Application Amendments and Budget Transfers Title I University Chris McLaughlin, Title I Specialist Office of Program Administration and Accountability Virginia Department of Education November 19, 2015

Learning Outcomes for Today’s Session The participant will be able to: State the purpose of application amendments Write and submit an amendment for budget and programmatic changes Write and submit a budget transfer request that is aligned with the approved Title I, Part A, application Describe Title I, Part A, grant award timeline, obligation requirements, and carryover limitation Monitor spend down of grant funds to accommodate fiscal deadlines

Amendments are Required § Fiscal control and fund accounting procedures. A State and a subgrantee shall use fiscal control and fund accounting procedures that insure proper disbursement of and accounting for Federal funds. § A State shall have procedures to ensure compliance. Each State shall have procedures for reviewing and approving applications for subgrants and amendments to those applications, for providing technical assistance, for evaluating projects, and for performing other administrative responsibilities the State has determined are necessary to ensure compliance with applicable statutes and regulations. Education Department General Administrative Regulations (EDGAR), Title 34

Amendments are Required § Revision of budget and program plans. (a) The approved budget for the Federal award summarizes the financial aspects of the project or program as approved during the Federal award process. It may include either the Federal and non- Federal share (see § Federal share) or only the Federal share, depending upon Federal awarding agency requirements. It must be related to performance for program evaluation purposes whenever appropriate. (b) Recipients are required to report deviations from budget or project scope or objective, and request prior approvals from Federal awarding agencies for budget and program plan revisions, in accordance with this section.

Life-Cycle of Grant = 27 Months Title I, Part A July 1 Application Due 15 Months Later 85% of grant must be obligated 27 Months Later 100% of grant must be obligated July 1, 2015September 30, 2016September 30, 2017 NOTE: Reimbursement requests for 100% of the grant must be submitted in OMEGA by mid-November of the year the award closes.

Grant Award Timeline Year of Grant Award Total Grant Award Period Deadline to Obligate 85 percent of Award* Deadline to Obligate 100 percent of Award Deadline to Request Reimbursement for ALL funds FFY 2015 ( ) July 1, 2015 – Sept. 30, 2017 Sept. 30, 2016Sept. 30, 2017Nov. 15, 2017 FFY 2014 ( ) July 1, 2014 – Sept. 30, 2016 Sept. 30, 2015Sept. 30, 2016Nov. 15, 2016 FFY 2013 ( ) July 1, 2013 – Sept. 30, 2015 Sept. 30, 2014Sept. 30, 2015Nov. 15, 2015 *Some divisions may receive a waiver to carry over more than 15 percent of award

Perfect world... The school division submits grant application and no changes are needed during the 27 month period while the grant expenditures match original plan to the penny.

Probable Scenario... July 1 Due Date Final Allocation Released (Amendment 1) Programmatic Change (Amendment 2) Federal Award Adjustment (Amendment 3) 85% Spend Down Plan (Amendment 4) Budget Adjustment (Amendment 5) Carryover Funds Zero Balance (Amendment 6) 27 Month Process

Application Amendments Amendments are necessary when: Allocations are announced via VDOE Superintendent’s Memos The division needs to make programmatic changes The division needs to change the projected budget, including moving funds between object codes Amendments should include: Amendment number and description of changes on cover page of application Modifications to application such as: Program narrative Detailed budget description Object code budget

Application Amendments Example

Missed Opportunity to Communicate (Omega Comment Area) What statements could have been made to document and summarize the grant activity?

Sample Amendment Comment (Omega Comment Area)

The “Obligation Clock” is always ticking! Obligate 85% of award within the required 15 month period

What does “Obligate” mean?

procedures/definition_of_obligation.pdf

Will you beat the clock? Obligate 85% prior to September 30 Review expenditures Review obligations Monitor spending progress in OMEGA

View Spending Progress Report

Budget Transfer Requests Budget transfers are necessary when: Initial program applications are approved Application amendments that include budget changes are approved Budget transfers should include: Object code changes that are aligned with application or amendment A comment that references the approved application or amendment (ideally) A comment including additional details if necessary

Budget Transfers Example 1

Budget Transfers Example 2

Budget Transfers Missed Opportunities to Communicate

Sample Budget Transfer Comment (OMEGA Comment Area)

SEC CARRYOVER AND WAIVER. (a) LIMITATION ON CARRYOVER- Notwithstanding section 421(b) of the General Education Provisions Act or any other provision of law, not more than 15 percent of the funds allocated to a local educational agency for any fiscal year under this subpart (but not including funds received through any reallocation under this subpart) may remain available for obligation by such agency for one additional fiscal year. (b) WAIVER- A State educational agency may, once every 3 years, waive the percentage limitation in subsection (a) if — (1) the agency determines that the request of a local educational agency is reasonable and necessary; or (2) supplemental appropriations for this subpart become available. (c) EXCLUSION- The percentage limitation under subsection (a) shall not apply to any local educational agency that receives less than $50,000 under this subpart for any fiscal year.

Carryover Waiver Guidelines School divisions may apply for a waiver to exceed the 15 percent carryover limitation once every three years if: 1.The state agency determines that the request is reasonable and necessary; or 2.Supplemental appropriations become available School divisions that receive less than $50,000 are excluded from the carryover limitation Superintendent’s Memo # – Title I, Part A Carryover Provisions and Reallocation Procedures Under the Elementary and Secondary Act of 1965 (ESEA)

Eligibility to Request Waiver Waiver Request from Division Eligible to Request Waiver in Future FFY 2015FFY 2018 FFY 2014FFY 2017 FFY 2013FFY 2016 FFY 2012FFY 2015

Reallocation Process School divisions that do not meet the 85% obligation requirement are subject to reallocation VDOE continuously monitors the spend down status of divisions and has established procedures and communication channels to ensure certification of obligation status

Amendments and Budget Transfers To meet obligation requirements, grant managers are expected to: Communicate with key stakeholders in the school division to plan application adjustments; Submit application amendments and correlating budget transfers in a timely manner; and Monitor OMEGA balances on a monthly basis. Critical deadlines may require frequent monitoring of the spend down balance.

Questions?

VDOE Contact Information: Title I, Part A Lynn Sodat, Ph.D., Title I Coordinator Phone: (804) Gabie Frazier, Title I Specialist Phone: (804) Chris McLaughlin, Title I Specialist Phone: (804) Shyla Vesitis, Title I/III Specialist Phone: (804)