Federal Programs Procedures Manual

Clint ISD 1 2018-2019 Federal Programs Procedures Manual – Revised 1/2019

Federal Programs Procedures Manual

Department of Federal Programs

Updated


Contents Federal Funding Overview & Cycle .................................................................................................................. 7

Special Tests and Provisions ........................................................................................................................... 9

Federal Grants ........................................................................................................................................... 9

Qualifications of Teachers & Paraprofessionals ............................................................................................ 9

Child Nutrition Department .......................................................................................................................... 9

State Accountability / Performance Reporting ............................................................................................. 10

Federal Report Cards ........................................................................................................................... 10

School Report Cards ............................................................................................................................ 10

Assessment Security Systems ............................................................................................................... 10

ESSA Consolidated Grants ........................................................................................................................... 11

Title I, Part A – Improving Basic Programs Overview ................................................................................... 11

Students Served .................................................................................................................................. 11

Components of a Schoolwide Program – ................................................................................................ 11

Clint ISD Planned Projects: ................................................................................................................... 12

Title I, Part C ‐ Migrant Education Program Overview .................................................................................. 12

Identification and Recruitment (Ages 3‐21) ............................................................................................. 12

Migrant Services Coordination (All grade levels ...................................................................................... 13

Migrant Education Program Planned Projects for Clint ISD ...................................................................... 13

Title II, Part A ‐ Supporting Effective Instruction Overview ............................................................................ 13

Clint ISD Planned Projects .................................................................................................................... 13

Title III, Part A ‐ English Language Acquisition (ELA) Overview .................................................................... 14


Title IV, Part A – Student Support and Academic Enrichment Grant (SSAEP) Overview ................................. 14


Gun-Free Schools Act .......................................................................................................................... 14

Federal Grants Budget Overview ................................................................................................................... 15

Budget Development for Federal Grants .................................................................................................... 15

Authorized Use of Federal Funds ............................................................................................................... 15

Comprehensive Needs Assessment (CNA) Overview .................................................................................. 16

Evaluation of Programs/Activities ............................................................................................................... 17

District Improvement Plan & Campus Improvement Plan ............................................................................. 17

Expenditure Reporting for Federal Grants .................................................................................................. 17

Schoolwide Programs ................................................................................................................................... 18


ESSA (Every Student Succeeds Act) Federal Grant Application ................................................................... 18

IDEA-B Special Education Federal Grant Application .................................................................................. 18

Timely Obligation of Funds ............................................................................................................................ 18

Period of Availability of Federal Funds ....................................................................................................... 19

Liquidation of Obligations .......................................................................................................................... 19

Federal Grants Budget Process ..................................................................................................................... 20

Title I, Part A (211) Schoolwide Programs .................................................................................................. 20

Serving Eligible Children in a Title I, Part A - Targeted Assistance Programs ............................................. 20

Title I Regulations for Identifying Eligible School Attendance Areas to Participate in Title I, Part A ............... 21

Discretion in Selecting Participating Areas and Schools ........................................................................... 22

Allocating Title I Funds to Participating Areas and Schools ...................................................................... 22

Allocating Title I Funds to Private Non-Profit School Children ................................................................... 23

Participation of Private School Children .................................................................................................. 23

Title I, Part C (212) Migrant Education Program .......................................................................................... 23

Title II, Part A (255/256) Supporting Effective Instruction Overview ............................................................... 23

Title III, Part A (263) English Language Acquisition (ELA) / Limited English Proficient (LEP) ........................... 24

Title IV, Part A (281) Student Support and Academic Enrichment Grant (SSAEP) .......................................... 24

Federal Grants Compliance Requirements ..................................................................................................... 24

Allowable Costs ....................................................................................................................................... 24

Factors Affecting Allowability of Costs ........................................................................................................ 25

Requesting Prior Written Approval ............................................................................................................. 27

Selected Items of Cost – 2 CFR Part 200, Subpart E ................................................................................... 27

Supplement/Supplant ............................................................................................................................... 28

What Does Supplement, Not Supplant Mean? ........................................................................................ 29

Rebutting the Presumption of Supplanting .............................................................................................. 29

Supplement, Not Supplant on Schoolwide Programs ................................................................................... 29

How to Document Compliance for an Auditor .............................................................................................. 30

Procedures for Complying with Supplement, Not Supplant ........................................................................... 30

Translating Essential Information for Parents & Family Members .................................................................. 31

Comparability of Services ......................................................................................................................... 32

The Test .............................................................................................................................................. 33

Comparability of Services ..................................................................................................................... 33

Special Revenue Fund Guidelines— Scientifically Based Research .................................................................. 33

Indirect Costs ............................................................................................................................................... 34


New Process for Requesting an Indirect Cost Rate for ISDs ......................................................................... 34

Roll‐Forward (Carryover Funds) .................................................................................................................... 34

District Purchases ........................................................................................................................................ 35

Technology Purchases ................................................................................................................................. 36

New Technology Equipment Purchases ..................................................................................................... 36

End of Year and Summer Checkouts ......................................................................................................... 37

At the Start of the School Year .................................................................................................................. 37

Lost/Stolen Equipment .............................................................................................................................. 37

Repairs of Technology Equipment ............................................................................................................. 37

Disposal, Salvage or Transfer of Equipment ............................................................................................... 37

Recycle of Chromebooks .......................................................................................................................... 39

Record Keeping/ Management ...................................................................................................................... 40

Campus/Department Responsibilities ............................................................................................................. 41

Training ....................................................................................................................................................... 41

Annual Retrieval ........................................................................................................................................... 41

Required Forms ........................................................................................................................................... 42

Destruction of Records ................................................................................................................................. 42

Financial Reporting of Federal Funding .......................................................................................................... 42

Other Programs and Related Services ........................................................................................................... 43

Homeless Program ....................................................................................................................................... 43

Identification of Students ........................................................................................................................... 43

Local Point of Contact ............................................................................................................................... 43

Foster Care & Student Success ..................................................................................................................... 43

Clint ISD Procedures for Ensuring Education Stability for Children in Foster Care .......................................... 43

State and Local Points of Contact .............................................................................................................. 50

Migrant Education Program ........................................................................................................................... 51

Identification and Recruitment of Students – services provided through Region XIX ESC ............................... 51

Parent Meetings – services provided through Region XIX ESC .................................................................... 51

Credit Recovery and other academic needs ................................................................................................ 51

Pregnancy Related Services ......................................................................................................................... 51

Identification of Students ........................................................................................................................... 51

Communities in Schools (CIS) ....................................................................................................................... 51

Referral Process ...................................................................................................................................... 51

Parent & Family Engagement Policy .............................................................................................................. 52


Statement of Purpose ............................................................................................................................... 52

Development of Policy .............................................................................................................................. 53

Title I Annual Meeting ............................................................................................................................... 53

School-Parent-Student Compact ............................................................................................................... 53

Staff and Parent Communication ............................................................................................................... 53

Funding ................................................................................................................................................... 53

Parent and Family Engagement Surveys .................................................................................................... 54

Personnel Management ................................................................................................................................ 54

Federally Funded Positions and Job Descriptions ....................................................................................... 54

Documentation of Federally Funded Employee Time and Effort Forms and/or Logs ....................................... 54

Federally Funded Personnel at 100% and Split Funded ........................................................................... 54

Tutoring Assignments ........................................................................................................................... 55

Summer School Assignments ................................................................................................................ 56


Overview of the Federal Programs Department

Mission Statement: The mission of the Clint Independent School District is to prepare all students to be

successful citizens. The District will work in partnership with the community and the family to create opportunities for the student to maximize personal potential.

Annual Goals:

1. The District will be a model of high standards for student academic excellence. 2. The District will ensure a safe well‐disciplined positive learning environment for all students. 3. The District will operate efficiently being fiscally responsible. 4. The District will become the employer of choice in order to seek and retain effective personnel. 5. The District will include parents, community, and business members in the education of all students.

Federal Programs Staff

Robert Flores Director of Federal Programs (915) 926‐3255

Dalia Miranda Secretary (915) 926‐3255

Elba Montero Title I Clerk (915) 926‐3253

Maria L. Chavira Title I Coordinator (915) 926‐3257

Lorena Ramirez Federal Programs Specialist (915) 926‐3259

Angelica Venzor Parent Involvement Specialist (915) 926‐3250

Hilda Adams Pregnancy Related Services – Teacher (915) 926‐3254

Department Fax (915) 926‐3258


Federal Funding Overview & Cycle The purpose of this manual is to describe the processes and procedures for the application of federal funding within the Clint Independent School District. This manual may not be all inclusive and will be updated as needed or required. Clint ISD works to ensure all federal laws and requirements are applied in a consistent and appropriate manner to meet the needs of all students and as required by federal grant program rules. The core components that drive the federal funding cycle, (see figure 0.1), provides the basis for determining the instructional needs, including all required elements that are aligned together to ensure a successful implementation. These components are not necessarily mutually exclusive at all times, but rather complement each other as important steps in this continual cycle. Comprehensive Needs Assessment (CNA)

The CNA develops the framework for the District Improvement Plan (DIP) and Campus Improvement Plan (CIP) in identifying the needs, budgets, challenges, measurements, assessment and planning for the impact of future changes. All information is compiled in the Plan4Learning software program.

Funds Notifications Notifications through the U.S. Department of Education and the Texas Education Agency, notifications of federal funding grant opportunities are made available for application consideration.

Decision Making

Decision making consists of the core members of the Superintendent’s cabinet which considers all aspects of external funding opportunities as they relate to the current and future needs of the District.

Application Process

The application process is driven by the CNA, availability of funds and the vision of the Superintendent’s cabinet, the Department of Federal Programs assembles the requirements for the funding application process.

Funds Received

Funds received from the U.S. Department of Education in conjunction with the Texas Education Agency determine the distribution and schedule of federal funds to Local Education Agency (LEA) such as the Clint Independent School District.

Oversight

Oversight is primarily the responsibility of the Department of Federal Programs working closely with the Business Services Department to ensure all federal guidelines are being met during the program implementation process. This includes budget reviews and collection of all appropriate documentation as required for program compliance.

Implementation Implementation is completed with the assistance of other key support service departments and regulating all key grant components to meet the original grant application specifications.


Evaluation The evaluation component driven primarily through the Departments of Elementary/Secondary Curriculum & Instruction in collaboration with the Department of Federal Programs, collect valuable information used to comply with program performance reporting.

CNA -

DIP & CIP

Funds Notification -

TEA / Dept. of Ed.

Decision Making -Superintendent's Cabinet

Application -

Federal Programs

Funds Received -

State & LEA

Oversight -

Federal Programs & Business Services

Implementation -

Curriculum & Instruction & Campuses

Evaluation -

Departmet of Curriculum & Instruction / Office of Academics &

Compliance / Department of Federal Programs

Figure 0.1

Federal Fund Cycle


Special Tests and Provisions Federal Grants Clint ISD ensures all eligible schools are able to use their Title I, Part A funds, in accordance with the number of economically disadvantaged students per campus. The PEIMS Department collects the economically disadvantaged data for students enrolled in Clint ISD during the registration process annually. The number of economically disadvantaged students at the first district PEIMS snapshot is used in the preparation of the grant application annually. These funds are used to upgrade the entire educational program of the school and to raise student achievement for students. These funds are used consistently in compliance with all statutory and regulatory requirements in a schoolwide program. All federal grants include provisions and assurances that the district agrees to comply with when a grant is accepted through the Texas Education Agency (TEA). The provisions and assurances will be reviewed for understanding at the time a federal grant is submitted for approval by the state agency. The provisions and assurances under the New EDGAR (Education Department General Administrative Regulations) will be followed as per federal regulation. The provisions and assurances can be found at the Texas Education Agency website or the TEA Grant Opportunities page: https://tea.texas.gov/Finance_and_Grants/Grants/Administering_a_Grant/Provisions_and_Assurances/ http://tea.texas.gov/WorkArea/DownloadAsset.aspx?id=25769804295

General Provisions and Assurances: required for every TEA grant agreement Debarment and Suspension: required for all federal grants, regardless of the dollar amount Lobbying Certification: required for all federal grants greater than $100,000 No Child Left Behind Act of 2001 (NCLB): required for all programs funded under the Elementary and

Secondary Act of 1965 Every Student Succeeds Act (ESSA): required for all programs funded under the Elementary and

Secondary Act of 1965 Qualifications of Teachers & Paraprofessionals Clint ISD will continue to comply with section 1119 of the Elementary and Secondary Education Act (ESEA), as amended by the Every Student Succeeds Act (ESSA), which requires the district to implement strategies and report the progress toward all teachers being highly effective and ensure that paraprofessionals meet certain qualifications and perform certain duties as allowed under the federal grant requirements. Teachers and Paraprofessionals hired with the use of federal funds will only be required to perform duties allowable under the federal grant requirements. Program Directors will monitor that program requirements are met by the personnel hired with the use of federal funds. Child Nutrition Department High Poverty Data / Verification of Free and Reduced Price Application The Child Nutrition Program collects economically disadvantaged / high poverty data for the submission of the Community Eligibility Provision (CEP) annually. The data collected by the Child Nutrition Program is not used in the submission of the ESSA grant application. The Community Eligibility Provision (CEP) provides students that receive a reimbursable meal are served meals at no charge. The provision improves access to free school meals in eligible high-poverty schools and it eliminates


the administrative burden of collecting household applications for free and reduced-price meals. The Child Nutrition Department relies on obtaining student eligibility through the Direct Certification Process, a secure database which matches household data from the Health and Human Service Commission (HHSC), the Texas Education Agency (TEA), and the Department of Agriculture (TDA). Accountability Processes and procedures regarding the school food accounts can be found in the Child Nutrition Department – Policy and Procedures Manual. Operations Information on the Procedures, Guidelines, and Agreement on Donating Leftover Food and Food Tables can be found in the Child Nutrition Department - Policy and Procedures Manual.

Updates to the procedures manual is made by the program director. State Accountability / Performance Reporting Federal Report Cards Every district that receives Title I, Part A funding is responsible for distributing the state-, district-, and campus-level report cards to each of its campuses, the parents of all enrolled students, and the general public/community. The Secondary Curriculum & Instruction Department ensures the Federal Report Cards is disseminated accordingly when the data is available by the Texas Education Agency. Additional information on the Federal Report Cards can be found at https://tea.texas.gov/frc.aspx. School Report Cards Every district is responsible in informing parents and guardians about their child’s school individual characteristics and academic performance. The Secondary Curriculum & Instruction Department ensures the School Report Card is disseminated accordingly to parents/guardians when the data is released by the Texas Education Agency. Additional information on the School Report Cards can be found at https://tea.texas.gov/perfreport/src/index.html.

Assessment Security Systems Maintaining the security and confidentiality of assessment results for students is important in the district. Procedures for maintaining the security and confidentiality of state assessments can be found the “Test Security Supplement” and in Board Policy EKB (Legal) – Testing Programs (State Assessments). The District Testing Coordinator provides an annual training to school testing coordinators and administrators on ensuring test security systems are followed thus eliminating any serious or procedural irregularities that can result if procedures are not followed. The Test Security Supplement can be found at the Texas Education Agency website at https://tea.texas.gov/student.assessment/security/. Board Policy EKB (Legal) – Testing Programs can be found on the Clint ISD website at www.clintweb.net or https://pol.tasb.org/Policy/Download/436?filename=EKB(LEGAL).pdf .


ESSA Consolidated Grants Title I, Part A – Improving Basic Programs Overview The purpose of Title I, Part A grant is to enable schools to provide opportunities for children served to acquire knowledge and skills contained in the challenging state content standards (TEKS) and to meet the challenging state performance standards (state mandated assessments) developed for all children. This purpose is accomplished by:

• ensuring high standards for all students and aligning the efforts of states, local educational agencies, and schools to help students served with Title I funds reach such standards;

• providing students with an enriched and accelerated educational program, including, when appropriate, the use of supplemental resources, schoolwide programs, or the increase of the amount and quality of instructional time so that students served with Title I funds receive at least the classroom instruction that other students receive;

• promoting schoolwide reform and ensuring access of children to effective instructional strategies and challenging academic content that includes complex thinking and problem solving experiences;

• providing substantial staff development opportunities to significantly upgrade the quality of instruction; • coordinating all Title I services with each other, with other educational services, and to the extent possible,

with health and social service programs funded from other sources; • providing parents meaningful opportunities to participate in the education of their children at home and at

school; • distributing resources, in amounts sufficient to make a difference, to areas and campuses where needs are

the greatest; • improving accountability by using the State assessment systems to measure how well Title I students are

achieving the challenging State student performance standards (TEKS) expected of all students; and providing greater decision making authority and flexibility to schools and teachers in exchange for greater responsibility for student performance.

Students Served All schools in Clint ISD are schoolwide. Therefore, children enrolled in the schools do not need to meet any identification eligibility criteria to participate and receive services through Title I, Part A.

Components of a Schoolwide Program – Requirements in all schoolwide campuses must include the following components:

• Conduct a comprehensive needs assessment of the entire school to determine the performance of its children in relation to the state mandated assessments and TEKS;

• Implement schoolwide reform strategies that are based on effective means of improving the achievement of children and that address the needs of all children in the school;

• Provide instruction by highly effective professional staff; • Provide high quality and on‐going professional development for teachers, principals, and paraprofessionals

and if appropriate, student services personnel, parents and other staff; • Implement strategies to attract highly effective teachers; • Implement strategies to increase parent & family engagement activities; • Plans for assisting preschool children in the transition from early childhood programs to elementary school

programs; • Measures to include teachers in the decisions regarding the use of academic assessments in order to

improve the achievement of individual students and the overall instructional program;


• Provide activities to ensure students who experience difficulty mastering any of the TEKS or state mandated assessments standards shall be provided with effective, timely additional assistance;

• Coordination and integration of federal, state, and local services and programs. Clint ISD Planned Projects:

• Parent & Family Engagement programs/activities • Salaries and benefits for teachers, central office support staff, and campus staff (Teachers/Instructional

Aides) • Supplemental program to support new, ineffective, and inexperienced teachers • Supplemental resources • Funds for intervention and tutoring programs • Funds for the summer school program

Title I, Part C ‐ Migrant Education Program Overview As of the start of the 2012‐2013 school year, Clint ISD has been in a Shared Services Agreement with Region 19 ESC. The service center will ensure services for identified Migrant students are implemented and grant compliance requirements are met. The purpose of Title I, Part C grant is to establish and improve programs and projects that are designed to meet the special educational needs of children of migratory agricultural workers or migratory fishers. The purpose of the Migrant Program is to design and support programs that help migrant students overcome the challenges of mobility, culture and language barriers, social isolation, and other difficulties associated with a migratory lifestyle in order to succeed in school and to successfully transition to postsecondary education or employment. This purpose is accomplished by:

• Identifying and recruiting eligible children within the school district, • Interviewing families to determine eligibility for migrant services, • Submitting the required reports as set forth by the Texas Education Agency ensuring all deadlines are met

accordingly, • Working with the PEIMS office and campus personnel to maintain migrant counts, immunizations, and

grades, • Communicating with district staff to ensure the enrollment and withdrawal of migrant students is completed

accordingly in a timely manner through the district student data management system. • Coordinating transportation for students and parents to/from migrant functions and activities, • Acting as liaison between the schools and the migrant community, • Making home visits to migrant families to communicate available school services, programs and community

social services, • Collaboratively working together (Clint ISD program/district staff & Region 19 ESC program staff) to ensure

all necessary academic and social services are provided to Clint ISD migrant students and their families.

Identification and Recruitment (Ages 3‐21) Through school districts and education service centers (ESCs), the Texas the Migrant Program actively seeks to identify and recruit all eligible migrant children and youth residing in our state. These are children who migrate with their parents or alone across school district lines in search of temporary or seasonal work in fishing or agriculture. Identification and recruitment are essential in order to offer migrant students opportunities to learn and succeed in school.


Migrant Services Coordination (All grade levels) This area of focus is required at all grade levels and seeks to ensure that migrant students and their families have their needs for educational and support services met, and are able to access all services for which they are eligible from entry in the Migrant Program's early childhood program for three year‐olds through transition into postsecondary education or employment. Migrant Education Program Planned Projects for Clint ISD

• Salaries and benefits of program staff • Supplemental Supplies and Materials • Migrant Student Credit Recovery Program • Lending Laptop Program • Student Camps and Workshops • Parent & Family Engagement Activities • School Supplies Distributions (on a need basis) • Food Pantry Distributions

Title II, Part A ‐ Supporting Effective Instruction Overview The purpose of Title II, Part A grant is to increase the academic achievement of all students by helping schools and school districts improve teacher and principal quality. This purpose is accomplished by:

• Elevating teacher and principal quality through recruitment, • Hiring and retention strategies to improve teacher and principal quality, • Increase the number of qualified teachers in the classroom and qualified principals and assistant principals

in schools. The program uses scientifically based professional development interventions and holds the district and schools accountable for improvements in student academic performance. Clint ISD Planned Projects

• Professional development activities and materials for Teachers/Principals • New Teacher Center Program for new, experience, and unexperienced teachers • Activities to promote teacher retention and recruitment

In addition, through the Texas Education Agency competitive grant application process, Clint ISD was awarded the 2018-2019 Principal Preparation Grant on April 27, 2018. The Notice of Grant Award (NOGA) for the grant was released on July 18, 2018. Clint ISD and Sul Ross State University Educational Leadership will agree to work together in a shared services agreement (SSA) to ensure the grant program activities are completed as indicated in the grant guidelines. The grant program will provide an effective principal preparation program to ten (10) teacher candidates. The program curriculum and training will focus on best practices on instructional leadership and offer candidates an authentic campus-based leadership experience during residency year. The residency program through SRSU will target the following areas:

• Sustained and rigorous clinical learning in an authentic school setting; • Evidence-based coursework; • Ongoing leadership support from an effective and experienced mentor principal;


• Opportunities to practice and be evaluated while enrolled in the program. Title III, Part A ‐ English Language Acquisition (ELA) Overview The purpose of Title III, Part A grant is to improve the education of limited English proficient children by assisting the children to learn English, meet challenging State academic content and meet student academic achievement standards. This purpose is accomplished by:

• Providing activities that use approaches and methodologies based on scientifically based research to teach LEP children,

• Developing and implementing new language instruction educational programs and academic content instruction programs for LEP children, including programs of early childhood on up to secondary school programs,

• Carrying out highly focused, innovative, locally designed activities to expand or enhance existing language instruction educational programs and academic content instruction programs for LEP children,

• Implementing, within an individual school, schoolwide programs for restructuring, reforming, and upgrading all relevant programs, activities, and operations relating to language instruction educational programs and academic content instruction for LEP children.

Clint ISD Planned Projects

• Second language acquisition program across K-12 • Professional learning opportunities for Teachers in grades PK-5 in the areas of reading, and math • Parent & Family Engagement Activities to learn about the second language acquisition, reading,

and math skills. • Instructional Materials

Title IV, Part A – Student Support and Academic Enrichment Grant (SSAEP) Overview The SSAEP grant provides funding to improve the academic achievement of all students by increasing capacity for Clint ISD, its schools, and communities to:

1) Provide all students with access to a well-rounded education, 2) Improve school conditions for student learning, 3) Improve the use of technology in order to enhance academic outcomes and digital literacy of students.

Clint ISD Planned Projects

• School Resource Officers Program at secondary schools supporting the safe and healthy students’ component.

• Hands on student learning activities in science, technology, engineering, and mathematics (STEM).

• STEM instructional materials • Professional learning tools and AV devices and resources for teachers to use in the classroom. • Effective uses of Technology resources for teachers in the classroom.

Gun-Free Schools Act A requirement under the Title IV, Part A grant is the Gun‐Free Schools Act which requires each state that receives funds under the Elementary and Secondary Education Act (ESEA), to have in effect a state law requiring districts to expel for at least one year any student who brings a gun to school or possesses a gun in school. This requirement is accomplished by:

• Annually informing students of discipline policies in the Student Handbook,


• Documenting student discipline incidents in the Enterprise Accounting System, • Taking appropriate actions by abiding to District policies (FO‐Legal, FO‐Local, FOA‐Legal, FOB Legal,

FOC‐Legal, FOCA‐Legal, FOD‐Legal, FODA‐Legal, FOE‐Legal, FOF‐Legal). The Gun-Free Schools Act must be addressed in the Clint ISD Student Handbook. The Student Handbook is distributed to every student at the beginning of the academic year. Parents and students acknowledge receipt of the handbook and those receipts are kept at the campus. Federal Grants Budget Overview Clint ISD refers to the Texas Education Agency Financial Accountability System Resource Guide (FASRG) for ensuring budget guidelines are followed accordingly. Clint ISD works to ensure the federal laws and requirements are applied in a consistent and appropriate manner to meet the needs of students as required by federal grants. Based on district needs, Clint ISD has the option to consolidate plans. At this time, Clint ISD does not consolidate plans. Budget Development for Federal Grants The following sources are used to develop budgets for federal grants: Historical data based on previous grant year actual budget Campus Improvement Plan (CIP) Needs Assessments District Improvement Plan (DIP) Staffing Needs Grant Requirements Carryover (Roll‐Forward) Funds, if applicable Budget Development – meeting with campus and district administrators

Data is compiled on the budget worksheet and Skyward (financial management) to ensure budgeted amounts match allocations. The data is then used in the submission of the TEA TEAL eGrants application. Budgeting projections are performed by the Program Director. Data entry into the TEAL eGrants application is performed by the Program Director. The certification and submittal of the completed TEAL eGrants application is performed by the Chief Financial Officer and/or other cabinet designee.

Authorized Use of Federal Funds All expenditures with Federal funds must comply with the Federal Cost Principles. All costs must:

a. Be necessary and reasonable for proper and efficient performance and administration of Federal awards; b. Be allocable to Federal awards under the provisions of the Federal Cost Principles (2 CFR Part 225); c. Be authorized or not prohibited under State or local laws or regulations; d. Conform to any limitations or exclusions set forth in the Federal Cost Principles, Federal laws, terms and

conditions of the Federal award, or other governing regulations as to types or amounts of cost items; e. Be consistent with policies, regulations, and procedures that apply uniformly to both Federal awards and other

district activities; f. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other

cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost;


g. Except as otherwise provided for in the Federal Cost Principles (2 CFR Part 225), be determined in accordance with generally accepted accounting principles;

h. Not be included as a cost or used to meet cost sharing or matching requirements of any other Federal award in either the current or a prior period, except as specifically provided by Federal law or regulation;

i. Be the net of all applicable credits; j. Be adequately documented.

The Program Director will refer to the applicable program guidelines issued by TEA to determine allowable use of grant funds and ensure that expenditures do not violate the Supplement Not Supplant requirement. In addition, the Program Director will ensure that costs are allowable according to the program guidelines and conform to the Federal Cost Principles prior to approval of any expenditure with Federal funds. The Chief Financial Officer will monitor compliance with Maintenance of Effort (MOE) for federal grants on a regular basis, but at least semi‐annually. Comprehensive Needs Assessment (CNA) Overview Preparation for any budget process begins with determining a combination of improvements, expansion of services and or sustainability in providing support for any organization.

A Comprehensive Needs Assessment will be created by each campus and district administrator in the district. The Comprehensive Needs Assessment is a systematic effort to acquire an accurate, thorough picture of the strengths of a school community that can be used in response to the identified educational needs of students. Every effort must be made to collect and review all data available to make appropriate decisions for the student body. The comprehensive needs assessment should be the centerpiece of the planning process ‐ the database from which the planning team develops its vision of the future. Assessing needs comprehensively means getting the full breadth of information for depth of understanding. The Comprehensive Needs Assessment is documented in the Plan4Learning software online based program. Conducting a CNA

• Clarify the Vision of the campus/district • Create a School Profile • Determine Data Collection Methods • Collect and Summarize Data • Analyze Data – Identify Needs and Set Goals • Implement Strategies and Evaluate Progress

The Key Players or Stakeholders

• Administrators • Teachers • Parents and Family Members • Community Leaders • District Administration

Documentation Required

• Agenda with date, time and location • Sign‐in sheet (participant name, role, signature)

o Title of meeting, date, time and location


• Meeting minutes/summary with date • Completed Comprehensive Needs Assessment Form

Evaluation of Programs/Activities An annual evaluation of the results achieved by the schoolwide program and revision of the schoolwide plan based on that evaluation must be conducted at the end of the school year. District Improvement Plan & Campus Improvement Plan The district/campuses are required to develop a campus improvement plan based on the needs identified in the district/campus needs assessment. The campus improvement plan should include the Components of a Schoolwide Plan as described in the Plan4Learning software online based program. Expenditure Reporting for Federal Grants Expenditure reports will be created by the Accounting Coordinator and approved by the Chief Financial Officer. The Accounting Coordinator shall be responsible for gathering the applicable data and preparing the required expenditure reports for all Federal awards. The Program Director and Program Coordinator and/or other Program Designee shall be responsible for reviewing and approving required Federal expenditure reports and for ensuring that these reports are submitted before the required deadline.

The Chief Financial Officer will grant final approval for drawdowns through the certification process on the TEA Grant Expenditure Reporting website. The Accounting Coordinator or designee will review cumulative expenditures for Federal grants and request any necessary drawdowns on a monthly basis. This review should occur after the processing of monthly payroll. The Accounting Coordinator will ensure the drawdown request will not exceed the threshold amount established by TEA.

The Accounting Coordinator or designee will generate a General Ledger Summary report in Skyward for each Federal grant. The actual expenditures will be totaled by object code. Any payroll liabilities that appear in the balance sheet accounts will be deducted from the 6100 object code total. This will prevent drawing more cash than has actually been expended.

The Accounting Coordinator or designee will then complete the required documentation used to track grant program year expenditures. Each grant is tracked on a separate worksheet. Every draw will be recorded on the appropriate worksheet. This will allow the Chief Financial Officer to determine the last time a draw was made. If cumulative expenditures have increased since the last draw, a new draw is required.

The Accounting Coordinator will keep records of Cash Receipts for the district and will be informed of each draw and to which account code(s) to post the revenue.

Audit trail ledgers will be reconciled by the Accounting Coordinator to confirm that expenditures only are requested.

A final expenditure report will be submitted on the TEA Grant Expenditure Reporting (ER) website by the deadline set for each program. The final expenditure report for federal grants through TEA will be performed by the Chief Financial Officer and Accounting Coordinator. The expenditure monitoring for the federal grants will be performed by the Chief Financial Officer, Accounting Coordinator, Program Director, Program Coordinator and/or other Program Designee. The deadlines will be obtained from the applicable TEA Grant Application.


Schoolwide Programs ESSA (Every Student Succeeds Act) Federal Grant Application The Director of Federal Programs completes the application according to the guidelines provided and specific to the grant. A consultation meeting is set in the spring semester with campus and district administrators, counselors, and parents to conduct the needs assessment pertinent to the application. Information collected from all present is discussed and entered in the application. Documentation of attendance, agenda and minutes are kept in the Department of Federal Programs. Once the application is approved it will be reviewed on an ongoing basis to determine if amendments are needed, as appropriate. IDEA-B Special Education Federal Grant Application The Special Education Director completes the application according to the guidelines provided and specific to the grant. A consultation meeting is set in early spring with campus and district administrators, counselors, and parents to review the application and conduct the needs assessment of the application. Information collected from all present is discussed and entered in the application. Documentation of the meeting and the application supporting material/data will be kept internally in the department. Once the application is approved it will be reviewed on an ongoing basis to determine if amendments are needed, as appropriate. Timely Obligation of Funds When Obligations are Made or Encumbered Obligations are defined as orders placed for property and services, contracts and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period. (This does not mean obligations for which goods and services will be delivered in a future grant period.) All obligations for all goods and services must occur during the grant period (i.e., between the beginning and ending dates as stated on the NOGA), and those goods and services must be delivered during the period of availability in sufficient time to provide substantial benefit to the grant to be considered necessary to carry out the objectives of the grant. 34 CFR § 200.71. Per TEA’s General and Fiscal Guidelines, in some instances, goods or services delivered near the end of the grant period may be viewed by TEA as not necessary to accomplish the objectives of the current grant period of availability. TEA will evaluate such expenditures on a case-by-case basis. Please note that a TEA monitor or an auditor may disallow those expenditures if the District is unable to (1) document the need for the expenditures, (2) demonstrate that program beneficiaries receive benefit from the late expenditures, or (3) negate the appearance of stockpiling supplies or equipment. A request of this nature is reviewed, as is any request, for compliance and timeliness. The following table illustrates when funds are determined to be obligated under federal regulations:

If the obligation is for: The obligation is made:

Acquisition of property On the date which the District makes a binding written commitment to acquire the property

Personal services by an employee of the District

When the services are performed

Personal services by a contractor who is not an employee of the District

On the date which the District makes a binding written commitment to obtain the services

Public utility services When the District receives the services Travel When the travel is taken Rental of property When the District uses the property


A pre-agreement cost that was properly approved by TEA prior to the obligation

On the first day of the grant project period

34 CFR § 75.707; 34 CFR § 76.707 In addition, TEA’s FAR requires encumbrance accounting. The amount committed (or obligated) must also be known to avoid over-expenditure of budgeted funds. An encumbrance accounting system is a method of ascertaining the availability of funds and then reserving funds to cover outstanding obligations. Encumbrances represent commitments (i.e., obligations) related to contracts not yet performed (executory contracts), and are used to control expenditures for the year and to enhance cash management. A school District often issues purchase orders or signs contracts for the purchase of goods and services to be received during the grant period. At the time these commitments or obligations are made, which in its simplest form means that when a purchase order is prepared, the appropriate account is checked for available funds. If an adequate balance exists, the amount of the order is immediately charged to the account to reduce the available balance for control purposes. The encumbrance account does not represent an expenditure for the period, only a commitment to expend resources. Period of Availability of Federal Funds All obligations must occur on or between the beginning and ending dates of the grant project. 34 CFR § 76.707. This period of time is known as the period of availability. The period of availability, or the period between the beginning and ending dates of the grant, are dictated by statute and will be indicated on TEA’s NOGA or other awarding agency’s GAN. Further, certain grants have specific requirements for carryover funds that must be adhered to. Federal education formula grant funds are typically awarded on July 1 of each year. While funds not obligated during the initial 15-month grant period remain available as carryover in the subsequent 12-month period, the District will always plan to spend to the best of its ability all current grant funds within the year for which the funds were initially appropriated. Per TEA, excess carryover and lapsing of funds may be an indicator in TEA’s risk assessment process. TEA calculates and manages the carryover process each year after final expenditure reports from the prior year are processed. Any carryover funds from the prior year are added to the application and NOGA for the subsequent year. Carryover funds must be used in accordance with the federal statute and regulations in effect for the carryover period and with any approved state plan or application. 34 CFR 76.710. Direct Grants: In general, the period of availability for funds authorized under direct grants is identified in the GAN. Liquidation of Obligations The District must liquidate (i.e., make the final payment because the goods or services were received during the grant period, or cancel the obligation because the goods or services were not received during the grant period) all obligations incurred under the award in accordance with the requirements of TEA or other awarding agency. For TEA formula grants, this is usually within 30 calendar days after the ending date of the formula grant to coincide with submittal of the final expenditure report to TEA. For direct grants from the Department of Education, this may be not later than 90 days after the end of the funding period unless an extension is authorized. 2 CFR § 200.343(b).


Any funds not obligated within the period of availability or not liquidated within the appropriate timeframe are said to lapse and must be returned to the awarding agency. 2 CFR § 200.343(d). Lapsing of funds is usually considered by TEA to be an indicator of poor planning and may cause the District to be identified as high risk. Consequently, the District closely monitors grant spending throughout the grant cycle. Obligated or encumbered funds are reviewed via am outstanding encumbrance report. Any encumbrances identified, that will not meet the timeliness of the grant, will be closed. This is determined by discussing the encumbrance with the campus or department head and a final recommendation is made by the program Coordinator or Director to the Chief Financial Officer to close the encumbrance. Federal Grants Budget Process Title I, Part A (211) Schoolwide Programs The Program Director will prepare a proposed budget covering all estimated needs of the program for the following school year. The preparation of the budget will include at least one parent and district staff members. The budget adoption will meet all timelines required by law. The grant allows for a 15% of its entire entitlement in Title I, Part A funds to be roll forward and/or carried over during the grant period. The district will make every effort to expend all its entitlements to address the needs of students in a timely manner. The Federal Programs Director meets with each campus administrator to finalized proposed federal budgets, to include Fund 211, 255, 263, and 281. In a schoolwide program, the school must use Title I, Part A funds to support activities that address specific educational needs of the school identified by the needs assessment and articulated in the schoolwide plan. The school must use other Federal funds in accordance with the specific requirements of each Federal program and with the assistance of the Program Director. In Clint ISD, all schools operate a schoolwide program. In a targeted assistance school, funds available under Part A may be used only for programs that are designed to help participating children meet the State’s student academic achievement standards expected of all children. Allowable activities in these schools include, but are not limited to, instructional programs, counseling, mentoring, other pupil services, and services to assist preschool children in the transition to elementary school programs, parental involvement activities, and professional staff development. If health, nutrition, and other social services are not otherwise available from other sources to participating children, Part A funds may be used as a last resort to provide such services. The Clint ISD plan will provide a description of the general nature of the services to be provided with Part A funds. However, each Title I school determines the actual program it will provide. Serving Eligible Children in a Title I, Part A - Targeted Assistance Programs Title I, Part A funds are to be used to provide services and benefits to eligible children residing or enrolled in eligible school attendance areas. Once funds are allocated to eligible school attendance areas a school operating a targeted assistance program must use Title I funds only for programs that are designed to meet the needs of children identified by the school as failing, or most at risk of failing, to meet the State’s challenging student academic achievement standards. In general, eligible children are identified on the basis of multiple, educationally related, objective criteria established by the Clint ISD and supplemented by the school. Children who are economically disadvantaged, children with disabilities, migrant children, and limited English proficient (LEP) children are eligible for Part A services on the same basis as other children who are selected for services. In addition, certain categories of children are considered at risk of failing to meet the State’s student academic achievement standards and are thus eligible for Part A services because of their status. Such children include: children who are homeless/displaced; children who participated in a Head Start, Even Start, Early Reading First, or Title I preschool


program at any time in the two preceding years; children who received services under the Migrant Education Program under Title I, Part C at any time in the two preceding years; and children who are in a local institution for neglected or delinquent or attending a community day program. From the pool of eligible children, a targeted assistance school selects those children who have the greatest need for special assistance to receive Part A services. Title I Regulations for Identifying Eligible School Attendance Areas to Participate in Title I, Part A Clint ISD will follow the requirements listed in identifying eligible school attendance areas and selecting those eligible areas that will participate in Title I, Part A and allocating Part A funds to the participating areas in the district. Clint ISD will rank all of its school attendance areas (the geographic area from which a public school draws its children) according to their percent of poverty.

- An LEA must use the same measure of poverty for: Identifying eligible school attendance areas. Determining the ranking of each area. Determining the allocation for each area.

- The LEA must select a poverty measure from the following options:

Children ages 5-17 in poverty as counted in the most recent census data approved by the

Secretary. Children eligible for free and reduced-priced lunches under the Richard B. Russell National School

Lunch Act. Children in families receiving assistance under the State program funded under Title IV, Part A of

the Social Security Act (Temporary Assistance for Needy Families). Children eligible to receive medical assistance under the Medicaid program. A composite of these data sources (listed above).

After Clint ISD has ranked all of its school attendance areas by poverty, the district must first serve, in rank order of poverty, its areas above 75 percent poverty, including any jr./middle schools and high schools. Only after the district has served all of its areas with a poverty rate above 75 percent may the LEA serve lower-ranked areas. The district has the option to: Option 1: Continue on with the districtwide ranking Option 2: Rank the remaining areas by grade span groupings (e.g., K‐6, 7‐9, 10‐12). The same districtwide poverty average must be used if the district selects option 1. For ranking by grade span groupings, the district may use the district-wide poverty average or the district-wide

grade span poverty averages for the relevant grade span grouping. If the district has no school attendance areas above 75 percent poverty, the district may rank district-wide or by

grade span groupings. A district’s organization of its schools defines its grade span groupings. For example, if the district has

elementary schools serving all elementary grades, middle schools, and high schools, the grade span groupings would be grades K-5, 6-8, and 9-12. To the extent if the district has schools that overlap grade spans (e.g., K-5, K-8, 6-8), the district should include a school in the grade span in which it is most appropriate.

A district with an enrollment of less than 1,000 students or with only one school per grade span is not required to rank its school attendance areas. A district may serve, for one additional year, an attendance area that is not currently eligible but that was eligible and served in the preceding year.


Discretion in Selecting Participating Areas and Schools Clint ISD may elect not to serve an eligible school attendance area or school that has a higher percentage of children from low‐income families (than a school that is served) if: (1) the school meets the Title I comparability requirements; (2) the school is receiving supplemental State or local funds that are spent according to the requirements of Sections 1114 or 1115, and (3) the funds expended from such other sources equal or exceed the amount that would be provided under Title I, Part A.

Allocating Title I Funds to Participating Areas and Schools Clint ISD will allocate Title I, Part A funds to participating school attendance areas or schools, in rank order, based on the total number of children from low-income families in each area or school. If the district serves any areas or schools below 35 percent poverty, the district must allocate to all its participating areas or schools an amount for each low-income child in each participating school attendance area or school that is at least 125 percent of the district's allocation per low-income child.

A districts’ allocation per low-income child is the total district allocation under Title I, Part A, subpart 2 divided by the number of low-income children in the LEA as determined using the poverty measure selected by the district to identify eligible school attendance areas. The district then multiplies this per-child amount by 125 percent.

The district calculates the 125 percent of its allocation per low-income child before the district reserves

any funds. The district must allocate at least this amount for each low-income child in every school the district

serves, not just for those schools below 35 percent poverty. If remaining funds are not sufficient to fully fund the next ranked eligible school attendance area or

school, the district may serve the area or school if it determines the funds are sufficient to enable children to make adequate progress toward meeting the State's challenging performance standards.

A district serving only areas or schools at or above 35 percent poverty must allocate funds in rank order, on the basis of the total number of low-income children in each area or school but is not required to allocate 125 percent of the district's allocation per low-income child. However, in determining what per-child amount to allocate, the district should bear in mind the purpose of such funding--to enable children who are most at risk of not meeting the State's challenging student academic achievement standards. The per-child allocation amount must be large enough to provide a reasonable assurance that a school can operate a Title I program of sufficient quality to achieve that purpose. The district is not required to allocate the same per-child amount to each area or school. However, the district must allocate a higher per-child amount to areas or schools with higher poverty rates than it allocates to areas or schools with lower poverty rates. A district that opts to serve schools below 75 percent poverty using grade span groupings may determine a different per-child amounts for different grade spans so long as those amounts do not exceed the amount allocated to any area or school above 75 percent poverty. Per-child amounts within grade spans may also vary so long as the LEA allocates higher per-child amounts to areas or schools with higher poverty rates than it allocates to areas or schools with lower poverty rates. The Clint ISD reserves the amounts generated by private school children from low‐income families who reside in participating public school attendance areas to provide services to eligible private school children.


Allocating Title I Funds to Private Non-Profit School Children Clint ISD will allocate Title I, Part A funds to participating school attendance areas or schools, in rank order, based on the total number of children from low-income families in each area or school. In calculating the total number of children from low‐income families, Clint ISD will include children from low‐income families who reside in a participating area and attend private schools, using the same poverty data, if available, as Clint ISD uses to count public school children. If the same data is not available, Clint ISD may use comparable data. If Clint ISD uses a survey of families of private school children, Clint ISD may extrapolate, from actual data on a representative sample of private school children, the number of children from low‐income families who attend private schools. Clint ISD may also correlate sources of data, or apply the low‐income percentage of each participating public school attendance area to the number of private school children who reside in that area. If Clint ISD selects a public school to participate on the basis of enrollment, rather than because it serves an eligible school attendance area, Clint ISD must, in consultation with private school officials, determine an equitable way to count private school children from low‐income families in order to calculate the amount of Title I funds available to serve private school children. Clint ISD may count private school children from low‐income families every year or every two years.

Participation of Private School Children Clint ISD implements provisions of equitable participation of private school children, this requirement may be tested on a general or program‐specific basis. Clint ISD contacts all private schools in the spring, after timely and meaningful consultation with private school officials, the district offers equitable services to eligible private school children, their teachers, and their families. Eligible private school children are those who reside in a participating public school attendance area on the basis of the total number of children from low‐income families. In calculating the total number of children from low‐income families’ enrolled/attending private schools. The district uses the portion of Title I, Part A funds attributable to private school children from low‐income families included in the calculation to provide services to eligible private school children. Clint ISD reserves funds off the top of its Title I, Part A allocation to provide instructional and related activities for public school students at the district level, the district also provides from those funds, as applicable, equitable services to eligible private school students. From applicable funds reserved for parent involvement and professional development, the district ensures teachers and families of participating private school children have an equitable opportunity to participate in professional development and parent involvement activities, respectively. The Chief Financial Officer will approve this budget to cover all required expenditures for the following school year. Title I, Part C (212) Migrant Education Program Effective at the beginning of the 2012‐2013 school year, Clint ISD entered a Shared Services Agreement with Region 19 ESC. The service center will ensure services to identified Migrant students are implemented and grant compliance requirements are met. Budgeting and amendments to the grant will be developed and processed by the Migrant Education Program at the Education Service Center. Quarterly reports are provided by the Migrant Education Program at the Service Center informing the district of the migrant program activities and costs for the grant period. Ongoing quarterly reports are provided to the Clint ISD program director. Title II, Part A (255/256) Supporting Effective Instruction Overview The Program Director will communicate with the Business Services Department, Elementary/Secondary Curriculum & Instruction Departments, and Human Resources Department on the Title II, Part A grant application and entitlements. The departments will prepare a proposed budget covering all estimated needs of the program for the following year. The preparation of the budget will take into consideration the needs assessment and apply the


needs in defining the program activities and strategies supported through the Title II, Part A grant requirements. The budget adoption will meet all timelines required by statute. The Chief Financial Officer will approve this budget to cover all required activities & expenditures according to the Title II, Part A grant for the following year. Title III, Part A (263) English Language Acquisition (ELA) / Limited English Proficient (LEP) The Program Director will communicate with the Elementary/Secondary Curriculum & Instruction Departments (Assistant Superintendents, Instructional Coordinators and Officers) on the Title III grant application and the entitlement amount. The Assistant Superintendent of Elementary/Secondary Curriculum & Instruction will prepare a proposed budget covering all estimated needs of the program for the following school year for Title III, Part A. The preparation of the budget will take into consideration the needs assessment and apply the needs in defining the program activities and strategies supported through the Title III, Part A grant requirements. The budget adoption will meet all timelines required by statute. The Chief Financial Officer will approve this budget to cover all required activities & expenditures according to the Title III, Part A grant for the following school year. Title IV, Part A (281) Student Support and Academic Enrichment Grant (SSAEP) The Program Director will communicate with the Chief Financial Officer and the Elementary/Secondary Curriculum & Instruction Departments (Assistant Superintendents, Instructional Coordinators, and Officers) on the Title IV grant application and the entitlement amount. A proposed budget covering all estimated needs will be developed for the following school year for Title IV, Part A. The preparation of the budget will take into consideration the needs assessment and apply the needs in defining the program activities and strategies supported through the Title IV, Part A grant requirements. The budget adoption will meet all timelines required by statute. The Chief Financial Officer will approve this budget to cover all required activities & expenditures according to the Title IV, Part A grant for the following school year. Federal Grants Compliance Requirements Clint ISD ensures all compliance requirements are met for the federal grants. The district and its schools upload required compliance documentation in an online filing system known as the Title I Crate. The uploaded data is reviewed by the Federal Programs Department on an ongoing basis and the data is used to meet compliance purposes.

Eligible schools are able to use their Title I, Part A funds, in accordance with the number of economically disadvantaged students per campus. These funds are used to upgrade the entire educational program of the school and to raise academic achievement for students. These funds are used consistently in compliance with all statutory and regulatory requirements in a schoolwide program.

Allowable Costs Grantees are required to have written procedures for determining the allowability of costs charged to federal grants. 2 CFR § 200.302(b)(7). All costs must be allowable under the federal cost principles in 2 CFR Part 200, Subpart E, and under the terms and conditions of the specific federal award. Expenditures must be aligned with budgeted items in the approved grant application. Certain changes or variations from the approved budget and grant application need prior approval from TEA or other awarding agency. Refer to


TEA’s guidelines on When to Submit an Amendment (under Amendment Submission Guidance) to determine when an amendment to the budget is required for TEA grants. When determining how the District will spend grant funds, the assigned program Coordinator or Director will review the proposed cost to determine whether it is an allowable use of federal grant funds before obligating and spending those funds on the proposed goods or services. This is accomplished during the purchase order approval process. All expenditures made with federal education funds must meet the standards outlined in EDGAR, 2 CFR Part 3474, and 2 CFR Part 200. The assigned program Coordinator or Director and fiscal staff, including federal program and business department staff must consider the following factors when making an allowability determination.

2 CFR Part 200 applies to grantees under all other programs under the Every Student Succeeds Act (ESEA) unless a State formally adopts its own written fiscal and administrative requirements for expending and accounting for all funds received by the State educational agencies (SEAs) and local education agencies (LEAs) under the ESEA. If a State adopts its own alternative requirements, the requirements must be available for inspection upon request by the U.S. Department of Education (USDE). .

https://www.gpo.gov/fdsys/pkg/CFR-2017-title34-vol1/xml/CFR-2017-title34-vol1-part299.xml#seqnum299.1

Factors Affecting Allowability of Costs In general, District staff must consider the following elements when determining the allowability of a cost. In accordance with the federal cost principles, all costs budgeted and charged to a federal grant must be: Necessary and Reasonable for the performance of the federal award.

Reasonable Costs: A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision to incur the cost was made. ”Reasonable” means that sound business practices were followed, and purchases were comparable to current market prices.

A cost can be reasonable if it meets all of the following conditions:

Prudence was used in making the decision to incur the cost, considering the person’s responsibilities to the District, its employees, the public, and the federal government.

It is necessary to carry out the objectives of the grant program or is recognized as an ordinary cost to operate the organization.

The District applied sound business practices; arm’s-length bargaining (i.e., the transaction was with an unrelated third party); federal, state, and other laws and regulations; and the terms and conditions of the award in making the decision.

The price is comparable to that of the current fair market value for equivalent goods or services. There were no significant deviations from the established practices of the organization which

may unjustifiably increase the cost. 2 CFR § 200.404. While 2 CFR § 200.404 does not provide specific descriptions of what satisfies the “necessary” element beyond its inclusion in the reasonableness analysis above, necessary is determined based on the needs of the program. Specifically, the expenditure must be necessary to achieve an important program objective. It means it is vital or required in order to meet the objectives of the grant or for the grant to be successful. Necessary does not mean “nice to have,” which means it is not necessary to accomplish the objectives of the program in that it is not vital or required for the success of the program.


A key aspect in determining whether a cost is necessary is whether the District can demonstrate that the cost addresses an existing need and can prove it. For example, the District may deem a language skills software program necessary for a limited English proficiency program. When determining whether a cost is necessary, the District considers:

Whether the cost is needed for the proper and efficient performance of the grant program; Whether the cost is identified in the approved budget or application; Whether there is an educational benefit associated with the cost; Whether the cost aligns with identified needs based on results and findings from a needs

assessment; and Whether the cost addresses program goals and objectives and is based on program data.

Allocable to the federal award. A cost is allocable to the federal award if the goods or services involved are

chargeable or assignable to the federal award in accordance with the relative benefits received. This means that the federal grant program derived a benefit in proportion to the funds charged to the program. 2 CFR § 200.405. For example, if 50% of a supplementary teacher’s salary is paid with grant funds, then that teacher must spend at least 50% of his or her time on the grant program. Additionally, if equipment or supplies purchased with grant funds benefits more than one grant program, the purchase must be “split-funded” among the grant programs receiving benefit. The District must be able to demonstrate how a particular cost benefits the specific population being served in the grant. This is an area of frequent audit exceptions.

Consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the District. For example, personnel whose travel is paid with federal funds is reimbursed at the same rates as personnel whose travel is paid with state or local funds, and the grant is charged accordingly.

Conform to any limitations or exclusions set forth as cost principles in 2 CFR Part 200, Subpart E, or in the terms and conditions of the federal award.

Consistent treatment. A cost cannot be assigned to a federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been assigned as an indirect cost under another award.

Adequately documented. All expenditures must be properly documented with original source documentation that is clearly written and maintained on file (either electronically or on paper) with accounting records. Documentation includes purchase orders/requisitions, invoices, receipts, verification of receipt of goods and services, travel authorizations and vouchers, contracts, time-and-effort records, copies of checks, bank statements, etc. Expenditures that are not supported by source documentation cannot be charged to the grant.

Determined in accordance with generally accepted accounting principles (GAAP), unless provided otherwise in 2 CFR Part 200.

Not included as a match or cost-share of another federal program, unless the specific federal program authorizes federal costs to be treated as such. Some federal program statutes require the grantee to contribute a certain amount of non-federal resources to be eligible for the federal program.

The net of all applicable credits. The term “applicable credits” refers to those receipts or reduction of expenditures that operate to offset or reduce expense items allocable to the federal award. Typical examples of such transactions are: purchase discounts; rebates or allowances; recoveries or indemnities on losses; and adjustments of overpayments or erroneous charges, such as credits. To the extent that such credits accruing to or received by the District relate to the federal award, they shall be credited to the federal award, either as a cost reduction or a cash refund, as appropriate. 2 CFR §200.406.


Any miles, points, credits, or awards accrued or earned for employee travel using a District-issued credit card (where the credit card bill is paid directly by the District) are the property of the District and will be used for employees travelling on behalf of the District to reduce the overall cost to the District. Any such miles, points, credits, or awards accrued will not be used for personal travel.

2 CFR Part 200’s cost guidelines must be considered when federal grant funds are expended. Federal rules require state- and District-level requirements and policies regarding expenditures to be followed as well. For example, state and/or District policies relating to travel or equipment may be narrower or more restrictive than the federal rules. In this case, the stricter State and/or District policies must be followed. Requesting Prior Written Approval Some costs discussed in the following sections and in the instructions to completing the grant application require prior written approval from the awarding agency. For TEA grants, prior written approval must be requested in accordance with TEA’s process. The District must submit the request in writing to the TEA Chief Grants Administrator. The Chief Grants Administrator may request additional information, as applicable, and may meet or consult with applicable TEA staff prior to responding to the District in writing. In addition, for certain costs that it may be difficult to determine reasonableness or allowability, the District may seek prior written approval for “special or unusual costs” not identified in the regulations in advance of the incurrence of such costs. This may prevent future disallowance or dispute based on “unreasonableness” or “non-allowability.” Prior written approval should include the timeframe or scope of the agreement. 2 CFR § 200.407. The assigned Coordinator or Director of the federal program will determine if and when the District should seek prior written approval for a certain cost prior to incurring the cost. Federal grant funds will not be expended for any costs that require prior written approval in accordance with 2 CFR 200, Subpart E, or the grant application instructions, if such prior written approval was not properly secured. Selected Items of Cost – 2 CFR Part 200, Subpart E 2 CFR Part 200, Subpart E, examines the allowability of 55 specific cost items (commonly referred to as Selected Items of Cost) at 2 CFR §§ 200.420 -.475. These cost items are listed in the chart below and may not be all inclusive. It is not assumed that an item is allowable because it is specifically listed, as it may be unallowable despite its inclusion in the selected items of cost section, or it may be allowable only under certain conditions, including prior written approval. The expenditure may be unallowable for a number of reasons, including: the express language of the regulation states the item is unallowable; the terms and conditions of the grant deem the item unallowable; or State/local restrictions dictate that the item is unallowable or allowable only under certain conditions or circumstances. The item may also be unallowable because it does not meet one of the factors affecting allowability of costs, such as being reasonable because it is considered too expensive. If an item is unallowable for any of these reasons, the District does not use federal funds to purchase it. Likewise, it is possible for the State and/or District to put additional requirements on a specific item of cost. Under such circumstances, the stricter requirements must be met for a cost to be allowable. Accordingly, employees consult federal, State and District requirements when spending federal funds. For example, the travel rules for grants administered by TEA are more restrictive than the federal cost principles allow, which means TEA’s policies must be followed.


In order for a cost to be allowable, the expenditure must also be allowable under the applicable federal program statute (e.g., Title I of the Elementary and Secondary Education Act [ESEA], or the Carl D. Perkins Career and Technical Education Act [Perkins]), along with accompanying program regulations, non-regulatory guidance, and grant award notifications. Most federal programs also contain the supplement, not supplant requirements. In general, this means that the District cannot use federal grant funds to pay for a cost or activity that is usually supported by state or local funds. In summary, for a cost to be allowable under a federal grant program, the District ensures it meets all of the following conditions. A cost that does not meet all of these conditions could be questioned during an audit or monitoring visit and could require repayment to the awarding agency. The cost must be: reasonable in cost (as described above) necessary to accomplish the objectives of the grant program (as described above) based on an identified need, concern, or area of weakness within the grant program appropriate under the authorizing program statute consistent with the underlying needs of the program in that it benefits the intended population of students or

teachers for which the funds are appropriated allocable to the grant based on the relative benefits received (as described above) authorized or not prohibited under state or local laws or regulations consistent with policies, regulations, and procedures that apply to all activities, including other grants and

state and local activities treated consistently as either a direct cost or as an indirect cost determined in accordance with GAAP not used to meet cost sharing or matching requirements of another federal grant (unless specifically

permitted in the other program statute or regulations) consistent with the terms and conditions of the grant award budgeted in the approved grant application adequately documented with appropriate supporting original source documentation the net of any applicable credits such as rebates or discounts allowable under the federal cost principles in most cases, supplemental to the core foundation program of the school and to other activities normally

conducted by the school (i.e., supplement, not supplant) if the school is a Title I schoolwide program, the grant program’s activities and applicable costs

must be included in the schoolwide plan, the school must have conducted a comprehensive needs assessment, and the plan must contain the required components specified in statute (see Title I, Part A, §1114[b]).

District personnel responsible for spending federal grant funds and for determining allowability must be familiar with the Part 200 selected items of cost section. District employees are required to follow these rules when charging these specific expenditures to a federal grant. In addition to checking the selected items of cost in Part 200, District staff must check costs against TEA’s Guidelines Related to Specific Costs, the Request for Application (RFA), local District policy, and any grant program restrictions to ensure the cost is allowable. Supplement/Supplant Most federal education grants contain the supplement, not supplant provision. In most cases, the expenditure of grant funds for a particular cost or activity must supplement, and not supplant, state or local funds. Therefore, supplement, not supplant is a crucial factor in determining whether a particular cost is allowable, and it must be understood by program and fiscal managers.


What Does Supplement, Not Supplant Mean? The intent behind supplement, not supplant, is that federal funds are not meant to substitute for state or local funds, but rather to provide for an additional layer of support for students who need extra academic assistance in order to succeed in school. Districts must demonstrate that federal funds are used to purchase additional academic and support services, staff, programs, or materials the state or District would not normally provide. The supplement, not supplant provision means, in general, that

Federal funds may not be used to replace activities normally funded from state or local funds. State and local funds may not be diverted for other purposes due to the availability of federal funds. Federal funds may not be used to support activities that are required by state law, State Board of Education

or Commissioner’s rule, or local policy. All students must receive the same level and quality of services from State and local resources. In other

words, State and local sources cannot be used to provide services to only some of the students, while Federal funds are used to provide services to the remaining students. (Schoolwide programs may be an exception.)

Federal funds must be used to supplement activities already being provided by the District, meaning they must be used to expand, enhance, or improve existing services and activities or to create something new.

Rebutting the Presumption of Supplanting Violations for supplanting with federal funds can be quite severe. If a grantee is determined to be supplanting with the entire program, the penalty could be as great as repaying 100% of the funds expended. Federal regulations require that a grantee repay funds in proportion to the harm to the federal government. Districts may be able to rebut the presumption of supplanting by an auditor or monitor. To determine compliance with the supplement, not supplant requirement, the District must determine what services would have been provided to students in the absence of federal funds. Generally in a situation where the District used Title I funds, for example, to provide services that it provided with non-Federal funds in the prior year(s), an auditor or monitor will presume supplanting occurred. The USDE provides excellent guidance on supplement, not supplant with regard to Title I, Part A in their Non-Regulatory Guidance on Title I Fiscal Issues, Revised February 2008. In addition, TEA’s Supplement, Not Supplant Handbook (under Handbooks) discusses supplement, not supplant as it applies to NCLB programs and other programs, including IDEA-B and Perkins. Both documents contain excellent information and examples as it pertains to rebutting the presumption of supplanting. Supplement, Not Supplant on Schoolwide Programs The fiscal requirements for supplement, not supplant are slightly different for Title I schoolwide programs than for Title I Targeted Assistance schools. In a Title I Targeted Assistance school, the District must identify low-achieving students and provide additional, supplemental services only to those identified students. In no case can federal funds replace state and local funds. (Refer to the archived USDE guidance on Targeted Assistance Schools for more information.) Unlike a Targeted Assistance program, however, a schoolwide program is not required to select and provide supplemental services to specific children identified as in need of services. A school operating a schoolwide program does not have to:


show that Federal funds used with the school are paying for additional services that would not otherwise be

provided demonstrate that Federal funds are used only for specific target populations separately track Federal program funds once they reach the school

A schoolwide program school, however, must use Title I funds only to supplement the amount of funds that would, in the absence of the Title I funds, be made available from non-Federal sources for that school, including funds needed to provide services that are required by law for children with disabilities and children with limited English proficiency. In other words, the same amount of state and local resources must still be spent on the school in order to conduct the regular academic program, and the amount of Title I funds must supplement, or be in addition to, the amount of state and local funds normally provided to that school [Title I, Part A, Section 1114(a)(2)]. The USDE provides helpful non-regulatory guidance on supplement, not supplant with regard to both Targeted Assistance schools and schoolwide programs. TEA also provides excellent guidance related to NCLB and other programs in a Supplement, Not Supplant Handbook: A Guide for Grants Administered by the Texas Education Agency. Again, it is important that District personnel involved in federal programs understand supplement, not supplant. School Districts are frequently cited for a supplant violation. On the surface, a particular cost may seem allowable in that it is reasonable, allowable under the federal cost principles, allocable, and appropriate under a federal program such as Title I, Part A. However, if the cost is not supplemental, all of the other factors do not counteract. All costs associated with a supplant violation would be required to be repaid to TEA or other federal awarding agency. How to Document Compliance for an Auditor Any determination about supplanting is specific to the individual situation, and general guidelines cannot be provided to meet the particular details of any situation. Examples of the types of documentation auditors may request from the District to demonstrate that the expenditure is supplemental to other federal and/or non-federal programs include the following:

Fiscal or programmatic documentation to confirm that, in the absence of federal funds, the District would have eliminated staff or other services in question

Board minutes/agendas with discussion of elimination of staff due to lack of state funds State or local legislative actions Itemized budget histories from one year to the next and information Planning documents Actual reduction in state or local funds Decision to eliminate position or services was made without regard to the availability of federal funds,

including the reason the decision was made Class-size data from previous years and upcoming year Specific policies and procedures related to supplement, not supplant requirements

Procedures for Complying with Supplement, Not Supplant The term ―supplement, not supplant is a provision common to many federal statutes authorizing education grant programs. There is no single supplement, not supplant provision. Rather, the wording of the provision varies depending on the statute that contains it.


Although the definition may change from statute to statute, supplement not supplant provisions basically require that grantees use state or local funds for all services required by state law, State Board of Education (SBOE) rule, or local policy and prohibit those funds from being diverted for other purposes when federal funds are available. Federal funds must supplement—add to, enhance, expand, increase, extend—the programs and services offered with state and local funds. Federal funds are not permitted to be used to supplant—take the place of, replace—the state and local funds used to offer those programs and services. The District process to ensure that all grant funded activities are supplemental shall be a collaborative effort between the assigned program Coordinators and Directors, finance, purchasing and all departments. All departments shall receive training and be aware of the supplement not supplant provisions. The assigned program Coordinators and Directors shall review and approve all purchases. The Grant Manager review shall include a determination if the planned purchase and/or expenditure meet one of the following guidelines:

The grant funds will be used to enhance, expand, or extend required activities. Examples may include tutoring, additional research-based instructional programs, or other supplemental expenditures not required by state law or local policy.

The grant funds will be used for specific grant activities included the grant application that are above and beyond the activities funded with local funds.

The grant funds will be used to supplemental grant activities as noted on the DIP or a CIP. The following practical questions may be asked when reviewing a purchase:

o Is the purchase really needed? o Is the expense targeted to a valid programmatic need? o Is the amount at a minimum needed to meet the need? o Is capacity in place to use what is being purchased? o Is a fair rate being offered? o Can the purchase be defended, if asked? o Does the purchase deviate from established practices or policies? o Is the purchase ordinary and necessary? o Is the purchase adequately documented as necessary, reasonable and allowable?

Program-specific supplement, not supplant provisions shall be complied with in addition to the overall federal funds requirements.

Translating Essential Information for Parents & Family Members The Clint ISD has an obligation to ensure meaningful communication with parents and/or family members in a language they can understand and to adequately notify parents and/or family members of information about any programs, services, or functions/activities within the district and its schools. Schools will communicate with parents and family members in a language and format a parent and family member can understand. This often will include translated documents and a language interpreter (if needed and upon request) for meetings and/or conversations. Schools will communicate with parents and/or family members important information and opportunities for their child(ren). The information includes but is limited to:

Registration and enrollment processes in school Grades, academic standards, and graduation


School rules and student discipline Attendance and withdrawal procedures Parent permission for activities/programs School closures (due to holidays, inclement weather and other situations) Opportunities to access programs and/or services (English language learner programs, advanced

placement, dual language programs, and other academic related programs, etc.) Special education and services available for students with disabilities

Schools will utilize various options to determine the common language(s) used at home through the data reported in various forms of school related documents, for example:

Home Language Survey Parent and Family Engagement Survey (the language used to complete the survey) Language used to complete the online student registration packet (returning students) Language used to complete the onsite student registration packet (new students) Other forms of school related documents

The data utilized to determine the common home languages will be documented in the district/campus needs assessment every year and strategies on ensuring parents and/or family members are provided with meaningful communication in a language and format they can understand are addressed in the district/campus improvement plans. For languages not common, the school may use a cover page explaining in those languages how a parent may receive oral interpretation of the form and should offer interpreters to ensure parents and/or family members accurately report their language communication needs on the form. The translation procedures are subject to change and will be modified in accordance to updates and guidance from the U.S. Department of Education (USDE) and the Texas Education Agency (TEA). Comparability of Services The Title I, Part A Comparability of Services report is one accountability requirement. The district will complete the required report, as required by TEA, and it will be reviewed by the Federal Programs Director and the Superintendent prior to submission. The report will be generated, calculated, completed and submitted by the Chief Financial Officer. The District is required to meet one test for all campuses across the board. The report is also generated during the budget process, more than once, to project comparability and ensure compliance, but will be finalized to meet submission deadlines as required. The measurements used to determine comparability are identified by TEA and issued in the Guidance Handbook. The measures and instructions will be adhered to and no deviations will occur. Any required adjustments will be made prior to the submission of the report. Since all campuses of the district receive Title I, Part A funds, the district must demonstrate that comparable state and local resources are provided to each Title I, Part A campus. The District will be considered to have met compliance with the comparability requirement through the submission of the comparability assurance document (CAD) which ensures the district has established and implemented the comparability requirements (refer to Legal and Local Policy EHBD – see below) as adopted by the Board of Trustees and referenced in the budgeting guidelines:

1. A districtwide salary schedule;


2. A policy to ensure equivalence among schools in teachers, administrators, and other staff; and 3. A policy to ensure equivalence among schools in the provision of curriculum materials and instructional

supplies. The Texas Education Agency (TEA) relies on data reported by districts through PEIMS to determine compliance with requirements in the federal guidelines, Texas Education Code and State Board of Education rules. TEA may request additional data, as necessary in order to clarify questions related to PEIMS data. Additionally, on‐site visits will be made in some districts to further assess qualitative and quantitative questions about supplemental programs. If TEA determines that a district supplanted the regular education program, then financial penalties may apply to the district. The Test To determine whether supplanting will occur, ask whether the service or material would, in the absence of supplemental funds, have been supported with state or local funds. If you did not have (supplemental) funds, would you still buy/pay for (service/material)? If you did not have Title I funds, would you still buy student desks for each regular classroom? If you did not have Title I funds, would you still purchase the ABC software package for your program? If the answer is YES, this may be supplanting. State and local funds which previously funded activities cannot be diverted to another purpose simply because funds are available to support those activities. If the answer is NO, the funds are being use to supplement the educational program. Comparability of Services All purchases must follow Board Policy EHBD (Local): The Board shall ensure equity in services among campus programs and shall maintain appropriate records reflecting equity. As reflected in District records, equity shall be maintained Districtwide in one of the following areas:

1. Expenditures of money per student from state and local funds;

2. Instructional salaries per student from state and local funds; or

3. Instructional staff/student ratios.

In special programs, such as special education and bilingual education, a lower ratio may be maintained and more money may be spent as necessary to fulfill other legal requirements. [See DEA] Special Revenue Fund Guidelines— Scientifically Based Research According to federal guidelines, all activities and programs should be supported with Scientifically Based Research. The U.S. Department of Education defines scientifically based research as research that –

• Employs systematic, empirical methods that draw on observations or experimentation. • Involves rigorous data analyses that are adequate to test the stated hypotheses and justify the conclusions

drawn. • Relies on measurements or observational methods that provide reliable and valid data across evaluators

and observers, across multiple measurements and observations, and across studies by the same or different investigators.


• is evaluated using experimental or quasi-experimental designs in which individuals, entities, programs, or activities are assigned to different conditions and with appropriate controls to evaluate the effects of the conditions of interest, with a preference for random-assignment experiments, or other designs to the extent that those designs contain within-condition or across-condition controls.

• Ensures experimental studies are presented in sufficient detail and with clarity to allow for replication or, at a minimum, offer the opportunity to build systematically on their findings.

• Has been accepted by a peer-reviewed journal or approved by a panel of independent experts through a comparably rigorous, objective scientific review.

Indirect Costs The Clint ISD general management costs are costs and activities that are for the direction and control of the district affairs that are organization wide, such as central accounting services, payroll preparation and personnel management. Indirect cost will be applied to grants in accordance to grant guidelines and at the approved rate stated in the guidelines. The indirect cost rate, contained in the eGrants system for requesting reimbursement may not agree with the grant requirements, and will be verified prior to submission of any reimbursement requests by the district Accounting Specialist and by the district Chief Financial Officer. For the fiscal year 2018-2019, the Texas Education Agency (TEA) received a new delegation agreement from the U.S. Department of Education (USDE) that specifies the USDE-approved rate calculation methodology. The following provisions are mandated by the USDE:

1. No indirect cost rate extensions are allowed, and all indirect cost rate extensions beyond 2017–2018 are rescinded. New rates must be calculated every fiscal year.

2. Three years of financial data must be used to calculate an indirect cost rate (for instance, to calculate rates for fiscal year 2018–2019, financial data from 2014–2015, 2015–2016, and 2016–2017 will be utilized).

New Process for Requesting an Indirect Cost Rate for ISDs Effective with school year 2018–2019, ISDs must request an indirect cost rate each year by completing and submitting the Indirect Cost Rate Proposal (ICRP) Additional Costs Workbook. The deadline for submitting the workbook, and thus requesting an indirect cost rate, is January 26, 2018.

The submission of the ICRP Additional Costs Workbook serves as an ISD’s request for an indirect cost rate. Rates will only be calculated for ISDs that submit a completed workbook. If the ISD does not submit a completed workbook, TEA will not calculate or issue a rate for that ISD for the 2018–2019 school year.

In the completed workbook, the ISD provides approximately 10% of the data required to complete the ICRP. The remaining 90% of the required data are drawn from the ISD’s certified Public Education Information Management System (PEIMS) data.

TEA will populate an ICRP for each ISD that submits a workbook by merging PEIMS data with the ISD’s submitted data. TEA will then provide each ISD with its completed ICRP for review and certification. Information regarding ISD certification of the completed ICRP will be provided in early 2018.

https://tea.texas.gov/About_TEA/News_and_Multimedia/Correspondence/TAA_Letters/2018%E2%80%932019_Process_for_Requesting_Indirect_Cost_Rates_(Independent_School_Districts_Only)/

Roll‐Forward (Carryover Funds) The Business Services Department will be notified upon receipt of the Notice of Grant Award (NOGA) by the Texas Education Agency (TEA). Budget appropriations will be submitted to the Business Services Department. The


appropriations made with the roll‐forward will be based on the identified needs and recommendations made by departments and/or campuses. The roll‐forward funds will be appropriated by the Business Services Department and will be expended accordingly in a timely manner. The department/campus administrator will verify the appropriations have been placed in the correct account code(s).

The Program Director will ensure the funds are distributed in accordance with the application requirements. Documentation of expenditures will be maintained by the department/campus to ensure all activities are in compliance with federal requirements. The Program Director and Business Services Department personnel will ensure all activities are allowable and meet the federal requirements. Monthly budget/account reports will be reviewed for compliance as well. District Purchases All district purchases must follow the procedures outlined in Administrative Regulation CHD(R). All District purchases will be made with an approved purchase order. The District will assume no responsibility for purchases made without an approved purchase order.

1. Purchase orders will be processed through the District Finance System.

2. District purchases must be made to approved vendors and must comply with state, federal and local purchasing guidelines. A procurement review is conducted by the Department of Federal Programs.

3. Purchase orders may require approval at the central office level by the Technology, Federal Programs,

Curriculum & Instruction, Special Education Departments or the Superintendent.

4. Purchase orders must be processed at the campus or departmental level with sufficient time to allow for the delivery of the materials and/or equipment within the required time. The campus or departmental level must insure a pro‐active time frame for such.

5. If an attachment is required for purchase order the campus or department must attach all completed

documents to the request via finance system procedures.

6. Once approved, the campus or department will forward fully approved purchase orders to the vendor, unless the vendor is an e‐vendor. E‐vendors receive requests directly via the finance system. E‐vendor information will be present on the purchase order.

7. Purchase orders must be complete to include the following:

• Include three quotes for the purchase, • complete vendor information, • quantity, • unit prices, • shipping and handling costs, • contract codes, • commodity codes, • DIP / CIP (Goal, Performance Objective and Strategy) • correct account coding • reasonable and accurate descriptions,


• applicable discounts, • federal funds procurement justification form should be completed and included in the purchasing

process (if needed), • And other completed approved attachments.

8. Once a purchase order has been processed, it is the responsibility of the initiating campus or department

to monitor the receipt of the purchase. All purchase orders must be received timely through the District Finance System in order to provide prompt payment to the vendor. Campus and departments must monitor receiving information and contacts vendors when appropriate.

9. Technology equipment purchases will follow the guidelines as issued by the Technology Department.

10. Furniture orders will be requested by completing and forwarding a purchase requisition to the Business

Services Department. The Business Services Department will research for surplus items or appropriate vendors and obtain a quote for the items requested. Once the research is finalized, the Business Services Department will forward all appropriate documents to the initiating campus or department for processing.

11. District purchases will be made in accordance to District regulations and guidelines in order to meet the

needs of the campus or department and the District. Cost comparisons will be made in order to obtain the best product for the least cost. All purchases will be made in accordance to campus and district plans.

12. District purchases must be completed by the dates communicated on the District Purchasing Cut Off

Calendar. Principals, Supervisors or other parties are responsible for budgets and may issue earlier cut‐off dates. All start up supplies must be ordered within this time frame. District purchasing will resume the following September.

Technology Purchases

New Technology Equipment Purchases New computers must meet the following minimum requirement to sustain a 3-5 year lifecycle

Minimum Core i3 processor or comparable Minimum 4gb Memory Minimum 64gb SSD (no spinning HDD) Network Port if possible 3yr warranty

All technology related purchases to include mobile devices that require imaging (laptops, desktops, iPads, Chromebooks) will be shipped directly to the campuses. The Budget Clerk will receive the equipment and verify that all equipment on the purchase requisition and shipping order is accounted for. Within 10 business days of receiving the equipment on campus the Budget Clerk will inventory all equipment of $50 or more in Gigatrak to include the brand, model, serial number, PO number, funding code, and location. They will also ensure at the all equipment is clearly and visibly labeled with the fund code, grant name, school year, purchase requisition number, and location. They will also place a “C” (no larger than 1 inch) on the left side of the equipment with a silver sharpie. The “C” must be clearly visible to meet federal guidelines. The Budget Clerk must submit a ticket on Schooldude for all equipment that needs to be imaged. The technology department is then expected to complete the necessary imaging process to CISD standards and close the ticket within 10 business days. All tickets should be completed at the campus. There are exceptions when technology equipment must be taken off


the campus at which time the technician must make note of the fact that they are taking the equipment off campus on the ticket and inform the Budget Clerk who will update the location of the equipment on Gigatrak. The campus budget clerk or campus assignee will need to check out the equipment to the responsible party or assigned location for inventory purposes within 10 business days of receiving the equipment on campus. The signed User Device Agreement can be uploaded to the ‘Images & Docs’ section on Gigatrak.

End of Year and Summer Checkouts ALL technology equipment must be checked in to the campus by teachers, faculty and staff at the end of the school year and documented on the campus clearance form. Technology equipment must be stored in a safe location for summer storage. Access to the location should be limited to 3 personnel assigned by the campus principal.

Principals will have the discretion to allow devices to be checked out for summer school or campus related activities. Devices will need to be checked out from Gigatrak for summer use and a Summer Device Agreement Form must be signed.

At the Start of the School Year ALL devices will be checked out using Gigatrak for teachers, faculty, and staff. It is the expectation of the district that equipment purchased with district funds must be on campus for instructional purposes. All devices are subject to spot checks and audits. If a device is not on the campus during an observation, spot checks, or audits, the staff member will receive a written warning. After 2 consecutive written warnings a written incident will be filed in their personnel file.

Lost/Stolen Equipment All lost/stolen equipment must have a police report filed w/in 48 hours with the campus SRO, police department. or sheriff’s department. The Budget Clerk must then change the ‘Condition’ on Gigatrak to ‘Lost’ or ‘Stolen’ and enter the case number for the report made on the ‘Note’ section under Tool Information (F2). Campuses must hold teachers, faculty and staff accountable for any lost/damaged devices. In the event technology equipment in missing and not replaced, the campus will be held responsible for monetary losses.

The User Device Agreement form states: I, the under signed, hereby agree to take responsibility for the item / s listed below. In the event that any of the item / s below is lost or broken I understand that I am responsible for replacing it with the exact item or making payment in the amount of the value stated below to Clint ISD. All items must be replaced or paid for within a 30 day period or the replacement value will be deducted from my next payroll check. Additionally I understand that cell phone overages will automatically be deducted from my next month's payroll check.

Repairs of Technology Equipment All repairs of technology equipment must be submitted using a SchoolDude ticket. It is the expectation of the technology department to attempt complete the ticket within 3 business days. All tickets should be completed at the campus. There are exceptions when technology equipment must be taken off the campus to ship to vendors for warranty and repairs. In those cases, the SchoolDude ticket must be updated to notify the principal, budget clerk, librarian, and the user who initiated the ticket when the device was removed from the campus and when it was returned. In addition, the equipment must be checked out in Gigatrak when the device leaves and returns to the campus. This will provide evidence the device was removed and returned to the campus. Disposal, Salvage or Transfer of Equipment ALL equipment must remain at the campus until all salvage or transfer requirements have been met and approval by Federal Programs and Business Services has been completed.


All requests to salvage poor, broken, or obsolete equipment must have a Fixed Assets Transfer form completed by the campus. It must include the funding code and PO in order to comply with procedures by TEA and district policy. The Budget Clerk must then change the ‘Condition’ in Gigatrak to ‘Salvage Pending’ for all equipment listed on the Fixed Asset Transfer form. Transfer of equipment from one campus or location to another must also have a Fixed Assets Transfer form completed. Before the Fixed Asset Transfer form in completed the budget clerk must first check that no other core content teachers/programs or students at the campus needs the equipment. If the equipment is no longer needed on the campus the budget clerk must check to see if core content teachers/programs or students at another campus needs the equipment. Once the Fixed Asset Transfer Form has been completed the ‘Condition’ in Gigatrak must be changed to ‘Transfer Pending’ for all equipment listed on the form. In cases where all items from a PO are being salvaged or transferred, all items must be accounted for before approval will be provided. Items missing/lost/stolen from the purchase order must be accompanied by a case number showing a police report was filed by the campus.


Recycle of Chromebooks Chromebooks that were purchased with only 1 year warranty will need to be maintained to sustain a lifespan of 3-5 years. As devices are broken/damaged, a Fixed Assets Transfer form must be completed to salvage the equipment. If the Chromebook was purchased with Federal or IMA Funds, all attempts to maintain the device in circulation will be made. Technology will clean the broken/damaged devices for working parts. Cases and motherboards will stay intact and sent to salvage.


Record Keeping/ Management In general, records document the use of funds, compliance with program and fiscal requirements, and the performance of the grant. In accordance with 34 C.F.R. §§ 76.730-.731 and §§ 75.730-.731, the District maintains all records that fully show (1) the amount of funds under the grant or subgrant; (2) how the District uses those funds; (3) the total cost of each project; (4) the share of the total cost of each project provided from other sources; (5) other records to facilitate an effective audit; and (6) other records to show compliance with federal program requirements. The District also maintains records of significant grant project experiences and results. 34 C.F.R. § 75.732. These records and accounts must be retained and made available for programmatic or financial audit. Pursuant to the provisions in 34 C.F.R. § 81.31(c), the USDE is authorized to recover any federal funds misspent within 5 years before the receipt of a program determination letter. Consequently, in accordance with TEA’s General Provisions and Assurances and the statute of limitations, the District retains records for a minimum of five (5) years from the date on which the final expenditure report is submitted or the ending date of the grant, whichever is later, unless otherwise notified in writing to extend the retention period by TEA or other awarding agency. However, if any litigation, claim, or audit is started before the expiration of the record retention period, the records will be retained until all litigation, claims, or audit findings involving the records have been resolved and final action taken. 2 C.F.R. § 200.333 Local governments in Texas, including all school Districts, open-enrollment charter schools, and ESCs, are required to implement a Records Management Policy, designate a Records Management Officer to oversee the policy, and comply with a Records Retention Schedule. The Texas State Library and Archives Commission (TSLAC) administers the records management requirements pursuant to the Local Government Records Act, Local Government Code, Chapters 201-205, and Chapter 441, Subchapter J, published as Local Government Bulletin D on TSLAC’s website. The District retains and destroys records in accordance with these requirements. Failure to produce a program or fiscal record for an auditor or monitor during the 5-year retention period will most likely result in an audit or monitoring finding and the repayment of funds for the missing documentation. Records That Must Be Maintained A record is any recorded information that documents school business; it serves as evidence that an activity, event, decision, or transaction occurred. A record must be retrievable at a later date (i.e., for 5 years after the ending date of the grant or after submittal of the final expenditure report, whichever is later). Not every piece of paper or every piece of data is an official record. Materials used for reference are just that – reference materials; they are not records. District personnel must use some judgment in determining whether a record constitutes an “official business record” by looking at the content of the record to determine its value in serving as evidence. A good place to start is by consulting the District’s Records Specialist. The Records Specialist serves as the District’s Records Management Officer. Records are created by the District to support a grant activity and they are retained as evidence of that activity. Records may come in a variety of different forms and may be created by the District or be received by the District in any medium, including hard copy paper or electronic, audio, or video. Whether the District creates it, or receives it from someone outside the District, if it documents school operations, it’s a record and must be retained according to the records retention schedule.


Most e-mails are records; telephone messages can be records. The record can be on a computer’s hard drive, on a USB, on a DVD, in a filing cabinet, or on someone’s desk. Even if the record contains confidential information and may be exempt from release under a Public Information Request (PIR), it is still a record and must be retained using proper security procedures to safeguard the confidential data. Records generally include but are not limited to:

General correspondence, including letters and e-mail Handwritten notes and electronic notes Completed forms and reports and the data used to complete the reports Personnel documentation Websites created by the District Audio tapes and video tapes Final, complete, and signed (if applicable) documents Plans, photographs, or drawings Data in spreadsheets and databases Financial records, including but not limited to budgets, accounting ledgers, all supporting

documentation for expenditures, copies of checks, bank statements, etc.

Records generally do NOT include: Convenience copies (extra identical copies created only for convenience of reference or research) Drafts of documents Copies of documents furnished to the public to fulfill a PIR Blank forms/stocks of publications (keep at least one copy for archives to demonstrate compliance or proof

of program activities) Library or museum materials Dispute resolution working files (the final written finding or report is a record) Personal or junk e-mail Ccs of e-mails (or letters) or convenience copies of e-mails (or letters) (the recipient in the “To” line is the

keeper of the official record) Campus/Department Responsibilities The campus Principal or Department supervisors are the custodians of the records while at their locations, and are responsible for the records “safekeeping” until picked up by the Districts Records Specialist. Training The campus Principal or Department supervisors shall appoint at least one person from their campus/department to attend District trainings related to records management. Trainings will be held at least once annually by the Business Services Department. Annual Retrieval The District’s Records Specialist will provide a schedule for retrieving records from the campuses/departments on an annual basis. Records will be taken and stored at the District records warehouse. Campuses/Departments must order the “uniform” records retention boxes from the Business Services Department prior to their scheduled pick‐up date. Records shall be stored and properly labeled by type or “like” record and by retention period; utilizing the state required “Retention Schedule for Records of Public School District” provided on the District’s web site.


Required Forms The following forms are required and are available on the District’s web site.

• Records Warehouse Transfer Form ‐ completed and submitted when submitting records to the District records specialist for transferring records to the District’s records warehouse.

• Intra‐District Records Request Form ‐ completed and submitted when District personnel are requesting a file(s) or record(s) from the District records warehouse.

• Student Transcript Request Form ‐ completed and submitted for requests for student transcripts (form includes procedures).

Destruction of Records Because records establish compliance with the use of funds and with program and fiscal requirements, failure to retain the proper records or to dispose of them prematurely can result in monumental problems for the District, including the repayment of all funds associated with the activity, event, decision, or transaction for which the records are missing. In addition, destroying or disposing of a record improperly or prematurely constitutes a Class A Misdemeanor under state law. The District cannot destroy any record that is involved in an ongoing litigation, claim, negotiation, public information request (PIR), audit or investigation, and administrative review or hearing. The District’s Records Management Policy includes policy and procedures for disposing of records. Records can only be destroyed in accordance with the Records Retention Schedule adopted by the District. Records that are not on the Records Retention Schedule may require written permission from the TSLAC prior to disposing. Procedures include maintaining a “records disposition log” that identifies the disposition date and method of disposal of each record. According to Local Government Code, §202.003, confidential records must be burned, shredded, or pulped. Open records can be burned, shredded, pulped, recycled, or buried in a landfill. If a contractor is hired to destroy records, the contractor must comply with all of the state and local government laws pertaining to the destruction of records as if it were the District. The only person in the District legally authorized to destroy or “approve to destroy records” is the District’s Records Specialist. The one exception to destruction of records pertains to duplicates or copies of an original record and the original record is required to be retained at another department. Duplicates and copies should only be kept while “Administratively Valuable” (AV) to the campus/department. These duplicates/copies will not be retrieved by the District’s records manager and must be destroyed at the campus/department by shredding. Financial Reporting of Federal Funding All official financial reports must come through the Business Services Department. Only the Business Services Department can provide official reports for all federal funding. Financial reporting will be in accordance to Board Policy BR (legal) and CFA (legal). Business Services will review all reports with appropriate personnel responsible for the specific federal grant. All managers of the grants and recipients will be aware of deadlines in order to comply with grant guidelines and ensure that all funds are spent on a timely manner. Funds are monitored by grant managers, Chief Financial Officer, Assistant Superintendent(s) of Curriculum & Instruction and any other appropriate personnel. Budget deadlines are set by the Superintendent and Cabinet.

• Periodic meetings with Director of Federal Programs, Chief Financial Officer, Assistant Superintendent(s) of Curriculum & Instruction and other appropriate personnel are held to review budgets, balances, and expenditures.


• Periodic meetings with director of federal programs and campus principals. • Annual meeting with the personnel department to review federally funded personnel.

Other Programs and Related Services Homeless Program Identification of Students The Homeless Liaison for the district will identify the homeless students in the district using the student residency questionnaires received from each campus. The homeless liaison will code the eligible students on PEIMS. The PEIMS clerk at the campus will receive the appropriate documentation for them to file in the student At‐Risk file. The PEIMS Clerk is required to code the eligible student for the free lunch program (PEIMS Code 99). The homeless liaison will ensure all homeless students are reviewed for eligibility on a yearly basis. Campus personnel will work with Homeless Liaison to ensure the needs of the students according to the McKinney‐Vento Program are identified and addressed. Reports for homeless students will be provided and discussed with the Director of Federal Programs and/or the Parental Involvement Specialist on a monthly basis or as needed. The Texas Education for Homeless Children and Youth (TEHCY) grant was awarded to Clint ISD to support homeless students with academic and social services while enrolled with the district. Other Services Provided

• Referrals to an immediate shelter. • Referrals to government agencies for social services to include medical services. • Referrals to food pantries in the El Paso County area(s). • Assistance with student transportation to the school of origin (on a need be basis).

Local Point of Contact Clint ISD has designated a point of contact to oversee the identification and provisions for children in homeless situations and ensure educational stability while attending schools in the district.

Angelica Venzor, Parental Involvement Specialist

District Homeless Liaison Phone number: (915) 926-3255

Email Address: [email protected] Foster Care & Student Success Clint ISD Procedures for Ensuring Education Stability for Children in Foster Care In December 2016, the Texas Education Agency released guidance on providing services to children in foster care. The foster care procedures have been developed in accordance with the Non-Regulatory Guidance: Ensuring Educational Stability for Children in Foster Care manual dated June 23, 2016. The manual can be found on the Texas Homeless Education Office website at: http://www.theotx.org/wp-content/uploads/2016/08/ed-hhs-fostercare-nonregulatory-guide.pdf on 10/11/2016. The procedures were finalized on 11/29/2016 by the Clint ISD Department of Federal Programs. A meeting was held on 2/2/2017 with district key personnel and Texas Department of Family & Protective Services to review and modify the current procedures. Below are the modified foster care procedures for the 2016-2017 school year and thereafter. The federal Fostering Connections to Success and Increasing Adoptions Act of 2008, Public Law 110351, was launched to increase the education stability of and improve education outcomes for youths in school. The legislation requires child welfare agencies to collaborate with the educational institutions to keep children in foster care in the same school when living placements change, if remaining in that school is in their best interest.


Legislation requires child welfare agencies to ensure that children in foster care who do change schools are promptly enrolled in a new school, with the relevant school records. On December 2015, the Every Student Succeeds Act (ESSA) was passed through Congress, which authorized the Elementary and Secondary Education Act of 1965 (ESEA), and built on the legislative successes by instituting new protections for children in foster care. On December 10, 2016, the legislative provisions will take effect which will require the Texas Education Agency and Local Education Agencies to work with child welfare agencies to ensure the educational stability of children in foster care are implemented. The Clint Independent School District has designated the roles and responsibilities of the Foster Care Liaison to Roberto Flores, Federal Programs Director. It is the responsibility of the Foster Care Liaison to ensure the enrollment processes are streamlined for students in foster care as well as implementing student data tracking and monitoring mechanisms; provide foster care‐related information and training to the district and work collaboratively with the Department of Family and Protective Services to help students maintain their school placement, when appropriate. Educational Stability Clint ISD will emphasize the importance of limiting educational disruption by keeping children who move in foster care (due to entering the foster care system or change in placement) in their schools of origin, unless it is determined to be in their best interest to change schools. Educational stability requirement for children in foster care include the following:

A child in foster care remains in his or her school of origin, unless it is determined that remaining in the school of origin is not in that child’s best interest;

If it is not the child’s best interest to stay in his or her school of origin, the child is immediately enrolled in the new school even if the child is unable to produce records normally required for enrollment; and

That the new (enrolling) school immediately contacts the school of origin to obtain relevant academic and other records. (ESEA section 1111(g)(1)(E)(i)-(iii)).

Foster care is defined as a 24-hour placement or substitute care for children placed away from their parents or guardians and for whom the child welfare agency has placement or care responsibility.

o Placements include but not limited to: foster family homes foster homes of relatives group homes emergency shelters residential facilities child care institutions pre-adoptive homes

Child Welfare Agency – Required Enrollment Documents for Submission to Clint ISD Schools Form 2085FC Placement Authorization Foster Care/Residential Care

(https://www.dfps.state.tx.us/site_map/forms.asp)

The Child Welfare Agency will be required to have an educational stability plan in a child’s case record, which is jointly developed with the child’s parents no later than 60 days after a child’s removal from the home, and every six


months thereafter. The agency will have the flexibility to determine which factors will be examined in determining whether remaining in the school of origin is in the child’s best interest, but the cost of school transportation should not be a factor in determining the best interest of the child for the purposes of school selection. Pre-School Age Children in Foster Care Clint ISD will ensure that a child in foster care remains in his or her preschool of origin, unless a determination is made that it is not in the child’s best interest. Special Education Services and Section 504 Clint ISD will make available a range of placement options to meet the needs of children with disabilities for special education and related services, including regular classes, special classes, separate schools, home instruction, and instruction in hospitals and other institutions. An educational placement of a child with a disability must be made by a group of knowledgeable persons. The group may include staff from the child welfare agency and meet annually, and be in accordance with the child’s individual needs. English Language Learners Clint ISD will ensure English Learners (ELs) children in foster care will participate meaningfully and equally in the Bilingual and ESL programs. School of Origin Clint ISD will ensure that a child in foster care enrolls or remains in his or her school of origin unless a determination is made that it is not in the child’s best interest. Should the child’s foster care placement change, the school of origin would be considered the school in which the child is enrolled at the time of the placement change. A call will be made from the CPS Specialist to the District Foster Care Liaison to inform Clint ISD of the transportation needs for the children in foster care. The focus is to ensure the stability of the child’s educational process.

School of Origin – is defined as the school in which a child is enrolled at the time of placement in foster care.


Example of Child’s Placement in School(s)

Diagram 0.1a

When a student exits foster care placement Clint ISD will ensure educational stability to students exiting foster care by ensuring the child continue in the school of origin through at least the end of the academic year, if appropriate. It is important for children to be able to maintain connections with their peers, teachers, and other supportive adults at their school. Best Interest Determination – FFC Regulation – Exhibit A Clint ISD along with the child welfare agency will have the flexibility in determining the factors considered in the evaluation of a child’s current education setting that pertain to a child’s best interest. The factors that will be evaluated and considered are as follows:

Preferences of the child; Preferences of the child’s parent(s) or educational decision maker(s) Placement of the child’s siblings; Influence of the school climate on the child, including safety; The availability and quality of the services in the school to meet the child’s educational and socioemotional

needs; History of school transfers and how these have impacted the child academically; How the length of commute/travel time would impact the child, based on the child’s developmental state;

Student enters foster care and place of residence changes

School A ‐ School of Origin (Now is 10 miles away from new place of

residence)

School B is closer (The Child Welfare Agency & District determine that it is in the student's best interest to attend this

school.) ‐ Student is enrolled.

A year later, the child's placement changes along with the place of

residence.

School B is now 5 miles away from the new place of residence.

School C is the closest school to the new residence.

School B is now considered the child's school of origin. It is the school the

child is currently enrolled in.


Whether the child is a student receiving services through IDEA or Section 504, the availability of services in school other than the school of origin;

Whether the child is an English Language Learner and is receiving services, the availability of those services in a school other than the school of origin.

The Foster Care Liaison, along with district staff, and other key partners will meet to discuss the child’s best interest determination as needed. The Foster Care Liaison will work closely with the child welfare agency to reach an agreement regarding the appropriate school placement of children in foster care. The child welfare agency, being the conservatorship of the student, will make the final determination on the child’s educational placement. Clint ISD will ensure the child remains in his or her school of origin while a determination is made. The form will be completed by the administrator, administrator designee and/or school counselor upon request by the Child Welfare Agency (as needed.) The school will submit a copy of the completed form to the District Foster Care Liaison in the Department of Federal Programs as quickly as possible, in order to prevent educational discontinuity for the child.

Best Interest Determination Flow Chart

Diagram 0.1b

Dispute Resolution Clint ISD will ensure the educational stability of children in foster care. The district will work closely with the child welfare agency to reach an agreement regarding the appropriate school placement of children in foster care. If a disagreement on the decision made should arise, the child welfare agency will be considered the final decision maker. The child welfare agency will make the final determination on the child’s educational placement.

Child Welfare Agency informs the school new placement of residence.

School provides agency with the appropriateness of the current

educational setting.

The Foster Care Liaison will work closely with the Child Welfare Agency to reach an agreement regarding the appropriate school

placement of children in foster care.

Child Welfare Agency and school representatives and other key

partners meet to determine child's school placement (if needed). Child remains in the same school until the determination for school placement

is made

The child welfare agency determines the child will remain in the school of origin. The Foster Care Liaison will make transportation arrangements for the child to remain in the school

of origin.


A dispute resolution process will be fair in nature and will be reached in a prompt manner. The district will provide each stakeholder as appropriate with a written explanation of the best interest determination for the child in foster care. The district will ensure the child remains in his or her school of origin while any disputes are resolved to minimize the academic disruptions while reducing the amount of moves between schools. Currently, the district will ensure that this process will be updated as situations arise or on a case-by-case basis. The procedures will be updated as appropriate. Transportation – FFC Regulation – Exhibit B Clint ISD will collaborate with the local child welfare agency to ensure that transportation for children in foster care is made available in order for children to remain in their school of origin when it is in their best interest to continue attending the school. It is important to keep in mind that transportation costs should not be considered when determining a child’s best interest. Clint ISD has developed a clear written procedure on how transportation arrangements will be met to ensure that children in foster care remain in their schools of origin, when in their best interest, will be provided, arranged and funded for the duration of the child’s time in foster care. The Individual Transportation Plan for Student in Foster Care – FFC (Exhibit B) form will be generated by school representative. The CPS Specialist will contact (email or phone call) the Foster Care Liaison when it is recommended the student in foster care is to remain in their school of origin. The form will be initiated and completed by the Foster Care Liaison and kept internally for processing through the Clint ISD Transportation Department and for audit purposes. Additional key stakeholders will be asked to provide their input and a signature will be obtained, as needed. Clint ISD and the local child welfare agency will work together to ensure transportation to children in foster care is available in a cost effective manner at all times. The district along with the child welfare agency will address transportation costs through a joint collaboration between both entities to ensure a decision is made to apply one of the following requirements for the additional costs incurred when providing transportation to the school of origin to children in foster care:

1) The local child welfare agency agrees to reimburse the district for the cost of transportation; 2) The district will agree to pay for the cost; 3) The district and the local child welfare agency will share the costs.

Ongoing meetings will be scheduled as needed between both entities to discuss possible cost effective, reliable, and safe transportation options. The following are examples of cost effective transportation options that the district will ensure to utilize when providing transportation to a child in foster care to the school of origin:

The student may be dropped off at a school bus stop/location near the existing transportation route for the school of origin;

The foster parents or other family member(s) are able to transport student to the school of origin; There are existing bus routes or stops close to the new foster care placement that cross district boundaries,

such as bus routes for other coordinated programs and transportation for homeless students as required by the McKinney-Vento Act;

The student is already eligible to receive transportation by other programs and services to include IDEA (only when the student’s IEP determines that transportation is a service that is required for a child with disabilities in foster care to receive FAPE.)


The district will ensure that additional costs incurred in providing transportation to the school of origin should reflect the difference between what the district would spend to transport a student to his or her assigned school and the cost of transporting a child in foster care to his or her school of origin. Additional costs are those costs that are visible when:

The difference between the special transportation costs (private bus/vehicle or transportation company) and the usual transportation costs for transporting a child.

The costs incurred when the district must reroute busses to transport a child in foster care to one of its schools.

It is highly recommended that the district and the child welfare agency consider and utilize all possible funding sources (including federal funds – Title I funds) to cover the addition transportation costs as deemed necessary.

Clint ISD Local Transportation Procedures of Foster Care Children to the School of Origin (Subject to change due to guidance information released by the Texas Education Agency)

Diagram 0.1c

Immediate Enrollment and Records Transfer Clint ISD will ensure children in foster care who change schools are not denied enrollment due to lack of required documents. The Registrar of the enrolling school will contact the student’s prior school for records. The district will review and revise policies and practices in order to remove any barriers to immediate enrollment and records transfer for children in foster care.

Local Child Welfare Agency point of contact communicates with Foster Care Liaison

Foster Care Liaison will complete the transportation plan and submit the form for input and signatures

from all key statekholders.

Foster Care Liaison coordinates transportation services with transportation department.

Transportation department will ensure services are made available to foster care student immediately

(within a 3 business day turnaround time)

Transportation department will alert the Foster Care Liaison once services have been coordinated.

Foster Care Liaison will contact CPS Specialist and provide the transportation plan.

The CPS Specialist will inform the Foster Care Liaison when a change in placement occurs within a 24 hour time period and/or when transportation services are

no longer needed.


State and Local Points of Contact Clint ISD has designated the following points of contact to oversee the provisions for children in foster care and ensure educational stability while attending schools in the district.

Roberto Flores, Director of Federal Programs District Foster Care Liaison

Phone number: (915) 926-3255 Email Address: [email protected]

Angelica Venzor, Parental Involvement Specialist


The district points of contact will ensure:

To work with the child welfare agency on the implementation of the Title I requirements; To develop and document processes for making the best interest determination(s); To facilitate the data sharing between stakeholders and following the FERPA privacy requirements; To develop and implement local transportation procedures and make necessary revisions to them as

deemed appropriate; To manage the best interest determinations and transportation disputes as needed; Children in foster care are enrolled in school and are regularly attending school; and Professional development and training is made available to school staff on the Title I requirements and

meeting the educational needs of children in foster care are conducted annually.

The local Child Welfare Agency has designated a point of contact for the agency to ensure a successful and sustainable collaboration between the district and the agency is evident.

Texas Department of Family & Protective Services

Rosa Masilang, Education Specialist Phone number: (915) 521-3862

Email Address: [email protected]

Texas Department of Family & Protective Services Lorena Maldonado, CPS Service Program Administrator


Student Data and Privacy Data sharing between the district and the child welfare agency is important in improving the educational outcomes of children in foster care. The Foster Care Liaison will ensure that student privacy, including FERPA and other privacy requirements under state, federal and local policy are adhered to. The Foster Care Liaison and the Child Welfare Agency will collaboratively work together to monitor and support the education success of the child, assist with the transitions, and make sure that the child is receiving the appropriate services and interventions. The Child Welfare Agency or other agencies will follow the requirements for requesting student records as defined in local policy (FL) - http://pol.tasb.org/Policy/Download/436?filename=FL(LOCAL).pdf. Collaboration The Region 19 Education Service Center has formed a Foster Care Education Coalition committee of stakeholders from various entities to collaborate in the shared vision of supporting the educational well-being of children in foster


care. The collaboration will be on-going and will meet as need to improve the efforts to meet the academic needs of all children in foster care. Migrant Education Program Identification and Recruitment of Students – services provided through Region XIX ESC A Migrant recruiter will identify migrant students in the district. The migrant recruiter will code the students on the New Generation System (NGS) and the Migrant Student Information Exchange (MSIX). The migrant recruiter will ensure all requirements for NGS are entered on a monthly basis. The Region XIX Education Service Center migrant personnel will provide reports for identified migrant students to the Director of Federal Programs. Parent Meetings – services provided through Region XIX ESC Migrant personnel will ensure a Parent Advisory Council (PAC) meets on a monthly basis and conduct migrant parent meetings to provide information, and services to migrant parents as stated under Title I, Part C. Credit Recovery and other academic needs The student’s academic needs will be identified by Region XIX Education Service Center migrant personnel and issues such as credit recovery, academic needs, school supplies and attendance, among others will be addressed throughout the school year. Pregnancy Related Services Identification of Students The Teen Pregnancy Teacher in the district will identify the students in the district needing services, to include, PRS and Homebound. Each PEIMS clerk or designated person at the campus will receive the appropriate documentation for them to code the student At‐Risk. The Teen Pregnancy Teacher will ensure all identified students are reviewed for eligibility on a weekly basis. Campus personnel will work with Teen Pregnancy Teacher to ensure the needs of the students are addressed. Reports for identified students will be provided and discussed with the Director of Federal Programs on a monthly basis and/or as needed. Communities in Schools (CIS) Referral Process In an effort to increase student academic success and performance, the district in collaboration with the service area provider (Communities in Schools – CIS) have come together to ensure students become academically successful. The services provided by the agency will assist students in at‐risk situations to become successful while in school. A student referral cycle/process has been set to assist schools in referring students to the appropriate program/agency (see figure 0.2).


Student Referral Cycle

Figure 0.2 (revised 9/2016)

Program Contact Phone Email Address

Communities in Schools (CIS)

CIS Designated Campus Coordinator and/or Robert Flores

Director / District Contact (915) 926‐3255 [email protected]

Migrant Education Program Rose Tarin Director (915) 780‐5311 [email protected]

McKinney‐Vento Education Act (Homeless Program)

Roberto Flores Director / Foster Care Liaison

Angelica Venzor Parental Involvement

Specialist / Homeless Liaison

(915) 926‐3250 [email protected] Foster Care &

Student Success

Pregnancy Related Services Hilda Adams Teacher (915) 926‐3254 [email protected]

Parent & Family Engagement Policy Statement of Purpose The Every Student Succeeds Act (ESSA) requires schools to work extensively in cooperation with parents, family members and school personnel in the decision making process. A percentage (1%) of the district’s Title I entitlement dollars is allocated and monitored by the federal government based upon Parent and Family Engagement activities. Clint ISD is committed to the goal to maintain close communication with its parents and family members to promote positive partnerships with the school. The staff and faculty will listen to the parents and family members and will seek their input on decisions related to their child’s educational needs. Together the school, parents, family members, and community can enhance their children’s lives by working as a cooperative team, sharing ideas and visions for the future.

Referrals to outside agencies & other District

Programs

Migrant Education Program –

Region 19 ESC

McKinney-Vento Education Act

(Homeless Program)

Foster Care & Student Success

Initiative

Pregnancy Related Services

(PRS)

Administrators Counselors

Communities in Schools (CIS)

Teachers Nurses

Staff


Development of Policy Clint ISD shall involve parents and family members in the development and revision of the written parent and family engagement policy. The district’s policy will be maintained at the district level and presented to campus committees for approval. The policy will be made available on the District’s website and accessible in a format that is understandable by parents/community. The policy will include a description of how the district will implement required parent and family engagement components. As well as, schoolwide campuses receiving Title I, Part A funds will involve parents and family members in the development and revision of the campus written parent and family engagement policy (English/Spanish). The policy will be maintained at the campus level and presented to their campus improvement team/committee for approval. The policy will be made accessible to parent(s) of the campus. The policy will include a description of how the campus will implement their parent and family engagement activities/components. The policy will be reviewed and evaluated annually. Title I Annual Meeting Each Title I campus will hold an annual meeting during the first semester of the new school year for all parents and family members. At the meeting the Title I program will be described, the Parent and Family Engagement Policy will be discussed, and opportunities for participation will be explained. The annual meeting will be held at a convenient time and location; notice of the meeting will be provided through written invitations to parents/caregivers and through public notices. Translators will be present at the meeting if needed. School-Parent-Student Compact In accordance with Title I regulations, each Title I campus is required to develop and annually update a School-Parent-Student compact jointly with school administrators, teachers, parents, and family members. The compact will provide an outline to enable the school and parent (to include, family members) to share responsibility for student performance and success. All involved parties are encouraged to discuss the contents. The compact will be reviewed and evaluated annually. Staff and Parent Communication Title I campuses will communicate with parents and family members on a regular basis. The Student Handbook will be used to communicate rules/procedures with the parents. Newsletters, teacher notes, the school marquee, conferences, personal contacts, phone calls, school messenger system and written notices will be used to establish and maintain open lines of communication with parents as needed. As much as possible, all communication will be provided in a language and format the parents can understand. Parents are encouraged to contact the school or the child’s teacher when questions or problems arise. Funding Clint ISD is required to set aside at least 1% of its Title I funds for the purposes of parent and family engagement activities. At least 90% of the funds are divided among the Title I campuses to meet the parent and family engagement requirements. Each campus administrator will assign a designated representative to work with parents at their respective campus. The designated representative is responsible for documentation of all parent and family engagement activities that occur at their campus and is responsible along with the campus administration for documentation of the parent and family engagement activities that occur at their campus and to help educate faculty and staff on the importance of parent and family engagement. They will work with the Director


of Federal Programs to ensure proper planning and spending of the Title I funds. Title I funds are supplemental and should not be used if the expenditure is required of all campuses in the district or state. Parent and Family Engagement Surveys The Director of Federal Programs or the designated staff member will generate the Parent and Family Engagement Surveys annually and disseminate to all campuses via Eduphoria. The principals or principal designee will ensure parents access the survey in Eduphoria to ensure a sample of the population is surveyed. Every effort will be made to collect the surveys from the parents in a timely manner by school personnel. Once the surveys are collected, they will be returned to the Department of Federal Programs for data disaggregation. Campus principals and other campus personnel will be provided with a copy of the results. The principal will review and share with faculty, staff and parents as needed. The survey results will be used in the development of the Campus Needs Assessment (CNA).

Personnel Management Federally Funded Positions and Job Descriptions Federally funded personnel salaries and wages will be set along with all other related expenses. The Human Resources Department will meet with the payroll staff from the Business Services Department and Federal Programs Department to ensure that federal guidelines are being met. The departments will work in partnership to ensure the following requirements are met for federally funded positions:

• Allowable positions • Job descriptions – will be revised (by program department); collected annually by the Human Resources

Department for all federally funded employees. • Check percentage in grant • Projections of salaries • Formula for Benefits • Place benefits/TRS in salary • Position control reports • Time and Effort

Documentation of Federally Funded Employee Time and Effort Forms and/or Logs Federally Funded Personnel at 100% and Split Funded Time and Effort Forms are required to be disseminated to employees. Sample forms are located on the Federal Programs web‐site. An annual training is provided to all users and all forms are collected and maintained by the Department of Federal Programs in accordance with all laws and requirements. The district may implement local requirements. Employee positions assigned to a single federal award and/or cost objective will be required to submit periodic certifications indicating the employee has met the requirements as set forth by the federal award and job description. Procedures are as follows:

1) The Federal Programs Department and Special Education Department requests a personnel listing of

federally funded employees from the Human Resources Department. The fund codes reviewed are Title I, Part A (211), Title II, Part A (255/256) and IDEA-B (Special Education) (224/225).


2) Based on the information provided, Time and Effort Certification Forms are generated for every employee on the listing by the department designee.

3) A memorandum or email message is generated and addressed to the campus administrators which will include a listing of personnel paid out of federal funds.

4) The memorandum or email message will have the following enclosed documents: Time and Effort Certification Form(s) (includes the employee’s name, fund, campus/department, and position) and only the split funded personnel will receive time and effort logs which are to be completed on a bi‐weekly basis by the employee.

5) Forms will require a signature and date by both the employee and supervisor.

6) Administrators are required to distribute the document(s) to their respective employees for completion. A deadline to complete and submit the documentation to the Federal Programs Department/Special Education Department is noted on the memorandum or email message.

7) Time and Effort Certification Forms are generated for employees by the department designee semi‐annually (every 6 months ‐ at the end of the semester). The certifications will be signed and dated by the employee and approved by the campus administrator. In the event that an employee cannot sign then the administrator (first knowledge of activities) may sign for the employee.

8) On‐going communication between the Federal Programs Department and the Human Resources Department is made throughout the year to ensure all documentation is addressed accordingly.

9) Original Time and Effort Certification Forms and Log(s) are kept and maintained in the respective departments. Documents are kept in binders and/or in an automated filing system for access when necessary.

Split Funded Positions (multiple cost objectives) Split funded positions require for Time and Effort statements to be maintained on a daily basis. In the event that a need to split fund a position arises, written permission needs to be submitted to Superintendent’s Cabinet. Approval will be granted only in the areas of need. Split funded positions are required to complete a Time and Effort log on a daily basis. Time and Effort logs are turned in on a bi‐weekly basis to the respective department. Tutoring Assignments Clint ISD offers a tutoring program to strengthen students’ academic skills. Employees hired to work the tutoring programs are required to complete a Time and Effort form on the last day of their work assignment. The 2018-2019 Timeline for Submission of Tutoring Form(s) delineates the submission of important documents.


Summer School Assignments Clint ISD offers a summer school program to strengthen students’ academic skills during the summer months. Employees hired to work the summer school programs are required to complete a Summer School Time and Effort form on the last day of their work assignment.

Federal Programs Procedures Manual

Documents

Transcript of Federal Programs Procedures Manual