JOHNSON O’MALLEY PROGRAM (2024)

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HO-CHUNK NATION

JOHNSON O’MALLEY PROGRAM

POLICY MANUAL

Updated 7/26/2005 Approved by HCN Education Council 11/22/05

Revised 5/5/07 Revisions Approved by the HCN Education Council 5/6/07

Revised 11/3 & 11/4/07 Revision Approved by the HCN Education Council 11/4/07

Revised 01/09; Revised 04/08/2010; 6/15/21; Revised 12/23; Revised 09/24

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JOM Goal Statement

It is the goal of the Ho-Chunk Nation JOM Division to ensure each area served by

the JOM Grant complies with Federal Regulations to ensure continued funding of

the grant and to ensure each student enrolled in the program receives fair and

equitable treatment and consideration for the program funds.

This manual will provide guidance for the Indian Education Committees to

follow when developing their by-laws and assist in the conduct of business in

their respective areas. This manual will also provide the Ho-Chunk Nation

JOM Division staff with their Standard Operating Procedures to maximize their

ability to provide service to the Native Students, the Committees and ensure

compliance with the terms of the Contract to ensure continued funding.

The Consolidated Tribal Government Program of the Ho-Chunk Nation will

provide learning experiences for eligible Indian students by implementing

educational programs designed to improve cultural awareness, attendance

and grade point average, decrease tardiness and increase extra-curricular

involvement.

Each local JOM Committee from each of the Ho-Chunk Nation Communities

approved the following supplemental educational opportunities for eligible

JOM students that would not otherwise be provided:

Educational Support Expenditure Plan;

Cultural Awareness Expenditure Plan; and

Administrative Expenditure Plan.

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SECTION I: ELIGIBILITY CRITERIA

[25 CFR. 2 (j). 273.12]

273.12 ELIGIBLE STUDENTS

The eligibility criteria include students who:

Are three (3) years by October 1st, through grade 12, except those who are enrolled

in Bureau or sectarian operated schools;



Are the descendant (child or grandchild) of a member of a federally recognized

tribe;



Are enrolled in a federally recognized tribe or are at least ¼ or more degree of

Indian blood.

SECTION II: JOM STUDENT LIST

1) A listing shall be made of all students who sign up during open enrollment

and who meet the eligibility requirements detailed in SECTION II of this

manual and are enrolled in a public school, including public pre-schools and

head start programs that are specifically affiliated with that area’s public

school district. In some cases enrolled in a charter school, and have also

registered for services with an Indian Education Committee. This list shall be

provided to the HCN JOM/Education Department by the 3rd Friday in

September.

2) Budget allocations to the various IEC’s are determined by the student list (head

count) for each IEC.

3) Open enrollment for the JOM Program will take place every beginning of the

school year from August 1 thru the third Friday of September.

4) IEC’s will make public announcements, mailings, or other notifications to

affected parents to optimize program enrollment.

5) JOM Program staff will produce an enrollment form for use in registering

participants for the program.

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a) These forms if they have been modified or updated since the previous

enrollment period will be mailed to the IEC Secretary no later than July

15, by the JOM Staff.

b) These forms will be standardized for use by all IEC’s. Copies, faxes or

other reproductions may be accepted as valid enrollment forms for the

purpose of registering participants for the JOM Program.

c) Enrollment forms will be completed by all participants. Participants when

initially enrolling will be required to submit proof of eligibility. It is the

responsibility of the parents/guardians and the IEC officers conducting

enrollment to physically verify eligibility. Proof of eligibility must be

written or physically tangible, meaning it can be seen, copied and

filed.

d) Proof of eligibility and enrollment forms will be kept on file by the HCN

JOM Program staff and the IEC Secretary. Once on file, for the participant

will not have to provide proof of Tribal Eligibility for subsequent years

of participation unless they move to a new school district (IEC coverage

area). Each participant must still complete an annual enrollment form.

e) The JOM Program staff (copies) and the IEC secretary (originals) will

keep all enrollment forms including proof of eligibility in Program files.

6) Students shall be included in the IEC’s student listing (head count) in the area in

which he/she/they will attend school.

7) IEC student listings (head counts) may be amended throughout the year, as

students/families relocate. However, the budget for the IEC’s will stay the same,

based on the original counts submitted for that year.

8) The IEC Officers will ensure that no participant is counted twice. This will be

verified by the JOM Program staff.

9) The IEC chairperson will ensure that the final student list (head count) for his/her

IEC is submitted to the HCN JOM Program Staff by the October 1st deadline.

10) JOM Program Registration form composition (at a minimum):

a) Date of Application

b) Student Sex

c) Student Name

d) Student Age

e) Student Date of Birth

f) Student Tribal Affiliation

g) Student Tribal Enrollment Number

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h) Student School Name

i) Student School District

j) IEC that Student is a Participant of

k) Student’s Parent/Guardian Name

l) Student’s Parent/Guardian Phone Number

m) Student’s Parent/Guardian Address w/ City, State and Zip Code

n) Verification by two (2) IEC officer signature

o) Other information as deemed necessary by the JOM Program staff

11) Student list (head count) composition:

a) IEC Name as header

b) School Year that the List represents (August, XXXX – June, XXXX)

c) Student Name w/ last name first and first name last

d) Listed in alphabetical order by first letter, etc. of last name.

e) Name of Parent/Guardian/Contact and Contact Information

including address and if and whenever possible, phone number and

email address.

SECTION III: STRATEGIC PLANNING

[The Annual Needs Assessment]

Annual Needs Assessment

1) 25 CFR Sections 273.16 (v) (b) (2) requires that the recipients of JOM Program

funding “Make an annual assessment of the learning needs of Indian children in the

community affected.”

2) The IEC’s will conduct an annual needs assessment during the final quarter of the

current school year to determine needs for the upcoming school year.

a) The IEC’s will conduct the annual needs assessment during the final quarter

of the current school year and have them completed by June 15th of that

year.

3) Needs Assessment Definition: a process designed to gather information about the

specialized and unique educational and culturally related needs of eligible Indian

students. The results for the survey will be used to develop the goals and objectives

for the JOM Program. A needs assessment is a determination of what the actual

needs are of an organization, a group or individual. A need is defined as a “condition

or discrepancy” from the norm. It can be based upon on either subjective (something

thought to exist) or objective (something that actually exists) information. Clear,

objective, quantifiable data is preferable in determining needs.

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4) The Annual Needs Assessment will be the tool that is used by the IEC’s in

determining the allocations of funds within their Education Plans. The Education

Plan determines where funds are placed within the IEC budgets specifically in the

areas of Cultural Awareness, Education Support, Administration, and Incentives as

determined by the Needs Assessments of each area.

SECTION IV: EDUCATION PLAN

1. The Educational Plan is the written document which outlines the plans for

providing programs to meet the unique and specialized needs of Indian students.

It is developed by the IEC’s. It identifies needs of the Indian students, the goals

and objectives to be accomplished, procedures to be followed, methods to be used

in evaluating the program as well as proposed budgets and is submitted as part of

the contract.

2. The Educational Plan will include, at a minimum:

a) Educational goals and objectives which adequately address the educational

needs of Indian students to be served by the contract and a method to

measure the success or failure of the plan so that appropriate steps

can be taken to correct the deficiencies that are noted.

b) Incorporate the program or programs developed by the IEC’s.

c) Procedures for the hearing grievances from Indian students, parents,

community members, and tribal representatives related to the programs

contracted. Such procedures shall provide for the adequate notice of the

hearing.

d) Identify established standards and requirements which shall be maintained

in operating programs and services contracted.

e) Describe how the standards and requirements will be maintained.

f) Outline procedures of administrative and fiscal management to be used by

the JOM Program staff if these do not already exist.

g) State the eligible Indian enrollment-total and classification by tribal

affiliation(s) and by age and grade level.

4) The Education Plan will also have as major headings/inclusions:

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a) Education Support Work Plan that will at a minimum contain:

i. A plan that is created to guide the student’s academic readiness

enhancement activities by assisting with the supplemental cost of

basic and unique educational needs.

b) Cultural Awareness Work Plan that will at a minimum contain:

i. A plan that is created to develop and foster cultural awareness in

the local community and school districts to reinforce tribal identity

in Indian students.

ii. Assessment plan for determining cultural awareness aptitude and

other relevant identity issues in the local community and school

districts.

c) Administration Work Plan that will at a minimum contain:

i. A plan that is created to provide reimbursement and payment for

meeting expenses, based on a percentage basis, incurred by the

IEC’s in carrying out their JOM

Program duties.

5) The Education Plan as well as the included Educational Support, Cultural

Awareness and Administration Work Plans must be based solely on the facts and

finding of the Annual Needs Assessment.

6) A copy of the Educational Plan will be maintained in the JOM Program files

located in the Johnson O’Malley & Pre K – 12 Grant Programs offices. The

original and a copy must also be kept by the IEC Secretary and readily

accessible to all officers and parents. This copy should be periodically

reviewed by all members of the IEC to ensure they are acting in a manner

consistent with their Plans.

SECTION V: Budget Process

Budget Calculation

1. The budget is calculated each year by the Education Designee and the total annual

available funding level for each IEC is calculated based upon the approved head

count which must be given to the JOM Staff by September 30th of each year.

2. Once the approved head count has been established, the annual funds that are

available that year are divided equally to each approved student. The numbers of

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approved students in your IEC area determine the funding level for your IEC that

year.

3. Once an IEC’s budget has been calculated and the JOM staff has distributed that

information to the IEC, the IEC will determine how it will use their money. This

must be based upon your IEC Approved Education Plan as determined by your

areas Needs Assessments.

Unexpended Funds

1. Any funds that are not used by an IEC or are not planned to be used by June 30th of

each school year will be pulled back into a general fund which is maintained by

the Contractor.

a) Funds that are remaining in the Contractor’s general fund will be

redistributed the following school year to support each IEC until their new

budget monies are made available from the Federal Government in

October. These are commonly referred to as “Start up Budgets”.

The Start up Budget is calculated by taking the IEC’s

approved master student list from the current school year and

subtracting the graduates from the list.

II.

The Contractor allocates $50.00 from the Contractor’s

general fund for each student remaining on the IEC’s master

student list.

III.

Those funds will then become the “Start up Budget” to allow

each IEC to operate in the new school year.

IV.

When the actual numbers are able to be determined by the

process outlined above (Budget Calculation), each IEC’s

new annual budget will be adjusted to reflect the correct

dollar amounts.

Restricted Expenditures

Any funds an IEC receives through its own fundraising efforts are not subject to the

conditions of this Contract.

Each IEC approves its own expenditure based upon its own unique needs; however, some

things cannot be purchased with Federal funds. The following is a listing of expenditures

that are not allowable.

1. Federal Funds made available under this Contract cannot be “Donated” or given as

charitable contributions.

2. Another factor to be taken into consideration when planning activities is to ensure

that Johnson O’Malley funds are used to support existing programs (supplemental)

and not replacing programs that are being provided by another funding resource

(supplanting).

Supplemental Programs – Programs that support and are in addition to existing

programs in the public schools. Johnson O’Malley funds cannot be used to

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replace existing programs but may be used to support or enhance the regular

school programs.

Supplanting Programs – Supplanting means establishing or building programs

using Johnson O’Malley funds which the school should already be providing

from their regular budget. Johnson O’Malley funds cannot be used to replace

funds which should be provided for existing programs. Supplanting is not legal

in Johnson O’Malley programs.

ii.

ITEMS NOT ELIGIBLE

a. Non-school related expenses (sports equipment, fees, etc. pertaining to activities

that are not sponsored and run through the local school-district)

i Examples:

1 AAU Basketball fees and equipment

2 Club-related sports (Soccer, Swimming, Hockey, etc.)

b. Class Rings and other class memorabilia

c. College class tuition (Concurrent Enrollment Fees)

d. Field trips for extracurricular activities that only include a select number of

students and not offered to all eligible JOM students in grade level

e. Home School Costs

f. Portrait Packages

Senior Pictures

ii School Pictures

g. No Student Cash awards are allowed

SECTION VI: GOALS AND CATEGORICAL OBJECTIVES

JOM Goal Statement

The Consolidated Tribal Government Program (#CTF55T43984) of the Ho-Chunk

Nation will provide unique learning experiences for eligible Indian students by

implementing educational programs designed to improve the effectiveness of the IEC’s

Educational Plans.

Categorical Objectives

Budgetary constraints and/or IEC goals and objectives may limit each IEC in using any

of the following (3) three objectives.

Educational Support Objective

By September 30 of the current school year, JOM staff in concert with the HCN

Education Department Accountant will facilitate a prorated percentage of dollars for

Educational Support Costs that will assist with the supplemental cost of basic and unique

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educational initiatives for each eligible JOM student to enable them access academic

readiness enhancement as detailed in the IEC Educational Plan.

Cultural Awareness Objective

By September 30 of the current school year, JOM staff in concert with the HCN

Education Department Accountant will facilitate a prorated percentage of dollars for

Cultural Awareness Costs that will create and foster cultural awareness in the local

community and to reinforce tribal identity for each eligible JOM student as described in

the IEC Educational Plan.

Administrative Objective

By September 30 of the current school year, JOM staff in concert with the HCN

Education Department Accountant will facilitate a prorated percentage of dollars or

Administrative Costs that will provide reimbursement and payment for meeting expenses

incurred by the JOM Committee(s) to enable them to carry out their JOM duties as

described in the IEC Educational Plan.

SECTION VII: PARENT & OFFICER TRAINING & NATIONAL

JOM CONFERENCE

1) JOM Program will plan and conducting Officer Training annually. The IEC

Officers are responsible for attendance at the training and wherever

necessary, for providing instruction and presentations to the parents in their

areas. The JOM Program Staff can provide assistance and support for this

training at each location at the request of the IEC.

a) The National Johnson O’Malley Conference takes place during September

each year. When funding is available and there is sufficient interest, IEC

officers and parents may be able to attend this conference. The interaction

with other JOM committee members around the country is considered very

educational and enlightening. Because funding is limited and because it takes

place during the school year, student attendance will not be encouraged or

funded by the JOM Program. You must be a parent or legal guardian of a

child that is registered for benefits with a recognized IEC.

2) Attendees at the National Johnson O’Malley Association Conference will also be

required to present on a topic of interest at any IEC meeting that requests them

or at any trainings conducted by the JOM Staff. IEC members and Officers

that attend the NJOMA conference will not be eligible to attend during

subsequent years while there are those interested and willing to attend that

have not previously attended the NJOMA conference. This is to ensure that

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we can maximize the opportunity for attendance by everyone to at least one

meeting.

SECTION VIII: INDIAN EDUCATION COUNCIL (IEC) ORGANIZATION &

MEETINGS

1) The IEC’s are established to meet the Johnson O’Malley Program requirement of

maximum Indian participation as stated in 25 CFR, Section 273.4.

2) The IEC’s involvement is a prerequisite to providing meaningful parent

participation in all aspects of educational programming, development, and

implementation.

a) Parent participation enhances program responsiveness to the needs of those

served and allows them the opportunity to determine and affect the desired

level of educational achievement and satisfaction which education can and

shall provide.

3) The IEC officers may include:

a) Chairperson

b) Vice-Chairperson

c) Secretary

d) Treasurer

Chairperson responsibilities are to:

i. Preside over all duly called meetings using simple Parliamentary

Procedure.

ii. Participate in duly called sub-committees.

iii. Participate and take the leadership role in the program needs

assessment process.

f) Vice-Chairperson responsibilities are to:

i. Assist the Chairperson in performing their assigned duties and

responsibilities.

ii. Act as the Chairperson, Secretary, Treasurer if he/she is not in

attendance and become the Chairperson if the office is vacated.

g) Secretary responsibilities are to:

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i. Serve as the Vice-Chairperson or Chairperson if necessary.

ii. Keep an official roster of IEC officers including current contact

information.

iii. Write and receive correspondence for the IEC.

iv. Record, sign and submit copies of the meeting minutes to the JOM staff

and maintain copies of meeting minutes.

v. Read minutes of the previous meeting.

vi. Maintain “copy-only” files of IEC business.

vii. Maintain forms and ensure their proper usage and completion as

required for compliance with all rules, regulations, laws, and this

manual.

viii.

Submit copies of all completed meeting documents, forms, and

files to the JOM staff for storage in the permanent program files.

h) Treasurer responsibilities are to:

i. Serve as the Secretary, Vice-Chairperson or Chairperson if

necessary.

ii. Maintain the fund raising activity finances of the IEC and report

on account status at duly called meetings.

iii. Reports on contract funds use and balances for the IEC

3. IEC officers must be elected by majority vote of the participating parents and/or

guardians, including persons acting as in loco parentis, of eligible Indian students.

Officers must also be parents of eligible Indian students.

4. IEC Policies and Procedures will, at a minimum, require:

a) Elections to be conducted in accordance with IEC on even numbered years

IEC’s will ensure that this is included within their by-laws during the

regular annual review and revision period (as designated by the IEC,

typically October). Note: By-laws can change at IEC discretion and

timeframe.

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b) BIA OIEP NACIE and Ho-Chunk Nation JOM Handbooks are distributed

to new officers.

c) New officers are given an orientation to their duties and responsibilities by

the JOM program staff after they are elected.

d) JOM Staff provide budget and program reports at duly called meetings as

requested.

e) JOM staff will attend IEC meetings, at the request of the IEC with a two

(2) week notice.

f) IEC secretaries ensure that agendas, meeting minutes, meal/door-prizes

are ready for all duly called meetings. Secretaries also ensure that

adequate meeting notice and pertinent agenda information is made

available to all parents of eligible Indian students and the JOM staff.

aa.)

Door Prizes are only for those parents of

registered students attending and participating in

a IEC meeting.

bb.)

Meals are only for those parents/guardians and

their JOM Program enrolled children attending

and participating in an IEC meeting.

g) IEC Officer will conduct all duly called meetings per IEC By-Laws.

h) Simple parliamentary meeting process and rules apply at all meetings and

it is the responsibility of the presiding officer to ensure compliance with

this.

aa.)

Motions made at meetings must be in writing and

read aloud by the Chairperson before being voted

upon. Only parents/guardians and members may

vote at the meetings.

bb.)

Secretaries will ensure that all motions and other

business are recorded in the official meeting

minutes as required.

5. IEC meeting procedures will follow, at a minimum;

b) Agenda prepared by the Chairperson, Vice-Chairperson and Secretary as

required to include, at least, the following:

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Call to Order

ii. Prayer

iii. Roll Call

iv. Agenda Approval

v. Review Meeting Minutes of Last Meeting

vi. Reports

vii. Unfinished Business

viii. New Business ix. Announcements

x. Next Meeting

xi. Adjournment

7) Copies of all meeting documents are turned in within three (3) business days of the

meeting for processing and filing by the JOM staff.

SECTION IX: FEDERAL JOM POLICY

1) The Education Plan serves as a contract between the Bureau of Indian Affairs

Office of Indian Education Programs National Advisory Committee on Indian

Education (BIA OIEP NACIE), the Contractor (Ho-Chunk Nation).

2) JOM Program staff monitors each sub-contractor for compliance with their

own education plans, by-laws, approved expenditure lists and all applicable

laws, rules and regulations.

3) All JOM Program files will be maintained in lockable file cabinets that are to be

kept locked when JOM Program staff is not present.

4) Funds received for the JOM Program from the BIA OIEP NACIE shall be

expended only for the benefit of eligible Indian students.

5) The JOM Program cannot supplant, but may supplement Federal, State, Tribal,

and local funds. Use of JOM Program funds will not result in the decrease of

Federal, State, Tribal or local funds which would be made available for Indian

students if there were no funds under this contract.

a) Tribes operating JOM Programs need to clearly understand that their JOM

Program is not duplicating the local school obligations to Indian students,

including transportation and tutoring that fall into this area.

b) The IEC’s of the Ho-Chunk Nation’s JOM Program will always ascertain

what services the schools in their areas of service are providing to Indian

students and then address the specialized and unique educational needs

that fall outside the school’s responsibilities.

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7) Federal, State, and local funds must be used to provide comparable services to nonIndian and Indian students prior to the use of JOM contract funds. The HoChunk Nation and its established programmatic funds is the “payer of last resort.”

8) The school lunch program of the United States Department of Agriculture

(USDA) shall constitute the only federally-funded school lunch program for

Indian students in public schools. Where Indian students do not qualify to

receive free lunches under the National School Lunch Program of the USDA

because the students are non-needy and do not meet the family size and income

guidelines for free USDA lunches, the Education Plan may provide, to the extent

of funding available for JOM Programs, for free school lunches for those students

who do not qualify for free USDA lunches but who are eligible students within

the JOM Program.

SECTION X: PROCESSING JOM REIMBURSEMENT

PAYMENTS & RECONCILIATIONS

1) The foundation of the JOM Program is to provide supplementary financial

assistance to meet the unique and specialized education needs of Indian children.

The JOM Program is not to be used as the primary funding source for any

activity. The donations of JOM funds is illegal per federal law.

2) The IEC will develop a list of reimbursable education related activities, items, and

purchases, as well as a list of allowable expenditures ensuring that the approved

expenditure list complies with each IEC’s annual budget. Any expenditures that

are included on the approved expenditure listing that creates a situation where any

students will exceed their equitable share of JOM funds should be balanced either

by the inclusion of an active fundraising program undertaken by that IEC or some

alternate explanation of funding plans must accompany the expenditure listing.

a. These lists will be reviewed annually and submitted with the Education

Plan to the JOM Division Staff.

b. All listed activities, items, and purchases must support the education plan.

3) The IEC shall approve all expenditures using simple parliamentary meeting

processes and record these motions and the actions taken in the appropriate

meeting minutes. The HCN JOM Division will not release any funds for

expenditures that are not on an IEC’s Approved Expenditure List, nor will

funds exceeding the total amount of funds approved on the Expenditure List

be distributed.

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4) Recipients of reimbursements must be parents/guardians of eligible Indian

children and these children must be enrolled in the JOM Program and must

appear on the enrollment list for the Program.

a. Original receipts, invoices, bills, etc. are required for all

reimbursements/payments. Copies may be used when originals are lost.

b. These documents are maintained in the permanent JOM Program files

located in the JOM staff office.

5) All requested reimbursements/payments must be submitted using the proper JOM

Program forms. Reimbursement/payments must also be recorded in the

appropriate meeting minutes including the vote results to approve/disapprove.

6) Completed reimbursement/payment requests are forwarded, with a copy of the

appropriate meeting minutes to the JOM program staff for review and processing.

The JOM Program staff will process the requests within ten (10) days from the

date that all required documentation is received by the JOM Staff from the IEC

Secretary. The JOM Program Staff will then forward the request to Treasury for

payment.

a. When received by the JOM Program staff the completed forms will be

date stamped and reviewed for accuracy, quorum attained, motions passed,

properly recorded information, proper forms used, receipts, invoices, bills,

etc. are attached, all information spaces are filled out, and required

signatures are present.

b. JOM Program staff also reviews the student listing to ensure the student(s)

are eligible.

c. JOM Program staff ensures that the item(s) are on the IEC’s approved

reimbursement/payment eligibility listing as well as that the budget line

item is covered by available funds.

1. If any required information is missing or incorrect the JOM

Program staff will send this back to the IEC for correction.

2. If there is a lack of funds, the request does not comply with the

approved expenditure listing or if the student is not listed on

the reimbursement/payment eligibility listing, the request will

be denied and returned to the IEC.

3. The IEC secretary is responsible for ensuring all submissions

to the JOM Program staff is complete, correct and that copies

have been made for their IEC files.

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4. JOM Program staff will make copies of items for submission

with vouchers. Originals will be kept in the JOM Program

files with a copy of the completed voucher.

5. Education Department staff mails all reimbursements/

payments to the designated recipient and provides a copy of

the check and voucher to the JOM Program staff, and/ or

IEC’s for filing.

7) Funds requested for a specific activity/expenditure must be used for that

specific activity/expenditure. All funds that are not used in the manner

specified must be reimbursed to the JOM Program immediately after the

event conclusion.

8) JOM related activities/expenditures are required to be reconciled within 72

hours of the closing of the event by the IEC.

a. Items to be included with all reconciliations (no exceptions):

Participant listing

ii.

Participant sign-in

iii.

Original Receipts or council approved receipt,

invoices, and/or bills

iv.

Unspent funds in either check or money order

made to: Ho-Chunk Nation

Copy of initial and subsequent meeting minutes

showing approval, planning, budget, and other

supporting documents supporting this having been

accomplished prior to the activity/expenditure

taking place.

vi.

Copy of the education plan used as the basis for

the activity/expenditure.

SECTION XI: SETTING UP SCHOOL SUPPLY

DISTRIBUTION, REIMBURSEMENTS AND ACCOUNTS

There are two (2) options for school supply purchase/reimbursement ONLY IF THE

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NEEDS ASSESSMENTS AND EDUCATION PLAN SUPPORT THIS

EXPENDITURE:

Option 1: Distribution by IEC

1) The IEC approves of bulk purchase through meeting minutes, specifying dollar

amount, who is to purchase, where the purchase is to be made (vendor or

vendor(s)), who is responsible for reconciliation and any other pertinent

information with accompanying motion and vote for approval.

2) IEC’s will also provide the JOM staff with a school supply list of bulk items to be

purchased by July 15 of the current school year.

a. The school supply list of bulk items will be prepared by the IEC’s using the

approved school supply lists of the school districts where participants will

be enrolled.

3) The IEC will set the school supply purchase amount allowed per student based

upon grade level and supplies required by school district(s) in the service area.

4) The IEC will be responsible for establishing a school supply distribution list with

student names and supplies to be issued based upon grade level and school

requirements.

5) The IEC will establish a distribution schedule that ensures that supplies are

delivered to participants prior to the start of school.

6) JOM Program staff will then have the responsibility of processing the request and

ensuring that a check is made available for the purchase from the vendor.

7) IEC Officers must be present during distribution of school supplies.

8) Participants, and/or parent/guardian will sign for receipt of school supplies.

9) School supply distribution must be reconciled by the IEC within thirty (30) days

of the completion of the distribution.

10) Any supplies or money that is not reconciled within thirty (30) days will be turned

over to the Ho-Chunk Nation Department of Justice for collection from the IEC

Officers of that area that were present during the distribution. If distribution

occurred when there were no IEC officers present, ALL officers will be deemed

responsible for the repayment of the unreconciled amounts.

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Option 2: Reimbursement

1) The IEC will determine and record in appropriate meeting minutes or an

allowable reimbursement list on file with the JOM Program detailing an amount

to be reimbursed per child for school supplies.

2) The IEC will determine and record in appropriate meeting minutes a deadline for

reimbursements to be turned in to the IEC for approval of payment.

3) The IEC Secretary will ensure that each reimbursement includes original receipts

with children’s names written on the back with parent or guardian name and

address (copies may be used if originals are not accessible) and a completed

Reimbursement/Payment Form listing all approved reimbursements. Also, a

completed Reimbursement Request Form for each parent or guardian requesting

reimbursement and that the amounts of each reimbursement and who it is to be

paid to are recorded in the appropriate meeting minutes with accompanying

motion and vote for approval.

4) All documents regarding reimbursement must be submitted by the IEC Secretary

to the JOM Staff within thirty (30) days of purchase/ receipt and approval with

appropriate meeting minutes. These documents must include the receipt, a

copy of the Education Plan and the approved expenditure list demonstrating

these expenditures are consistent with the goals of the IEC.

5) JOM Staff will have ten (10) days to process all reimbursement requests after they

are received and submit the request to Treasury for processing.

SECTION XII: FINANCIAL MANAGEMENT

STANDARDS

GRANTEE means the nonprofit corporation or other legal entity to which a grant is

awarded and which is accountable to the Federal Government for the use of the funds

provided. [Source: EDGAR—Section 74.3 Definitions]

As a GRANTEE of federal funds, the HO-CHUNK NATION (HCN) Education

Department Accountant and selected staff of the Department of Treasury must

collectively plan, implement and evaluate fiscal activities including Financial Status

Reports (SF-269s) to maintain compliance to the following standards.

(A)

Financial Reporting: Accurate, current, and complete disclosure of the

financial results of each project or program shall be made in accordance with

the financial reporting requirements of the grant or sub grant.

Revised 2024

(B)

Accounting Records: Records which identify adequately the source and

application of funds for grant or supported grant-supported activities shall be

maintained. These records shall contain information pertaining to grant or

supported awards, authorizations, obligations, unobligated balances, assets,

outlays, income, and, if the recipient is a government, liabilities.

(C)

Internal Controls: Effective control and accountability shall be maintained

for all grant or supported cash, real and personal property covered by

Subpart O of this part (reference EDGAR Section 74.3), and other assets.

Recipients shall adequately safeguard all such property and shall assure that

it is used solely for authorized purposes.

(D)

Budgetary Controls: The actual and budgeted amounts for each grant or

grant-supported activity shall be compared. If appropriate or specifically

required, recipients shall relate financial information to performance or

productivity data, including the production of unit cost information. If unit

cost data are required, estimates based on available documentation will be

accepted whenever possible.

(E)

Advance Payments: Procedures shall be established to minimize the time

elapsing between the advance of Federal grant or supported funds and their

disbursement by the recipient. When advances are made by a letter-of credit

method, the recipient shall make drawdowns as close as possible to the time of

making disbursements.

(F)

Allowable Costs: Procedures will be established for determining the

reasonableness, allow ability, and allocability of costs in accordance with the

applicable cost principles prescribed by Subpart A of this part and terms of

the grant.

(G)

Source Documentation: Accounting records shall be supported by

source documentation such as cancelled checks, paid bills, payrolls, contract

and sub grant award documents.

SECTION XIV: REPORTING REQUIREMENTS

The following REPORTING REQUIREMENTS will be planned,

implemented and evaluated by the Ho-Chunk Nation Education

Department to comply with mandated GRANTEE responsibilities. The

actual drafting of these reports must be conducted by the IEC’s and submitted

to the JOM Program Staff for compilation and submission to the BIA.

Without the participation of the Parents, the program cannot effectively be

evaluated or implemented.

Revised 2024

Semi-Annual Financial Status Report

(SF-269 A and Attachment 1)

Will be facilitated by the HCN Department of Treasury and submitted by April 25,

October 25, and/ or final 90 days after the conclusion of the contract or fiscal year.

SECTION XV: ANNUAL REPORT

A product final assessment of JOM activities (Annual Narrative Report) will be compiled

by collection of data that define the net effects of the EDUCATION PLANS applied in

the project. The Annual Narrative Report will produce and interpret findings related to

whether the three (3) OBJECTIVES produced desirable changes and their potential for

being replicated. The following measurable narrative reporting format will assess

whether this JOM program worked. The Annual Report is due December 31st each year.

Educational Support Objective

By September 30, of the current contract year, JOM staff in concert with the HCN

Education Department Accountant will facilitate a prorated percentage of dollars for

Educational Support Costs that will assist with the cost of basic and unique educational

initiatives for each eligible JOM student to enable them access academic readiness

enhancement as approved by the IEC’s.

Accomplishments:

Barriers to Implementation:

Corrective Action:

Recommendations:

Cultural Awareness Objective

By September 30, of the current contract year, JOM staff in concert with the HCN

Education Department Accountant will facilitate a prorated percentage of dollars for

Cultural Awareness Costs that will: (1) create and foster cultural awareness in the local

community and (2) to reinforce tribal identity for each eligible JOM student as approved

by the IEC’s.

Accomplishments:

Barriers to Implementation:

Corrective Action:

Recommendations:

Revised 2024

Administrative Objective

By September 30, of the current contract year, JOM staff in concert with the HCN

Education Department Accountant will facilitate a prorated percentage of dollars for

Administrative Costs that will provide reimbursement and payment for meeting expenses

incurred by the JOM Committee(s) to enable them to carry out their JOM duties as

approved by the IEC’s.

Accomplishments:

Barriers to Implementation:

Corrective Action:

Recommendations:

SECTION XVI: PENALITIES FOR NON-COMPLIANCE WITH HCN JOM

POLICY MANUAL [SOURCE AUTHORITY 25CFR-273.51]

If any officer, director, agent or employee of, or connected with, any contractor or

subcontractor under this part embezzles, willfully misapplies, steals, or obtains by fraud

any of the funds or property connected with the contract or subcontract, he/she shall be

subject to the following penalties:

If the amount involved does not exceed $100, he/she shall be fined not more than

$1,000 or imprisoned not more than one year, or both.

If the amount involved exceeds $100, he/ she shall be fined not more than $10,000

or imprisoned for not more than two years, or both.

In an effort to avoid Federal penalties these actions will be taken

first.

If at any time, an IEC is determined to operate in a manner inconsistent with the JOM

Policy Manual, the JOM Division Manager will take the following steps to try and

obtain voluntary compliance.

1) The non-compliant act(s) will be brought to the attention of the IEC along with

any supporting documentation or information.

a. The IEC Representative will be afforded the opportunity to address the

issue(s) and demonstrate that the issue(s) was resolved

2) If the IEC is unable to resolve the issue locally, the JOM Division Manager will

freeze the IEC budget until the issue can be resolved though the Ho-Chunk Nation

Department of Justice. Once action has begun through the Ho-Chunk Nation

Department of Justice and the outcome seems to support the timely resolution of

Revised 2024

the situation, the JOM Division Manager MAY unfreeze the IEC’s budget or may

place conditions that must be met in order to have the budget unfrozen. These

may include the replacement of an IEC officer or the immediate repayment to the

Ho-Chunk Nation any funds that are not reconciled.

3) If issues are not in a timely fashion through the intervention of the Ho-Chunk

Nation Department of Justice nor through voluntary repayment or other

recommended action, the JOM Division Manager may re-allocate the affected

areas funds to another area to ensure that services are still provided to the affected

areas children. The affected area will then comply with the new areas by-laws,

expenditure lists and any other regulations that they may have in place until such

time as the JOM Division Manager deems it appropriate for the affected area to

resume its role of providing services.

Revised 2024

APPENDIX

Budget Profile Sheet

[Headcount & Annual Budget by Area]

JOM

Budget Breakdown

[Baraboo/Reedsburg/Portage, Black River Falls/Neillsville, Eau

Claire/Augusta/Osseo-Fairchild, La Crosse, Madison (Dane

County), Pittsville/Port Edwards/Nekoosa, Stevens Point, Tomah,

Wisconsin Dells/Mauston/Adams-Friendship, Wisconsin Rapids,

Wittenberg]

JOM FINANCIAL REPORTING

SAMPLE

[Source: HCN Education Department Accountant]

HCN JOM PROGRAM APPROVED FORMS

[Source: HCN JOM Staff]

Revised 2024

EXAMPLE

FYXXXX JOM

BUDGET

AREA

HEADCOUNT

ANNUAL BUDGET

ADMINISTRATION

N/A

$23,550.00

BARABOO

$5,368.00

BLACK RIVER FALLS

129

$9,111.00

LA CROSSE

$4,097.00

NEILLSVILLE

$706.00

PITT/PORT ED/NEK

$3,178.00

TOMAH

$5,580.00

WISCONSIN DELLS

166

$11,725.00

WISCONSIN RAPIDS

$2,966.00

WITTENBERG

$3,461.00

EAU CLAIRE

$2,825.00

MADISON

$4,944.00

STEVENS POINT

$989.00

TOTAL

778

$78,500.00

General Rules in Federal Budgets

Administration 30%

Program Services 70%

Total 100%

breakdown per student is

23,550.00

54,950.00

78,500.00

70.63

Revised 2024

JOM PROGRAM APPROVED FORMS

All forms listed are to be used, as needed and required, when conducting IEC

business. The format of these forms can be altered to suit each area as needed but the

content of the information must remain intact.

The IEC Meeting Minutes Forms can be used “as-is” or as a guide for typed minutes. Submit

all sheets, used or un-used to JOM Program staff for inclusion in the permanent program files.

Revised 2024

Johnson O’Malley Program

Meeting Minutes Form

Date: _____/_____/_____

Type of Meeting: ________________________________________________________

Location of Meeting: _____________________________________________________

Time Meeting Called to Order: __________ a.m.

p.m.

(Circle One)

Meeting Called to Order by: __________________________ Title: _______________

Prayer Conducted by: ____________________________________________(Optional)

Attendees Names: (Note: Officers put their title

next to their name)

1. _______________________________ 11. _______________________________

2. _______________________________ 12. _______________________________

3. _______________________________ 13. _______________________________

4. _______________________________ 14. _______________________________

5. _______________________________ 15. _______________________________

6. _______________________________ 16. _______________________________

7. _______________________________ 17. _______________________________

8. _______________________________ 18. _______________________________

9. _______________________________ 19. _______________________________

10. _______________________________ 20. _______________________________

Quorum established (circle one):

YES

Revised 2024

Note: If more space is needed on any page, use the back of the

pages and be sure to reference what it is a continuation of.

AGENDA

________________________________________________________________________

Revised 2024

Motion Made Is To Approve Agenda: _______________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: __________________________

MINUTES REVIEW FOR LAST MEETING

Minutes of Last Meeting Read By: ______________________ Title: ______________

Comments: _____________________________________________________________

Revised 2024

Motion Made Is To: ______________________________________________________

Revised 2024

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: __________________________

REPORTS

Report: ________________________________________________________________

Reported by: ________________________________ Title: ______________________

Report: ________________________________________________________________

Reported by: ________________________________ Title: ______________________

Report: ________________________________________________________________

Revised 2024

Reported by: ________________________________ Title: ______________________

Report: ________________________________________________________________

Reported by: ________________________________ Title: ______________________

UNFINISHED BUSINESS

Unfinished Business: _____________________________________________________

Revised 2024

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: __________________________

Unfinished Business: _____________________________________________________

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

_____ Against

_____ Abstained

Revised 2024

Motion: (check one)

Carries

Fails

Other:

__________________________ Unfinished Business:

_____________________________________________________

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: __________________________

Unfinished Business: _____________________________________________________

Revised 2024

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: _________________________

NEW BUSINESS

New Business: ___________________________________________________________

Revised 2024

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: __________________________

New Business: ___________________________________________________________

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

_____ Against

_____ Abstained

Motion: (check one)

Carries

Fails

Other:

__________________________ New Business:

___________________________________________________________

Revised 2024

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: __________________________

New Business: ___________________________________________________________

Revised 2024

Motion Made Is To: ______________________________________________________

Motion Is Made By: ______________________ Second Is By: ___________________

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: _________________________

ANNOUNCEMENTS

Announcement: _________________________________________________________

Made by: ___________________________________ Title: ______________________

Announcement: _________________________________________________________

Revised 2024

Reported by: ________________________________ Title: ______________________

Announcement: _________________________________________________________

Reported by: ________________________________ Title: ______________________

Announcement: _________________________________________________________

Reported by: ________________________________ Title: ______________________

Next Meeting Information

Next Meeting Location: ___________________________________________________

Revised 2024

Date: _____/_____/_____ Time: __________ a.m. /

p.m. (Circle One)

Next Meeting Expense Check Should Be Made To: ___________________________

Address: ____________________________ City: __________________ State: ______

Zip: _________ Tel. #: _______________________ Fax #:

_______________________

Adjournment Motion

Motion Is Made By: ______________________ Second Is By: ___________________

Time: _______________ am/pm

Vote: _____ For

Motion: (check one)

_____ Against

Carries

_____ Abstained

Fails

Other: _________________________

Signature of Secretary: __________________________________

By signing this document I am attesting that everything herein is factual and true to the

best of my knowledge.

Note: Attach all other documents, sign-in sheet form, receipts and others necessary for

reimbursements or other action by the JOM staff Services Johnson O’Malley Program

staff to this form before submitting. Keep a copy of all documents for your IEC files.

Revised 2024

Johnson O’Malley Program

Meeting Sign -in Form

Date: _____/_____/_____

Name

(Print)

Location: ____________________________________________

Address & Phone #

Email address

Signature

Revised 2024

Johnson O’Malley Program

Meal Receipt Form

Date: _____/_____/_____

Name

Location: ____________________________________________

Signature

(Print)

Revised 2/21/06

Revised 2024

Johnson O’Malley Program Registration Form

Date: _____/_____/_____

Male: _______

Female: _______

Student Name: ____________________________________ ______________________________________

(Print)

Grade: __________ Age: ________ D.O.B.: _____/_____/_____ Email address:______________________

MM DD

Mailing Address: ____________________________________City: ______________ State: ____ Zip:______

Tribal Affiliation: _________________________________ Tribal Enrollment #: _______________________

School District: _____________________________________ School Name: __________________________

JOM Area/IEC (Circle One):

Baraboo/Reedsburg/Portage/Wi Dells/Mauston Black River Falls/Neillsville/ AC-H-M/Blair-Taylor Eau Claire

Wittenberg Augusta/Osseo-Fairchild

La Crosse

Madison/Dane County

Pittsville/Port Edwards/Nekoosa

Stevens Point

Tomah/ Sparta

Wisconsin Rapids

Parent/Guardian Name: _______________________________________ Phone #: ______________________

(Print)

Are you available to serve on the JOM Parent/Officer Committee?

Yes: _____ No:_____

Chairperson’s specific duties – Call meetings, Chair meetings, and Represent Committee

Secretary’s duties – Record minutes, Send minutes and meeting notices ou

Vice-Chairperson’s duties – Act as Chair in Chair’s absence.

We invite your comments regarding your child so that we may better meet his/her educational needs in his/her

school or other areas:

Eligibility requirements are: 3 years of age (by October 1st) through grade 12 and are a 1/4 or more

degree Indian blood AND recognized by the Secretary as being eligible for Bureau services (273.12 Eligible

students.) Documentation must be submitted to IEC Secretary/ Officers to verify enrollment/blood

quantum one time (not needed each year).

I hereby give authority to the JOM IEC Officers to verify my child’s enrollment by receiving a copy of the Certificate

Degree of Indian Blood for purposes of JOM program eligibility.

___________________________________________________

Parent/ Guardian Signature:

Participant Eligibility Verified By IEC Officer:__________________________________Signature

Participant Eligibility Verified By IEC Officer: __________________________________ Signature

Revised 2024

Revised 2/21/06 2 Revision 11/4/2007

Johnson O’Malley Program

IEC Door Prize Receipt Form

Date: _____/_____/_____

Name

(Print)

IEC: _______________________________________________

Prize Won

Signature

Revised 2024

Johnson O’Malley Program

IEC Activity Payment Receipt Form

Date: _____/_____/_____

IEC: _________________________________________________________

Activity: ________________________________ Location: _____________________________________

Name

(Print)

Amount

(Cook, Dancer,

Payment

Etc.)

Recv’d

Title

Signature

Revised 2024

Johnson O’Malley Program

IEC Activity Participation Verification Form

Date: _____/_____/_____

IEC: __________________________________________________ ____

Activity Name: _________________________ Location:

____________________________________

Name

Title

(Print)

(Student/Parent/Guardian)

Signature

Revised 2024

Johnson O’Malley Program

Parent Training Report Form

Date: _____/_____/_____

Name (Print): ________________________________ IEC Area: ________________

Title of Training: ________________________________________________________

Presenter: ___________________________ Location: __________________________

Date of Training: _____/_____/_____ Topic(s): _______________________________

To: _____/_____/_____

_______________________________

New Ideas, Methods, Activities, Information Shared: __________________________

Recommended Suggestions for HCN JOM Program to Utilize: __________________

Positive/Negative Aspects of Training Offered: _______________________________

Revised 2024

Recommend Sending Parents Again Next Year?

YES

If NO, explain? __________________________________________________________

Please attach copies of all handouts, student materials, and other pertinent

documents. Also complete the Narrative Report on the training(s) you attended to

share with other JOM parents.

Training Report Narrative

Revised 2024

Signature:_______________________________________

Revised 2/21/06

Second revision 8/6/09

Revised 2024

Reimbursement Request Form

Johnson O’Malley Program

Make Check Payable to:

IEC/School District

Address/Street, P.O. Box

IEC Chairperson:

City

State

Zip

IEC Meeting Date of Approval:

Telephone #

Name of Student (Print)

Description

IEC Budget Line

Item # to be

Charged

Amount

TOTAL:

Will NOT be processed without signature.

Parent/Guardian Signature:

Date:

Reminder: Attach original receipts,

bills, etc. for faster processing

Yellow highlighted must be completed by parent for

reimbursement to be approved.

Revised 2024

Johnson O’Malley Program

Reimbursement/Payment Form

Date: _____/_____/_____

School Year _______/_______

TO: Johnson O’Malley Program Staff

FROM: ______________________________ /IEC

(Expenses listed on this form have been approved for payment at the IEC meeting described

above. Copies of the minutes and supporting documents must be attached)

For Reimbursement(s) (Describe):

Total Amount $___________________

For Payments to School(s)/Vendor(s) (Describe):

Total Amount $___________________

Are minutes of IEC meeting, receipts, invoices, bills, cancelled checks, etc. attached as required?

YES

NO - If no explain: ____________________________

__________________________________________________________________________________

Other Comments: ___________________________________________________________________

______________________________________________________ ____________________________

Revised 2024

Form completed by: _______________________________/_________________________________

Signature

Title

Printed Name:

______________________________________________________________________

Front

Details of Approved JOM Expense(s) - _________________________________IEC

Revised 2/21/06 second revision 8/6/09

Date

Make Check Payable To:

Amount

Purpose

Line Item

DD/MM/YY

Revised 2024

Revised 2/21/06 second revision 8/6/09

Back

Revised 2024

Ho-Chunk Nation

Johnson O’Malley Program

Needs Assessment Survey

IEC: ____________________________________FY:_____________________

1. PLEASE CHECK ANY NEEDS THAT SHOULD BE PROVIDED THROUGH THE JOM PROGRAM TO

NATIVE AMERICAN STUDENTS

_______A. Tutoring

Grade___________

_______B. Indian Cultural Programs

1. ______ Presentations 2.______ Pow wows 3._____ Arts & Crafts

Other Suggestions: _____________________________________________

_______C. Math/Science Improvement

_______D. Reading/Language Improvement

_______E. School Supplies

_______F. Career Counseling or Higher Education Orientation

_______G. Educational Support (list): ___________________________________________

_______H. Other Suggestions: _________________________________________________

2. SELECT YOUR CHOICE OF THE THREE (3) MOST IMPORTANT NEEDS LISTED:

1. ______________________________

2. ______________________________

3. ______________________________

3. HOW DO YOU THINK YOUR JOM IEC FUNDS COULD BE BETTER UTILIZED TO ENABLE NATIVE

AMERICAN STUDENTS TO BE REPRESENTED EQUALLY IN SCHOOL ACTIVITIES?

_____________________________________________________________________________________

4. DO YOU FEEL THE JOM IEC IS REPRESENTING YOUR SPECIFIC SCHOOL DISTRICT? ___________IF NOT,

WHY? ______________________________________________________

4. PLEASE CIRCLE THE CATEGORY THAT BEST DESCRIBES YOU:

PARENT/GUARDIAN

STUDENT

Revised 2024

Johnson O’Malley Program

School Supply Receipt Form

Date: _____/_____/_____

IEC: _______________________________________________

Child’s Name

Parent/Guardian Name

(Print)

Parent/Guardian Signature

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.