California Compliance & Accountability
Federal Program Monitoring (FPM)
A practical introduction to California’s coordinated process for determining whether selected local educational agencies meet programmatic and fiscal requirements tied to categorical funding.
FPM in plain language
Federal Program Monitoring is the CDE’s coordinated review of selected local educational agencies (LEAs). Reviewers use the program instruments for the applicable year, examine evidence, and may interview district and school personnel or advisory groups. They determine whether the LEA is meeting the legal and fiscal requirements included in the review.
What FPM is
- A structured compliance determination based on stated requirements
- A review of both written controls and evidence that those controls operate in practice
- A process that can result in findings requiring LEA-wide correction
What FPM is not
- It is not the LEA’s annual financial audit
- It is not a review of every program or every organizational risk
- Selection for review is not, by itself, evidence of noncompliance
How an LEA enters the review cycle
CDE assigns LEAs to rotating cohorts and uses risk-based factors to select agencies for review. Factors may include program size, fiscal analysis, compliance history, and indicators connected with continuous improvement or differentiated assistance. The selection notice—not the general program list—defines the LEA’s actual review year, format, programs, and sites.
Selection is a monitoring decision, not a finding
A risk factor helps CDE decide where monitoring resources should be directed. It does not establish that an LEA has violated a requirement.
The FPM lifecycle
- Continuous compliance: The LEA operates required programs and retains evidence throughout the year.
- Selection and scope: CDE identifies the review format, participating programs, and schools or sites.
- Orientation and access: The LEA confirms its review lead, internal team, calendar, and California Monitoring Tool (CMT) roles.
- Evidence submission: Documents are uploaded, linked to the correct evidence request, and certified in CMT.
- Review: CDE examines evidence and, depending on format, conducts interviews or onsite verification.
- Determination: CDE identifies compliant items and issues a Notification of Findings for items determined noncompliant.
- Resolution: The LEA corrects the underlying condition across the agency and submits evidence of correction.
- Closure: CDE accepts the resolution evidence and closes the finding and review.
How to read a program instrument
| Instrument element | What it does | LEA question |
|---|---|---|
| Statutory core item | States the central compliance requirement | Can we demonstrate that the required condition exists? |
| Supporting item | Breaks the requirement into testable components | Which office, site, or process owns each component? |
| Legal authority | Identifies the statute, regulation, or controlling requirement | Does our local practice address the actual requirement? |
| Evidence request | Organizes the material reviewers need to make a determination | Does the evidence prove both design and implementation? |
| Example evidence | Suggests possible documents or records | What authentic local evidence best demonstrates compliance? |
Example documents are helpful illustrations, not a substitute for reading the requirement. A policy alone may not prove that the policy was implemented.
What programs may be included?
The participating programs and instruments change over time. A review may involve several different program families:
Instruction and student support
Examples include compensatory education, English learner programs, homeless and migrant education, school support and improvement, neglected or delinquent programs, and expanded learning.
Fiscal and grant administration
Fiscal monitoring and the fiscal responsibilities attached to particular federal or state-funded programs may be reviewed.
Equity, civil rights, and complaints
Education equity, civil rights review, and Uniform Complaint Procedures may be part of the coordinated monitoring structure.
Instructional and workforce programs
Career technical education, physical education, supporting effective instruction, and other participating programs may be included.
Shared responsibility across the LEA
| Role | Typical responsibility |
|---|---|
| Executive leadership | Sets authority, removes barriers, and ensures findings are corrected throughout the LEA. |
| FPM coordinator | Maintains the master calendar, scope, evidence map, communications, and certification workflow. |
| Program leads | Interpret current instrument items and demonstrate program implementation. |
| Fiscal staff | Connect expenditures, time documentation, allocation methods, and internal controls to program requirements. |
| School and site staff | Demonstrate how district requirements operate where services are delivered. |
| Data and systems staff | Produce traceable records, validate populations and dates, and protect confidential information. |
| Board and advisory support | Preserve agendas, minutes, approvals, consultation records, notices, and associated attachments. |
| CMT administrator/coordinator | Manages access and certifies evidence requests when the submission is ready. |
Findings, correction, and closure
A finding means CDE determined that the evidence did not establish compliance with an instrument item. The LEA should address the requirement and the underlying cause—not merely replace a missing file. When a sampled school reveals a systemic condition, correction applies throughout the LEA, not only at the reviewed site.
Confirm the operative deadline
CDE’s current Compliance Monitoring page states that resolution documents are due within 60 calendar days after the Notification of Findings and that a Resolution Agreement may not extend beyond 240 calendar days from the last review day. Some older CDE FAQ and CMT pages still display 45- and 225-day periods. Follow the dates in the LEA’s current Notification of Findings and CMT record, and confirm any discrepancy with the assigned CDE FPM Review Lead.