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Presented by Larry Fazzari Petrea Stoddard 1. 34 Code of Federal Regulations (CFR) Section 76 State-Administered Programs Changes To iGrants 2011-2012.

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Presentation on theme: "Presented by Larry Fazzari Petrea Stoddard 1. 34 Code of Federal Regulations (CFR) Section 76 State-Administered Programs Changes To iGrants 2011-2012."— Presentation transcript:

1 Presented by Larry Fazzari Petrea Stoddard 1

2 34 Code of Federal Regulations (CFR) Section 76 State-Administered Programs Changes To iGrants 2011-2012 Anatomy of the iGrant Applications Title I, Part A and Learning Assistance Program (LAP) Consolidated Program Review (CPR) Most Common Non-Compliance Issues Resources and Links Title I, Part A/LAP Spring Training Agenda 2

3 34 Code of Federal Regulations (CFR) Section 76 State-Administered Programs 3

4 Getting EDGAR Education Department General Administrative Regulations (EDGAR) Section 76 4

5 5 34 CFR § 76 State Administered Programs Subpart AGeneral Subpart BHow a State Applies for a Grant Subpart CHow a Grant is Made to a State Subpart DHow to Apply to the State for a Subgrant Subpart EHow a Subgrant is Made to an Applicant Subpart FWhat Conditions Must Be Met By the State and Its Subgrantees Subpart GWhat Are the Administrative Responsibilities of the State and Its Subgrantees Subpart HHow Does a State or District Allocate Funds to Charter Schools Subpart IWhat Procedures Does the Secretary Use to Get Compliance

6 34 CFR Part 76 Subpart A-General 76.1 – Definition State Formula Grant a program whose authorizing statute or implementing regulations provide a formula for allocating program funds among eligible states – Regulations Program implementation regulations, if available Authorizing statute consistent with General Education Provisions Act (GEPA) Regulations in 34 Part 76 – Applies to all state-administered United States Department of Education (ED) programs 6

7 34 CFR Part 76 Subpart A-General 76.2Exceptions to this part Will be identified in the implementing regulations of individual programs If not identified in programs implementing regulations, 34 CFR provisions apply 7

8 34 CFR Part 76 Subpart A-General 76.50Eligibility ED Secretary makes grant to appropriate state agency- usually the Office of Superintendent of Public Instruction (OSPI) Authorizing statute determines extent Grant used directly by OSPI Passed to eligible districts 76.52Distribution (competitive, formula, or both) Dictated by program statute 8

9 34 CFR Part 76 Subpart A-General 76.52Eligibility of faith-based organizations Apply for and receives on same basis with other private organizations State may not discriminate (same basis) Religious activities must be offered at separate time/location 9

10 34 CFR Part 76 Subpart D-Application 76.300Contact State for Procedures – Most are available in iGrants 76.301District Application (iGrants) – Must meet section 422 of GEPA 76.302Notice to districts – Amount- iGrants – Period of obligation- iGrants – Requirements of grant 10

11 34 CFR Part 76 Subpart D-Application 76.303Joint applications and projects If permitted by state May not exceed formula amount for those included Follow requirements Accounting system must permit identification of costs of grant 11

12 34 CFR Part 76 Subpart D-Application 76.304District to make application available to public (includes private schools) Includes Application Evaluation Periodic program plan Report related to program 12

13 34 CFR Part 76 Subpart E-Application 76.400State procedures for reviewing an application – OSPI must review applications – Entitlement programs approved if Applicant eligible, AND Meets federal requirements and statutes of program – Discretionary programs approved if Applicant eligible Applicant meets federal statutes and regulations State determines project submitted should be funded 13

14 34 CFR Part 76 Subpart D-Application 76.401Disapproval of applicationopportunity for hearing – Programs for which district may request hearing before state disapproves application Title I, Part A Title I, Part D Title II, Part A IDEA, Part B IDEA, Section 619 Title III 14

15 34 CFR Part 76 Subpart F-Conditions 76.500Federal statutes and regulations on nondiscrimination – Must comply with Nondiscrimination on the basis of race, color or national origin (34 CFR Section 100) Nondiscrimination on the basis of sex (34 CFR section 106) Nondiscrimination on the basis of handicap (34 CFR section 104) Nondiscrimination on the basis of age (34 CFR section 90) 15

16 34 CFR Part 76 Subpart F-Conditions 76.530General cost principles 34 CFR 74.27 and 74.34 34 CFR 80.22 76.532Prohibits using funds for religion Specifically prohibited Religious worship, instruction, proselytization Equipment or supplies for above Construction, remodeling, repair, operation, or maintenance of facilities used for above purposes 16

17 34 CFR Part 76 Subpart F-Conditions 76.533Acquistion of real property; construction Not allowed unless specifically permitted by authorizing statute or implementing regulations 76.534Tuition and fees May not be used to meet matching, cost sharing or maintenance of effort requirements of a program 17

18 34 CFR Part 76 Subpart F-Conditions 76.560-.561Indirect cost rates Governed by 34 CFR Section 80.22 which specifies OMB Circular A-87 should be followed Must have current indirect cost rate agreement to charge indirect costs to a grant School Apportionment and Financial Services has such an agreement and calculates these on behalf of districts based F-196 Incorporated into iGrants 18

19 34 CFR Part 76 Subpart F-Conditions 76.563Restricted indirect cost rate Must be used for all programs with statutory requirement prohibiting use of federal funds to supplant non-federal funds 76.564-569Formula for indirect cost rate SAFS computes this based upon data in the F-196 See also Accounting, Budgeting and Financial Reporting at 19

20 34 CFR Part 76 Subpart F-Conditions 76.580Coordination with other activities Coordinate each project with other activities that are in the same geographic area served by the project and that serve similar purposes and target groups 76.591-.592Districts to cooperate during federal evaluations 76.600Construction regulations Must be followed if authorizing statute permits use of funds for this purpose 20

21 34 CFR Part 76 Subpart F-Conditions 76.650-.677Private School Participation Follow if authorizing statute requires 76.651Responsibilities Equitable participation District retains administrative direction and control over funds and property used to benefit private school students 21

22 34 CFR Part 76 Subpart F-Conditions 76.652Consultation with Private Schools Consult with representatives of students during all phases of development and design of program and provide a genuine opportunity for input. Include- Which children will receive benefits How needs of children identified What benefits provided How benefits provided How program evaluated 22

23 34 CFR Part 76 Subpart FConditions 76.653Needs, number of students, and types of services Comparable to public school students 76.654Benefits for private school students Comparable in quality, scope, and opportunity to participate 76.656Level of expenditures for private school students Same average amount 23

24 34 CFR Part 76 Subpart F-Conditions 76.656Application requirements Description of services provided to private schools Number of private school students eligible Number of private school students served Basis of selection Places and times of services Differences between services in private and public schools and reasons for differences 24

25 34 CFR Part 76 Subpart F-Conditions 76.657Separate classes prohibited If at same site and contain both public and private school students 76.658Funds not to benefit private school Cannot finance existing level of instruction or benefit private school Program to meet specific needs of eligible students 25

26 34 CFR Part 76 Subpart F-Conditions 76.659Use of public school personnel May be used to provide equitable program benefits to private school students only if not normally provided by private school 76.660Use of private school personnel May use program funds only if services performed outside regular hours of duty and under the public school supervision and control 26

27 34 CFR Part 76 Subpart F-Conditions 76.661Equipment and supplies If permitted by program, public school keeps title Placed only for time needed for program Used only for program Can be removed without remodeling Removed if no longer needed for program or needed or to prohibit use for other than program purposes 27

28 34 CFR Part 76 Subpart F-Conditions 76.662Construction Program funds cannot be used for construction of private school facilities 76.670-.677Bypass Secretary may waive requirements for providing services to private school children for certain programs; requires filing, notice and hearing 28

29 34 CFR Part 76 Subpart F-Conditions 76.681Protection of human subjects 76.682Treatment of animals 76.683Facility health or safety standards 29

30 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.700Comply with statutes, regulations, state plan and applications 76.701State administers and supervises 76.702Fiscal control and fund accounting procedures Must insure proper disbursement and accounting 76.703When State may obligate funds 76.704State plans 30

31 31 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.707When obligations are made If the obligation is forWhen obligated Personal services by employee When services performed Non-employee servicesDate of written commitment Non-personal service workDate of written commitment Public utility servicesWhen services received TravelWhen travel taken Rental of real or personal property When property used Real or personal propertyDate of written commitment

32 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.708When obligation of funds begins Formula grants, later of Date state may begin obligation Date application submitted in substantially approvable form Subject to final approval of application State may approve pre-agreement costs 32

33 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.709Obligation during carryover period Funds not used during year for which appropriated or carryover period shall be returned to the federal government 76.710Obligations during carryover period subject to statutes, regulations and applications 33

34 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.711Identification by CFDA number Found on grant award notification Catalog of Federal Domestic Assistance Find Department of Education CFDA numbers at 41e870f21a02a5c4f5db 34

35 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.720State financial and performance reports 76.722District reports required by OSPI OSPI may require district to submit reports to enable the agency to meet its reporting responsibilities 35

36 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.730Records related to grant funds Must keep records that show Amount of grant funds Use of grant funds Total cost of program Share of program cost from other sources Other records to facilitate an effective audit 76.731Records related to compliance Must keep records showing program compliance 36

37 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.740Protection of and access to student records; student rights in research, experimental programs and testing Records governed under GEPA section 438; 34 CFR part 99 Research, testing and experimentation governed under GEPA section 439; 34 CFR part 98 37

38 34 CFR Part 76 Subpart GAdministrative Responsibilities 76.770State shall have procedures to ensure compliance Reviewing and approving applications and any amendments Providing technical assistance Evaluating Other as necessary to ensure compliance 76.783District may request hearing 38

39 Changes to iGrants 2011-12 FP 201Title I, Part A FP 218LAP 39

40 Page 2Assurances no longer need to be mailed to OSPI Page 3Added new page-Affirmation of Consultation with Private School Officials Upload one for each participating private school Page 4District Plan (formerly Page 3) pre-populated-Be sure to UPDATE for current information Page 5Allocations and Set Asides (formerly Page 4) shows 20% and 10% amounts Page 6Public Schools (formerly Page 5) shows total low income and enrollment (compare to Page 5) Page 7Private Schools (formerly Page 6) Title I, Part A iGrant FP 201 Changes 40

41 New Activities Added, Effective 2011-12 31Instructional Professional Development 32 –Instructional Technology iGrant Budget Changes New Activities 41

42 Used for the additional costs relating to instructional professional development of school district personnel Focus on extra costs: Travel Registration fees Payments to vendors for training Tuition reimbursement Substitute costs Other related costs iGrant Budget Changes Activity 31 42

43 Salary costs: Base salaries for attendees are not coded to this activity. Assigned professional development staff base salaries may be coded here. Contracted extra duty days for the express purpose of professional development may be coded here. Direct-charged extra time related to professional development may be charged here. Open in all programs EXCEPT 97,98,99. iGrant Budget Changes Activity 31 43

44 Primary use is for recording General Fund expenditures for computers and related equipment that is based in the schools. General software that is installed on all school-based computers may be charged here. (For example, Microsoft Office.) Computer-based curriculum (digital textbooks, educational software) should not be coded here. Use Activity 27. iGrant Budget Changes Activity 32 44

45 Salary costs Salaries and benefits for staff members whose assignment supports instructional technology may be charged here. Districtwide technology support, IT department, Help Desk, etc., should not be charged here (Program 97, Activity 72). Allowable objects 0,3,4,5,7,8,9. (Not object 2) iGrant Budget Changes Activity 32 45

46 Charging of an IT person who also teaches Split-code Portion of time teaching should be coded to Activity 27-2 (certificated) Portion of time related to instructional technology should be coded to Activity 32-3 (classified) iGrant Budget Changes Activity 32 46

47 Title I, Part A ARRA, FP 482 Eliminated Note: All Title I, Part A ARRA funds must be obligated by September 30, 2011 Title I, Part A iGrant 482/ARRA Changes 47

48 Anatomy of the Applications 48

49 Title I, Part A iGrant FP 201 49

50 Substantial approval Page 1 50

51 June 1, 2011 District deadline to submit a substantially approvable status (SAS) request to ensure notification by July 1. (Applies to all programs except for Special Education.) June 2011 Throughout June districts are notified of substantially approved status. Substantially Approvable Status 51

52 52

53 53

54 Assurances Page 2 54

55 Be sure date i s current. 55

56 Affirmation of Consultation with Private Schools Page 3 56

57 57

58 District Program Plan Page 4 58

59 59

60 Allocation/Set Asides Page 5 60

61 61

62 To Page 6 62

63 Section A Required Set Asides Required Set Asides (Section A, Page 5, iGrants) Parent Involvement [1118(a)(3)] At least 1% if allocation more than $500,000 Homeless [1113(c)(3)(A); 1115(b)(3)] Amount needed to serve homeless children who do not attend participating Title I, Part A schools Neglected [1113(c)(3)(A); 1115(b)(3)] Amount needed for neglected children placed in the care of individuals or facilities by DSHS 63

64 Section A Required Set Asides Required Set Asides (Section A, Page 5, iGrants) Equitable Services to Private School Students of eligible, participating private schools Equitable services to students (Page 7, individual) Equitable services to parents (parent involvement, Page 5) Equitable services to teachers (professional development, Page 5) 64

65 95% remains in amount to allocate to buildings 5% is deducted from allocation 65

66 Section B Required Set Asides Required Set Asides with Schools in School Improvement Transportation for Public School Choice (PSC) (Step 1 and above) and Supplemental Educational Services (SES) (Step 2 and above) [1116(b)(10)(A)] Must equal 20% of district allocation Minimum 5% for transportation for PSC, if needed Minimum 5% for SES, if needed Remaining 10% for either or both 66

67 Section B Required Set Asides Required Set Asides with Schools in School Improvement (continued) To release unneeded amounts for other allowable uses Meet all conditions (L-1 of SES Non Regulatory Guidance) Submit FP 557 and receive OSPI approval Request and make application revisions to reallocate 67

68 Enter amount needed (up to 5%) 68

69 Amount needed to equal 20% Enter funding source. Amount will deduct. MUST be used if needed. 69

70 Section C Required Set Asides-Schools Required Set Asides with Schools in School Improvement Professional development to address cause of identification for school improvement [1116(3)(A)(iii)] 10% of building allocation May be part of district professional development set aside if district is in Step 1 or above of improvement for building principal and teachers Enter on Page 6 70

71 Section C Professional Development Required Set Asides with Districts in District Improvement – 10% of district allocation [1116(c)(7)(A)(iii)] for district instructional staff 71

72 72

73 Optional Set Asides Summer school and/or extended day programs Preschool On-going professional development for instructional staffcan be used to enable staff not meeting highly qualified to do so Additional parent involvement Other Should be small amount Must be defined Title I, Part A Required Set Asides 73

74 Must equal amount allocated on Page 6 74

75 75 Equitable Share

76 Minimum amounts of total Total 76

77 Must be at least 100 in this example 77

78 Public School Breakdown Page 6 78

79 Allocations to Buildings Rank order all buildings according to poverty percent (usually based on free and reduced lunch percentage) Must serve buildings over 75% in FTE order Then rank and serve by grade span or districtwide Can reach buildings down to 35% If district average is lower than 35%, can reach buildings down to district (or grade span) average but must allocate at least 125% of district per pupil amount to every building in the rank order Buildings with higher poverty must have per pupil allocation of at least as much as one with lower poverty 79

80 Allocations to Buildings Districts with enrollment of less than 1000 students or districts with only one building per grade span are not required to rank order their buildings A building which was both eligible and served the prior year may be served an additional year even if not otherwise eligible 80

81 MUST be equal 81 New

82 82

83 Individual Building Page 83

84 Private School Breakdown Page 7 84

85 Must be equal Should approximate 85

86 Needed for any school indicating intent to participate in Title I, Part A 86

87 87

88 88

89 LAP FP 218 89

90 90

91 New 91

92 Only grades 11 and 12 92

93 93

94 94

95 Cannot be greater than allocation less indirects 95

96 Title I, Part A End of Year ReportRegular Year iGrant FP 244 96

97 Note: dates will change to September 1, 2010 through June 30, 2011 97

98 Must equal 98

99 Total number of buildings receiving Title I, Part A funds in which Corrective Action was implemented. Of the above, buildings enter the number of buildings implementing each type of corrective action Required implementation of a new research-based curriculum or instructional program Extension of the school year or school day Replacement of staff members relevant to the schools low performance Title I, Part A End of Report Additional QuestionsPage 4 99

100 Corrective action (contd) Significant decrease in management authority at the school level Replacement of the principal Restructuring the internal organization of the school Appointment of an outside expert to advise the school Title I, Part A End of Report Additional QuestionsPage 4 100

101 Total number of buildings receiving Title I, Part A funds implementing restructuring actions under ESEA Of the above buildings, enter the number of schools implementing each type of restructuring action Replacement of all or most of the school staff (which may include the principal) School closure Entering into a contract with a private entity to operate the school Other major restructuring of the school, please describe Title I, Part A End of Report Additional QuestionsPage 4 101

102 Was the District required to implement corrective action ?(Yes/No) If yes, indicate which corrective action was implemented Implemented a new curriculum based on state standards Authorized students to transfer from district schools to higher performing schools in a neighboring district Deferred programmatic funds or reduced administrative funds Title I, Part A End of Report Additional QuestionsPage 4 102

103 Replaced district personnel who are relevant to the failure to make AYP Removed one or more schools from the jurisdiction of the district Restructured the district Title I, Part A End of Report Additional QuestionsPage 4 103

104 LAP End of Year ReportRegular Year iGrant FP 245 104

105 105

106 Common Errors 106

107 Page 1 : Request SAS/indicate yes or no Page 2 : Assurances signed and current Page 3: Question B: Student achievement data/ current assessment data-trend over time Answer all questions completely Answer the question ASKED Page 4: A2-Homeless Set Aside A4A-Set Aside-Private Schools/in district A4B-Set Aside-Private schools/out of district Title I, Part A Most Common Errors-iGrant 201 107

108 Page 4: B1-4 School Identified in Improvement C-District identified for improvement D1-Administration of public and private schools- include indirect from budget Amount available to public school buildings-must match page 5-buildings allocation Amount to public school page must match total on page 4 108

109 Page 5: Complete all boxes for each building Basis PPE-based on pct. low income-in rank order Budget: FTE-Complete boxes at bottom of budget page for Teaching/27-2 (Cert.) 27.3 (Class.) and Supervision/27.2 (Cert.) 27.3 (Class.) 109

110 200/Carryover Calculation 201/Regular Year Application 244/Regular Year/EOY 246/Regular Year/EOY/Summer School 335 /Reallocation 361/Comparability 508/Waivers Request 557/Reauthorization of Choice/SES Set Aside Title I, Part A iGrant Form Packages 110

111 218/Regular Year Application 245/Regular Year/EOY Report 247/Regular Year/Summer School/EOY Report 418/Carryover Authorization LAP iGrant Form Packages 111

112 Page 1: A-Brief description of LAP program Page 1: B: District assessment/data trends for prior three years Page 1: #2: Process to identify students served with LAP Page 1: #8-Extended learning opportunities for 11 th and 12 th grade students LAP iGrant 218 Application Common Errors 112

113 Page 2: Allowable expenditures-all six allowable expenditure plus indirect from budget equals total LAP allocation. Page 3: Student information-head count/content count Public School Page: Complete all building boxes Budget: FTE-Complete boxes at bottom of budget page [Teaching/27-2 (Cert.) 27.3 (Class.) and Supervision/21.2 (Cert.) 21.3 (Class.)] LAP iGrant 218 Application Common Errors 113

114 Title I, Part A Application Revisions and Carryover 114

115 May only be completed when application has received final approval Send iGrant email requesting needed pages to be unlocked Provide brief reason for request Example: Revise SES and choice once all parental requests are received Application Revisions 115

116 ESEA §1127 Less than $50,000No limit Over $50,00Limited to 15% of allocation May request waiver no more than once every three years if- Request is reasonable and necessary or Supplemental appropriations become available Waiver for districts needing waiver due to ARRA funds can be used for 2010-11 funds into 2011-12 (One-in-three year clock starts when last waiver requested) Carryover-Title I, Part A iGrant FP 200, Budget Revision 201 116

117 Carryover due to required set asides must be used for those purposes. Examples: Parent involvement Professional development SES and PSC Private schools Homeless Neglected Consider effect on rank order in buildings Considerations For Use of Carryover 117

118 Fiscal Issues 118

119 Maintenance of Effort ESEA Sections 1120A(a) and 9521 34 CFR 299.5 Comparability ESEA Section 1120A(c) and (d) 34 CFR 200.79 Supplement vs. Supplant ESEA Section 1120(b) & 1114(a)(2)(B) 34 CFR 200.79 Time and Effort 2 CFR Section 225 Federal Office of Management and Budgets Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments. Fiscal Issues-Big Four 119

120 At the district level The district has maintained fiscal effort if either of the tests below were met at 90 percent of the preceding year The combined fiscal effort per student or The aggregate (total of included) expenditures of the district These tests are performed by OSPI based on district information on the F-196 financial reports SAFS provides interactive worksheetuse it Maintenance of Effort 120

121 At the building level All schools in the district are Title I, Part A schools, the district must use state and local funds to provide services that, taken as a whole, are substantially comparable in each school Use iGrant report 361, due October 30, 2011 Compare Title I, Part A buildings to Non-Title buildings If all Title I, Part A compare to each other Comparability 121

122 Services to students Presumptions of supplanting for districts and targeted assistance buildings- Federal funds were used to provide services that the district was required to make available under federal, state or local law Federal funds were used to provide services provided with non-federal funds in the prior year(s) Title I, Part A or C funds were used to provide services for participating children that were provided with non-federal funds for non-participating children Rebuttal may be possible in some cases Supplement Not Supplant 122

123 Presumption of supplanting for Title I, Part A schoolwide buildings Must show each schoolwide building received all state and local funds to which it is entitled, including those for basic education, for children with disabilities and for limited English proficient children Supplement Not Supplant 123

124 Time and effort reporting is required when any part of an individuals salary is charged to a federal program Single cost objective Semi annual certification Multiple cost objectives Monthly time reports or Personnel Activity Reports (PARs) Time and effort reports show how time was actually worked Must account for 100% of time worked Must reconcile to budget at least quarterly Time and Effort 124

125 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 percent on programs combined Semi-annual certification If employee works partially on programs combined and partly on those not combined Monthly time report (PAR) Schoolwide Time and Effort 125

126 Consolidated Program Review (CPR) Review Cycle Most Common Non-Compliance Issues Title I, Part A and LAP 126

127 2010-2011 Districts in ESDs 121 and 171 2011-2012 Districts in ESDs 105, 112, and 113 2012-2013 Districts in ESDs 123 and 189 2013-2014 Districts in ESDs 101 and 114 CPR Monitoring Review Timeline 127

128 1.1 At beginning of each school year, the district notified parents in all Title I, Served buildings that they may request the professional qualifications of the students classroom teacher. (Copy of notice with information may request and date sent) 1.3 The District Annual Report card to parents and community on the progress of each school and the district as a whole toward meeting requirements for (a) highly qualified staff and (b) student progress toward state and national goals (Description of how information is disseminated and contains all required elements: 1. Reading, Mathematics, and Science assessment data. 2. Accountability data (AYP). 3. Teacher quality data. 4. NAEP results, if applicable.) Title I, Part A Most Common Non-Compliance Issue District Level

129 1.12 There is a District Parent Involvement Policy containing all of the required elements. (Conduct with parents an annual review) 1.12b The district ensures that parents have the opportunity to be involved in the decisions regarding the 1% set aside for parent involvement funds. (Parent survey, meeting minutes, and/or agenda) Title I, Part A Most Common Non-Compliance Issues District Level

130 1.17 The district ensures that each school identified for improvement has developed or revised a school improvement plan, developed in consultation with parents, community, district, and outside experts. (All sanctions for each applicable step) 1.22 The district has revised, no later than three months after identification, a continuous district improvement plan in consultation with parents, school staff and others. (Copy of District Improvement Plan with all required elements) Title I, Part A Most Common Non-Compliance Issues District Level

131 1.25 Charges to federal grants are charged & documented appropriately. OMB Circular A 87, Attachment B. (Documentation for sub-coding for each applicable set-aside) Title I, Part A Most Common Non-Compliance Issues District Level

132 1.6 Instructional paraprofessionals must be under the direct supervision of a certificated teacher. (Evidence of supervision from highly qualified certificated staff) 1.7 Each Title I, Part A Schoolwide building has a Schoolwide/SIP building plan that contains the ten component requirements. (Documentation matrix of coordination of federal, state, and local services) Title I, Part A Most Common Non-Compliance Issues Building Level

133 1.8 Schoolwide program is evaluated annually. (Documentation of ongoing evaluation) 1.10 The most-at-need students are identified. (An example of a rank order list /entrance and exit procedures) 1.11 The Targeted Assistance program shall be reviewed on an ongoing basis. (Documentation of ongoing review, progress of participating children and revision of the targeted plan, if necessary) Title I, Part A Most Common Non-Compliance Issues Building Level

134 1.14 Building Parent Involvement Policy/Plan are developed jointly, agreed on and disseminated to parents of Title I, Part A participating students. Copy of up-to-date policy containing all required elements-example of compact) Title I, Part A Most Common Non-Compliance Issues Building Level

135 2.1 Selection of eligible students for LAP services. RCW 28A.165.025; WAC 392-162. (Evidence that only students achieving below state and district assessment are served) 2.2 Accelerated Student Learning Plans are developed for participating students. RCW 28A.165.025(3); WAC 392-162. (Roles, Goals, Communication and Review/Adjustment) 2.3 Services are provided for eligible 11th and 12th grade students who are not on track to meet local or state graduation. RCW 28A.165. Evidence of services for selected participating students) Learning Assistance Program (LAP) Most Common Non-Compliance Issues District/Building Level

136 1.3.1 Time and Effort 1.5.1 Supplement Not Supplant 1.6.1 Program Income SES Providers, CTE 1.7.1 Equipment, Capital and Theft Sensitive Contain all components, theft-sensitive definition 1.8.1 Procurement Address all four areas especially small purchases and sole sourcing Fiscal Non-Compliance Issues 136

137 Resources Links Title I, Part A and LAP 137

138 Title I, Part A Resource Links 138

139 LAP Resource Links 139

140 Resource Links OMB Circular A-87Allowable Costs (Codified as 2 CFR 225) OMB Circular A-102 Grants and Cooperative Agreements with State and Local Governments OMB Circular A-133Audit Requirements and the related Compliance Supplement 34 CFR 80Administrative Requirements 34 CFR 76Requirements for grants passed to districts through the state agency, OSPI idx?c=ecfr&tpl=/ecfrbrowse/Title34/34cfr76_main_02.tpl idx?c=ecfr&tpl=/ecfrbrowse/Title34/34cfr76_main_02.tpl

141 Director, Gayle Pauley: Program Supervisors Petrea Stoddard: Mary Jo Johnson: Reginald Reid: Jamilyn Penn: John Pope: Larry Fazzari: Jody Hess: Bill Paulson: Administrative Support Julie Chace: Kevan Saunders: Tony May: OSPI Title I, Part A/LAP Contacts 141

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