SP 9-73 – Monitoring of Federal and State Programs

Colorado Community College System / System Procedure

SP 9-73

EFFECTIVE: March 1, 2009
APPROVED: February 11, 2000
REVISED: March 3, 2014

REFERENCES: C.R.S. 23-8-102 (Career Technical Act); P.L. 109-270 (Carl D. Perkins Act of 2006); P.L. 93-112, Section 504


/ Nancy J. McCallin /
Nancy J. McCallin, Ph.D.
System President


The procedure applies to the state system community colleges and all secondary and postsecondary institutions that operate an approved career and technical education program and receive state career and technical education funding or any federal funding as a subrecipient of the Colorado Community College System (CCCS).


Board Policy 9-73 requires the System President to promulgate procedures necessary to implement the CCCS monitoring program.


This procedure provides guidance for implementation of the compliance monitoring program.

CCCS will monitor educational institutions to evaluate the effectiveness of their compliance:

  1. the Carl D. Perkins Act,
  2. Career and Technical Education programs,
  3. the Colorado Technical Act, and
  4. Compliance with Title VI of the Civil Rights Act of 1964 (Title VI), Title IX of the Education Amendments of 1972 (Title IX) and Section 504 of the Rehabilitation Act of 1973 (Section 504) (Methods of Administration).

In accordance with BP 9-73, Monitoring of Federal and State Programs, 5% of educational institutions which conduct approved Career and Technical Education programs will be selected for monitoring annually. Monitoring will include a review of federal compliance requirements for the Carl D. Perkins Act, the Colorado Technical Act or a review of compliance with Title VI, IX and Section 504.

For each type of review, CCCS will implement a risk-based methodology for determining which educational institution will receive a monitoring visit and the scope of the review.

For Carl D. Perkins Act and Colorado Technical Act, planning methodologies will include the award amount and the length of time since the educational institution’s last monitoring; additional factors may be considered in the analysis.

For review of compliance with Title VI, IX and Section 504 the targeting methodology approved by the U.S. Department of Education’s Office for Civil Rights will be used to select institutions for on-site monitoring.

Monitoring may be performed on-site or remotely, as determined appropriate based on the scope of the review performed, availability of personnel and considerations of travel costs.

Procedures will be designed to address material compliance requirements and may include other requirements not considered material, but significant to compliance with the program. Procedures will be reviewed for effectiveness annually.

Procedures for review of compliance with Title VI, IX and Section 504 are designed biennially and provided to the federal Office for Civil Rights for their review and approval.

All subrecipients, including individual member districts within a consortium must submit either an annual OMB Circular A-133 compliance audit or a statement attesting that they are not subject to OMB Circular A-133 audit requirements as part of the Carl D. Perkins Award Packet. CCCS will review each A-133 audit and will consider the impact of any findings on the Carl D. Perkins program.

Monitoring reviews may uncover costs that are not allowable to the programs. In that case, CCCS may invoice the educational institution for the amount of the unallowable cost.

Based on a Monitoring visit or a review of the OMB A-133 compliance audit, CCCS may determine a suspension of funding is necessary until a participating institution has developed adequate controls and processes to ensure compliance with the programs.


CCCS reserves the right to change any provision or requirement of any procedure at anytime.