IDEA 2004 Program Requirements and Funding EligibilityOffice of Special ProgramsApril 13, 2011

What do you know?

IDEA Entitlement FundingSection 611(school age) and 619 (preschool)

To provide students with disabilities aged 3-21, including students who have been suspended or expelled from school, a free appropriate public education, which includes special education and related services, to meet their unique educational needs and to meet other requirements under the act.

FAPE must include special education and related services designed to meet a students unique needs and prepare him or her for further education, employment, and independent living.

PROGRAM OBJECTIVESIDEA 2004 Special EducationSection 611, Part BSection 619, PreschoolStudents 3-21Students 3-5School AgePreschoolCFDA: 84.027CFDA: 84.127

children with disabilities have available to them a free appropriate education (FAPE)protect rightsassist agencies, districts with the education of students with disabilities (SWDs)assess and ensure effectiveness of efforts to educate children with disabilities

LOGISTICS Flow ThroughOctober Public School Enrollment Count and Low SES Count completedPrevious May Private School Enrollment Count RequestedMarch/April Allocations received from OSEPMarch 31 - Out-of-state DHHR student count completedMarch/April - State and federal allocations releasedInstructions for completion of on-line plan and funding amounts for the upcoming year are distributed to LEAs

LOGISTICS Flow ThroughApril-LEAs complete District Self-Assessment as part of needs assessment for strategic plans/LEA applicationApril/May LEA Budget Completed include LEA state/local expenditures for MOE May 1 Online plan rolls over to next fiscal yearJune 1-- LEA online plans due to OSP for review.June-July - Submitted applications are reviewed & upon approval grants are issued.NOTE: SEA receives federal awards in July and October. LEA may obligate up to 25% of total award prior to October 1.

LEA Entitlement - Flow Through

Entitlement Amount = Base + Population + Poverty Base Allocation (students with disabilities 1998/1996) Population/Poverty Amount = Entitlement Base Population Amount = 85% [Entitlement Base](allocated to LEAs based on most recent public and private school enrollment all students ) Poverty Amount =15% [Entitlement Base](allocated to LEAs based on most recent count of low SES students eligible for free/reduced lunch)

Example

Total Entitlement = $61,649,797

Base$22,891, 709

Population85% [$61,649,797 - $22,891,709 ] = $32,944.375

Poverty15% [$61,649,797 - $22,891,709 ] = $5,813,713

FUNDING ALLOCATIONS

Chart1

1

9

90

Allocations

High Cost Fund

1%

Set Aside9%

Flow Thru90%

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High Cost Fund1

Set Aside9

Flow Thru90

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USE OF FUNDSAllowable CostRTI and Coordinated Early Intervening ServicesHigh cost fundExcess CostMaintenance of EffortPrivate Schools

IDEA Part B and OMB Circular A-87OSEP ClarificationsIDEA Part B and OMB Circular A-87IDEA Part B and OMB Circular A-87

Allowable Costs

U.S. Dept. of Ed RequirementsEDGAR Education Department General Administrative RegulationsGives authority to OMB circularsGeneral Education Provisions Act - GEPAOffice of Management and Budget (OMB)OMB Circular A-133 Single AuditCompliance Supplement Part 4OMB Circular A-87

Allowable Cost 300.202 Use of amounts.Must be expended in accordance with the applicable provisions of this part.Must be used only to pay the excess costs of providing special education and related services to children with disabilities.Must be used to supplement State, local, and other Federal funds and not to supplant those funds.

IDEA Permissive Use of Funds300.208(1) Services and aids that also benefitnondisabled children.(2) Coordinated Early intervening servicesHigh cost special education/ related services.(b) Administrative case management.Purchase appropriate technology for recordkeeping, data collection, and related case management activities

Basic Guidelines of Cost PrinciplesAll costs must be:NecessaryReasonableAllocable*

Helpful Questions to Ask to Determine if a Cost is AllowableIs the proposed cost consistent with federal cost principles?Is the proposed cost allowable under the relevant program?Is the proposed cost consistent with an approved program plan and budget?Is the proposed cost consistent with program specific fiscal rules?Is the proposed cost consistent with EDGAR?

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OMB Circular A-87Allowable CostsEstablishes principles and standards for determining allowable costsYou have to read A-87 in conjunction with the IDEA to understand how it appliesTo the degree there is any conflict, IDEA requirements take precedence*

Do I need to spend these funds to meet the purposes and needs of the program?

Costs must be necessary and reasonable for proper and efficient performanceCosts are necessary and reasonable if, in nature and amount, they do not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost*

Basic Guidelines: ReasonablePractical aspects of reasonableIs the expense targeted to a valid programmatic or administrative consideration?Do I have the capacity to use what I am purchasing?Did I pay a fair rate? Can I prove it?Would I be comfortable defending this purchase?*

Basic Guidelines: Allocable

Practical aspects of allocableCan I prove the program benefited?Can I prove other programs are not benefiting?Ensuring only authorized useIncidental benefit*

Basic Guidelines: AllocableCan only charge in proportion to the value received by the programExample: LEA purchases a computer to use 50% in federal program and 50% in a state programCan only charge half of the cost to the federal program*

OMB Circular A-87Allowable CostsAppendix B of A-87 lists 43 selected items of cost examplesAlcoholic beverages are unallowableConference/meeting costs are allowable if primary purpose is dissemination of technical information (meals, transportation, rental of facilities, speakers fees, etc.) but see Appendix B, item 14 regarding Entertainment CostsCosts of professional organizations and subscriptions are allowableMemberships in civic, community or social organizations are allowable with the approval of the Federal awarding agencyCosts of membership in organizations whose primary purpose is lobbying are unallowable*

Selected Items of Cost(examples)Advertising & Public Relations CostsGenerally not allowable, except as specified in OMB Circular A-87, Attachment B

EntertainmentAmusement, field trip or social activities (tickets to shows or sporting events, meals, lodging, etc.) are generally not allowable*

Selected Items of Cost(examples)Salaries and WagesAllowable if proper time distribution recordsTravel CostsTransportation, lodging, subsistence, and related items, when traveling on business are allowable with certain restrictionsTrainingTraining for employee development is allowable; for IDEA, professional development for special education personnel or for general education teachers regarding how to teach students with disabilities

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NCRTI/OSEP ClarificationIDEA Part B specific examples of use of funds:FAPESpecial education teachers and administratorsRelated services providersMaterials and supplies for students with disabilitiesProfessional development for special education personnel or to assist general education personnel in teaching special education students

NCRTI/OSEP ClarificationSpecialized equipment or devices to assist children with disabilitiesTwo exceptions:Title I/IDEA schoolwide programsCoordinated early intervening services for students without disabilities needing academic or behavioral support to succeed in general education

Coordinated Early Intervening Services Purpose from Congressional Committee Report:and early intervening services to reduce the need to label children as disabled in order to address the learning and behavioral needs of such childrenU.S. Department of EducationOffice of Special Education ProgramsBuilding the Legacy 2004*

Building the Legacy 2004

CEISWith an approved plan, the LEA may (or in some cases is required to) use up to 15% of IDEA funds for: Professional developmentProviding educational and behavioral evaluations, services, and supports, including scientifically-based literacy instructionProviding educational and behavioral evaluations, services, and supports including scientifically based literacy instruction

U.S. Department of EducationOffice of Special Education ProgramsBuilding the Legacy 2004*

Building the Legacy 2004

*A Conceptual Framework for RTIHigh NeedLow NeedCore InstructionIncreasingly Intensive Instructional InterventionsLevel of need for student to be successful in core instructionStudents may receive services in all areas of the pyramid at any one point in timeServices for Students with IEPs

RTI and CEISCEIS (and IDEA) funds may not be used for Tier 1CEIS (and IDEA) funds may not be used for universal screeningCEIS funds may be used for Tier 2 and Tier 3, but special education students should not be includedCEIS may be used for RTI training

CEIS and Supplement Not SupplantCEIS funds may be used to supplement but not to supplant services provided with funds available under the ESEA (e.g. after school tutoring, school improvement activities)Violations include:Funding services otherwise required by state, federal or local lawFunding services paid in prior year, e.g. previously paid by Title IThis may be rebutted if the services would not have been funded from other sources if CEIS were not available

Progress MonitoringProgress monitoring is a scientifically based practice that is used to assess students academic performance and evaluate the effectiveness of instruction and instructional interventions. Generally, Title I, Title III, and CEIS funds may be used to fund progress monitoring (but not universal screening) if the progress monitoring is used to determine the response to an intervention that is supportable with Title I, Title III, or CEIS funds.*

RTI and IDEA Funding (not CEIS)A special education teacher fully funded by IDEA (non-CEIS) funds who is providing special education to students with disabilities may include one or more at-risk students in this group. E.g. if a replacement reading program, such as Wilson, is being taught to special education students in a pull-out period, Tier 3 RTI students could participate for a limited period of time, provided this arrangement does not exceed the Policy 2419 per period caseload and does not displace any special education student from IEP services

RTI and IDEA Funding (not CEIS)The special education teacher or related services personnel fully-funded by IDEA cannot be scheduled to provide special education services part of the day and other duties (e.g., interventions for students without disabilities) during another part of the day.IDEA funds may not be used for universal screening (conducted for all students) for RTI

HIGH COST/HIGH ACUITY FUNDS

High Cost FundFor the purpose of assisting districts in addressing the needs of high need students with disabilities, each State has the option to reserve for each fiscal year 10% of the amount it reserves for State-level activities.Each State must:develop and make available a high cost planconsult with districtsdevelop a funding mechanism and schedule for fund distributionWV includes state high acuity funds in this planDivision of Instructional & Student Services*

Division of Instructional & Student Services

High Cost FundStakeholder involvementDefinition: Individual application for an eligible SWD who:is 3-21 years of agehas a current IEPlives within the LEA requesting funds or receives special education and related services within the LEAcost is equal to or greater than $45,000 per year

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EXCESS COSTIDEA 2004

Excess CostThe excess cost requirement prevents an LEA from using funds provided under Part B of the Act to pay for all of the costs directly attributable to the education of a child with a disability, subject to paragraph (b)(1)(ii) of this section.

Excess costs are those costs for the education of an elementary school or secondary school student with a disability that are in excess of the average annual per student expenditure in an LEA during the preceding school year for an elementary or secondary student.

Excess Cost Elementary vs. SecondarySection 602(8) of the Act and 300.16 require the LEA to compute the minimum average amount separately for children with disabilities in its elementary schools and for children with disabilities in secondary schools. The formula for these calculations are provided in 34 CFR, Appendix A to Part 300.The form and calculations to meet this requirement are in Section VIII of the LEAs on-line strategic plan.

Excess Cost Elementary vs. SecondaryData on the form is primarily self-filling and calculating and is pulled from the LEAs general ledger information stored in WVEIS.

To calculate the amounts required for elementary vs. secondary, as required by law, total expenditures for the provision of special education services are pro-rated and entered in the form from a table that was developed in conjunction with the Office of Technology and the Office of School Finance.

Excess Cost Elementary vs. SecondaryThis table was established based upon the following premises:Sums the salary expense of teachers by location within the general ledger. Pre-kindergarten through grade six was defined as elementaryGrades seven through 12 were defined as secondary. Using the above definitions to segregate total salary expense, a prorated percentage to total expenses was assigned to each elementary and secondary.The total expense pulled from WVEIS in each of the fund categories was then multiplied by the resulting factor which provides the amounts to be used in each of the calculations for elementary or secondary results.The child counts used in the calculations were divided based on the assumption of ages 3-12 as elementary and 13-21 as secondary.

MAINTENANCE OF EFFORTIDEA 2004

IDEAs MOE RequirementsSEA IDEA prohibits a state from reducing state financial support for special education below the amount of that support for the preceding fiscal year. (34 CFR 300.163)

LEAs IDEA requires that LEAs must budget the same amount of local funding for special education as it expended in the previous fiscal year. (34 CFR 300.203)

MOE Two ComparisonsEligibilityDetermining whether an LEA is eligible to receive the IDEA Part B Funds Budget to Actual Expenditure ComparisonEstimate based on most recent year reviewed in June 1 submissionReviewed and revised after year is closed

ComplianceDetermine if the LEA met the requirements of IDEAs maintenance of effortActual to Actual Expenditure Comparison

SO IMPORTANT TO UNDERSTANDThis is the eligibility test based on expenditures pulled from the WVEIS financial management system from the most recent year compared to the LEA-provided budget amount. COMPLIANCE is met through actual to actual expenditure comparison. If compliance is not met, the LEA must pay back the difference in non-federal funds.

REPAYMENT

*Part B LEA MOE Requirement: Supplement/Not SupplantFunds under Part B must be used to supplement State, local and other Federal funds and not to supplant themSee 34 CFR 300.202(a)(3)

If an LEA maintains its fiscal effort, it will only be using Part B funds to supplement local, or State and local, funds, and not to supplant them

IDEA does not require a particular cost test This is contrary to Title I and confusing to many WV LEAs*

Four Tests to Meet MOEAn LEA needs to only meet ONE of the following comparison tests:Local & State expenditures in total for SWDLocal Only expenditures for SWDThe per student capita amount of Local & State expenditures for SWDThe per student capita amount of Local Only expenditures for SWD

Medicaid and MOE 300.154 .(g)(2) Methods of ensuring servicesIf a public agency spends reimbursements from Federal funds (e.g., Medicaid) for services under this part, those funds will not be considered State or local funds for purposes of the maintenance of effort provisionsMedicaid revenues and expenditures must be specifically coded in WVEIS accounting

Other Post Employment Benefits OPEBBeginning with FY10, LEAs are required to account for future post employment benefits for employeesExpenditures are recorded; should be attributed to 2xxxx as applicableWhen OPEB expenditures are recorded, they are pulled when WVDE calculates MOEProcedures for recording expenditures must be consistent year to year to avoid complications with MOE calculation

PRIVATE SCHOOLSIDEA 2004

Private SchoolsThe LEA is responsible for child find and services to children with disabilities enrolled by their parents in private schools within the school districtAmount to be expended by the LEA for the provision of those services shall be equal to a proportionate amount of Federal funds made available under this part.In calculating the proportionate amount, the LEA shall consult with the private schools and conduct a thorough and complete child find process.

PreschoolsAnd what about parentally placed preschoolers?

Children aged 3-5 are considered to be parentally-placed private school children with disabilities enrolled by their parents in private, including religious, elementary schools, if they are enrolled in a private school that meets the definition of elementary school in 34 CFR 300.13 34 CFR 300.133(a)(2)(ii)*

*ConsultationTo ensure timely and meaningful consultation, an LEA (or SEA) must consult with private school representatives and representatives of parents of parentally-placed private school children with disabilities during the design and development of special education and related services . . . 34 CFR 300.134

ConsultationWhat must the consultation process involve? *Child find processDetermining the proportionate share of IDEA funds availableDetermining the consultation process to be usedHow, where, and by whom services will be providedDisagreement process for LEA

Child Find RequirementsIf private schools are located within the district, conduct child find for children in private schools. Records must be maintained on: 1) the number of children evaluated; 2) the number found eligible as part of child find, and 3) the number of children served.

Expenditures*Number of eligible children with disabilities In public schoolsIn private schools300+ 20320Federal Part B Flow-Through $$LEA receives$152,500 $152,500 320$476.57 a student x 20 students$9,531.25 for proportionate share

Expenditures/Proportionate ShareState and local funds may supplement but not supplant federal funds for this population34 CFR 300.133(d)Cost of child find may not be considered in proportionate share obligation 34 CFR 300.131(d)Amount is calculated within the Five-Year Online Strategic Plan when district enters child count numbersBudget and services are included in plan; funds coded in WVEIS under program/function code 51510*

Use of Carry-Over FundsIf the LEA has not spent all the funds within the initial year of the grant award, it must obligate those funds for special education and related services for students parentally placed in private school during the one-year carry-over period

If all requirements are met, and funds remain at the end of the carry-over period, the LEA may request approval to transfer the funds to other allowable expenditures under IDEA

Budget Revision Request for Private School Expiring Funds Includes:A list of private schools within the district;A brief description of the child find process, The districts count on December 1, 2008 and December 1, 2009 of: 1) private school students evaluated, 2) students found eligible and 3) students receiving services through a Services Plan;Copies of the completed and signed Documentation of Consultation forms for the 2009-2010 and 2010-2011 Documentation of attempts to consult with private schools that have not signed the affirmation, if any;A brief explanation of reasons why the funds could not be expended; andBudget revision request forms and journal entry

QuestionsOSP Fiscal Resources Web Pagehttp://wvde.state.wv.us/osp/FY11StrategicPlan.html

Sandra McQuain, Ed. D. Office of Special Programs(304) 558-2696smcquain@access.k12.wv.us

Janice HayOffice of Internal Operations(304) 957-9833, ext. 53423jehay@access.k12.wv.us

Significant Disproportionalityand CEISSpecial Education Directors MeetingSeptember 2010 and April 2011Dr. Lanai JenningsCoordinator, Office of Special Programs

What is Significant DisproportionalityStates must annually collect and examine data to determine if Significant Disproportionality is occurring based on race or ethnicity.

Authority: Section 618(d) of the IDEA and the implementing regulations in 34 CFR 300.646

What is Significant DisproportionalityData analyses by race/ethnicity must include the following: identification of children as children with disabilities; identification of children as children with a particular disability; placement of children with disabilities in particular educational settings; and the incidence, duration, and type of disciplinary actions, including suspensions and expulsions.

What is Significant DisproportionalityStatistical results stand alone A review to determine whether the significant disproportionality is the result of inappropriate identification is not applicable

SEA must require any LEA identified as having significant disproportionality in any of the four above-mentioned analysis categories to reserve the maximum amount of funds for comprehensive Coordinated Early Intervening Services (CEIS). 15% of IDEA funds

Defining Significant DisproportionalityStates have the authority to define for LEAsState determines criteriafor what level of disproportionality is significant

How does WV defineSignificant DisproportionalityCell size = 20Relative Risk Ratios (RRR) must be greater than or equal to 3.0Placement and identification are examinedDiscipline: type, duration, and incidenceConsecutive year provision

Additional OSP Business RulesNo rounding occurs for the resultant RRR. a RRR of 2.9999 does not trigger consequences for the districtWhen fewer than 20 students in a single minority group are identified as having a disability, placement in an LRE, or assigned OSS, ISS, or total removals, the RRR is not required to be calculatedHowever, OSP may choose to do so to report to districts for tracking purposes.

SIGNIFICANT DISPROPORTIONALITY IS NOT SPP/APR INDICATORS 4B, 9, OR 10

Side-by-Side Comparison

Side-by-Side Comparison

Has Significant Disproportionality been identified in your district?OSPSignificant DisproportionalityandCEIS Resourceshttp://wvde.state.wv.us/osp/SignificantDisproportionality-CEIS.html

What happenswhen significant disproportionalityis identified?

Require LEAs touse 15% of Part B fundsfor CoordinatedEarly Intervening Services(CEIS)particularly, but not exclusively, for children in those groups significantly over identified.For Determinations of Significant DisproportionalityStates must:

For Determinations ofSignificant DisproportionalityLEA must:Publicly reporton the revision ofpolicies,practices,and procedures

What are Coordinated Early Intervening Services (CEIS)?

http://wvde.state.wv.us/osp/CEIS_Memo08-09.pdf

CEISServices provided through IDEA funding for at-risk students who do not receive special education servicesK-12 onlyDirect academic or behavioral interventionsProfessional development

Mandatory or Voluntary CEISMandatory Use of CEIS: LEA is identified with Significant Disproportionality by race/ethnicity in LRE, identification or disciplineLEA must reserve the maximum amount (i.e., 15% IDEA funds)Funds are used to address the Significant DisproportionalityNo option to reallocate funds

Voluntary Use of CEIS: LEA opts to set aside IDEA funds for the provision of services to students without disabilities (SWODs)LEA may use up to the maximum amountFunds address district determined needLEA may also reallocate any unspent funds while funds are available for obligation

How does a district set aside CEIS funds?CEIS funds must be specified in a districts special education plan and proposed budget.Go to: Compliances/ LEA Special Education / LEA Early Intervening

Coordinated Early Intervening Services Narrative Need for program Entrance criteria Description of services and targeted grades, subjects, etc. Method of monitoring progress Exit criteria How funds will be spent

Related Areas on Plan1) LEA Allocation ScreenCEIS set aside should be updated2) CEIS portion of budget should reflect services to students without disabilities and be aligned with CEIS narrative 5 digit program function code should begin with 13) When applicable, professional development plan and goals / objectives / actions should also align.

Reporting RequirementsCEIS is a new 618 report Two required reporting mechanisms:LEA Application CEIS program descriptionTotal number of students who received CEIS during the school yearTotal number of students who received CEIS in prior school years and who later qualified for special education and/or related servicesWVEISweb Intervention ScreensIdentifies students by WVEIS number Specify only students who received CEIS during the prior school year

Special Education Plan Report Required at the time of LEA application submission

Click Yes here(Default setting is No)

Required by June 15 each school year after CEIS are providedWVEISweb tracking

Why is Significant Disproportionality Important?More likely to be assigned to segregated classrooms or placementsMore likely to be assigned long term suspensionsHave limited access to inclusive and general educational environmentsExperience higher dropout rates and low academic performanceOften exposed to substandard and less rigorous curricula May be missclassified or inappropriately labeled

Why is SignificantDisproportionality Important?May receive services that do not meet their needs; andAre less likely than their white counterparts to return to general education classrooms.

Are more likely to become dropouts or receive a certificate of attendance and/or experienceHigh unemployment ratesLack of preparation for the workforceDifficulty in gaining access to postsecondary education

Why is Significant Disproportionality Important?

Other factors that may contribute to Significant Disproportionality:LanguageIntrinsic deficitsChild poverty & associatedrisk factorsAssumptions about intelligenceWait-to-fail modelResearch to practice gap

Federal Program RequirementsOffice of Special ProgramsApril 13, 2011

AGENDAFederal Grants ManagementFederal Programs ComplianceOMB Circulars and EDGARAuditsTime and EffortObligation and LiquidationInventory Management

FEDERAL PROGRAMS COMPLIANCECommon federal grants management rules apply to all federal education fundsGEPA (General Education Provisions Act)EDGAR (Education Department General Administrative Regulations)OMB Circulars (Primarily A-133 and A-87)Specific program (e.g. IDEA) rules applyDistrict and state financial procedures applyPolicy 8200-PurchasingCapital Assets Manual (inventory)Chart of Accounts (budget codes)Federal and state monitoring may review compliance with all of the aboveSpecial attention paid to procedures used when ARRA funds are involved

Education Department General Administrative Regulations (EDGAR)Contains specific rules governing systems:Financial Management 80.20 74.21Procurement 80.36 74.40-74.48Inventory 80.32 74.34

Gives authority to OMB circulars

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OMB Circular A-133What is it?Who uses it?Why is it important?

Auditors use it to determine which programs they audit

*Single Audit Act and A-133Requires annual auditType A programs ($500,000)At-risk Type B programs ($100,000)Completed audit reports to Federal Audit Clearinghouse which distributes to Federal agenciesAgencies have 6 months from issue date of report to resolve audit findings

What do auditors look at?Depends on the programThis is covered in the A-133 compliance supplementMatrix of Compliance Requirements

66 Environmental Protection Agency (EPA)66.458YYYYYYYYYYYY66.468YYYYYYYYYYYY81 Department of Energy (DOE)81.042YYYYYYYYYY84 Department of Education (ED)84.002YYYYYYYYYY84.010YYYYYYYYYYY84.011YYYYYYYYYYY84.027 84.173YYYYYYYYYY84.032-GYYY84.032-LYYYY84.041YYYYYY84.042 84.044 84.047 84.066 84.217YYYYYYYYY84.048YYYYYYYYYYYY84.126YYYYYYYYYYYY84.181YYYYYYYY84.186YYYYYYYYYY84.282YYYYYYYYYY

CFDATypes of Compliance RequirementsA.Activities Allowed or UnallowedB.Allowable Costs/Cost PrinciplesC.Cash ManagementD.Davis-Bacon ActE.EligibilityF.Equipment andReal PropertyManagementG.Matching, Level of Effort, EarmarkingH.Period of Availability of Federal FundsI.Procurement and Suspension and DebarmentJ.Program IncomeK.Real Property Acquisition/Relocation AssistanceL.ReportingM.Subrecipient MonitoringN.Special Tests And Provisions

*OMB A-133 Compliance RequirementsIDEA-Related RequirementsActivities Allowed or UnallowedAllowable Costs/Cost PrinciplesCash ManagementDavis-Bacon Act (Not Applicable)Eligibility (Not Applicable)Equipment and Real Property ManagementMatching, Level of Effort, EarmarkingPeriod of Availability of Federal FundsProcurement and Suspension and DebarmentProgram Income (Not Applicable)Real Property Acquisition/Relocation Assistance (Not Applicable)ReportingSubrecipient MonitoringSpecial Tests and Provisions

Federal Grants Management and Compliance ConsiderationsTime and EffortTimely Obligation and Liquidation/Cash ManagementInventory ManagementBudget Transfers

TIME AND EFFORT(A Common Audit Finding)Largest expenditure category in special education budgets : PersonnelAudit Standard: Must be able to document amount of time under each grantPolicies/procedures to determine percentages of time devoted to individual Federal programs and awardsTime and effort certification or personnel activity report (PAR)

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Time and EffortIf federal funds are used for salaries time distribution records must be kept

Must demonstrate that employees paid with federal funds actually worked on the specific federal program

Type of documentation depends on the number of cost objectives the employee worked on

These cost objectives must be connected to the employees salary source

Time and EffortWhat is a cost objective?A specific grant award, or other category of costs, that requires the grantee to track specific cost information

If an employee works on a single cost objective:Semi-Annual CertificationSigned by employee and supervisor every six months

Example: I hereby certify that for the period January 1, 2011 through June 30, 2011 one-hundred percent (100%) of my time and effort was spent on IDEA, Part B Administration.

Time and EffortIf an employee works on multiple cost objectives then a Personnel Activity Report (PAR) must be maintained:

After-the-fact-recordCompleted at least monthlyMust include total activity for which the employee is compensatedSigned and dated by employee (supervisor may also sign)

Time and EffortQuarterly comparisons of actual costs to budgeted distributionsIf a variance of 10% or greater existsAdjust expenditures to reflect costs of the actual time reported.In order to minimize future differences, adjust estimated distributions for future payrolls to activity performed in the previous quarter. This should help minimize the difference in actual wages paid to time recorded.If difference is less than 10%, may make adjustment annually.

OBLIGATION AND LIQUIDATIONDefinitionsObligation EDGAR 76.707

Liquidation-The issuance of payment for an obligation.

If the obligation is for-- The obligation is made--(a) Acquisition of real or personal propertyOn the date on which a binding written commitment to acquire the property.(b) Personal services by an employeeWhen the services are performed.(c) Personal services by a contractor who is not an employeeOn the date on which a binding written commitment is made to obtain the services.(d) Performance of work other than personal servicesOn the date on which a binding written commitment is made to obtain the work.(e) Public utility servicesWhen the services are received.(f) TravelWhen the travel is taken.(g) Rental of real or personal propertyWhen the property is used.

Obligation and LiquidationCash Management Improvement ActLEAs must draw down cash from grant awards to pay expenses only as they are incurred. Interest earned on federal cash draws held in excess of three days require the remission to the SEA of interest earned on that excess.Exhaust FY 11 funding before using FY 12 funding.Check balances of FY 10 funding Ending obligation date is September 30, 2011 and ending liquidation date is December 31, 2011.

Obligation and Liquidation-TimelinesAvailability of IDEA FundsFY 10 (IDEA regular and ARRA)Obligation periodJuly 1, 2009 September 30, 2011Ending liquidation dateDecember 31, 2011FY 11Obligation periodJuly 1, 2010 September 30, 2011Ending liquidation dateDecember 31, 2012FY 12Obligation periodJuly 1, 2011 September 30, 2013Ending liquidation dateDecember 31, 2013

Obligation and Liquidation-Use of Budget Revision ProcessWhen are budget revisions required?What is the process?WVDE forms 11-20-12 and 11-20-13GNL 520 (please print entry with object text description)Who do you contact?OSP Budget Revisions Memo February 2010 (Copy of memo recently emailed to the Special Education Directors ListServ on 2/18/2011).

Project Financial ReportsGood tool to assist in monitoring budget/expendituresSelect countySelect project02 state special education43 IDEA fundsSelect fiscal year May select specific months

http://wveis.k12.wv.us/surveys/genledger_projects_years.cfm

INVENTORY MANAGEMENTEDGAR 80.32(c)-(e)EquipmentFederal definition of Equipment (OMB Circular A-122)Tangible personal propertyUseful life of more than one yearAcquisition cost of $5,000 or more

For purposes of maintaining IDEA InventoryAs above, exceptUseful life of more than one year, regardless of acquisition costExample: PDAs, Computers, Cell phones, Copiers, Projectors, Digital Cameras, Etc.

See also WVDE Capital Assets Manual

Inventory Management - EquipmentMust have adequate controls in place to account for:Location of equipmentCustody of equipmentSecurity of equipment

LEA should have procedures in place and documentation to track and account for the location and assignment of equipment at all times A tracking system must be implemented for requesting and signing out equipment to be used off-site

Inventory Management-EquipmentMust protect against unauthorized useMay use for other projects as long as use is incidental and does not interfere with authorized useWhen property is no longer needed, must follow disposition rulesTransfer to another federal programOver $5,000 Keep or sell, but must pay a share based on the percentage of federal ED participation at initial acquisitionUnder $5,000 May keep, sell, or dispose of it with no obligation to EDWhen property is lost, damaged or stolenFollow procedures in the WVDE Procedures Manual Capital Asset System (Send copy of documentation to SEA)

Monitoring and ComplianceSection 618 DeterminationsFiscal management a monitoring focus of OSEP for states and districts

Timely and accurate submission of data and LEA applicationTimely liquidationTime and effort documentationAudit findings

Report On The ARRA Grant FundsReport FTE jobs funded with ARRA IDEA fundsReport project status (activities)Report quarterly on the expenditure of ARRA IDEA fundsEnter in Five Year Online Strategic Plan ARRA Reporting by end of each quarterReport vendors receiving payments $25,000 and over, including name, product description

Where to Find Federal Education Grants Management RequirementsOffice of Management & Budget (OMB) Circulars : A -87; A- 133 http://www.whitehouse.gov/omb/circularsCircular A-133 Compliance Supplement (2009): http://www.whitehouse.gov/omb/circulars_a133_compliance_09toc/

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Where to Find Federal Education Grants Management RequirementsProgram Rules: www.ed.govStatutesRegulationsGuidanceGeneral Education Provisions Act (GEPA):http://www.law.cornell.edu/uscode/20/usc_sup_01_20_10_31.html Education Department General Administrative Regulations (EDGAR): http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html

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WVDE Financial Requirement Manuals/Formshttp://wvde.state.wv.us/finance/

ContactsJanice Hayjehay@access.k12.wv.us(304) 558-2686 CoordinatorOffice of Internal Operations

Sandra McQuain(304) 558-2696smcquain@access.k12.wv.usAssistant DirectorOffice of Special Programs

Medicaid and EducationAdditional Source of FundingApril 13, 2011

www.cms.gov

Centers for Medicare & Medicaid Services

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Medicaid

Medicaid is a jointly-funded, Federal-State health insurance program for certain low-income and needy people. It covers approximately 36 million individuals including children, the aged, blind, and/or disabled, and people who are eligible to receive federally assisted income maintenance payments.

To ensure public and expert involvement in running our programs, CMS maintains a number of chartered advisory committees. These committees, whose meetings are open to the public, are used to provide advice or make recommendations on a variety of issues relating to CMS's responsibilities and activities.

DHHS/CMS Initiatives include:

Beneficiary Notices Initiative

Medicare Learning Network (MedLearn)

The American Customer Satisfaction Index

Home and Community Based Services:

Americans with Disabilities Act / Olmstead

New Freedom Initiative

Real Choice for Systems Change Grants

Systems Change Grants for Community Living

Ticket to Work and Work Incentives Improvement Act of 1999 (TWWIIA)

State Health Reform

Maternal HIV Consumer Information

Performance Measurement (APP)

Health Insurance Portability and Accountability Act (HIPAA),including the Administrative Simplification Act (AS)

Emergency Payment For Services

Medicare-Endorsed Rx Discount Card Initiative

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Medicare Integrity Program.

Medicare.gov | Department of Health and Human Services | NMEP

Privacy Policy | Feedback | Help | Website AccessibilityFreedom of Information Act | Privacy Act

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State PlanEach state determines its State Plan within the general guidelines of the federal CMS.

Medicaid and Education TimelineU.S. Congress IDEA WV Code 18-2-5bMedicaid State Plan Amended 198920001990for children with IEPsOnly TherapiesAdded IEPs, Care Coor, Sp. Trans. Personal Aides

WV Code 18-2-5b(a) The state board shall become a Medicaid provider and seek out Medicaid eligible students for the purpose of providing Medicaid and related services to students eligible under the Medicaid program and to maximize federal reimbursement for all services available under the Omnibus Budget Reconciliation Act of one thousand nine hundred eighty-nine, as it relates to Medicaid expansion

IDEAA noneducational public agency described in paragraph (b)(1)(i) of this section may not disqualify an eligible service for Medicaid reimbursement because that service is provided in a school contextReinforced that Medicaid would reimburse covered services provided by the school.

IDEAA public agency may use the Medicaid or other public benefits or insurance programs in which a child participates to provide or pay for services required under this part, as permitted under the public benefits or insurance program

IDEAIf a public agency spends reimbursements from Federal funds (e.g., Medicaid) for services under this part, those funds will not be considered "State or local" funds for purposes of the maintenance of effort provisions in Sec. Sec. 300.163 and 300.203.

IDEAReduction of Other Benefits.--Nothing in this part shall be construed to permit the State to reduce medical or other assistance available or to alter eligibility under title V of the Social Security Act or title XIX of the Social Security Act (relating to Medicaid for infants or toddlers with disabilities) within the State.

Each School District 1st # Therapy Provider # 0 00XXXXXXXX Audiology # OT # PT # SLP # RN # Psychology # Each School District 2nd # Cost-Based Provider # 15XXXXXXXX - New Initial/Triennial IEP Annual IEP Personal Care (full) Personal Care (part) Sp. Trans. Vehicle Sp. Trans. Aide Care Coordination

19902000

RESA LEAWVDHHR - Molina Processing Agency;Bureau ofMedical Services BMSRemittance AdviceDenial/pendingElectronic claimBilling Form or WVEIS EntrySupporting Documentation: IEP Progress Notes Attendance Records Care Coordination formPayment Direct Deposit

DocumentationStudent Related Documentation Included in IEP services the IEP form Therapy notes/log: Notes/outcome re: student progress and prognosis The Care Coordination form Personal Care form Specialized Transportation form number of special education students riding specialized transportation

Billing Documentation - WVEISMaintain documentation in the students individual cumulative file in a centralized location.

State of West Virginia Form DOE-105Version 8/09/01

Physician Authorization/Certification Form

Student Name (L, F, M): __________________________________________________

Diagnosis:__________________________________________________

Medicaid Number:__________________________________________________

The following services have been included on the above-named students Individualized Education Plan.

Service

X = Included on IEP

Service Amount (times per wk/mo and/or minutes per wk/mo)

Speech Therapy

PT; OT

I certify the above-identified services as medically necessary.

__________________________________________________

Name (Print)

Date

____________________________________

Signature

Freedom of ChoiceFreedom to choose services from providers outside the school systemMedicaid cannot cover duplicate servicesEstablish in writing that the School System is not to seek reimbursement for services that are provided by an outside agency. (Consent form)

Frequently Asked QuestionsPersonal care : Services must be provided on a full-time basis. The aide must not be responsible for any other student. Not specific to the aide

Full-time / Full Day = $150.94/day ($3,018.80/month 20 days)

Full-time/ Partial Day = $75.47/day ($1509.40/month 20 days)

Frequently Asked QuestionsCare Coordination : Coordinate delivery of services related to IEP. Check all activities completed during that month, but may bill even if only one activity was checked.

1 billing per month/per student = $77.09/mo.

Service Record Care Coordination

Medicaid Number

Last Name

First Name

WVEIS Number

Diagnosis Code

School

County

Beginning Date

Ending Date

Procedure Code

Units

T2022

1

Care Coordination. T2022 = 1 unit per month. List dates of any and all

activities completed this calendar month.

Care Coordination Activities

Date(s)

A. Met with Special Ed. or Reg. Ed. teacher regarding childs service needs/progress

B. Met with Therapist regarding service needs/progress

C. Met with Psychologist regarding service needs/progress

D. Met with Social Worker

E. Met with Counselor regarding service needs/progress

F. Met with Personal Care Aide regarding needs/progress

G. Met with other health care provider regarding childs service needs/progress

H. Issued letter/memorandum regarding childs service needs/progress

I. Contacted provider(s) to schedule testing/consultation

J. Met with parent(s)/guardian(s) regarding childs treatment needs/progress

K. Met with parent(s)/guardian(s) on testing results

L. Issued letter/memorandum to parent(s)/guardian(s)

M. Contacted parent(s)/guardian(s) to schedule consultation

N. Met with child to discuss progress

O. Met with child to discuss service needs

P. Met with child to discuss social/behavioral issues

Q. Reviewed provider assessment/testing results

R. Reviewed provider notes/memoranda regarding childs service needs/progress

S. Prepared progress notes

T. Prepared summary of provider consultation

U. Prepared summary of parent/guardian consultation

V. Prepared summary of child consultation

W. Prepared other documentation of service treatment/progress

X. Other:

Outcome: (Circle one) A. Progress Satisfactory - Continue IEP until completion date. or

B. Reconvene IEP Team to address change

________________________________ __________________

Signature Date

Menu

https://wveis.k12.wv.us/surveys/mmis.cfm

January 21 to February 15

IDEADiscussion: In order for a public agency to use the Medicaid or other public benefits or insurance program in which a child participates to provide or pay for services required under the Act, the public agency must provide the benefits or insurance program with information from the child's education records (e.g., services provided, length of the services).

IDEAInformation from a child's education records is protected under the Family Educational Rights and Privacy Act of 1974, (FERPA) Under FERPA and section 617(c) of the Act, a child's education records cannot be released to a State Medicaid agency without parental consent, except for a few specified exceptions that do not include the release of education records for insurance billing purposes.

CONSENT TO RELEASE INFORMATION FROM EDUCATIONAL RECORDS FOR MEDICAID BILLING

Students Full Name

The county school district wishes to periodically apply for reimbursement for certain services provided to eligible children during the year by accessing Medicaid or other publicly funded benefits. This access will not result in any decrease in available lifetime coverage or any other insured benefit; will not result in any cost to the child or the childs family; will not increase any premium or lead to the discontinuation of the childs benefits or insurance; and will not create any risk of loss of the childs eligibility for West Virginias Title XIX MR/DD Waiver Program based on aggregate health-related expenditures.

The county school system is providing the following Medicaid covered services to your child:

TYPE OF SERVICE

FREQUENCY

(per week/month/year)

Is the service also provided outside the school system?

Audiology Services

Occupational Therapy Services

Physical Therapy Services

Psychological Services

Speech Therapy Services

Nursing (RN) Specialized Procedures

Personal Care Aide (direct 1:1)

Specialized Transportation (vehicle)

Specialized Transportation (aide)

IEP-Development

(Initial or Annual/Triennial Update)

Care Coordination

One per month

If your child is receiving audiological, occupational therapy, physical therapy, psychological and/or speech services from a provider(s) outside the school system, please list the name of the provider(s) in the box(es) provided so that the school system does not duplicate the outside providers Medicaid billing.

Medicaid reimbursement to districts is authorized by West Virginia Code 18-2-5b, effective March 15, 1990. These funds provide additional financial resources for the countys educational services. Regardless of the status of the consent, the school district will continue to provide your childs IEP services with available federal, state and/or local school district dollars.

I give my consent to release information from my childs educational records for the purpose of Medicaid billing for the duration of services.

Parent Signature: _______________________________________

Childs Medicaid Number: ________________________________

Family Physician (optional): _______________________________________

West Virginia Department of Education

February 2010

http://wvde.state.wv.us/osp/medicaid.html

ASSISTIVE TECHNOLOGY FUNDING Kathy Knighton kknighto@access.k12.wv.usOffice of Special ProgramsWest Virginia Department of Education

What is Assistive Technology? Any item, piece of equipment, or product system, whether acquired commercially or off the shelf, modified, or customized, that is used to maintain, or improve functional capabilities of individuals with disabilities Individuals with Disabilities Education Act (IDEA).

Tremendous potential to promote equity for students with disabilities independent self-confident productive integrated into school and society.

Legal AspectsSchool districts are mandated to make assistive technology available to all students with disabilities if appropriate to receive a free, appropriate public education (FAPE). IEP Team DecisionHome Use Funded by districtProvide devices/services

Consideration of special factors.Assistive technology must be considered for ALL students in the special education process.

Challenges of Delivering Assistive TechnologyLack of InformationCurrent/accurate informationLack of ExpertiseSkills/KnowledgeHigh Rate of Abandonment1/3 abandoned after first yearLack of FundingSignificant barrierInclusion and Lack of Assistive Technology

Implications for Schools PLANNINGSchool districts long range technology and special education plans, procedures, services, and budget include assistive technology.

TRAININGAll staff are able to appropriately consider students for assistive technology services and/or devices.Staff are trained to integrate technology in teaching to help students with disabilities gain skills and achieve higher standards.

INCLUSION Assistive technology is used to support the inclusion of students with disabilities in regular education placements and access to the general curriculum.

FUNDING QUESTIONSARE SCHOOL DISTRICTS REQUIRED TO PAY FOR ASSISTIVE TECHNOLOGY DEVICES AND SERVICES? Yes. District must provide the equipment, services or programs recommended in the IEP. Use federal, state, or local fundsAccess other sources such as Medicaid, Vocational Rehabilitation, and/or private health insurance policies to pay for the devices and services.

CAN SCHOOL DISTRICTS REQUIRE PARENTS TO USE THEIR PRIVATE INSURANCE TO PAY FOR NECESSARY ASSIS5IVE TECHNOLOGY DEVICES AND SERVICES? No. Free in FAPE is extremely significant regarding children with disabilities who may require assistive technology devices or services.As stated in IDEA and its regulations, all aspects of special education and related services must be provided "at no cost to the parents." If family agrees to allow the district to access private insurance Decision must be strictly voluntary.

Funding..CAN FAMILIES BE ASKED TO PURCHASE THE DEVICES OR AUGMENT THE IDENTIFIED ASSISTIVE TECHNOLOGY NEEDS OF THEIR CHILD? Shared responsibility between school, families, employers, and community Parents must agree to Joint funding If family does purchase the AT device, schools cannot mandate that the device be brought to school. Families can insist that another device be provided for school use.

ARE THERE OTHER OPTIONS FOR SCHOOLS TO CONSIDER IN LIEU OF PURCHASING THE ASSISTIVE TECHNOLOGY DEVICE?Yes. Purchase of equipment or devices is not always necessary or even advisable Temporary condition or expected to improve or deteriorateNeed to try-out equipment before purchase for a studentConsider rental or long-term lease - purchase optionsLong-term leasing or lease/ purchase agreements benefits no obligation on behalf of the school to purchase device;reduction of obsolete inventoryuse of equipment without a lump sum purchase; flexible leasing terms; upgrading equipment as more improved technology becomes available; and, upgrading equipment as the student's needs change.

FundingCAN SCHOOL DISTRICTS SHARE THE FUNDING RESPONSIBILITIES OF PROVIDING ASSISTIVE TECHNOLOGY DEVICES AND SERVICES? YES. Transitioning from WV Birth to Three programs to public school preschool programsTransitioning from public school to adult services through Rehabilitation ServicesOwnership of the device is an important issue to consider by IEP Teams

DO SCHOOL DISTRICTS HAVE THE RESPONSIBILITY TO PAY FOR AN INDEPENDENT EDUCATION EVALUATION (IEE) REGARDING ASSISTIVE TECHNOLOGY? YES. Parent has right to an IEE at public expense if the parent disagrees with an evaluation obtained by the public agency. Requirements in WV Policy 2419: Regulations for the Education of Exceptional Students.

ARE SCHOOL DISTRICTS RESPONSIBLE FOR CUSTOMIZATION, MAINTENANCE, REPAIR AND REPLACEMENT OF ASSISTIVE TECHNOLOGY DEVICES? YES. If family owned AT is used by the school, on the IEP, and is necessary for providing Free Appropriate Public Education (FAPE)District responsible for maintenance, repair, and re-placement

ASSISTIVE TECHNOLOGY SUPPLEMENTAL FUNDING GRANT

PURPOSE OF SUPPLEMENTAL FUNDING GRANTResource when unanticipated costly assistive technology device and/or service for a specific student with a disability and other funding sources are not available. Reimbursement for assistive technology devices and/or services is contingent upon an approved application with corresponding required documentation and funding availability. Responsibility of district to purchase AT immediately after identified.Districts required to ensure that AT is provided regardless of any funding opportunities from the Office of Special Programs. PRIORITIES OF SUPPLEMENTAL FUNDING GRANTNewly identified students with costly assistive technology needs as determined by an IEP team. Not students who have previously been identified and should have been receiving assistive technology devices and/or services.

GRANT REQUIREMENTSAPPLICATION FOR INDIVIDUAL STUDENT MUST:Provide student specific informationIdentify students specific assistive technology need(s)Include a copy of the students IEP that documents the need for the assistive technology services and/or devicesInclude an invoice(s) for the assistive technology device(s) or service(s)Include specific Assurance Statements signed by the county superintendent and the special. education director

Please Note: Requests from districts who have expired state and/or federal grant awards with unencumbered amounts and/or who have been required to return unencumbered special education funds are not eligible to apply for these supplemental funds.

Applications should be mailed to: Kathy Knighton, Office of Special Programs 1900 Kanawha Boulevard East Building 6, Room 304 Charleston, West Virginia 2530.

CAMP GIZMO 2011Assistive Technology Summer CampParents, professionals and students learn how assistive technology can help young children (0-8) with significant and multiple developmental needs

WV Schools for the Deaf and Blind CampusRomney, WV July 9-14 Lodging/meals providedRegistration (website)

Professional Development Opportunities

WV FUNDING RESOURCES

WV DEPARTMENT OF EDUCATION (WVDE) OFFICE OF SPECIAL PROGRAMS Kathy Knighton kknighto@access.k12.wv.us Annette Carey acarey@access.k12.wv.us Ruth Ann King raking@access.k12.wv.usValerie Wilson vwilson@access.k12.wv.us

WV Birth to Three Program (WVDHHR) Contact: Pam Roush, (304) 558-6311, 1-800-642-9704

WV Early Childhood Resource Lending Library (ECRLL) 1-800-642-9704 http://cedwvu.org/resources/library.php

West Virginia Assistive Technology System (WVATS) (888) 829-9426 http://wvats.cedwvu.org/

West Virginia Division of Rehabilitation Services (304) 776-4702 http://www.wvdrs.org

THANK-YOU!!!!!*

Five-Year Online Strategic PlanSpecial Education Component

Annual Application for IDEA, Part B and Preschooland State Aid for Exceptional Children2011-2012

State Performance PlanAnnual Performance ReportSPP/APR Evaluates the states efforts to implement the requirements and purposes of IDEA 2004 and describes how the state will improve implementationFive Year Online Strategic Plan Special Education Component/Annual Desk Audit Evaluates the LEAs efforts to implement the requirements/purposes and describes how the LEA will improve implementation

Results Indicators Targets Set by StateGraduationDropoutAssessment participation and proficiencySuspension Educational Environments Ages 6-21Educational Environments Ages 3-5Early Childhood Outcomes Parent Involvement Postsecondary outcomes within one year

Compliance Indicators Targets Set by OSEPDisproportionality by race/ethnicity all disabilitiesDisproportionality by disabilityInitial evaluations within timelinesC to B transition at age 3IEPs with transition requirementsGeneral supervision noncompliances

Leverage PointPlace in the system where force can be applied

The bottom line of systems thinking is leverage seeing where actions and changes in structures can lead to significant, enduring improvements Peter SengeLeverage Ratio of change in input to change in output

13 - IEP with adequate goals and transition servicesAn appropriate goal for the system

Access to the gen. Ed. curriculumInstructional ModelsRTI and PBIS

TimelineJune 1, 2011 Applications and County Budgets dueCounty budget populates plan after submissionJuly 1, 2011 Begin issuing grant awards Failure to respond to needed corrections may result in monitoring issues

When to useFunds may not be obligated prior to July 1 or the date a substantially approvable application is submitted, whichever is last.50% of grant award amount is available July 1 for obligation; 50% available in October (comes as one grant award). All funds must be obligated by September 30, 2012Spend IDEA FY 10 carry over, including IDEA ARRA, and FY 11 IDEA first

Five Year Online Plan Special Education ComponentA plan within the County Mission and Core PlanAnnually updated and submitted June 1Data analysis disaggregated and supplemented for students with exceptionalitiesTypically one goal for students with exceptionalities.Objectives can target the specific areas for improvement Professional development, actions and expenditures implement goal/objectivesMust meet compliance requirements to receive state and IDEA funding

Priority Strategic IssuesWhat are your priority strategic issues (e.g. areas of leverage you will target to improve outcomes)?How did you determine your priority strategic issues?How does logic modeling/root cause analysis contribute to this process?

Five Year Online Strategic PlanFive YearPlan Committee Special Ed Director is memberData AnalysisAchievement on previous WESTEST2 and APTADropout, graduationCSADA/ADA findings and needsOther monitoring report corrective actionsGoals/Objectives/Actions

Special Education ComponentsGoals/Objectives/ActivitiesEnter a special education goal or attach Action Step to an existing plan goalA separate special education goal clearly communicates the special education section of the plan and facilitates OSP review. Objectives: Write a measurable objective for priority strategic issues for SWD.Should link to measurements within Data Analysis section

Professional Development PlanProfessional Development Plan activities are no longer goal-specificUse the screen provided to enter all PD activitiesCheck the Special Education boxProvide all information:Date (month/year at minimum)TopicTarget audience (special educators; general educators learning to work with special ed students or implement special ed policy)Mode of deliveryFunding source (include use of funds here or in subtasks; e.g. stipends, substitutes, trainers)

Action StepsWRITE or SELECT an ACTION STEP FOR GOAL Subtasks clarify specific activities within the Action StepCheck boxes indicate the applicable plan components for the Action Step. Step may serve more than one purpose (e.g. IDEA, Title I), but must clearly describe how funds will be used to benefit students with disabilities (or gifted)

Action Step/SubtasksSpecify the activity being funded and source of funds (IDEA B, IDEA Preschool, State aid); specify it is for students with disabilities, if it isnt obviousPersonnel FTE and type of position (e.g. multicategorical sp. ed teacher, speech language pathologist, teacher of autism, instructional aide) WVEIS budget includes FTE and program/function code for the specific type of teacher

Action Step/Subtasks Services Describe the contracted services to be provided (e.g. physical therapy/occupational therapy; speech)Includes tuition for students placed out of state by DHHR/Courts (state aid)Budget program/function codes specific to the type of service will identify it in the WVEIS budget

Action Step/Subtasks Materials/supplies/equipmentBe specific; describe what will be purchased and for whomBreak down large amounts into specific types, Examples: Supplemental materials Wilson ReadingTechnology hardware- computers for SWDGeneral supplies for special ed classrooms

Action Step/Subtasks Itemize Equipment $5,000 or over in Compliances Equipment section Budget object codes, specify supplemental materials, software, hardware, general suppliesFor IDEA preschool funds, program/function should be specific to preschool (e.g. 21282)For IDEA school ages funds used for general supplies and materials, multicategorical code is permitted (21210)

Action Step/SubtasksCoordinated Early Intervening Services include Action Step/Subtask, then describe in full in the Early Intervening Section under CompliancesBudget program function codes will begin with 1xxxx to indicate this is a general education expenditure

Action Step/SubtasksServices to Students Parentally Placed in Private Schools Required for Proportionate ShareSubtasks specify the services provided to implement service plansMay include expenditures for professional development for teachers to work with private school students with disabilitiesMay include materials/supplies/equipment to implement service plansAll items remain in control of the public schools and are returned to public schools when no longer needed to provide services to SWDBudget program/function code 5xxxx allows tracking of required expenditures

Action Step/SubtasksFacilitiesIf funds are spent on facilities/construction, must include detailed plan under the Compliances sectionOtherExpenditures not included in other steps (e.g., indirect, travel, CSADA teams)Indirect amount is provided by OSEP (Budget code 7xxxx)

Five Year Online Strategic PlanCompliances LEA - Special EducationGuidanceAllocationsPrivate SchoolsExcess costsMaintenance of Effort (MOE)Early Intervening (CEIS)EquipmentConstruction

CompliancesAllocations Must updatePrivate Schools Calculation of proportionate amount for students parentally placed in private schools must check NO box if district has no students or enter number; must enter updated child count numbersExcess Costs Review and provide assuranceMOE Maintenance of effort currently compares two most recently available prior years expenditures; Complete local only calculation, if needed to show MOE. MOE Line 13 Must enter FY12 state/local budgetCoordinated Early Intervening Services as applicableEquipment ($5000 or more requires permission)Construction (requires permission)

AllocationsPress the SELECT button to select all the FY12 allocations.If Coordinated Early Intervening Services will be budgeted, enter amount in the box provided and UPDATE.

Private SchoolsDistricts must annually update the plan for spending a proportionate share of IDEA funds on students parentally placed in private schools through consultation with representatives of private schools to address use of ARRA funds.IDEA funds must be expendedCan provide services and equipment/materials for implementing students service plansCant give funds or property to private schoolsAfter a carry-over period of one year, LEA may apply to transfer unexpended funds

Private SchoolsDistrict maintains the count of eligible students (not just those receiving services)District enters count into the boxes in the Compliances - LEA-Private Schools screen and Updates to calculate the FY12 required amountThese amounts (school age and preschool) must be included in the budget under program/function code 5xxxx.

Other DocumentationUpdate consultation with representatives of private schools and representatives of parents of students parentally placed in private schoolsMaintain documentation of consultation (no need to submit to OSP for FY12).Will be submitted if transfer of funds is requested at end of carry-over year

Excess CostExcess costs are those costs for the education of an elementary school or secondary school student with a disability that are in excess of the average annual per student expenditure in an LEA during the preceding school year for an elementary or secondary school student.

CSBO reviews information in Excess Cost screen pulled from WVEIS for accuracy in calculating the districts excess cost

Supplement, Not Supplant,No Particular Cost Test 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, either in total or per capita, then the Part B funds are supplementing those local, or state and local, expenditures and the LEA has met its MOE and supplement/not supplant requirements.

Maintenance of Effort AlertMany districts are failing to maintain effortTo be eligible for plan approval and to receive a grant award for FY 12, the LEA must submit a FY12 LEA budget that assures MOE will be metMedicaid funds spent for students with disabilities are not counted as local funds for MOE (CFO reports to WVDE and codes Medicaid revenues and expenditures in WVEIS for FY11)Use of Medicaid funds for special education provides flexibility year to year without affecting MOE

Special Ed Director and CSBO and Superintendent Ensure MOEThis is the eligibility test based on expenditures pulled from the WVEIS financial management system from the most recent year compared to the LEA-provided budget amount. COMPLIANCE is met through actual to actual expenditure comparison. If compliance is not met, the LEA must pay back the difference in non-federal funds.

REPAYMENT

Four Tests to Meet MOEAn LEA needs to only meet ONE of the following comparison tests:Local & State expenditures in total for SWDLocal Only expenditures for SWDThe per student capita amount of Local & State expenditures) for SWDThe per student capita amount of Local Only expenditures for SWDFirst must budget adequate amount; then must spend

Reduction in Maintenance of Effort (MOE) Reporting for FY10If the LEA was approved for Reduction in MOE based on increase in federal funds for FY10, expenditure of the freed-up funds will be verified through the online Project Financial Reports (00087).Amount of reduction will equal the amount expended for expenditures allowable under ESEA, up to the maximum allowable amount.The required amount to meet MOE for FY12 will be calculated by subtracting 00087 funds and Medicaid expended for SWD (00083) from the FY10 expenditures. Amount is reported to OSEP in a new Section 618 report

MOE Allowable Reasons to Reduce MOE The voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel (paid with state funds and replaced with less costly personnel or not replaced)A decrease in the enrollment of children with disabilities (for the years in question)The termination of the obligation of the agency, consistent with Part B, to provide a program of special education to a particular child with a disability that is an exceptionally costly program

MOE Explanation of ReductionThe termination of costly expenditures for long-term purchases, such as the acquisition of equipment or the construction of school facilities 5. The assumption of cost by the high cost fund operated by the SEA under 34 CFR 300.704(c).

Coordinated Early Intervening Services (CEIS)Services for students in K-12 who are not identified as students with disabilities and who need additional academic and behavior supports to remain in the general education environmentMust define and identify which students are the recipients of CEIS and track them for two years to document non-eligible or eligible status. WVDE will provide tracking protocol.

CEIS May Include:professional development in research-based academic and behavioral interventions including literacy instruction and adaptive/instructional softwareevaluation, services and supports including literacy instruction the WVDE defines literacy as reading, math and writing

CEISCEIS amount is calculated on IDEA, Part B (School Age and Preschool) allocationFunds expended may come from IDEA, Part B only or include PreschoolAmount and number of students served and identified is reported to OSEP in a new Section 618 report

Coordinated Early Intervening Services ReportAdd a Column to Report 2010-11Also Reported in WVEIS

2007-20082008-20092009-20102010-2011Number of students without disabilities who received coordinated EISNumber of students without disabilities reported above who were Initially referred and found eligible as students with disabilities (within two years).

CEIS Plan SectionNeed for programEntrance criteria definition of student needing additional academic and/or behavior supportDescribe program, interventions, professional development, curriculum/materials, targeted subject, schools, gradesProgress monitoring and exit criteriaHow funds will be spent

Budget SpreadsheetExcel spreadsheet updated for FY12 e-mail to Sandra McQuain to assist in review of WVEIS budget, or send alternative if availableWVEIS budget FTEs, program/function and object codes must be specific and match activities described in the subtasksUse WVDE Chart of Accounts for codes

BudgetSubmitted budget from WVEIS will populate the Budgets LEA Special Education tab in the planWork with your Chief School Business Official to get it right the first time Grant awards will not be forwarded until WVEIS budget is accurate

Chart of Accountshttp://wvde.state.wv.us/finance/Revisions needed must be made after July 1 through the budget revision processGrant awards will not be forwarded until the needed changes are approved by OSP.

Sections/Program Codes Across IDEA, ARRA and State AidChart of Accounts July 1, 2009Program/function codes:2xxxx- Special Education Services (Public)1xxxx - Coordinated Early Intervening Services5xxxx - Services for Students with Disabilities Parentally Placed in Private Schools Project Codes - (43) will identify IDEA funds00Y87 MOE reduction funds00Y83 Medicaid funds

Printing and SubmissionWhen you are finished, go to Printing/Submission Special EducationClick the pdf, review it.SubmitPlan sends e-mail to Sandra McQuainWhen plan is evaluated, a checklist is posted in the plan and an e-mail to you is generated. Go to this screen to see the required revisions. Plan maintains copies of the pdfs.

Budget Revisions

Expenditure of IDEA funds should align with the special education online plan that is submitted to the SEA and approved for use of funding and subsequent approved budget revisions.A cumulative deviation from the purpose as outlined in the online plan in excess of 10% of the total award amount must be supported by an approved budget revision request.

Budget RevisionsFollow process outlined in OSP budget revision memo Must submit both required WVDE formsSpecial education director signs WVDE 11-20-13 formCSBO attaches budget journal entry and submits via e-mailed pdfSend to jehay@access.k12.wv.usOSP reviews and CSBO will receive an e-mail with approval or required corrections.

QuestionsOSP Fiscal Resources Web Pagehttp://wvde.state.wv.us/osp/FY11StrategicPlan.html

Sandra McQuain, Ed. D. Office of Special Programs(304) 558-2696smcquain@access.k12.wv.us

Janice HayOffice of Internal Operations(304) 957-9833, ext. 53423 jehay@access.k12.wv.us

The purposes of the Individuals with Disabilities Education Act are to:

Ensure that all children with disabilities have available to them a free appropriate public education which emphasizes special education and related services designed to meet their unique needs;Ensure that the rights of children with disabilities and their parents or guardians are protected;Assist States, localities, educational service agencies and Federal agencies to provide for the education of all children with disabilities; andAssess and ensure the effectiveness of efforts to educational children with disabilities.*************We have reviewed the components of RTI used in this presentation. Now lets look at a visual representation that illustrates a possible RTI framework and focuses on the services provided to students. This illustration is a triangle. The base of the triangle, which is red, comprises the largest section and is labeled core instruction. The top section is blue and is labeled increasingly intensive instructional interventions. Within the larger triangle, there is a narrow green triangle that runs from the base of the triangle to the tip and is labeled Services for Students with IEPs. The arrow to the right of the triangle illustrates the increasing level of student need and intervention.

In this conceptual framework for RTI, the large triangle represents a continuum of services that a student may receive. It is important to note that this framework illustrates the type of instruction and interventions that are provided. One student could receive instruction and interventions in both levels. All students must have access to core instruction, denoted in red at the base of the triangle. As previously noted, core instruction includes whole-group and small-group instruction (such as reading groups). Most students require little more than high-quality core instruction to be academically successful; however, a small number of students will require more supports.

As we move up the triangle, two events are occurring: First, the interventions are becoming increasingly intensive. Second, as the interventions become increasingly intensive, there is a corresponding decrease in the number of students who need to be served.

In the top of the triangle, denoted in blue, are various interventions that are provided to a subset of students who are identified as needing additional supports in order to meet State academic achievement standards. These interventions may vary in intensity, meaning that they may vary in terms of the teacher-student ratio, length of session, frequency, and duration of the intervention. Children with disabilities may receive services in all areas of the triangle as evidenced by the narrow green triangle. LEP students may also receive services in all areas of the triangle. ***As defined for this presentation, progress monitoring is the fourth component of RTI and is used to make instructional decisions based on a students response to research-based interventions. Progress monitoring is a critical component of RTI because it allows a comparison between a students performance and his or her learning goals. Progress is measured by comparing expected and actual rates of learning. Progress monitoring occurs frequently during the course of an intervention to determine if the student is responding to the intervention. Progress monitoring is an allowable use of Title I, Title III and CEIS funds when it is used to determine the response to an intervention that is supportable with these funds. *Another option that has been provided to States is the opportunity to use a maximum amount of its discretionary monies to establish a fund to support counties with high need students.

In accordance with this requirement, States choosing to exercise this option

must develop a plan, that includes a definition of a high need student based upon input from LEAs

and develop a funding mechanism

and schedule of distribution.,

WV has developed such a plan, has disseminated it across the state and the memo and corresponding application are on the OSE website

*****LEAs can meet this eligibility requirement by passing one of four tests of funding.

Test #1 is a comparison of State and Local actual expenditures from last year compared to what is budgeted for state and local expenditures this year.

Test #2 is a comparison of the amount that was transferred from Fund 10 to Fund 27 last year compared to what is budgeted as a transfer this year.

Test #3 is a comparison of state and local costs broken out per pupil, based on last years Child Count, compared to that same test using this years budgeted amounts.

Test #4 is a comparison of the Fund 10 transfer costs broken out per pupil, based on last years Child Count, compared to that same test using this years budgeted amounts.

The LEA only needs to meet one of the four tests to have made eligibility. The LEA could fail tests 1, 3, or 4, but if the LEA meets test 2, then MOE eligibility and eventually compliance, have been met.

*******What - Audits of States, Local Governments, and Non-Profit OrganizationsWho auditorsWhy Stipulates an auditees responsibilities and what federal programs are audited. Not all programs are audited.

**This is what the auditors use to formulate their audit plan. Their audit plan are the steps they will perform to conduct their audit. They are not program experts so they have to use this supplement in order to conduct audits of federal programs.

**Activities Allowed or Unallowed - Most of guidance will come from Circular A-87 and IDEA regulations. Also may be limited by purpose stated on grant agreement (grants issued to district by WVDE for substitutes, professional development, etc.)Allowable Costs/Cost Principles - Includes time and effort record.Cash Management Cash Management Improvement Act of 1990 will hear referred to as the three-day rule. Provides for the efficient transfer of federal financial assistance between the federal government and the states and establishes procedures to minimize the time elapsing between the transfer of funds from the one entity to another. US Treasury to State State to District District to Vendor. Requires remittance of interest earned in excess of $100 per year, and must be remitted on a quarterly basis.Davis-Bacon Act Deals with prevailing wage rates to laborers and mechanics-generally not applicable to IDEA CFDAsEligibility Specifies the criteria for determining whether subrecipients can participate generally not applicable to IDEA CFDAsEquipment and Real Property Management Must use, manage, and dispose of equipment acquired under a Federal grant in accordance with State laws and procedures and applicable federal regulations.Matching, Level of Effort, Earmarking includes maintenance of effort, high cost fund, CEIS fundsPeriod of Availability of Federal FundsProcurement and Suspension and Debarment-All purchases with federal funds must follow established policies and procedures which must include any clauses required by governing federal regulations. Further, non-federal entitles are prohibited from contracting with or making subawards to parties that are suspended or debarred.Program Income not applicableReal Property Acquisition not applicableReporting applies to financial and child count reportingSubrecipient Monitoring State responsible for monitoring the districts use of awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the district administers the award in compliance with laws and regulations.Special Tests/Provisions Participation of Private School Children, Charter Schools, School wide Programs**Employees salaries and wages may be assigned to federal grants initially based on budgets or other estimated distribution percentages and should produce reasonable approximations of the actual employee time distributions that are subsequently reported. When estimates are used, districts must compare actual costs based on monthly time and effort reported to the estimates used for coding payroll expenditures. This much occur at least quarterly.

If the comparison shows that the difference of the time reported and actual payroll expenditures is greater than 10 percent, then the district must do two (2) things.

First, the county must adjust the accounting records/expenditures to reflect costs of the actual time reported.Second, in order to minimize future differences, the estimated distributions used to charge payroll for the following quarter must be changed to reflect the reported actual distributions of the previous quarter.*Be sure to monitor budget and expenditures and submit a request for a revision, if required, in order to make changes and have time to obligate funds before end of obligation period. Will distribute memo/policy and discuss later if time allows.*A good source available to Directors to review financial records. Contains budget for the IDEA grants as well as expenditures.*****The Medicare Catastrophic Coverage Act changed the section of the Soc. Sec. Act to provide that Medicaid would pay for services provided by the education system to children with IEPs.Each county school district was enrolled by WV Medicaid as a group provider and individual treatment providers for Audiology, Speech, PT, OT, Private Duty Nursing, and Psychology were enrolled if they met Medicaid qualifications.Each county school district was given a second group provider for a group of services that are cost-based for treatment planning, care coordination, personal care aide, and transportation (aide and vehicle).

*THIS IS THE FEDERAL DEFINITION OF ASSISTIVE TECHNOLOGY ACCORDING TO THE INDIVIDUALS WITH DISABILITIES EDUCATION ACT IT IS THE RESPONSIBILITY OF THE IEP COMMITTEE TO DETERMINE THE ASSISTIVE TECHNOLOGY DEVICES OR SERVICES THAT MAY BE NECESSARY FOR A STUDENT WITYH A DISABILITY TO RECEIVE FAPE.IF THE IEP TEAM DETERMINES THAT ASSISTIVE TECHNOLOGY IS NEEDED - IT IS THE RESPONSIBILITY OF THE SCHOOL DISTRICT TO PROVIDE IT. OUR PURPOSE TODAY IS NOT TO DELVE IN TO THE LEGAL ASPECTS OF TECHNOLOGY, BUT TO GIVE YOU A BRIEF OVERFVEW OF ASSISTIVE TECHNOLOGY AND HOW IT CAN BE USED IN THE CLASSROOM WITH ALL STUDENTS. *IDEA is very clear about the responsibility of the school district

Home use big issue

AT must be considered for ALL children going through special ed process and checked on the IEP*As a result of legislation and the districts obligation there are several implication for school districts. ****

***LEAs can meet this eligibility requirement by passing one of four tests of funding.

Test #1 is a comparison of State and Local actual expenditures from last year compared to what is budgeted for state and local expenditures this year.

Test #2 is a comparison of the amount that was transferred from Fund 10 to Fund 27 last year compared to what is budgeted as a transfer this year.

Test #3 is a comparison of state and local costs broken out per pupil, based on last years Child Coun