ATTACHMENT 3 Schopp, Melody (DOE) I I From: Campbell, Roger Sent: Wednesday, August 01, 2012 9:16 AM To: Schopp, Melody (DOE) Subject: draft Melody, If you have some Take a look at let me know what you think. i certainly don?t want it to be an indictment against the Department or anyone else. I also don?t want to have it sound defensive either. if you would like i can also provide other documents that have prepared for you if you think that will be useful. I don?t know how effective this format is but i know the length doesn?t do the situation justice. l'C Background of the Office of Indian Education In 2003 the Interim Secretary of Education, Tom Hawley, visited with me regarding a concept that he was hoping that he could begin to make a reality in the state of South Dakota. Through his association with the Council of Chief State School Officers(CCSSO) he learned of certain states who had dedicated specific personnel or resources to address the challenges faced in the area of Indian Education. There was action that was initiated to bring together an informal work group to help redevelop some basic framework for the office or individual who would direct the effort of the Department of Education in the area of Indian Education. Prior to the department actually selecting someone to lead the effort the decision Was made to begin or reinstitute an annual summit or conference dedicated to identifying proven models of success in the education of native students across the state. The DOE held the first Indian Education Summit later that year and the following year the Department hired a Indian Education Coordinator. Background 'of Gaining Early Awareness and Readiness for Undergraduate Programs (Gear Up SD) In 2005 the SD DOE became involved with the Gear Up program through a partnership with the Oceti Sakowin Education Consortium (OSEC), who was represented by Ted Hamilton and Stacy Phelps. The competitive application for funding to the USDOE for a statewide Gear Up initiative had a focus towards focusing on an American Indian student population but it did not include significant representation from public schools rather it focused mainly on the Tribal/BIE school population. It did include some public school districts with?significant native populations. From 2005-2011, which were the dates for the first Gear Up grant, the program has been run? with almost complete autonomy with Mid-Central Education Cooperative assuming the fiscal agent role and the OSEC organization working as a conduit for the Tribal/BIE schools. When I initially took the position of Indian Ed. Director in 2011 there were a number of challenges that had been communicated to me from the DOE about Gear Up and a more recent grant, College Access Challenge. The Gear Up 1 grant had more history in terms of questions about accountability specifically but both grants and the management of each has been a point of contention in the department as well as certain agencies outside the department. Because that the first Gear Up Grant had seen three DOE Secretaries and four Directors i didn?t feel it prudent to proceed with implementing any changes to fiscal policies and certainly not the programmatic make-up of Gear UP or College Access Challenge. i In September of 2011 the SD DOE was awarded a new GU Grant in the amount of approximately $24 million dollars for seven years. Prior to the notification of award had informed. the Gear Up Project Coordinator and contractors of pending changes in terms of establishing accountability. There was a delay in the contracting process. in 2011, on at least two separate occasions, I had approached both and MCEC staff/leadership regarding changes to fiscal reporting due to some of the concerns that had been brought forth regarding the Gear Up program. From the beginning have been transparent with the Finance and Grants Management department as well as the department leadership in my approach. I have kept Department in the loop regarding the expectations that have set forth for regarding fiscal reporting. At no time has the intent of my actions ever been questioned by the Department. but rather have been encouraged to continue to seek a level of accountability that has been non-existent since the inception of the first SD Gear Up Program. Accountability - in terms of staff who have been paid under the grants, a detailed determination of which staff was paid by which grant and what percentage of their time was allocated to the respective grants. When this request has been made it took 2 months for one of the contractors to produce an FTE list and grant allocation for each employee and it was inconsistent with what was presented in terms of the budget. Certain individuals were not accurately defined in terms of grant responsibilities. There were also instances of certain employees being paid from both grants at amounts inconsistent with SD DOE standards. There were dollars attempted to be expended that were without grant agreement or contract and based on our agreement with the contractor were not reasonable or necessary. When the request has been made in terms of which schools are assigned to which of the seven Outreach Coordinators, there is difficulty or delay in providing the requested information. The amount and purpose of travel is also in question because travel policies were not in place or were not followed. There is question about the necessity of certain supplies and equipment expenditures. Prior to the new Gear Up grant none of the accountability measures that lam instituting had been followed. We have also communicated to the feds through the annual performance report that there were certain activities that had taken place but in fact they had not. There has also been a lack of checks and balances with the fiscal responsibilities. The Business Manager for Mid Central Education Cooperative (MCEC) is also the CFO American lndian institute for Innovation who is another grant partner. He also serves in the capacity of Business Manager for the Oceti Sakowin Education Consortium (OSEC) who is another grant partner. The Assistance Business Manager for MCEC is paid at 80% FTE directly off of the Gear Up grant but is titled as Data Specialist. The Business Manager for All! is a MCEC employee who in the past was the highest paid employee paid out of the College Access Challenge grant. We are almost to the end of the seventh year of Gear Up in SD and to date there has never been an audit of this federal program. i have requested that the Department consider an audit of one of the previous grant years. it has been decided that the Department will move forward with increased diligence in the monitoring of both of these grants now that we have established an improved level of grant administration from MCEC but i suggest that we consider doing an audit of certain line items of the budget to include Personnel, Travel, Supplies Equipment. Transparency in terms of the level communication from the department and the contractors about the activities of the grant and staff; I am trying to ascertain which personnel performs what function. Historically, there has been little effort by the Project Director to provide oversight of the program. Over the last six months i am attempting to gauge what activities are actually taking place and who is conducting them; the Gear Up staff, either through MCEC, or the schools. have initiated a process in which the partners of each respective grant have a copy of the plan so that they better understand their role within the framework of the grant. We are hoping to delineate between the organizational 2 partners. It has been determined that agreements between MCEC and other partners have been incorrect or have not been in place which is not following proper grant administration. There has not been an collective effort to effectively communicate with the SD DOE in terms of grant initiatives nor has there been attempts at building relationships to improve the data collection efforts so that we can more effectively assess and measure the program. Clarity? In terms of understanding what the goals and objectives of the grants are and the determination of the effectiveness of their implementation. It is the responsibility of the DOE to ensure the oversight and integrity of the grant and its initiatives by working with the independent external evaluator to measure the effectiveness of the grant. Historically the Gear Up program has suffered from objectivity in its assessment due to the relationship between the contractor and evaluator. Currently, through a competitive bid process, the DOE has contracted with an Independent External Evaluator who will assist in providing a fair and unbiased assessment to the effectiveness and efficiency of the Gear Up program. As the current Project Director have certain responsibilities to both the SD Gear Up grant and SD College Access Challenge grant. I believe anecdotally have been accused of being misguided or ill-intentioned but if you look at the collective effort of what I have tried to bring to the situation, it can be determined that have acted in the best interests of the SD DOE in trying to manage these grants with an improved amount of accountability, transparency and clarity. SchoPP. MJejody (DOE) ATTACHMENT 4 From: Campbell, Roger Sent: Wednesday, August 01, 2012 10:56 AM To: Schopp, Melody (DOE). Subject: Additional information This PDF is the document that Dan, Stacy and Scott came to present to you last April. l?ve cut and pasted rebuttal to some of those concerns. . seer-rm sweeper There are 13 different points that made and l?ll try to limit my responses which i didn?t provide at the meeting. 1. We?re all partners but SD DOE is the lead partner; i feel that the other partners will provide whatever 10. financial/programmatic information that we request . There have been no significant changes to programmatic issues that would warrant input There is email dialogue between the partners that somewhat contradicts this statement; I received from grants management the instructions for grant request in mid~December; I requested the grant early February and we actually sent them the contract on 2.19.12; they took a month to get it back and we signed it on 3.20.12 Similar situation to money being dispersed using their own discretion and when the school payments became an issue they blame DOE They?ve expended the resources on staff but have not paid the schools which is a large part of the data collection needed for the prepared the response to the Program Officer about these concerns; in that report were inaccuracies about the actual progress of the project This situation is similar to the contracting process; additionally, BCKuhn indicated on last week?s call that they APR was just a report and data collection that was separate from the program evaluation that the independent External Evaluator was going to be doing; that was her respOnse when I asked about a possible conflict of interest because she had submitted an RFP to be the independent External Evaluator while already contracted to do the data collection for don?t feel that they can pick and choose to independently spend money without a contract and then also use it as an excuse l?m not sure when and where it has been stated to have these ?Project Management Team? meetings; additionally, the Project Director has not been involved in a number of the management issues that the Work Plan requires and have apparently taken place without the oversight or inclusion of the Project Director; once again, a double-standard with theuse of the Work Plan. I?m not sure why this was a concern; we never indicated any changes regarding the partner schools Per Jan Martin there, were no boundaries crossed ?-The intent of the questions/observations about working with DOE to collect needed data was to assist the SDGU staff with data collection so that the data was consistent and accurate when reported for APRs, evaluations, or in other settings. A sample of the data available through SDAP was provided to illustrate how student data without names can be obtained for use in the data collection. As a person working with large amoUnts of secure data for both NAEP and for SD DOE, the need for protecting the rights of students is paramount in the processes used for reporting. There was never the intention to do anything with the data provided. Based on the MOU between the state and the schools must know that the DSTEP data goes through SD DOE before it goes to the for determining AYP. Additionally, all the BlE/tribal/other private schools in the state have access to their school?s data through SDAP/elVletric so that the data sample was provided as a way to educate project staff on what is possible. 1 11. The Project Director was asking questions to gauge the effectiveness and efficiency of the Gear Up Program; at no time was it suggested that we were going to make any significant programmatic changes. The statement that the project is not going to collect student achievement data seems to go against the needed data for the evaluation plan. In addition, the collecting of student data in the data system the project is implementing calls for test data among other data. The case was made in the proposal that the database was needed because the BIE/tribal schools have a different data system. On page 1:1 of the project abstract, it states that state assessment scores will be used as part of the overall evaluation. On page 8:45, objectives 1.8 and 1.9 require the collection and analysis of state assessment scores for participants/participating schools. 12. We will access any data from the BIE that is necessary and allowable to effectively and accurately measure the impact of the SD Gear Up Grant; I Will go to each and every school with this message and if they don?t wish to provide we can reallocate resources to other eligible schools/students. Again, there are numerous places in the grant application that indicates that assessment data are part of the overall data collection needed to satisfy federal requirements. 13. IVICEC has not consulted with the SD DOE in the past regarding this financial information on the SD Gear Up funds or the SD CACG funds which they should have been doing all along; if they would have checked, SD DOE would have provided the information. Roger Campbell (605) 773-3 783 From:'CampbelI, Roger Sent: Wednesday, August 01, 2012 9:16 AM To: Schopp, Melody (DOE) Subject: draft Melody, If you have some Take a Iook at let me know what you think. i certainly don?t want it to be an indictment against the Department or anyone else. I also don?t want to have it sound defensive either. If you would like I can also provide other documents that i have prepared for you if you think that wiII be useful. 1 don?t know how effective this format is but i know the length doesn?t do the situation justice. Background of the Office of Indian EduCation In 2003 the Interim Secretary of Education, Tom Hawley, visited with me regarding a concept that he was hoping that he could begin to make a reality in the state of South Dakota. Through his association with the Council of Chief State School Officers(CCSSO) he learned of certain states who had dedicated specific personnel or resources to address the challenges faced in the area of Indian Education. There was action that was initiated to bring together an informal work group to help redevelop some basic framework for the office or individual who would direct the effort of the Department of Education in the area of Indian Education. Prior to the department actually selecting someone to lead the effort the decision was made to begin or reinstitute an annual summit or conference dedicated to identifying proven models of success in the education of native students across the state. The DOE held the first Indian Education Summit later that year and the following year the Department hired a Indian Education Coordinator. Background of Gaining Early Awareness and Readiness for Undergraduate Programs (Gear Up SD) In 2005 the SD DOE became involved with the Gear Up program through a partnership with the Oceti Sakowin Education Consortium (OSEC), who was represented by Ted Hamilton and Stacy Phelps. The competitive application for funding to the USDOE for a statewide Gear Up initiative had a focus towards focusing on an American Indian student population but it did not include significant representation from public schools rather it focused mainly on the Tribal/BIE school population. It did include some pUblic school districts with significant native populations. From 2005-2011, which were the dates for the first Gear Up grant, the program has been run with almost complete autonomy with Mid-Central Education Cooperative-assuming the fiscal agent role and the OSEC organization working as a conduit for the Tribal/BIE schools. When I initially took the position of Indian Ed. Director in 2011 there were a number of challenges that had been communicated to me from the DOE about Gear Up and a more recent grant, College Access Challenge. The Gear Up grant had more history in terms of questions about accountability specifically but both grants and the management of each has been a point of contention in the department as well as certain agencies outside the department. Because that the first Gear Up Grant had seen three DOE Secretaries and four Directors I didn?t feel it prudent to proceed with implementing any changes to fiscal policies and certainly not the programmatic make?up of Gear UP or College Access Challenge. In September of 2011 the SD DOE was awarded a new GU Grant in the amount of approximately $24 million dollars for seven years. Prior to the notification of award I had informed theGear Up Project Coordinator and contractors of pending changes in terms of establishing accountability. There was a delay in the contracting process. In 2011, on at least two separate occasions, I had approached both AMI and MCEC staff/leadership regarding changes to fiscal reporting due to some of the concerns that had been brought forth regarding the Gear Up program. From the beginning I have been transparent with the Finance and Grants Management department as well as the department leadership in my approach. I have kept Department in the loop regarding the expectations that I have set forth for regarding fiscal reporting. At no time has the intent of my actions ever been questioned by the Department. but rather have been encouraged to continue to seek a level of accountability that has been non?existent since the inception of the first SD Gear Up Program. Accountability In terms of staff who have been paid under the grants, a detailed determination of which staff was paid by which grant and what percentage of their time was allocated to the respective grants. When this request has been made it took 2 months for one of the contractors to produce an FTE list and grant allocation for each employee and it was inconsistent with what was presented in terms of the budget. Certain individuals were not accurately defined in terms of grant responsibilities. There were also instances of certain employees being paid from both grants at amounts inconsistent with SD DOE standards. There were dollars attempted to be expended that were without grant agreement or contract and based on our agreement with the contractor were not reasonable or necessary. When the request has been made in terms of which schools are assigned to which of the seven Outreach Coordinators, there is difficulty or delay in providing the requested information. The amount and purpose of travel is also in question because travel policies were not in place or were not followed. There is question about the necessity of certain supplies and equipment expenditures. Prior to the new Gear Up grant none of the accountability measures that I am instituting had been followed. We have also communicated to the feds through the annual performance report that there were certain activities that had taken place but in fact they had not. There has also been a lack of checks and balances with the fiscal responsibilities. The Business Manager for Mid Central Education Cooperative (MCEC) is also the CFO American indian Institute for innovation (Alli) who is another grant partner. He also serves in the capacity of Business Manager for the Oceti Sakowin Education Consortium (OSEC) who is another grant partner. The Assistance Business Manager for MCEC is paid at 80% FTE directly off of the Gear Up grant but is titled as Data Specialist. The Business Manager for Alli is a MCEC employee who in the past was the highest paid employee paid out of the College Access Challenge grant. Transparency in terms of the level communication from the department and the contractors about the activities of the grant and staff; i am trying to ascertain which personnel performs what function. Historically, there has been little effort by the Proiect Director to provide oversight of the program. Over the last six months i am attempting to gauge contractor and evaluator. Currently, through a competitive bid process, the DOE has contracted with an independent External Evaluator who will assist in providing a fair and unbiased assessment to the effectiveness and efficiency of the Gear Up program. As the current Project Director i have certain responsibilities to both the SD Gear Up grant and SD College Access Challenge grant. i believe anecdotally i have been accused of being misguided or ill-intentioned but if you look at the collective effort of what i have tried to bring to the situation, it can be determined that have acted in the best interests of the SD DOE in trying to manage these grants with an improved amount of accountability, transparency and clarity. ATTACHMENT 5 Sch0pp. Melody (DOE) From: Schopp, Melody (DOE) Sent: Wednesday, August 01, 2012 4:24 PM To: 1 Campbell, Roger Subject: RE: Additional information Roger We need to stop doing this back and forth thing. i don?t know where any of this is going and it seems all this is going to do is further the issues. This was April it is useless at this point to address the issues again.ICan we simply move forward? - Jl/Leeadt; From: Campbell, Roger Sent: Wednesday, August 01, 2012 10:56 AM To: Schopp, Melody (DOE) Subject: Additional information This PDF Is the document that Dan, Stacy and Scott came to present to you last April ve cut and pasted rebuttal to some of those concerns. File. SDGUG SDCAG. There are 13 different points that lVlCEC/Allt made and ll try to limit my responses which i didn? provide at the- meeting. 1. We?re all partners but SD DOE is the lead partner; I feel that the other partners will provide whatever financial/programmatic information that we request 2. There have been no significant changes to programmatic issues that would warrant input 3. There is email dialogue between the partners that somewhat contradicts this statement; I received from grants management the instructions for grant request in mid?December; I requested the grant early February and we actually sent them the contract on 2.19.12; they took a month to get it back and we signed it on 3.20.12 4. Similar situation to money being dispersed using their own discretion and when the school payments became an issue they blame DOE - 5. They? ve expended the resources on staff but have not paid the schools which is a large part of the data collection neededfor the lVlCEC/Alil/BCKuhn prepared the response to the Program Officer about these concerns; in that report were inaccuracies about the actuai progress of the project 6. This situation is similar to the contracting process; additionally, BCKuhn indicated on last week?s call that the APR was just a report and data collection that was separate from the program evaluation that the independent External Evaluator was going to be doing; that was her response when I asked about a possible conflict of interest because she had submitted an RFP to be the independent External Evaluator while already contracted to do the data collection for MCEC. 7. i don?t feel that they can pick and choose to independently spend money without a contract and then also use it as an excuse I 8. l? not sure when and where it has been stated to have these ?Project Management Team? meetings, additionally, the Project Director has not been involved In a number of the management issues that the Work Plan requires and have apparently taken place without the oversight or inclusion of the Project Director; once again, a double?standard with the use of the Work Plan. 9. l?m not sure why this was a concern; we never indicated any changes regarding the partner schools 1 10. 1'1. 12. 13. Per Jan Martin there were no boundaries crossed ??The intent of the questions/observations about working with DOE to collect needed data was to assist the SDGU staff with data collection so that the data was consistent and accurate when reported for APRs, evaluations, or in other settings. A sample of the data available through SDAP was provided to illustrate how student data without names can be obtained for use in the data collection. As a person working with large amounts of- secure data for both NAEP and for SD DOE, the need for protecting the rights of students is paramount in the processes used for reporting. There was never the intention to do anything with the data provided. Based on the MOU between the state and the BIE, schools must know that the DSTEP data goes through Si) DOE before it goes to the for determining AYP. Additionally, all the BlE/tribal/other private schools in the state have access to their school?s data through SDAP/eMetric so that the data sample was provided as a way to educate project staffon what is possible. The Project Director was asking questions to gauge the effectiveness and efficiency of the Gear Up Program; at no time was it suggested that we were going to make any significant programmatic changes. The statement that the project is not going to collect student achievement data seems to go against the needed data for the evaluation plan. in addition, the collecting of Student data in the data system the project is implementing calls for test data among other data. The case was made in the proposal that the database was needed because the BlE/tribal schools have a different data system. On page 1:1 of the project abstract, it states that state assessment scores will be used as part of the overall evaluation. On page 8:45, objectives 1.8 and 1.9 require the collection and analysis of state assessment scores for participants/participating schools. We will access any data from the that is necessary and allowable to effectively and accurately measure the impact of the SD Gear Up Grant; 1 will go to each and every school with this message and if they don?t wish to provide we can reallocate resources to other eligible schools/students. Again, there are numerous places in the grant application that indicates that assessment data are part of the overall data collection needed to satisfy federal requirements. has not consulted with the SD DOE in the past regarding this financial information on the SD Gear Up funds or the SD CACG funds which they should have been doing all along; if they would have checked, SD DOE would have provided the information. Roger Campbell (605) 773~3783 From: Campbell, Roger Sent: Wednesday, August 01, 2012 9:16 AM To: Schopp, Melody (DOE) Subject: draft Melody, if you have some Take a look at let me know what you think. certainly don?t want it to be an indictment against the Department or anyone else. i also don?t want to have it sound defensive either. if you would like i can also provide other documents that i have prepared for you if you think that will be useful. i don?t know how effective this format is but i know the length doesn?t do the situation justice. l?C Background of the Office of Indian Education In 2003 the Interim Secretary of Education, Tom Hawley, visited with me regarding a concept that he was hoping that he could begin to make a reality in the state of South Dakota. Through his association with the Council of Chief State School OfficerleCSSO) he learned of certain states who had dedicated specific personnel or resources to address the challenges faced in the area of Indian Education. There was action that was initiated to bring together an informal work group to help redevelop some basic framework for the office or individual who would direct the effort of the Department of Education in the area of Indian Education. Prior to the department actually selecting someone to lead the effort the decision was made to begin or reinstitute an annual summit or conference dedicated to identifying proven models of success in the education of native students across the state. The DOE held the first Indian Education Summit later that year and the following year the Department hired a Indian Education Coordinator. Background of Gaining Early Awareness and Readiness for Undergraduate Programs (Gear Up SD) In 2005 the SD DOE became involved with the Gear Up program through a partnership with the Oceti Sakowin Education Consortium (OSEC), who was represented by Ted Hamilton and Stacy Phelps. The competitive application for fundingto the USDOE for a statewide Gear Up initiative had a focus towards focusing on an American Indian student population but it did not include significant representation from public schools rather it focused mainly on the Tribal/BIE school population. It did inClude some public school districts with significant native populations. From 2005-2011, which were the dates for the first Gear Up grant, the program has been run with almost complete autonomy with Mid-Central Education Cooperative assuming the fiscal agent role and the OSEC organization workingas a conduit for the Tribal/BIE schools. When I initially took the position of Indian Ed. Director in 2011 there were a number of challenges that had been communicated to me from the DOE about Gear Up and a more recent grant, College Access Challenge. The Gear Up grant had more history in terms of questions about accountability specifically but both grants and the management of each has been a point of contention in the-department as well as certain agencies outside the department. Because that the first Gear Up Grant had seen three DOE Secretaries and four OIE Directors didn?tfeel it prudent to proceed with implementing any changes to fiscal policies and certainly not the programmatic make-up of Gear UP or College Access Challenge. In September of 2011 the SD DOE was awarded a new GU Grant in the amount of approximately $24 million dollars for seven years. Prior to the notification of award I had informed the Gear Up Project Coordinator and contractors of pending changes in terms of establishing accountability. There was a delay in the contracting process. In 2011, on at least two separate occasions, I had approached both and MCEC staff/leadership regarding changes to fiscal reporting due to some of the concerns that had been brought forth regarding the Gear Up program. From the beginning I have been transparent with the Finance and Grants Management department as well as the department leadership In my approach. I have kept Department in the loop regarding the expectations that I have set forth for regarding fiscal reporting. At no time has the intent of my actions ever been questioned by the Department. but rather have been encouraged to continue to seek a level of accountability that has been non? ?existent since the inception of the first SD Gear Up Program. Accountability - In terms of staff who have been paid under the grants, a detailed determination of which staff was paid by which grant and what percentage of their time was allocated to the respective grants. When this request has been made it took 2 months for one of the contractors to produce an FTE list and grant allocation for each employee and it was inconsistent with what was presented' In terms of the budget. Certain individuals were not accurately defined 3 in terms of grant responsibilities. There were also instances of certain employees being paid from both grants at amounts inconsistent with SD DOE standards. There were dollars attempted to be expended that were without grant agreement or contract and based on our agreement with the contractor were not reasonable or necessary. When the request has been made in terms of which schools are assigned to which of the seven Outreach Coordinators, there'is difficulty or delay in providing the requested information. The amount and purpose of travel is also in question because travel policies were not in place or were not followed. There is question about the necessity of certain supplies and equipment expenditures. Prior to the new Gear Up grant none of the accountability measures that I am instituting had been followed. We have also communicated to the feds through the annual performance report that there were certain activities that had taken place but in fact they had not. There has also been a lack of checksand balances with the fiscal responsibilities. The Business Manager for Mid Central Education Cooperative (MCEC) is also the CFO American Indian Institute for Innovation who is another grant partner. He also serves in the capacity of Business Manager for the Oceti Sakowin Education Consortium (OSEC) who is another grant partner. The Assistance Business Manager for MCEC is paid at 80% FTE directly off of the Gear Up grant but is titled as Data Specialist. The Business Manager for is a MCEC employee who in the past was the highest paid employee paid out of the College Access Challenge grant. . . We are almost to the end of the seventh year of Gear Up in SD and to date there has never been an audit of this federal program. I have requested that the Department consider an audit of one of the previous grant years. It has been decided that the Department will move forward with increased diligence in the monitoring of both of these grants now that we have established an improved level of grant administration from MCEC but I suggest that we consider doing an audit of . Certain line items of the budget to include Personnel, Travel, Supplies Equipment. Transparency In terms of the level communication from the department and the contractors about the activities of the grant and staff; I am trying to ascertain which personnel performs what function. Historically, there has been little effort by the Project Director to provide oversight of the program. Over the last six months I am attempting to gauge what activities are actually taking place and who is conducting them; the Gear Up staff, either through MCEC, or the schools. I have initiated a process in which the partners of each respective grant have a copy of the plan so that they better understand their role within the framework of the grant. We are hoping to delineate between the organizational partners. It has been determined that agreements between MCEC and other partners have been incorrect or have not been in place which is not following proper grant administration. There has not been an collective effort to effectively communicate with the SD DOE in terms of grant initiatives nor has there been attempts at building relationships to improve the data collection efforts so that we can more effectively assess and measure the program. Clarity In terms of understanding what the goals and objectives of the grants are and the determination of the effectiveness of their implementation. It is the responsibility of the DOE to ensure the oversight and integrity of the grant and its initiatives by working with the independent external evaluator to measure the effectiveness of the grant. Historically the Gear Up program has suffered from objectivity in its assessment due to the relationship between the contractor and evaluator. Currently, through a competitive bid process, the DOE has contracted with an Independent External Evaluator who will assist in providing a fair and unbiased assessment to the effectiveness and efficiency of the Gear Up program. I As the current Project Director I have certain responsibilities to both the SD Gear Up grant and SD College Access Challenge grant. I believe anecdotally I have been accused of being misguided or ill-intentioned but if you look at the collective effort of what I have tried to bring to the situation, it can be determined that I have acted in the best interests of the SD DOE in trying to manage these grants with an improved amount of accountability, transparency and clarity.