IDEA Part B ARRA Allocations and Funding Issues 2009 Special Education Directors Conference...

IDEA Part B ARRA IDEA Part B ARRA Allocations and Funding Allocations and Funding

IssuesIssues2009 Special Education 2009 Special Education

Directors ConferenceDirectors Conference

Presented by:Presented by:Tim ImlerTim Imler

Presentation OutlinePresentation Outline FY 10 IDEA Regular and ARRA Grant AwardsFY 10 IDEA Regular and ARRA Grant Awards

Excess Cost and MOE RequirementsExcess Cost and MOE Requirements

Allowance for Federal Funds to reduce Local Allowance for Federal Funds to reduce Local Expenditures (50% excess rule)Expenditures (50% excess rule)

Payment Schedules & Expenditure ReportsPayment Schedules & Expenditure Reports

ARRA ReportingARRA Reporting

Helpful Internet SitesHelpful Internet Sites

Division Contact InformationDivision Contact Information

IDEA Part B Grant Awards

FY 10 Regular ARRA*Flow Through $503,378,371 $506,479,753

Preschool $17,369,463 $18,311,491

* ARRA funds must be obligated by September 30, 2011

IDEA PART B – FEDERAL SPECIAL ED.IDEA PART B – FEDERAL SPECIAL ED.

FY 10 Regular ARRA Distribution Totals

GRANTAWARD

$503,378,371 $506,479,753 $1,009,858,124

LEA* $448,161,695 $506,479,753 $954,641,448

SEA** $55,216,676 $0 $55,216,676

R&B$27,608,338

(50%) $0 $27,608,338

Disc.$18,072,543

(33%)$0 $18,072,543

Adm.$9,535,795

(17%)$0 $9,535,795

*LEAs will receive 89% of the FY 10 total regular grant award

**SB 1815 (P.A. 94-0069) eliminated 3% state set-aside growth cap in

Section 14-8.01 for FY 06 and thereafter

34 CFR 30034 CFR 300

Assistance to States for the Assistance to States for the

Education of Children with DisabilitiesEducation of Children with Disabilities

300.705(b) Permanent formula300.705(b) Permanent formula Went into effect when the federal Went into effect when the federal

appropriation reached $4,924,672,200appropriation reached $4,924,672,200

Base Year: established in the fiscal year Base Year: established in the fiscal year preceding the first fiscal year the federal preceding the first fiscal year the federal appropriation reached the $4.9 billion appropriation reached the $4.9 billion mark (FY 2000)mark (FY 2000)

34 CFR 30034 CFR 300Assistance to States for the Assistance to States for the


300.705(3) Increase in funds (Amount over the Base)300.705(3) Increase in funds (Amount over the Base) 85% distributed on the basis of the relative 85% distributed on the basis of the relative

population of children 3-21 who are of the same population of children 3-21 who are of the same age children with disabilities for whom the State age children with disabilities for whom the State ensures the availability of FAPE under Part B Act;ensures the availability of FAPE under Part B Act;

15% distributed for the same population of 15% distributed for the same population of children but who are living in povertychildren but who are living in poverty(Ill uses Dept of Human Services poverty count). (Ill uses Dept of Human Services poverty count).

IDEA Allocation VariablesIDEA Allocation Variables BASE YEAR - PART B FLOW THROUGHBASE YEAR - PART B FLOW THROUGH

-- -- Calculated from the Dec 1, 1998 Child CountCalculated from the Dec 1, 1998 Child Count

-- Each district’s count multiplied by $518.66-- Each district’s count multiplied by $518.66

-- Since FY 00 -- Since FY 00 the special education child count hasthe special education child count has not been used to determine IDEA PART B FLOW not been used to determine IDEA PART B FLOW

THROUGH district allocationsTHROUGH district allocations

IDEA Part B Flow Through Base Year Amount is IDEA Part B Flow Through Base Year Amount is $145,798,830$145,798,830

IDEA Allocation VariablesIDEA Allocation Variables BASE YEAR - PART B PRESCHOOLBASE YEAR - PART B PRESCHOOL

---- Calculated from the Dec 1, 1996 Child CountCalculated from the Dec 1, 1996 Child Count

-- Each district’s count multiplied by $485.55-- Each district’s count multiplied by $485.55

-- Since FY 98 -- Since FY 98 the special education child countthe special education child count has not been used to determine IDEA PART Bhas not been used to determine IDEA PART B PRESCHOOL district allocationsPRESCHOOL district allocations

IDEA Part B Preschool Base Year Amount isIDEA Part B Preschool Base Year Amount is $12,582,011$12,582,011

IDEA Allocation VariablesIDEA Allocation Variables

PUBLIC ENROLLMENT (FALL HOUSING)PUBLIC ENROLLMENT (FALL HOUSING)

-- -- All public students ages 3-21All public students ages 3-21

-- -- Enrollment taken as of September 30Enrollment taken as of September 30

-- -- Due to ISBE by October 31Due to ISBE by October 31

-- -- Subtracts Tuitioned In StudentsSubtracts Tuitioned In Students

(non-resident pupils)(non-resident pupils)

-- -- Includes Tuitioned Out StudentsIncludes Tuitioned Out Students

(resident district students)(resident district students)


NON-PUBLIC ENROLLMENTNON-PUBLIC ENROLLMENT-- Non-public Registration, Enrollment & Staff Report -- Non-public Registration, Enrollment & Staff Report

-- All non-public students ages 3-21-- All non-public students ages 3-21

-- -- VoluntaryVoluntary

-- Enrollment taken as of September-- Enrollment taken as of September 30 30

-- Must be a Not For Profit school-- Must be a Not For Profit school

-- Special Education Private Facilities are not counted-- Special Education Private Facilities are not counted

-- REPORTED ENROLLMENT DOES NOT TAKE INTO-- REPORTED ENROLLMENT DOES NOT TAKE INTO ACCOUNT THE STUDENT’S RESIDENCEACCOUNT THE STUDENT’S RESIDENCE


2008-09 Enrollment files are closed2008-09 Enrollment files are closed

Public and Non-Public Enrollment questions Public and Non-Public Enrollment questions should be directed to the should be directed to the Division of Data Division of Data Analysis and Progress ReportingAnalysis and Progress Reporting

Jim SweeneyJim Sweeney – Public Fall Housing Report – Public Fall Housing Report Shafique AzamShafique Azam – Non-Public Enrollments – Non-Public Enrollments

www.isbe.net/researchwww.isbe.net/researchPhone 217-782-3950Phone 217-782-3950


POVERTYPOVERTY

-- Obtained from the Department of Human Services-- Obtained from the Department of Human Services

-- 3 Yr Running Average-- 3 Yr Running Average

-- Included in the count are recipients of Food-- Included in the count are recipients of Food

Stamps, Temporary Assistance for Needy FamiliesStamps, Temporary Assistance for Needy Families

(TANF), Kid Care and Medicaid(TANF), Kid Care and Medicaid

FY 10 IDEA Flow Through Allocation FY 10 IDEA Flow Through Allocation ExampleExample

FY 10 IDEA Part B Grant Award to LEAs = FY 10 IDEA Part B Grant Award to LEAs = $448,161,695$448,161,695Subtract LEA Grant Base $145,798,830 = Subtract LEA Grant Base $145,798,830 = $302,362,865$302,362,865

At 85% = $257,008,435At 85% = $257,008,435At 15% = $45,354,430At 15% = $45,354,430

Entity Receiving Funds [District/Cooperative #1]Entity Receiving Funds [District/Cooperative #1]December 1, 1998 child count December 1, 1998 child count 405 405

Base IDEA Flow Through allocation for 99-00 yrBase IDEA Flow Through allocation for 99-00 yrcalculated at $518.66 times the child countcalculated at $518.66 times the child count $210,058$210,058Public Enrollment (08-09 school year)Public Enrollment (08-09 school year) 2,001 2,001Non-Public Enrollment (08-09 school year)Non-Public Enrollment (08-09 school year) 27 27Total EnrollmentTotal Enrollment 2,028 2,028Percentage of State enrollmentPercentage of State enrollment .08846% .08846%Funding = % of state enrollment * Funding = % of state enrollment * $257,008,435$257,008,435 $227,360$227,360Low Income Count (DHS 3yr Average)Low Income Count (DHS 3yr Average) 464.66 464.66Percentage of State Low Income CountPercentage of State Low Income Count .05848% .05848%Low Income funding = % of low income * Low Income funding = % of low income * $45,354,430$45,354,430 $26,524 $26,524Allotment (FY 10) = Base+Enrollment+Low IncomeAllotment (FY 10) = Base+Enrollment+Low Income $463,942$463,942

ARRA IDEA Flow Through Allocation ARRA IDEA Flow Through Allocation ExampleExample

Combine FY 10 Regular and ARRA Grant Amount = Combine FY 10 Regular and ARRA Grant Amount = $954,641,448$954,641,448Subtract LEA Grant Base $145,798,830 = Subtract LEA Grant Base $145,798,830 = $808,842,618$808,842,618

At 85% = $687,516,225At 85% = $687,516,225At 15% = $121,326,393At 15% = $121,326,393

Entity Receiving Funds [District/Cooperative #1]Entity Receiving Funds [District/Cooperative #1]December 1, 1998 child count December 1, 1998 child count 405 405

Base IDEA Flow Through allocation for 99-00 yrBase IDEA Flow Through allocation for 99-00 yrcalculated at $518.66 times the child countcalculated at $518.66 times the child count $210,058$210,058Public Enrollment (08-09 school year)Public Enrollment (08-09 school year) 2,001 2,001Non-Public Enrollment (08-09 school year)Non-Public Enrollment (08-09 school year) 27 27Total EnrollmentTotal Enrollment 2,028 2,028Percentage of State enrollmentPercentage of State enrollment .08846% .08846%Funding = % of state enrollment * Funding = % of state enrollment * $687,516,225$687,516,225 $608,205$608,205Low Income Count (DHS 3yr Average)Low Income Count (DHS 3yr Average) 464.66 464.66Percentage of State Low Income CountPercentage of State Low Income Count .05848% .05848%Low Income funding = % of low income * Low Income funding = % of low income * $121,326,393$121,326,393 $70,953 $70,953Base + Enrollment + Low IncomeBase + Enrollment + Low Income $889,216$889,216Subtract FY 10 Regular IDEA FT AllocationSubtract FY 10 Regular IDEA FT Allocation ($463,942)($463,942)ARRA IDEA FT Allocation until Sept 30, 2011ARRA IDEA FT Allocation until Sept 30, 2011 $425,274$425,274



300.16 Excess Cost Definition300.16 Excess Cost DefinitionExcess costs means those costs that are in excess of the average annual Excess costs means those costs that are in excess of the average annual per-student expenditure in an LEA during the preceding school year and per-student expenditure in an LEA during the preceding school year and that must be computed after deducting amounts received that must be computed after deducting amounts received

Under Part BUnder Part B Under Part A of title I of the ESEAUnder Part A of title I of the ESEA Under Parts A and B of title III of the ESEA and;Under Parts A and B of title III of the ESEA and; Any State or local funds expended for programs that would qualify for Any State or local funds expended for programs that would qualify for

assistance under any of the parts of this section, but excluding any assistance under any of the parts of this section, but excluding any amounts for capital outlay or debt service.amounts for capital outlay or debt service.

300.202(a)(3) Supplement Not Supplant300.202(a)(3) Supplement Not Supplant Part B funds will be used to Part B funds will be used to supplementsupplement State, Local and other Federal State, Local and other Federal

funds; funds; not to supplant those fundsnot to supplant those funds

If the LEA maintains (or exceeds) its level of local, or state and local If the LEA maintains (or exceeds) its level of local, or state and local expenditures for special education and related services from year to year, expenditures for special education and related services from year to year, either in total or per capita, then the Part B funds are in fact, either in total or per capita, then the Part B funds are in fact, supplementing those local or state and local expenditures and the LEA has supplementing those local or state and local expenditures and the LEA has met its MOE and supplement/not supplant requirements. In other words, if met its MOE and supplement/not supplant requirements. In other words, if you’ve met the MOE requirements, you’ve also met the supplement/not you’ve met the MOE requirements, you’ve also met the supplement/not supplant requirements. supplant requirements.



300.203 Maintenance of Effort300.203 Maintenance of Effort Funds provided to an LEA under Part B must not be Funds provided to an LEA under Part B must not be

used to reduce the level of expenditures for the used to reduce the level of expenditures for the education of children with disabilities made by the education of children with disabilities made by the LEA from local funds below the level of those LEA from local funds below the level of those expenditures for the preceding fiscal year. expenditures for the preceding fiscal year.

To verify LEA eligibility, the amount of local funds To verify LEA eligibility, the amount of local funds budgeted for the education of children with budgeted for the education of children with disabilities in the current year is at least the same, disabilities in the current year is at least the same, either in total or per capita, as the amount spent for either in total or per capita, as the amount spent for that purpose in the previous year.that purpose in the previous year.

LEA must have on file with the SEA information to LEA must have on file with the SEA information to demonstrate that the requirements of this section are demonstrate that the requirements of this section are met (Local Audit & MOE Worksheet).met (Local Audit & MOE Worksheet).



300.204 Exceptions to Maintenance of Effort300.204 Exceptions to Maintenance of Effort An LEA may reduce the level of expenditures under An LEA may reduce the level of expenditures under

Section 300.203 per the following conditions:Section 300.203 per the following conditions:-- Voluntary departure, retirement of special education -- Voluntary departure, retirement of special education

personnel who are replaced by qualified, lower-personnel who are replaced by qualified, lower-salaried staffsalaried staff

-- A decrease in the enrollment of children with -- A decrease in the enrollment of children with disabilitiesdisabilities-- Termination of the obligation of the agency for a -- Termination of the obligation of the agency for a

child that was exceptionally costly as determined child that was exceptionally costly as determined by the SEAby the SEA

-- Termination of costly expenditures for long-term -- Termination of costly expenditures for long-term purchases such as the acquisition of purchases such as the acquisition of

equipment or equipment or the construction of school the construction of school facilitiesfacilities



300.205 Adjustments to local fiscal efforts in certain fiscal 300.205 Adjustments to local fiscal efforts in certain fiscal yearsyears

For any fiscal year for which the allocation received by an LEA For any fiscal year for which the allocation received by an LEA exceeds the amount the LEA received for the previous fiscal year, exceeds the amount the LEA received for the previous fiscal year, the LEA may reduce the level of expenditures otherwise required the LEA may reduce the level of expenditures otherwise required up to up to 50%50% of the amount of that excess. of the amount of that excess.

Use of Amounts To Carry Out ESEA ActivitiesUse of Amounts To Carry Out ESEA ActivitiesIf an LEA exercises authority to use federal funds in that manner, If an LEA exercises authority to use federal funds in that manner, the LEA must use an amount of local funds equal to the reduction the LEA must use an amount of local funds equal to the reduction in expenditures to carry out activities that could be supported with in expenditures to carry out activities that could be supported with funds under ESEA regardless of whether the LEA is using funds funds under ESEA regardless of whether the LEA is using funds under ESEA for those activities. under ESEA for those activities.

This includes any activities allowed under Title I, Impact Aid, and This includes any activities allowed under Title I, Impact Aid, and other ESEA programs. An LEA could use these funds to pay for other ESEA programs. An LEA could use these funds to pay for activities that are currently being funded with other state or local activities that are currently being funded with other state or local funds or for new activities.funds or for new activities.

50% Supplant Eligibility50% Supplant Eligibility

Per 34 CFR 300.600(a) of IDEA, States are Per 34 CFR 300.600(a) of IDEA, States are required to make "Determinations" on the required to make "Determinations" on the performance of LEA and Early Intervention performance of LEA and Early Intervention Service programs. Service programs.

LEA Determinations are made in one of four LEA Determinations are made in one of four categories: (1) Meets Requirements, (2) categories: (1) Meets Requirements, (2) Needs Assistance, (3) Needs Intervention Needs Assistance, (3) Needs Intervention and (4) Needs Substantial Interventionand (4) Needs Substantial Intervention

An LEA cannot utilize the 50% supplant rule An LEA cannot utilize the 50% supplant rule unless they are determined as “Meets unless they are determined as “Meets Requirements”Requirements”..

50% Supplant Calculation Example50% Supplant Calculation Example

FY 2009 Allocation FY 2009 Allocation $400,000$400,000

FY 10 Regular & ARRA FY 10 Regular & ARRA $900,000$900,000

Excess AmountExcess Amount $500,000$500,000

50% of Excess50% of Excess $250,000$250,000

An LEA choosing to take advantage of this flexibility is only An LEA choosing to take advantage of this flexibility is only required to maintain expenditures at the reduced MOE level in required to maintain expenditures at the reduced MOE level in subsequent years, until that LEA increases the level of special subsequent years, until that LEA increases the level of special education expenditures, using state or local funds, on its own.education expenditures, using state or local funds, on its own.

For example, if the LEA expended $1,500,000 of local and state For example, if the LEA expended $1,500,000 of local and state funds on special education and related services in FY 2009 and funds on special education and related services in FY 2009 and lowered that amount by $250,000 (from the previous slide) in FY lowered that amount by $250,000 (from the previous slide) in FY 2010, the LEA must expend at least $1,250,000 in state and local 2010, the LEA must expend at least $1,250,000 in state and local funds on special education and related services in FY 2010 to funds on special education and related services in FY 2010 to meet the MOE requirement. In FY 2010, the year the LEA took the meet the MOE requirement. In FY 2010, the year the LEA took the MOE reduction, it also must ensure that $250,000 is expended on MOE reduction, it also must ensure that $250,000 is expended on activities allowable under the ESEA.activities allowable under the ESEA.

In FY 2010 and subsequent years, the LEA does not have to In FY 2010 and subsequent years, the LEA does not have to continue to separately “track” the $250,000 expended for ESEA continue to separately “track” the $250,000 expended for ESEA activities.activities.

Implementing the 50% RuleImplementing the 50% Rule

Payment Schedules & InterestPayment Schedules & Interest

Monthly Payment Schedules must Monthly Payment Schedules must reflect anticipated expenditures to reflect anticipated expenditures to avoid potential excess cash.avoid potential excess cash.

Excess cash will be withheld from Excess cash will be withheld from future scheduled payment(s).future scheduled payment(s).

Federal interest must be returned to Federal interest must be returned to the appropriate Federal Agency if > the appropriate Federal Agency if > $100. (34 CFR 80.21) $100. (34 CFR 80.21)

Expenditure ReportsExpenditure Reports

Cooperatives that subgrant funds to Cooperatives that subgrant funds to their member districts their member districts does notdoes not constitute an expenditure.constitute an expenditure.

Cooperatives must ensure member Cooperatives must ensure member districts have districts have expendedexpended funds that funds that were subgranted and report the were subgranted and report the aggregated expenditures on their aggregated expenditures on their quarterly and final expenditure reports. quarterly and final expenditure reports.

ARRA Reporting VariablesARRA Reporting VariablesFirst StepsFirst Steps All districts and cooperatives must have a All districts and cooperatives must have a

Nine Digit Dun and Bradstreet (DUNS) Nine Digit Dun and Bradstreet (DUNS) number assigned number assigned http://fedgov.dnb.com/webformhttp://fedgov.dnb.com/webform

All districts and cooperatives must register All districts and cooperatives must register with the Central Contractor Registration site with the Central Contractor Registration site www.ccr.govwww.ccr.gov. All Federal vendors, suppliers, . All Federal vendors, suppliers, contractors and grant recipients are required to contractors and grant recipients are required to register in this database and are required to register in this database and are required to have a DUNS# issued to them.have a DUNS# issued to them.

ARRA Reporting VariablesARRA Reporting Variables

TimelinesTimelinesAll expenditure and other ARRA data must be All expenditure and other ARRA data must be reported CUMULATIVE or year-to-date from the reported CUMULATIVE or year-to-date from the point that each LEA began expending ARRA funds point that each LEA began expending ARRA funds through the end of each quarterly reporting period.through the end of each quarterly reporting period.

Each subsequent quarterly report will also be Each subsequent quarterly report will also be cumulative. In other words, the report due January cumulative. In other words, the report due January 2010, will include the data reported through 2010, will include the data reported through September 2009 and be updated to include data that September 2009 and be updated to include data that accumulated through December 2009. ISBE will accumulated through December 2009. ISBE will aggregate all ARRA expenditures across fiscal aggregate all ARRA expenditures across fiscal years for each LEA.years for each LEA.


Jobs Created and RetainedJobs Created and RetainedA job created is a new position created and filled; a job A job created is a new position created and filled; a job retained is an existing position that would not have been retained is an existing position that would not have been continued were it not for ARRA funding.continued were it not for ARRA funding.

FTE – Full Time EquivalencyFTE – Full Time EquivalencyEnter the FTE for each position. This is calculated as total Enter the FTE for each position. This is calculated as total hours worked divided by the number of hours in a full-time hours worked divided by the number of hours in a full-time schedule. The figure should be reflected to two decimal schedule. The figure should be reflected to two decimal places.places.

The number reported should represent a reasonable average The number reported should represent a reasonable average of FTE’s created and retained for the quarter. Such an estimate of FTE’s created and retained for the quarter. Such an estimate would ideally be done by taking FTE’s for each pay period in would ideally be done by taking FTE’s for each pay period in the quarter and averaging them. It could also be done at a the quarter and averaging them. It could also be done at a single point in time, as long as care is taken that the single single point in time, as long as care is taken that the single point is representative of the quarter for the position.point is representative of the quarter for the position.


Awards made to a vendor greater than $25,000Awards made to a vendor greater than $25,000A vendor is defined as a dealer, distributor, merchant, or other seller A vendor is defined as a dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of the providing goods or services that are required for the conduct of the program.program.

A vendor: A vendor: (1) Provides the goods and services within normal business operations; (1) Provides the goods and services within normal business operations; (2) Provides similar goods or services to many different purchasers; (2) Provides similar goods or services to many different purchasers; (3) Operates in a competitive environment; (3) Operates in a competitive environment; (4) Provides goods or services that are ancillary to the operation of the (4) Provides goods or services that are ancillary to the operation of the Federal program; andFederal program; and(5) Is not subject to compliance requirements of the Federal program.(5) Is not subject to compliance requirements of the Federal program.

If a sub-recipient (i.e. district or cooperative) awards ARRA funds greater If a sub-recipient (i.e. district or cooperative) awards ARRA funds greater than $25,000 to a vendor for services required needed to carry out the than $25,000 to a vendor for services required needed to carry out the project or program, the sub-recipient must report the identity of the project or program, the sub-recipient must report the identity of the vendor by reporting the DUNS number, if available, or otherwise the name vendor by reporting the DUNS number, if available, or otherwise the name and zip code of the vendor’s headquarters.and zip code of the vendor’s headquarters.

Helpful Internet SitesHelpful Internet SitesARRA Recovery Site :ARRA Recovery Site :http://www.recovery.gov/http://www.recovery.gov/

ARRA Department of Education GuidanceARRA Department of Education Guidancehttp://www.ed.gov/policy/gen/leg/recovery/index.htmlhttp://www.ed.gov/policy/gen/leg/recovery/index.html

ARRA-IDEA Part B Department of Education Guidance ARRA-IDEA Part B Department of Education Guidance http://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.pdfhttp://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.pdf

State or Federal Project and Payment Information:State or Federal Project and Payment Information:http://206.166.105.128/FRISInquiry/http://206.166.105.128/FRISInquiry/

IDEA 2004 IDEA 2004 http://idea.ed.gov/explore/homehttp://idea.ed.gov/explore/home

USDE – Office of Special EducationUSDE – Office of Special Educationhttp://www.ed.gov/about/offices/list/osers/osep/index.htmlhttp://www.ed.gov/about/offices/list/osers/osep/index.html

Division of Funding and Disbursement ServicesDivision of Funding and Disbursement ServicesPhone: 217/782-5256Phone: 217/782-5256

Fax: 217/782-3910Fax: 217/782-3910

IDEA Flow Through & Preschool Grants, Expenditure Reports and IDEA Flow Through & Preschool Grants, Expenditure Reports and PaymentsPayments

Sharon ConrathSharon [email protected]@isbe.net

Division of Special Education ServicesDivision of Special Education ServicesPhone: 217/782-5589Phone: 217/782-5589

Fax: 217/782-0372Fax: 217/782-0372

IDEA Flow Through and Preschool Program ConsultantsIDEA Flow Through and Preschool Program ConsultantsBonnie DouglasBonnie Douglas Penny KellyPenny [email protected]@isbe.net [email protected] [email protected]

IDEA Part B ARRA Allocations and Funding Issues 2009 Special Education Directors Conference...

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