# JOHNSON O’MALLEY PROGRAM (2024) > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/tribal%3Aho-chunk%3A1d5acd340a30c779 ## Record - **Collection:** Tribal code - **Document type:** Tribal code ## Text 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 Revised 2024 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. 2 Revised 2024 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. 3 Revised 2024 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 4 Revised 2024 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. 5 Revised 2024 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: 6 Revised 2024 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 7 Revised 2024 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”. I. 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). i. Supplemental Programs – Programs that support and are in addition to existing programs in the public schools. Johnson O’Malley funds cannot be used to 8 Revised 2024 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 i 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 9 Revised 2024 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 10 Revised 2024 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: 11 Revised 2024 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. 12 Revised 2024 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: 13 Revised 2024 i. 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. 14 Revised 2024 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. 15 Revised 2024 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. 16 Revised 2024 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): i. 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 v. 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 17 Revised 2024 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. 18 Revised 2024 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. 19 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. 20 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: 21 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: a 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. b 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 22 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. 23 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] 24 Revised 2024 EXAMPLE FYXXXX JOM BUDGET AREA HEADCOUNT ANNUAL BUDGET ADMINISTRATION N/A $23,550.00 BARABOO 76 $5,368.00 BLACK RIVER FALLS 129 $9,111.00 LA CROSSE 58 $4,097.00 NEILLSVILLE 10 $706.00 PITT/PORT ED/NEK 45 $3,178.00 TOMAH 79 $5,580.00 WISCONSIN DELLS 166 $11,725.00 WISCONSIN RAPIDS 42 $2,966.00 WITTENBERG 49 $3,461.00 EAU CLAIRE 40 $2,825.00 MADISON 70 $4,944.00 STEVENS POINT 14 $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 25 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. 26 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 / NO 27 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 ________________________________________________________________________ 28 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: _____________________________________________________________ 29 Revised 2024 Motion Made Is To: ______________________________________________________ 30 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: ________________________________________________________________ 31 Revised 2024 Reported by: ________________________________ Title: ______________________ Report: ________________________________________________________________ Reported by: ________________________________ Title: ______________________ UNFINISHED BUSINESS Unfinished Business: _____________________________________________________ 32 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 33 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: _____________________________________________________ 34 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: ___________________________________________________________ 35 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: ___________________________________________________________ 36 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: ___________________________________________________________ 37 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: _________________________________________________________ 38 Revised 2024 Reported by: ________________________________ Title: ______________________ Announcement: _________________________________________________________ Reported by: ________________________________ Title: ______________________ Announcement: _________________________________________________________ Reported by: ________________________________ Title: ______________________ Next Meeting Information Next Meeting Location: ___________________________________________________ 39 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. 40 Revised 2024 Johnson O’Malley Program Meeting Sign -in Form Date: _____/_____/_____ Name (Print) Location: ____________________________________________ Address & Phone # Email address Signature 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 41 Revised 2024 Johnson O’Malley Program Meal Receipt Form Date: _____/_____/_____ Name Location: ____________________________________________ Signature (Print) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Revised 2/21/06 42 Revised 2024 Johnson O’Malley Program Registration Form Date: _____/_____/_____ Male: _______ Female: _______ Student Name: ____________________________________ ______________________________________ (Print) Grade: __________ Age: ________ D.O.B.: _____/_____/_____ Email address:______________________ MM DD YY 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 43 Revised 2024 nd 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 1 2 3 4 5 6 7 8 9 10 11 44 Revised 2024 Johnson O’Malley Program IEC Activity Payment Receipt Form Date: _____/_____/_____ IEC: _________________________________________________________ Activity: ________________________________ Location: _____________________________________ Name (Print) Amount of (Cook, Dancer, Payment Etc.) Recv’d Title Signature 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 45 Revised 2024 Johnson O’Malley Program IEC Activity Participation Verification Form Date: _____/_____/_____ IEC: __________________________________________________ ____ Activity Name: _________________________ Location: ____________________________________ Name Title (Print) (Student/Parent/Guardian) Signature 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 46 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: _______________________________ 47 Revised 2024 Recommend Sending Parents Again Next Year? YES NO 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 48 Revised 2024 Signature:_______________________________________ Revised 2/21/06 Second revision 8/6/09 49 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. 50 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: ___________________________________________________________________ ______________________________________________________ ____________________________ 51 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 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 52 Revised 2024 20 21 22 23 24 25 26 27 Revised 2/21/06 second revision 8/6/09 Back 53 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 54 Revised 2024 Johnson O’Malley Program School Supply Receipt Form Date: _____/_____/_____ IEC: _______________________________________________ Child’s Name Parent/Guardian Name (Print) (Print) Parent/Guardian Signature 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 55 --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Aho-chunk%3A1d5acd340a30c779. Public record. Not legal advice.