Exercising Greater Flexibility in Administering Federal Grant FundsNora Hancock, EdDAssociate CommissionerGrants and Federal Fiscal Compl iance

Association for Compensatory

Educators of Texas October 10, 2014

Flexibility

Closing the Student Achievement Gap

Demographic Landscape (who we are)

Over 5 million Texas students in 2012–2013 school year

64% African American and Hispanic

30% white

60% economically disadvantaged

National Assessment of EducationalProgress (NAEP) Results: Rankings and

Gaps

Fourth-Grade Reading Ranking

• White: 12th• African American: 14th• Hispanic: 35th

Fourth-Grade Reading Gaps

• Between white and African American: 24 points

• Between white and Hispanic: 27 points

NAEP Results: Rankings and Gaps

Eighth-Grade Reading Ranking

• White: 9th• African American: 14th• Hispanic: 29th

Eighth-GradeReading Gaps

• Between white and African American: 26 points

• Between white and Hispanic: 24 points

NAEP Results: Rankings and Gaps

Fourth-GradeMath Ranking

• White: 6th• African American: 5th• Hispanic: 14th

Fourth-GradeMath Gaps

• Between white and African American: 24 points

• Between white and Hispanic: 20 points

NAEP Results: Rankings and Gaps

Eighth-GradeMath Ranking

• White: 5th• African American: 4th• Hispanic: 4th

Eighth-GradeMath Gaps

• Between white and African American: 27 points

• Between white and Hispanic: 19 points

Writing Performance

STAAR Writing English I: 30% gap English II: 28% gapbetween economically disadvantaged and non-economically disadvantaged students

Writing Performance

STAAR Writing English I - 27% Gap English II - 30% Gapbetween White students and African American students

2013 Graduation Rates

Texas high school graduation rate: 88%Gaps:• African American student graduation rate is 8.9%

lower than the white student rate• Hispanic student graduation rate is 8.7% lower

than Asian student rate

Implementing Flexibility in Administering Federal Grant Funds and Title I, Part A Schoolwide Programs

Guiding Principles• Allowing local discretion • Providing clear guidance• Removing barriers• Improving performance• Ensuring grant funds spent appropriately • Strengthening accountability

Federal Flexibility Initiative Focus

1. TEA policy changes2. Title I, Part A schoolwide programs3. Uniform Guidance

TEA Policy Changes1. Grant administration2. Title I, Part A Schoolwide Programs3. Uniform Guidance

1. Grant Administration Policy Changes• Grant application• Grant application negotiation• Grant accounting process• Federal fiscal subrecipient monitoring

Grant Application Streamlined

• Applicants no longer required to submit certain information and documentation• TEA staff do not automatically deny late or

retroactive amendments

Grant Application Negotiation

• TEA staff will no longer negotiate applications and amendments with a “one size fits all” approach

Grant Accounting Process• Detailed documentation only required upon

request• TEA staff will no longer assume that large

reimbursement requests made at the very end of the grant period are not allowable

Substitute Time and Effort Deadlines

• TEA now has three submission periods for management certification form (which allows an LEA to use the substitute system)

• Deadlines for 2014–2015 school year:o September 4, 2014 for fall, spring, and summer semesterso December 15, 2014 for spring and summer semesterso May 15, 2015 for summer semester

Federal Fiscal Subrecipient Monitoring

• TEA monitors only conduct reviews of current-year grants that have not closed• TEA provides for settlement conferences to

resolve federal fiscal monitoring findings that could result in enforcement actions

2. Title I, Part A Schoolwide Programs• Encouraging schoolwide programs• Schoolwide background data• TEA support for schoolwide programs• Title I, Part A consolidation options

Encouraging Title I, Part ASchoolwide Programs

• Flexibility offered by schoolwide program modelo Easing of some programmatic requirementso Allowing campuses to consolidate funds into a single

budget “pool”

• Clear guidance given on web pageso Continuously updated information

Title I, Part A Schoolwide Programs

(2014–2015)

1,200 Number of LEAs eligible for Title I, Part A funds(out of 1,216 LEAs)

6,613 Number of campuses eligible to operate a Title I, Part A schoolwide program (out of 8,177 campuses)

5,854 Number of Title I, Part A schoolwide campuses5,037 consolidate Title, Part A funds234 consolidate federal funds583 consolidate all federal, state, and local

134 Number of Title I, Part A targeted assistance campuses

TEA Support for Title I, Part A

Schoolwide Programs

• Clear guidance• Models and examples• Technical assistance

Title I, Part A Schoolwide Options

• Full consolidation• Federal funds consolidation• Title I, Part A funds only

Key Issues for Schoolwide Programs

•Specific programmatic and fiscal requirements•Account code structure and PEIMS reporting•Consolidating funds vs. coordinating funds•Carryover•Monitoring and documentation

Federal Subrecipient Monitoring

•Monitoring process•Documentation required of LEAs with

campuses that operate schoolwide programs

High-Risk Grantee Designation

•High-risk grantee designation and special conditions apply to LEA•Affects reimbursement requests to campuses

operating a schoolwide program•Required documentation•Uniform Guidance

3. Uniform Guidance• Reasons for change• Final regulations: December 26, 2014

Uniform Guidance Goals• Streamline guidance for federal awards to ease

administrative burden• Strengthen oversight of federal funds to reduce risks

of waste, fraud, and abuse

Most Significant Changes• Time and effort requirements• “Specific conditions” option• Subrecipient monitoring requirements• Monitoring findings and resolution requirements

Uniform Guidance:Time and Effort Requirements

• Certifications• Substitute system

Uniform Guidance:Specific Conditions

• “High-risk” grantee designation• Review of each subrecipient’s risk level

Uniform Guidance:Subrecipient Monitoring

Requirements• Scope of monitoring determined by each

subrecipient’s risk• Possible monitoring activities

Uniform Guidance: Audit Findings and Resolution

Requirements• Raising thresholds for:o Required single audito Questioned costs

Next Steps• Responding to questions• Tools to assist LEAs

Questions and Feedback

Contact Information Title I, Part A schoolwide programs:

Anita VillarrealDivision of Federal and State Education Policynclb@tea.state.tx.us

Federal flexibility initiative:Terry ReyesOffice for Grants and Federal Fiscal Complianceterry.reyes@tea.state.tx.us

More Contact Information FASRG account code structure:

financialaccountability@tea.state.tx.us

PEIMS reporting:peimscustomersupport@tea.state.tx.us