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New Title I Coordinators Training
Title I Team
Office of Federal and State Accountability
July 16, 2015
1
Agenda• Welcome and Introductions
• ESEA Background and Purpose, ESEA Waivers
• District Set-Asides
• Schoolwide Plans
• Supplement, Not Supplant
• Allowable Use of Funds2
AgendaAccounting and Reporting Amendments,
Carryover and Other Fiscal Responsibilities
Comparability Report
Maintenance of Effort (MOE) Monitoring
Private Schools
Grants Accounting Processing System (GAPS)
Q & A Session
3
WELCOME AND INTRODUCTIONS
Roy StehleDirector of Federal and State Accountability
4
ESEA BACKGROUND AND PURPOSEELEMENTARY AND SECONDARY EDUCATION ACT OF 1965
Roy StehleDirector of Federal and State Accountability
5
Title I• Title I is the first title in the ESEA of 1965 as
reauthorized as the NCLB Act of 2001.
• Title I is the largest federal aid program for K-12 schools.
• The purpose is to ensure that all students have a fair, equal, and significant opportunity to obtain a high-quality education and reach, at a minimum, proficiency on challenging state academic achievement standards and assessments. 6
Title I• South Carolina receives over $200 million in Title I
funds.
• The vast majority of funds are allocated to districts, and through districts, to schools.
• Title I is designed to support state and local school reform efforts.
• Title I is designed to support teaching and learning for students who are most at risk of not meeting state standards.
7
Title I• Title I Coordinators have a major responsibility to
see that the funds that flow to the districts are used for the educational purposes intended in the law.
• Title I Coordinators have a major role in overseeing that the funds are spent to be in compliance with applicable law, regulations, and guidance.
• Title I Coordinators need to be well versed in both program and compliance. 8
Title I• Title I Coordinators need to be up to date on the
latest in education reform efforts and to understand curriculum and instruction.
• Title I Coordinators need to know the law, the regulations, and guidance related to Title I.
• Title I Coordinators also need to be familiar with EDGAR (Education Department General Administrative Regulations).
9
Title I Tips to survive:
• Learn federal programs from multiple perspectives.• Evaluate your program activities.• Understand and control your budgets.• Tap outside resources.• Train your staff and those you work with.• Be visible – be the Title I expert.• Seek help from veterans.• Work with your SEA staff.
10
Questions
11
ESEA FLEXIBILITY WAIVER UPDATE
Roy StehleDirector of Federal and State Accountability
12
ESEA Flexibility Waiver Update
Since reauthorization of ESEA was not on the horizon, the purpose of the waiver was to relieve the SEA’s and LEA’s of the burden of the “all or nothing” accountability of the NCLB Act of 2001 and to allow states and locals to design reforms to improve academic achievement and to increase the quality of instruction for all students.
What did SEA’s and LEA’s gain?• Flexibility regarding the 2013-14 accountability timeline
for determining AYP.• Flexibility regarding district and school improvement
requirements.• Flexibility to support school improvement efforts.• Other additional flexibilities were permitted.
13
ESEA Flexibility Waiver Update
What S.C. agreed to do:
In Principle 1: College and Career Ready Expectations for All Students
In Principle 2: State-Developed Differentiated Recognition, Accountability, and Support
In Principle 3: Support of Effective Instruction and Leadership 14
ESEA Flexibility Waiver Update• The S.C. waiver request was submitted and
approved by the U.S. Department of Education in 2012.
• The waiver has been renewed through 2017-18.
• Several amendments have been made to Principle 1, Principle 2 and Principle 3.
• Accountability was run on the waiver methodology for the spring 2012, 2013, and 2014 testing with districts and schools receiving a letter grade A-F.
15
ESEA Flexibility Waiver Update
• The current renewal is subject to meeting the commitments and timelines as submitted in the current version of the SC ESEA Waiver as approved by the USED.
• SC has college and career ready state standards in ELA and math.
• SC is procuring a test aligned with the state standards.
• School and district ratings are paused for one year.
16
ESEA Flexibility Waiver Update
• Student performance will be reported based on the spring 2015 tests.
• No new Priority or Focus Schools will be identified based on the spring 2015 testing.
• Assistance and support for Priority and Focus schools remains a work in progress.
• Title I Public School Choice and Supplemental Educational Services no longer are offered.
• Student growth remains as a component of the Teacher and Principal evaluation systems.
17
What the Future Holds
• ESEA reauthorization has been taken up (again) in Congress.
• There are two House bills and one Senate bill (Every Child Achieves Act).
• The Administration has its Blueprint Proposal.
• Once reauthorization becomes law, SC would transition from the ESEA Flexibility Waiver to the new ESEA.
18
Questions
19
DISTRICT SET-ASIDES
Jewell Stanley Title I, Team Lead
20
What are District Set-Asides?
Definition:Reservations for district-wide activities that are taken from the current year Title I allocation prior to distributing funds to schools.
21
Types of District Set-Asides
Required Set-Asides:1. Parent Involvement - One percent (1%) of the current year allocation must be reserved (if current allocation is $500,000 or more). • Ninety-five (95) percent of the 1% for Parent
Involvement must be allocated to Title I schools.
2. Homeless - District must set aside funds for homeless (no pre-determined percentage is required).
22
Required set-asides (cont.):
3. Highly Qualified (HQ) Professional Development - A district whose teachers are not all HQ must set-aside funds (as needed) for professional development to obtain HQ status.
**Other funds, such as Title II, may be used to meet this requirement (Listed separately on Page 2-C).
23
Non-required Set-Asides:
1. LEA Administration: Used for funding administrative staff, supplies, equipment, travel, etc. at the district level for Title I administrative purposes.
2. Other – Summer school, pre-school programs, intersession programs, additional professional development, school improvement, etc.).
* Activities must be in Title I schools only, except pre-school programs.
24
Page 2-C “District Set-Asides"
• Reflects:District’s total requested amount Minus district’s set-asides Equals the amount available to allocate to schools.
25
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District Set-AsidesPage 2-C Addendum
• Purpose of the addendum is to explain the activities and uses of funds for the various set-asides and to attest that supplanting is not evident.
• Adequate details that specifically explain the requested use of funds must be provided in the activities column.• Remember, the plan is available to the public so
be specific enough to justify the use of funds and put the amount into context. 27
28
District set-asides (Instructional Programs)
If the district is reserving funds to provide instructional and related activities for Title I schools or professional development for teachers or paraprofessionals it must also provide from those funds equitable services to eligible private school children. (Examples of activities: parental involvement, professional development, summer school.)
29
Because the reservation of funds by an LEA will reduce the funds available for distribution to participating areas and schools, the LEA must consult with teachers, pupil services personnel (where appropriate), principals, and parents of children in participating schools in determining, as a part of the LEA plan, what reservations are needed.
This issue must also be a part of the consultation with private school officials before an LEA makes any decisions regarding these reservations.
30
Remember that poverty is the only factor on which a district may determine funding. In other words, an LEA may not allocate funds based on the instructional model, educational need, or any other non-poverty factor.
31
Supplemental District Set-asides
Guiding principles- All plans should be examined to determine if supplement, not supplant will be violated.• Activities, programs or interventions should be
examined to see if they fit best in a school allocation or as a district set-aside. • Have rationale or justification for placing the
funding for programs, activities, or interventions in a district set-aside instead of allocating funds directly to the schools. 32
Supplemental District Set-asides
• USED monitoring of states has resulted in findings of district set-asides where funds were used or distributed to schools without regard to poverty or per pupil allocation (PPA).
33
Supplemental District Set-asides
• Rationale for set asides should be apparent. (Examples- LEA Administration, district sponsored Title I summer school program held at one site serving several schools, Pre-K).
• Note: If the district is serving private schools then these schools need to be consulted as well when planning supplemental set-asides.
34
Supplemental District Set-asides
• Set-asides for the purchase of supplies and technology without being tied to an allowable activity, program, or intervention are not allowable.
35
Supplemental District Set-asides
Examples of Allowable District Set-Asides:• LEA administration including indirect cost• Preschool programs• Parent Involvement above the 1%• Specific program strategies at Title I schools• District wide staff to work at Title I schools • Supplemental nurses/social workers• District interventions at Title I schools that are
“Focus”, “Priority” or by Federal Accountability Grade, such as schools earning a “D” or “F” rating
36
Supplemental District Set-asides
Examples of Allowable District Set-Asides:• Job Embedded PD (Instructional Coaches
for example) at Title I schools or subset of Title I schools with identified needs• Extended learning time for Title I schools
37
Questions
38
SCHOOLWIDE PLANS
Jewell Stanley Title I, Team Lead
39
TWO TYPES OF TITLE I PROGRAMS• Targeted Assistance• Supplemental education services to eligible
students with the greatest need.
• Schoolwide• Comprehensive program designed to upgrade
the entire educational program in order to improve achievement of the lowest-achieving students.
• a school with poverty percentage of 40% or more.
40
SCHOOLWIDE PROGRAMS• Maximize flexibility in using Federal funds.
• Serve as a vehicle for whole-school reform with focus on improving achievement of lowest-achieving students.
• Allow for easier leveraging of non-Federal and Federal funds to work together to improve educational performance of the entire school.
• Address student needs through a schoolwide plan based on a comprehensive needs assessment.
41
SCHOOLWIDE PROGRAMS1. Comprehensive needs assessment of entire school
2. Comprehensive schoolwide plana. Incorporates whole school reform strategies that--
i. Strengthen the core academic program ii. Increase the amount of quality learning time to help provide enriched and accelerated curriculum iii. Meet the needs of historically underserved students iv. Provide services the meet the needs of low-achieving students
b. Focuses on ensuring Highly Qualified Teachers in schoolsc. Incorporates high-quality ongoing professional developmentd. Identifies strategies to attract Highly Qualified Teachers
42
SCHOOLWIDE PROGRAMS• e. Incorporates parent engagement strategies
• f. Assists pre-school children transition to elementary school
• g. Includes teachers in Data-Driven Decision-making
• h. Provides low-achieving students with effective, timely additional assistance
• i. Focuses on the coordination and integration of funds
3. Annual evaluation, with revisions as necessary43
SCHOOLWIDE PROGRAMS• Title I, Part A funds may be used for any activity that supports the needs
of students, particularly the lowest achieving students, in the school that are identified through a comprehensive needs assessment and included in the schoolwide plan.
Will the proposed use of funds:• Drive results for students who are failing or at risk for failing state
achievement standards?• Increase meaningful professional development?• Accelerate reform?• Foster continuous improvement and evaluate activities to modify or
discontinue?
44
SCHOOLWIDE PROGRAMSKey Requirements include:• Supplement not supplant requirements are different for targeted assistance schools and schoolwides. Title I schoolwides must receive their fair share of local and state general funds.
• Necessary and reasonable to accomplish the purposes of Title I.
• Use of Title I funds should always be consistent with the program requirements and the general uses of federal funds. 45
SCHOOLWIDE PROGRAMSTitle I Use of Funds in a Schoolwide Plan – Examples • Increase participation of low-achieving students in advanced coursework.• Provide intensive summer school classes for low-achieving students, including high school students to prepare them for the rigor of taking advanced courses.• Provide afterschool tutoring.• Develop and use formative and interim assessments to track progress of low-achieving students and train teachers in their use.• Purchase or develop supplemental instructional materials aimed at improving achievement of low-achieving students, including Student with Disabilities and English Learners. 46
SCHOOLWIDE PROGRAMSTitle I Use of Funds in a Schoolwide Plan – Examples
• Conduct needs assessments
• Upgrade the curriculum for the entire school
• Implement an early warning system to identify low-achieving students or
students at risk of dropping out
• Extend the school day or school year
• Reorganize class schedules to increase teacher planning time
• Revamp the school’s discipline process to improve achievement of low-
achieving students
• Hire additional teachers to serve Title I students
• Hire specialist to coach teachers in how to better serve low achieving
students
47
SCHOOLWIDE PROGRAMSTitle I Use of Funds in a Schoolwide Plan – Examples
• Reorganize classes to promote personalized learning for low achieving students• Implement career academies to assist low-performing students prepare for college and careers• Implement school safety programs to improve the achievement of low-achieving students• Provide professional development to ensure effective teachers and leaders to serve low-achieving students• Engage in activities to improve school climate designed to improve the achievement of low-achieving students
48
SCHOOLWIDE PROGRAMSTitle I Use of Funds in a Schoolwide Plan – Examples Turning Around Low-Achieving Title I Schools • Implementing rigorous interventions to turn around low-
achieving schools• Assessing strengths and weaknesses of school leaders,
teachers, and other school staff• Recruiting principals• Screening and identifying external partners• Multipronged strategies for changing school’s culture and
improving teaching and learning49
Questions
50
SUPPLEMENT, NOT SUPPLANT
Roy StehleDirector of Federal and State Accountability 51
Supplement, Not Supplant
According to federal guidance:
LEAs may use Title I funds only to supplement or increase the level of funds that would, in the absence of Title I funds, be made available from non-federal sources for the education of students participating in Title I programs.
52
Supplement, Not Supplant ~In plain language - Please~• Another way to look at supplement, not supplant is to ask
the question - what would districts and schools be required to offer in the absence of any federal funding? For example – the state required Defined Minimum Program for elementary schools.
• Title I funds (and most federal funds) should be used in addition to state and/or local funding and not in the place of state or local funding.
• Title I funds should not be used to meet other federal requirements (Title III, IDEA, etc.) 53
How to Determine if Activities are Supplemental
• Testing for Presumptions of Supplanting:• Is it required by the state, district, or
federal statute or regulation?• Are the same services provided for in non-
Title I schools or students with (non-supplemental) state/local funds?•Were these activities paid for in prior years
with state/local funds?54
Other Questions to Consider • Are the Title I schools receiving similar
services provided for by state/local funding as non-Title schools?• Are Title I schools receiving their “fair
share”?• Are the Title I schools being treated
comparably (similar positions, technology, etc.)?
55
Supplanting Defense/Rebuttals• Similar activity is funded in a non-Title school with
supplemental funding, such as:• State At-Risk Funding• Discretionary Grant• Possibly, other funds that all schools are not
eligible • This is generally known as the “exclusion” rule
to supplement, not supplant.• An example might be an afterschool program
funded with Title I funds at Title I schools and funded with state At Risk funding at non Title I schools.
56
Supplanting Defense/Rebuttals
• Activities funded in prior year with state/local funds• However, the state/local funds used to pay for
activities were reduced/eliminated and during budget prioritization the activities are to be eliminated• Document in Board agendas, minutes, etc.• Document via directives from the state (funding
levels, allocations, etc.)• Budget reports/meetings 57
Supplanting Defense/Rebuttals• Activities required by local, state, or federal
statute• This presumption of supplanting is almost
always not rebuttable. It is presumed that in the absence of federal funding, the district/school would be required to do the activity anyway.• Basic ESOL programs would be a good example of
a program that districts would have to provide in the absence of any federal funding.
58
Supplemental Title I Activities
• Common supplemental uses of Title I funds:• Decreasing class size (below state requirements)• Providing extra supplies/materials• Providing additional professional development• Extending learning time (before/after school or
summer school)• Funding extra support services - nurses, guidance
counselors, etc.Always call your Title I Program Contact to get an opinion on supplement, not supplant issues.
59
Questions
60
ALLOWABLE USE OF FUNDS
Jewell StanleyTitle I, Team Lead
61
Allowable Use of FundsLevels of Complexity:• 2 CFR Part 200– Basic allowability
• EDGAR Part 76 – General allowability for the USED
• ESEA Law and Regulations
• ESEA Program Guidance
• USED Policy Letters 62
2 CFR Part 200(200.403)To be allowable, a cost must generally:a.) be necessary and reasonable for the performance of the Federal award and allocable thereto under these principals
63
2 CFR Part 200
b.) Conform to any limitations or exclusion set forth in these principals or in the Federal award as to types or amounts of cost items;
c.) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
64
OMB Uniform Guidance Cost Principles
d.) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.e.)Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments. 65
OMB Uniform Guidance Cost Principles
f.) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either current or a prior period.g.) Be adequately documented.
66
Allowable vs Non-allowable
Allowable Non- allowable
• Salaries and Benefits (teacher to reduce class size or to provide remediation services)
• Professional Development (Conference attendance or brining in a speaker or consultant)
• Instructional Supplies and Materials (purchasing supplemental reading or math programs; books for PLCs
• Family Engagement Activities• Extended Day Programs
• Entertainment Costs (including amusement, social activities, and ceremonials and any associated costs )
• Field Trips (amusement parks; fairs)
• Gift Certificates/Gift Cards• Student Incentives **
(exceeding 1% of allocation)
** Student incentives are best placed in the Title I Schoolwide Regular Plan.
67
Allowable Costs
In deciding whether a cost is allowable, you need to decide if it fits the grant program.• Do your homework as not everyone you talk
to will have the “right” answer. • Look at flexibility as what you want to do may
not fit one grant program but may fit another program. • Be able to “defend” your position and your
decision. 68
When determining if expenditures are appropriate, ask the following questions:
• How does this expenditure directly support student achievement for at risk students?
• How does this expenditure directly support meaningful professional development?
69
When determining if expenditures are appropriate, ask the following questions:
• How does this expenditure increase the participation of parents in school activities or assist parents to support student achievement?
• How does this expenditure foster continuous improvement and evaluate activities to modify or discontinue?
70
Allowable Costs
• There is no single list of allowable Title I or ESEA activities.
• The most inclusive guidance is the Title I Use of ARRA Funds Guidance from September 2009.
• Check with your district’s policies. District policies can be more restrictive than Title I regarding allowability. 71
Allowable Costs
If you are unsure about the whether a cost is allowable – always check with your Finance Department and your Title I Program Manager (SCDE).
72
Questions
73
Time for Lunch ! 74
ACCOUNTING & REPORTING
Karen CookEducation Associate
75
Federal Accounting Requirements
• LEA can not hinder the preparation of required reports• LEA must track expenditures to a level of
detail that demonstrates compliance
76
Financial Management Standards
• Accurate, current, complete disclosure of activities
• Maintain adequate records to identify source and execution of the plan• Award letters• Authorizing statute• Budgets (obligated, unobligated)• Revenues/Expenditures
77
Financial Management Standards
• Accountability of cash/property
• Ensure use of supplies/equipment for authorized purposes
• Budget to actual expenditure comparisons
78
Budgeting• To ensure adequate fiscal control, recipients of
federal funds must establish a categorical summary by “line item” for each project budget.
• Title I project budget period• July 1st – June 30th
79
80
Budget Obligations
• Obligations - orders placed, contracts awarded, and goods/services received but not paid for during the project period
• Amendments must be approved prior to making obligations or incurring expenditures
• Earliest date for obligations is July 1st and an approvable project is submitted
• Deadline for obligations is June 30th
81
Reminders
• No cash advances are sent to an LEA
• LEA expenditures are reimbursed by reporting actual expenditures in the Grants Accounting Processing System (GAPS)
• Final expenditure reports due approximately August 15th
82
Questions
83
BUDGET AMENDMENT PROCESS
Karen CookEducation Associate
84
When to Submit Budget Amendments
• Required:• Increasing/Decreasing overall funding • Adjustments to allocations after project has
been approved or to adjust carry over
• Change in the scope of activities
85
Types of Budget Amendments
• Correcting account coding
• Previously used incorrect function/object codes
• Increasing/decreasing budget in existing
activities to adjust projections to meet actual need
• Adding new activities to the district or Title I
schools
86
Budget Amendment Components
• Required Components of Budget Amendments:• Budget Narrative • (e-mail, letter, pages from the online application)
• Make appropriate changes in GAPS• To show increases/(decreases) by function/object
code
87
Budget Narrative• Explains where the shifts occur • Where moving funds from/to• Explanation of the proposed use of funds
• If at district level• Which district set-aside?
• If at school Level• Which school(s)?• Type of strategy • Activity description detail 88
Budget Narrative Detail• Explanation of the services/activities funded by
the shift• Provide same level of detail as required during
project submission
• How are activities supplemental?• Detailed description of activity• CSR (student/teacher ratio before and after applying Title I)• Types of positions funded/position title, # FTE’s• Brief examples of types supplies/materials to be purchased • Estimation of projected number of items/unit cost for large
purchases, such as for large technology purchases89
Budget Narrative Pointers• If only correcting account coding• Only need to state why previous function/object code was
inappropriate and the new codes. State that “there are no changes in the scope of services or funding of activities previously requested”.
• Emphasize whether it is increasing/expanding an existing activity or funding a new activity• Less detail required if adding budget to previously approved
activities, but describe activity being increased and need for additional funding
• More detail needed for entirely new activities to demonstrate allowability and how the activities are supplemental 90
Increase Turn Around for Budget Amendment Approval• Contact project manager prior to the shift for assistance with
allowability, compliance, and level of detail needed for narrative• Provide sufficient narrative detail• Work with district project accountant/budget analyst• To ensure previous amendments and expenditures are taken into
consideration• Include all components of the amendment• Project number, account coding, and narrative
• E-mail the request • Please do not submit multiple copies or submit to Finance first• Only submit to assigned project manager• Input into the online application• Submit by the superintendent• Make appropriate changes in GAPS
91
Questions
92
CARRYOVER & OTHERFISCAL RESPONSIBILITIES
Karen CookEducation Associate
93
Title I Carryover
• Title I has a 15% carryover limitation of LEA’s current year allocation
• An LEA may apply for a waiver to exceed the limitation• However, this may only be granted once every three
years
94
Records Retention
• According to EDGAR – records are to be retained for three years after the final closeout report
• Or, until outstanding litigation, claims, negotiation, or audits are resolved
95
Time & Effort Records
• Staff paid from a single federal award:
• Do not need time sheets• Must be documented by semi-annual
certification signed by employee and supervisor
96
97
Time & Effort Records
• Staff paid from multiple funds (multiple federal or combination of federal/state funds):
• Salaries/benefits must be supported by a monthly time sheet
• Unless in a schoolwide plan and employee works on one single cost objective, such as a teacher or parent liaison.• In this case, only a semi-annual certification is needed• master schedule collected and signed monthly by the
supervisor can be used for additional support
98
99
100
Questions
101
COMPARABILITY
David BoisonEducation Associate
102
Comparability
•Comparability means FAIRNESS
•Required by NCLB, Section 1120A(c)
103
Comparability
•Required every year you receive Title I funding•Unless: one school per grade span•Or: One large school and one small
school
104
Comparability
•Complete by NOVEMBER 15
•Comparable by JANUARY 15
105
Comparability
Federal criteria:•District-wide salary schedule•District policy to ensure equivalence
of staff•District policy to ensure equivalence
in materials and supplies•Assurance # 27!!!
106
Comparability
Federal criteria (continued)• Test• SDE picks the test• In SC the test = student:teacher
107
Comparability
• If student:teacher ratio does not work:•Adjust funding source•Move people•Use another method (contact
SCDE first)108
Comparability
PROCEDURE:•Must count students and teachers ON SAME
DAY!• Compare Title I schools by grade spans you
serve• Compare non-Title I to Title I schools or • If all Title I schools, compare least poor to
most poor 109
Comparability
PROCEDURE: (continued)• Count students using districts ADM
program• Count allowed staff using best possible
system (ex. personnel or finance)• Do not count 3 or 4 year olds
110
Comparability
PROCEDURE: (continued)• Source data must be verifiable by auditor• Social security numbers and salaries are not
needed• A K-8 school can be counted as one K-5 and one
6-8 school• A K-2, 3-5 or similar school can be excluded if
only one in district
111
Comparability
PROCEDURE: (continued)•Use SCDE form
or•District produced form (as long as all
information is included)
112
Questions
113
Karen CookEducation Associate
Maintenance of Effort
114
What is MOE?
•Maintenance of Effort (MOE) is a federal requirement that requires grant recipients and/or sub-recipients to maintain a certain level of state/local fiscal effort to be eligible for full participation in federal grant funding.
115
The Underlying Principle
• The district is responsible for maintaining effort in providing a free public education to all students from year to year.
• Title I is in addition to the required education that all students receive.
116
Purpose
• To ensure the recipient of federal funds does not spend those funds in place of state and local dollars
• To ensure the recipient spends their state and local funds for the same activities that would be provided if federal dollars were not available
117
“Meeting” MOE
• MOE is based on the two previous years
• Districts meet MOE for 2015 - 2016 if:
• 2014 state/local effort = is at least 90% of 2013
• For example:
MOE for 2013: $7,305.50
90% of $7,305.50 = $6,574.95
MOE for 2014: $7,246.03
$7,246.03 > $6,574.95 so MOE has been met 118
Step 1:Preceding Year Audit Report Total Expenditures:(Refer to the audited Location Reconciliation Schedule) $ 15,200,000
Step 2:Items Subtracted From Total Expenditures in Step 1:(List page number for each data source from Audit Report.)Federal Expenditures (SEFA) Page $595,000 Capital Outlay (Attach Report) 170,000.00 Debt Service Page 73,500.00 Community Services Page 1,600.00 Pupil Activity Fund Page 45,000.00 Intergovernmental Page 9,800.00 Total Amount Excluded: $ (894,900.00)
Total Expenditures for MOE Calculation: $ 14,305,100.00
Step 3:135 ADM: 2,105
The per pupil MOE calculated for the preceding yearfrom Audit Year 2014 : $ 6,795.77
Step 4:The per pupil MOE calculated for the second preceding yearfrom Audit Year 2013 : (Attach Worksheet) $ 6,576.98
Met MOE Requirements? * Met MOE
*Compare the per pupil MOE in step 3 to the per pupil MOE of step 4. The per pupil amount in step 3must be not less than ninety percent of the per pupil amount in step 4 to meet the MOE requirement.
119
Note:
• SEA must determine maintenance of effort most favorable to each LEA.
• Allocation reduction if an LEA fails to meet the MOE requirement
• The state has no authority to waive the MOE requirement. ED may waive the requirement for:• exceptional or uncontrollable circumstances, such as natural disaster• a precipitous and unforeseen decline in the financial resources of
the State120
Due to state/local budget reductions, meeting the MOE 90% requirement may be much more
difficult to achieve!!!
Coordinate with district financial staff and the Office of Federal and State Accountability to
prepare!!!
Karen Cook803-734-4040
Questions
122
15 Minutes
123
Title I Monitoring
David BoisonEducation Associate 124
How to Survive a Title I Audit
• The Audit Forms•Organizing for the Audit• The Audit•Common Problem Areas•Helpful Hints•Help is Available 125
The Audit Forms• Eleven Forms:
1. Project Administration 2. Parent Involvement 3. Schoolwide Projects 4. Targeted Assistance Projects 5. District Improvement 6. School Improvement 7. Supportive Services
8. Equipment and Inventory Control 9. Private School Services10. Budget Monitoring11. Internal Controls
126
The Audit Forms (cont.)
• Questions are from Title I requirements• Copies of forms are sent before the audit• Not all forms may be used• Not all questions may apply • Documentation and evidence are usually
required• Help is available
127
Organizing for the Audit
• Determine what forms will be used at your district• Prepare a folder for each form• Collect documentation• Use binder or box to organize folders
128
The Audit
• Starts at 8:30am @ D.O.• 8:30-12:00: work done at D.O.• Break for lunch• 1:00: Visit School(s)• 4:00pm: Audit completed
Note: times are approximate129
Common Problem Areas
• 135 ADM•March F&R lunch count (SNACS report)• Counting 3 and/or 4 year olds•Math errors• Rounding errors• Banding errors• Time and Attendance Records
130
Common Problem Areas (cont.)
• Private school contact• Principal’s attestation letter• Parents Right to Know• Comparability (if required)•Maintenance of Effort• Parent Involvement Policy• Parent-School Compact
131
Common Problem Areas (cont.)
• Survey/evaluation of parent involvement programs• Targeted assistance student selection
process• Documenting meetings (agenda, sign-in
sheet and minutes)• Getting schools on-board• Offering parents all that is required by
Title I• Inventory control
132
Helpful Hints• Have a Title I meeting at the beginning of
the school year• Use newsletters, newspaper and web to
communicate Title I requirements to parents• Document Title I meetings• Find a helper (parent coordinator, Title I
facilitator, etc.)• Have a binder or box for documentation to
use throughout the year
133
Questions
134
Help is AvailableContact:
David BoisonEducation Associate
Review guidance: www.ed.sc.gov under Title I
135
Private SchoolsParticipation in Title I of Children Enrolled in Private Schools
David BoisonEducation Associate
136
Eligibility
• Private school children, parents and teachers, by law, may be eligible for Title I services (section 1120 of ESEA)• Student resides in a Title I attendance area• Student is failing or at risk of failure at school• Services are equitable• Services are secular, neutral and non-ideological• Money determined by low income students• Students served determined by attendance area
and educational need (NOT by poverty).137
Contact and Consultation• LEA contacts private schools (when: March;
where: in and/or outside of district: “25 mile rule”, use lists of privates schools in area; how: certified mail) soliciting participation in Title I• Private school, if eligible, decides to participate or
not • Invite private school to consultation meeting• LEA and private school cooperate on services• LEA administers and evaluates the program• See guidance re: consultation requirements
(guidance is on SCDE website: “Title I Service to Eligible Private School Children (Non-Regulatory Guidance”)
138
Planning• Planning meeting with private school before
start of program (March/April for following school year)• Private school to sign affirmation form that
consultation took place (affirmation form is in Title I on-line application)• Affirmation obtained by LEA and provided to
SEA139
Equitable Services• Services to private schools must be equitable when
compared to services provided to public schools.• Equitable services are proportionate to number of eligible
students at the private school.• Equitable services include district set-asides for student
instructional programs, parent involvement activities, professional development and summer school, if applicable.• Equitable services do not include pre-K, district
improvement, supplemental services or school choice.• Program at the private school is a district program.
Materials, supplies, personnel etc., are the responsibility of the LEA. (No Title I funds are given directly to the private school)
140
Determining Eligible Students• Data needed: student’s address, student’s grade
level, income level of parents.
• LEA calculates eligible students by one of these methods:• using same measure of poverty as LEA• using comparable data to the USDA free/reduced
program• extrapolating data if data from private school is
incomplete• proportionality based on the public school the students
at the private school would have attended141
Funding a Private School Program• Funding a private school utilizes two sources of
money: 1. Per pupil allocation and 2. Equitable services
• The amount allocated for the private school’s program is based on the per pupil allocation generated by eligible private school children (see page 2D of the Title I application).
• If there are more than one served private school in the district the amount per school is based on the eligible students attendance area (they carry their per pupil allocation by attendance area with them to the private school). 142
Funding a Private School Program(continued)
• The amount allocated for the private school’s equitable services (instructional set asides, parent involvement and professional development) is based on proportionality, that is, the proportion of private school children from low income families who would have attended a public Title I school divided by the number of children from low income families in public and private schools participating in Title I • See the Equitable Services Worksheet in the
Title I on-line application (page 22) 143
Application Approval• LEA should maintain record of consultation with
private school• LEA maintains record of minutes of meetings,
written correspondence, parent surveys etc.• Consultation should take place before important
decisions are made on the design and implementation of the program• SEA to obtain copy of affirmation form, equitable
services worksheet and copy of private school plan• Complete Title I on-line application for private
schools 144
Children Eligible for Services
Eligibility for private school services is based on:• Residence in a Title I public school attendance
area• Educational need (child must meet
requirements of section 1115(b) of ESEA [targeted assistance criteria])
Poverty is not a criteria
145
Administrative Costs
• LEA may reserve funds “off the top” to administer public or private school Title I programs• This money is not taken from the amount allocated
to private schools• Funds for instructional services are allocated after
“off the top” deductions are made• Admin. costs include special capital expenses (non-
instructional services such as insurance, maintenance, purchase or lease of real or personal property, installation, etc.)
146
Questions
147
Grants Accounting Processing System (GAPS)
Karen CookEducation Associate 148
(Grant Title Specific) Coordinator(Grant Title Specific) FinanceGrant Accounting Finance Approver
Assigned by Web Access Coordinator within the District - please do not forward to SCDE
Roles
149
Budget ProcessDistrict Program
Coordinator Submits Online Application and Loads Budget into GAPS
District Finance Office Approves Budget in GAPS
OFSA Project Coordinator
Approves Online Application
OFSA Team Leader Approves Online
Application
OFSA Director Approves Online
Application
OFSA Team Leader Approves Budget in
GAPS
District May Begin to File Expenditure
Claims
150
8/15/15 – Last Day for Entry/Submission of June 30, 2015 Expenditures
Final report date shown in GAPS – Last Day for that sub grant to have expenditure reports submitted
Deadline
151
Training• Online Video presentations• Can be viewed at any time • Available online for future reference.
http://www.ed.sc.gov/agency/cfo/finance/Grants-Accounting/
Monthly Newsletter – Please read for updates http://www.ed.sc.gov/agency/cfo/finance/Financial-Services/ 152
Questions?
153
Questionsand
Answers Session
154
