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Title I/LAP Spring Workshop

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1 Title I/LAP Spring Workshop
Office of Superintendent of Public Instruction 2009

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

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

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

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

6 Basic Guidelines—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

7 Basic Guidelines—Reasonable 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

8 Basic Guidelines—Allocable Costs
Benefits the program Indirect costs

9 Specific Items of Cost Attachment B

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

11 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

12 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

13 Public Relations 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

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

15 Alcoholic Beverages Unallowable!!!

16 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 diving 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.

17 Electronic Data Processing
Allowable But see Equipment

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

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

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

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

22 Compensation for Personal Services
Allowable If follow 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.

23 Contingencies Unallowable Allowable
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.

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

25 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.

26 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

27 Disbursing Service Allowable Cost of disbursing funds.

28 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.

29 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

30 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.

31 Equipment and Capital Expenditures
Equipment with acquisition cost of less then $5,000 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

32 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).

33 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.

34 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 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.

35 Gains and Losses on Disposition of Depreciable Capital Assets
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 ED grants

36 General Government Expenses
Unallowable Salaries and expenses of chief executives (superintendent's office, principal’s 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)

37 Idle Facilities and Idle Capacity
Unallowable unless Necessary to meet fluctuations in workload Were necessary when acquired (limit 1 year) Does not usually apply to ED grants

38 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

39 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 has 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 districtst biennially Other (see section 25)

40 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

41 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 contractor’s defects in materials or workmanship.

42 Interest Unallowable Costs incurred for interest on borrowed capital or the use of district’s 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

43 Lobbying Unallowable!!!

44 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

45 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.

46 Memberships, Subscriptions and Professional Activities
Allowable Districts memberships in business, technical, and professional organizations. District’s 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.

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

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

49 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.

50 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.

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

52 Publication and Printing Costs
Allowable Must be reasonable and allocable.

53 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.

54 Reconversion Costs Allowable
Restoration or rehabilitation of district’s facilities to approximately same condition immediately prior to federal awards, less costs related to normal wear and tear.

55 Rental Costs Allowable Must be reasonable.
Sale and district back limited to what it would have cost if district owned the property. Less than arm’s length transactions limited to amount if district had title to property. Districts must be treated as capital districts under GAAP (follow FASB Stmt 13). See interest section.

56 Taxes Allowable Unallowable 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.

57 Training Allowable Reasonable for professional development of employees.

58 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.

59 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.

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

61 Time and Effort Reporting

62 Where is the Requirement?
Time and effort reporting is required under the 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, Item 11, Compensation for personnel services

63 When is Time and Effort Required?
Time and effort reporting is required when any part of an individual’s salary is charged to a federal program. Charge may be “direct” or “indirect”.

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

65 What is a cost objective?
Work activities allowable under the terms and conditions of a funding source

66 What are some examples of a single cost objective?
100% charged to a single federal program activity Exceptions Title I, Part A and LAP. Federal Special Education and State Special Education. Schoolwide programs. Multiple activities in a single federal program.

67 What are some examples of multiple cost objectives?
Salary charged to more than one activity in a single federal program 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

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

69 What is a monthly time report? (PAR)
Accounts for total activity Prepared at district monthly Signed by employee Reflects actual work performed (not budget) Agrees to supporting documentation

70 When are adjustments to actual made?
If payroll is initially based on budgeted or estimated time/amounts, payroll and time and effort reports must be compared at districts quarterly If the difference is 10% or more and any needed adjustments made Payroll records must be adjusted to actual Following quarter’s estimates must be adjusted

71 What time and effort is reported?
Report time actually worked in a specific activity not time budgeted Budgets are reconciled to actual at districts quarterly

72 Who should sign the reports?
Monthly reports (PARs) should be signed by the employee Semi annual certifications should 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

73 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!

74 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).

75 Administrators Superintendent, assistant superintendent, principal, assistant principal usually not allowable charge to federal program Requires good documentation to support. Could be a supplant issue.

76 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).


78 What is a substitute system?
Other method for determining time and effort report based on sample of work performed Must be approved by OSPI prior to use JoLynn Berge is responsible for approval Must be statistically sound Should be periodically reviewed to determine if still appropriate

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

80 Fiscal Requirements

81 District Requirement Section 1120A(a) and 9521 of NCLB 34 CFR 299.5
Maintenance of Effort District Requirement Section 1120A(a) and 9521 of NCLB 34 CFR 299.5

82 Maintenance of Effort The district has maintained fiscal effort if either The combined fiscal effort per student or The aggregate (total of included) expenditures of the district were at districts 90% of that of the preceding year. This shows the district maintained its non-federal funding within 90%.

83 Maintenance of Effort “Preceding fiscal year” = the federal fiscal year or the 12 month fiscal period used for reporting purposes prior to the beginning of the federal fiscal year in which funds become available. Example: For funds available July 1, 2009 Preceding fiscal year is 2003 (SY ) Second preceding fiscal year is 2002 (SY ) Third preceding fiscal year is 2001 (SY )

84 Maintenance of Effort Expenditures included for MOE Administration
Instruction Attendance and health service personnel Pupil transportation services Operation and maintenance of building Fixed charges Net expenditures to cover deficits for food services and student body activities

85 Maintenance of Effort Expenditures excluded for MOE Community services
Capital outlay Debt service Supplemental expenses made pursuant to a disaster declared by the President of the USA Any expenditures made for funds provided by the federal government

86 Maintenance of Effort When a district does not meet the maintenance of effort test its allocation is reduced in the exact proportion by which it fell below 90% (combined fiscal effort per student and aggregate expenditures) The measure most favorable to the district is used

87 Maintenance of Effort In determining maintenance of effort for the year following a failure to maintain effort, OSPI considers the district’s expenditures in the year the failure occurred to be 90% of the expenditures for the third preceding year. OSPI does not use the expenditures for the year in which the failure occurred.

88 Maintenance of Effort District may apply to the US Department of Education for a waiver for Exceptional or uncontrollable circumstances, such as a natural disaster, or Precipitous decline in the financial resources of the district.

89 Supplement Not Supplant
Considers services Section 1120A(b) and (d) of NCLB 34 CFR

90 Supplement Not Supplant
Targeted Assistance Schools Title I funds must be used only to supplement the level of funds that would, in the absence of Title I, be available from non federal (state and local) sources for Title I students The district is not required to provide Title I services using a particular instructional method (i.e. pull out programs, in class, etc.) Based on services

91 Supplement Not Supplant
Program meets the intent and purposes of a Title I program in a targeted assistance program if It serves only children who are failing or most at risk of failing to meet the state’s performance standards. It provides supplementary services designed to meet the educational needs of the children who are participating in the program. It uses the state’s assessment system to review the effectiveness of the program.

92 Supplement Not Supplant
Targeted Assistance Buildings Presumptions 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. Rebuttals may be possible

93 Supplement Not Supplant
Exclusions The district may exclude supplemental state or local funds expended in any school for programs that meet the intent and purposes of Title I, Part A (e.g., Learning Assistance Program)

94 Supplement Not Supplant
Schoolwide Program Schools Must use Title I funds only to supplement the amount of funds that would, in the absence of Title I funds, be made available for that schoolwide program (including funds needed to provide services required by law for disabled children and LEP children) Similar to MOE

95 Supplement Not Supplant
Program meets the intent and purposes of Title I in a schoolwide program if: It is implemented in a school with 40% or more poverty. It is designed to promote schoolwide reform and upgrade the entire educational operation of the school. It is particularly designed to meet the educational needs of at-risk students. It uses the state’s assessment system to review the effectiveness of the program.

96 Comparability Building level Section 1120A(c) and (d) 34 CFR OSPI Bulletin

97 Comparability A district may receive Title I, Part A funds only if it uses state and local funds to provide services in Title I schools that, taken as a whole, are at district comparable to services provided in non-Title I schools.

98 Comparability If all schools in the district are Title I schools, the district must use state and local funds to provide services that, taken as a whole, are substantially comparable in each school.

99 Comparability Comparability is met if the district provides written assurance it has established and implemented A district wide salary schedule A policy to ensure equivalence among schools in teachers, administrators, and other staff A policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies

100 Comparability Alternative criteria
The district may meet the comparability requirement if it establishes and implements other measures for determining compliance such as student/teacher rations, student/instructional staff salary ratios or total expenditures per school. Staff salary differentials for years of employment may not be included in comparability determinations. The district need not include unpredictable changes in student enrollment or personnel assignments that occur after the beginning of a school year.

101 Comparability Documentation Report comparability each year on iGrant 361. The district must develop procedures/policies for meeting the comparability requirement and maintain records that are updated at district biennially.

102 Comparability Exclusions
Bilingual education for children of limited English proficiency (State Transitional Bilingual). Excess costs of providing services to children with disabilities (State Special Education). Supplemental state and local funds spent for programs that meet the intent and purposes of Title I, Part A (LAP).

103 Targeted Assistance and Schoolwide Programs

104 Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs Targeted Assistance Programs target Title I, Part A services to the students at greatest risk of not meeting the state’s student academic achievement standards Students Pre-K through grade 12 are eligible for Title I, Part A services

105 Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs Building staff must decide what content areas (Reading, Math, Language Arts, etc.) and grade levels to be served with Title I, Part A funds Decision based on greatest need

106 Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs Students in the identified subject areas and grade levels are selected for Title I, part A services based on “…multiple, educationally related, objective criteria established by the local educational agency and supplemented by the school” This usually means the use of results from standardized tests, parent request, grade level academic performance, teacher and other administrative recommendations, and other discretionary criteria

107 Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs A composite score can be developed using the test results, classroom performance and teacher recommendations The students’ names are then rank-ordered, by subject area and grade level, on a list beginning with the most at-risk students The district and/or building Title I staff then determine how many students can be served based on the amount of Title I, Part A funds that have been allocated to the building

108 Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs Instructional programs are then developed to meet the academic needs of the most at-risk students Students who qualify for services can be homeless, migrant, special education students, and former Head Start, Even Start and Early Reading First students who participated in those programs within the past two years The Title I, Part A staff then must decide whether the services will be delivered via an in-class or pullout model, or a combination of both

109 Pullout and In-Class Instructional Delivery Models
Targeted Assistance Programs Title I, Part A regulations strongly encourage minimizing the removal of students from the regular classroom to provide Title I, Part A services Extended learning opportunities (before and after school, Saturday school, summer programs) are also encouraged

110 Targeted Assistance and Schoolwide Programs
Designed for schools with 40% or higher poverty Requires a year of planning A schoolwide plan, which includes ten (10) required components, must be completed The plan must include the names and the dollar amounts of the federal and state programs that have been combined into the schoolwide program

111 Targeted Assistance and Schoolwide Programs
The schoolwide program must address the intent and purpose of each of the federal programs that have been included in the program Schoolwide programs must still meet all requirements relating to health, safety, civil rights, student and family participation and involvement, services to private school children, maintenance of effort, and comparability of services

112 Targeted Assistance and Schoolwide Programs
Although all students in the schoolwide program are eligible for Title I, Part A services, the students who are at greatest risk of not meeting the state academic achievement standards are the main focus Annual evaluation of the program/plan effectiveness is required

113 New Regulations November 2008

114 NEW Notification Districts must notify parents of students about public school choice options no later than 14 calendar days before the start of the school year. [34 CFR (b)(4)(iv) & 34 CFR (a)(2)]

115 NEW Parent Outreach A district may count in the amount required for choice-related transportation and SES (20% obligation) the cost for parent outreach and assistance to meet these requirements. A district may count up to an amount equal to 0.2% of the district’s Title I, Part A allocation (1% of the 20% obligation). Examples of allowable costs include Parent notices Communication through the media, internet, and community partners Displaying information on the district’s website Parent fairs [34 CFR (a)(2)(iii)(C)

116 NEW Student information The district must prominently display on its website, in a timely manner: The number of students who were eligible for and the number of students who participated in public school choice and SES, beginning with data from the school year and each subsequent school year. For the current school year, a list of SES providers approved by the state to serve the district and the locations where services are provided. For the current school year, a list of available schools to which students eligible to participate in public school choice may transfer. [34 CFR (c)(1)]

117 Transparency for Parents
NEW Transparency for Parents For each district, states must post on their Web sites The amount of funds available for choice-related transportation and SES as required in §200.48(a)(2) (the 20% obligation). The per-child amount for SES as calculated under §200.48(c)(1). States must indicate on the list of approved providers those SES providers that are able to serve students with disabilities or those students are limited English proficient [§200.47(a)(3)(iii)].

118 To spend less than the amount needed to meet the 20% obligation, a district must meet, at a minimum, the following criteria: Partner, to the extent practicable, with outside groups, such as faith-based organizations, other community-based organizations, and business groups, to help inform eligible students and their families of opportunities to transfer or to receive SES [§200.48(d)(2)(i)(A)]. Ensure that eligible students and their parents have a genuine opportunity to sign up to transfer or to obtain SES, including: Providing timely, accurate notice to parents. Ensuring that sign-up forms for SES are distributed directly to all eligible students and their parents, and are made widely available and accessible through broad means of dissemination, such as the Internet, other media, and communications through public agencies serving eligible students and their families [§ & §200.37].

119 Ensure that eligible students and their parents have a genuine opportunity to sign up to transfer or to obtain SES, including by: Providing a minimum of two enrollment “windows,” at separate points in the school year, that are of sufficient length to enable parents of eligible students to make informed decisions about requesting SES and selecting a provider [§200.48(d)(2)(i)(B)]. Ensure that eligible SES providers are given equal access to school facilities, using a fair, open and objective process, on the same basis and terms as are available to other groups that seek access to school facilities [§200.48(d)(2)(i)(C)]

120 District Responsibilities to Document and Notify the State
NEW District Responsibilities to Document and Notify the State To spend less that the amount needed to meet its 20% obligation, an district must: Maintain records demonstrating that it has met the criteria in §200.48(d)(2)(ii), and Notify the state that it: Has met the criteria in §200.48(d)(2)(i); and Intends to spend the remainder of its 20% obligation on other allowable activities, specifying the amount of that remainder [§200.48(d)(2)(iii)].

121 Consequences for Non-Compliance
NEW Consequences for Non-Compliance If a state determines that an district has failed to meet any of the criteria in §200.48(d)(2)(i), the district must: Spend an amount equal to the remainder of its 20% obligation in the subsequent year, in addition to its 20% obligation for that year, on choice-related transportation costs, SES, or parent outreach and assistance, or Meet the criteria and obtain permission from the state before spending less than the required amount in that subsequent school year. The state must confirm the district’s compliance with the criteria before granting such permission [§200.48(d)(4)].

122 American Recovery and Reinvestment Act (ARRA)

123 Education Stabilization Funds
Two types Funds that go to the Governor Based on set formula To address shortfall in K-12 and Higher Education Leftover, if any, divided proportionally between school districts based on proportion of Title I, Part A funding formula Note: These are NOT Title I, Part A funds May be spent on ESEA, IDEA, Perkins, Building Modernization

124 Education Stabilization Funds
Funds that go to the USED To be distributed as Targeted and EFIG Title I, Part A funds These ARE Title I, Part A funds Other School Improvement McKinney-Vento Homeless Education IDEA Early Childhood Educational Technology—Title II, Part D Innovation and Improvement (Teacher Incentive)

125 Education Stabilization Funds
One Time Funding Give careful thought to efficient and effective use Staffing may not be best use since cannot be sustained Possible uses Summer school Professional development activities Additional curriculum Tutoring 30 month availability

126 Education Stabilization Funds
Consider pitfalls Supplement Not Supplant Maintenance of Effort Comparability Carryover Sustainability

127 Education Stabilization Funds
Set asides will apply Parent involvement Professional development due to not making AYP Private school equitable share Set asides may apply Supplemental Educational Services Choice for public school transportation

128 CPR Issues Title I, Part A
District Parent Involvement Policy is current and contains all required components Building Parent Involvement is current and contains all required components Notice to parents they may request information regarding professional qualification of student’s classroom teacher District report card to parents Instructional paraprofessionals must be under the direct supervision of a certificated teacher

129 Schoolwide plan must contain all ten components.
Matrix of funding sources Intent and purposes of combined program funds Targeted Assistance Model Evidence of eight components Rank order list Evidence of entrance and exit

130 CPR Issues Learning Assistance Program (LAP)
Eligibility of students. Evidence that only students achieving below state and district assessments are served. Accelerated student learning plans contain all four components. Expanded learning opportunities for grades eight, eleven and twelve.

131 CPR Issues Fiscal Maintenance of Effort Reconciliation of T/E to budget Capital Asset Policy Small and Attractive Procurement Personal Service Contracts (Sole Sourcing)

132 CPR Issues Set- Aside Compliance
Set-Aside /Earmarks on iGrants Separate Sub-codes Track Expenditures Ranking of allocations

133 iGrant Revisions Title I, Part A
iGrant Package 201: Title I, Part A (Regular Year) Request for Substantial Approval: (The following pages only to be completed for SA.) Complete Page 1 (Request for SA and complete matrix for preliminary budget)) Complete Page 2 (Assurances) Complete Page 3 (Plan) Page 2: Program Narrative Q 1: Types of additional assistance-Summer School box indicated requires completions iGrant 465) Q 8: Updated link to N/D facilities Q 14-15: Change in order of District and Building Parent Involvement policy questions Page 3: Set-Aside Page A 3: Update link to N/D Facilities E. Schoolwide Programs: Eliminate box Public School Page: Remove box on profile: Number of years in Schoolwide

134 iGrant Revisions Title I, Part A
iGrant Package 244: Title I, Part A (End of Year) Regular Year Section 1A, 1B, 1C, 1D, 1E: Added in unduplicated count: Category: Not Identified Category Section IIIB: Instructional Program- Social Studies deleted

135 iGrant Revisions Title I, Part A
iGrant Package 246: Title I, Part A (End of Year) Summer School Section 1A, 1B, 1C, 1D, 1E: Added in unduplicated count: Category: Not Identified Category Section IIB/IIC: Instructional Program Social Studies deleted Section IIID: Program Staff Data Delete # 7 Other (e.g. volunteers)

136 iGrant Revisions Title I, Part A
iGrant Package 246: Title I, Part A (Summer School Program Application) Page 1: Program Description Page 2: Program Staff data

137 iGrant Revisions Learning Assistance Program (LAP)
iGrant Package 218: Learning Assistance Program (Regular Year) Application changes may vary depending on legislative decisions. iGrant Package 245: Learning Assistance Program (End of Year) Regular Year Section IB: Student Data: Count for race/ethnicity Not Identified

138 iGrant Revisions Learning Assistance Program (LAP)
iGrant Package 247: Learning Assistance Program (EOY) Summer School Section IB: Unduplicated count by race/ethnicity Added Not Identified category iGrant Package 466: Learning Assistance Program (Summer School Application) Page 1: Program Description Page 2: Program Staff data

139 Questions ?????????

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