MORE Fiscal Fun

Making and out of Federal Funds(Formerly Known as Fiscal Fun)ESEA Odyssey 2014

1Acknowledgement:The content in this presentation is, in part, provided by the National Association of State Title I Directors, July, 2013.Oregon Department of EducationsStrategic PlanGoal: Every student graduates from high school and is ready for college, career, and civic life.Providing students at risk of academic failure with supplemental academic supportEnsuring that students are taught by highly qualified and effective teachersTaking steps to close the achievement gap with historically underserved populations

Session ObjectivesIdentify general purpose of ESEA fundsConnect use of ESEA funds to ODE Strategic PlanFiscal ComplianceAllowable ExpendituresSupplement, Not SupplantCIP Budget Narrative AlignmentSeparate AccountsComparabilityTime Distribution ReportingBudget Narrative & CarryoverNew Rules (Omni Circular)Fiscal ComplianceAllowable ExpendituresNecessary, Reasonable, and AllocableAllowable ExpendituresOffice of Management and Budget (OMB) Circular A-87 requires that the use of funds for a specific purpose be:necessary and reasonable for the proper and efficient performance and administration of the program; andauthorized and not prohibited under state and local laws or regulations.

77It is required that the activity that is paid for is necessary for your school/district, a reasonable expenditure, and is allowable under and consistent with all ESEA fiscal and programmatic requirements.

Red Flags from Federal Program Monitors Rarely Allowable: Field trips T-shirts, tote bags, promotional items Costs related to awards ceremoniesFood costs

Never Allowable: Door prizes RewardsGift Cards

Supplement, not SupplantSupplement, not SupplantFederal funds supplement state and local fundsTitle I provides federal dollars to supplement educational opportunities for children who live in high poverty areas and who are most at risk of failing to meet the states challenging achievement standardsDescribed in ESEA Title I - A, the OMB Circular A-133 Compliance Supplement, and USEDs Non-Regulatory Guidance: Title I Fiscal Issues Revised 2008.(among other places)Supplement, not SupplantSCHOOLWIDE: A school participating in a schoolwide program shall use funds available to carry out this section only to supplement the amount of funds that would, in the absence of funds under this part, be made available from non-Federal sources for the school, including funds needed to provide services that are required by law for children with disabilities and children with limited English proficiency. [ESEA 1114(a)(2)(B)]

Supplement, not SupplantTARGETED ASSISTANCE PROGRAM: Funds received under this part may not be used to provide services that are otherwise required by law to be made available to [eligible] childrenbut may be used to coordinate or supplement such services. [ESEA 1115(b)(3)]Targeted Assistance Programs under same rules as Schoolwide regarding supplement, not supplant.Supplement, not SupplantFederal funds must be used to supplement, not supplant services, staff, programs, or materials that would otherwise be paid with state or local funds (and in some cases, other federal funds).Always ask: What would happen in the absence of federal funds?Supplement, not SupplantFederal funds must be used to supplement, not supplant services, staff, programs, or materials that would otherwise be paid with state or local funds (and in some cases, other federal funds).Always ask: What would happen in the absence of federal funds?Supplement, not SupplantSupplement, not supplant is different depending on the type of Title I program model

Targeted Assistance SchoolsIn Title I Targeted Assistance schools, funds are used to provide supplemental educationally-related services to eligible students participating in Title I programsSupplement, not SupplantSchoolwide Program Schools

In Title I schoolwide schools, funds provided are supplemental to the state and local funds and may be used to support any activities in the schoolwide plan. Districts are not required to demonstrate that Federal funds are used only for a specific target population

Supplement, not SupplantPresumption of supplantingThe district has used the Title I funds to provide services that the district was required to make available under federal, state, or local lawThe district used Title I funds to provide services it provided with non-federal funds in the prior year(s)The district has used Title I funds to provide services for participating children that it provided with non-federal funds for non-participating childrenSupplement, not SupplantTo rebut presumption show:Fiscal or programmatic documentation to confirm, that, in the absence of federal funds, staff services in question would have been eliminatedState legislative or local board actionBudget histories and informationCIP Budget NarrativeCIP Budget NarrativeThe budget narrative is the districts contract with the SEA on how federal funds are going to be spentThe budget narrative is tied into monitoring in that district expenditures for the Title program are checked against the budget narrative

CIP Budget NarrativeAssurancesPrayer CertificationContactsConsolidated SpendingDue No Later Than October 1st

Budget Narrative on the RoadRegional Training and Technical Assistance Fall 2014Eastern Oregon Northeastern OregonMetro WestMetro EastSouthern OregonCentral-Willamette ValleyCentral OregonSouth Coast

CarryoverGrant PeriodTitle I funds are available for 27 monthsFederal FY 2014 funds:July 1, 2014 September 30, 2015 (1st grant period)October 1, 2015 September 30, 2016 (Carryover period)CarryoverMay be because:Late start of programChange in personnel costsChanged planCongress assumes We dont need the funding!CarryoverCarryover must be requested through CIP Budget Narrative Expenditures through September 30Carryover pages open in CIP Budget Narrative around November 1715% LIMIT Title I-ACan have more than 15% once every 3 yearsDistricts must not plan for carryover24Waiver if the request is reasonable and necessaryCarryover limitation does not apply to districts who receive less than $50,000 in Title IAComparabilityComparabilityAn LEA may receive funds under this part only if State and local funds will be used in schools served under this part to provide services that are at least comparable to services in schools that are not receiving funds under this part.ESEAFiscal RequirementsSection 1120A(c)

26ONLY applies to Title I-AComparabilityIf the LEA is serving all of its students under this part, the agency may only receive funds if it will use State and local funds to provide services that are substantially comparable in each school.

ESEAFiscal RequirementsSection 1120A(c)

Comparability - ExclusionsLEA that has only one school per grade spanLEA may exclude schools with fewer than 100 students

28Everybody stand up!Sit down ifComparabilityComparability WorksheetsWritten AssuranceDistrict-wide salary schedulePolicy of equivalence in staffingPolicy of equivalence in materials and suppliesCriteria and Guidance located at: http://www.ode.state.or.us/search/page/?id=194029Do annual in Oct be completed by Dec.if not comparable must make change immediately

ComparabilityComparing Title I-A to non-Title I-ATitle I-A schools need to be within 110%

Comparing Title I-A to Title I-ASchools need to be within 90%-110% of each other30Time DistributionTime Distribution:Why is this important?Salary costs are material to many grantsAbsence of adequate documentation is a basis for repayment of fundsConsidered explicitly as a risk factor by OMBNumerous grantees have had to repay millions because of Time & Effort issues.

OMB A-87 RulesIf federal funds are used for salaries then Time Distribution records are required.Must demonstrateIf employee is paid from federal funds, then employee worked on that specific federal program/cost objective.

TerminologyTime and attendance recordsPayroll recordsMonday worked 8:00-4:00Semi-annual certificationTime and effort recordsMonday worked 50% on Title I-A and 50% on general fund activities Adequate ReportingRetained by districtPrepared after the factFull disclosure report of full time workedCredible endorsement

Semi-Annual CertificationSigned every six months by supervisor or employeeFrom August 23, 2014, until December 31, 2014, Jane Goodall spent 100% of her time on Title I-A schoolwide program implementation at Primate Elementary School.

Time and EffortTime and Effort (AkaPersonnel Activity Reports --PAR)Signed and dated every month by employeeActual accounting of time after the fact Showing total effortShould have report and back up documentation to verifycalendar, work product, time log

Fixed Schedule ReportingEmployees who are paid out of multiple sources, but whose schedule is the same each day, may document time and effort as follows:The employee will continue to provide the personnel activity report required from a varied schedule employeeThe employee on a fixed schedule may submit two documents on a semi-annual basis one certifying the funding sources being charged and the other showing the established fixed schedule. A document showing the established fixed schedule in most educational settings would be the employees daily schedule of classes and duties.

New Rules ComingOmni CircularOmni CircularGoverns the use of federal fundsCondenses eight previous circulars into one super circularUSED can issue interpretive guidance to states and local education agenciesImplemented December 26, 2014Impacts 2015 federal allocations and carryover from previous allocationsSome Changes & ClarificationsItem Under the Omni CircularAudit RequirementAudit Requirement raised from $500,000 to $750,000Time & EffortFurther clarifiedMeals & ConferencesFurther clarifiedMonitoringRisk factors; tied to performance measuresProcurement & Property ManagementFurther clarifiedQuestionsContactsDistricts A D:Jesse Parsonsjesse.parsons@state.or.us503-947-5602Districts E P:Melinda Bessnermelinda.bessner@state.or.us503-947-5626Districts Q Z:Russ Sweetruss.sweet@state.or.us503-947-5638