School-wide Consolidation: LEA Panel 2016 ESEA Directors Institute August 25, 2016

Renee Palakovic Director of Planning Division of Consolidated Planning & Monitoring Renee.Palakovic@tn.gov (615) 253-3786

Session Objectives

Session Objectives School-wide consolidation of funds Options for consolidation Federal funds eligible for consolidation Single pool of funds Identifying programs & contributions Determining IDEA maximum contribution Reimbursement requests Meeting intents and purposes of programs consolidated Statutory and regulatory requirement changes Keys to success for consolidation of funds Overview of pilot program Panel discussion with current pilot participants

Consolidation of Funds

School-wide Consolidation of Funds Consolidation of funds is an OPTION, not a requirement School MUST be operating a Title I school-wide program Funds are placed into a single pool to increases flexibility Funds included in consolidation lose their identity Funds must be used to meet the intents and purposes of grant programs included in the consolidation Some federal statutory and regulatory requirements can be eased at the school level

Consolidation Options Consolidate only school level federal funds Funds lose their identity Must meet the intent and purpose of programs included Funds can be used to address the educational needs identified in the school-wide plan Consolidate school level state, local and federal funds No distinction between federal and non-federal funds Funds can be used to address any needs identified in the school-wide plan (may be non-educational)

Federal Funds Eligible for Consolidation Any federal funds administered by the United States Department of Education (USDOE) that can be used to support students in public schools Formula funds such as Title I, Part A Title II, Part A Title III IDEA, Part B Perkins Discretionary (competitive) funds Must still complete activities within the funding application Head Start and National School Lunch CANNOT be included because they are not administered by USDOE

Single Pool of Funds A school determines the programs to be included in the consolidation The school-wide plan identifies the programs and amounts to be consolidated Funds are combined into a single pool of funds Funds from the pool are used to support the activities outlined in the school-wide plan Expenditures are not “tracked” back to specific programs within the pool

Single Pool of Funds School Building Title I Part A Title II Part A IDEA Part B State/Local Funds Building Total School A $182,535 $25,000 $94,462 $2,048,115 $2,350,112 School B $115,455 $27,709 $1,380,884 $1,549,048 School C $181,780 $69,272 $1,940,161 $2,216,213 Total Funds Distributed to Individual Schools $479,770 $75,000 $191,443 $5,369,160 $6,115,373

Single Pool of Funds If IDEA, Part B funds are being consolidated The maximum amount of funds consolidated must be calculated based on the number of students with disabilities in the school School must comply with all other requirements of IDEA, Part B to the same extent as it would if funds were not included in the consolidation IDEA Allocation # of SWDs in LEA # of SWDs in School LEA Per Pupil Maximum School Amount for Consolidation $500,000 500 50 $1,000 $50,000 (50 X $1,000)

Single Pool of Funds Reimbursement requests must separate the amount spent from the school-wide pool Amounts requested from each program are based on Total expenditure from the pool Percentage of contribution to the pool Total pool expenditure: $350,000 School Building Title I Part A Title II Part A IDEA Part B State/Local Funds Building Total School-wide Pool $479,770 $75,000 $191,443 $5,369,160 $6,115,373 Percent of Total Contribution 7.8% 1.2% 3.1% 87.9% 100% Percent of Expenditures to be Reimbursed $27,300 (7.8%) $4,200 (1.2%) $10,850 (3.1%) $307,650 (87.9%) $350,000 (100%)

Intent and Purpose Schools consolidating funds are not required to meet most statutory or regulatory requirements of the program, but must meet the intents and purposes of the programs included in the consolidation For example: Title II, Part A: the intent and purpose of this program is to increase student achievement through strategies such as: Improving teacher and principal quality Increasing the number of highly qualified teachers, principals and assistant principals in schools Holding LEAs and schools accountable for improvements in student academic achievement

Intent and Purpose A school-wide program would meet the intent and purpose of Title II, Part A if: The school-wide plan contains activities and strategies that promote increased student achievement, such as On-going and sustained professional development for teachers and administrators Strategies to recruit and retain highly effective, highly-qualified teachers Teacher mentoring programs Induction programs for new teachers

Intent and Purpose Schools consolidating IDEA funds as part of the school-wide pool must still meet all requirements of IDEA IDEA funds must still be counted as federal funds in the IDEA excess cost and supplement not supplant calculations SWDs in the school must Receive services in accordance with properly developed IEPs Be afforded all of the rights and services guaranteed to SWD and their parents under IDEA

Statutory and Regulatory Requirements Several federal statutory and regulatory requirements are eased through school-wide consolidation at the school level Supplement/supplant Building level testing, rather than expenditure level Time and effort Pool of funds is a single cost objective Procurement & equipment inventory If consolidating state, local and federal Can use state and local procurement rules Federal equipment tracking rules do not apply Fiscal accounting of expenditures Not tracked back to individual grant programs Tracked only as part of the school-wide pool of funds

Statutory and Regulatory Requirement Several federal statutory and regulatory requirements remain, but are handled differently Maintenance of effort Expenditures calculated based on percentage of funds contributed to the pool Comparability Percentage of federally paid staff based on percentage of funds contributed to the pool Carryover limits Calculated based on LEA total award Carryover amounts based on total expenditures and percentage of funds contributed to the pool

Keys to Success

Funding Clear funding formula to determine state and local funds allocated to schools School level allocation of federal funds Limited set asides at the LEA level Decision making authority at the school for Staffing Interventions Materials & supplies Professional development

School-wide Plan Comprehensive needs assessment done annually All relevant data included (academic, discipline, attendance, parent/community engagement, teacher evaluation, etc.) In depth data analysis Root cause analysis Prioritization of goals to be met in one academic year Targeted strategies to meet goals Action steps that are: Aligned to goals and strategies Measurable Intentional opportunities for plan review and revision throughout the school year

Recordkeeping Accurate documentation of programs and funds included in the school-wide pool Budget and accounting codes necessary to separate costs from all other expenditures Support to show meeting intents and purposes of grants included in the consolidation Policies and procedures for accurately determining: IDEA school maximums (if included in the pool) Maintenance of effort Comparability Federal fund reimbursement requests

School-wide Pilot

School-wide Pilot 2015-16 was the planning year Quarterly task force meetings/trainings for interested LEAs Discussions with state auditors and USEd for buy-in and support Development of procedures and state structures Problem solving discussions 2016-17 is the implementation year Three participating LEAs Warren County Putnam County Alvin C. York Institute ePlan revisions completed and functional for 2016-17 Planning tool revisions almost complete for 2016-17

School-wide Pilot In addition to implementation in 2016-17, CPM will Monitor progress and support LEAs implementing Educate other interested LEAs and offer training as requested Publish written procedures for the consolidation of funds in a school-wide program Update ePlan as needed for increased functionality Any interested LEAs will have the option of consolidating funds in the 2017-18 school year

School-wide Pilot Panel Introduction of members of panel Questions for the panel Was it difficult to get buy-in from others in the LEA? Did you have to make procedural changes in order to consolidate funds in selected schools? If so, what? How? Did the consolidation of funds necessitate staffing changes in your LEA? Did you have to provide training for staff to move forward with the consolidation of funds in the selected schools? Have you seen any program/student benefits from this yet? If not, do you believe there will be benefits as you proceed through this first year?

Questions

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