Although the steps outlined below are generally progressive, they are not necessarily linear. Steps may occur simultaneously, be skipped, or be repeated as necessary until the situation is adequately resolved.

Targeted Technical Assistance

Most issues will require limited involvement from HIDOE staff:

1. Contact the subgrantee project director regarding identified issues and provide targeted and individualized feedback, clarification, suggestions, support, resources, and technical assistance.
2. Conduct informal or formally-scheduled check-ins to assess progress and offer continued support and assistance.
3. Include related parties in communication, as appropriate (e.g. project director, site coordinators, principals, the complex area superintendent, advisory council chair, leadership of the lead community partner organization, external program providers, etc.)

Meeting with Subgrantee Project Director

If progress is limited, observation is needed, program response is inadequate, or in-person communication is warranted or desired by either party:

1. Schedule a meeting with the subgrantee project director and other parties, as necessary, to discuss the issue and develop solutions.
2. Document the meeting with either written feedback form or meeting notes.

Follow-up Letter with Timeline of Deliverables

If the risk is moderate-priority or high-priority or if no clear consensus was reached in the meeting with subgrantee project director:

1. HIDOE State Program Manager sends communication to the subgrantee project director with a timeline for expected actions and deliverables. Ideally, the timeline and deliverables are developed in conjunction with the subgrantee project director in the meeting or during follow-up communication, but they may be imposed by HIDOE staff.
2. Offer additional recommendations and technical assistance, as appropriate.

Delay or Withholding of Funds

If required actions and timelines are unmet:

1. Delay or withhold funds.
2. Communicate to the subgrantee project director in writing what steps are necessary in order to have funds released.

Special Grant Award Conditions

In conjunction with, or after, Step 4, depending on the nature of the issues:

1. Attach “Special Grant Award Conditions” to the grant award which, if not met, may result in delay or withholding of payment or termination of the grant.
2. Depending on the issues, these conditions may include, but are not limited to, requiring the subgrantee to:
   1. Meet timelines and deliverables such as those in Step 3 or Step 6,
   2. Conduct additional monitoring or correct prior monitoring findings,
   3. Provide additional reporting or documentation, such as back-up documentation,
   4. Notify HIDOE immediately of certain actions or milestones,
   5. Notify HIDOE immediately when various unanticipated events occur, such as significant administrative changes or barriers to implementation of the grant,
   6. Submit other fiscal or programmatic documentation, and/or
   7. Repay any ineligible expenses identified, using non-federal funds.

Intensive Technical Assistance

Depending upon the needs of the subgrantee and upon HIDOE capacity:

1. Provide more intensive technical assistance to the subgrantee project director to assist with the implementation of required actions and/or special grant conditions.
2. If funds allow, additional resources may be directed to support the provision of contracted technical assistance.

Targeted Site Visit

If additional information is needed to assess the nature or scope of the issues, the needs of the subgrantee, or barriers to resolution of risks:

1. Conduct a targeted site visit. This is typically more limited in scope visit than the regular monitoring visit.
2. Issue a written site visit report to the subgrantee project director, with copies to the complex area superintendent, principal, and/or executive director of the lead community partner agency.

Corrective Action Plan

If progress is limited, timelines and deliverables are not met, additional concerns are raised in the site visit, or subgrantee project director response to prior communication is limited:

1. Develop a formal Corrective Action Plan with a detailed timeline of expected actions, with specific milestones and deliverables and responsible parties identified for each item.
2. Ensure that all appropriate parties are aware of the corrective action plan. This may include site coordinators, principals, the complex area superintendent, the executive director of the lead community partner organization, advisory council chair, external program providers, and other partners.
3. Schedule periodic check-ins or follow-up meetings with the subgrantee project director and/or other contacts, as defined in the action plan, regarding the outlined actions. Document meetings with either a written feedback form or meeting notes.
4. Offer additional recommendations and technical assistance as necessary to implement the plan.

Reduction or Termination of Grant

As a last resort, if required actions and timelines continue to be unmet or if the situation is critical enough to warrant it:

1. Reduce the grant award or terminate the grant.
2. If the grant award is reduced, communicate to the program administration in writing what steps and documentation, if any, are necessary to reverse the reduction.
3. If the grant is terminated, make immediate efforts to find another subgrantee that may be capable of implementing the grant with the same population of students.
4. Notify all appropriate parties of the reduction or termination of the grant.

Conditions for Future 21CCLC Funding Eligibility

Applicant for RFAs who have been identified “high risk” by HIDOE in previous 21CCLC projects will be subject to additional conditions:

1. As a component of the Request for Application review process, notify such applicants upon completion of the application review process.
2. Communicate previous areas of risk, including monitoring findings and annual risk analysis to applicant.
3. Applicant must address and provide evidence of correction of the deficiency(ies) during the application evaluation timeframe.
4. Deem responses sufficient or not sufficient to qualify for a 21CCLC award.
5. Notify all appropriate parties of the sufficiency of the review.

Ongoing Communication, Monitoring, Follow-up

Throughout the above process HIDOE staff will continue to communicate with subgrantee project director on a regular basis and offer individualized feedback, clarification, suggestions, support, resources, and technical assistance. The further along in the progression of steps this goes without resolution, the more frequent and more formal communication will be. Once the situation is adequately resolved, the issues raised will continue to be tracked via ongoing monitoring efforts, as appropriate to ensure that problems do not resurface.
For questions pertaining to the monitoring of the 21CCLC program in Hawaii, please contact Marissa Akui, Interim Director Community Engagement Branch, Hawaii Department of Education, 21cclc@k12.hi.us.