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NEW YORK STATEEDUCATION
DEPARTMENT
FY15-16 Federal Charter Schools Program (CSP)Continuation OrientationMay 19, 2015
Today’s Audience
Representatives from schools that are completing the planning phase of the CSP grant and want to understand the implementation phase (also referred to as continuation phase).
Consultants assisting charter schools with completing documents to access CSP implementation grant funds.
What is the CSP Grant?
The New York State Education Department received a five year Federal Charter Schools Program (CSP) grant that runs from 2011-2016.
Funding is under Title V, Part B of the No Child Left Behind Act of 2001 (NCLB)
The primary purpose of the grant is to award sub-grants for charter school planning, program design and initial implementation
Amount of CSP Funds
NYS Allocation Amounts:
$500,000 base amount, max amount of $750,000 Underserved Student Population Priority will increase
award to $625,000 (determined after Year 1) Meeting Program Authorizer Design Priority will increase
award to $750,000 (determined at application) CSP Grantees cannot receive both incentives, as it would
push award past $750,000 max amount
CSP Grant Web Help
The CSP general grant webpage is located at:http://www.p12.nysed.gov/psc/grants.html
2015-16 CSP Continuation Funding is located at: http://www.p12.nysed.gov/psc/funding/1415contapp.html
http://www.p12.nysed.gov/psc/documents/nonregguidance.doc (204 KB) provides information regarding various provisions of the CSP Grant.
Guidance on Internal Controls for grants can be found on pg. 52 – The Fiscal Oversight Guidebook The New EDGAR webinar slides and recording featuring Tiffany Winters, Esq.,
from Brustein and Manasevit, PLLC can be found at: http://www.p12.nysed.gov/psc/
Three Budget Periods
CSP grant funds can be used for up to 36 months within three budget periods: up to 18 months of planning (generally budget period 1)
up to 24 months of implementation/continuation (generally budget periods 2 & 3)
Budget Periods: Example 1
Master contract with dates from 1/1/13 – 8/31/15 is divided into three budget periods.
Planning Phase (before school opens, up to 18 months):
Budget period 1 might be from 1/1/13 – 8/31/13
School Opened 9/1/13 that begins receiving per-pupil funding on 7/1/13
Implementation Phase (up to 24 months):
Budget period 2 would be from 9/1/13 – 8/31/14
Budget period 3 would be from 9/1/14 – 8/31/15
Budget Periods: Example 2
A master contract with dates from 1/1/14 – 8/31/16 is divided into three budget periods.
Planning Phase (before school opens):
Budget period 1 might be from 1/1/14 – 08/31/14
School Opened 9/1/14 that begins receiving per-pupil funding on 7/1/14
Implementation Phase (24 months):
Budget period 2 would be from 9/1/14 to 8/31/15
Budget period 3 would be from 9/1/15 to 8/31/16
Budget Periods: Example 3
A master contract with dates from: 7/1/14 - 6/30/17
11/1/14 - 6/30/17
12/16/14 - 6/30/17
Are divided into three budget periods.
Planning Phase (before school opens):
Budget period 1 might be from 12/16/14 – 06/30/15
School Opening on 9/1/15 that begins receiving per-pupil funding on 7/1/14
Implementation Phase (24 months):
Budget period 2 would be from 7/1/15 to 6/30/16
Budget period 3 would be from 7/1/16 to 6/30/17
Planning vs. Implementation
Can be up to 18 months long prior to opening doors
Allowable expenditures include: Salaries for Staff Purchased Services Supplies & Materials Equipment Purchases Travel Expenses Rent
Can be up to 24 months long and span the first two years of operation
Allowable expenditures include: Purchased Services Supplies & Materials Equipment Purchases Travel Expenses
Planning Phase(Budget Period 1)
Implementation/Continuation Phase
(Budget Period 2 & 3)
Allowability
As a general matter, costs must be:
Reasonable Necessary Allocable to meet the objectives of the grant
Power Point Slides on Allowability and Grants Management:
Allowable Initial Implementation Expenditures
For initial implementation of the charter school,expenditures can be made for:
• Informing the community about the school, • Acquiring necessary equipment and educational materials and
supplies, • Acquiring or developing curriculum materials, and • Other initial operating costs that cannot be met from State or
local sources (per supplement, not supplant requirement)
*Note: July 1 is the date charters begin receiving per pupil funding from Districts. After July 1 CSP funds may not be used for costs met from State or local sources, such as rent or teacher salaries. This prevents violating the ‘supplement not supplant’ requirement for Federal grant funds. Typically we begin budget year 2 (first implementation period) on July 1 to coincide with the receipt of per pupil funding.
Allowable Continuation CSP Expenditures
Refinement of the desired educational results and of the method for the measuring progress towards achieving those results
Professional development of teachers and other staff who will work in the charter school
Acquiring necessary equipment, educational materials and supplies
Acquiring or developing curriculum materials
And any other operating costs to begin a charter school that cannot be met from state or local sources
For Budget Periods 2 and 3 be aware of ‘supplement, not supplant’ requirement.
Professional/Support Staff Salaries
Salaries for professional and support staff are a permissible expenditure for CSP funds during the Planning phase
Once your school begins to per-pupil funding from school districts (July 1 of first year of operation), CSP funds may not be used to fund salaries or any other item that should be paid for with state or local funding. This is referred to as the ”supplement, not supplant” federal requirement, as outlined in the CSP Nonregulatory Guidance (section D-3, page 15).
Salaries are generally not permissible expenditures during the Implementation phase, unless they fund personnel splitting time between ongoing operational activities and initial implementation activities.
Only the portion of time related to initial implementation (i.e. curriculum development and recruitment of students for future grades) may be funded with CSP.
The charter school must maintain accurate time and effort records to document the amount of time each employee works on tasks related to initial implementation.
Purchased Services
CSP Funds may be used to contract with vendors to provide certain services necessary to both the planning and implementation of services:
Professional Development Board of Trustee training Accounting and Financial Management
Expenditures associated with these services should be reported with specific details on pricing structure
Hourly rate with total number of hours, or Flat rate for the services described
Supplies & Materials
CSP may be used to purchase supplies and materials necessary for the day to day operation of school
Computers and related peripherals Desks, Chairs, other furniture SmartBoards Books and periodicals School supplies Food purchases using CSP funds should be on a separate line, so
that we can assess reasonableness of these costs
However, any item that has a unit cost in excess of $5,000 per item must be in the Equipment category, not the Supplies and Materials category.
Travel Expenses
CSP funds may be used to pay for expenses related to travel and attending professional development conferences
Expenses should be described in detail so that we can ascertain if they are reasonable and necessary
Equipment
Equipment purchases are items in excess of $5,000 per unit
Initial implementation activities may include acquiring necessary equipment and educational materials and supplies.
The equipment must be necessary and reasonable for the proper and efficient performance and administration of the grant.
Minor Remodeling
CSP funds may not be used for construction.
However, CSP funds may be used for necessary
maintenance, repair, or upkeep of buildings and equipment that neither add to the permanent value of the property nor appreciably prolong its life, but merely keep it in an efficient operating condition.
2014-2015 FS-10 Final Expenditure Reports
For 2014-15 FS-10 Final Expenditure Report:
Date of Submission for budget periods ending 6/30/15 9/30/15 or ASAP: Send in FS-10F long form SED CSO and grants finance staff review FS-10F long form Final payment for 2014-15 grant year is made
Date of Submission for budget periods ending 8/31/15 11/30/15 or ASAP: Send in FS-10F long form SED CSO and grants finance staff review FS-10F long form Final payment for 2014-15 grant year is made
Continuation Application Approval
For 2015-16 Continuation application:
Date of Submission for budget periods ending 6/30/15 DUE 5/30/15- SED CSO staff review 2015-16 Continuation forms submitted 6/15/15: SED CSO staff sends documents to SED Grants Finance 7/1/15: Budget Approved
Date of Submission for budget periods ending 8/31/15 DUE 7/31/15 - SED CSO staff review 2015-16 Continuation forms submitted 8/15/15: SED CSO staff sends documents to SED Grants Finance 9/1/15: Budget Approved
***Dates are tentative and are subject to change based on timely receipt of budgets from schools***
2015-16 Continuation Forms
Budget Periods ending 6/30/15 - Due 5/30/15: Budget Periods ending 8/31/15 - Due 7/31/15:
2015-16 Grant Application Cover Page (Form A) 2015-16 Budget Workplan and Annual Project Update (Form B)
Please consult the instructions for guidance. 2015-16 FS-10 Budget Form (Form C)* 2015-16 Contract Budget Summary (Form D)
Must be uploaded to the portal electronically http://portal.nysed.gov and Mailed with original signatures to:
NYSED Charter School Office
Attn.: CSP Project Manager
New York State Education Department
89 Washington Avenue | EB 5th Floor Mezzanine
Albany, New York 12234
2015-16 Continuation Forms (cont’d)
Requested by July 31, 2015: 2014-15 Progress Report (Form E)
ONLY FOR SCHOOLS WITH GRANTS ENDING 8/31/15
Due 90 days after the end of the 2014-15 budget period for all grants:
FS-10F Long Form (Form G) Annual Program Update Form (Form B) 2014-15 Equipment Monitoring Form (Form F)
Budget Workplan and Annual Program Update
There are two sections of the 2015-16 Budget Workplan and Annual Program Update (Form B) with different due dates:
Budget Workplan Chart is part of the continuation application and due the same date as the rest of the application depending on contract dates;
Annual Program Update is completed at the end of the budget period and should be submitted with your equipment monitoring form within 90 days of the budget end date.
Please consult the instructions for guidance.
Forms and Contact Information… Grant Forms:
http://www.p12.nysed.gov/psc/funding/1415contapp.html
Submission Portal: http://portal.nysed.gov
Contact Information: [email protected] Lori Genito- CSP Grants Manager, 518-486-1736
Fiscal Forms
CSP FS-10 Budget Form
Enter the budget for either budget period 2 or budget period 3;
Items must be consistent with the expenditures in your CSP application implementation budget;
The budget summary page must: be signed by chief administrative officer (not CMO), include your project number and school name;
Please send 1 original (blue ink) and 2 copies
2015-16 FS-10 (Form C) - please use Excel version
Amendments (FS-10A) Amendments to your CSP grant’s budget are allowable but must be initiated no less
than two months before the end of your current budget period.
Example: If your 2014-15 budget period ends 8/31/15, the CSO needs to have received your email request by July 1, 2015.
To be approvable, budget amendments must:
Fall within the already approved activities listed in your grant application Stay within the confines of the non-regulatory and federal guidance that govern your
grant. Non-regulatory guidance can be found at: http://www.p12.nysed.gov/psc/funding/nonregguidance.pdf , and
Contain a valid justification for the change(s) requested.
No changes can be made until you have received approvalVisit http://www.p12.nysed.gov/psc/Amendment.html for full instructions on submitting
amendments.
Payments: FS-10/FS-25/FS-10F Upon FS-10 budget approval: You receive an initial 20% payment of
your budget total.
Request for Reimbursement: FS-25 forms are used to request up to 70% of your budget funds. To help expedite payments, it is recommended you complete these forms on a monthly basis as long as you are in need of the funds. Cash payments prior to the end of the grant period cannot exceed 90% of a grant’s budget.
End of Budget Period: FS-10 Final Expenditure Long Forms are used to request the remaining 10% of your Budget. Once your final expenditures are approved, the remaining funds will be sent and your budget period will be closed out.
Independent Auditor: Agreed Upon Procedures
Audit Guide Charter School Audit Guide Summary Auditor will look at overall expenditures for reasonableness
and test a sample of expenditures to determine if expenditures are in accordance with grant purposes, are applied to the correct budget category, and are recorded in the proper fiscal period.
Auditor will also review FS-25 form(s) submitted to NYSED and tie a sample of expenditures into requests for reimbursement.
Reporting & Monitoring: Items to Watch
Items identified in prior monitoring: CSP Revenue Tests
Revenue not recorded Revenue not recorded in the correct fiscal period
CSP Expenditure Tests Equipment purchased, but not received must be reflected a credit in the CSP
general ledger account and should not be included on the school’s final expenditure report (FS-10F)
Expenditures not charged to the correct fiscal year Request for reimbursement (FS-25) Tests
Funds not expended within one month following request for reimbursement An accurate written tracking/filing system was not maintained for fiscal records.
New Federal Grant Regulations:
Charter School implementation of ‘the New EDGAR”
Board adopted policies and procedures must be in place by June 30, 2015
Implementation of these new policies and procedures by July 1, 2015
Link for the Power Point Slides and recorded webinar on the New EDGAR requirements: http://www.p12.nysed.gov/psc/
Federal Grant Regulations, cont’d: The New EDGAR includes these areas:
Internal controls: to account for and safeguard all assets Comparison of expenditures with budget amounts Written cash management procedures to minimize the
‘parking’ of advance grant funds Advances must be maintained in insured, interest bearing
accounts when awards are greater than $120,000 And expected interest earned $500 or more Interest earned over $100 must be remitted annually
Federal Grant Regulations, cont’d:
Written procedures for determining allowability of grant costs. The procedures should explain the process used throughout the grant development and budget process For example- consideration that cost is generally recognized as
ordinary and necessary, arms length bargaining, market price for comparable goods…
Personnel expenses must be based on records that accurately reflect the work performed
If the charter school has a parent, affiliate or subsidiary organization they must also maintain written standards of conduct covering organization conflicts of interest.
Federal Grant Regulations, cont’d:
Must disclose in writing, in a timely manner, all violation s of Federal criminal law involving fraud, bribery or gratuity violations.
All procurement transactions must be conducted with full and open competition.
Micro-purchases of supplies and services under $3,000 may be awarded without soliciting competitive quotations if the cost is reasonable. To the extent practicable must distribute micro-purchases equitably among qualified suppliers.
NYSED as the ‘pass through entity’ is required to take prompt action when instances of noncompliance are identified including audit findings.
Resources & Links
NYSED’s Charter School Office
SED Grants Finance Guidance and Information
National Charter School Resource Center
United States Department of Education Charter Schools Home Page
Questions?
• Email: [email protected] with the subject line: CSP Grant: Question
• Contact the CSP Grant Manager:
Lori Genito
Or
(518) 486-1736
