Schoolwide Funding Consolidation Panel Panelists: Nancy Konitzer, Arizona Department of Education,...
-
Upload
jessie-rodgers -
Category
Documents
-
view
215 -
download
0
Transcript of Schoolwide Funding Consolidation Panel Panelists: Nancy Konitzer, Arizona Department of Education,...
Schoolwide Funding Consolidation PanelPanelists:
Nancy Konitzer, Arizona Department of Education, Rebecca Vogler, Cincinnati Public Schools and
Jose Figueroa, Baboquivari Unified School District
Moderated By: Tiffany R. Winters, Esq. and Leigh Manasevit, Esq.
Brustein & Manasevit, PLLCwww.bruman.com Spring Forum 2015
Three Types of SW Schools
1. SW with no consolidation2. SW that consolidates only federal funds3. SW that consolidate federal, state, and local
funds• Sometimes referred to as “SW3”
2Brustein & Manasevit, PLLC
All Schoolwide Programs: Basic Requirements
• Consolidate programs to upgrade the entire educational program of the school
• Ensure all children meet standards, particularly those most at risk
• Requirements:– 40% poverty– Schoolwide plan
Brustein & Manasevit, PLLC3
• All formula (non-competitive) BUT some caveats -• Includes IDEA - up to cap (but not exempt from programmatic
requirements)• Migrant; Indian Ed restrictions re consultation
• All discretionary (competitive)• Still must comply with application
• ED only (no School Lunch, Head Start)
• Important: Must Identify in SW PLAN: the programs that are “consolidated” and the amounts consolidated from each!
4
What federal program funds can be consolidated?
Brustein & Manasevit, PLLC
For Formula Grants
Meet “Intents and Purposes”• A school that consolidates federal funds is not required to
meet most of the statutory and regulatory requirements of the specific federal programs applicable at the school level. – Not required to ID particular children or provide
supplemental services
5Brustein & Manasevit, PLLC
For Discretionary Grants
• Must still carry out all activities described in application• But do not need to account separate for specific expenditures
of the discretionary grant funds
6Brustein & Manasevit, PLLC
What does it mean to consolidate funds?
• Treat funds like a “single pool of funds”• Lose individual program identity• School has one flexible pool of funds
– LEA does not literally need to combine funds in a single account or pool with its own accounting code
– “Pool” is used conceptually
• “Use to support any activity of the schoolwide program without regard to which program contributed the specific funds used for a particular activity”
7Brustein & Manasevit, PLLC
Can the State prevent consolidation?
• NO. Each SEA must “encourage schools to consolidate funds from Federal, State, and local sources in their schoolwide programs”, and
• “Each State plan shall contain assurance that - the SEA will modify or eliminate State fiscal and accounting barriers so that schools can easily consolidate funds from other Federal, State, and local sources for schoolwide programs”
• ESEA 1111(c)(9) and (10)
8Brustein & Manasevit, PLLC
TYPES OF SW PROGRAMS AND
LEVELS OF CONSOLIDATION
1. No Consolidation2. Consolidate only federal funds3. Consolidate federal, state and local funds
Brustein & Manasevit, PLLC
9
Standard Title I Schoolwide School- No Consolidation
• All students are eligible Title I Students• Title I funds must be spent on the “educational needs”
of school– Identified in needs assessment– Articulated in SW Plan
• Must account for and track the Title I funds separately, identifying the activities the Part A funds support
• EDGAR and allowability rules apply
10Brustein & Manasevit, PLLC
Schoolwide School With Federal Funds Only Consolidation
• All students are eligible Title I Students• Title I funds must be spent on the “educational needs”
of school (same as standard Title I school)
• Single Federal consolidated pool
• “From an accounting perspective, the funds from the contributing Federal programs lose their individual identity when they become part of a consolidated schoolwide pool and would be accounted for as part of that pool rather than by the individual programs that contribute to the consolidated schoolwide pool.”
11Brustein & Manasevit, PLLC
Schoolwide School With Consolidation of Federal, State and Local Funds
• “When Title I, Part A funds are consolidated with State and local funds . . . they lose their identity.”
• No distinction between federal and non-federal
• EDGAR does not apply
12Brustein & Manasevit, PLLC
THE MECHANICS OF CONSOLIDATION
13
Brustein & Manasevit, PLLC
The Mechanics of Consolidation
EXAMPLE 1: Across all SW schools in LEA•Consolidated schoolwide pool with its own accounting code
•The expenditures attributed to that code are charged on a proportional basis– If Title I contributed 8%, then 8% of SWP expenses
charged to Title I
14Brustein & Manasevit, PLLC
The Mechanics of Consolidation (cont.)
EXAMPLE 2: Single school model•No single accounting code for SWP •For accounting purposes, LEA attributes expenditures back to specific program REGARDLESS of what services those funds support•Two options for distributing expenditures:
– proportion of revenues or sequence charging
Brustein & Manasevit, PLLC15
Recordkeeping in SWP
• School operating SWP that consolidates funds is not required to maintain separate fiscal accounting records, by Federal program, that ID the specific activities supported by each program’s funds.– May have to track to functional categories like salaries, travel, supplies,
etc. BUT– The LEA would not be required to track how much it spends on
activities (for example, salaries) back to a specific program included in the consolidated SW pool.
16Brustein & Manasevit, PLLC
Reporting with SW Consolidation
Proportional Basis (or “any other reasonable method”)
•Use for identifying:– Carryover– Amount unused non-federal funding– MOE– Comparability– Reporting expenditures back to State or USDE– State Per Pupil Expenditure (SPPE)
17Brustein & Manasevit, PLLC
Supplement Not Supplant in all SW Schools
• ESEA 1114(a)(2)(B): Title I must supplement the amount of funds that would, in the absence of Title I, be made available from non-federal sources– The actual service need not be supplemental
• School must receive all the state and local funds it would otherwise need to operate in the absence of Federal funds– Includes routine operating expenses such as building maintenance and
repairs, landscaping and custodial services
18Brustein & Manasevit, PLLC
Time and Effort Required with Consolidation?If LEA/school consolidates . . . Then must keep . . .
Federal, state, and local funds No time and effort records
Federal only Time and effort required
Nothing (only Title I funds SWP) Time and effort required
Brustein & Manasevit, PLLC19
PANELISTS
Nancy Konitzer, Arizona Department of Ed; Rebecca Vogler, Cincinnati Public Schools; and
Jose Figueroa, Baboquivari Unified School District
Brustein & Manasevit, PLLC
20
Schoolwide Legal Resources
• Statute: ESEA Section 1114• Regulations: 34 CFR 200.25-200.29• Non-Regulatory Guidance
– Designing Schoolwide Programs Guidance: March 2006 www.ed.gov/policy/elsec/guid/ designingswpguid.doc
– “Title I Fiscal Issues,” February 2008 (replacing May 2006) http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf• Consolidating funds in schoolwide programs, MOE, SNS, Comparability,
Grantbacks, Carryover
21Brustein & Manasevit, PLLC
QUESTIONS?Brustein & Manasevit, PLLC
22
Brustein & Manasevit, PLLC23
This presentation is intended solely to provide general information and does not constitute legal advice or a legal service. This presentation does not create a client-lawyer relationship with Brustein & Manasevit, PLLC and, therefore, carries none of the protections under the D.C. Rules of Professional Conduct. Attendance at this presentation, a later review of any printed or electronic materials, or any follow-up questions or communications arising out of this presentation with any attorney at Brustein & Manasevit, PLLC does not create an attorney-client relationship with Brustein & Manasevit, PLLC. You should not take any action based upon any information in this presentation without first consulting legal counsel familiar with your particular circumstances.