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2013 EL Coordinators
MeetingTitle III Budget
TopicsO Title III Subgrant Allocation TimelineO Supplement, not SupplantO Title III 2% Administrative CapO Professional Development
RequirementO Federal Grants Closeout – Obligation
and Liquidation of Funds
NCLB Title III Provides discretion over
instruction methods. Local entities have the flexibility to choose the method of instruction to teach limited-English proficient children.
Targets funds to the classroom. Ninety-five percent of funds must be used for grants at the local level to teach limited English proficient children.
KDE Title III – EL/LEP and Immigrant Funding Allocation Process Timeline
• Declaration of Participation mailed to superintendentsJanuary
• Declaration of Participation Deadline. This is the opportunity to express interest in receiving Title III Funding
April
• Data Verification. Districts run IC LEP Extract and clean up LEP and Immigrant Data
May 1-31
• LEP and Immigrant counts pulled by KDE from Infinite Campus data compiled; Division of Budgets calculates tentative allocations
June 1
KDE Title III – EL/LEP and Immigrant Funding Allocation Process Timeline
• USDOE notification of grant award to KDE• Calculations are prepared and eligible
districts will be emailed subgrant information containing Title III Agreement, Application and Budget Plan with their tentative allocation
July
• Final Calculations are prepared. Superintendent, EL Coordinator and Finance Officer receive sub-grant notification of final allocation with the Award Notification
August
• District must complete Title III Plan and Budget mailed in the subgrant packet of final allocation. Return to KDE Title III/Division of Budgets
within 10 days after
being notified
October 1
Final release from Federal Government ; Washington’s budget year
Supplement, not Supplant
NCLB Title IIISection 3115 (g)
Supplement, not Supplant Requirement - General
Title III funds must be used to supplement the level of Federal, State and local funds
that, in the absence of Title III funds, would
have been expended for programs for limited English proficient (LEP) students
and immigrant children and youth.(section 3115(g))
Title III – A Supplemental Program to Serve English Learners
instructional program/serviceprovided by the district to all students
instructional program/servicerequired by Federal laws/regulations
instructional program/servicerequired by State and local laws/regulations
Title III-funded activities
Building Blocks to an Effective Title III Program:Two Required Activities
professional development
high-quality language instruction educational program
Supplement, not Supplant Requirement
Questions to Ask When Considering Whether Title IIIFunds Can be Used Without Violating
the Supplement, not Supplant Requirement
1. What is the instructional program/service provided to all students?
2. What does the LEA do to meet Lau requirements? 3. What services is the LEA required by other Federal, State, and
local laws or regulations to provide? 4. Was the program/service previously provided with State, local,
and Federal funds?
Based on the answers to the above questions, would the proposedfunds be used to provide an instructional program/service that is inaddition to or supplemental to an instructional program/service thatwould otherwise be provided to LEP students (or be required to beprovided by other laws/regulations) in the absence of a Title III
grant?
Supplement, not Supplant Requirement - General
The First Test of Supplanting: Required by Law
The U. S. Department of Education assumes supplanting exists if –
An LEA uses Title IIIfunds to provide services that the
LEA isrequired to make available
under State or locallaws, or other Federal laws.
Supplement, not Supplant Requirement - General
The Second Test of Supplanting: Prior Year
The U. S. Department of Education assumes supplanting exists if –
An LEA uses Title III funds to provideservices that the LEA provided in the prior
year with State, local or other Federal funds.
This assumption can be rebutted.
To refute the “prior year” test of supplanting, the LEA would need to have contemporaneous records to confirm…
Budget cuts were made in a number of areas, not just services for LEP students; and,
There was in fact a reduced amount of State or local funds to pay for this activity/position; and
The LEA made the decision to eliminate the position/activity without taking into consideration Federal funds.
Title III 2% Administrative
CapNCLB Title III
3115 (b)
Districts have a limit of 2% of the Title III grant award for administration. (section 3115(b))
Administration = administrative costs + indirect costs
Examples of administrative costs:support staff, coordinators, & other personnel
that perform administrative functions
Administrative costs are associated with the overall project management and administration and which are not directly related to the provision of services to participants or otherwise allocable to the program cost objectives/categories.
(Source: OMB Circular A-87)
Two types of administrative costs: Personnel & Non-Personnel
Examples of personnel costs for direct administration:• Salaries, benefits, & other expenses of the recipient or
sub-recipient's staff who perform these functions:overall program management, as distinct from overall program implementation, preparing program plans & budgets, and preparing reports related to program requirements.
Examples of non-personnel costs for direct administration:• Costs for goods & services required for program
administration, such as equipment purchase/rental, utilities, office supplies, postage, and rental and maintenance of office space
(Source: 1997 USDOE Indirect Cost Determination Guidance for State and Local Government Agencies)
High Quality Professional Development
NCLB Title IIISection 3115(c)(2)
NCLB Title III
Key Requirements – Title III Subgrants
School districts must use Title III funds to provide high-quality language instruction programs that are based on scientifically based research, and that have demonstrated that they are effective in increasing English proficiency and student achievement.
Districts are required to provide high-quality professional development to classroom teachers, principals, administrators, and other school or community-based organizational personnel in order to improve the instruction and assessment of limited English proficient student
Federal Grants Closeout
Obligations and Liquidation of Program Funds
Spending Title III Grant Money
Title III FundsO As of May 23, 2013 - 19.8% of
Kentucky FY12 Title III funds had not been drawn by Districts/Consortiums
O Totaling $751,566.92O As of August 20, 2013 – 16.4% of
Kentucky FY12 Title III funds had not been drawn down by Districts/Consortiums
O Totaling $619,743.20
FY12 Subgrant Funds13 Districts
Se-ries1
16%
81%
24%24%
100%
47%31%
17%10%5%13%
57%
23%
Percent of funds NOT dr...
IMPORTANT Spending Timeline
July 1– Awarded Amount (subject to Federal adjustment
October 1)27 months to spend funds*Special Note: Plan 15 months
September 30 – Funds Encumbered Prior to date
December 10 – Deadline to pay and draw (Federal Cash Request) encumbered funds
Thank you!
Your questions
Contact InformationDiverse Learners Branch [email protected]
Title III Program [email protected](502) 564-4970
Division of Budgets [email protected](502) 564-1979
Resources
Office of Management & Budget (OMB) Circular A-87:
http://www.whitehouse.gov/omb/circulars_a087_2004/
EDGAR – (See parts 76 and 80 in particular):
http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.pdf
Office for Civil Rights, ELL Resources:http://www.ed.gov/about/offices/list/ocr/ellresources.html
