Office of Superintendent of Public Instruction 2009.

Office of Superintendent of Public Instruction

2009

OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments,

Codified in 2 CFR Section 225

PurposeProvides principles and standards for

determining costs for federal awardsGrantsCost reimbursement contractsOther agreements with state and local

governments and federally recognized Indian tribal governments

3

Attachment ADefinitionsBasic Guidelines

Factors affecting allowabilityReasonable costsAllocable costsApplicable credits

Classification of CostsDirect and Indirect Costs

4

Basic Guidelines—Allowability of CostsTo be allowable a cost must:

Be necessary and reasonable for proper and efficient performance and administration of federal awards

Be allocable to federal awardsBe authorized and not prohibitedConform to any limitations in the circular Be consistent and applied consistently (capital

assets, direct vs. indirect cost, etc.)

5

Basic Guidelines—Allowability of CostsAllowable if:

Follows generally accepted accounting principles

Not be used to meet cost sharing or matching of another federal award

Is net of all applicable creditsIs adequately documented

6

Basic Guidelines—Reasonable CostsPrudent Person Test

Ordinary and necessary for operation or performance of federal award

Follows sound business practices; arms length bargaining; follows laws/regulations federal terms

Market price for comparable goods and services

Administered with prudenceNo significant deviations; consistent with non-

federal7

Basic Guidelines—Allocable CostsBenefits the programIndirect costs

8

Attachment B

9

AccountingAllowable

Cost to establish and maintain accounting and other information system

10

AdvertisingAllowable

Recruitment of personnelProcurement of goods and servicesDisposal of surplus materials (unless

reimbursed at standard rate)For specific purposes necessary to

requirements of federal award

11

Public RelationsAllowable

Specifically required by federal award (only as direct cost)

Communicate specific activities or accomplishments from performance of federal award to public or press (direct cost)

Necessary to liaison with news media-limited to keeping public informed on federal notices, contracts, grant awards, financial matters

12

Public RelationsUnallowable

All other advertising and public relationsCosts of conventions, meetings or other events

Costs of displays, demonstrations, exhibits Costs of meeting rooms, hospitality suites, etc. Salaries and wages of employees engaged in setting

up and displaying exhibits, making demonstrations, providing briefs

Promotional items (models, gifts, souvenirs) Costs of advertising and PR designed to solely

promote governmental unit

13

Advisory CouncilsAllowable

As direct cost if authorized by federal awarding agency

As indirect cost where allocable to federal awards

14

Alcoholic BeveragesUnallowable!!!

15

Audit ServicesAllowable

If performed in accordance with Single Audit Act (and OMB Circular A-133).

Percentage of costs charged to federal awards for single audit may not exceed percentage derived by diving federal funds expended by total funds expended by recipient during fiscal year. Exceed only if appropriate documentation of higher costs

Other audit costs must be preapproved or part of indirect cost allocation plan or rate.

16

Electronic Data ProcessingAllowable

But see Equipment

17

Bad DebtsUnallowable

Unless specifically provided for in federal program award regulations.

18

Bonding CostsAllowable

Costs of bonding employees and officials if in accordance with sound business practice.

19

BudgetingAllowable

Costs for development, preparation, presentation and execution of the budget.

20

CommunicationsAllowable

Costs of telephone, mail, messenger, etc.

21

Compensation for Personal ServicesAllowable

If follow time and effort requirements and documentation.

Are reasonable for services rendered and conform to established policy of district consistently applied to both federal and non-federal employees.

Hired in accordance with district rules and meets merit system or other federal requirements.

22

ContingenciesUnallowable

Contributions to contingency reserve for events which cannot be predicted.

AllowableSelf-insurance reserve.Pension plan reserves.Post retirement health and other benefits

computed with acceptable actuarial cost method.

23

Contributions and DonationsUnallowable

All contributions and donations, including cash, property, and services by governmental units to others, regardless of recipient.

24

Defense and Prosecution of Criminal and Civil Proceedings and ClaimsUnallowable

Costs incurred in defense of any civil or criminal fraud.

Costs incurred by a contractor in connection with any criminal, civil or administrative proceedings commenced by the United States or a state.

Legal expenses for prosecution of claims against the federal government.

AllowableLegal expenses required to administer federal

program.

25

Depreciation and Use AllowancesAllowable

Use one or the other, not both for asset class.Follow district policy and GAAP.

UnallowableLand.Buildings or equipment purchased or donated

by federal government or used as part of match.

See Circular for additional guidance

26

Disbursing ServiceAllowable

Cost of disbursing funds.

27

Employee Morale, Health and Welfare CostsAllowable

Costs of health, first-aid clinics and/or infirmaries, recreational facilities, employee counseling services, employee information publications, related expenses consistent with district policy.

Income from any of these activities will be offset against expenses.

28

EntertainmentUnallowable

Costs of entertainment, including amusement, diversion and social activities and any costs directly associated with such costs. Examples: tickets to shows or sports events, meals,

lodging, rentals, transportation, gratuities

29

Equipment and Capital ExpendituresAllowable

Through depreciation or use allowances, ORCharged directly.

Includes equipment, replacement equipment, other capital assets and improvements which materially increase the value or useful life of equipmentFederal agencies may waive or delegate

approval.

30

Equipment and Capital ExpendituresEquipment with acquisition cost of less then

$5,000 are considered supplies allowable as direct costs

Change in capitalization levelMay continue to follow use or depreciation or

amortize amount to be written off over period negotiated with cognizant agency (OSPI)

Trade in for replacement equipment may be used to offset cost of new

31

Fines and PenaltiesUnallowable

Unless incurred as a result of compliance with specific provisions of federal award or written instructions by awarding agency authorizing (rare).

32

Fundraising and Investment Management CostsUnallowable

Costs of organized fund raising, including financial campaigns, solicitation of gifts and bequests, and similar expenses incurred to raise capital or obtain contributions.

Costs of investment counsel and staff to enhance income from investments.

AllowableCosts associated with pension, self-

insurance or other funds which include federal participation.

33

Gains and Losses on Disposition of Depreciable Capital AssetsAllowable in year they occur as credits or

charges Limited to difference between amount realized

on property and undepreciated basis.Unallowable

Amount depreciated, amortized, or use allowance.

When property given in exchange as part of the price of similar item.

Losses from failure to maintain insurance.34

Gains and Losses on Disposition of Depreciable Capital AssetsSubstantial relocation of federal awards from

a facility where federal participation to another facility prior to expiration of useful life requires federal approval

Does not usually apply to ED grants

35

General Government ExpensesUnallowable

Salaries and expenses of chief executives (superintendent's office, principal’s office)

Salaries and expenses of school boards whether incurred for purposes of legislation or executive direction

Cost of prosecutorial activities unless authorized by program regulations (rare)

36

Idle Facilities and Idle CapacityUnallowable unless

Necessary to meet fluctuations in workloadWere necessary when acquired (limit 1 year)

Does not usually apply to ED grants

37

Insurance and IndemnificationAllowable

Costs of insurance required, approved or maintained pursuant to the federal award

Costs of other insurance (allocable to program) Follow district policy and sound business practice

Costs due to losses not covered due to nominal deductible insurance coverage if follow sound management practice

Minor losses not covered by insurance which occur in ordinary course of operations

38

Insurance and IndemnificationAllowable

Contributions to reserve for self-insurance programs (including workers compensation, unemployment compensation, and severance pay) subject to: Type of coverage, extent of coverage and rates would

have been allowed has insurance been purchased to cover the risks

Earnings and investment income on reserves credited Contributions to reserves based on sound actuarial

principles and updated at districtst biennially Other (see section 25)

39

Insurance and IndemnificationAllowable (conditions)

Actual claims paid to or on behalf of former or current employees must be allowable in the year of payment Consistent policy followed Allocated as general administrative expense to all

activities of districtInsurance refunds must be credit against costsOnly to extent provided in federal award

40

Insurance and IndemnificationUnallowable

Costs of insurance or contributions to a reserve covering risk of loss of or damage to federal government property unless agency has specifically required or approved.

Actual losses which could have been covered by permissible insurance.

Cost of commercial insurance that protects against costs of contractor for contractor’s defects in materials or workmanship.

41

InterestUnallowable

Costs incurred for interest on borrowed capital or the use of district’s own funds.

AllowableFinancing costs of allowable costs of

building acquisition, construction , reconstruction or remodeling if: Financing from bona fide third party external to

district Assets used in support of federal awards Earnings on debt service reserve and interest offset

42

LobbyingUnallowable!!!

43

Maintenance, Operations and Repairs

Allowable, if:Not prohibited by law.Keeps property in efficient operating condition.Does not add to value or prolong life of

property.Are not included in rental or charges for space.

Costs which add to permanent value or prolong life should be treated as capital expenditures

44

Materials and SuppliesAllowable

Charge actual price after deducting discounts, rebates and allowances.

Stockroom withdrawals at cost.Incoming transportation charges are part of

materials and supplies costs.

45

Memberships, Subscriptions and Professional ActivitiesAllowable

Districts memberships in business, technical, and professional organizations.

District’s subscriptions to business, technical and professional periodicals.

Meetings and conferences where primary purpose is dissemination of technical information (includes meals, transportation, rental of meeting facilities and incidental costs).

Membership in civic and community social organizations with approval of federal agency.

46

Memberships, Subscriptions and Professional ActivitiesUnallowable

Membership in organizations substantially engaged in lobbying.

47

Motor PoolsAllowable

Costs of service organization which provides automobiles to district at mileage or fixed rates and/or provides vehicle maintenance, inspection, and repair services.

48

Pre-Award CostsUnallowable, unless

Necessary to comply with the proposed delivery schedule or period of performance.

Only to extent they would have been allowable if incurred after award date.

Only with written approval of awarding agency.

49

Professional Service CostsAllowable

Professional and consultant services, including retainer fees, by persons or organizations that are members of a particular profession or possess a special skill, if: Reasonable Not contingent upon recovery of costs from the

federal governmentUnallowable

Defense and prosecution of criminal and civil proceedings and claims.

50

Proposal CostsAllowable

Costs to prepare proposals for potential federal awards. Treat as indirect costs unless prior approval of

federal awarding agency

51

Publication and Printing CostsAllowable

Must be reasonable and allocable.

52

Rearrangements and AlterationsAllowable

Ordinary and normal rearrangement and alteration of facilities.

Special arrangements and alterations specified in the federal award or with prior approval.

53

Reconversion CostsAllowable

Restoration or rehabilitation of district’s facilities to approximately same condition immediately prior to federal awards, less costs related to normal wear and tear.

54

Rental CostsAllowable

Must be reasonable.Sale and district back limited to what it would

have cost if district owned the property.Less than arm’s length transactions limited to

amount if district had title to property.Districts must be treated as capital districts

under GAAP (follow FASB Stmt 13).See interest section.

55

TaxesAllowable

If legally required.Gasoline taxes, motor vehicle fees other taxes

which are user fees for benefits to federal program.

UnallowableSelf-assessed taxes and/or policies that

disproportionately affect federal programs.If deemed inappropriate by federal agency.

56

TrainingAllowable

Reasonable for professional development of employees.

57

Travel CostsAllowable

Transportation, lodging subsistence and related items for employees on official business.

May be charged based on actual cost, per diem or combination in accordance with district policy.

Travel costs for general government employees are allowable when specifically related to federal awards.

All charges must be reasonable and not exceed normally allowed costs.

58

Travel CostsUnallowable

Costs in excess of normal costs permitted by district policy (use federal guidance if no district policy).

Commercial airfare must be coach rate or equivalent.

Non-commercial air travel is generally not allowable.

59

Underrecovery of Costs under Federal AgreementsUnallowable

Excess costs over federal contribution of one award are not permitted to be charged to other awards.

60

Where is the Requirement?Time and effort reporting is required under

the Federal Office of Management and Budget’s Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments

Attachment B, Selected Items of Cost, Item 11, Compensation for personnel services

62

When is Time and Effort Required?Time and effort reporting is required when

any part of an individual’s salary is charged to a federal program.

Charge may be “direct” or “indirect”.

63

What type of reporting is needed?

Single cost objective →Semi annual certification

Multiple cost objectives →Monthly time reports or Personnel Activity Reports (PARs)

64

What is a cost objective?

Work activities allowable under the terms and conditions of a

funding source

65

What are some examples of a single cost objective?

100% charged to a single federal program activity

Exceptions Title I, Part A and LAP.Federal Special Education and State Special

Education.Schoolwide programs.Multiple activities in a single federal program.

66

What are some examples of multiple cost objectives?

Salary charged to more than one activity in a single federal program

Salary charged partially to federal program and partially to state and/or local sources

Salary charged partially to sources combined into a schoolwide program and partially to those not included

67

What is a semi-annual certification?

Statement individual(s) worked solely on activities related to single cost objective

Completed at districts every six monthsSigned by employee or supervisor with first-

hand knowledge of work performed

68

What is a monthly time report?(PAR)Accounts for total activityPrepared at district monthlySigned by employeeReflects actual work performed (not budget)Agrees to supporting documentation

69

When are adjustments to actual made?

If payroll is initially based on budgeted or estimated time/amounts, payroll and time and effort reports must be compared at districts quarterly

If the difference is 10% or more and any needed adjustments made Payroll records must be adjusted to actual Following quarter’s estimates must be adjusted

70

What time and effort is reported?

Report time actually worked in a specific activity not time budgeted

Budgets are reconciled to actual at districts quarterly

71

Who should sign the reports?

Monthly reports (PARs) should be signed by the employee

Semi annual certifications should be signed by employee or supervisor having first-hand knowledge of work performed

For internal control purposes, districts may require both the employee and supervisor to sign

72

What type of supporting documentation is needed?Documentation is VERY important.

Examples include, but are not limited to:Class schedulesNumber of studentsNumber of minutes

Remember DOCUMENT! DOCUMENT! DOCUMENT!

73

Supplemental Contracts, Stipends, Extra Hours

Primary contract and additional contracts may be considered separately

Based upon whether or not charged to federal programTime and effort may be required for primary

contract but not supplemental (or vice versa).

74

Administrators

Superintendent, assistant superintendent, principal, assistant principal usually not allowable charge to federal programRequires good documentation to support.Could be a supplant issue.

75

Schoolwide ProgramsSchoolwide plan must specify programs

to be included (not all programs may be included)

A schoolwide program is a single cost objectiveIf employee works 100% on programs

combined → Semi annual certification.If employee works partially on programs

combined and partly on those not combined → Monthly time report (PAR).

76

Schoolwide Program

Schoolwide ProgramTitle I, Part A (Disadvantaged)LAPBEALocal FundingTitle IV (Safe/Drug-Free)Title V (Innovative)Most US Dept Ed Programs

except Reading First

Cannot IncludeTransitional BilingualState Special EdReading FirstI-728State Highly Capable

RestrictedMigrantIndian EducationFederal Special Ed

77

What is a substitute system?Other method for determining time and effort

report based on sample of work performedMust be approved by OSPI prior to use

JoLynn Berge is responsible for approvalMust be statistically soundShould be periodically reviewed to determine

if still appropriate

78

For Additional InformationOSPI Bulletin 048-08 (Time and Effort

Reporting)ExamplesSample forms

OSPI Bulletin 046-08 (Combining Funds in Schoolwide Programs)

OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments (2 CFR Section 225)

79

Maintenance of Effort

District Requirement

Section 1120A(a) and 9521 of NCLB34 CFR 299.5

81


The district has maintained fiscal effort if eitherThe combined fiscal effort per student or

The aggregate (total of included) expenditures of the district were at districts 90% of that of the preceding year.

This shows the district maintained its non-federal funding within 90%.

82

Maintenance of Effort“Preceding fiscal year” = the federal fiscal year

or the 12 month fiscal period used for reporting purposes prior to the beginning of the federal fiscal year in which funds become available.

Example: For funds available July 1, 2009Preceding fiscal year is 2003 (SY 2007-2008)Second preceding fiscal year is 2002 (SY 2006-

2007)Third preceding fiscal year is 2001 (SY 2005-2006)

83

Maintenance of EffortExpenditures included for MOE

AdministrationInstructionAttendance and health service personnelPupil transportation servicesOperation and maintenance of buildingFixed chargesNet expenditures to cover deficits for food

services and student body activities

84

Maintenance of EffortExpenditures excluded for MOE

Community servicesCapital outlayDebt serviceSupplemental expenses made pursuant to a

disaster declared by the President of the USAAny expenditures made for funds provided by

the federal government

85


When a district does not meet the maintenance of effort test its allocation is reduced in the exact proportion by which it fell below 90% (combined fiscal effort per student and aggregate expenditures)

The measure most favorable to the district is used

86


In determining maintenance of effort for the year following a failure to maintain effort, OSPI considers the district’s expenditures in the year the failure occurred to be 90% of the expenditures for the third preceding year.

OSPI does not use the expenditures for the

year in which the failure occurred.

87

Maintenance of EffortDistrict may apply to the US Department of

Education for a waiver for

Exceptional or uncontrollable circumstances, such as a natural disaster,

orPrecipitous decline in the financial resources of

the district.

88

Supplement Not Supplant

Considers services

Section 1120A(b) and (d) of NCLB

34 CFR 200.79

89

Supplement Not SupplantTargeted Assistance Schools

Title I funds must be used only to supplement the level of funds that would, in the absence of Title I, be available from non federal (state and local) sources for Title I students

The district is not required to provide Title I services using a particular instructional method (i.e. pull out programs, in class, etc.)

Based on services

90

Supplement Not SupplantProgram meets the intent and purposes of a

Title I program in a targeted assistance program if

It serves only children who are failing or most at risk of failing to meet the state’s performance standards.

It provides supplementary services designed to meet the educational needs of the children who are participating in the program.

It uses the state’s assessment system to review the effectiveness of the program.

91


Targeted Assistance BuildingsPresumptions of supplanting

The district has used the Title I funds to provide services that the district was required to make available under federal, state or local law.

The 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 children.

Rebuttals may be possible

92


Exclusions

The district may exclude supplemental state or local funds expended in any school for programs that meet the intent and purposes of Title I, Part A (e.g., Learning Assistance Program)

93

Supplement Not SupplantSchoolwide Program Schools

Must use Title I funds only to supplement the amount of funds that would, in the absence of Title I funds, be made available for that schoolwide program (including funds needed to provide services required by law for disabled children and LEP children)

Similar to MOE

94

Supplement Not SupplantProgram meets the intent and purposes of Title

I in a schoolwide program if:It is implemented in a school with 40% or more

poverty.

It is designed to promote schoolwide reform and upgrade the entire educational operation of the school.

It is particularly designed to meet the educational needs of at-risk students.

It uses the state’s assessment system to review the effectiveness of the program.

95

ComparabilityBuilding level

Section 1120A(c) and (d)

34 CFR 200.79

OSPI Bulletin 011-04

96

Comparability

A district may receive Title I, Part A funds only if it uses state and local funds to provide services in Title I schools that, taken as a whole, are at district comparable to services provided in non-Title I schools.

97

Comparability

If all schools in the district are Title I schools, the district must use state and local funds to provide services that, taken as a whole, are substantially comparable in each school.

98

Comparability Comparability is met if the district provides

written assurance it has established and implemented

1. A district wide salary schedule2. A policy to ensure equivalence among

schools in teachers, administrators, and other staff

3. A policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies

99

ComparabilityAlternative criteria

The district may meet the comparability requirement if it establishes and implements other measures for determining compliance such as student/teacher rations, student/instructional staff salary ratios or total expenditures per school.Staff salary differentials for years of employment may

not be included in comparability determinations.

The district need not include unpredictable changes in student enrollment or personnel assignments that occur after the beginning of a school year.

100

ComparabilityDocumentation

Report comparability each year on iGrant 361.The district must develop procedures/policies for meeting the comparability requirement and maintain records that are updated at district biennially.

101

ComparabilityExclusions

Bilingual education for children of limited English proficiency (State Transitional Bilingual).

Excess costs of providing services to children with disabilities (State Special Education).

Supplemental state and local funds spent for programs that meet the intent and purposes of Title I, Part A (LAP).

102

Targeted Assistance and Schoolwide Programs

103


Targeted Assistance Programs

Targeted Assistance Programs target Title I, Part A services to the students at greatest risk of not meeting the state’s student academic achievement standards

Students Pre-K through grade 12 are eligible for Title I, Part A services

104



Building staff must decide what content areas (Reading, Math, Language Arts, etc.) and grade levels to be served with Title I, Part A funds

Decision based on greatest need

105



Students in the identified subject areas and grade levels are selected for Title I, part A services based on “…multiple, educationally related, objective criteria established by the local educational agency and supplemented by the school”

This usually means the use of results from standardized tests, parent request, grade level academic performance, teacher and other administrative recommendations, and other discretionary criteria

106



A composite score can be developed using the test results, classroom performance and teacher recommendations

The students’ names are then rank-ordered, by subject area and grade level, on a list beginning with the most at-risk students

The district and/or building Title I staff then determine how many students can be served based on the amount of Title I, Part A funds that have been allocated to the building

107



Instructional programs are then developed to meet the academic needs of the most at-risk students

Students who qualify for services can be homeless, migrant, special education students, and former Head Start, Even Start and Early Reading First students who participated in those programs within the past two years

The Title I, Part A staff then must decide whether the services will be delivered via an in-class or pullout model, or a combination of both

108

Pullout and In-Class Instructional Delivery Models


Title I, Part A regulations strongly encourage minimizing the removal of students from the regular classroom to provide Title I, Part A services

Extended learning opportunities (before and after school, Saturday school, summer programs) are also encouraged

109


Schoolwide Programs

Designed for schools with 40% or higher povertyRequires a year of planningA schoolwide plan, which includes ten (10)

required components, must be completedThe plan must include the names and the dollar

amounts of the federal and state programs that have been combined into the schoolwide program

110


Schoolwide Programs

The schoolwide program must address the intent and purpose of each of the federal programs that have been included in the program

Schoolwide programs must still meet all requirements relating to health, safety, civil rights, student and family participation and involvement, services to private school children, maintenance of effort, and comparability of services

111


Schoolwide Programs

Although all students in the schoolwide program are eligible for Title I, Part A services, the students who are at greatest risk of not meeting the state academic achievement standards are the main focus

Annual evaluation of the program/plan effectiveness is required

112

New RegulationsNovember 2008

113

Districts must notify parents of students about public school choice options no later than 14 calendar days before the start of the school year.

[34 CFR 200.37(b)(4)(iv) & 34 CFR 200.44(a)(2)]

NotificationNEW

114

Parent OutreachA district may count in the amount required for choice-

related transportation and SES (20% obligation) the cost for parent outreach and assistance to meet these requirements.

A district may count up to an amount equal to 0.2% of the district’s Title I, Part A allocation (1% of the 20% obligation). Examples of allowable costs include

Parent notices Communication through the media, internet, and

community partners Displaying information on the district’s website Parent fairs

[34 CFR 200.48(a)(2)(iii)(C)

NEW

115

Student informationThe district must prominently display on its

website, in a timely manner:The number of students who were eligible for and the

number of students who participated in public school choice and SES, beginning with data from the 2007-08 school year and each subsequent school year.

For the current school year, a list of SES providers approved by the state to serve the district and the locations where services are provided.

For the current school year, a list of available schools to which students eligible to participate in public school choice may transfer.

[34 CFR 200.39(c)(1)]

NEW

116

Transparency for ParentsFor each district, states must post on their Web sites

The amount of funds available for choice-related transportation and SES as required in §200.48(a)(2) (the 20% obligation).

The per-child amount for SES as calculated under §200.48(c)(1).

States must indicate on the list of approved providers those SES providers that are able to serve students with disabilities or those students are limited English proficient

[§200.47(a)(3)(iii)].

NEW

117

To spend less than the amount needed to meet the 20% obligation, a district must meet, at a minimum, the following criteria:Partner, to the extent practicable, with outside

groups, such as faith-based organizations, other community-based organizations, and business groups, to help inform eligible students and their families of opportunities to transfer or to receive SES [§200.48(d)(2)(i)(A)].

Ensure that eligible students and their parents have a genuine opportunity to sign up to transfer or to obtain SES, including: Providing timely, accurate notice to parents. Ensuring that sign-up forms for SES are distributed directly

to all eligible students and their parents, and are made widely available and accessible through broad means of dissemination, such as the Internet, other media, and communications through public agencies serving eligible students and their families [§200.36 & §200.37].

118

Ensure that eligible students and their parents have a genuine opportunity to sign up to transfer or to obtain SES, including by: Providing a minimum of two enrollment “windows,” at

separate points in the school year, that are of sufficient length to enable parents of eligible students to make informed decisions about requesting SES and selecting a provider [§200.48(d)(2)(i)(B)].

Ensure that eligible SES providers are given equal access to school facilities, using a fair, open and objective process, on the same basis and terms as are available to other groups that seek access to school facilities [§200.48(d)(2)(i)(C)]

119

District Responsibilities to Document and Notify the State

To spend less that the amount needed to meet its 20% obligation, an district must: Maintain records demonstrating that it has met the

criteria in §200.48(d)(2)(ii), and Notify the state that it:

Has met the criteria in §200.48(d)(2)(i); and Intends to spend the remainder of its 20% obligation on

other allowable activities, specifying the amount of that remainder [§200.48(d)(2)(iii)].

NEW

120

Consequences for Non-ComplianceIf a state determines that an district has failed to meet

any of the criteria in §200.48(d)(2)(i), the district must: Spend an amount equal to the remainder of its 20%

obligation in the subsequent year, in addition to its 20% obligation for that year, on choice-related transportation costs, SES, or parent outreach and assistance, or

Meet the criteria and obtain permission from the state before spending less than the required amount in that subsequent school year. The state must confirm the district’s compliance with the criteria before granting such permission [§200.48(d)(4)].

NEW

121

American Recovery and Reinvestment Act (ARRA)

122

Education Stabilization FundsTwo types

Funds that go to the Governor Based on set formula To address shortfall in K-12 and Higher Education Leftover, if any, divided proportionally between

school districts based on proportion of Title I, Part A funding formula Note: These are NOT Title I, Part A funds May be spent on ESEA, IDEA, Perkins, Building

Modernization

123

Education Stabilization FundsFunds that go to the USED

To be distributed as Targeted and EFIG Title I, Part A funds

These ARE Title I, Part A funds Other

School Improvement McKinney-Vento Homeless Education IDEA Early Childhood Educational Technology—Title II, Part D Innovation and Improvement (Teacher Incentive)

124

Education Stabilization FundsOne Time Funding

Give careful thought to efficient and effective use Staffing may not be best use since cannot be

sustained Possible uses

Summer school Professional development activities Additional curriculum Tutoring

30 month availability

125

Education Stabilization FundsConsider pitfalls

Supplement Not SupplantMaintenance of EffortComparabilityCarryoverSustainability

126

Education Stabilization FundsSet asides will apply

Parent involvementProfessional development due to not making

AYPPrivate school equitable share

Set asides may applySupplemental Educational ServicesChoice for public school transportation

127

CPR IssuesTitle I, Part ADistrict Parent Involvement Policy is current

and contains all required componentsBuilding Parent Involvement is current and

contains all required componentsNotice to parents they may request

information regarding professional qualification of student’s classroom teacher

District report card to parentsInstructional paraprofessionals must be under

the direct supervision of a certificated teacher

128

Schoolwide plan must contain all ten components.

Matrix of funding sources Intent and purposes of combined program funds

Targeted Assistance Model

Evidence of eight componentsRank order listEvidence of entrance and exit

129

CPR IssuesLearning Assistance Program (LAP)Eligibility of students.Evidence that only students achieving below

state and district assessments are served.Accelerated student learning plans contain all

four components.Expanded learning opportunities for grades

eight, eleven and twelve.

130

CPR IssuesFiscalMaintenance of Effort

Reconciliation of T/E to budget

Capital Asset PolicySmall and Attractive

ProcurementPersonal Service Contracts(Sole Sourcing)

131

CPR IssuesSet- Aside Compliance

Set-Aside /Earmarks on iGrantsSeparate Sub-codes

Track Expenditures

Ranking of allocations

132

iGrant RevisionsTitle I, Part AiGrant Package 201: Title I, Part A (Regular Year)

Request for Substantial Approval: (The following pages only to be completed for SA.)– Complete Page 1 (Request for SA and complete matrix for preliminary budget))– Complete Page 2 (Assurances)– Complete Page 3 (Plan)

Page 2: Program Narrative• Q 1: Types of additional assistance-Summer School box indicated requires

completions iGrant 465)• Q 8: Updated link to N/D facilities• Q 14-15: Change in order of District and Building Parent Involvement policy

questions

Page 3: Set-Aside PageA 3: Update link to N/D FacilitiesE. Schoolwide Programs: Eliminate box

Public School Page:Remove box on profile: Number of years in Schoolwide

133

iGrant RevisionsTitle I, Part A

iGrant Package 244: Title I, Part A (End of Year) Regular Year

Section 1A, 1B, 1C, 1D, 1E: Added in unduplicated count:

Category: Not Identified Category

Section IIIB: Instructional Program-Social Studies deleted

134


iGrant Package 246: Title I, Part A (End of Year) Summer School

Section 1A, 1B, 1C, 1D, 1E: Added in unduplicated count:

Category: Not Identified Category

Section IIB/IIC: Instructional ProgramSocial Studies deleted

Section IIID: Program Staff Data Delete # 7 Other (e.g. volunteers)

135


iGrant Package 246: Title I, Part A (Summer School Program Application)

Page 1: Program DescriptionPage 2: Program Staff data

136

iGrant RevisionsLearning Assistance Program (LAP)

iGrant Package 218: Learning Assistance Program (Regular Year)

Application changes may vary depending on legislative decisions.

iGrant Package 245: Learning Assistance Program

(End of Year) Regular YearSection IB: Student Data: Count for race/ethnicityNot Identified

137

iGrant RevisionsLearning Assistance Program (LAP)

iGrant Package 247: Learning Assistance Program (EOY) Summer School Section IB: Unduplicated count by race/ethnicityAdded Not Identified category

iGrant Package 466: Learning Assistance Program (Summer School Application)Page 1: Program DescriptionPage 2: Program Staff data

138

Questions?????????

139

Office of Superintendent of Public Instruction 2009.

Documents

Transcript of Office of Superintendent of Public Instruction 2009.