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2012 Title I, Part A/LAP Spring Workshop Office of Superintendent of Public Instruction.

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Presentation on theme: "2012 Title I, Part A/LAP Spring Workshop Office of Superintendent of Public Instruction."— Presentation transcript:

1 2012 Title I, Part A/LAP Spring Workshop Office of Superintendent of Public Instruction

2 Allowable Costs OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments Codified in 2 CFR Section 225 2

3 Purpose Provides principles and standards for determining costs for federal awards Grants Cost reimbursement contracts Other agreements with state and local governments and federally recognized Indian tribal governments 3

4 Attachment A Definitions Basic Guidelines Factors affecting allowability Reasonable costs Allocable costs Applicable credits Classification of Costs Direct and Indirect Costs 4

5 Basic GuidelinesAllowability 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 and not prohibited Conform to any limitations in the circular Be consistent and applied consistently (capital assets, direct vs. indirect cost, etc.) 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 5

6 Basic GuidelinesReasonable Costs Prudent Person Test Ordinary and necessary for operation or performance of federal award 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 6

7 Basic GuidelinesAllocable Costs Benefits the program Indirect costs 7

8 Specific Items of Cost Attachment B 8

9 Accounting Allowable Cost to establish and maintain accounting and other information system 9

10 Advertising Allowable Recruitment of personnel Procurement of goods and services Disposal of surplus materials (unless reimbursed at standard rate) For specific purposes necessary to requirements of federal award 10

11 Public Relations Allowable Specifically required by federal award (only as direct cost) Communicate specific activities or accomplishments from performance of federal award to public or press (direct cost) Necessary to liaison with news media-limited to keeping public informed on federal notices, contracts, grant awards, financial matters Unallowable All other advertising and public relations Costs of conventions, meetings or other events Costs of displays, demonstrations, exhibits Costs of meeting rooms, hospitality suites, etc. Salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, providing briefs Promotional items (models, gifts, souvenirs) Costs of advertising and PR designed to solely promote governmental unit 11

12 Advisory Councils Allowable As direct cost if authorized by federal awarding agency As indirect cost where allocable to federal awards 12

13 Alcoholic Beverages Unallowable!!! 13

14 Audit Services Allowable If performed in accordance with Single Audit Act (and OMB Circular A-133) Percentage of costs charged to federal awards for single audit may not exceed percentage derived by dividing federal funds expended by total funds expended by recipient during fiscal year Exceed only if appropriate documentation of higher costs Other audit costs must be preapproved or part of indirect cost allocation plan or rate 14

15 Electronic Data Processing Allowable But see Equipment 15

16 Bad Debts Unallowable Unless specifically provided for in federal program award regulations 16

17 Bonding Costs Allowable Costs of bonding employees and officials if in accordance with sound business practice 17

18 Budgeting Allowable Costs for development, preparation, presentation and execution of the budget 18

19 Communications Allowable Costs of telephone mail messenger, etc. 19

20 Compensation for Personal Services Allowable Comply with time and effort requirements and documentation Are reasonable for services rendered and conform to established policy of district consistently applied to both federal and non-federal employees Hired in accordance with district rules and meets merit system or other federal requirements 20

21 Contingencies Unallowable Contributions to contingency reserve for events which cannot be predicted Allowable Self-insurance reserve Pension plan reserves Post retirement health and other benefits computed with acceptable actuarial cost method 21

22 Contributions and Donations Unallowable All contributions and donations, including cash, property, and services by governmental units to others, regardless of recipient 22

23 Defense and Prosecution of Criminal and Civil Proceedings and Claims Unallowable Costs incurred in defense of any civil or criminal fraud Costs incurred by a contractor in connection with any criminal, civil or administrative proceedings commenced by the United States or a state Legal expenses for prosecution of claims against the federal government Allowable Legal expenses required to administer federal program 23

24 Depreciation and Use Allowances Allowable Use one or the other, not both for asset class Follow district policy and GAAP Unallowable Land Buildings or equipment purchased or donated by federal government or used as part of match See Circular for additional guidance 24

25 Disbursing Service Allowable Cost of disbursing funds 25

26 Employee Morale, Health and Welfare Costs Allowable Costs of health, first-aid clinics and/or infirmaries, recreational facilities, employee counseling services, employee information publications, related expenses consistent with district policy Income from any of these activities will be offset against expenses 26

27 Entertainment Unallowable Costs of entertainment, including amusement, diversion and social activities and any costs directly associated with such costs Examples: tickets to shows or sports events, meals, lodging, rentals, transportation, gratuities 27

28 Equipment and Capital Expenditures Allowable Through depreciation or use allowances, OR Charged directly Includes equipment, replacement equipment, other capital assets and improvements which materially increase the value or useful life of equipment Federal agencies may waive or delegate approval 28

29 Equipment and Capital Expenditures Equipment with acquisition cost of less then $5000 are considered supplies allowable as direct costs Change in capitalization level May continue to follow use or depreciation or amortize amount to be written off over period negotiated with cognizant agency (OSPI) Trade in for replacement equipment may be used to offset cost of new 29

30 Fines and Penalties Unallowable Unless incurred as a result of compliance with specific provisions of federal award or written instructions by awarding agency authorizing (rare) 30

31 Fundraising and Investment Management Costs Unallowable Costs of organized fund raising, including financial campaigns, solicitation of gifts and bequests, and similar expenses incurred to raise capital or obtain contributions Costs of investment counsel and staff to enhance income from investments Allowable Costs associated with pension, self-insurance or other funds which include federal participation 31

32 Gains and Losses on Disposition of Depreciable Capital Assets Allowable in year they occur as credits or charges Limited to difference between amount realized on property and the undepreciated basis Unallowable Amount depreciated, amortized, or use allowance When property given in exchange as part of the price of similar item Losses from failure to maintain insurance Substantial relocation of federal awards from a facility where federal participation to another facility prior to expiration of useful life requires federal approval Does not usually apply to United States Department of Education (ED) grants 32

33 General Government Expenses Unallowable Salaries and expenses of chief executives (superintendent's office, principals office) Salaries and expenses of school boards whether incurred for purposes of legislation or executive direction Cost of prosecutorial activities unless authorized by program regulations (rare) 33

34 Idle Facilities and Idle Capacity Unallowable unless Necessary to meet fluctuations in workload Were necessary when acquired (limit one year) Does not usually apply to ED grants 34

35 Insurance and Indemnification Allowable Costs of insurance required, approved or maintained pursuant to the federal award Costs of other insurance (allocable to program) Follow district policy and sound business practice Costs due to losses not covered due to nominal deductible insurance coverage if follow sound management practice Minor losses not covered by insurance which occur in ordinary course of operations 35

36 Insurance and Indemnification Allowable Contributions to reserve for self-insurance programs (including workers compensation, unemployment compensation, and severance pay) subject to: Type of coverage, extent of coverage and rates would have been allowed had insurance been purchased to cover the risks Earnings and investment income on reserves credited Contributions to reserves based on sound actuarial principles and updated at district biennially Other (see section 25) 36

37 Insurance and Indemnification Allowable (conditions) Actual claims paid to or on behalf of former or current employees must be allowable in the year of payment Consistent policy followed Allocated as general administrative expense to all activities of district Insurance refunds must be credit against costs Only to extent provided in federal award 37

38 Insurance and Indemnification Unallowable Costs of insurance or contributions to a reserve covering risk of loss of or damage to federal government property unless agency has specifically required or approved Actual losses which could have been covered by permissible insurance Cost of commercial insurance that protects against costs of contractor for contractors defects in materials or workmanship 38

39 Interest Unallowable Costs incurred for interest on borrowed capital or the use of districts own funds Allowable Financing costs of allowable costs of building acquisition, construction, reconstruction or remodeling if Financing from bona fide third party external to district Assets used in support of federal awards Earnings on debt service reserve and interest offset 39

40 Lobbying Unallowable!!! 40

41 Maintenance, Operations and Repairs Allowable, if Not prohibited by law Keeps property in efficient operating condition Does not add to value or prolong life of property Are not included in rental or charges for space Costs which add to permanent value or prolong life should be treated as capital expenditures 41

42 Materials and Supplies Allowable Charge actual price after deducting discounts, rebates and allowances Stockroom withdrawals at cost Incoming transportation charges are part of materials and supplies costs 42

43 Memberships, Subscriptions and Professional Activities Allowable Districts memberships in business, technical, and professional organizations Districts subscriptions to business, technical and professional periodicals Meetings and conferences where primary purpose is dissemination of technical information (includes meals, transportation, rental of meeting facilities and incidental costs) Membership in civic and community social organizations with approval of federal agency 43

44 Memberships, Subscriptions and Professional Activities Unallowable Membership in organizations substantially engaged in lobbying 44

45 Motor Pools Allowable Costs of service organization which provides automobiles to district at a mileage or fixed rates and/or provides vehicle maintenance, inspection, and repair services 45

46 Pre-Award Costs Unallowable, unless Necessary to comply with the proposed delivery schedule or period of performance Only to extent they would have been allowable if incurred after award date Only with written approval of awarding agency 46

47 Professional Service Costs Allowable Professional and consultant services, including retainer fees, by persons or organizations that are members of a particular profession or possess a special skill, if Reasonable Not contingent upon recovery of costs from the federal government Unallowable Defense and prosecution of criminal and civil proceedings and claims 47

48 Proposal Costs Allowable Costs to prepare proposals for potential federal awards Treat as indirect costs unless prior approval of federal awarding agency 48

49 Publication and Printing Costs Allowable Must be reasonable and allocable 49

50 Rearrangements and Alterations Allowable Ordinary and normal rearrangement and alteration of facilities Special arrangements and alterations specified in the federal award or with prior approval 50

51 Reconversion Costs Allowable Restoration or rehabilitation of districts facilities to approximately same condition immediately prior to federal awards, less costs related to normal wear and tear 51

52 Rental Costs Allowable Must be reasonable Sale and lease back arrangements limited to what it would have cost if district owned the property Less than arms length transactions limited to amount if district had title to property Rental costs under leases must be treated as capital leases under GAAP (follow FASB Stmt 13) See interest section 52

53 Taxes Allowable If legally required Gasoline taxes, motor vehicle fees other taxes which are user fees for benefits to federal program Unallowable Self-assessed taxes and/or policies that disproportionately affect federal programs If deemed inappropriate by federal agency 53

54 Training Allowable Reasonable for professional development of employees 54

55 Travel Costs Allowable Transportation, lodging, subsistence, and related items for employees on official business May be charged based on actual cost, per diem or combination in accordance with district policy Travel costs for general government employees are allowable when specifically related to federal awards All charges must be reasonable and not exceed normally allowed costs 55

56 Travel Costs Unallowable Costs in excess of normal costs permitted by district policy (use federal guidance if no district policy) Commercial airfare must be coach rate or equivalent Non-commercial air travel is generally not allowable 56

57 Underrecovery of Costs under Federal Agreements Unallowable Excess costs over federal contribution of one award are not permitted to be charged to other awards 57

58 Time and Effort Reporting 58

59 Where is the Requirement? Time and effort reporting is required under the Federal Office of Management and Budgets Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments Attachment B, Selected Items of Cost, Item 11, Compensation for personnel services 59

60 When is Time and Effort Required? Time and effort reporting is required when any part of an individuals salary is charged to a federal program Charge may be direct or indirect 60

61 What type of reporting is needed? Single cost objective Semi annual certification Multiple cost objectives Monthly time reports or Personnel Activity Reports (PARs) 61

62 What is a cost objective? Work activities allowable under the terms and conditions of one or more funding sources 62

63 What are some examples of a single cost objective? 100% charged to a single federal program activity Federal Special Education and State Special Education Schoolwide program Multiple activities in a single federal program 63

64 What are some examples of multiple cost objectives? Salary charged to more than one set aside activity in a single federal program (e.g., parent involvement, professional development) Salary charged partially to federal program and partially to state and/or local sources Salary charged partially to sources combined into a schoolwide program and partially to those not included 64

65 What is a semi annual certification? Statement individual(s) worked solely on activities related to single cost objective Completed at least every six months Signed by employee or supervisor with first-hand knowledge of work performed 65

66 What is a monthly time report? (PAR) Must account for total contracted compensated hours Must be prepared at least monthly Must be signed by employee May also be signed by supervisor Must reflect actual work performed (not budget) Must agree with supporting documentation (e.g., calendar) 66

67 When are adjustments to actual made? If payroll is initially based on budgeted or estimated time, payroll and time and effort reports must be reconciled at district quarterly If the difference is 10% or more Payroll records must be adjusted to match actual time worked Following quarters payroll estimates must be adjusted 67

68 What time and effort is reported? Report time actually worked in a specific activity not time budgeted for that activity Budgets are reconciled to actual at least quarterly. 68

69 Who should sign the reports? Monthly reports (PARs) must be signed by the employee Semi annual certifications may be signed by either employee or supervisor having first-hand knowledge of work performed For internal control purposes, districts may require both the employee and supervisor to sign 69

70 What type of supporting documentation is needed? Documentation is VERY important. Examples include, but are not limited to: Class schedules Number of students Number of minutes Remember DOCUMENT! DOCUMENT! DOCUMENT! 70

71 Supplemental Contracts, Stipends, Extra Hours Primary contract and additional contracts may be considered separately Based upon whether or not charged to federal program Time and effort may be required for primary contract but not supplemental (or vice versa) 71

72 Administrators Superintendent, assistant superintendent, principal, assistant principal usually not allowable charge to federal program Generally presumed to be a supplant issue Requires good documentation to rebut supplant presumption Other administrators (e.g., federal program directors) may be charged to federal program(s) based on time and effort Supporting documentation must be maintained 72

73 Schoolwide Programs Schoolwide plan must specify programs to be included (not all programs may be included) A schoolwide program is a single cost objective If employee works 100% on programs combined Semi annual certification If employee works partially on programs combined and partly on those not combined, Monthly time report (PAR) 73

74 Schoolwide Program 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 74

75 What is a substitute system? An alternative method for determining and reporting time and effort based on statistical sampling of work performed Must be approved by OSPI prior to use Jennifer Carrougher ( is responsible for approval (as well as any revisions) Should be periodically reviewed to determine if still appropriate Any revision of a previously approved substitute system must be submitted to OPSI for approval prior to use 75

76 For Additional Information OSPI Bulletin 051-11 (Time and Effort Reporting) Examples Sample forms OSPI Bulletin 050-11 (Combining Funds in Schoolwide Programs) OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments (2 CFR Section 225) 76

77 COMBINING FUNDS IN SCHOOLWIDE PROGRAMS Schoolwide-Systematic Reform Based Model 77

78 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 78

79 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 79

80 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 80 Step 2

81 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 81

82 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 82

83 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 83

84 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 84

85 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 85

86 Supplement not Supplant Met in schoolwide program by documenting each school operating a schoolwide program receives all the state and local funds it would otherwise receive to operate its educational program in the absence of Title I, Part A or other federal education funds This includes funds required for Special Education and ELL students 86

87 Use correct order 1.Determine which funds will be combined 2.Address intents and purposes in the plan 3.Meet and document intents and purposes 4.Determine how to charge 87

88 Fiscal flexibility Examples of ways to charge consolidated funds Charge proportionately based on revenue Charge sequentially Charge based on activity (not use flexibility) 88

89 Federal No Child Left Behind (NCLB) Waiver and Washington State What does this mean for Washington State SES? 89

90 1.College- and Career-Ready Expectations for All Students 2.State-Developed Differentiated Recognition, Accountability, and Support 3.Supporting Effective Instruction and Leadership 4.Reducing Duplication and Unnecessary Burden Principles For Improving Student Achievement and Increasing the Quality of Instruction 90

91 1.The requirements in the Elementary and Secondary Education Act (ESEA) Section 1111(b)(2)(E)-(H) that prescribe how a State Education Agency (SEA) must establish annual measurable objectives (AMOs) for determining adequate yearly progress (AYP) to ensure that all students meet or exceed the states proficient level of academic achievement on the states assessments in reading/language arts and mathematics no later than the end of the 2013–2014 school year The SEA requests this waiver to develop new ambitious but achievable AMOs in reading/language arts and mathematics in order to provide meaningful goals that are used to guide support and improvement efforts for the state, districts, schools, and student subgroups 91 ESEA Flexibility Request-Waiver 1

92 2.The requirements in the ESEA Section 1116(b) for a district to identify for improvement, corrective action, or restructuring, as appropriate, a Title I, Part A school that fails, for two consecutive years or more, to make AYP, and for a school so identified and its district to take certain improvement actions The SEA requests this waiver so that a district and its Title I, Part A schools need not comply with these requirements ESEA Flexibility Request-Waiver 2 92

93 3.The requirements in ESEA Section 1116(c) for an SEA to identify for improvement or corrective action, as appropriate, a district that, for two consecutive years or more, fails to make AYP, and for a district so identified and its SEA to take certain improvement actions The SEA requests this waiver so that it need not comply with these requirements with respect to its districts ESEA Flexibility Request-Waiver 3 93

94 4.The requirements in ESEA sections 6213(b) and 6224(e) that limit participation in, and use of funds under the Small, Rural School Achievement (SRSA) and Rural and Low-Income School (RLIS) programs based on whether a district has made AYP and is complying with the requirements in ESEA Section 1116 The SEA requests this waiver so that a district that receives SRSA or RLIS funds may use those funds for any authorized purpose regardless of whether the district makes AYP ESEA Flexibility Request-Waiver 4 94

95 Implementation of School Improvement Requirements Flexibility from requirement for school districts to identify or take improvement actions for schools identified for improvement, corrective action, or restructuring Eliminates Public School Choice (PSC) as a mandate Eliminates Supplemental Educational Services (SES) as a mandate Eliminates the 20 percent district Title I, Part A set aside to fund PSC and SES Eliminates the 10 percent set aside for professional development for schools Flexibility to Improve Student Achievement and Increase the Quality of Instruction 95

96 Priority schools: Identify lowest-performing schools and implement interventions aligned with the turnaround principles Focus schools: Identify and implement interventions in schools with the largest achievement gaps or low graduation rates among subgroups Priority and Focus Schools 96

97 What is a Priority school? At least the lowest five percent of Title I, Part A schools based on all students performance on state assessments Title I, Part A- participating and Title I, Part A- eligible high schools with < 60 percent graduation rate We propose to use the Washington Achievement Index to identify lowest performing schools (rather than just reading and math) Districts with priority schools ensure the schools implement turnaround principles using a set-aside of up to 20 percent of district Title I, Part A funds Priority Schools 97

98 What is a focus school? At least 10 percent of Title I, Part A schools with the lowest subgroup achievement and biggest gaps among subgroups; may also include non-Title I, Part A schools (middle or high performing, non low income schools with large achievement gaps) Proposing: update the Washington Accountability Index to include each subgroup separately Districts with focus schools must implement a plan to improve the performance of subgroups who are furthest behind using a set-aside of up to 20 percent of district Title I, Part A funds Focus Schools 98

99 5.The requirement in ESEA Section 1114(a)(1) that a school have a poverty percentage of 40 percent or more in order to operate a schoolwide program The SEA requests this waiver so that a district may implement interventions consistent with the turnaround principles or interventions that are based on the needs of the students in the school and designed to enhance the entire educational program in a school in any of its priority and focus schools that meet the definitions of priority schools and focus schools, respectively, set forth in the document titled ESEA Flexibility, as appropriate, even if those schools do not have a poverty percentage of 40 percent or more ESEA Flexibility Request-Waiver 5 99

100 6.The requirement in ESEA Section 1003(a) for an SEA to distribute funds reserved under that section only to districts with schools identified for improvement, corrective action, or restructuring The SEA requests this waiver so that it may allocate Section 1003(a) funds to its districts in order to serve any of the states priority and focus schools that meet the definitions of priority schools and focus schools, respectively, set forth in the document titled ESEA Flexibility ESEA Flexibility Request-Waiver 6 100

101 ESEA Flexibility Request-Waiver 7 7.The provision in ESEA Section 1117(c)(2)(A) that authorizes an SEA to reserve Title I, Part A funds to reward a Title I, Part A school that (1) significantly closed the achievement gap between subgroups in the school; or (2) has exceeded AYP for two or more consecutive years The SEA requests this waiver so that it may use funds reserved under ESEA Section 1117(c)(2)(A) for any of the states reward schools that meet the definition of reward schools set forth in the document titled ESEA Flexibility. 101

102 8.The requirements in ESEA Section 2141(a), (b), and (c) for a district and SEA to comply with certain requirements for improvement plans regarding highly qualified teachers The SEA requests this waiver to allow the SEA and its districts to focus on developing and implementing more meaningful evaluation and support systems ESEA Flexibility Request-Waiver 8 102

103 9.The limitations in ESEA Section 6123 that limit the amount of funds an SEA or district may transfer from certain ESEA programs to other ESEA programs The SEA requests this waiver so that it and its districts may transfer up to 100 percent of the funds it receives under the authorized programs among those programs and into Title I, Part A ESEA Flexibility Request-Waiver 9 103

104 10.The requirements in ESEA Section 1003(g)(4) and the definition of a Tier I school in Section I.A.3 of the School Improvement Grants (SIG) final requirements The SEA requests this waiver so that it may award SIG funds to a district to implement one of the four SIG models in any of the states priority schools that meet the definition of priority schools set forth in the document titled ESEA Flexibility NOTE: Waiver number 11 was NOT requested ESEA Flexibility Request-Waiver 10 104

105 12.The requirements in ESEA Sections 1116(a)(1)(A)-(B) and 1116(c)(1)(A) that require districts and SEAs to make determinations of AYP for schools and districts, respectively. The SEA requests this waiver because continuing to determine whether a district and its schools make AYP is inconsistent with the SEAs state-developed differentiated recognition, accountability, and support system included in its ESEA flexibility request The SEA and its districts must report on their report cards performance against the AMOs for all subgroups identified in ESEA Section 1111(b)(2)(C)(v), and use performance against the AMOs to support continuous improvement in Title I, Part A schools that are not reward schools, priority schools, or focus schools Optional Flexibilities-Waiver 12 105

106 13.The requirements in ESEA Section 1113(a)(3)-(4) and (c)(1) that require a district to serve eligible schools under Title I, Part A in rank order of poverty and to allocate Title I, Part A funds based on that rank ordering The SEA requests this waiver in order to permit its districts to serve a Title I, Part A-eligible high school with a graduation rate below 60 percent that the SEA has identified as a priority school even if that school does not rank sufficiently high to be served Optional Flexibilities-Waiver 13 106

107 Waiver Resources Summary of ESEA Flexibility Request Flexibility Request FAQs 107

108 Resource Links OMB Circular A-87Allowable Costs (Codified as 2 CFR 225) OMB Circular A-102 Grants and Cooperative Agreements with State and Local Governments OMB Circular A-133Audit Requirements and the related Compliance Supplement 34 CFR 80Administrative Requirements 34 CFR 76Requirements for grants passed to districts through the state agency, OSPI idx?c=ecfr&tpl=/ecfrbrowse/Title34/34cfr76_main_02.tpl idx?c=ecfr&tpl=/ecfrbrowse/Title34/34cfr76_main_02.tpl 108

109 Director, Gayle Pauley: Program Supervisors Petrea Stoddard: Mary Jo Johnson: Reginald Reid: Jamilyn Penn: John Pope: Larry Fazzari: Bill Paulson: Administrative Support Julie Chace: Tony May: OSPI Title I, Part A/LAP Contacts 109

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