1. M AINTENANCE OF E FFORT & C OMPARABILITY R EPORT Teresa Scott Director-Grant Management Albuquerque Public Schools scott_teresa@aps.edu NM ASBO Fall Conference Los Vaqueros Room September 13, 2012 1:30pm – 3:00pm Please silence electronic devices

2. C HANGING THINGS FROM THE W INTER C ONFERENCE

3. A F EW L AWFUL R EMINDERS Supplement not Supplant State & Local expenditures for Students with disabilities must remain equal to or greater than the expenditures for same in the previous year in total or per capita (IDEA-B MOE) Demonstrating comparability is a prerequisite for receiving Title I, Part A funds. Because Part A allocations are made annually, comparability is an ANNUAL requirement. Handouts with more technical language provided.

4. IDEA B M AINTENANCE O F E FFORT

5. E XPENSE OBJECT TO INCLUDE 53211 Diagnosticians – Contracted 53212 Speech Therapists – Contracted 53213 Occupational Therapists – Contracted 53214 Physical/Recreational Therapists – Contracted 53215 Psychologists/Counselors – Contracted 53216 Audiologists – Contracted 53217 Interpreters – Contracted 53218 Specialists – Contracted 53219 Special Ed Assistants (Non-Instructional) – Contracted

6. E XPENSE OBJECT TO INCLUDE Job codes under the Object 51100, 51200, 51300 1311 Diagnosticians 1312 Speech Therapists 1313 Occupational Therapists 1314 Physical/Recreational Therapists 1315 Psychologists/Counselors 1316 Audiologists 1317 Interpreters 1318 Specialists 1319 Special Ed Assistants (Non-Instructional) 1412 Teachers – Special Education 1712 Instructional Assistants – Special Education

7. Account Descriptions09-10 Expenses10-11 Expenses11-12 Expenses 1412SPED Teach-Salary $ 59,875,583 $ 60,213,239 $ 60,119,071 1412SPED Teach-Stipend $ 450,092 $ 635,101 $ 63 1712SPED EA-Salary $ 14,715,908 $ 14,984,667 $ 15,177,399 1712SPED EA-Stipend $ - $ 6,048 $ - 1712SPED EA-OT $ - $ 7,715 $ 999 1621Extended School Year-Stipends $ - $ 984,248 $ 950,023 1311Diags $ 6,647,223 $ 5,595,561 $ 6,072,520 1312Speech-Lang Path $ 10,766,890 $ 9,575,011 $ 8,761,646 1313OT $ 4,002,303 $ 3,889,012 $ 3,655,682 1314PT $ 1,874,149 $ 1,880,772 $ 1,764,230 1315School Psychs $ - $ 1,266,635 $ 1,380,945 1316Audiol $ 742,825 $ 697,769 $ 656,768 1317Interp $ 956,975 $ 967,391 $ 976,180 1318O&M $ 105,790 $ 106,612 $ 94,963 1319Interp non sp ed $ - $ 4,145 $ - 53711Contract - ESY buses $ - $ 427,371 $ 531,447 53211Diags-Contracted $ - 53212Speech-Lang Path-Contracted $ - 53213OT-Contracted $ - 53214PT-Contracted $ - 53215Psych/Counselor-Contracted $ - 53216Audio-Contracted $ - 53217Interp-Contracted $ - 53218Specialist-Contracted $ - 53219SPED Asst-Non Inst-Contracted $ - $ 2,442,537 District Totals $ 100,137,738 $ 101,241,297 $ 102,584,473 District (short)/long $ 1,103,559 $ 1,343,176 Total Charters $ 2,639,335 $ 2,628,623 $ 2,893,728 Charter (short)/long $ (10,712) $ 265,105 Grand Total…. $ 103,422,917 $ 103,869,920 $ 105,478,201 Overall (short)/long $ 1,092,847 $ 1,608,281 Operational Accounts

8. Title I Maintenance Of Effort

9. E XPENDITURES TO INCLUDE WHEN DETERMINING MAINTENANCE OF EFFORT FOR TITLE I In determining whether an LEA has maintained fiscal effort, an SEA must consider the LEA's expenditures from State and local funds for free public education. These include expenditures for administration, instruction, attendance and health services, pupil transportation services, operation and maintenance of plant, fixed charges, and net expenditures to cover deficits for food services and student body activities. [34 CFR 299.5(d)(1)] Functions 1000, 2xxx, 3xxx

10. E XPENDITURES TO EXCLUDE WHEN DETERMINING MAINTENANCE OF EFFORT FOR TITLE I Expenditures for community services, capital outlay, debt service, or supplemental expenses made as a result of a Presidentially declared disaster are not to be included in the determination. In addition, any expenditures made from funds provided by the Federal government are excluded from the determination. [34 CFR 299.5(d)(2)] Functions: 4000 = Capital Outlay 5000 = Debt Service

11. T ITLE I M AINTENANCE OF E FFORT Figured at SEA Level If the LEA does not maintain effort, they will be notified by the SEA.

12. Title I Comparability Report

13. C OMPARABILITY R EPORT Section 1120A(c) of the ESEA provides that an LEA 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 least comparable to the services provided in schools that are not receiving Title I funds. If the LEA serves all of its schools with Title I funds, the LEA must use State and local funds to provide services that, taken as a whole, are substantially comparable in each Title I school. [Section 1120A(c)]

14. H OW OFTEN IS THIS REPORT DONE ? Demonstrating comparability is a prerequisite for receiving Title I, Part A funds. Because Part A allocations are made annually, comparability is an ANNUAL requirement. Procedures for how to complete this should be kept on file at your district

15. C RITERIA FOR M EETING C OMPARABILITY Because the SEA is ultimately responsible for ensuring that LEAs comply with the comparability requirement, the SEA may establish the method a district uses to determine comparability NM PED requires Student/Instructional staff (FTE) ratios and Student/Instructional staff salary ratios The PED forms for preparation are on the PED WebEPSS site on line.

16. S TEPS TO PREPARING T ITLE I C OMPARABILITY R EPORT Step 1: Determine the “break-out” or “spanning” of the schools Schools can be split by grade and then by size Split the Schools by Title I and Non-Title I Fill out the Signature page with these determinations

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18. S TEPS TO PREPARING T ITLE I C OMPARABILITY R EPORT Step 2: Prepare the calculation sheet for each Grade Span and each size (small/large) In this example for APS there are 14 calculation sheets

19. T HE 14 SHEETS 1. Grade Span A (K-5 th ) small schools 200 to 600 students non-Title I 2. Grade Span A (K-5 th ) small schools 200 to 600 students Title I 3. Grade Span A (K-5 th ) large schools 601 to 1001 students non-Title I 4. Grade Span A (K-5 th ) large schools 601 to 1001 students Title I 5. Grade Span B (6 th -8 th ) small schools 300 to 800 students non-Title I 6. Grade Span B (6 th -8 th ) small schools 300 to 800 students Title I 7. Grade Span B (6 th -8 th ) large schools 801 to 1332 students non-Title I 8. Grade Span B (6 th -8 th ) large schools 801 to 1332 students Title I 9. Grade Span C (9 th -12 th ) small schools 138 to 232 students non-Title I 10. Grade Span C (9 th -12 th ) small schools 138 to 232 students Title I 11. Grade Span C (9 th -12 th ) large schools 1152-2269 students non-Title I 12. Grade Span C (9 th -12 th ) large schools 1152-2269 students Title I 14. Grade Span X Title I Charter schools all operational allocations 13. Grade Span X non-Title I District schools all operational allocations

20. I NFORMATION TO INCLUDE ON EACH SHEET All schools that fit the span (Do not include pre-K) Total number of students that the school reported on STARS 40 th day Total number of low income students that the school reported on STARS 40 th day FTE for employees paid from State/Local funds (can exclude Special Ed paid staff) pulled on 40 th day Salaries for employees paid from State/Local funds (can exclude Special Ed paid staff) pulled on 40 th day

21. N ON - TITLE I S CHOOL S HEET DETAILED SCHOOL DATA ESEA TITLE I COMPARABILITY REPORT COMP FORM 3-B Name of District: Albuquerque Public Schools Non-Title I Schoolsx PERCENT LOW INCOME ACTUAL GRADE SPAN STUDENTS ENROLLED STATE FUNDED FTE STAFF SALARIES EXCLUDING LONGEVITY NAMES OF SCHOOL (1)(2)(3)(4)(5)(6) 596: Freedom High School 22.00%9-12167.0011.70$489,457.18 516: Nex+Gen Academy 40.00%9-12205.0018.20$755,385.16 372.0029.90 $ 1,244,842.34 AVERAGE STUDENTS PER FTE AVERAGE DOLLARS PER STUDENT AVERAGE OF STUDENTS AVERAGE FTE AVERAGE OR COMPARISON SALARY 7A8A Averages for non-title I schools. 186.0014.95 $ 622,421.1712.44$3,346.35 Measure 7BMeasure 8B 13.68$3,011.72 110% of90% of Box 7ABox 8A Instructions: Please complete this page first if your district has public schools that do not participate in Title I. Then complete the "Title I Schools" Worksheet. Use SY 11-12 40th day data. Do not include Pre-K students. List only operational FTEs do not include FTEs that are paid for with non-operational funds such as Title I. If all schools in your district participate in Title I, then complete the "Title I Schools" worksheet only. Sheet #9 9. Grade Span C (9 th -12 th ) small schools 138 to 232 students non-Title I

22. T ITLE I S CHOOL S HEET Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed. DETAILED SCHOOL DATA ESEA TITLE I COMPARABILITY REPORT COMP FORM 3-B Name of District: Albuquerque Public Schools Title I Schools X PERCENT LOW INCOME ACTUAL GRADE SPAN STUDENTS ENROLLED STATE FUNDED FTE STAFF SALARIES EXCLUDING LONGEVITY STUDENTS PER FTE DOLLARS PER STUDENT MARK "X" IF NOT COMPARABLE NAMES OF SCHOOL (1)(2)(3)(4)(5)(6)(7)(8)(9) 597: School on Wheels 79.70%9-12138.0011.00$452,902.0012.55$3,281.90 549: New Futures School 95.80%9-12232.0018.10$798,220.0012.82$3,440.60 Comparability Formula Option 1 - Select this option if district has Non-Title I Schools. Total Non-Title I AVERAGE STUDENTS PER FTE AVERAGE DOLLARS PER STUDENT AVERAGE OF STUDENTS AVERAGE FTE AVERAGE OR COMPARISON SALARY 7A8A 186.0014.95$622,421.1712.44$3,346.35 Measure 7BMeasure 8B 13.68$3,011.72 110% of 90% of Box 7ABox 8A Instructions: Please complete the table below for all Title I schools. Use SY 11-12 40th day data. Do not include Pre-K students. List only operational FTEs. If your district has schools that do not participate in Title I then make sure the "Non-Title I Schools" worksheet is completed FIRST. After completion the comparability formula will be pre- populated and auto-calculated. Choose one comparability measure, either Measure 7B or 8B (highlighted in green) in the Comparability Formula Option I and apply it consistently for each Title I School. If all schools in the district participate in Title I then complete the table below and choose Comparability Formula Option 2. Once the data is entered, the comparability measures will be auto- calculated and will appear in the green highlighted boxes. Choose one measure and apply it consistently for each Title I School. Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed. Sheet #10 10. Grade Span C (9 th -12 th ) small schools 138 to 232 students Title I

23. S TEPS TO PREPARING T ITLE I C OMPARABILITY R EPORT Step 3: The PED created sheets will auto fill the calculations once the data has been entered. Go through each line of the Title I Pages to be sure that each school is in compliance. To be comparable you may only choose one method of comparability, either by FTE or salary not a combination.

24. T ITLE I S CHOOL S HEET Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed. DETAILED SCHOOL DATA ESEA TITLE I COMPARABILITY REPORT COMP FORM 3-B Name of District: Albuquerque Public Schools Title I Schools X PERCENT LOW INCOME ACTUAL GRADE SPAN STUDENTS ENROLLED STATE FUNDED FTE STAFF SALARIES EXCLUDING LONGEVITY STUDENTS PER FTE DOLLARS PER STUDENT MARK "X" IF NOT COMPARABLE NAMES OF SCHOOL (1)(2)(3)(4)(5)(6)(7)(8)(9) 597: School on Wheels 79.70%9-12138.0011.00$452,902.0012.55$3,281.90 549: New Futures School 95.80%9-12232.0018.10$798,220.0012.82$3,440.60 Comparability Formula Option 1 - Select this option if district has Non-Title I Schools. Total Non-Title I AVERAGE STUDENTS PER FTE AVERAGE DOLLARS PER STUDENT AVERAGE OF STUDENTS AVERAGE FTE AVERAGE OR COMPARISON SALARY 7A8A 186.0014.95$622,421.1712.44$3,346.35 Measure 7BMeasure 8B 13.68$3,011.72 110% of 90% of Box 7ABox 8A Instructions: Please complete the table below for all Title I schools. Use SY 11-12 40th day data. Do not include Pre-K students. List only operational FTEs. If your district has schools that do not participate in Title I then make sure the "Non-Title I Schools" worksheet is completed FIRST. After completion the comparability formula will be pre- populated and auto-calculated. Choose one comparability measure, either Measure 7B or 8B (highlighted in green) in the Comparability Formula Option I and apply it consistently for each Title I School. If all schools in the district participate in Title I then complete the table below and choose Comparability Formula Option 2. Once the data is entered, the comparability measures will be auto- calculated and will appear in the green highlighted boxes. Choose one measure and apply it consistently for each Title I School. Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed. These FTE have to be less than the average below OR These Amounts have to be more than the average below

25. S TEPS TO PREPARING T ITLE I C OMPARABILITY R EPORT Step 4: For any school that is not comparable, journal entries or adjustments in staff must be made to bring the school into comparability. The forms supplied for completion by the PED are to be uploaded to PED WebEPSS on a yearly basis. Due dates and notification will be established by PED. All documents including the documents pulled to obtain the backup for the amounts used, are to be kept in the district (Charter) for a minimum of 3 years after release of auditor’s report for audit purposes.

26. H ELPFUL LINKS Code of Federal Regulations: http://cfr.vlex.com/source/code-federal-regulations-34- education-1083 http://cfr.vlex.com/source/code-federal-regulations-34- education-1083 Policy Sec 9521. Dept of Ed “Maintenance of Effort” (ESEA-NCLB) http://www2.ed.gov/policy/elsec/leg/esea02/pg112.html State MOE submission for Ed Job funds (PDF): http://www2.ed.gov/programs/educationjobsfund/submissio ns.html http://www2.ed.gov/programs/educationjobsfund/submissio ns.html Policy Sec 5141 Maintenance of Effort: http://www2.ed.gov/policy/elsec/leg/esea02/pg61.html Title I Fiscal Issues: http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf

27. Q UESTIONS ? Thank you!!!