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

2. Renee Palakovic Director of Planning Division of Consolidated Planning & Monitoring (615)

3. Session Objectives

4. 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

5. Consolidation of Funds

6. 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

7. 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)

8. 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

9. 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

10. 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

11. 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)

12. 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%)

13. 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

14. 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

15. 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

16. 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

17. 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

18. Keys to Success

19. 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

20. 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

21. 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

22. School-wide Pilot

23. 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
is the implementation year
Three participating LEAs
Warren County
Putnam County
Alvin C. York Institute
ePlan revisions completed and functional for
Planning tool revisions almost complete for

24. 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 school year

25. 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?

26. Questions

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