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TITLE I PROGRAM DIRECTORS TRAINING 1 Developed by the Office of Title I.

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1 TITLE I PROGRAM DIRECTORS TRAINING 1 Developed by the Office of Title I

2 2 I.To provide an overview of Title I requirements that must be implemented in schools and districts. II.To enable the program director to implement Title I policies at the school and district level. III.To provide technical assistance and support to the Title I program director(others) responsible for Title I program design and implementation. Goals and Objectives

3 3 1.Overview of Elementary and Secondary Education Act 2.Intents and Purpose of Title I 3.Eligibility 4.Comprehensive Needs Assessment 5.Program Requirements 6.Supplement vs. Supplant 7.Serving Nonpublic School Students 8.Professional Development 9.Paraprofessionals 10.Family and Community Enagagement 11.ESEA Flexibility Agenda

4 The Early Years – In the Classroom

5 Signing of the Elementary and Secondary Education Act (ESEA) of 1965

6 Title I, Part A: Intent and Purpose Public Law 107-110 Section 1111-1127 : Improving the Academic Achievement of the Disadvantaged Improving Basic Programs Operated by Local Education Agencies (LEA) provides supplemental funding to state and LEAs for resources to help schools with high concentrations of students from low-income families provide a high quality education that will enable all children to meet the states student performance standards. 6

7 Title I - A Brief History 1965 - Elementary and Secondary Education Act 1981 - Educational Consolidation and Improvement Act (Chapter 1) 1988 - Reauthorized – focus on accountability 1994 - Improving Americas Schools Act (Title I) 2001 - No Child Left Behind 2008 - New Rules – CFR 200 2010 - Secretarys Blueprint for Reform 2011- ESEA Flexibility Waivers 2014- Renewal of ESEA Flexibility Waivers

8 Scope of Title I-Nationwide 2011-2012 School Year * Federal allocation of over $14 billion o Title I represents the largest federal elementary and secondary education program Over 66,000 schools Over 23 million students served * US Department of Ed-Data Express ( 8

9 Scope of Title I in New Jersey 2011-2012 School Year Allocation of $302,805,798 388, 681 students served ( over 7,000 nonpublic) Supplemented instructional programs in English Language Arts, Mathematics, Science, Social Studies and CTE Provided support services: guidance, medical, dental, eye care (Title I Schoolwide and Homeless) 9


11 Eligibility Eligible School Attendance Area (§1113) The proportion of economically disadvantaged students in a school determines the amount of funds that may go to a school. Any student enrolled in an eligible school may receive Title I services if they are low achieving. All Title I funds must be distributed and accounted for. Low-income nonpublic school students in served school attendance areas must receive an equitable share. 11

12 Eligibility 1. Select poverty criteria: Free/reduced lunch, TANF, Medicaid, Composite, Feeder Method 2. Rank Schools: Based on the percentage (not number) of children from low-income families. 3. Serve Schools 75% rule Poverty rate at/above district poverty rate Grade-span grouping Poverty rate below 35% Per pupil expenditure calculated at 125% or 1.25 times the district per pupil amount Poverty rate 35% 12


14 Comprehensive Needs Assessment Includes the input of all stakeholder groups o Teachers, administrators, families, community members, students (if appropriate) and technical assistance providers Ongoing process that is summarized in the districts Consolidated Application Foundation for the use of Title I funds Expenditures not supported by comprehensive needs assessment are not necessary and reasonable. 14

15 Purpose : Enable schools to identify their strengths and weaknesses, so they can specify priority problems and plan activities to help improve student achievement and meet state academic standards. The following can be used: State assessments District commercial tests and other data Teacher tests and observations Surveys and stakeholder input 15 Data-Driven Decision Making

16 The problems selected by the district require an adequate description that identifies the following: The target population The causes of the problem The identification of the data source The analysis of the data, areas to be measured The measurement tool The specific school targets 16 Priority Problems


18 Targeted Assistance and Schoolwide Programs Title I supports schools in implementing either a school-wide program or a targeted assistance program. These programs must use effective methods and instructional strategies that are grounded in scientifically based research. 18 Targeted Assistance Schoolwide Poverty Threshold 40%

19 Targeted Assistance Programs (TAS) Title I funds are used only for services for eligible children who are failing or at risk of failing to meet state standards. Eight required program components Must identify student eligibility for services. 19

20 Targeted Assistance Programs (TAS) 20 Establish entrance and exit criteria based on multiple, objective, and uniform criteria such as : Assessment results, teacher recommendations, and parent recommendations Children who have the greatest academic need receive Title I services Districts may need to prioritize the student selection to provide a meaningful program

21 Targeted Assistance Programs (TAS) 21 Eight Essential Components (§1115) 1.Assist students in reaching state standards 2.Are based on effective means for improving student achievement 3.Ensure appropriate planning 4.Use instructional strategies effectively by minimizing pull-out and offering in-class support or extended day and summer programs 5.Coordinate with and support regular education programs such as pupil services (counseling, mentoring) and transition programs 6.Offer instruction by highly qualified staff 7.Provide professional development 8.Use strategies to increase parental involvement

22 Targeted Assistance Programs (TAS) Instructional and Programmatic Strategies In- class support Extended year programs Summer programs Transition programs Coaches Test prep classes Specified professional development 22

23 Schoolwide Programs 23 34 CFR 200.25 [t]he purpose of a schoolwide program is to improve academic achievement throughout a school so that all students, particularly the lowest-achieving students, demonstrate proficiency related to the State's academic standards...

24 Schoolwide Programs (SW) 24 Criteria (§1114) Title I funds are used to upgrade the educational program of the entire school to meet the states academic standards. 40 percent or more of the students enrolled in the school, or residing in the school attendance areas, must be from low-income families. A comprehensive needs assessment must be conducted. The district must meet with stakeholder group when developing the schoolwide plan


26 Title I Schoolwide Plan Reflects 10 components of a schoolwide programs Annual requirement Submitted with districts Consolidated Application 26

27 Title I Schoolwide Plan The schoolwide plan must include the following three elements: 1. A description of how the school will implement the mandatory schoolwide program components described below; 2. A description of how the school will use resources from Title I and other resources to implement those components; and 3. A list of federal, state, and local programs that will be consolidated in the schoolwide program. 27

28 Stakeholder Engagement ESEA §1114(b)(2)(B)(ii) The schoolwide plan should be developed with the involvement of parents and other members; Provide all students in the school the opportunity to meet the states proficient and advanced levels of student academic achievement; Use effective methods and instructional strategies that are grounded in scientifically based research; and Strengthen the core academic program in the school. 28

29 Evaluation 34 CFR § 200.26 (c) A school operating a schoolwide program must Annually evaluate the implementation of, and results achieved by, the schoolwide program, using data from the State's annual assessments and other indicators of academic achievement; Determine whether the schoolwide program has been effective in increasing the achievement of students in meeting the State's academic standards, particularly for those students who had been furthest from achieving the standards; and Revise the plan, as necessary, based on the results of the evaluation, to ensure continuous improvement of students in the schoolwide program. 29

30 Needs Assessment ESEA §1114(b)(1)(A) Schools must perform a comprehensive needs assessment of the entire school. The assessment must be based upon information that includes the achievement of children in relation to the State academic content standards and the State student academic achievement standards. 30

31 Reform Strategies ESEA§1114(b)(I)(B) Provide all students in the school the opportunity to meet the states proficient and advanced levels of student academic achievement Use effective methods and instructional strategies that are grounded in scientifically based research Strengthen the core academic program in the school 31

32 Reform Strategies ESEA§1114(b)(I)(B) Increase the amount and quality of learning time (i.e., extended school year, before and after school programs, and summer programs) Provide an enriched and accelerated curriculum Meet the educational needs of historically underserved populations Include strategies to address the needs of ALL children in the school (particularly, the needs of low-achieving students) 32

33 Family and Community Engagement ESEA§1114(b)(1)(F) Schoolwide plans must contain strategies to involve families and the community in assisting children to do well in school Families and communities must be involved in the planning, implementation, and evaluation of the schoolwide program 33


35 Supplement Not Supplant Schoolwide Programs Schoolwide Programs: Programs and services do not have to be supplemental; Title I funds used to support the program must be supplemental. District cannot reduce schools state/local funding based on an increased Title I allocation. The amount of state/local funding to schools must be sufficient to support the schools basic educational program. Documentation that schools have enough state/local funds to fully operate without federal funds. District must be able isolate the state/local funds needed for schools in current year and prior years.

36 Supplement Not Supplant Targeted Assistant Programs and District-Level Expenditures Presumption of supplanting The district has used the Title I funds to provide services that the district was required to make available under federal, state or local law. The district used Title I funds to provide services it provided with non-federal funds in the prior year(s). The district has used Title I funds to provide services for participating children that it provided with non-federal funds for non- participating children.

37 Supplement Not Supplant Targeted Assistance Program Scenarios District has 3 elementary schools. School A and B are Title I-funded schools with a Targeted Assistance Program. School C is not a Title I school. The district wants to pay the salaries of its basic skills teachers in School A and B with Title I funds and will pay the salaries of its basic skills teachers in School C with local funds. Is this allowable? NO! This is supplanting. 37

38 Supplement Not Supplant Targeted Assistance Program Scenarios A district with a Targeted Assistance Program has an afterschool program for its Title I students. With Title I funds, it wants to pay the salary of the Title I teacher, instructional materials for the students in this afterschool program, and iPads for the students to use as part of the program. Are all of these things allowable? YES! All of these costs are supplemental and used for Title I teachers/students only. 38

39 Supplement Not Supplant Targeted Assistance Program Scenarios The school would like to send all of its Math teachers to a Math Recovery professional development program that provides a powerful mathematics intervention framework that gives teachers the unique techniques and assessment tools they need to help elementary children achieve lifetime results. Is this allowable? NO! In a Targeted Assistance program, Title I funds for professional development may benefit Title I staff only. 39

40 Supplement Not Supplant Targeted Assistance Program Scenarios The school wants to contract with reading expert to provide onsite professional development on techniques and assessment tools to help low-achieving students achieve lifetime results. The school would like every teacher to participate in the professional development. Is this allowable? YES! The district may pay for a consultant/expert to come to school district to provide professional development that primarily benefits Title I staff. The other teachers may attend as "incidental benefit." 40

41 Supplement Not Supplant Targeted Assistance Program Scenarios A Title I school with a Targeted Assistance Program would like to put in three SmartBoards in English language arts classes where the majority of students (about 70%) are Title I. Is this allowed? NO! Title I instructional equipment may benefit Title I students only. 41

42 Supplement Not Supplant Targeted Assistance Program Scenarios A Title I school with a Targeted Assistance Program would like to use Title I funds to hire a data analyst, a Math Coach and a Literacy Coach. Is this allowed? Possibly, but not advisable! The services of these staff would have to be limited to Title I students only. This is a high bar to meet in a targeted assistance program, so it is advisable for the district to use it state/local funds for these positions. 42


44 Eq uitable Service Provision ESEA §1120 Requires districts receiving Title I, Part A funds to provide services to: Eligible nonpublic students Teachers of eligible nonpublic school students Families of eligible nonpublic school stude nts 44

45 Equitable Services Why? Census poverty data includes low-income families with nonpublic school children Census poverty data used to determine districts Title I allocations Child Benefit Theory: Funds benefit child ONLY 45

46 Child Benefit Theory 34 CFR § 200.66 Title I services benefits the individual child, NOT the entire school. Services are provided by the district, not the nonpublic school Child Benefit Theory complies with the Constitutional Prohibition against Federal funding- No funds are to EVER go to the nonpublic school! 46

47 Equitable Service Provision ESEA §1120 Step 1 : Locating Nonpublic Students Step 2 : Counting Nonpublic Students o Enrollment data, Income data Step 3 : Generating Nonpublic Allocation 47

48 Equitable Service Provision ESEA §1120 Step 1 : Locating Resident Nonpublic Students Resident nonpublic schools Bordering nonpublic schools Transportation Documents (Busing routes, Aid-in-Lieu) 48

49 Equitable Service Provision ESEA §1120 Step 2: Counting Resident Nonpublic Students Enrollment data : match resident nonpublic students to their public school attendance area Low-income data : Contact schools enrolling resident nonpublic students Various methods: survey, extrapolation, proportionality, equated m 49

50 Equitable Service Provision ESEA §1120 Step 3: Generating Nonpublic Allocations Who: Nonpublic students who 1) live in the attendance area of a Title I public school and 2) come from low-income families How: District enters enrollment and low-income numbers into its annual Title I, Part A application How much: The same per-pupil amount as public schools students residing in the Title I attendance area 50

51 Participation of Students Enrolled in Private Schools ( ESEA § 1120 ) An eligible private school student resides in the participating attendance area of the school district and is selected on the same basis as targeted assistance students. The district in consultation with non-public school official(s) MUST establish clearly defined entrance and exit criteria to meet the needs of eligible nonpublic school children using multiple, educationally related, objective criteria (i.e. Achievement tests, teacher referral/recommendations based upon objective, and educationally related criteria; and grades) 51

52 Allocating Funds District reserves off the top – If a district reserves funds for instructional related activities for public school students at the district level, the district must also provide from these funds equitable services to eligible nonpublic school children. Amount of funds must be proportional to the number of nonpublic school children from low-income families residing in public school attendance areas. 52

53 Allocating Funds Not eligible for equitable services o N&D/ Homeless Eligible for equitable services o Parental Involvement o Professional Development o Districtwide Instructional Programs 53

54 Consultation Consultation between the public school and private schools, during the design and development of the programs: Must be timely and meaningful. Must take place on an annual basis, and be documented by the district: sign in sheets, agenda, written affirmation. Must continue throughout the year, to ensure the needs of private school students are being met. Shall occur before the school district makes any decision that affects the opportunities of eligible private school children, teachers, and other educational personnel to participate.

55 Delivery of Services Under control and supervision of the public school. The public school maintains control of all materials, supplies, equipment, and property acquired with Title I funds for the benefit of eligible private school students. Services for private school children must begin at the same time as services for public school children.

56 Delivery of Services Key word is services. No public funds are distributed to private schools, only services and materials..

57 Delivery of Services Examples Instructional services outside the regular classroom. Extended learning time (before/after school and in the summer). Family literacy programs. Counseling programs. Early childhood. Home tutoring. Computer-assisted instruction.

58 Delivery of Services Materials and supplies purchased with Title I funds may ONLY be used by the identified Title I students in the Title I program. Must be supplemental and may not replace or supplant services that would, in the absence of Title I, be provided by nonpublic school to participating nonpublic school children. 58

59 Evaluation The district in conjunction with nonpublic officials MUST define annual progress for nonpublic school Title I participants. If annual progress is not met, the district in conjunction with nonpublic officials must modify the Title I program. 59


61 Professional Development Must be sustained, high-quality, classroom-focused training in core content areas and strategies that work Use of Title I funds for PD will vary depending upon Title I program Title I teachers, principals, paraprofessionals, and other staff may participate. 61

62 Allowable Uses Strategies tied to the states academic standards, state student performance standards and consistent with the districts needs assessment Activities involving parents in the education of their children Activities addressing the needs of teachers in Title I schools and students most academically at-risk Activities incorporating teaching strategies in the CCSS/CCCS areas for meeting the needs of academically at-risk students 62


64 Requirements Instructional paraprofessionals in targeted assistance and schoolwide programs MUST meet one of the following criteria: Have an Associates Degree or higher Completed two years of college coursework Passed a rigorous test showing the ability to assist with the teaching of reading, writing, and mathematics 64

65 Duties 1. Provide one-on-one tutoring when a student is not being instructed by a teacher. 2. Assist with classroom management. 3. Provide instructional assistance in a computer lab. 4. Conduct parental involvement activities. 5. Provide support in a library/media center. 6. Act as a translator. 7. Provide instructional support under the direct supervision of a teacher. 65


67 Why Family and Community Engagement? It is required by law. It helps raise student achievement. 67

68 Family and Community Engagement Parent involvement is one form of family and community engagement The Title I statute defines the term parental involvement as the participation of parents in regular, two-way, and meaningful communication involving student academic learning and other school activities. 68

69 Family and Community Engagement Applies to all Title I districts & schools. Comprehensive and based upon families needs. Benefit the greatest number Title I families who have children being served in Title I programs. One-percent reserve of Title I allocations over $500,000. 69

70 Family and Community Engagement District Set-Asides Districts receiving $500,000 or more in Title I, Part A funds must set aside, at minimum, 1% for family & community engagement purposes, including promotion of family literacy and developing parenting skills. 95% of the district set-sides must be allocated to Title I buildings for building-level family and community engagement activities. Districts < $500,000 must also provide family and community engagement opportunities at the district and building levels.

71 Parents Right-to-Know (§1111) At the beginning of the school year Title I district must notify parents of their right to request the following information regarding their childs teachers: Whether the teacher has met state qualifications and licensing criteria. Whether the teacher is under emergency or provisional status. Whether the teacher has a baccalaureate degree, certification in the discipline field and other pertinent education. Whether the child is provided services by paraprofessionals, and, if so, their qualifications. Schools must notify parent when their child has been taught for four consecutive weeks by a teacher not highly qualified. 71

72 Language Instruction Education Program (§1111 ) 72 Not later than 30 days after the beginning of the school year, the district is required to inform the parent (s) of a limited English proficient child identified for participation in a language instruction educational program of the following: The reasons for the identification of their child as limited English proficient and in need of placement in a language instruction educational program. The childs level of English proficiency, how such level was assessed, and the status of the childs academic achievement.

73 The Written Parental Involvement Policy (§1118 ) Describes how the district will: Involve parents in developing the districts plan for school review and improvement Provide coordination, assistance and support to assist in planning and implementing effective parental involvement activities to improve student performance Build schools and parents capacity for strong parental involvement Coordinate and integrate parental involvement strategies with other programs (e.g., Head Start, Reading First etc.) Conduct an annual evaluation of the content and effectiveness of the parental involvement policy Involve parents in the activities of schools served under Title I 73

74 The Written Parental Involvement Policy (§1118) School Policy Requirements Each school must develop, jointly with parents of children participating in Title I services, a written school parental involvement policy that describes how the school will carry out the parental involvement requirements in §1118(c)-(f), including the development of a parent compact 74

75 The School-Parent Compact: Shared Responsibility for High Student Achievement (§1118 ) Each school must develop a school-parent compact jointly with parents, student and teachers of students receiving Title I services that outlines: How parents, the entire school staff, and students will share the responsibility for improved student academic achievement. How the school and parents will build and develop a partnership to help children achieve the states high standards. 75

76 Annual Parent Meeting §1118(c)(1)(2) All Title I funded schools invite parents to attend a meeting to inform parents of Title I program Meeting must be documented (invitational flyer/letter, agenda, sign-in-sheets, and minutes) 76

77 Title I Parental Involvement Notification Requirements for Districts 77 /title1/program/parent/resources /Requirements.pdf * Includes sample templates


79 10 Areas Subject to Waiver 1. District improvement requirements 2. School improvement requirements 3. 100% Proficiency by 2013-2014 4. Rural districts 5. Schoolwide Programs 6. Rewards schools 7. Supports for schools in need of improvement 8. Highly-qualified teacher plans 9. Transferability 10. Use of School Improvement Grant (SIG) funds 79

80 Waiver Implementation 2012-2014 Schools no longer identified as schools in need of improvement. Identify priority schools (lowest 5% of Title I participating and/or eligible schools) Identify focus schools (10% of Title I schools that contribute to the achievement gap) 80

81 Waiver Implementation 2012-2014 Progress Targets : The NJDOE will calculate Progress Targets for schools and districts based on the goal of closing the achievement gap by half within six years. The Progress Targets are set in annual equal increments toward a goal of reducing by half the percentage of students in the all students group and in each subgroup who are not proficient within six years. 81

82 Progress Targets The all students group has a proficiency rate of 40%, so there is a 60% point gap between 100% proficiency and the current rate. (100 – 40 = 60) Divide the gap in half to determine the target for the sixth year – a gain of 30 percentage points. ( 60 / 2 = 30) Divide the 30-percentage point gain into six equal increments to set annual targets. (30/6 = 5) The school in begins with 40% proficiency rate, and obtain proficiency rates of 45%, 50%, 55%, 60%, 65%, and finally 70% in each of the following years of the six-year period. 82

83 Waiver Implementation 2012-2014 Requirement for the NJDOEs district and school report cards to identify a school in need of improvement and a district in need of improvement. Under the waiver, the Report Card will not identify schools as a School in Need of Improvement based solely on narrow AYP achievement targets. 83

84 Waiver Implementation 2012-2014 Requirement for a school to have a poverty rate of 40% or higher to operate a Title I schoolwide program. The waiver allows districts to apply to operate a Title I schoolwide program in a Priority or Focus School with a poverty rate below 40%. 84

85 Waiver Implementation 2012-2014 The requirement for districts reporting less than 100% of their teachers as meeting the definition of Highly Qualified to develop and implement an improvement plan. The waiver provides increased focus on the development of more meaningful evaluation systems for teachers. 85

86 Web Site Resources NJ Department of Education Title I Parental Involvement Notification: US Department of Education Guidance NCLB Consolidated Subgrant Reference Manual Presidents Blueprint for Reform 86

87 Targeted Assistance Schoolwide Programs Parental Involvement Paraprofessionals Private School Children Web site: 87 US Department of Education Non-Regulatory Guidance


89 What Happens When Federal $$$ Are Misspent?????? 89

90 US Dept of Education- Office of Inspector General 90 Accountability. Efficiency. Effectiveness. Oversight

91 OIG Fraud News According to court documents, on June 20, 2007, BROOKS-SIMMS pled guilty to conspiracy to commit federal program fraud. She admitted she secretly conspired with a local businessman, to approve the purchase of an educational software program for the Orleans Parish School System. Jefferson received over $900,000 of Orleans Parish School Board money as his sales commission for selling the software program to the school board. In exchange for her assistance in promoting and approving the software program, BROOKS-SIMMS received approximately $140,000 as a bribe/reward from the Jefferson. Both BROOKS-SIMMS and the Jefferson funneled these payoffs through several bank accounts to disguise their illegality. On August 21, 2009, Jefferson was convicted by a federal jury after a two week trial and has been sentenced to serve ten (10) years in federal prison.

92 OIG Fraud News THOMPSON was employed at Langston Hughes Academy Charter School as the Business and Human Resources Manager/Financial Manager beginning approximately July 1, 2008 until approximately November 6, 2009. THOMPSON admitted that in her position at Langston Hughes Academy Charter School, she would make cash withdrawals while acting in her capacity as Business and Human Resources Manager/Financial Manager and then manipulated the schools record in order to conceal the thefts. The amount of loss to Langston Hughes Academy Charter School is approximately $660,000.

93 OIG Fraud News PHILADELPHIARosemary DiLacqua, 51, of Philadelphia, was sentenced today to a year and a day in prison for honest services mail fraud committed while she was board president for the Philadelphia Academy Charter School (PACS), announced United States Attorney Michael L. Levy. DiLacqua accepted a total of approximately $34,000 in payments from codefendant Kevin OShea, the former CEO of PACS, and another former school official that she did not disclose on her mandatory statement of financial interest form or to the other board members. After receiving these undisclosed payments, DiLacqua approved a series of salary increases for OShea and also a 20-year consulting contract for the other former school official that would have paid him in excess of $100,000 annually for no more than 90 days of consulting each year. When OShea left PACS the following Spring (May 2008), he was earning in excess of $200,000 in salary from PACS.

94 OIG Fraud News FORMER CEO OF CHARTER SCHOOL SENTENCED TO 37 MONTHS ON FRAUD, THEFT AND TAX CHARGES In July 2009, O'Shea entered a guilty plea admitting that he stole between $400,000 and $1 million from PACS by: (1) using approximately $710,000 in PACS' funds to purchase a building in the name of his purported non-profit business; (2) demanding kickbacks from PACS vendors; (3) submitting for reimbursement at least $40,000 in fraudulent invoices for personal meals, entertainment, home improvements, and gas and telephone bills; (4) having approximately $50,000 worth of home repairs improperly billed to PACS; (5) collecting approximately $34,000 in rent from entities using PACS facilities; and (6) hiring a computer firm in an attempt to destroy computer evidence to obstruct this investigation. O'Shea also admitted to filing a false tax return for 2006.

95 Board Minutes What should be in my Board minutes? Resolutions to: Apply for Funds (copy of budget statement)

96 Board Minutes What should be in my Board minutes? EDGAR Part 80, Section 20 Appointment of Teachers o Name o Salary o School o Funding Percentage for Each Program Appointment of Secretaries, Aides, Program Directors, etc. o Name o Salary o Work Location o Funding Percentage for Each Program

97 Final Expenditure Reports Must be consistent with budget (amendments filed through County Office) – EWEG Monitors CANNOT: o Move more than 10% of total funds, whichever is less, without State approval (filed through County Office) o Add a budget category without State approval (filed through County Office) o Carryover more than 15% of total amount received more than once every three years without State approval (Must have good reason) – NJDOE has a Waiver in Place

98 Carryover of Funds (Set Asides) Some Carryover Funds are Restricted to the Original Intent and Purpose of the Funding **** Accounting Tracking Required **** Parental Involvement o If these funds carried over, then can only be spent for original intent and purpose or must be refund to SEA

99 Select Expenditures and Support Needed Fully-funded Salaries Periodic certification signed at least semi-annually Signed by employee and supervisor ** New Model – October 2012 /tech/schoolwide022213/ /tech/schoolwide022213/ - Click on Sample Time and Activity Reports

100 Select Expenditures and Support Needed Split-funded Salaries Personnel activity reports Signed by employee and supervisor Must be an after-the-fact distribution of actual activity Prepared at least monthly and must coincide with pay periods

101 Select Expenditures and Support Needed General Purchases Must have purchase orders Must have account number on P.O. Should indicate Title I purchases Signed by Business Administrator If split P.O., Title I should be easily identifiable REMEMBER – Money spent in Individual Schools should EQUAL amount in Step 4 of Eligibility

102 Select Expenditures and Support Needed Equipment Maintain master inventory listing (Date, Serial Number, Model, Cost, Location) Each school should maintain subsidiary listing All equipment should be labeled with Title I or equivalent tracking system Need to keep records for FIVE years past disposition (date needs to be on master list) Even if not equipment for GRANT purposes, if district has a lower threshold, then tracking of equipment is required If less expensive to inventory than to replace, it should be inventoried

103 Select Expenditures and Support Needed Employee Benefits TPAF/FICA reimbursement applies only to teachers contracted salaries, supervisors and program directors TPAF/FICA reimbursement report does not apply to aides, secretaries or clerical, stipends, substitute teachers or summer teachers All other benefits based on actual cost, not budgeted percentages

104 Select Expenditures and Support Needed Employee Benefits – TPAF/FICA Reimbursement Report

105 Selected Items of Cost Special rules for specific expenses Still subject to basic guidelines Examples: o Alcohol: Never allowable o Salaries and Wages: Allowable if time distribution o Meetings and conferences: Allowable if dissemination of technical information

106 Selected Items of Cost – Student Incentives The US Dept. of Education(ED) has indicated that an LEA may use Title I funds to provide non-monetary rewards of nominal value (e.g., Plaque, gift certificate, or book, etc.) in an effort recognize Title I students for good performance. Title I funds may NOT be used to pay students a stipend or provide some other type of award as an incentive for student participation in a Title I program

107 Selected Items of Cost – Parent Incentives To encourage parents of Title I students to participate in school activities in the evening, an LEA may use Title I funds to provide light refreshments. Note, ESEA § 1118(e)(8) authorizes LEAs to use Title I funds for parent-related activities that are reasonable and necessary for expenses associated with parental involvement activities, including child care and transportation to enable parents to attend school-related meetings and training sessions

108 Helpful Questions to Ask When Analyzing Costs Is the proposed cost consistent with federal cost principles? OMB A-87, Attachment B Is the proposed cost allowable under the relevant program? (Title I, IDEA, etc) Is the proposed cost consistent with an approved program plan and budget? (EWEG) Is the proposed cost consistent with program specific fiscal rules? (Supplement not Supplant) Is the proposed cost consistent with EDGAR?

109 Documentation required for both school-level and district- level expenditures Documentation must explain: 1. How is the expenditure reasonable and necessary to carry out the intent and purpose of the program? 2. What need, as identified in the comprehensive needs assessment, does the expenditure address? 3. How would the program, activity, or strategy be funded if the Title I, Part A funds are not available? Expending Funds 109

110 Documentation must explain: If for a schoolwide campus, how will the expenditure upgrade the entire educational program on the campus? How is the expenditure supplemental to other nonfederal programs? How will the expenditure be evaluated to measure a positive impact on student achievement? Expending Funds 110

111 Allowable Costs All Costs must be : Necessary Reasonable Allocable Legal under state and local law

112 Nonpublic Expenditures Same Fiscal Rules Apply o Only your districts students o Students that need extra services NO longer just supplies/computer – SERVICES ARE REQUIRED Carryover o Funds not Spent in Prior Year (Discretion) o Automatic flow of district carryover in EWEG

113 Nonpublic Expenditures Third Party Provider Contracts When bid, the specifications should have the Stephens Amendment wording Vendor Complaint Policy Details on who provides parental involvement activities Renting/Ownership of Supplies, Trailers, etc. Breakout of Invoices to Include: o Instructional Salaries and Benefits o Instructional Supplies o Rental of books, supplies, trailers o Administrative Charges/Profit

114 Nonpublic Expenditures Third Party Provide Contracts Administrative Costs of Third Party Providers counts against the Districts Five Percent (5%) Total Administrative Costs Who pays the Administrative Costs? Off the top allocation of the District of Other Title I Funds (USDOE Non Regulatory Guidance)

115 Fiscal Policy District Policies on: Maintenance of Effort Comparability Supplement vs. Supplant

116 Fiscal Policy Maintenance of Effort Current Expenditures (Not Including Capital Outlay) o Less: Community Services o Divided by: Average Daily Enrollment Compare to prior year (current year/prior year) and must be at least 90% *** Must Be Done Annually ***

117 Fiscal Policy Maintenance of Effort Example LineDescriptionAggregate Expenses Average Daily Enrollment Amount Per Student 1 Amount from 2004-2005 $ 5,098,944377.50 13,507.14 2 Amount LEA had to Spend in 2005- 2006 (90% of Line 1) $ 4,589,050377.50 12,156.42 3 Actual Amount Spent in 2005-2006 $ 5,095,897398.00 12,803.76 4 Amount District Failed to Maintain 5 Percent of Reduction in 2006-2007 EXCESS $ 506,847 $ 647.34

118 Fiscal Policy Comparability Compare Like-Kind Grade Span Groupings (Elementary, Middle or High – Only 3 Groupings) Monitoring Coming Soon – Verify staffing

119 Schoolwide Programs MUST have approved plan that addresses all schoolwide issues Time sheets are required (except in a blended resource fund, e.g., Fund 15 for former Abbott districts)

120 Frequently Asked Questions Time Sheets and Salaries Q:Multiple Federal Grants – If someone works on multiple federal grants, must their salary be allocated to all the grants since it is one large federal pot of money? A: Yes, since each is a separately funded program.

121 Fiscal News from Washington New Haven Audit Report from Office of Inspector General Supplanting in a Schoolwide Program

122 Fiscal News from Washington William Floyd Audit Report from Office of Inspector General Unsupported Expenses Unsupported Adjusting Journal Entries Supplanting of Textbooks Weak Internal Controls

123 Fiscal News from Washington City of Detroit and Parent Involvement Fund 2005 Disallowed Charges for Entertainment, Promotional Items and Public Relations Need to be necessary, reasonable, allocable and documented Disallowed items include advertising for an event and live musical entertainment at parent volunteer function

124 Fiscal News from Washington City of Detroit -Revisit in 2008 Over $131 Million in 2005 and $126 Million in 2006 No Time Sheets – Almost $50 Million Teaching non-Title I students – even though most of Detroit is schoolwide some schools are not (no plan submitted) and OIG looked to these schools and found staff being funded that were teaching non-Title I identified students. Detroit argued they could have been schoolwide if they did a plan and the OIG rejected this argument Over $21 M for adjusting entries for employees that were charged to other programs and then charged to Title I Gift cards they could not show got to students $150,000 for martial arts training

125 Fiscal News from Washington OIG Audit-St. Louis Lost 125 Computers Serving Ineligible Schools o

126 Fiscal News from Washington OIG Audit Kiryas Joel Union Free School District Supplanted funds by charging rent to lease building for public school Couldnt Support Salaries for After School Program

127 Fiscal News from Washington Philadelphia Findings totaling $138,376,068 Unsupported salaries (some direct and some through adjusting entries) School police paid from Title I Funds Supplanting (moving company, etc) No backup for school choice charges of $1.3M Weak internal controls

128 Fiscal News from Washington Maryland – Title I ARRA Funds Findings totaling $540,013 $8,736 in gifts to staff $4,352 in Dinner Cruises in Baltimore Harbor Lack of Receipts for Expenses $200,323 in Unsupported Title I and IDEA Salaries $3,922 for tablets with no controls over them or applications that are downloaded (Items against policy – 22%)

129 Fiscal News from Washington Former Charles County Public Schools Title I Coordinator Sentenced (Maryland). The former Title I coordinator was sentenced to serve 27 months in prison and 36 months of supervised release. She was also ordered to pay more than $115,300 in restitution for theft. The former official used Title I grant funds to purchase technology items for herself, family, and friends, including computers, video games consoles, portable media players, tablet computers, and televisions.

130 Fiscal News from Washington Sandra Campbell, 57 a former Detroit Public Schools contract accountant and school board candidate, and her daughter, Domonique Campbell, 38, a Detroit Public Schools teacher, were convicted today by a federal jury in Detroit on charges of program fraud conspiracy, money laundering conspiracy, and tax charges following a five-week jury trial, United States Attorney Barbara L. McQuade announced today. The jury returned its verdict after only one-and-a-half hours of deliberations. McQuade was joined in the announcement by FBI Special Agent in Charge Robert D. Foley, III and Special Agent in Charge, Erick Martinez, Internal Revenue Service, Criminal Investigation. The evidence presented at trial established that between 2004 and 2008, Sandra Campbell and Domonique Campbell obtained in excess of $530,000 from the Detroit Public Schools through a fraudulent scheme in which orders were placed with the Campbells sham company for books and educational materials never provided to the schools. Sandra Campbell and Domonique Campbell conspired to launder the fraud proceeds and to defraud the Internal Revenue Service and failed to report the money they fraudulently obtained from the Detroit Public Schools as income on their tax returns. United States Attorney Barbara L. McQuade said, Anyone who considers stealing from our school children should take note that we are scrutinizing records and conduct, and will prosecute wrongdoers.

131 Common Audit Findings Lack of time sheets (or signature of employees/supervisors) Improper payroll distribution (not pro-rated) Purchase orders not indicating Title I (and adjusting entries to reclassify amounts)

132 Common Audit Findings Policies not being updated for current law Supplanting on purchases of non-salaried items Not spending at the schools approved in the application Not liquidating within timelines (now less than prior year)

133 Conclusion Remember: If you take the money, you are responsible for knowing the rules and regulations concerning the grant. If you need further help contact Anthony Hearn o (609) 633-2492 o

134 When in Doubt, Reach Out!! 609-943-4283 134

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