1. Title I, Part A/LAP Spring Workshop
May 2013
Title I, Part A/LAP Spring Workshop

2. Agenda Schoolwide Programs Parent Involvement Private Schools
Title I, Part A iGrant Application - FP201
Charter Schools
Allowable Costs – Basic Guidelines
Time and Effort
Learning Assistance Program (LAP)

3. Title I, Part A
Schoolwide programs

4. Title I, Part A Schoolwide Programs
The schoolwide program model is a comprehensive reform strategy designed to upgrade the entire reading and mathematics program for the Title I, Part A building
The primary goal of the schoolwide program is to ensure that all students, particularly those who are low-achieving, demonstrate proficient and advanced levels in the state academic achievement standards
To create schoolwide reform, the primary focus of the schoolwide program is to design and implement a well defined “schoolwide-system model”, of tiered/leveled additional interventions

5. Step 1 Readiness to Benefit: Schoolwide-Systematic Reform Based Model
Clarify the vision of reform/A clear focus
Discuss with staff shared vision
Analyze ten components of schoolwide plan

6. Step 2
Develop a comprehensive needs assessment for the entire building:
Modify schoolwide needs based on annual evaluation and review of program
Determine where the building is now and where it wants to be when its vision is realized
Collect, sort, analyze data
Reading, mathematics, language arts, and science
Set priorities and concerns
Identify strengths and weaknesses

7. Step 3
Build Schoolwide comprehensive component plan to identify reform strategies:
Create a tiered/leveled model of additional intervention
Determine and identify proven researched-based strategies, designed to facilitate reform and improvement
Accept a collective responsibility for reaching and teaching all students
Tie all components to needs assessment (including which programs to be combined in the schoolwide program)
Set measurable goals-define action plan for reform
Includes list of programs combined, amount combined and how their intent and purpose of each combined program are met in the schoolwide plan and program (this will be used to determine appropriate time and effort)

8. Step 4 Implement the plan Ongoing review of action plans
Review effectiveness of systematic-intervention model
Keep documentation of implementation
Modify and make adjustments, as needed, during the year

9. Consolidating Funds
Schoolwide programs may combine federal, state and local funds of programs consolidated
Schools operating schoolwide programs are not required to maintain separate accounting records for combined programs if
Combined programs are identified in the plan
School maintains records documenting intents and purposes of programs combined are met

10. Purpose/Benefit of Consolidation
To help schoolwide school effectively design and implement a comprehensive plan to upgrade the entire educational program in the school based on needs identified in the needs assessment
When combining BEA funds, instructional staff become schoolwide staff
Instructional staff are part of an additional tiered-model of interventions
Use of all available resources to meet needs
Flexibility in use of resources
Not required to account separately for funds used in program
Not required to meet most statutory and regulatory requirements of specific program included in consolidation

11. Consolidation of Funds
Treat funds as a single “pool” of funds
Lose individual identity
Use funds to support any activity of the schoolwide program
But, must meet intent and purpose of each program

12. Schoolwide Program Cannot Include Title I, Part A Schoolwide Program
Title I, Part A (Disadvantaged)
Title II, Part A (Professional Development)
BEA (Basic Education)
Local Funding, Levy, District, etc.
Title III, (Immigrant)
Most ED Programs
Cannot Include
Transitional Bilingual
State Special Education
State Highly Capable I
Other State Programs which are
limited only to certain
students (not available to all
students in the building)
Restricted
Migrant
Indian Education
Federal Special Education
LAP
Carl Perkins

13. Consolidated Program Review: CPR Schoolwide Non-Compliance Issues
1.7: Each Title I, Part A schoolwide building has a schoolwide building plan that contains the 10 component requirements and evidence the plan has been implemented, Section 1114(b)(1); 34 CFR

14. Supporting Documentation: Building Level-Schoolwide
Building Level: A copy of a schoolwide plan that includes the following 10 required components and supporting evidence:
Comprehensive need assessment
Schoolwide reform strategies
Instruction by highly qualified teachers
On-going professional development
Strategies to attract highly qualified teachers
Strategies to increase parent involvement
Transition
Measures to include teachers in assessment decisions
Strategies for additional assistance
Coordination and integration of federal, state and local services and programs

15. Common CPR-Non Compliance Issues Related to Schoolwide Plan
Schoolwide plan not current-not updated from original plan submission
Schoolwide plan not well-defined-statements with no evidence
Schoolwide documentation evidence reveals schoolwide model is in actuality a targeted-assistance program model
Cannot provide schoolwide plan

16. Common CPR-Non Compliance Issues Related to Schoolwide Plan Components
The following components missing or lack of evidence:
Instruction by highly qualified teachers
Strategies to attract highly qualified teachers to high needs schools
Transition
Coordination and integration of federal, state and local services and programs

17. Common CPR-Non Compliance Issues Related to Schoolwide Plan Component
Component 10: Coordination and integration of federal, state and local services and programs
Component missing completely
Evidence for component list names of programs only
No matrix: Does not list funds combined, amount of funds, and the intent and purposes of combined funds
Matrix missing one or more of three required fields
Matrix lists all funds in building-allowable/restricted/or not allowable to combine

18. Use Correct Order Determine which funds will be combined
Address intents and purposes in the plan
Meet and document intents and purposes
Determine how to charge

19. Fiscal Flexibility Examples of ways to charge consolidated funds
Charge proportionately based on revenue
Charge sequentially
Charge based on activity (not use flexibility)

20. Title I, Part A Schoolwide: Supporting Documentation
OSPI Combining Funds Bulletin: Bulletin #
Designing Schoolwide Programs: Non-Regulatory Guidance-March
ESEA/Section 1114(b)(1); 34 CFR

21. Parent involvement policy
Title I, Part A
Parent involvement policy

22. Parent Involvement CPR Issues
District and Building Policies containing all the required elements.
District & Building CPR Monitoring Checklist
Evidence of implementation:
Notification of meetings
Agendas
Sign-in Sheets

23. Parent Involvement CPR Issues
1% (Districts who receive an allocation of $500,000 or greater)
The district ensures parents have the opportunity to be involved in decisions regarding the 1% parent involvement funds.
Evidence at district level of:
Parent survey
Meeting minutes, and/or
Agenda

24. FP 201-Updates

25. FP 201-Updates

26. FP 201-Updates
Policy/Plan

27. Parent Involvement News
Title I, Part A Parent Involvement Webpage
Survey News
OSPI Title I, Part A – New Parent Involvement Website
Parent involvement website with requirements across all federal programs (long term goal)

28. Parent Involvement -Resources
Parental Involvement: Title I, Part A Non-Regulatory Guidance
Keys to Successful Partnerships: Six Types of Involvement
CISL Website – Family Engagement, translation/interpretation
Spanish/English glossary of education terms

29. Title I, Part A
Private Schools

30. School District Responsibility to Provide Equitable Services for Eligible Private School Students, Teachers and Parents
Equitable services must be provided whether the private school is within or outside school district boundaries.
Students – Supplemental instruction in reading, language arts or mathematics
Teachers of Title I, Part A Served Students – Professional development in the area of Title I, Part A services
Parents of Title I, Part A Served Students – Parent involvement activities that assist parents with the learning of their children

31. Eligibility Criteria for Funds and Services
Funds: Funds are generated on the basis of the number of students from low-income families who reside in the participating Title I, Part A public school attendance areas and attend private schools, whether the private schools are located within the district or outside the district boundaries
Services: Private school students who reside within a Title I, Part A attendance area and are failing or most at risk of failing to meet high standards are eligible for services

32. Establish Procedures to Ensure Equitable Services are Identified and Provided
Process involves multiple entities who must establish an agreeable procedure that works best for them, including the process to identify eligible students and determination and delivery of equitable services
Entities include:
Residing district of the private school student
District where the private school is located
Private school

33. Possible Options for Equitable Services Process
Private school contacts the districts where students live
Residing district then conducts consultation to identify eligible students
Equitable services identified – residing district and private school may work with district where private school is located to provide services
Residing district contacts private schools in the surrounding area to identify eligible students
Residing district consults with private schools and district where each private school is located
School district where private school is located contacts the private school and proceeds to contact residing districts of identified students
Conducts consultation process
Identifies all low-income students
Identifies students out of district and contacts residing district
Districts and private school work together to determine services

34. Providing Equitable Services
Services may be provided by:
Employee of the residing district
Third party contract by residing district
District where the private school is located
Interlocal agreement between the residing district and the district where the private school is located establishes the services to be provided along with the funding amounts to provide the services
Services may be provided by an employee of the school district or a third party

35. Title I Equitable Services Resources
Title I Services to Eligible Private School Children, Non-Regulatory Guidance, October 2003 (Department of Education)
Ensuring Equitable Services to Private School Children: A Title I Resource Tool Kit, September 2006 (PDF with downloadable tools) (Department of Education)
Both documents available on the OSPI website at:

36. iGrant Application – FP 201
Title I, Part A
iGrant Application – FP 201

37. Title I iGrant Application (FP201) Changes
Contact Page: Please update school district contact information
Page 1: REAP Section removed
Page 2: Assurances updated
Page 3: Affirmation of Consultation form updated – If a affirmation form was completed for consultation process – okay to use for this year.
Page 4: Questions 10 & 11 Priority, Focus or Emerging Schools expanded
Page 4: Questions 14, 15 & 16 Parent Involvement updated
Pages 5-7: No changes

38. Title I, Part A
Charter Schools

39. Charter Schools - Accountability
Accountability is overseen in accordance with state charter school law
The charter authorizer is primarily responsible for holding charter schools accountable under the Title I, Part A provisions unless state law specifically gives the state educational agency (SEA) direct responsibility for charter school accountability
Section 1111(a)(2)(A)

40. Charter Schools - Allocations for Title I, Part A
If a charter school is authorized by an entity other than a traditional school district, the SEA will still be responsible for allocating Title I, Part A funds directly to the charter school, pursuant to federal and state laws
If a charter school is, under state law, part of a district, the district will allocate federal funds to the charter school on the same basis as it provides funds to its other schools

41. Charter Schools - Corrective Action
As with other public schools, charter schools that are unable to make adequate yearly progress (AYP) by the end of the second full school year after identification are placed under corrective action
The appropriate entity under state law has responsibility to reorganize a charter school’s management or take other corrective actions, consistent with state charter law and the state’s accountability plan for its charter schools
Section 1116(b)(7)(C)

42. Charter Schools - Teacher Qualifications
The law provides that a teacher who teaches core academic subjects in a charter school meets the certification requirement if he or she meets the requirements set forth in a state’s charter school law regarding certification or licensure
Teachers in charter schools do not have to be licensed or certified by the state if the state’s charter law does not require such licensure or certification
Section 9101(23)(A)(i)

43. Charter Schools - Paraprofessional Qualifications
Paraprofessional aides hired to work in programs supported with Title I, Part A funds must have a high school diploma or its recognized equivalent
Those who act as translators or conduct parent involvement activities must also have completed at least two years of study at an institution of higher education, possess at least an associate’s degree, or demonstrate subject-matter competence through a formal state or local assessment
Section 1119(c)-(e)
*This requirement applies only to paid paraprofessionals and not to parents or other volunteers. In addition, the term “paraprofessional” applies only to individuals who provide instructional support and not to school staff who have only non-instructional duties (e.g., providing technical support for computers, providing personal care services to students, carrying out clerical functions) [34 C.F.R. Section (a)(2)].

44. Allowable Costs – Basic Guidelines
Title I, Part A
Allowable Costs – Basic Guidelines

45. Allowability of Costs To be allowable a cost must:
Be necessary and reasonable for proper and efficient performance and administration of federal awards
Be allocable to federal awards
Be authorized under state and local laws, policies and procedures
Conform to any limitations in the A-87 circular
Be consistent and applied consistently (capital assets, direct vs. indirect costs, etc.)

46. Allowability of Costs Allowable if:
Follows generally accepted accounting principles
Not be used to meet cost sharing or matching of another federal award
Is net of all applicable credits
Is adequately documented

47. Reasonable Costs Prudent Person Test
Ordinary and necessary for operation or performance of federal awards
Follows sound business practices; arms-length bargaining; follows laws/regulations federal terms
Market price for comparable goods and services
Administered with prudence
No significant deviations; consistent with non-federal
Benefits the program

48. Supplement-Not-Supplant (Services to Students)
Presumptions of supplanting for districts and targeted assistance buildings-
Federal funds were used to provide services that the district was required to make available under federal, state or local law
Federal funds were used to provide services provided with non-federal funds in the prior year(s)
Title I, Part A or C funds were used to provide services for participating children that were provided with non-federal funds for non-participating children
Rebuttal may be possible in some cases

49. Supplement-Not-Supplant
Presumption of supplanting for Title I, Part A schoolwide buildings
Must show each schoolwide building received all state and local funds to which it is entitled, including those for basic education, for children with disabilities and for limited English proficient children

50. Time and Effort reporting
Title I, Part A
Time and Effort reporting

51. Why Does Time and Effort Continue to be an Audit Problem?
Large percent of federal education funds used for staffing
Staff turnover
Decentralized responsibilities
Lack of adequate communication between program and fiscal staff
Complexity of applying requirements to variety of situations
People don’t like it!

52. Where are the Requirements?
Time and effort reporting is required under 2 CFR Section 225 (formerly Federal Office of Management and Budget’s Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments)
Attachment B, Selected Items of Cost, Compensation for personal services

53. When is Time and Effort Required?
Time and effort reporting is required when any part of an employee’s salary is:
Charged to a federal program
Used as match for a federal program
Employee’s time is split between an indirect and any direct cost objective

54. What is an employee?
Salaries, wages and benefits are charged under objects 2, 3, and 4
An employee is NOT a vendor or independent consultant/contractor
No time and effort is needed for non-employees (See OMB Circular A-133 __.210 for vendor criteria)

55. What type of reporting is needed?
Single cost objective→Semi-annual certification
Multiple cost objectives→Monthly time reports or Personnel Activity Reports (PARs)

56. What is a “cost objective”?
A particular set of work activities for which cost data is accumulated
For purposes of time and effort reporting: Define cost objectives according to the set of work activities allowable under the terms and conditions of each funding source (Examples: Parent Involvement or Professional Development in a Federal Program)

57. What are some typical examples of single cost objectives?
The set of work activities allowable under:
A single federal program
A single required set-aside/reserve in a federal program
Federal Special Education and State Special Education
A schoolwide program
A federal program and its state/local match

58. What are some typical examples of multiple cost objectives?
The work activities of:
A federal program with multiple set-asides/reserves
A federally-funded program and a state-and/or locally-funded program
A schoolwide program and a program not combined in the schoolwide program

59. What is a semi annual certification?
Statement (certification) individual(s) worked solely on activities related to a single cost objective during defined dates
Completed at least every six months
Signed and dated by employee or supervisor with first-hand knowledge of work performed
For internal control purposes, district may request both employee and supervisor sign

60. What is a monthly time report? (PAR)
Accounts for total worked time/activity (including non-federal time)
Prepared and signed at least monthly
Signed and dated by employee
Reflects actual work performed (not budgeted)
Agrees with supporting documentation

61. What type of supporting documentation is needed?
Requires a judgment call
Examples include, but are not limited to:
Class schedules
Number of students
Number of minutes
Calendars or work logs

62. When is a “reconciliation” required?
Payroll records must be compared to time and effort reports at least quarterly to ensure no unallowable charges to federal awards

63. When is an accounting adjustment required?
If the difference is 10 percent or more:
Payroll charges must be adjusted at the time of the reconciliation
AND: The following quarter’s budget estimates must be adjusted to more closely reflect actual activity
If the difference is less than 10 percent:
No accounting adjustment is required until the end of the year
BUT: At year-end any payroll charges to federal awards that exceed actual time and effort must be eliminated

64. Who should sign the reports?
Monthly reports (PARs) must be signed by the employee
Semi-annual certifications must be signed by employee or supervisor having first-hand knowledge of work performed
For internal control purposes, districts may require both the employee and supervisor to sign

65. Schoolwide Programs
A schoolwide plan must specify programs to be combined
A schoolwide program is a single cost objective if an employee works 100 percent on programs combined→Group or individual semi-annual certification permitted
If an employee works partially on programs combined and partly on those not combined→ Monthly time report (PAR) required

66. Supplemental Contracts, Stipends, Extra Hours
Primary contract and additional contracts may be reported separately
Time and effort may be required for primary contract but not supplemental (or vice versa)

67. Administrators
Superintendent, assistant superintendent, principal, assistant principal are usually not allowable charges to federal programs
Exceptions require detailed documentation to support
Generally a supplant issue

68. What is a substitute system?
Alternative method for calculating and supporting compensation charges to federal grant funds (usually based on a statistical sample of work performed)
Used only for federal programs specified in approved substitute system plan
Must be approved by OSPI prior to use
Must be statistically sound
Should be periodically reviewed to determine if still appropriate

69. New Substitute System
Semi-annual certifications permitted for multiple cost employees with predetermined (fixed) schedules
Employee MUST sign
Must notify OPSI prior to use

70. Other Requirements for Charging Compensation to Federal Programs
Reasonable, necessary and allocable to the program charged
Compensation consistent with nonfederal activities of the district
Leave buy-out at termination is an indirect charge
Supplement, not supplant applies to many programs

71. Tips…… Know the basics Train and re-train:
Annual training in district
Explain the “why”
OSPI Bulletin – Keep it handy
Assign central responsibility:
Ensure all reports are completed
Communicate:
Who needs to communicate what changes to whom
Ask for help if needed

72. Additional Information on Time and Effort
OSPI Bulletin
Examples
Sample forms
2 CFR Section 225 (OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments
Time and effort FAQs (on CPR website at )

73. OSPI Title I/LAP Contacts
Title I, Part A/LAP Program Director
Gayle Pauley,
Title I, Part A/LAP Program Supervisors
Bill Paulson,
Jody Hess,
John Pope,
Larry Fazzari,
Mary Jo Johnson,
Penelope Mena,
Petrea Stoddard,
Reginald Reid,
Title I, Part A/LAP Support Staff
Julie Chace,
Tony May,