation in compliance with the provisions set forth in their sub-grant awards. The coalition or its designee

must conduct monitoring activities to ensure the accuracy of payments of the monthly reimbursement requests.

Summary for all criteria related to payment – When a coalition identifies a discrepancy, it must document the

following information to support findings – appropriate screen prints, copies of incorrect income sheets/notices,

copies of corrected calculations and copies of attendance and reimbursement records.

1. YES Is the parent copayment amount subtracted from the reimbursement payment correct?

2. YES Is the SR payment rate correct? (s. 1002.85(2)(c)8, F.S.)

3. YES Is the SR payment rate less than or equal to the provider’s private pay rate?

4. YES Did the coalition document that the payment cleared the coalition’s financial

institution/bank? (ss. 1002.82(2)(p) and 1002.84(9), F.S.)

5. YES Does the amount paid to the provider match the amount owed based on the closed

reimbursement amount in EFS? (ss. 1002.82(2)(n) and (p), F.S.)

XI. Voluntary Prekindergarten Child Eligibility

VPK law requires OEL to adopt procedures that govern a coalition or school district’s enrollment and eligibility

determination of a child in the VPK Program (s. 1002.75(2)(a), F.S.). A coalition determines a child’s eligibility based

on Rule(s) 6M-8.200 and 8.202, FAC.

The review team examined 32 VPK eligibility file(s) for compliance. Four of the reviewed files contained one or more

findings.

VPKC-A. Child Age and Residential Eligibility

To be eligible for VPK or VPK Specialized Instructional Services (SIS), a child must reside in Florida while

attending the VPK Program and must be 4 years of age, but not 5 years of age or older, on Sept. 1 of the program

year.

A coalition must include in the family’s file verification that the applicant currently resides in Florida. A coalition

may verify residency information with documentation that includes an in-state physical address. There is no

minimum length of time an applicant must reside in Florida to obtain benefits. The applicant may also be a

temporary resident in a domestic violence center or homeless shelter in Florida or authorized emergency

management location.

1. YES Did the coalition determine and appropriately document that each child was 4 years of age

on or before Sept. 1 of the program year? (ss. 1002.53(2) and 1002.66(1)(a), F.S.; Rule 6M-

8.200(1), FAC)

2. YES Is each applicant a Florida resident? (s. 1002.53(2), F.S.; Rule 6M-8.200(2), FAC)

VPKC-B. Child Registration and Application (VPK and VPK SIS), Child Eligibility and Enrollment

Certificate (COE) and Parent Guide

A parent wishing to enroll his or her child in the VPK Program must submit a completed and signed Form OEL-

VPK 01 (Student Application) to a local early learning coalition in the county where the VPK site the parent

selected is located. Alternatively, a parent may register online at https://spe.schoolreadiness.org/pe/ and print and

submit the confirmation of the online application to the local early learning coalition or provider.

https://spe.schoolreadiness.org/pe/


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If a parent wishes to enroll his or her child in the VPK SIS Program, the parent must submit a completed and

signed Form OEL-VPK 01 (Student Application), Form OEL-VPK 01S (Supplemental Student Application) and

an individual education plan to a coalition or provider. A parent seeking VPK SIS services may also register

online.

Once a coalition determines that a child is eligible for the VPK or VPK SIS Program, the coalition issues the

child’s parent Form OEL-VPK 02 (COE) or Form OEL-VPK 02S Part A and B (SIS COE and Schedule of

Services). The provider and the parent must sign the form. A VPK provider may only enroll a child in the VPK

Program after a coalition determines that the child is eligible for the program. To enroll an eligible child, the VPK

provider admitting the child must submit (return) the child’s completed COE and Schedule of Services (if

applicable) to the coalition. A coalition shall complete a child’s enrollment in EFS by recording an association

between the child and the child’s assigned VPK class.

1. YES Is there a completed, signed and dated Form OEL-VPK 01/ OEL-VPK 01S or registration

form (VPK and VPK SIS) online confirmation for each child? (ss. 1002.53(4), 1002.66 and

1002.75(2)(a), F.S.; Rule 6M-8.201(1), FAC)

2. NO Did the coalition determine that each child was eligible, and did the coalition issue a

completed, signed and dated Form OEL-VPK 02 (COE)/OEL-VPK 02S Part A (SIS COE)?

(s. 1002.66, F.S.; Rule 6M-8.202(1)(c), FAC)


#15

3. YES Is there documentation from the provider indicating the child’s VPK class assignment? (Rule 6M-8.202(2)(a), FAC)

4. YES Is there evidence that each parent received a copy of the VPK Parent Handbook or received

access to the rights and responsibilities listed in the handbook? (Rule(s) 6M-8.2011 and 6M-

8.201, FAC)

OEL recommends corrective action for noncompliance with VPK child eligibility criteria

(VPKC-B). For all uncorrected findings, the coalition should take the following corrective

actions to comply with all applicable statutes, rules and recommendations –

Provide training to staff on completing forms and reviewing forms to verify completion. Submit evidence of

completed training, such as a training agenda or technical assistance letter, to OEL.

The coalition needs to correct the following file(s) – #15

VPKC-C. Reenrollment

Section 1002.71, F.S., states that a child who, for any of the VPK programs listed in s. 1002.53(3), F.S., has not

completed more than 70 percent of the hours authorized to be reported for funding under subsection (2), or has

not expended more than 70 percent of the funds authorized for the child under s. 1002.66, F.S., may withdraw

from the VPK Program for good cause or extreme hardship and reenroll in the VPK Program. In cases where the

student has already reenrolled for good cause or extreme hardship, the student may seek a good cause exemption

for a subsequent reenrollment.

Reenrollment for good cause –

A coalition may reenroll a student for good cause in the same program type (school-year or summer) in which the

student was previously enrolled if all of the following apply – the student has not substantially completed the

VPK Program, the student has not previously reenrolled for good cause or due to an extreme hardship, and the

student’s parent or guardian completes the Reenrollment Application (Form OEL-VPK 05) and submits it to the

early learning coalition as documentation that the student was or is prevented from attending the VPK class for

http://www.leg.state.fl.us/statutes/index.cfm?App_mode=Display_Statute&Search_String=&URL=1000-1099/1002/Sections/1002.53.html



Report AS13-14.01

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good cause. The total funding for a child who reenrolls in one of the programs for good cause may not exceed one

full-time equivalent (FTE) student. A coalition shall issue funding for a child who withdraws and reenrolls in one

of the programs for good cause according to OEL’s uniform attendance policy.

Reenrollment for extreme hardship –

A coalition may reenroll and report a student for funding purposes as one FTE student, as s. 1002.71(2), F.S.,

defines, in the summer VPK Program, if all of the following apply – the student has not substantially completed

the VPK Program, the student has not previously reenrolled due to an extreme hardship or for good cause, and the

student’s parent or guardian completes and submits the Reenrollment Application to the early learning coalition

with supporting written documentation of extreme hardship. A child may reenroll only once in a VPK Program

under this subsection. A child who reenrolls in a VPK Program under this subsection may not subsequently

withdraw from the program and reenroll, unless the child receives a good cause exemption under this subsection.

OEL shall establish criteria specifying whether a good cause exists for a child to withdraw from a VPK Program,

whether a child has substantially completed a VPK Program and whether there exists an extreme hardship that is

beyond the child’s or parent’s control.

Good cause exemption –

A student may receive a good cause exemption to the one-time reenrollment limitation. A coalition may grant a

good cause exemption from the limitation of one reenrollment for any one of the following reasons identified

within the OEL VPK – Good Cause Exemption to Reenrollment memorandum dated February 10, 2012

(Appendix C). In order to maintain appropriate documentation regarding reenrollments, a coalition may request

that a parent complete and sign Form OEL-VPK 05B (Good Cause Exemption Application) supplemental to the

initial reenrollment application and attach documentation of an extreme hardship, if applicable. The parent must

submit the forms to the coalition. If the child is reenrolled with a coalition other than the coalition of the previous

enrollment, the coalition may also request that a parent complete and resubmit Form OEL-VPK01 (Child

Application). The coalition must follow the procedures for registration, eligibility determination and enrollment of

the child in the VPK Program. The coalition will then determine the VPK student’s eligibility for a good cause

exemption and return a copy of the form to the parent for presentation to the new provider if the coalition

determines the VPK student eligible.

1. NO If applicable, did the coalition reenroll the child according to VPK rule and program

requirements? (s. 1002.66, F.S.; Rule 6M-8.210, FAC)


#13, 23



The coalition corrected the following file(s) – #13, 23

VPKC-D. Statewide Information System (EFS) Accuracy

The Early Learning Grant Agreement requires a coalition to use the most current release of the OEL single

statewide information system, currently known as the Enhanced Field System (EFS). A coalition must use the

EFS database to establish eligibility for child care funding. EFS data must accurately reflect the most current

household circumstances that the applicant presented to the coalition. EFS data is the basis for reimbursement and

federal and state reporting.

1. NO Does the information in each VPK child file match the information in EFS? (s.

1002.82(2)(n), F.S.; Early Learning Grant Agreement (11))



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VPKC-E. Eligibility Policies and Procedures

Section 1002, F.S., establishes the VPK Program for each child who resides in Florida who will have attained the

age of 4 years on or before Sept. 1 of the school year and who is not yet eligible for admission to kindergarten in a

public school under s. 1003.21(1)(a)2, F.S. A coalition shall have local policies to ensure that its policies and

contractor policies do not discriminate against children and that it meets enrollment requirements and timeframes

(Early Learning Grant Agreement (39)).

1. YES Do the coalition’s policies comply with statute regarding not limiting the number of

children a provider can enroll in its VPK Program? (s. 1002.53(6)(a), F.S.)

VPKC-F. VPK Child Previous Corrective Actions

A coalition must submit a corrective action plan (CAP) response to OEL’s written notices of findings of non-

compliance within 30 days and implement the CAP response.

1. YES Did the coalition implement VPK child corrective actions that the previous OEL-issued


VPKC-G. VPK Child Subcontractor Monitoring

The Early Learning Grant Agreement, section 8, requires a coalition to have and implement an annual monitoring

plan documenting the coalition’s planned monitoring procedures for all contracts, grants, agreements and

programs. The plan must include quarterly monitoring that addresses, at a minimum, the requirements listed in the

VPK Standard Eligibility Review Program Guide, including using all required elements and sample sizes.

The coalition certifies that it has established and shall implement a monitoring plan, which includes, at a

minimum, monitoring or testing coalition subrecipient activities, reporting, corrective action resolution and

tracking.

1. N/A Did the coalition’s monitoring of its subrecipient(s) include each VPK child and payment

validation criterion the VPK Standard Eligibility Review Program Guide lists?

2. N/A Did the coalition follow the sample size guidelines during monitoring of its subrecipient(s)

for VPK child eligibility and payment validation?

XII. Voluntary Prekindergarten Payment Validation

VPKPV-A. VPK Attendance Monitoring

A coalition shall have well-defined procedures for attendance monitoring and provider payments. A coalition

must implement a records retention policy ensuring that it maintains all documentation in accordance with sub-

grant award provisions. A coalition must conduct monitoring activities to ensure payment accuracy for monthly

reimbursement requests.

A VPK provider must keep a daily record of a child’s program attendance and require the parent to verify

monthly the child’s attendance for the prior month using VPK daily attendance forms –

– Form OEL-VPK 03S (Child Attendance and Parental Choice Certificate Short) – The parent may use the

short form if the VPK provider records daily attendance using a paper sign-in/sign-out log that records the date,



Report AS13-14.01

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child’s name and signature of the parent or other person dropping off or picking up the child to or from the VPK

site or an electronic attendance-tracking system that records the date, time, child’s name and electronic signature,

card swipe, entry of a personal identification number or similar daily action the parent takes or other person

dropping off or picking up the child from the VPK site.

– Form OEL-VPK 03L (Child Attendance and Parental Choice Certificate Long) – If the provider does not

maintain daily sign-in/sign-out logs, the parent must complete and sign Form OEL-VPK 03L that indicates on

which days the child was in attendance for that month. A coalition pays a VPK provider according to the

provisions of OEL’s Uniform Attendance Policy for Funding the VPK Program and Advance Payment and

Reconciliation for the VPK Program Rules.

1. YES Does the coalition have Enrollment/Attendance Certification or OEL-VPK 02S Part B

(Schedule of Services) for each child enrolled in the VPK Program? (s. 1002.71(6), F.S.; Rule

6M-8.305(3), FAC)

2. NO Did the provider maintain and complete Forms OEL-VPK 03S or OEL-VPK 03L according

to rule? (s. 1002.71(6), F.S.; Rule 6M-8.305(1) and (2), FAC)


#10, 12, 20, 29, 31

3. NO Does the Enrollment/Attendance Certification match the parent’s sign-in or sign-out sheets

and Form OEL-VPK 03S or Form OEL-VPK 03L? (s. 1002.71(6), F.S.; Rule 6M-8.305, FAC)


4, 6, 13, 17, 29, 32

4. NO Did the provider correctly document absences and temporary emergency closures? (Rule

6M-8.204, FAC)


13, 17, 29

5. NO Do the sign-in or sign-out sheets or VPK-03L match the Final Provider Reimbursement

Report? (s. 1002.71(6), F.S.; Rule 6M-8.305, FAC)


6, 17, 29


Certification or VPK-02S Part B (Schedule of Services)? (s. 1002.71(6), F.S.; Rule(s) 6M-

8.305, FAC)


#13

The coalition has completed the following corrective actions –

The coalition corrected the following file(s) – #1, 4, 6, 10, 12, 13 (for A3 and A4), 17, 20, 29 (for A2, A3

and A4), 31

OEL recommends corrective action for noncompliance with VPK payment validation criteria

(VPKPV-A). For all uncorrected findings, the coalition should take the following corrective


For file No. 13, submit to OEL clarification or proof that the coalition made an adjustment to EFS

showing the child’s April 19, 2013, absence.

For file No. 29, the May 29, 2013, absence is outside of the program period, yet shows in the file as an

absence along with two other absent days in May 2013 that were within the VPK program period. The


Report AS13-14.01

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coalition made an attendance adjustment in EFS showing that the child was absent for three days. The

coalition must provide case clarification or submit documentation to OEL regarding why the coalition

adjusted for three days (one of which OEL does not consider a VPK eligible day) instead of two.

For file No. 32, submit to OEL clarification of an electronic sign-in/sign-out process and missing

information or submit proof that the coalition provided provider training on the requirement that

attendance documentation contains the child’s name.

The coalition needs to correct the following file(s) – #13 (for A6), 29 (for A5), 32 (for A3)

VPKPV-B. VPK Provider Reimbursement

Each coalition must implement a records retention policy to maintain all documentation according to provisions in

their sub-grant awards. A coalition or its designee must conduct monitoring activities to ensure the payment

accuracy for monthly reimbursement requests.

After a coalition approves the Enrollment/Attendance Certification, the coalition will generate a provider

reimbursement report for the net reimbursement amount the coalition should pay the provider. A coalition will

pay the provider by electronic funds transfer (EFT) or by warrant (check). A coalition should verify that the

provider received the payment.

1. YES Are VPK rates correct for provider’s county? (s. 1002.71(3), F.S.)

2. YES Did the coalition document that the payment cleared the coalition’s financial

institution/bank? (ss.1002.82(2)(p), F.S.)

3. YES Does the amount paid to the provider match the amount owed based on the closed

reimbursement amount in EFS? (s. 1002.82(2)(n) and (p), F.S.; Rule(s) 6M-8.204 and 6M-

8.205, FAC)

XIII. Voluntary Prekindergarten Provider

A coalition administers the VPK Program through the service delivery of a VPK provider. Even after a coalition has

determined that a provider is eligible to deliver the program, a coalition has an ongoing duty to verify the provider’s

compliance with Florida Statutes, state rules and coalition procedures.

The OEL review team examined 56 VPK classroom director and instructor credentials and qualifications within 20

child care provider sites to establish whether all instructors were qualified before the coalition authorized the instructors

to enter the classroom. None of the instructor files reviewed contained findings.

VPKP-A. VPK Provider Eligibility and Class Registration

Before delivering instruction or receiving payment for the VPK Program services, a VPK provider must submit

complete and signed Forms OEL-VPK 10 (Statewide Provider Registration Application) and Form OEL-VPK 11

(Class Registration Application) Parts A and B with supporting documentation. A coalition must follow

procedures for classroom registration that Rule 6M-8.300, FAC, describes. During the program year, if there are

any changes that would affect the information the provider initially supplied on the OEL-VPK 10, 11A or 11B

during the registration process, the VPK provider must give written notice to the coalition within 14 calendar days

from the date the change occurred. In order to properly notify the coalition, the provider may complete an updated

OEL-VPK 10, 11A or 11B or local form with required information. Private and public school providers must

complete Forms OEL-VPK 10 and OEL-VPK 11A and 11-B for each VPK site and submit the completed forms

to the coalition. The forms are available electronically at


Report AS13-14.01

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http://www.floridaearlylearning.com/OEL_Program_Guidance-Policy.html. The coalition must update forms

annually, at a minimum.

Form OEL-VPK 10 (Statewide Provider Registration Application) –

A VPK provider registering for the VPK Program must annually complete and sign Form OEL-VPK 10 before

delivering instruction or receiving payment for the VPK Program. A provider must submit Form OEL-VPK 10 to

the coalition in the county of the VPK provider’s site. If a VPK provider has more than one VPK site, the provider

must submit a separate Form OEL-VPK 10 for each site.

Form OEL-VPK 11, Parts A and B (Class Registration Application) –

A VPK provider cannot deliver instruction or receive payment until the provider submits annually completed and

signed Forms OEL-VPK 11A (Instructors) and OEL-VPK 11B (Calendars). If the VPK provider has more than

one VPK class, the provider may submit information for multiple classrooms on each form with supporting

documents for each class. The director, owner, operator, principal or school district staff at a private provider or

public school must submit Form OEL-VPK 11A and B to the coalition annually. The coalition must complete the

OFFICIAL USE ONLY section on the bottom of Forms OEL-VPK 11A and 11B to verify that the coalition

reviewed the form for accuracy and timeliness.

1. YES Is there a completed, signed and dated Form OEL-VPK 10 (Statewide Provider

Registration Application) for each provider? (Rule 6M-8.300(1), FAC)

2. YES Is there a completed, signed and dated Form OEL-VPK 11A and B (Class Registration

Application) for each class? (Rule(s) 6M-8.204(3)(a)-(b) and 6M-8.300(2), FAC)

VPKP-B. Statewide Provider Agreement

Before delivering instruction or receiving payment for the VPK Program, a coalition must verify that both it and

the VPK provider (private or public school) sign a Form OEL-VPK 20 (Statewide VPK Provider Agreement) or

Form OEL-VPK 20S (Specialized Instructional Services Provider Agreement) before the coalition pays the

provider. The VPK provider may not offer services or instruction until the provider receives notice from the

coalition of its eligibility to offer VPK services.

A public school district may sign a single provider agreement (Form OEL-VPK 20 or 20S) on behalf of all public

school VPK providers in the district, and the owner or manager of multiple private VPK providers within the

coalition’s service area may sign a single provider agreement on behalf of all of his or her VPK providers. A

coalition is not obligated to pay for costs the provider incurs before the agreement’s beginning date or after the

agreement’s ending date.

The OEL review examines VPK classroom instructors’ credentials and qualifications within private child care

provider sites to establish whether all instructors were qualified before a coalition authorized the instructors to

enter the classroom. Each VPK class must have at least one VPK instructor who is qualified to act as a VPK

instructor. In addition to VPK instructor qualifications, a VPK SIS instructor must have a license or certification

for applied behavior analysis, speech language pathology, occupational therapy, physical therapy, clinical social

work, psychology or have approval from the Florida Department of Education (DOE) as Rule 6A-6.03033, FAC,

describes. A VPK instructor must be of good moral character, must complete a level 2 background screening

before entering the classroom and submit and clear a background rescreening every five years, and must not be

ineligible to teach in a public school due to a suspended or revoked educator certificate.

Statute defines time limits on validity for VPK coursework or credential requirements. All instructors must have

valid credentials before entering a VPK classroom and maintain valid credentials while acting as VPK instructors.

A private VPK provider must have a VPK director who has a VPK director credential that meets or exceeds the

http://www.floridaearlylearning.com/OEL_Program_Guidance-Policy.html


Report AS13-14.01

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minimum standards adopted under s. 1002.57, F.S. A VPK director who earned a director credential on or before

December 31, 2006, is exempt from completing additional requirements to obtain a VPK endorsement. A director

who received a director credential on or after January 1, 2007, must complete a series of requirements to receive a

VPK endorsement.

1. YES Is there a completed, signed and dated Form OEL-VPK 20 or Form OEL-VPK 20S that

contains all required information and attachments? (ss. 1002.55(2)(i), 1002.55(3)(j) and (k),

1002.61(3)(b), 1002.66 and 1002.75, F.S.; Rule 6M-8.301, FAC)

2. YES Has each private provider met the requirements for a legally operating provider eligible to

deliver the VPK Program? (ss. 1002.55(3)(a)-(b), 1002.61(3), 1002.63(3) , 1002.66(4) and

1002.91(7), F.S.; Rule 6M-6A-6.03033, FAC)

3. YES Does each private VPK provider have a director with a valid director credential and, if

applicable, a VPK Director Endorsement? (ss. 1002.51(5), 1002.55(3)(g) and 1002.57, F.S.)

4. YES Does each lead instructor meet the required credentials? (ss. 1002.55(3)(c), 1002.55(4),

1002.61(4), and 1002.63(4) and (5), F.S.)

5. YES Does each substitute instructor meet the required credentials? (ss. 1002.55(3)(e), 1002.61(6)

and 1002.63(6), F.S.; Rule 6M-8.410, FAC)

6. YES Does each VPK lead, substitute and secondary instructor for each class a provider offers

have evidence of a current level 2 background screening clearance for the entire classroom

period? (ss. 435.04, 1002.55(3)(d)-(e), 1002.61(5), and 1002.63(5), F.S.; Rule(s) 65C-22.006

and 6M-8.410, FAC)

7. YES Does each lead, substitute and secondary instructor for each class that a private provider

offers have evidence of a signed and current Affidavit of Good Moral Character (AGMC)?

(ss. 435.04 and 1002.55(3)(d)-(e), F.S.; Rule 6M-8.410, FAC)

VPKP-C. Program Classroom Sizes

A school-year program may not begin instruction more than 14 days before Labor Day. A summer program may

not begin instruction before May 1. A VPK class may not exceed 20 children for a school-year program or 12

children for a summer program. If a mixed group of VPK and non-VPK children are in a class, both groups count

toward the 20-child or 12-child maximum class size. A VPK class may not exceed the maximum class size

enrollment or attendance on a particular day. For school-year classrooms with 12 or more children, a secondary

instructor must be present.

1. N/A Did the coalition verify that the VPK classroom(s) met the applicable student/teacher ratios

during the review period? (ss. 1002.53(6)(b), 1002.55(3)(f), 1002.61(7) and 1002.63(7), F.S.;

Rule(s) 6M-8.204(3) and 6M-8.400, FAC)

VPKP-D. Statewide Kindergarten Screening; Kindergarten Readiness Rates

Section 1002.69(5), F.S., requires OEL to annually calculate each private and public provider’s VPK readiness

rate. Section 1002.67, F.S., requires the Department of Education (DOE) to develop performance standards for

children in the VPK Program. If a provider’s readiness rate falls below the established level based on assessments,

Rule 6M-8.701(2), FAC, requires OEL to place the provider or school on probation. The provider must then

submit an improvement plan for the coalition or school district’s approval and implement the plan. The plan must

include a curriculum that DOE approved or a staff development plan. OEL is responsible for setting the minimum

readiness rate. If the readiness rate falls below the established level, a VPK provider has 21 calendar days from

OEL’s adoption of the minimum readiness rate(s) to acknowledge status as a low-performing provider through

www.ImproveVPK.org.

http://www.improvevpk.org/


Report AS13-14.01

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Section 1002.69(7), F.S., states that a provider on probation for more than two consecutive years must receive a

good cause exemption to continue operating. Should the provider fail to receive the exemption, s. 1002.67(4)(c)3,

F.S., and Rule 6M-8.702, FAC, require OEL to notify coalitions that they must remove that provider from future

eligibility to provide the VPK Program. The provider must not provide the VPK Program or receive state funds

for providing the VPK Program for five years.

1. YES For all sampled providers on probation, did the coalition approve or disapprove the VPK

provider’s improvement plan within 14 days after receiving the improvement plan? (s.

1002.67, F.S.; Rule(s) 6M-8.700 and 6M-8.701, FAC)

2. YES For all sampled providers on probation, did the coalition require the providers to submit

and implement an improvement plan according to rule? (ss. 1002.67 and 1002.69, F.S.;

Rule(s) 6M-8.700(2) and (4), and 6M-8.701(2), FAC)

3. YES If a VPK provider was on probation for two consecutive years or more and subsequently

failed to meet the minimum readiness rate, did it receive approval for a good cause

exemption from OEL or did the coalition remove it from delivering the program? (ss.

1002.67(4)(c)3 and 1002.69(7), F.S., and Rule 6M-8.702, FAC)

VPKP-E. Statewide Information System (EFS) Accuracy

The Early Learning Grant Agreement requires a coalition to use the most current release of the OEL single

statewide information system, currently known as the Enhanced Field System (EFS). A coalition must use the

EFS database to establish eligibility for VPK services. EFS data is the basis for reimbursement and state

reporting.

The review shall consist of comparing VPK provider eligibility files against the EFS database records for

accuracy of entry, timeliness of processing actions and case history note narrations.

1. YES Does the information in each VPK provider file match the information in EFS? (s.

1002.82(2)(n), F.S.; Early Learning Grant Agreement (11))

VPKP-F. VPK Provider Profiles

Section 1002.53 (5), F.S., requires the coalition to provide each parent enrolling a child in the VPK Program with

a profile of every private VPK provider and public school delivering the program within the county where the

parent is enrolling the child. The profiles must include, at a minimum, each provider’s or school’s services,

curriculum, instructor credentials and staff-to-child ratio.

The coalition shall also provide parents with the provider’s or school’s kindergarten readiness rate calculated

according to s. 1002.69, F.S., based upon the most recent available results of the statewide kindergarten screening.

1. YES Are VPK profiles available to all parents enrolling or registering their children in the VPK

Program? (s. 1002.53(5), F.S.; Rule 6M-8.201(4)(a), FAC)

2. YES Do the VPK profiles include the five required areas? (s. 1002.53(5), F.S.; Rule 6M-

8.201(4)(a), FAC)

VPKP-G. VPK Provider Previous Corrective Actions

A coalition must submit a corrective action plan (CAP) response to OEL’s written notices of non-compliance

findings within 30 days and then implement the CAP response. The coalition certifies that it has established and

shall implement a monitoring plan, which includes, at a minimum, monitoring or testing of coalition subrecipient

activities, reporting, corrective action resolution and tracking.

1. NO Did the coalition implement VPK provider corrective actions that the previous OEL-issued




Report AS13-14.01

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According to the 2011-2012 ELC of Brevard Accountability Review Corrective Action Plan

(CAP), OEL required the coalition to submit a repayment plan to OEL’s Financial Administration

and Budget Services Unit due to an instructor failing to complete the early literacy training or

equivalent, making the class invalid. In the 2011-2012 CAP, the coalition acknowledged that the

coalition had not correctly validated the lead instructor’s credentials and the provider, therefore,

was not at fault and the coalition would not recoup funds from the provider. As of Oct. 25, 2013,

the Financial Administration and Budget Services Unit had not received a repayment plan from

the coalition.

OEL recommends corrective action for noncompliance with VPK provider eligibility criteria

(VPKP-G). For all uncorrected findings, the coalition should take the following corrective


Comply with the OEL-approved corrective action plan and submit a repayment plan to OEL’s Financial

Administration and Budget Services Unit according to Fiscal Guidance 240.01 or submit documentation to

OEL demonstrating that the coalition submitted the appropriate repayment to OEL.

XIV. Data Accuracy

The team reviewed selected edit and exception reports, listed below. The purpose of the reports is to identify

anomalies in EFS data that may indicate data entry error or non-compliance in SR or VPK eligibility. Not all files

identified on the reports are in error. The review analysts identified instances during the review of these reports

that required coalition follow-up and OEL team validation. Reports indicated by “*” are standard reports the OEL

DQI unit runs and provides to the coalitions on a quarterly or monthly basis. OEL expects the coalition to follow

up and correct identified items. The coalition shall comply with data correction requests or data cleansing

activities as OEL communicated (Early Learning Grant Agreement Section 11(E)).

Note – Question numbers in this section correspond to question numbers in the Data Accuracy Review Guide and

may not follow the standard numerical order.

DA-A. School Readiness (SR) Edit and Exception Reports

*Active SR file(s) with SSA/SSI income – Assists with identifying if children’s income is excluded properly

and/or if parents’ income is included properly. The report also assists in determining if the case was placed in the

correct billing group.

*Total Family Income exceeds 200 percent – Identifies families who are potentially over income and ineligible

for the program.

*Gold Seal Edit Report – Identifies providers with a Gold Seal payment that have a missing certificate or error

with the certificate end date.

SR Redeterminations Report – Identifies SR child enrollments that do not have program end dates entered into

EFS.

Based on the following EFS reports, is the coalition in compliance with OEL requirements?

4. NO *Active SR file(s) with SSA/SSI income (19)

The review team examined 12 file(s) for compliance. One of the reviewed files contained one or more

findings.

5. YES *Total Family Income exceeds 200 percent (29)

7. YES *Gold Seal Edit Report (1)


Report AS13-14.01

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9. YES SR Redetermination Report



The coalition corrected the file in error for *Active SR file(s) – with SSA/SSI income.

DA-B. Voluntary Prekindergarten (VPK) Edit and Exception Reports

VPK Redeterminations Report – Identifies VPK child enrollments that do not have program end dates entered

into EFS.

Is the following EFS report in compliance with OEL requirements?

5. YES VPK Redetermination Report

DA-E. DA Previous Corrective Actions

A coalition must submit a corrective action plan (CAP) response to OEL’s written notices of non-compliance

findings within 30 days and then implement the CAP response. The coalition certifies that it has established and

shall implement a monitoring plan, which includes, at a minimum, monitoring or testing of coalition subrecipient

activities, reporting, corrective action resolution and tracking.

1. YES Did the coalition implement DA corrective actions that the previous OEL-issued

Accountability Section review report lists?


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XV. Recommended Corrective Actions Summary Review

OEL requires the coalition to submit a corrective action plan (CAP) for all compliance issues within 30 days from

receiving this accountability review report. The response should demonstrate the coalition’s steps to address each

compliance issue and the numbered findings on the monitoring spreadsheets. For all uncorrected findings, a

corrective action plan should identify the initial finding’s cause and the coalition’s plan for continued compliance. See

the suggestions below for how to correct findings and avoid future findings.

Coalition Governance (CG)

The coalition has no pending corrective actions in this review area.

Operations and Program Management (OPM)



Agreement outlines.

Child Care Resource and Referral (CCR&R)


Educational Services Delivery (ESD)





Survey parents to evaluate the outcome measure related to this plan element. Develop and use a tracking

tool to evaluate surveys providers and parents complete. Update or develop a process to include in the

coalition plan activities and performance measures that align with the outcomes the coalition plan states.


amendment, the coalition must also track the new outcome measure(s) once OEL approves the

amendment.

School Readiness Eligibility (SR)

Submit a revised wait list procedure adhering to the eligibility priorities that s. 1002.87, F.S., establishes,

and permit staff to add children who qualify for school readiness services to the wait list according to

Rule 6M-4.300, FAC.

Conduct and submit to OEL evidence (e.g., agenda or sign-in/out sheet) of staff training on wait list

placement practices.

Develop a process that aligns with Rule 6M-4.300, FAC and includes validating each name on the wait

list every six months by response to a letter, by phone or in person. Notification of such validation must

give the parent a specific timeframe in which to contact the coalition with updated information to

maintain wait list eligibility. Submit new process and an updated SPE UWL report to OEL.

Revise policy ELCB-SR-0006-08, in accordance with the 2012-2013 Grant Agreement and OEL-FG

240.04 dated Aug. 6, 2013, to explicitly state




The coalition shall make written notification to OEL at least five business days prior to taking action

to notify provider or families of a determination to disenroll a child from early learning programs due


Report AS13-14.01

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to a projected funds deficit. The coalition shall submit the notification to OEL with a copy of the two

most recent monthly use analyses and identify the enrollment priority group from which the coalition

plans to disenroll children due to a projected funds deficit and the projected number of children the

coalition plans to disenroll within the enrollment priority group.

The coalition shall make written notice, which includes the effective date of the child’s disenrollment,

to any affected child’s parent or guardian at least two weeks before the coalition disenrolls the child

from the School Readiness Program due to a projected funds deficit.


descending order, beginning with the highest enrollment priority, in accordance with s. 1002.87(1),

F.S.




disenrollment of a distinct subgroup within an enrollment priority (e.g., a school-age child older than

a specific age).



School Readiness Payment Validation (SRPV)


VPK Child Eligibility (VPKC)



VPK Payment Validation (VPKPV)

For file No. 13, submit to OEL clarification or proof that the coalition made an adjustment to EFS showing

the child’s April 19, 2013, absence.

For file No. 29, the May 29, 2013 absence, is outside of the program period, yet shows in the file as an

absence along with two other days absent in May 2013 that were within the VPK program period. The



adjusted for three days (one of which was not considered a VPK eligible day) instead of two.

For file No. 32, submit to OEL clarification of an electronic sign-in/sign-out process and missing information

or submit proof that the coalition provided provider training on the requirement that attendance

documentation contains the child’s name.

VPK Provider Eligibility (VPKP)


Administration and Budget Services Unit according to Fiscal Guidance 240.01 or submit documentation to OEL

demonstrating that the coalition submitted the appropriate repayment to OEL.

Data Accuracy (DA)


Suggested Business Practices

See the attached management addendum. OEL does not require corrective action for suggested business practices;

however, OEL highly recommends corrective action to improve the coalition’s service delivery.

Office of Early Learning Brevard Coalition Courtesy Review/Corrective Action Plan Page 1 of 14

EARLY LEARNING COALITION OF BREVARD COUNTY, AS13-14.01 Type of Response Date of Response

Coalition Courtesy Review Response December 27, 2013

Office of Early Learning Courtesy Review Response January 16, 2014

Coalition Corrective Action Plan February 17, 2014

Office of Early Learning Response to Corrective Action Plan February 27, 2014

Instructions for Corrective Action Plan due 30 days after report’s publication: (1) For all findings, corrected and

not corrected, identify the cause of the initial finding and how to ensure continued compliance. (2) For a finding

the coalition has not corrected since the review, the coalition should take corrective actions to comply with all

applicable statutes, rules, and recommendations.

III. Coalition Background Information Organization and staffing – The coalition has a staff of 12 employees who implement the programmatic aspects

of the coalition’s board of directors’ mission. The management staff includes the executive director, director of

quality assurance, director of business operations, director of program initiatives, director of human resources, IT

specialist, administrative coordinator, provider services administrator, finance administrator, family resource

administrator and two family services administrators.

Coalition courtesy review response:

Based on the role defined in this paragraph, two positions are not applicable. Please remove the “IT specialist”

and “administrative coordinator” from the above paragraph.

OEL courtesy review response:

Since providing the draft report to the coalition, OEL has reformatted the coalition background information

section. It will now read – “Organization and staffing – The coalition has a staff of 63 full-time employees who

implement the programmatic aspects of the coalition’s board of directors’ mission.”

V. Coalition Governance

CG-C. Previous Corrective Actions

1. NO Did the coalition implement CG corrective actions that the previous OEL-issued


Statute requires that private sector members make up more than one-third (more than 33 percent) of coalition

boards. In the coalition’s 2009 accountability review, the coalition was out of compliance with this

requirement and has remained so for 10 of the last 12 months. In its 2009 accountability review corrective

action plan, the coalition stated that it hired a partnership development manager to assist with board

recruitment. The coalition recently commuted its optional members to private sector status, satisfying this

requirement. However, OEL has not received documentation of the coalition’s board recruitment efforts since

2009.




coalition into compliance with the more than one-third private sector board member requirement.



The coalition would like to request adding, “It was determined that continued funding for the partnership

development manager was no longer feasible and not effective for board member recruitment.”


Based on the courtesy review, OEL will add the following language to the completed corrective action –

The coalition reported that it no longer employs a partnership development manager because it concluded that

the position was unfeasible and ineffective for board member recruitment.

VI. Operations and Program Management

OPM-A. Operations, Human Resources and Internal Controls

5. NO Have the coalition and its contractors implemented background screening procedures, as

set forth in the OEL Grant Agreement and applicable laws? (ss. 435.03, 435.04, 943.052 and

1002.84(9), F.S.; Early Learning Grant Agreement (45))

Coalition policies and procedures do not comply with s. 435.04, F.S., and Early Learning Grant Agreement

background screening requirements. OEL sampled 12 coalition employees and eight were out of compliance –

One employee received a Florida Department of Law Enforcement (FDLE) screening on Apr. 2, 2013,

although the coalition hired the employee on July 29, 2013. OEL did not receive documentation that the

employee received a required Federal Bureau of Investigation (FBI) National Criminal Records Check.

An employee hired on Oct. 2, 2006, does not have an FBI or FDLE background screening in her file. The

Agency for Health Care Administration deemed the employee “eligible” on Oct. 18, 2010.

An employee hired on Aug. 24, 2009, received an FDLE screening on Oct. 21, 2010, and does not have

an FBI screening on file.

An employee hired on Oct. 18, 2010, received an FDLE screening on Oct. 21, 2010, and does not have an

FBI screening on file.

An employee hired on Dec. 3, 2012, received FDLE and FBI screenings from ServPro on Sept. 24, 2013.

Three employees with ServPro FDLE and FBI screenings from Sept. 23, 2013, have hire dates of July 1,

2012, and July 1, 2013.

OEL recommends corrective action for noncompliance with operations and program management

criteria (OPM-A). For all uncorrected findings, the coalition should take the following corrective


Update and implement policies and procedures to require potential employees to submit to and pass level 2

criminal background screenings prior to the coalition making an employment offer.



Agreement outlines.


See the attached documentation (DRR_OPM.pdf, CharlieReese Background, Ken L Batie Background, and

StevenBrucato_Background) for consideration.


Following the exit conference with the coalition, OEL revised the language for the first required corrective action

to state, “Update and implement policies and procedures to require potential employees to submit to and pass

level 2 criminal backgrounds screenings within the timeframes the Early Learning Grant Agreement outlines.”


Based on the courtesy review, OEL will remove the following findings from the report –

An employee hired on Oct. 2, 2006, does not have an FBI or FDLE background screening in her file. The

Agency for Health Care Administration deemed the employee “eligible” on Oct. 18, 2010.

One employee received a Florida Department of Law Enforcement (FDLE) screening on Apr. 2, 2013,

although the coalition hired the employee on July 29, 2013. OEL did not receive documentation that the

employee received a required Federal Bureau of Investigation (FBI) National Criminal Records Check.

An employee hired on Aug. 24, 2009, received an FDLE screening on Oct. 21, 2010, and does not have an

FBI screening on file.

An employee hired on Oct. 18, 2010, received an FDLE screening on Oct. 21, 2010, and does not have an FBI

screening on file.

An employee hired on Dec. 3, 2012, received FDLE and FBI screenings from ServPro on Sept. 24, 2013.

The following findings will remain in the report –

Three employees with ServPro FDLE and FBI screenings from Sept. 23, 2013, have hire dates of July 1,

2012, and July 1, 2013.

The coalition still needs to complete the following corrective actions –



Agreement outlines.

Coalition CAP response:

The coalition submitted file(s) –

Feb. 14, 2014 –

OPM-A, “OPM-A Corrective Action Plan Corresponding narrative”

Feb. 26, 2014 –

Background_Security_Investigations_Corrected.

OEL CAP response:

ACCEPTED. The coalition submitted a revised process that indicates the coalition will complete, at minimum,

the level 1 background screening process for contracted service staff within the timeframes the Early Learning

Grant Agreement outlines. OEL requires no further corrective action.

However, OEL recommends the coalition remove the language stating “within ten days of hire” from its

background screening policy. Though this language aligns with the current (2012-2013) Early Learning Grant

Agreement, OEL does not expect it to be included in the 2014-2015 Early Learning Grant Agreement. OEL

recommends that, upon publication of the 2014-2015 Early Learning Grant Agreement, the coalition should revise

its background screening policy to reflect the agreement’s updated language related to level 1 background

screenings.

VII. Child Care Resource and Referral

CCR&R-A. Delivery of CCR&R Services

1. NO Does the coalition adhere to Quality Assurance Assessment requirements for CCR&R

services? (s. 1002.92, F.S.; Rule 6M-9.300, FAC)

OEL made two Quality Assurance calls and one online request to the coalition’s offices. OEL used the 2013-

2014 Quality Assurance Assessment Forms to determine compliance with this indicator. One call and the

online request met all requirements, and one call did not –


Call No. 1, placed on Sept. 12, 2013, did not meet element No. 4. The specialist asked for the caller’s race

and for the caller’s employer’s telephone number. The specialist told the caller that if the caller did not

provide the employer’s telephone number, the specialist would end the interview. Specialists are not

allowed to ask either question or demand the information from callers seeking CCR&R services.

The online request, placed on Sept. 17, 2013, met all requirements.

Call No. 3, placed on Oct. 17, 2013, met all requirements.

OEL recommends corrective action for noncompliance with CCR&R criteria (CCR&R-A). For all

uncorrected findings, the coalition should take the following corrective actions to comply with all

applicable statutes, rules and recommendations –

Provide staff training emphasizing the importance of meeting required CCR&R program elements, especially

only requesting required information during a CCR&R interview.


See the attached documentation (CCRR_A_1 and CCRR_QAA_phone_call) for consideration.


Based on the courtesy, this finding will remain in the report. OEL will note that the coalition completed the

corrective action. OEL requires no further corrective action.

CCR&R-D. Provider Information

1. NO Does the coalition provide the minimum information about each organization using the

provider update process? (s. 1002.92(3)(a), F.S.; Rule 6M-9.300(5), FAC)

OEL sampled five provider profiles in EFS. Two contained errors.

[The following table is for informational purposes and OEL will delete it from the final report.]

Provider Name Incorrect Information

Angel Kids Child Care Rates

Palm Bay Christian Preschool Additional fees, rates, enhanced

services, additional environmental

elements

OEL recommends corrective action for noncompliance with CCR&R criteria (CCR&R-D). For all



The coalition should provide evidence (EFS screen shots, update forms, etc.) to verify that the most recent

provider update forms match the information in EFS.

Provide and update annually before the CCR&R agency’s last business day in May a provider’s information

in the statewide information system that OEL maintains for each organization that offers family day care,

public and private child care programs, Head Start, prekindergarten early intervention programs, special

education programs for prekindergarten handicapped children, services for children with developmental

disabilities, full-time and part-time programs, before and after school programs, vacation care programs,

parent education, the TANF program and related family support services within the coalition’s service area

(Rule 6M-9.300, F.A.C.).

At a minimum, the CCR&R agency shall provide for each organization

Contact information.

Accreditation status.


Program styles offered.

Schedule.

Ages served.

Enrollment information and vacancies.

Curriculum type.

Private pay rates charged.

Environment.

Special services offered.

Languages other than English the provider’s staff speaks fluently.

Staffing.

Transportation.

Meal options.


See the attached documentation (CCRR_D_1a and CCRR_D_1b) for consideration.


Based on the courtesy review, OEL will remove the following findings from the report –

Angel Kids Child Care –

Rates – The coalition changed the rates the same day as the provider update. The coalition noted the

change in the history notes.

Palm Bay Christian School –

Additional Fees – The provider’s late fee is not a fixed amount but a percentage of the monthly amount,

and EFS does not allow percentages in the amount field.

Rates – The provider offers a variety of part-time enrollment options (e.g., five-day, three-day), and EFS

cannot accommodate entries for different varieties of part-time enrollment.

In order to clarify the reasons for the Additional Fees and Rates errors during future accountability reviews, OEL

added a Management Addendum observation stating –

The coalition was unable to correctly enter additional fees and rates into EFS for one provider profile. The

coalition could not enter the additional fees because the late fee is a percentage rather than a fixed amount,

and EFS does not allow the use of percentages in the amount field. The coalition could not correctly enter

rates because the provider offers a variety of part-time care options based on enrollment (e.g., five-day, three-

day). EFS is unable to accommodate multiple entries for care-type, making it impossible for the coalition to

enter all varieties of part-time rates.

Due to EFS’s inability to accommodate additional fees as a percentages and a variety of rates (e.g., five-day,

three-day) for part-time care, OEL recommends that the coalition add a History Notes entry indicating that the

coalition assesses additional fees as a percentage of the client’s rate and has several rates for part-time care

based on the number of days enrolled for part-time care. The history note would avoid confusion during

future accountability reviews.

The following findings will remain in the report. OEL will note that the coalition completed the corrective actions

Palm Bay Christian School –

Enhanced Services and Additional Environmental Elements.

OEL requires no further corrective action.


VIII. Educational Services Delivery

ESD-A. Staff Development, Training and Teaching Opportunities

1. NO Does the coalition demonstrate compliance with its SR plan for coordinating staff

development, training and teaching opportunities? (s.1002.83(13), F.S.; coalition plan section

2.4.1)

The coalition provided evidence it is coordinating staff development, training and teaching opportunities as

well as conducting curriculum training, developmental screenings training, pre- and post-assessment training,

and warm line services training.

However, the coalition is not in compliance with its current plan. One of the outcome measures for plan

section 2.4.1 states that the coalition expects SR and VPK instructors to use coalition scholarships to complete

continuing education courses. Though the coalition collaborates with other entities to provide training and

credentialing opportunities, it no longer provides scholarship funds for this purpose.


(ESD-A). For all uncorrected findings, the coalition should take the following corrective actions to

comply with all applicable statutes, rules and recommendations–





The coalition did not submit a response to this finding.


Based on the courtesy review, the finding will remain in the report. Respond to the above listed recommended

actions with the corrective action plan no later than 30 days after report publication.


The coalition submitted file ESD-A, which contains a revised plan section 2.4.1.

OEL CAP response:

ACCEPTED (pending implementation). The coalition submitted a draft of revised plan section 2.4.1. However,

the coalition still needs to adhere to the plan amendment process and receive approval from OEL prior to

implementing the revised plan section 2.4.1 as a business practice. The coalition should submit the revised plan

section 2.4.1 for OEL approval as soon as possible but no later than 30 days after OEL’s acceptance of the

coalition’s corrective action plan. Upon official submission through the plan amendment process of plan section

2.4.1, OEL will relieve the coalition of further action regarding this finding.

ESD-D. Strategies to Improve the Quality and Availability of Child Care Services

1. NO Does the coalition demonstrate compliance with its coalition plan for improving child care

service quality and availability? (s. 1002.85(2)(d), F.S.; coalition plan section(s) 5.1.1, 5.2.1,

5.3.1 and 5.4.1)

Plan section 5.3.1 states, “85% of providers and parents participating in educational opportunities will express

a gain in knowledge on the developmental needs of infants and toddlers.” The coalition provided evidence to

OEL that it offered training to providers on infants and toddlers and administered knowledge gains surveys to

providers based on the trainings. The coalition also submitted a parental education and engagement policy,

which includes a requirement to provide parents with educational materials and resources. The coalition


submitted to OEL examples of pamphlets to be distributed to parents and a list of library resources available

to parents, which is in compliance with coalition policy.

However, the coalition did not provide to OEL any evidence that it surveys parents participating in

educational opportunities or evidence of a tracking system that incorporated information from the completed

surveys to determine whether the coalition met the related outcome measure.


(ESD-D). For all uncorrected findings, the coalition should take the following corrective actions to

comply with all applicable statutes, rules and recommendations –


Survey parents to evaluate the outcome measure related to this plan element. Develop and use a tracking tool

to evaluate surveys providers and parents complete. Update or develop a process to include in the coalition

plan activities and performance measures that align with the outcomes the coalition plan states.


amendment, the coalition must also track the new outcome measure(s) once OEL approves the amendment.







The coalition submitted ESD_D_SurveyRevised, which contains a revised Customer Satisfaction Survey.

OEL CAP response:

ACCEPTED (pending implementation). The coalition submitted a revised customer satisfaction survey.

However, the coalition did not submit a tracking tool developed to evaluate surveys providers and parents

complete. Submit the tracking tool to OEL as soon as possible but no later than 30 days after OEL’s acceptance of

the coalition’s corrective action plan. Upon review and acceptance of the submitted tracking tool, OEL will

relieve the coalition of further action regarding this finding.

IX. School Readiness Eligibility

SR-V. Eligibility Policies, Priorities and Disenrollment

1. NO Does the coalition have clearly defined and written wait list procedures and eligibility

enrollment procedures that reflect the mandated eligibility priority categories for serving

children in the SR Program? (s. 1002.87(1) and (3), F.S.; Rule 6M-4.300, FAC)

The coalition is out of compliance with the following criterion –

The coalition appears to only place children who are 5 years old or younger on the wait list. Although its

policy states, “Each parent’s SR application meets preliminary eligibility requirements in order to be

placed or remain on the UWL,” the coalition’s practice is to verify that it only places children birth

through kindergarten age on the wait list. The coalition does not include all eligibility categories.

OEL ran a list from the Single Point of Entry (SPE) Unified Wait List (UWL) on Sept. 9, 2013, covering

July 1, 2013, through Aug. 31, 2013, and found 302 overdue wait list redeterminations.


2. NO Does the coalition have written policies and procedures that comply with s. 1002.87(7), F.S.,

and the Early Learning Grant Agreement for disenrolling children from SR services? (s.

1002.87(7), F.S.; OEL-FG-240.04; Early Learning Grant Agreement 12(e))

The coalition’s policy ELCB-SR-0006-08 does not fully comply with the 2012-2013 Early Learning Grant

Agreement and OEL-FG-240.04 requirements. The policy does not specifically address

The requirement to notify OEL at least 48 hours prior to the board initiating formal consideration to

disenroll a group of children from early learning programs due to a projected funds deficit.

The coalition must provide written notification to OEL at least five business days prior to taking action to

notify the provider or families of a determination to disenroll a child from early learning programs due to

a projected funds deficit.

OEL recommends corrective action for noncompliance with SR eligibility criteria (SR-V). For all



Submit a revised wait list procedure adhering to the eligibility priorities s. 1002.87, F.S., establishes and

permit staff to add children who qualify for school readiness services to the wait list according to Rule 6M-

4.300, FAC.

Develop a process that aligns with Rule 6M-4.300 and includes validating each name on the wait list every

six months by response to a letter, by phone or in person. Notification of such validation must give the parent

a specific timeframe in which to contact the coalition with updated information to maintain wait list

eligibility. Submit new process and an updated SPE UWL report to OEL.

Revise policy ELCB-SR-0006-08, in accordance with the 2012-2013 Grant Agreement and OEL-FG 240.04

dated Aug. 6, 2013, to explicitly state




The coalition shall make written notification to OEL at least five business days prior to taking action to

notify provider or families of a determination to disenroll a child from early learning programs due to a


The coalition shall make written notice, which includes the effective date of the child’s disenrollment, to

any affected child’s parent or guardian at least two weeks before the coalition disenrolls the child from

the School Readiness Program due to a projected funds deficit.


descending order, beginning with the highest enrollment priority, in accordance with s. 1002.87(1), F.S.




disenrollment of a distinct subgroup within an enrollment priority (e.g., a school-age child older than a

specific age).




For question No. 1, see the attached documentation (DRR_SR_Elig_a and DRR_SR_Elig_b) for

consideration.

For question No. 2, although the policy does not specifically address notifying OEL 48 hours prior to the

board initiating formal consideration nor notifying the providers or families at least five business days prior to

a disenrollment, it does state that after consulting with OEL to disenroll a group of children, the coalition will

mail parents and providers a letter of termination at least 30 days in advance of the termination date. Based on

the language, one can infer the 48 hour timeframe and five business day notification would be met since

providers and families would be informed 30 days in advance of termination due to a projected funds deficit.


We respectfully request the finding be changed to a business practice observation or technical assistance with

the requirement of updating our policy to explicitly state the language found in the 2012-13 Grant Agreement

and OEL-FG 240.04 (dated Aug. 6, 2013).


Based on the courtesy review, the finding will remain in the report. While OEL concurs that coalitions may

“establish a methodology for enrolling children from the waiting list and local rollover policies that take the

age of the child into consideration based on community needs and budget/forecast for direct services,” in

accordance with the OEL Implementing House Bill 7165 document, question 40, “coalitions must follow the

new requirements in law and serve all children included in the priority groups based on available funding.”

Therefore, the coalition must place all applicable eligibility categories on the wait list regardless of the

coalition’s ability or inability to provide services to each category based on funding.

The coalition should submit to OEL a revised wait list procedure adhering to the eligibility priorities that s.

1002.87, F.S., establishes, and permit staff to add children who qualify for school readiness services to the

wait list according to Rule 6M-4.300, FAC. Additionally, the coalition should provide staff training on wait

list placement practices and submit evidence of the completed training (e.g., agenda, sign-in/out sheet) to

OEL. Respond to the recommended actions with the corrective action plan no later than 30 days after report

publication.

Based on the courtesy review, OEL will remove this finding from the report. In response to the coalition’s

courtesy response, OEL contacted the OEL Data Quality Unit, which verified the issues the coalition

experienced with the SPE/UWL system. OEL accepts the coalition’s due diligence in reporting and

attempting to resolve the issues.

OEL added an observation to the Management Addendum stating –

OEL ran a list from the Single Point of Entry (SPE) Unified Wait List (UWL) on Sept. 9, 2013, covering

July 1, 2013, through Aug. 31, 2013, and found 302 overdue wait list redeterminations. In its Courtesy

Response, the coalition provided evidence to OEL that the high number of overdue wait list

redeterminations is due to technical issues with the SPE/UWL and that the coalition has performed due

diligence in attempting to remedy the problems.

The coalition should continue to perform its due diligence to validate each name on the wait list every six

months and should contact the OEL Data Quality Unit if problems persist.

Based on the courtesy review, this finding will remain in the report. OEL-FG 240.04 states that “a coalition

shall adopt a written policy that, at a minimum, provides for the following…” Due to the dates of the review

period for the Accountability Report AS13-14.01, OEL assessed the coalition’s disenrollment policy against

FG 240.04 (dated August 2012) and found the coalition policy did not align with the August 2012 version of

FG 240.04 due to the following missing language –

The requirement to notify OEL at least 48 hours prior to the board initiating formal consideration to

disenroll a group of children from early learning programs due to a projected funds deficit.

The coalition must provide written notification to OEL at least five business days prior to taking action to

notify the provider or families of a determination to disenroll a child from early learning programs due to

a projected funds deficit.

FG 240.04 (dated August 2012) states the requirement for the coalition to notify parents and providers 30

days prior to disenrollment, but the two required notifications to OEL must occur prior to the 30 day

notification to parents and providers. The coalition’s policy does not address the OEL timelines. FG 240.04

(dated August 2013) changed the timeframes for notification to parents and providers from 30 days to two

weeks.


The coalition should revise policy ELCB-SR-0006-08, in accordance with the 2012-2013 Grant Agreement

and OEL-FG 240.04 dated Aug 6, 2013, to explicitly state




The coalition shall make written notification to OEL at least five business days prior to taking action to

notify provider or families of a determination to disenroll a child from early learning programs due to a

projected funds deficit. The coalition shall submit the notification to OEL with a copy of the two most

recent monthly use analyses and identify the enrollment priority group from which the coalition plans to

disenroll children due to a projected funds deficit and the projected number of children the coalition plans

to disenroll within the enrollment priority group.

The coalition shall make written notice, which includes the effective date of the child’s disenrollment, to

any affected child’s parent or guardian at least two weeks before the coalition disenrolls the child from

the School Readiness Program due to a projected funds deficit.


descending order, beginning with the highest enrollment priority, in accordance with s. 1002.87(1), F.S.




disenrollment of a distinct subgroup within an enrollment priority (e.g., a school-age child older than a

specific age).



Submit the revised policy with the corrective action plan no later than 30 days after report publication.


The coalition submitted the following files –

Feb. 14, 2014 –

SR_WaitListPolicyNew.

The coalition submitted SR_TrainingNarrative.

The coalition submitted SR_WaitListProcedureNew.

The coalition submitted SR_DisenrollmentPolicyRevised.

Feb. 24, 2014 –

Wait_List_Policy_Draft_Corrected.

Feb. 27, 2014 –

CCRR Priorities and Waitlist Training Sign In Sheet 2.26.14

Priority Training 2.26.14

School Readiness Eligibility Priorities for New Enrollments Disenrollments and Rollovers

OEL CAP response:

ACCEPTED. OEL accepts the coalition’s response. OEL requires no further corrective actions.


XI. Voluntary Prekindergarten Child Eligibility

VPKC-B. Child Registration and Application (VPK and VPK SIS), Child Eligibility and Enrollment

Certificate (COE) and Parent Guide

2. NO Did the coalition determine that each child was eligible, and did the coalition issue a

completed, signed and dated Form OEL-VPK 02 (COE)/OEL-VPK 02S Part A (SIS COE)?

(s. 1002.66, F.S.; Rule 6M-8.202(1)(c), FAC)


OEL recommends corrective action for noncompliance with VPK child eligibility criteria (VPKC-

B). For all uncorrected findings, the coalition should take the following corrective actions to comply

with all applicable statutes, rules and recommendations –



The coalition needs to correct the following file(s) – #15







The coalition held a preliminary VPK training on Jan. 22, 2014 (training documents included). The coalition will

hold a more detailed follow-up training for all coalition staff on Feb. 26, 2014. The coalition will provide a

comprehensive review of all aspects of determining VPK eligibility during the training. The coalition will submit

to OEL a copy of the sign-in sheet and training materials following the training. The coalition submitted the

following files –

VPK_Cb_15.

VPK_Cb_Narrative.

OEL CAP response:

ACCEPTED. OEL accepts the coalition’s response. OEL requires no further corrective action.

XII. Voluntary Prekindergarten Payment Validation

VPKPV-A. VPK Attendance Monitoring

3. NO Does the Enrollment/Attendance Certification match the parent’s sign-in or sign-out sheets

and Form OEL-VPK 03S or Form OEL-VPK 03L? (s. 1002.71(6), F.S.; Rule 6M-8.305, FAC)

The following file(s) did not comply with all applicable statutes, rules and recommendations – #1, 4, 6, 13,

17, 29, 32

5. NO Do the sign-in or sign-out sheets or VPK-03L match the Final Provider Reimbursement

Report? (s. 1002.71(6), F.S.; Rule 6M-8.305, FAC)


The following file(s) did not comply with all applicable statutes, rules and recommendations – #1, 6, 17, 29


Certification or VPK-02S Part B (Schedule of Services)? (s. 1002.71(6), F.S.; Rule(s) 6M-

8.305, FAC)


The coalition has completed the following corrective actions –

The coalition corrected the following file(s) – #1, 4, 6, 10, 12, 13 (for A3 and A4), 17, 20, 29 (for A2, A3 and

A4), 31

OEL recommends corrective action for noncompliance with VPK payment validation criteria

(VPKPV-A). For all uncorrected findings, the coalition should take the following corrective actions


For file No. 13, submit to OEL clarification or proof that the coalition made an adjustment to EFS showing

the child’s April 19, 2013, absence.

For file No. 29, the May 29, 2013 absence, is outside of the program period, yet shows in the file as an

absence along with two other days absent in May 2013 that were within the VPK program period. The



adjusted for three days (one of which OEL does not consider a VPK eligible day) instead of two.

For file No. 32, submit to OEL clarification of an electronic sign-in/sign-out process and missing information

or submit proof that the coalition provided provider training on the requirement that attendance

documentation contains the child’s name.

The coalition needs to correct the following file(s) – #13 (for A6), 29 (for A5), 32 (for A3)







The coalition submitted VPK_PVa_13, a trial provider reimbursement report; VPK_PVa_29, a trial provider

reimbursement report; and VPK_PVa_32, a provider history report with sign-in/out summary.

OEL CAP response:

ACCEPTED. OEL accepts the coalition’s response. OEL requires no further corrective action.

XIII. Voluntary Prekindergarten Provider

VPKP-D. Statewide Kindergarten Screening; Kindergarten Readiness Rates

2. NO For all sampled providers on probation, did the coalition require the providers to submit

and implement an improvement plan according to rule? (ss. 1002.67 and 1002.69, F.S.;

Rule(s) 6M-8.700(2) and (4), and 6M-8.701(2), FAC)


The coalition did not provide documentation to OEL indicating it took steps to verify the provider

implemented the improvement plan for the 2011-2012 program year prior to allowing the provider to offer

services as Rule 6M-8.700, FAC, requires as of March 26, 2013.


(VPKP-D). For all uncorrected findings, the coalition should take the following corrective actions


Submit documentation to OEL that the coalition took steps to verify the provider implemented the improvement

plan for the 2011-2012 program year prior to allowing the provider to offer VPK services for the following

program year.


See the attached documentation (DRR_VPK_Provider.pdf) for consideration.


Based on the courtesy review, the finding will remain in the report. The documentation the coalition submitted to

OEL did not relate to the provider in question. Please refer to the VPK Provider scorecard for further information.

Respond to the above listed recommended actions with the corrective action plan no later than 30 days after report

publication.


The coalition submitted VPK_PVd_Narrative.

OEL CAP response:

ACCEPTED. Upon further review, OEL will remove this finding from the report. OEL requires no further

corrective action.

VPKP-G. VPK Provider Previous Corrective Actions

1. NO Did the coalition implement VPK provider corrective actions that the previous OEL-issued


The coalition’s corrective action plan from its most recent accountability review required the coalition to

submit a repayment plan to OEL’s Financial Administration and Budget Services Unit. As of Oct. 25, 2013,

the Financial Administration and Budget Services Unit had not received a repayment plan from the coalition.


(VPKP-G). For all uncorrected findings, the coalition should take the following corrective actions



Administration and Budget Services Unit according to Fiscal Guidance 240.01.




Based on the courtesy review, the finding will remain in the report.

Following the courtesy review exit conference, OEL modified the finding as follows –

According to the 2011-2012 ELC of Brevard Accountability Review Corrective Action Plan (CAP), OEL

required the coalition to submit a repayment plan to OEL’s Financial Administration and Budget Services


Unit due to an instructor failing to complete the early literacy training or equivalent, making the class invalid.

In the 2011-2012 CAP, the coalition acknowledged that it had not correctly validated the lead instructor’s

credentials and the provider, therefore, was not at fault and the coalition would not recoup funds from the

provider. As of Oct. 25, 2013, the Financial Administration and Budget Services Unit had not received a

repayment plan from the coalition.

OEL likewise modified the required corrective action. The coalition still needs to complete the following

corrective action –


Administration and Budget Services Unit according to Fiscal Guidance 240.01 or submit documentation to

OEL demonstrating that the coalition submitted the appropriate repayment to OEL.

Respond to the above listed recommended actions with the corrective action plan no later than 30 days after report

publication.


The coalition submitted VPK_PVg.

OEL CAP response:

ACCEPTED (pending implementation). OEL accepts the following corrective actions –

In order to comply with the OEL-approved corrective action plan for the ELC of Brevard Accountability

Report AU11-12.21, the coalition submitted to OEL a payment request invoice, a Final 5045 Report, a

scan of a corresponding check for $26,458.50 and associated Final Provider Reimbursement Reports.

As soon as possible but no later than 30 days after OEL’s acceptance of the coalition’s corrective action plan, the

coalition should submit payment totaling $26,458.50 to OEL. Once OEL processes the coalition’s payment, OEL

will relieve the coalition of further action regarding this finding.

Management Addendum

VPK Providers

The instructor for file No. 21 signed the Affidavit of Good Moral Character (AGMC) twice on July 17, 2012. One

signature verified that the instructor had possible disqualifying offenses and the second verified that the instructor

did not have possible disqualifying offenses. The level 2 background screening did not reveal any disqualifying

offenses. The coalition stated that the two signatures were in error. The instructor no longer works for the facility

and the coalition cannot correct the file.

Suggested Actions

Develop a process to verify that signatures on AGMCs accurately reflect instructors’ backgrounds and that the

AGMC matches the level 2 background screening.




Based on the courtesy review, OEL is removing this observation from the Management Addendum.

SHAN GOFF

EXECUTIVE DIRECTOR, OFFICE OF EARLY LEARNING

250 MARRIOTT DRIVE • TALLAHASSEE, FL 32399 • 850-717-8550 • Toll Free 866-357-3239 • www.FloridaEarlyLearning.com

FLORIDA DEPARTMENT OF EDUCATION

Pam Stewart

Commissioner of Education

MEMORANDUM

DATE: January 16, 2014

TO: Sky Beard, Executive Director, Early Learning Coalition of Brevard County

FROM: Reginal Williams, Program Integrity Manager, Office of Early Learning

SUBJECT: Management Addendum to Accountability Report AS13-14.01

As part of the Early Learning Coalition of Brevard County’s accountability review, OEL is

providing business practice observations for the coalition’s consideration. The observations are

attached to this memo as the Management Addendum to the accountability report AS13-14.01.

These observations are not a part of the main compliance report. The operational definition of an

observation is a specific instance, issue or circumstance that does not rise to the level of a finding

but does warrant being brought to the attention of OEL and the coalition’s management.

Observations can include items noted that increase the entity’s risk of potential non-compliance

and, if left unresolved, could generate findings in future program years.

Note that OEL does not require a response to any business practice observations or the

associated suggested actions. If the coalition decides to address these observations, do so in a

separate response within 30 days of the report’s publication.

Contact Andrea Ward, accountability review supervisor, at 850-717-8609, with any additional

questions.



Addendum to AS13-14.01

Page 2 of 5

MANAGEMENT ADDENDUM TO REPORT AS13-14.01

Observations

The Office of Early Learning (OEL) Program Integrity Unit, Accountability Section, verifies

compliance and accountability for early learning program implementation and operation through

sound standards and best practices. Although the Accountability Section has addressed

compliance issues within the report AS13-14.01that require a 30-day corrective action plan, the

observations noted below address suggested business practices and training issues. OEL

recommends that the coalition correct these issues to improve service delivery provided to

children and their families.

Coalition Governance

Coalition bylaws do not specifically address standing committees. The bylaws mention only

the Executive and Nominating committees by name, which implies they are standing

committees. The bylaws do not state that the Executive Committee has decision-making

authority or the authority to act on the board’s behalf between full board meetings in

emergency situations. However, the coalition submitted to OEL a chart of governance

documents that state, “When issues arise that must be addressed in a timely manner, the

Committee will have the authority to respond to allow coalition business to proceed.” The

coalition’s website lists additional committees – Finance, Legislative, Quality Improvement

and By-Laws.

The coalition’s Executive Committee appears to also function as a Finance Committee as

indicated in the title of minutes as Executive/Finance Committee.

The coalition has no written code of conduct guidelines, nor board member-signed code of

conduct forms.

The coalition bylaws do not address the executive director’s responsibilities.

Suggested Actions

Revise coalition bylaws to include–

Identification of standing committees.

A statement that the Executive Committee has final action authority in emergency

situations.

A statement identifying the Finance Committee as a standing committee or a revised title

of the Executive Committee as the Executive/Finance Committee.

A definition of the executive director’s responsibilities.

Develop a policy requiring board members to receive training on s. 112.313, F.S.,

requirements regarding a code of ethics. The policy should require that board members sign a

form stating they will comply with the requirements.

Operations and Program Management

The coalition’s fraud policy memo references the Agency for Workforce Innovation, which no

longer exists.



Page 3 of 5

Suggested Actions

Update the fraud policy memo to state that the coalition refers fraud cases to OEL.

Child Care Resource and Referral

The coalition was unable to correctly enter additional fees and rates into EFS for one provider

profile. The coalition could not enter the additional fees because the late fee is a percentage

rather than a fixed amount, and EFS does not allow the use of percentages in the amount field.

The coalition could not correctly enter rates because the provider offers a variety of part-time

care options based on enrollment (e.g., five-day, three-day). EFS is unable to accomodate

multiple entries for care-type, making it impossible for the coalition to enter all varieties of part-

time rates.

Suggested Actions

Due to EFS’s inability to accommodate additional fees as a percentages and a variety of rates

(e.g., five-day, three-day) for part-time care, OEL recommends that the coalition add a History

Notes entry indicating that the coalition assesses additional fees as a percentage of the client’s

rate and has several rates for part-time care based on the number of days enrolled for part-time

care. The history note would avoid confusion during future accountability reviews.

Educational Services Delivery

One of the outcome measures for plan section 2.4.1 states that the coalition will offer a

minimum of four VPK standards trainings each year. The outcome measure is in response to

the stated activity that the coalition will update its website on an as-needed basis and retain a

list of trainings the coalition mailed to providers. The coalition provided evidence to OEL

that it offered six VPK standards trainings by posting them to the coalition’s website between

July 2012 and February 2013. However, the outcome measure is not a direct indicator that

the coalition updated the website on an as-needed basis or that the coalition mailed training

lists to providers.

Activity 1a for plan section 4.2.1 states, “All eligible children 0-5 (not enrolled in school)

will receive a coalition approved screening at a minimum of twice per year. Screenings will

be done within 30 days of the age-appropriate tool.” Activity 1c states, “Providers will be

offered training and technical assistance on administering ASQ. At a minimum annually after

initial enrollment, providers will administer the age appropriate approved developmental

screening.” The activities conflict in wording and it is unclear whether the coalition requires

one screening per year or two. In addition, coalition policies and procedures state that

providers should conduct screening within 45 days of enrollment, rather than the 30 days

activity 1a states.

Suggested Actions

Update or develop a process to include activities and performance measures that align with

the outcomes the coalition plan states or submit a plan amendment to reflect current services

delivery.

Amend plan section 4.2.1 activities so that the screening process is clear and to align with the

coalition’s policies and procedures.



Page 4 of 5

School Readiness Eligibility

On Nov. 17, 2013, OEL’s Data Quality Unit ran a Unified Wait List (UWL) report for

children not on the coalition’s wait list. The report showed that the wait list contains a

“NULL” value for missing data rather than a “Date Off Wait List” date for the 15 sampled

cases.

OEL ran a list from the Single Point of Entry (SPE) Unified Wait List (UWL) on Sept. 9,

2013, covering July 1, 2013, through Aug. 31, 2013, and found 302 overdue wait list

redeterminations. In its Courtesy Response, the coalition provided evidence to OEL that the

high number of overdue wait list redeterminations is due to technical issues with the

SPE/UWL and that the coalition has performed due diligence in attempting to remedy the

problems.

Files No. 10, 11 and 12 did not have the recipient checked off as the parent receiving TCA.

The coalition’s policy ELCB-SR-0001-08 reflects eligibility priorities in effect prior to the

implementation of s. 1002, F.S.

The coalition’s School Readiness policy and procedure documents do not currently align

with 2013 Florida Statutes due to outdated information referencing 2012 Florida Statutes.

Changes to School Readiness policy and procedure implemented in the 2013 Florida Statutes

became effective Aug. 1, 2013, in accordance with chapter 1002, F.S. During the onsite

review, OEL discussed the outdated School Readiness policies and procedures with the

coalition. The coalition informed OEL that it is aware of the changes and is in the process of

revising its SR policy and procedure documents.

Suggested Actions

Complete the “Date Off Wait List” field to assist the coalition’s wait list management and

tracking of children the coalition removes from the wait list.

The coalition should continue to perform its due diligence to validate each name on the wait

list every six months and should contact the OEL Data Quality Unit if problems persist.

Submit to OEL documentation that the coalition provided staff training and communicated

with the referring agency.

Review policies concerning eligibility priorities and revise as necessary to bring the policies

into compliance with the requirements of s. 1002, F.S.

Review and revise the coalition’s School Readiness policies and procedures to align with ss.

1002.81-97, F.S.

VPK Child Eligibility

The coalition does not require parents or providers to sign the Child Eligibility and

Enrollment Certificate. Rule 6M-8.202(1)(c)1, FAC, states, “A coalition, upon determining

that a child is eligible for the VPK program, shall issue the child’s parent Form OEL-VPK 02

(Child Eligibility and Enrollment Certificate) dated February 14, 2007, which is hereby

incorporated by reference and may be obtained as described in Rule 6M-8.900, F.A.C.” Rule

6M-8.202(2)(a), FAC, states, “A VPK provider may only enroll a child in the VPK program

after the coalition determines that the child is eligible for the program. To enroll an eligible

child, the VPK provider admitting the child must submit the child’s certificate of eligibility

and the child’s assigned VPK class to the coalition.” Rule 6M-8.202(2)(d), FAC, further

states, “A coalition shall complete a child’s enrollment in the statewide information system



Page 5 of 5

by recording an association between the child and the child’s assigned VPK class. A

coalition is encouraged, but not required, to notify a parent by mail after his or her child’s

enrollment is complete.” While the coalition’s process implements the basic intent of rule,

the process should include requiring both the provider and parent to sign the OEL-VPK 02.

Having both parties’ signature will mitigate the risk of having challenges with properly

documenting VPK reenrollments, especially in the beginning of a VPK program year when

requests for reenrollments may be more prevalent.

The coalition’s Voluntary Pre-Kindergarten (VPK) Child Enrollment Procedures references

ch. 411, F.S.; Rule 60BB-8.20, FAC; and AWI-VPK01. In 2013, ch. 1002, F.S., replaced ch.

411, F.S.; Rule 60-BB-8.20, FAC, is now Rule 6M-8.20, FAC; and the AWI-VPK01 is OEL-

VPK 01. Additionally, the coalition submitted OEL’s Voluntary Prekindergarten (VPK)

Standard Eligibility Review Program Guide to document the coalition’s policies and

procedures.

Suggested Actions

Provide evidence of an updated process that requires both the parent and provider to sign the

OEL-VPK 02 as an official acknowledgement that the provider and parent agree to the

child’s enrollment at the provider’s site. The process should include evidence that the

coalition will retain the completed OEL-VPK 02 form. Provide proof to OEL of staff and

provider training regarding the updated process.

Update the coalition’s enrollment procedures to reflect current statute, rule and child

application. Further, if the coalition continues to use OEL’s Voluntary Prekindergarten

(VPK) Standard Eligibility Review Program Guide to supplement its policies and procedures

for VPK enrollment, the coalition should obtain and utilize a copy of the most current guide,

published Oct. 15, 2013.

Mark:

• Complete Review of Mission Statement, Survey of Existing Board Talent and Improve Technology (Priority Plan and affordable initial steps ASAP)

• Consolidate Diversified funding and increased community collaboration with the intent to

put a plan in place by summer

• Incorporate Parent Education into Improving Quality and have it as a first focused Quality initiative for the fall

Althea In review of the Quality Initiative list that was created at the January board meeting some of the ideas were also covered by the Diversified funding, Increase awareness through community collaboration and Parent education groups. The 2 consistent items running through the list are copied below with some timelines I believe are doable:

Quality Programs

• Identify Evidenced-Based practices (best practices) for quality – identify tool(s) to measure quality including safety by May 31, 2014

• Front-end education for providers – what it takes to run a quality company. Streaming education on “quality” at ELC, by July, 2014

• Importance of being voluntary • Support providers through mentoring programs

o Healthy competition o Utilize videotaping, provider reps, retired teachers/other providers,

shadow/visit other centers o Share good practices

Program Initiatives/Incentives

• Initiative – what is it? by June 2014 o Value

• Package as advantage to providers – new school year 2014 o Make them want it o Advertise as “best” o Contractual incentives

tiered reimbursement Reimbursement based on scores DCF/Licensing rewards for no infractions

• ELC funds for substitutes for teachers

3/17/2014

1

ELC Board of Directors meeting

March 18 2014March 18, 2014

Preliminary Waitlist Documentation Statistics

Timeframe ApplicationsSupporting

Documentation Received

Percent of Applicants Added

to Waitlist

1/25/14 – 1/31/14 41 22 54%

2/1/14 – 2/7/14 50 23 46%

2/8/14 – 2/14/14 46 13 28%

2/15/14 – 2/21/14 36 14 39%

2/22/14 – 2/28/14 23 8 35%

3/1/14 – 3/11/14 23 10 43%

VPK Readiness Rates

• The VPK Provider Kindergarten Readiness Rate measures how well a VPK provider prepares four-year-olds to be ready for kindergarten based upon the Florida Early Learning and Developmental Standards for Four-Year Olds. The VPK Standards describe what four-year-old children should know and be able to do by the end of their prekindergarten year.

VPK Readiness rates (12.13)

• Number of Providers (12.13) – 189 for School Year program– 7 for Summer program

• Number of Providers (11.12) – 196 for School Year program– 10 for Summer program

VPK Readiness Rates Verification process

Before Readiness Rates are finalized, providers and the Coalition are asked to:

– Review the list of children served in their program and submit corrected information if there are changes to the name, gender, date of birth or the number of hours each child attended If a child has not been matched to theirchild attended. If a child has not been matched to their kindergarten screening results, providers may also submit information concerning the child’s kindergarten attendance to assist the Department in the matching process.

– Coalitions review the information submitted and accept or decline any changes to the attendance data.

VPK Readiness Rates Verification process

Providers may also file a Dispute if they believe there are inaccuracies in:

• The number of children served • The number of children meeting substantial

completion • The number of children screened on any measure • The number of children in the readiness rate

calculation • Change of ownership during the program period

3/17/2014

2

VPK readiness rateverification process

Once all changes have been made the State Board of Education (SBOE) sets the minimum readiness rate. VPK providers who do not meet pthe minimum rate are designated as a Provider on Probation (POP) and must acknowledge their status and develop and submit an improvement plan.

VPK readiness rateverification process

• Of the 189 School Year VPK providers, 98 completed the online verification process (52%)

• Of the 7 Summer VPK providers, 6 completed the online verification process (86%)p ( )

Accounting for all providers, 53% completed the online verification process

Vpk readiness ratedispute process

Of the providers who verified information, 18 (17%) f d i f ti th t l d th t18 (17%) found information that lead them to dispute their rate.

VPK Readiness rates (11.12 Compared to 12.13)

Score Number of Providers (11.12)

% of Providers(11.12)

Number of Providers (12.13)

% of Providers(12.13)

POPs (<70) 27 13% 16 8%

70 - 75 13 6% 20 10%

76 - 80 13 6% 10 5%

81 - 85 26 13% 25 13%

86 - 90 35 17% 38 19%

91 - 95 31 15% 25 13%

96 - 99 8 4% 14 7%

100 41 20% 38 19%

No Rate 12 6% 10 5%

Providers on probation

• Of the 16 identified:– 12 are first year POPs– 3 are second year

1 is a third year (will need to apply for a Good– 1 is a third year (will need to apply for a Good Cause Exemption)

Historical POP data

Total Number of Providers

Number of LPPs/POPs

%

05.06 141 7 5%

06.07 154 16 10%

07.08 169 15 9%

08.09 189 14 7%

09.10 194 9 5%

10.11 204 39 19%

11.12 206 27 13%

12.13 196 16 8%

3/17/2014

3

Looking ForwardUpdates Kindergarten

ReadinessVPK

Trends

School Readiness Enrollment

Workforce Referrals

Percent of Children Meeting Substantial Completion and in the Rate

BREVARD

CNBB

FLAGLER/VOLUSIA

GATEWAYHILLSBOROUGH

IRMO

LAKE

NATURE COAST

PASCO/HERNANDO

PINELLASPOLK SANTA ROSA

SARASOTA

SOUTHWEST FL87%

89%

91%

93%

95%

13

STATEALACHUA

BIG BENDBROWARD

DUVAL

ESCAMBIA

FLAGLER/VOLUSIA

HEARTLAND

IRMO

MANATEE

MARION

MIAMI-DADE/MONROENORTHWEST FLORIDA

OKALOOSA/WALTON

ORANGE

OSCEOLA

PALM BEACH

PUTNAM/ST. JOHNSSEMINOLE

SOUTHWEST FL

ST. LUCIE

75%

77%

79%

81%

83%

85%

87%

Looking ForwardUpdates Kindergarten

ReadinessVPK

Trends

School Readiness Enrollment

Workforce Referrals

Percent of Programs with a Rate of 70 or Higher

ALACHUA

BREVARD

CNBB

GATEWAYMARION

NATURE COAST

NORTHWEST FLORIDAOKALOOSA/WALTON

PASCO/HERNANDO

PINELLAS

PUTNAM/ST. JOHNS

SANTA ROSA

SEMINOLE85%

90%

95%

14

STATE

BIG BEND

BROWARDDUVAL

ESCAMBIAFLAGLER/VOLUSIA

HEARTLAND

HILLSBOROUGH

IRMOLAKE

MANATEE

MIAMI-DADE/MONROE

ORANGE

OSCEOLA

PALM BEACH

POLK

SARASOTA

SOUTHWEST FL

ST. LUCIE

60%

65%

70%

75%

80%

Status of 14.15 CDBG Funding

City of Titusville – Award not yet announced

City of Cocoa – $7670 awarded

City of Melbourne – $12,000 awarded

City of Palm Bay – $13,500 awarded

Brevard County – Application not yet released

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Early Learning Coalition of Brevard County, Inc.

BYLAWS Article I

Name and Location of Organization

Section 1.1. Name of the Coalition The name of the organization shall be the Early Learning Coalition of Brevard County, Inc. hereinafter sometimes referred to as the Coalition. Section 1.2. Location of the Coalition The principal office of the organization shall be located in Brevard County. The Coalition may have offices within the county as the members may determine or as the affairs of the organization may require. Article II

Section 2.1. Purpose of the Coalition

Purpose, Intent and Responsibilities

It shall be the purpose of the Coalition to diligently and efficiently carry-out the intent of the School Readiness Act, the enabling legislation, set forth in Section 411.01 Florida Statute and House Bill 1A enrolled during the 2004 Legislative session, creating Part V of Chapter 1002, Florida Statute (as may be amended from time to time), including but not limited to: Assisting parents and the local community by providing opportunities for the at-risk birth to kindergarten population to enhance their opportunities for education success through participation in quality school readiness programs; reviewing the administrative and financial services and evaluating program performance related to early education and care that are provided by various groups; evaluating the performance of the various provider groups and distributing available funds to such groups in accordance with the intent of the School Readiness Act and the Early Learning Voluntary Education Program. Section 2.2. Not for Profit Corporation The Coalition shall promote and pursue its purpose and other lawful business through the exercise of powers permitted to not for profit corporations under chapter 617 of the Florida Statutes; provided however, that this corporation, in exercising it’s purpose shall do so as a tax exempt organization in accordance with Section 501 (c) (3) of the Internal Revenue Code of 1986, as amended.

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Article III

Membership

Section 3.1. Number of Members The Early Learning Coalition of Brevard shall have at least 15 members but no more than 30 members Section 3.2. Membership Members of the Coalition are mandated through the Florida Statute noted in section 2.1. These individuals serve continuously while they are in their respective positions. A member who no longer represents his/her constituency shall notify the chair in writing and their seat shall remain vacant until the organization or group they represent identifies a new representative. Selection of members shall be addressed by the Nominating Committee in accordance with the requirements set forth in Florida Statute. Section 3.2.1 Mandated Members

a. Circuit Administrator or designee, Department of Children and Families, District 7, who is authorized to make decisions on behalf of the department

b. Superintendent or designee, Brevard County Public Schools, who is authorized to make decisions on behalf of the department

c. Executive Director or designee, Brevard Workforce d. Director or designee, Brevard County Health Department e. Children’s Services Council or Juvenile Welfare Board Chair or Executive Director, if applicable f. Agency Head, Brevard County Environmental Health Services g. Head Start Director h. A representative of private for- profit child care providers, including private for-profit family child

care homes i. A representative of faith based child care providers j. A representative of programs for children with disabilities under the Federal Children with

Disabilities Education Act k. President or designee of Brevard Community College l. One member appointed by the Brevard County Board of County Commissioners or the governing

board of a municipality m. A central agency administrator, where applicable n. The Governor shall appoint the chair and two additional members, who shall meet the same

qualifications as private sector business members Section 3.2.2 Private Sector Business Members The Coalition will have more than 1/3 of its members from the private business sector as defined in the Office of Early Learning policy number OEL-PI-0003-05 or its amendments. The private sector nominations may be solicited from the Cocoa Beach Area Chamber of Commerce, Melbourne/Palm Bay Area chamber of Commerce; Palm Bay Area Chamber of Commerce, Titusville Chamber of Commerce; or economic development organizations.

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Section 3.3. Tenure of Coalition Members Members shall be elected so that there are always three classes of approximately equal size, with the term of each class ending in consecutive years in order to achieve the required consecutive three-year terms, with the exception of the Governor’s appointees who may serve 4-year terms. The initial members shall be elected for initial terms of three years, each which shall be considered one term. Members elected after the initial terms shall be elected for a term of three years. Members elected after March 1, 2006 shall be elected for a term of four years. Section 3.4. Membership duties Serving on the Coalition will require a commitment of time including regular coalition meetings, committee involvement, reading and becoming educated about many aspects of early childhood development and school readiness. 3.4.1 Representatives not appointed by the Governor who are elected prior to March 1, 2006 may serve a

maximum of two consecutive three-year terms. Representatives elected after March 1, 2006 may serve a maximum of two consecutive four-year terms. A representative elected to fill a position for one year or less will be eligible to serve two additional terms as described above. Members may be nominated to serve additional terms after a one year break in service

3.4.2 Any representative may be removed by a two-thirds (2/3) vote of a quorum of the members whenever, in

their judgment, the best interest of the organization would be served. The Chair prior to the next Coalition meeting shall give notice of removal in writing to the members.

3.4.3 Any member may resign by giving written notice to the Chair and the Executive Director of the

Coalition. Such resignation shall take effect at the acceptance of such resignation by the Coalition. 3.4.4 Members will not receive any compensation for their services. The Coalition may approve

reimbursement for expenses related to authorized Coalition business upon meeting. 3.4.5 Members of the Coalition are subject to the Ethics Provisions in Chapter 112, (Part III of the Florida

Statutes). 3.4.6 Unexcused absences from two (2) consecutive meetings or four (4) regularly scheduled meetings within

a fiscal year (July-June) by an appointed, voting member is equivalent to resignation from the Coalition. 3.4.7 Mandated members absent from two (2) consecutive meetings or four (4) regularly scheduled meetings

within a fiscal year (July-June) without due cause may be notified by the Chair that their membership is not in good standing.

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Article IV

Voting

Section 4.1. Voting All members of the Coalition shall have equal voting rights and equal privileges. 4.2.1. Fifty-one percent (51%) of the voting members shall constitute a quorum for the transaction of business

at any meeting of the Coalition. If less than fifty-one percent (51%) of the members are present at said meeting, a majority of the Coalition present may adjourn the meeting without further notice.

4.2.2. A quorum could be met by the use of a conference call, providing that the public is given proper notice of

a telecommunications meeting and reasonable access to observe and, when appropriate, participate. All recording requirements must be met.

Section 4.3. Meetings Regular meetings shall be held at a time and place to be decided by the members. The Coalition will meet as needed in order to conduct the coalition’s business. The date of any regular meeting may be changed by the Executive Committee in a scheduled meeting where a quorum of members is present. Notification of changes to a regularly scheduled meeting shall be publicly noticed within a reasonable amount of time. 4.3.1. The annual meeting of the Coalition will be held each year in the first quarter after the end of the fiscal

year. 4.3.2. Special meetings of the membership may be called by or at the request of the Chairman or Executive

Committee. The person or persons authorized to call special meetings may fix any place within Brevard County as the place for holding any special meetings called by them.

4.3.3. Agenda and Order of Business The Coalition Chair and Staff will establish an agenda and order of business to include a treasures report and public comment for each meeting held by the Coalition. 4.3.4. Minutes of all Coalition meetings shall be kept. These minutes shall be provided to members at least five

(5) days prior to the next scheduled meeting. 4.3.5. Meeting of the Coalition shall be open to the public. Section 4.4. Parliamentary Authority All meetings will be conducted in general accordance with the current edition of the

Modern Rules of Order.

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Article V

Officers

Section 5.1. Election of Officers A voting member shall be eligible for nomination and election to any elective office in the Coalition. 5.1.1. A Nominating Committee shall be elected by the Coalition members, and shall convene for the purpose

of certifying the eligibility of member candidates for office and to prepare an official slate of nominees. Nominations may be made from the floor.

5.1.2. Each elected officer shall take office at the end of the annual meeting where they will be installed and

shall serve for a term of one year or until a successor is duly qualified and elected. Officers may serve in the same position for a maximum of two consecutive years.

5.1.3. If an office is vacated prior to the scheduled expiration of the term the Chair shall call for voluntary

appointments to the vacated office. If more than one member volunteers, the Chair shall call for a ballot vote. If there are no voluntary appointments, the Chair may appoint a member to the office. The appointment will be approved by the members to fill the vacancy until the term ends.

Section 5.2. Officers of the Coalition 5.2.1. The Chairman shall preside at all meetings of the Coalition and perform the duties, which are usually

executed by the Chief Executive Officer. The Chair shall call for voluntary chairpersons appointments of all committees and may appoint a chairperson if there are no volunteers and perform such other duties as prescribed by the Coalition.

5.2.2. The Vice-Chairman shall perform the duties of the Chairman when the Chair is absent and have such

other responsibilities as may be designated by the Chairman. 5.2.3. The Treasurer shall keep an account of moneys received and expended for the use of the Coalition and

should make a report at all regularly scheduled Coalition meetings. 5.2.4. The Secretary shall ensure that notice required by these bylaws is given and shall keep records of all

proceedings of the Coalition. The Secretary may perform any other duties incident to the Office of Secretary.

5.2.5 In the event that any office of the Executive Committee (Chairman, Vice-Chairman, Treasurer, Secretary) becomes vacant and is seated with an interim position, the interim position is to be maintained as an officer until the next annual election, or until deemed necessary by a majority vote, at which time a new member may be elected.

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Article VI

Committees

Section 6.1. Committee Membership The Chair or Executive Committee may establish special committees as deemed necessary. The Chair will appoint the Committee Chair. 6.1.2. Each committee shall meet as necessary at meeting times designated by the committee Chair. 6.1.3. The committee Chair shall submit a written report to the members before the next regularly scheduled

meeting if official action is required by the Coalition. 6.1.4 Notice of all committee meetings will be made pursuant to Florida Statute 268.011. Section 6.2. Nominating Committee The members shall elect the Nominating Committee each year. The Nominating Committee Chair will be appointed by the Chair of the Coalition from among the nominating committee members. 6.2.1. Officers are to be elected during the Coalition’s Annual Meeting. At the prior meeting, the Nominating

Committee Chair shall call for nominations to be submitted prior to the Annual Meeting. 6.2.2. The Nominating Committee Chair shall submit a written slate of officers 30 days prior to the next

meeting. Nominations may be made from the floor. 6.3.3 The Coalition shall elect officers through the use of a ballot vote. Article VII

Section 7.1. Conflict of Interest

Conflict of Interest

The Coalition members and officers recognize their responsibility to protect the Coalition’s interests and avoid potential conflicts arising between the private interests of a Member, Officer, or Management Staff Member and his or her responsibilities. The Coalition members shall establish a conflict of interest policy designed to identify circumstances that would fail to serve the best interests of the Coalition. Such policy shall be reviewed at least annually as to its effectiveness and revised if necessary. A conflict of interest is a circumstance, condition, or situation in which the (a) personal interest of a Coalition member or officer, or (b) the interests of any principal by which he or she is retained of (c) the parent organization or subsidiary of a corporate principal by which he or she is retained, may result in personal, financial, professional, and political gain at the expense of or to the detriment of the Coalition and is purposes. Article VIII

Record Keeping, Fiscal Year, & Audits

Section 8.1. Record keeping

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Correct and complete books and records of the proceedings of the Coalition and its committees are the responsibility of the elected Secretary. Records of the coalition’s financial accounts are the responsibility of the Treasurer. Section 8.2. Fiscal Year The fiscal year shall commence on July 1 of each year. Section 8.3 Annual Audit The Coalition members shall be responsible for providing for an annual certified audit of the Coalition’s annual financial statements and any required compliance audits. Such audits shall be conducted by an independent firm of certified public accountants with demonstrated expertise in the area of publicly funded not for profit organizations. Article IX

Governance

Section 9.1 Governance Document The Coalition shall adopt a governance document. The Coalition’s interpretation of the governance document shall be considered the correct interpretation when reached by majority vote. Article X

Bylaws

Section 10.1. Implementation These Bylaws shall become effective immediately upon adoption. The Coalition’s interpretation of the bylaws shall be considered the correct interpretation when reached by majority vote. Section 10.2. Amendments These Bylaws may be altered, amended, or repealed and new Bylaws may be adopted by a 2/3 vote of the members present at any regular meeting or at any called meeting of the members, if at least fourteen (14) days written notice is given of an intention to alter, amend, or repeal these Bylaws at such meeting. These bylaws are a part of the Coalition’s early learning plan. Any amendment to them constitutes an amendment to the plan. Original Date: 08/26/99 1st

2 Revision: 09/21/99

nd


rd


th


th


th


th


th


th

10 Revision: 03/06/06 th Revision: 10/21/08

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11th

12 Revision: 01/19/10

th


th Revision: 3/11/13 14th

Revision: 3/18/14

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