TSCPA 2013 ISD Title 1A and IDEA B

2013 Texas School District Accounting and Auditing Conference

June 11, 2013

Title I, Part A – Improving Basic Programs (CFDA 84.010)

Compliance Requirements

Program Objectives

• Improve the teaching and learning of children who:– Are at risk of not meeting the state’s student

performance standards and– Reside in areas with high concentrations of children

from low-income families

2

• A. Activities Allowed or Unallowed• B. Allowable Costs/Costs Principles• C. Cash Management• D. Davis-Bacon Act• E. Eligibility• F. Equipment and Real Property

Management• G. Matching, Level of Effort,

Earmarking

• H. Period of Availability• I. Procurement and

Suspension and Debarment• J. Program Income• K. Real Property Acquisition

Relocation Assistance• L. Reporting• M. Subrecipient Monitoring• N. Special Tests and Provisions

3

Matrix of Compliance Requirements



Earmarking




4

Title I, Part A Compliance Requirements – Not Applicable



Earmarking




5

Title I, Part A Compliance Requirements – Usually Not Direct and Material



Earmarking




6

Title I, Part A Compliance Requirements – Direct and Material

A. Activities Allowed or Unallowed

• Obtain NCLB Consolidated Federal Grant Application and all amendments– Keep in mind the program’s objective– Read negotiation notes and grantee comments – Which campuses are targeted assistance, schoolwide, or not served?– Review program budget summary– Is capital outlay budgeted?– Identify the activities that are specifically allowed or prohibited by law,

regulations, and the provisions of contract or grant agreements

7


• Targeted Assistance Programs– District may only use TIA funds to meet the needs of

children identified as being in greatest need of services• Schoolwide Programs

– District may use TIA funds for activities that are part of the Campus Improvement Plan (CIP) to improve student performance and upgrade the entire educational program

8


• Targeted Assistance Programs meet the intent and purpose of Title I, Part A if the program:– Serves only students failing or most at risk of failing to

meet the state’s academic achievement standards,– Provide supplementary services designed to meet the

special needs of the students in the program, and– Uses the state’s assessment system to determine

effectiveness of the program.

9


• Schoolwide Programs meet the intent and purpose of Title I, Part A if the program:– Campus meets the poverty threshold (40%) for eligibility,– Promotes schoolwide reform and upgrades the entire educational

operation of the campus– Meets the educational needs of all children in the school, particularly

those failing, or most at risk of failing to meet the state’s academic achievement standards

– Uses the state’s assessment system to determine effectiveness of the program.

10

B. Allowable Costs/Cost Principles

• Requirements for school districts are contained in OMB Circular A-87, “Cost Principles for State, Local, and Indian Tribal Governments” (2 CFR part 225)

• Allowability/unallowability of certain items is cost is provided– Allowable– Allowable with restrictions– Unallowable– Not specifically addressed

• Costs must be necessary and reasonable

11

• Economically disadvantaged

• Disabilities• Migrant• Limited English proficient• In a neglected or delinquent

institution• Attending a community day

program

• Head Start, Even Start, Early Reading First, Title I preschool program, Migrant Education Program under Title I, Part C – At any time in the 2

preceding years

12

E. 1 Eligibility for Individuals (Targeted Assistance Programs Only)

E.2 Eligibility for Group of Individuals or Area of Service Delivery

• Districts with less than 1,000 enrolled students or with only one school per grade span (e.g., K-5, 6-8, 9-12) are not required to rank its school attendance areas– a.k.a Single Attendance Area– All campuses are eligible to receive TIA services– District may choose to serve any or all its campuses– Not required to allocate funds to campuses in rank

order

13


• Districts determine eligibility based on the level of poverty in each school attendance area. Measures of poverty that can be used are:– Children, ages 5-17, in poverty counted in the most recent census– Children eligible for free and reduced price lunches– Children in families receiving TANF assistance– Children eligible to receive Medicaid assistance– A composite of the above measures

• Districts must use the same measure consistently in ranking its school attendance areas

14


• If poverty measure is greater than 75% the area or school must be served unless: – The school meets TIA comparability requirements,– The school is receiving supplemental state or local funds that are

spent in accordance with sections 1114 and 1115 of TIA, and– The supplemental state and local funds expended in the area or

school equal or exceed the amount that would be provided under TIA.

– Appears as “Skip” on the grant application

15


• If TIA funds remain after serving all campuses >75%, the District should– Rank all remaining eligible campuses (those >40%)

either by grade span or by District as a whole, and– Serve these campuses in rank order, either within the

grade span grouping or within the District as a whole

16


• A District may designate as eligible:– Any campus where at least 35% of students are from low-

income families– Any campus from an ineligible school attendance area, if

its low-income % of enrolled students is greater than or equal to that of a participating campus

– Any ineligible campus that was eligible last year and served as a TIA campus for one additional transition year

17


• Allocating funds to campuses in rank order on the basis of the total number of low-income students in each attendance area (multiple attendance area)– Districts are not required to allocate the same per

pupil amount to each campus, however, the District can not allocate a greater per pupil amount to a campus with a lower low-income rate than it allocates to campuses with higher low-income rates

18


– Districts that choose to serve campuses with 75% low-income or less using grade span groupings may determine different per pupil amounts for different grade spans as long as they don’t exceed the amount allocated to campuses above 75% low-income

– Per pupil amounts within grade spans may also vary as long as higher per pupil are amounts are used with campuses with the higher low-income rates than campuses in the grade span with lower low-income rates

19


Campus Grade Total Residing Low-income Residing

Percentage Low-income

Daisy MS 6-8 500 255 51%

Rose Elem. K-5 600 300 50%

Bluebonnet HS

9-12 475 171 36%

Totals 1,575 726 46%

20

Anywhere ISD Campus Allocation ExampleSingle Attendance Area


Campus Grade Total Residing Low-income Residing


Oak Elem. PK-5 480 384 80%

Birch MS 6-8 430 324 75%

Aspen Elem. K-5 300 177 59%

Mesquite MS 6-8 320 158 49%

Catalpa Elem K-5 505 178 35%

Cedar MS 6-8 458 150 33%

Elm Elem. PK-5 840 125 15%

Maple HS 9-12 900 112 12%

Hackberry MS 6-8 450 55 12%

Totals 4,683 1,663 36%21

Anywhere ISD Campus Allocation ExampleMultiple Attendance Area


Campus Low-income Residing


Per Pupil Amount

Campus Allocation

Oak Elem. 384 80% $700 $268,800

Birch MS 324 75% $700 $226,800

Aspen Elem. 177 59% $700 $123,900

Mesquite MS 158 49% $700 $110,600

Catalpa Elem 178 35% $700 $124,600

Totals $854,700

22

Anywhere ISD Campus Allocation ExampleMultiple Attendance Area – Option 1 ($1M entitlement), Same per pupil amount




Per Pupil Amount

Campus Allocation

Oak Elem. 384 80% $800 $307,200

Birch MS 324 75% $800 $259,200

Aspen Elem. 177 59% $700 $123,900

Mesquite MS 158 49% $600 $94,800

Catalpa Elem 178 35% $600 $106,800

Totals $891,900

23

Anywhere ISD Campus Allocation ExampleMultiple Attendance Area – Option 2 ($1M entitlement), Tiered approach




Per Pupil Amount

Campus Allocation

Oak Elem. 384 80% $700 $268,800

Birch MS 324 75% $700 $226,800

Aspen Elem. 177 59% $700 $123,900

Mesquite MS 158 49% $400 $63,200

Catalpa Elem 178 35% $700 $124,600

Totals $807,300

24

Anywhere ISD Campus Allocation ExampleMultiple Attendance Area – Option 3 ($1M entitlement), Rank by grade span


• Before allocating TIA funds, Districts must reserve funds to provide comparable services to:– Children in local institutions for neglected children and– Homeless children who do not attend participating schools

• A District may reserve funds to provide comparable services to:– Children in local institutions for delinquent children– Neglected and delinquent children in community day school

programs

25

G.2.1 Level of Effort – Maintenance of Effort (MOE)

• A District may receive its full TIA entitlement if either– The combined fiscal effort per student or– The aggregate expenditures For the preceding year was not less than 90% of the

combined fiscal effort or aggregate expenditures for the 2nd preceding fiscal year

• Totals to use for per student calculation– Refined ADA, Membership, or Enrollment

26


• MOE is determined using state and local operating expenditures by function– Excluding expenditures for community service, capital

outlay, or debt service, and any federally funded expenditures

• Remember to include Ed Jobs from Fund 287

27


• MOE is determined using state and local operating expenditures by function– Excluding expenditures for community service, capital

outlay, or debt service, and any federally funded expenditures

• The TEA monitors compliance with MOE using data reported to PEIMS (TEA provides templates)

• The TEA is required to reduce allocation of TIA funds for MOE noncompliance

28

G.2.2 Level of Effort – Supplement not Supplant

• Supplement – to add to, to expand, to increase, to extend• Supplant – to take the place of, to replace• Level of state and local support for programs remains at least

constant and not replaced by federal funds• Federal funds may not be used to provide services required by:

– State law,– State Board of Education rule, or– Local policy

29

G.2.2 Level of Effort – Supplement not Supplant

Supplement/Supplant All purchases with Title I funds MUST be supplemental.

In general, to supplement, not supplant means that Title I funds are used to implement programs and services that would not be available if it were not for these federal funds. In other words, if Title I funds were not available to do this activity, the district would not do it.

The Supplement, Not Supplant Tests When determining whether a fiscal expenditure supplements and not supplants, school districts must run these three tests.

o Test I: Required – Is the program or activity that the district wants to fund required under state, local, or another federal law? If it is, then it is supplanting.

o Test II: Equivalency – Were state or local funds used in the past to pay for this program or activity? If they were, it is supplanting.

o Test III: Non-Title I Programs – Are the same programs or activities being implemented in other schools that do not receive Title I funds AND are these programs and activities being paid for with state or local funds? If yes, then this is supplanting.

If an expenditure does not pass any of the above tests, then it is presumed that Title I funds are supplanting state or local funds. Expenditures must pass all three tests to be supplemental.

Any Title I funds found to be used to supplant expenditures, must be repaid with non-federal funds and can effect future Title I allocations.

30

• Parent involvement activities (1% if entitlement is greater than $500,000)

• Service to eligible private school students

• Preschool programs• Administration of TIA• Professional development

activities (10% required if identified for School Improvement)

• School improvement activities (choice-related transportation and other supplemental services)

• Homeless students attending campuses not served by TIA

• Students residing in local facilities for neglected and delinquent

31

G.3 Earmarking (activities funds are reserved for prior to campus allocation)

N.1 Participation of Private School Children

32

• Districts must: – Have timely and meaningful consultation with private

school officials– Provide equitable services to eligible private school

children, their teachers, and their families– Use the portion of TIA funds attributable to private

school children from low-income families in determining services to provide

N.1 Participation of Private School Children

33

• Example– $100,000 of TIA fund allocated based on 100 children from

low-income families– 25 are private school children– $25,000 of the $100,000 must be expended to provide

equitable services to private school children• Funds reserved “off the top” must also benefit eligible private

school children in proportion (e.g., parental involvement, professional development)

N.2 Schoolwide Programs

34

To operate a schoolwide program, a school must include the following three core elements:

• Comprehensive needs assessment of the entire school• Comprehensive plan based on data from the needs assessment• Annual evaluation of the results achieved by the schoolwide program and

revision of the schoolwide plan based on that evaluation

N.2 Schoolwide Programs

35

A schoolwide plan also must include the following components:

• Schoolwide reform strategies• Instruction by highly qualified professional staff• Strategies to increase parental involvement• Additional support to students experiencing difficulty• Transition plans for assisting preschool children in the successful transition to the schoolwide program

N.3 Comparability

36

• State and local funds used at TIA campuses provide services that, taken as a whole, are at least comparable to services at non-TIA campuses

• Requirement ensures that TIA campuses receive the same level of services from state and local funds as other campuses

• Does not apply to single attendance areas or campuses with fewer than 100 students

N.3 Comparability

37

• Compliance can be determined on a districtwide basis or on a grade-span basis

• Consider Ed Job funds• The Comparability Computation Form (CCF) and

Assurance Document is uploaded on the TEASE– For 2012-2013 these were due on 11/12/2012

• The TEA monitors compliance using the PEIMS data on actual expenditures

N.5 Identifying Schools and LEAs Needing Improvement

38

• A TIA district or campus that does not meet AYP for 2 or more consecutive years will enter School Improvement status under NCLB

• Depending on the number of years the district or campus has failed to meet AYP, a particular set of requirements becomes effective (e.g., corrective actions, restructuring)

• Districts must prepare and distribute a “report card” of annual progress, including those campuses identified for improvement

N.6 Highly Qualified Teachers and Paraprofessionals

39

• Teachers working in a program supported by TIA funds and providing direct instruction in any core academic area must be “highly qualified” – Hold at least a bachelor’s degree,– Be filly certified to teach in Texas, and– Demonstrate competency in their core academic area


40

• Paraprofessionals provide instructional support in a program supported with TIA funds including:– One-on-one tutoring– Classroom management– Instructional assistance in computer lab or support in library or media

center– Conduct parental activities– Translator– Instructional support under direct supervision of a highly qualified

teacher


41

• Paraprofessionals must meet one of these qualifications:– Completed at least 2 years study at a higher education

institution (48 semester hours),– Obtained an associate’s (or higher) degree, or– Met a rigorous standard of quality met through a

formal state or local academic assessment

Resources

• OMB Circulars– http://tinyurl.com/bu5cydn

• TEA Title I, Part A – Improving Basic Programs– http://tinyurl.com/ctvrdtz

• Celina Miller, CPA – [email protected]

• Guadalupe Garcia, CPA– [email protected]

42

http://tinyurl.com/bu5cydn

http://tinyurl.com/ctvrdtz

mailto:[email protected]

mailto:[email protected]

Auditing the Special Education Cluster (CFDA

84.027/84.173

Objectives

• Office of Management and Budget (OMB) A-133 Compliance Requirements

• Maintenance of Effort (MOE)• Special Ed FAQ• Texas Education Agency Desk Review Audit

Where do we Start?

• Matrix of Compliance Requirements (Part 2)• Part 4 Department of Education Cross Cutting Section • Part 4 CFDA 84.027/84.173 Specific Compliance Supplement• IDEA B Application• TEA Funds

– 224 – Formula (84.027)– 225 – Preschool (84.173)– 226 – Discretionary (84.027)– 227- IDEA B – Deaf (84.027)– 228- IDEA B – Preschool Deaf (84.173)

14 Compliance Requirements

A. Activities Allowed or Unallowed H. Period of AvailabilityB. Allowable Costs/Cost Principles I. Procurement and Suspension

and DebarmentC. Cash Management J. Program IncomeD. Davis Bacon K. Real Property Acquisition and

Relocation AssistanceE. Eligibility L. ReportingF. Equipment and Real Property Management

M. Subrecipient Monitoring

G. Matching, Level of Effort, and Earmarking

N. Special Tests and Provisions

Special Ed Cluster Compliance Requirements – Not Applicable

A. Allowable Activities H. Period of Availability

B. Allowable Costs/Cost Principles I. Procurement and Suspension and Debarment

C. Cash Management J. Program IncomeD. Davis Bacon K. Real Property Acquisition

and Relocation AssistanceE. Eligibility L. Reporting

F. Equipment and Real Property Management




Special Ed Cluster Compliance Requirements – Usually NOT Direct and Material


and DebarmentC. Cash Management J. Program IncomeD. Davis Bacon K. Real Property Acquisition and

Relocation AssistanceE. Eligibility L. ReportingF. Equipment and Real Property Management




Special Ed Cluster Compliance Requirements- Direct and Material


and DebarmentC. Cash Management L. ReportingF. Equipment and Real Property Management



A/B – Activities Allowed & Unallowed and Allowable Costs/Cost Principles

• Read the Grant Application• Read the Special Education TEA Website for allowable

activities• Allowable Cost/Cost Principles under OMB Circular A-87

(2 CFR 225) • TEA provides Side By Side Guidance


• IDEA, Part B Formula (84.027) - excess costs of providing special education and related services to children with disabilities. Special education includes specially designed instruction, at no cost to the parent, to meet the unique needs of a child with a disability, including instruction conducted in the classroom, in the home, in hospitals and institutions and in other settings, and instruction in physical education.


• IDEA, Part B Formula (84.027) - Related services include transportation and such developmental, corrective and other supportive services as may be required to assist a child with a disability to benefit from special education. Related services do not include a medical device that is surgically implanted or the replacement of such device. A portion of these funds, under conditions specified in the law, may also be used by the LEA: for services and aids that also benefit non-disabled children; for early intervening services; to establish and implement high-cost or risk-sharing funds; and for administrative case management.


• IDEA, Part B Formula (84.027) -Excess costs are those costs for the education of an elementary school or secondary school student with a disability that are in excess of the average annual per student expenditure in an LEA during the preceding school-year.


• LEAs are required to compute the minimum average amount of per pupil expenditure separately for children with disabilities in its elementary schools and for children with disabilities in its secondary schools, and not on a combination of the enrollments in both. Appendix A to 34 CFR part 300 provides detailed guidance and an example for calculating the average per pupil expenditures and the minimum average amounts that the LEA must spend before using IDEA funds


• IDEA Preschool (84.173) A LEA may use Federal funds under the Preschool Grants Program only for the costs of providing special education and related services (as described in previous slides) to children with disabilities ages three through five and, at a State’s discretion, providing a free appropriate public education to two-year-old children with disabilities who will turn three during the school year


• Ed Flex Waiver (i.e. Job Descriptions in lieu of Semi-annual certifications) does NOT apply to the Special Education Cluster

• Employees charged 100% to a federal program or cost objective must complete semi-annual certifications signed by either the employee’s direct supervisor or the employee


• For employees split-funded then time and effort must be completed at least monthly and must coincide with one pay period.

• For charter schools – all employees must completely time and effort on a monthly basis. – Reminder: charter schools follow Circular A-

122 and not A-87 like school districts

Cash Management

• Reimbursement should be requested after the entity paid for the goods/services.

• TEA allows entities to request reimbursement no more than three days in advance

• This is done through Web-ER reports

Equipment & Real Property Mgmt

• Federal guidelines – if an asset has a cost of $5,000 or greater and a useful life greater than 1 year, then it is considered a capital asset.

• For those assets received directly from the federal government, physical inventory should be taken at least every two years

• TEA requests that this be done for all capital assets purchased with federal grants


• In the past, the unit cost of the item was taken into consideration when determining if the item met the capitalization threshold. In accordance with new guidance from the United States Department of Education (USDE), a group of like items that will be housed in the same location (i.e., computers and accessories for a computer lab) are considered one unit and the aggregated cost of the items will determine if the capitalization threshold has been met.


• Software and data management systems may be coded to class object codes 6200, 6300, or 6600 depending on the specific circumstances of the transaction. The LEA should consult the Financial Accountability System Resource Guide (FASRG) or contact the Division of School Financial Audits at 512-463-9095 for guidance. Failure of the LEA to properly classify cost items may result in an unfavorable audit finding. Approval of budgeted costs on the special education grant applications pertains only to the allowability of the activity and cost and not its accounting treatment.

http://www.tea.state.tx.us/index4.aspx?id=1222


• Determine real property dispositions for the audit period and ascertain such real property acquired with Federal awards.

• For dispositions of real property acquired under Federal awards, perform procedures to verify that the non-Federal entity followed the instructions of the awarding agency, which will normally require reimbursement to the awarding agency for the Federal portion of net sales or fair market value at the time of disposition, as applicable.

Other applicable requirements

• Period of availability• Procurement and Suspension and Debarment

– $50,000 or more: follow competitive procurement method– $25,000 or more suspension and debarment– $100,000 or more (Federal awarding agency must approve contracts)

when• Awarded by noncompetitive negotiation• Awarded when only single e bid or offer was received• Awarded to other than the apparent low bidder• Specifying a “brand name” produce may require prior Federal awarding agency

approval

Earmarking

• An LEA can use not more than 15 percent of the amount of Federal funds (less any amount by which it reduces State and local expenditures under 20 USC 1413(a)(2)(C)) (See G.2.1.b. in this section), in combination with other funds for early intervening services for children in kindergarten through grade 12 who have not been identified under IDEA but need additional academic and behavioral support to succeed in the general education environment (20 USC 1413(f); 34 CFR section 300.226).

• How were the funds identified and how were they spent?

Reporting

• Financial reports are your draw down reports submitted through TEA’s Grant Expenditure Reporting (Formerly Web ER)– Do they agree to the trial balance?– Ensure that indirect cost rate used to request

reimbursement does not exceed indirect cost rate issued by TEA for entity.

– Restricted Rate must be used; TEA maximum is 8 percent; most are between 1.5 percent and 3 percent

Reporting – Special Reporting

• Report of Children and Youth with Disabilities Receiving Special Education Under Part B of the Individuals With Disabilities Education Act, as amended (OMB Nos. 1820-0030, 1820-0043, 1820-0517, 1820-0521, and 1820-0621) – Each SEA is required to report to the Secretary an unduplicated count of children with disabilities receiving special education and related services.

Reporting – Special Reporting

• Each SEA must: (1) establish procedures to be used by LEAs and other educational institutions in counting the number of children with disabilities receiving special education and related services; (2) obtain certification from each agency and institution that an unduplicated and accurate count has been made; and (3) ensure that documentation is maintained that enables the State and the Secretary to audit the accuracy of the count (34 CFR sections 300.645(a), (c), and (e)).

• LEAs must report to the SEA in accordance with the SEA-established procedure.

• Long story Shorts – PEIMS Reporting meets these requirements.

Special Tests and Provisions

• Schoolwide Programs• Access to Federal Funds for New or Significantly

Expanded Charter Schools

Maintenance of Effort (MOE)

• LEAs must maintain at least the same level of fiscal effort as it did in the previous year– E.G. In 2011, the LEA spent $100,000 in local/state special

education funds; in 2012 the LEA must spend at least $100,000

http://www.tea.state.tx.us/index2.aspx?id=214749988– The federal government wants to ensure that federal

funds are not utilized to provide services that should are normally provided with state and local funds


MOE and PIC 99

• The allocation of PIC 99 is important and must be used during the budgeting and monitoring process of MOE.

• The allocation of PIC 99 can make all of the difference• Remember that MOE is evaluating the use of state and

local funds;

MOE and Refunds

• LEAs must refund TEA an amount equal to the amount of the noncompliance. However, the amount cannot exceed the IDEA Part B maximum entitlement for the non-compliant year

• Repayment must be made from non-Federal funds or from Federal funds for which accountability to the Federal government is not required.

MOE Voluntary Reductions

• There is no benefit to reduce effort (under exceptions in one year to establish new level of effort going forward (USDE Guidance April 2011 guidance rescinded in 2012)

• Except under the following: – Voluntary Reduction Based on Flexibility Option 34

CFR Section 300.205– Allowable exceptions

MOE Voluntary Reductions (continued)

• To be eligible to reduce MOE, all three of the following criteria must be met:– The LEA must have an increase in IDEA-B Formula

entitlement from the previous year– The LEA must have a determination level of "Meets

Requirements"– The LEA cannot be identified as having significant

disproportionality under 34 CFR §300.646

MOE Reductions – 5 Allowable Exceptions

#1 The voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel. Reductions in force do not qualify as an exception;

#2 A decrease in the enrollment of children with disabilities;

MOE Reductions – 5 Allowable Exceptions (continued)

# 3 The termination of the obligation of the LEA, consistent with IDEA-B, to provide a program of special education to a particular child with a disability that is an exceptionally costly program, as determined by the TEA, because the child: a. Has left the jurisdiction of the agency; b. Has reached the age at which the obligation of the agency to provide FAPE has terminated; or c. No longer needs the program of special education;

MOE Reductions – 5 Allowable Exceptions (continued)

# 4 The termination of costly expenditures for long-term purchases, such as the acquisition of equipment; and/or

# 5 The assumption of cost by the high cost fund under 34 CFR §300.704(c). (Federal Fund 226 –high needs children)

If you are using one of these exceptions, please refer to Forms C-G provided by TEA provides districts with the guidance on what information TEA would request

TEA Forms for MOE

Special Ed FAQs

• Q7. Are reductions in force across the district that also includes RIFs in special education an allowable MOE exception? Voluntary personnel departure yes, but what about RIFs?

• A7. No. A reduction in force does not qualify as an exception pursuant to P.L. 108-446, Sec. 613(a)(2)(B)(i). Only voluntary departures and departures for just cause (i.e., involuntary termination due to dereliction of duty, etc.) are an allowable exception to the IDEA MOE requirement.

Special Ed FAQs

• Q8. We are looking at possibly not replacing staff through attrition as a possible way to meet these significant budget cuts, what impact would this have on MOE?

• A8. If special education staff resign or retire and are not subsequently replaced by the LEA, the LEA may claim an exception to MOE. A RIF does not qualify for an exception to MOE but the voluntary departure of staff would.

• Q9. If we are required to utilize 15% of our federal funds for EIS, what will be the impact on MOE?

• A9. The amount available to the LEA to reduce its fiscal effort will be reduced. In some instances, the LEA may not have an amount available to it.

In Case of a Review

• Excel and PDF file of the general ledger (actual and budget amounts)

• Detail payroll information with employee name, % paid from Special Ed and other funding sources, title

• Reconciliation between GL and Payroll Journal• Org Chart• Calculate the minimum average amount separately for

children with disabilities in its elementary schools and for children with disabilities in its secondary schools

In Case of a Review

• Coordinated Early Intervening Services (15% maximum)• Private Nonprofit Schools Participation• Policies and procedures are in place

Resources

• Special Education Funding: http://www.tea.state.tx.us/index2.aspx?id=2147493439 – Guidance on coordinated early intervening services– Guidance on Excess Costs– High Cost Fund information and instructions– Guidance on MOE– Guidance on MOE Reduction– Program Guidelines and Application Instructions– Guidance on Proportionate Share– Guidance on Schoolwide Programs– Share Services Arrangements


Business

TSCPA 2013 ISD Title 1A and IDEA B