Course Description:

The Vocational Education Amendments of 1976 mandated a federal audit of every state’s vocational education program. For many states, colleges and districts, that may have been the last thorough examination of the internal controls for CTE eligible recipients and eligible state agencies. Due to the fact that Subpart F of the Uniform Guidance only requires single audits to cover “major programs”,

expenditures and controls for costs under Perkins CTE, AEFLA, and WIOA often are not audited. And because these smaller programs are often not audited, administrators may be emboldened to undertake greater risks. Accordingly, the Inspector General at ED now reports an increased focus on fraud, including financial conflicts of interest, falsified documentation, missing property, persistent internal control issues, irregularities in contract awards, unverifiable vendors, low quality products and services, and unreasonable

costs. In this session, Steven Spillan and Michael Brustein will discuss steps and strategies that colleges, districts, non-profits, and state agencies should consider to reduce the risk of non-compliance relating to the expenditure of CTE, AEFLA and WIOA funds. In addition, we will discuss the responsibilities of “pass-through” entities to implement robust monitoring protocols, particularly

where there is no single audit review of these programs.