Individuals with Disabilities Education Act (IDEA) and

#iasboAC18May 3 – 4, 2018, Schaumburg, IL

Individuals with Disabilities

Education Act (IDEA)

and

Maintenance of Effort

(MOE)

IASBO Annual Conference – May 4, 2018

1


Introductions

2

Cinda Pembroke: ModeratorBusiness Manager, [email protected]

Leyden Area Special Education Cooperative

Colleen Wronski : SpeakerBusiness Manager, [email protected]

Lincoln-Way Area Special Education District #843

Mihaela Miller : SpeakerBusiness Services Coordinator, [email protected]

Northern Suburban Special Education District

mailto:[email protected]



CLUES

Error on the page

A Attachment

Do you know the answer?


4

IDEA COMPLIANCE CYCLEMid March

MOE Compliance Sheets released

5/31 Last day for IDEA amendments

6/30 Last day of grant period

7/1 IDEA application due – start of period

8/31 last day for grants extension

by 7/1 MOE Exceptions due for

IDEA approval

1/31 Excess Cost

due


5

IDEA ELIGIBILITY

REQUIREMENTS

ASSURANCES

EXCESS COST MOE


6

ASSURANCES


7

IDEA ELIGIBILITY

REQUIREMENTS

ASSURANCES

EXCESS COST MOE


BEFORE accessing federal funds

EXCESS COST REQUIREMENT8


9

MOE EXCESS COST

What is the cost to

educate a gen edstudent


10

IDEA ELIGIBILITY

REQUIREMENTS

ASSURANCES

EXCESS COST MOE


C

11

MOE COMPONENTS

ELIGIBILITY AND COMPLIANCE


• Will you comply this year?

MOE Excess Cost FY18

• Did you comply last year?

MOE Compliance

FY18

• Have you budgeted to comply next year?

MOE Eligibility FY19

PAST PRESENT FUTURE

12


13

What Does MOE Really

Mean?

The LEA must maintain

State/Local effort of at least the

SAME LEVEL

of expenditures for the education

of children with disabilities from

ONE FISCAL YEAR to the NEXT.


Enhance Replace

Supplement v. Supplant

14


15

Information is pulled from the

District’s AFR (that was filed with

ISBE).

https://www.isbe.net/Documents/

moe-afr-ref-sheet-17.pdf

MOE DATA SHEET

A

B


16

FOUR OPTIONS TO MEET MOE

State

Local

Current Year

State

Local

Previous Year

OPTION I


17

OPTION II

State

Local

Current Year

State

Local

Previous Year

Per capitaPer capita


18

OPTION III

State

Local

Current Year

State

Local

Previous Year


19

OPTION IV

State

Local

Current Year

State

Local

Previous Year

Per capitaPer capita


20

FAILURE TO MEET MOE

Can NOT be paid with federal funds


21

HANDLING EXCEPTIONS


22

FOUR EXCEPTIONS to MOE

• Voluntary Departure of Special Education Staff

• Decrease in Enrollment of Children with IEPs

• Termination of a Costly Obligation for a Specific

Child

• Termination of a Costly Long-Term Purchase


STAFF RELATED examples

Retired staff

sal and fringe

$80,000

New staff sal

and fringe

$50,000

Lower MOE

by $30,000

Retired staff

sal and fringe

$80,000

Retired staff

not replaced

$0.00

Lower MOE

by $80,000

Riff staff

sal and fringe

$80,000

MOE can not

be lowered

23

The voluntary departure, by retirement or otherwise,

or departure for just cause, of special education or

related services personnel.

staff not

replaced

$0.00


24

STAFF RELATED not allowable

Reduction in force (RIF)

Layoffs

Eliminating

positions

Dismissal

District/LEA not renewing contract


STUDENT RELATED example

MOE - Base Year

Total $100,000 Child Count 50per capita

$2,000

Not Acceptable

Total $75,000

Child Count 40

Per capita $1,875

Acceptable

Total $85,000

Child Count 40

Per capita $2,125

25

A decrease in the enrollment of children with IEPs,

including graduating or leaving the jurisdiction students


No longer obligated to provide an exceptionally

expensive program to specific student(s).

26

STUDENT RELATED example

Student Cost

$150,000

Residential

program

$120,000

Lower MOE

by $30,000

Student Cost

$150,000

IEP Nurse

Change

$70,000

Lower MOE

by $70,000

Student Cost

$150,000

Non IEP

services

change

MOE can not

be lowered


Termination of costly expenditures for long

term purchases (capital outlay)

Loan for

special

education bus

$20,000

Loan paid offLower MOE

by $20,000

27

Costly Purchase example


AFR misreported expenditures or revenues

(Must have revised MOE District Worksheet with

auditor letter of verification)

LEA is on Cash Accounting and IDEA

payments are reported correctly based on cash

but they distort MOE

28

LEA OVERALL COSTS allowable


District letter

Exception to Maintenance of Effort if

applicable

Auditor letter if applicable

Revised Maintenance of Effort if applicable

29

EXCEPTION PACKET

D

E

G

F


Be consistent with special education

expenditures

MINDING MOE

30

H Begin with the end in mind – mirror the

AFR and update it every quarter

Document potential exceptions to MOE

throughout the year

B Use the AFR reference sheet https://www.isbe.net/Documents/moe-afr-ref-sheet-17.pdf


31

SPOT the PROBLEMSH


Questions and AnswersWe thank you for your time!

32


GET HELP

33

Special Education Services: (217) 782-5589

IDEA GRANT COORDINATORS

Tammy Greco [email protected]

Felicia Malloy [email protected]

MOE PART TIME CONSULTANT

Pam Jurkoshek [email protected]

ISBE CONTACT INFORMATION





PRESENTERS:

MODERATOR INFO:

Cinda PembrokeBusiness Manager, [email protected]

Leyden Area Special Education Cooperative

PANELISTS INFO:

Colleen WronskiBusiness Manager, [email protected]

Lincoln-Way Area Special Education District #843

Mihaela MillerBusiness Services Coordinator, [email protected]

Northern Suburban Special Education District

34





Based on state and local expenditures not

revenues

Local ONLY option must have auditable data

Four tests to meet MOE

Five allowable exceptions

35

MOE RECAP

https://www.isbe.net/Pages/IDEA-Part-B-Grant-Program-Information.aspx


WHAT NEXT?

Give MOE 1 hour every quarter.

You will be a step ahead!

36

xxxxxxxxxxxxxxxxxxxxx

Attachment A

xxxxxxxxxxxxxxxxxxxxx

Annual Financial Report Lines

SPECIAL EDUCATION EXPENDITURES1000 Instruction (Special Education Programs) 8, 9, 22, 23, 211, 2122110 Attendance & Social Work Services 36, 226

2120 Guidance Services 37, 227

2130 Health Services 38, 228

2140 Psychological Services 39, 229

2150 Speech Pathology & Audiology Services 40, 2302210 Improvement of Instruction Services 44, 234

2220 Educational Media Services 45, 235

2230 Assessment & Testing Services 46, 236

2310 Board of Education Services 49, 239

2320 Executive Administration Services 50, 240

2330 Service Area Administration Services 51, 2412410 Office of Principal Services 55, 253

2510 Direction of Business Support Services 59, 122, 257

2520 Fiscal Services 60, 2582540 Operation and Maintenance of Plant Services 61, 124, 260, 338

2550 Special Education Pupil Transportation Pupil Transportation & Claim Reimbursement Report

2570 Internal Services 64, 263

2600 Support Services - Central 72, 271

4000 Payments for Special Education Program 79, 86, 94, 133, 183, 276, 300

FEDERAL FUNDS REVENUE 4600 IDEA Preschool Flow-Through 218

4620 IDEA Flow-Through 220

districts use only highlighted functions

cooperatives use any expenditure functions as verified by afr

Annual Financial Report (AFR) Lines

AFR REFERENCE SHEET

Used to Detemine

Maintenance of Effort (MOE)

Functions

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Attachment B

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May 1, 2018

Ms. Catherine Lauria Chief School Business Official West Northfield District 31 3131 Techny Road Northbrook, IL 60062

Ms. Lauria:

Per the 34 CFR 300.203(b), each LEA’s eligibility to use IDEA funds is contingent upon verification that the LEA

budgets local or state/local funds, for the education of children with disabilities, in the current grant period at least

the same total or per capita amount as was expended in the last fiscal year for which records are available (up to 2

years prior). Each stand-along district or member of a special education cooperative must document in the IDEA grant

application MOE eligibility for the fiscal year. All districts should maintain their MOE eligibility documentation at the

local level with their grant records. MOE eligibility is considered met when a district meets one of four MOE criteria

OR meets MOE eligibility exceptions.

As you project next year’s special education expenditures please select one of the MOE Eligibility Criteria

options as compared to the most recent AFR:

The current year’s state and local budgeted expenditures are greater than the previously expended state

and local actual expenditures.

The current year’s local budgeted expenditures are greater than the previously expended local actual

expenditures.

The current year’s state and local per capita budgeted costs are greater than the previously expended state

and local per capita actual costs.

The current year’s local per capita budgeted costs are greater than the previously expended local per capita

actual costs

None apply, but the district meets MOE eligibility through allowable MOE exceptions:

If you checked the box above, please also circle one of the following, whichever applies:

1. The voluntary departure, by retirement or otherwise, or departure for just cause, of special

education or related services personnel.

2. The Termination of obligation of the agency, consistent with this part, to provide a program of

special education to a particular child with a disability that is an exceptionally costly program, as

determined by the SEA, because the child:

A. Has left the jurisdiction of the agency;

B. Has reached the age at which the obligation of the agency to provide Free and Appropriate

Public Education (FAPE) to the child has terminated; or

C. No longer needs the program of special education

3. The termination of costly expenditures for long-term purchases, such as acquisition of equipment

or the construction of school facilities.

_____________________________________________________ ________________________________________ Ms. Catherine Lauria Date

Please return signed form to

[email protected] by June 15th 2018.

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Attachment C

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Maintenance of Effort

FY13-FY14

Our district’s special education expenditures decreased in the 2013-2014 school

year compared to the 2012-2013 school year due to a large number of graduations.

Some students placed in tuition-based programs last year were placed in district-

run programs this school year. Also, one student moved out of state.

In addition to student changes, we had a staff member who retired as well as two

members who left and were replaced with less experienced staff.

Below is student information related to the above mentioned circumstances:

Student Name Program Notes

Student name 1 School 1 Graduated

Student name 2 School 1 Returned to district

Student name 3 School 2 Returned to district

Student name 4 NSSED ELS Graduated



Student name 7 NSSED NSAE Graduated



Student name 10 NSSED ECP Moved out of state

During the 2012-2013 school year, there were a total of 86 students served by our District

in tuition-based placements and 10 fewer students being served the 2013-2014 school year.

The LEA may reduce the level of expenditures below the level of the preceding fiscal year if the reduction is attributable to any of the following. Provide

specific details and dollar amounts. If the total justifications equal/exceed the MOE shortfall, fiscal effort has been maintained for the reporting year.

The voluntary departure, by retirement, resignation, or departure for just cause, of special education

or related services personnel. (Does not include contract non-renewal, reassignment or staff lay-off due to RIF.)

reason for leaving

Sally Jay Special Area Admin Retired not replaced

Kevin Land Teacher Moved Kristin Moon

Sarah Lee Teacher Moved Michael Long

subtotals subtotals

total

The termination of the obligation to provide an exceptionally costly special education program to a

child with a disability (child leaves the district, ages out, graduates, or no longer needs the program due

to an IEP change. (Identify student initials, reason(s) expenditures are no longer needed, previous placement,

and whether the previous cost was for tuition, transportation, aide or specify other.)

student tuition transport aide other

C V Graduated School 1

B E Returned to district School 1

C B Returned to district School 2

L G Graduated NSSED ELS 33,382.00

M M Graduated NSSED ELS 33,382.00

E W Graduated NSSED ELS 33,382.00 32,516.00

B B Graduated NSSED NSAE 48,925.00

M P Graduated NSSED NSAE 48,925.00

M L Graduated NSSED NSAE 48,925.00

M L Moved out of state NSSED ECP 45,644.00

total

The termination of costly expenditures for long-term purchases, such as the acquisition of equipment

or the construction of school facilities (purchased previous year with individual cost of at least $1,000).

total

Total

Allowable Exceptions to Maintenance of Effort

48,925.0$

45,644.0$

509,517$

353,699.00$

Region-County-District-Type (RCDT)

Telephone Number

District Name

Name of Person Completing Report

salary & benefits

395,125$

130,125$

75,000$

33,382.0$

65,898.0$

48,925.0$

48,925.0$

EXCEPTIONS TO MAINTENANCE OF EFFORT Federal IDEA Regulations 34 CFR §§ 300.204 & 300.205

2013 - 2014

salary & benefits replacement nameemployee name position

33,382.0$

184,436$

Maintenance of Effort Shortfall from Worksheet

-$

-$

-$

210,689$

184,436$

325,081$

totalreason services not needed previous placement

72,189$

95,000$ 84,250$

LEA is prepared to justify from audited AFRs and other sources maintained on file at the LEA, the information reported on this form. July 2014

325,081.0$

-$

costdate purchaseddescription of expenditure

-$

ISBE Use Only

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The voluntary departure, by retirement, resignation, or for just cause, of special education or related services personn(paid with State and/or Local funds.) (Does not include contract non-renewal, reassignment or staff lay-off due to RIF.

reason for leaving salary & benefits

subtotals subtotals -$

total -$ The termination of the obligation to provide an exceptionally costly special education program to a child with a disabilit

(paid with State and/or Local funds) (Child leaves the district, ages out, graduates, or no longer needs the program due to an IEP changestudent (initials) tuition $ transport $ *aide $ **other $ total $

*name of aide --**other-- total -$

The termination of costly expenditures for long-term purchases, such as the acquisition of equipment or the constructioof school facilities (paid with State and/or Local funds.)(Unit cost must be at least $5,000--attach copy of invoice.)

unit cost

total -$

-$

LEA is prepared to justify from audited AFRs and other sources maintained on file at the LEA, the information reported on this form. July 2018

-$

date(s) purchaseddescription of expenditures

ISBE Use Only

Exceptions to Maintenance of EffortFederal IDEA Regulations 34 CFR §§ 300.204 & 300.205

2016-2017 (FY 2019)

salary & benefits replacement name

Maintenance of Effort Shortfall from MOE Worksheet

employee name position

Region-County-District-Type (RCDT)

Telephone Number

District Name

Name of Person Completing Report

-$

to any of the following reasons. If the total of allowable exceptions equals or exceeds the MOE shortfall, fiscal effort has been maintained. The level of State and/or Local expenditures may be reduced below the level of the preceding fiscal year only if the reduction is attributable

-$

Total Allowable Exceptions

to Maintenance of Effort

-$

name of previous year placementreason services not needed current year

-$

A

Memo To: Illinois State Board of Education/Northern Suburban Special Education District

Cc: Business Manager Name

From: Auditor name

Date:

Subject: 20_ _ -20_ _ MOE calculation

The following outlines items that were miscoded on the AFR and the adjustment necessary to correct the report:

The am ount of $187,081 has been deducted fr om Line 2 – Fu nction 1000 (Instruction). This is due to salary and benefits for certain administrators allocated to Function 1200 which belong in Function 2190. Also this am ount contain cash i n lieu of benefi ts for adm inistrators a llocated to Function 1200 wh ich belo ng in Functions 2190 and 2210).

The am ount of $3 39,315 has been add ed to Li ne 2 – Fu nction 1 000 (I nstruction). This is due to certain medical and dental expenses not being allocated to fu nctions properly.

The amount o f $24,346 has been adde d to Line 3 – F unction 2140 (Psychological Services). T his is due to certain m edical and de ntal expenses not allocated to functions properly.

The amount of $444,000 has been added to Line 4 – Function 2150 (Special Education Tuition/Svcs). This is due to COOP invoices being paid out of the regular ed line.

We have verified the accuracy of the revisi ons to the 20 _ _-20_ _ Maintenance of Effort Worksheet amounts to be correct. Please let me know if you have any questions or need additional information.

Auditor

Audit Firm

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AUDIT FIRM LETTER HEAD

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December 1, 2013 December 1, 2014

1. Total special education pupils enrolled

SPECIAL EDUCATION EXPENDITURES

Function

2. 1000 Instruction (Special Education Programs) 918,580.00$

3. 2140 Psychological Services 133,371.00$

4. 2150 Speech Pathology & Audiology Services 81,970.00$

5. 2330 Special Area Admininstration Services 218,975.00$

6. 2550 Special Education Pupil Transportation -$

7. 4000 Payments for Special Education Programs 203,831.00$

8. Other -$

9. TOTAL SPECIAL EDUCATION EXPENDITURES 1,556,727.00$

FEDERAL FUNDS REVENUEFunction

10. 4620 IDEA Flow-Through 57,847.00$

11. 4600 IDEA Preschool Flow-Through -$

12. TOTAL FEDERAL FUNDS REVENUE 57,847.00$

SPECIAL EDUCATION NET EXPENDITURES Per Capita

13. 1,498,880.00$

(line 9 minus (-) line 12) 19,722.11$

14. Previous Year Special Education Net Expenditures 1,486,421.00$

20,935.51$

15. Comparison of Current to Previous Year Special 12,459.00$

Education Net Expenditures (line 13 minus (-) line 14) (1,213.40)$

Revisions to the preprinted MOE District Worksheet must be submitted with an auditor's letter verifying the figures reported on this form.

District must be prepared to justify, from an audited Annual Financial Report (AFR) and other sources, the information reported on this form. July 2016

Current Year Special Education Net Expenditures

71 76

ILLINOIS STATE BOARD OF EDUCATIONDivision of Special Education Services

100 North First StreetSpringfield, Illinois 62777-0001

Maintenance of Effort District Worksheet (Revised)

Region-County-District-Type (RCDT) District Telephone NumberContact Person

July 1, 2014 through June 30, 2015

FY15 MOE Compliance

FY16 MOE Compliance

FY17 MOE Compliance

FY18 MOE Compliance

FY19 MOE

Compliance

FY19 IDEA

Eligibility

IDEA 2015-2016 IDEA 2016-2017 IDEA 2017-2018 IDEA 2018-2019 IDEA 2018-2019 IDEA 2018-2019 IDEA

Uses FY14 AFR FY15 AFR FY16 AFR FY17 AFR FY18 Projections FY19 BudgetCompared to FY13 AFR FY14 AFR FY15 AFR FY16 AFR FY17 AFR FY17 AFR

iStar Child Count as of December 1st of 2013 2014 2015 2016 2017 2017A Number of Special Ed Students 91 96 85 80 83

B EXPENDITURES

1200 Instruction Special Ed 1,559,530 1,620,224 1,681,005 1,345,335 1,345,335 2140 Psychological Services 16,148 101,481 111,862 115,781 115,781 2150 Speech Pathology 186,012 139,598 162,186 170,162 170,162 2330 Special Area Admin Svcs. 123,102 126,888 130,913 134,303 134,303 2550 Special Ed Pupil Transportation 59,145 64,032 102,978 92,087 92,087 4120 Special Education Tuition/Svcs. 691,368 710,158 604,117 828,531 828,531

Total Special Education Exp 2,635,305 2,762,381 2,793,061 2,686,199 2,686,199 - C REVENUES

4620 IDEA 113,527 73,542 112,609 112,873 108,180 4600 IDEA PRE-K 1,560 549 1,023 1,184 791 4857 ARRA4856 ARRA PRE-SCHOOL

Total Offsetting Revenue 115,087 74,091 113,632 114,057 108,971 -

NET EXPENDITURES 2,520,218 2,688,290 2,679,429 2,572,142 2,577,228 -

Current to Previous SP ED Net Exp 25,779 168,072 (8,861) (107,287) 5,086 (2,572,142)

Per Cap 27,695 28,003 31,523 32151.775 31,051 #DIV/0!

Current to Previous SP ED Per Cap 6,004 308 3,520 629 (1,101) #DIV/0!