The purpose of this policy is to describe the (1) additional internal controls and oversight measures taken by the DeSoto Parish School Board (the School Board) to manage federal funds received through the American Recovery and Reinvestment Act (ARRA) and (2) the duties and responsibilities of the various School Board departments and Central Office.


The School Board’s approach to managing federal funds is de-centralized.  Heads of departments and program staff make key decisions on whether to apply for federal funds or not, how to use these funds, and how to meet federal requirements that come with the acceptance of funds.  Central Office reviews these decisions through the budgeting, procurement, and reporting process.  The Superintendent and the School Board Members (our governing body) provide authority for departments to use federal funds, develop programs, and conduct program activities.


The School Board uses its existing control and oversight measures for federal funds to manage ARRA funds but where necessary will supplement these control and oversight measures to meet the requirements of ARRA.   All ARRA funds received and disbursed from inception of grant to October 14, 2010 were managed under our existing accounting internal control policies which were sufficient to meet the requirements of ARRA.


The additional control and oversight measures for ARRA outlined in this document are referred to DeSoto Parish ARRA Accountability Policies and Procedures.


The Federal ARRA funds received by the School Board are as follows:


  1. School Lunch Equipment Assistance – United States Department of Agriculture

  2. Title I Stimulus – United States Department of Education

  3. Idea B Stimulus – United States Department of Education

  4. Idea Preschool Stimulus – United States Department of Education

  5. ARRA- EETT – United States Department of Education

  6. Homeless Education Disaster Assistance – United States Department of Education

  7. Education Jobs Funds – United States Department of Education

  8. School Improvement Fund 1003(g) – United States Department of Education


The objectives of the DeSoto Parish ARRA Accountability Policies and Procedures are to:


  1. Avoid waste, fraud, and abuse;

  2. Ensure that costs charged to ARRA programs are allowable costs, in accordance with applicable laws, regulations, agreements, and contracts;

  3. Ensure that funds provided under ARRA awards are separately accounted for, from receipt to obligation to expenditure;

  4. Ensure that effective cash management is employed for Recovery funds to minimize the time elapsing between (i) the transfer of funds from the Federal Government, or from a pass-through entity, to (ii) disbursement;

  5. Ensure that the use of ARRA funds meet all federal requirements as described in individual ARRA grant awards and OMB Circulars;

  6. Fulfill ARRA act reporting requirements in a timely and accurate manner.




  1. Superintendent

    The Superintendent has and will sign all ARRA award certifications, budgets, and applications which are all necessary for the receipt and use of ARRA funds.

    The Superintendent is accountable for use of ARRA funds and must meet all ARRA requirements including transparency and reporting requirements.

    The Superintendent sets the priorities for use of ARRA funds awarded to the School Board.

    The Superintendent’s priorities are to:


  1. Save or create jobs and promote economic recovery;

  2. Use ARRA funds to stabilize the School Board’s fiscal situation;

  3. Invest ARRA funds wisely;

  4. Secure the maximum amount of ARRA resources available to the School Board;

  5. Apply federal accountability and transparency requirements;

  6. Fulfill federal reporting requirements.


The Superintendent delegated authority for oversight of ARRA Funds to the Business Department with oversight by the Director of Business Services and the Director of Curriculum and Instruction.


The Business Department and the Curriculum and Instruction Department develop and approve ARRA recovery plans and spending plans outlined in this policy for the various School Board Departments/Programs in charge of the ARRA funds.


The Director of Business Services, Director of Curriculum and Instruction, Grants Manager, and the various department/program heads meet on a periodic basis to discuss spending, budgets, and reporting requirements.  Policies and procedures are implemented by this group through memos, budget documents, in –person meetings, emails, and phone calls.


  1. Curriculum and Instruction Department

    The Superintendent appointed the Curriculum and Instruction Department to coordinate ARRA activities under the supervision of the Director of Curriculum and Instruction and the various Curriculum and Instruction Supervisors.  

    Responsibilities of the Director and the Supervisors include:


  1. Plan and coordinate ARRA activities for the School Board;

  2. Review and make recommendations on ARRA recovery and spending plans, submitted by the department/programs.

  3. Convene regular ARRA coordinators meetings.

  4. Communicate with ARRA coordinators on ARRA policies and procedural matters

  5. Act as a liaison with federal entities regarding ARRA policy and procedural matters.

  6. Participate in ARRA conferences, teleconference calls, and webinars.

  7. Produce reports that summarize ARRA awards to all departments and entities.


  1. Department /Program Supervisors/Coordinators

    The Superintendent has designated department/program Supervisor/ Coordinators over each ARRA award.  These individuals are responsible for developing and implementing a department level ARRA recovery plan consistent with federal guidance and the Superintendent’s priorities.  An ARRA recovery plan is an overall, written strategy for the use of ARRA funds received by a department. 

    Other responsibilities of the ARRA Supervisor/Coordinator include:


  1. Establish a department team.  This team will handle selection of projects and activities, approving expenditure of ARRA funds, and all ARRA related services.

  2. Convene ARRA team meetings on a regular basis.

  3. Ensure that federal agency, guidance, control, and oversight requirements are followed.   Design, and implement internal controls to effectively meet the requirements for ARRA funds as outlined in Office of Management and Budget’s (OMB) Circular A-133, OMB Circular A-133, Compliance Supplement Addendum #1, and All Executive Office of the President Memorandums. 

  4. Ensure compliance with the State and the School Board’s procurement policies as outlined in the DeSoto Parish School Board’s School Purchasing Manual.

  5. Maintain ARRA grant documentation for each ARRA award.  ARRA grant documentation should include the award letter, approved grant application, key correspondence, and other information between the School Board, State, and federal government.

  6. Track state matching fund requirement if any for ARRA funds

  7. Reconcile grant information such as expenditures to the School Board’s accounting system on a monthly basis.  This reconciliation is required for each ARRA grant prior to data being uploaded to the State.


  1. Business Department

    The Business Department responsibilities for the management of ARRA funds are to:


  1. Reconcile grant information such as expenditures to the School Board’s accounting system on a quarterly basis.  This reconciliation will be required for each federal grant prior to data being uploaded to the State government.

  2. Ensure that quarterly reports for each ARRA award are reported on time.

  3. Prepare quarterly reporting and ensure that reports are submitted on time.

  4. Prepare requests for reimbursement reports that are accurate and timely.

  5. Develop and implement an internal monitoring plan for ARRA awards (when funds and resources become available). 

  6. Assist departments/programs with developing and implementing internal controls and processes to manage ARRA funds and reduce overall risk level.

  7. Require ARRA funds be expended according to procurement requirements.

  8. Issue ARRA procurement procedures and provide training on these procedures.

  9. Assist the departments and make sure they meet reporting, transparency, and other requirements.

  10. Make sure all ARRA funds are accounted for in separate funds from receipt to obligation to expenditure.

  11. Maintain files with all ARRA grant documentation the same as the departments as a backup.

  12. Review ARRA expenditures requests for consistency with Federal guidelines and Superintendent’s priorities.

  13. Ensure effective cash management of ARRA funds.

  14. Assist all departments in meeting ARRA reporting requirements.




The Louisiana Department of Education will collect and report the School Board’s data for ARRA funds.  The eGMS (eGrant) system will be utilized as the collection and mechanism for all ARRA grants.  The School Board’s Business Affairs Department is responsible for reporting ARRA expenditures in the eGMS system.  The Grants Manager has eGMS payment system access for the ARRA application managed through eGMS for all ARRA funds of the School Board.  The ARRA Grant Bookkeepers prepare all requests for reimbursement and Periodic Expense Reports.  All reports are reviewed by the Grants Manager before submission.  The ARRA Grant Bookkeepers creates all requests for reimbursement.  The Grants Manager submits the Periodic Expense Reports.  All requests for reimbursement are signed and approved by the Superintendent or his designee.  The Business Department is responsible for the timely submission of accurate reports.  If necessary, the Business Department will make corrections to any reports and/or requests for reimbursement.


Expenditure data will be posted in the General Ledger and reports will be derived from the School Board’s financial accounting system.  School Board jobs data will be calculated from payroll and other data in the School Board’s Payroll/HR system.  To ensure accuracy and timely submission of data the best available financial and jobs data will be reported.  For quarterly reporting, in some cases the quarter-end data might be incomplete or inaccurate.  The most current accurate data available will be reported.  As reports are cumulative, any information for the previous quarter not reported by the 5th day after the end of that quarter will be included in the next quarterly report.


If the School Board is notified that corrections are needed to any reports filed, corrections will be made in a timely manner.


  1. Periodic Expense Reports

    The first ARRA reporting period represents expenditures from Award Date through September 30, 2009 and must be reported to the Federal Government no later than October 10, 2009. 

    The School Board must submit a PER (Periodic Expense Report) through eGMS no later than 5 days after quarter end to allow for statewide data to be prepared for transmission by the tenth day after quarter end.  The PER summary page by object code as well as the EIC breakdown must reflect obligations for quarter end.  However, there will be an additional field to collect actual expenditures as of quarter end.

    The PER will be modified to include an additional page for ARRA data collection.  A page to collect expenditures by EIC (Education Improvement Code) will also be added for Title I, IDEA Part B, IDEA Preschool ARRA programs.  The School Board is required to have a DUNS number.  The DUNS number will be collected on the Central Contacts page within eGMS.  The School Board must maintain an active registration with the Central Contractor registry (CCR) as well.  The CCR expiration date will also be required and will be collected on the Central Contacts Page. 

    ARRA reporting data to be collected outside of eGMS:


  1. Title I School Improvement will be collected through the Consolidated State Performance Report.

  2. Food and Nutrition will be collected through the Child Nutrition Programs Website.


The Louisiana Department of Education will pre-populate as much of the data as possible.  The following information will be collected.  This is subject to change as additional guidance is provided.  The School Board Information that will be collected is as follows:


  1. Total amount of recovery funds received from that agency

  2. The amount of recovery funds received that were expended or obligated to projects or activities

  3. A detailed list of projects or activities for which recovery funds were expended or obligated including the name of the project or activity, a description of the project or activity, and an evaluation of the completion status of the project or activity.

  4. Number of jobs created or retained by the project or activity

  5. Description of Jobs Created

  6. DUNS Number

  7. Pillar and Implementation Values shall be reported using the following values:



  1. Vendor Level Information shall include the following information and will repeat for up to 15 vendors and is required for any sub award of $25,000 or greater:



  1. A page containing a certification statement has also been added to the PER that will require the submitter of the PER to check off in agreement that the data being reported is complete and accurate to the best of their knowledge. 

  2. A narrative detailing how estimates were calculating regarding jobs created and saved along with any supporting documentation must be provided.  The document can be uploaded with the PER.  Documents must be in Word or PDF.  A document must be uploaded to submit the PER so if no estimates have been completed then a document stating such should be uploaded. 

  3. Job estimates must be reported on a quarterly, not cumulative, basis.  

  4. The School Board is not required to make a subjective judgment on whether jobs were created or retained as a result of the Recovery Act. 

  5. Jobs created or retained are to be reported as hours worked and paid for with Recovery Act funds.

  6. Complete and submit the ARRA Job Worksheet sent quarterly to the Louisiana Department of Education.


  1. Requests for Reimbursements

    Requests for Reimbursements should be prepared monthly and filed with 30 days of month end.  Expenditure reports and payroll data obtained from the School Board’s financial accounting and HR/Payroll system should be used to prepare those requests.  Reconciliation of expenditures to financial data should be prepared before submission and analytical procedures should be performed to determine that information is accurate.


Adopted:  December, 2010

Recoded from DDB and Revised:  June, 2012



Ref:    American Recovery and Reinvestment Act of 2009, (Public Law 111-5)

Board minutes, 12-9-10, 6-28-12


DeSoto Parish School Board