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Office of Superintendent of Public Instruction
2009
OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments,
Codified in 2 CFR Section 225
PurposeProvides principles and standards for
determining costs for federal awardsGrantsCost reimbursement contractsOther agreements with state and local
governments and federally recognized Indian tribal governments
3
Attachment ADefinitionsBasic Guidelines
Factors affecting allowabilityReasonable costsAllocable costsApplicable credits
Classification of CostsDirect and Indirect Costs
4
Basic Guidelines—Allowability of CostsTo be allowable a cost must:
Be necessary and reasonable for proper and efficient performance and administration of federal awards
Be allocable to federal awardsBe authorized and not prohibitedConform to any limitations in the circular Be consistent and applied consistently (capital
assets, direct vs. indirect cost, etc.)
5
Basic Guidelines—Allowability of CostsAllowable if:
Follows generally accepted accounting principles
Not be used to meet cost sharing or matching of another federal award
Is net of all applicable creditsIs adequately documented
6
Basic Guidelines—Reasonable CostsPrudent Person Test
Ordinary and necessary for operation or performance of federal award
Follows sound business practices; arms length bargaining; follows laws/regulations federal terms
Market price for comparable goods and services
Administered with prudenceNo significant deviations; consistent with non-
federal7
Basic Guidelines—Allocable CostsBenefits the programIndirect costs
8
Attachment B
9
AccountingAllowable
Cost to establish and maintain accounting and other information system
10
AdvertisingAllowable
Recruitment of personnelProcurement of goods and servicesDisposal of surplus materials (unless
reimbursed at standard rate)For specific purposes necessary to
requirements of federal award
11
Public RelationsAllowable
Specifically required by federal award (only as direct cost)
Communicate specific activities or accomplishments from performance of federal award to public or press (direct cost)
Necessary to liaison with news media-limited to keeping public informed on federal notices, contracts, grant awards, financial matters
12
Public RelationsUnallowable
All other advertising and public relationsCosts of conventions, meetings or other events
Costs of displays, demonstrations, exhibits Costs of meeting rooms, hospitality suites, etc. Salaries and wages of employees engaged in setting
up and displaying exhibits, making demonstrations, providing briefs
Promotional items (models, gifts, souvenirs) Costs of advertising and PR designed to solely
promote governmental unit
13
Advisory CouncilsAllowable
As direct cost if authorized by federal awarding agency
As indirect cost where allocable to federal awards
14
Alcoholic BeveragesUnallowable!!!
15
Audit ServicesAllowable
If performed in accordance with Single Audit Act (and OMB Circular A-133).
Percentage of costs charged to federal awards for single audit may not exceed percentage derived by diving federal funds expended by total funds expended by recipient during fiscal year. Exceed only if appropriate documentation of higher costs
Other audit costs must be preapproved or part of indirect cost allocation plan or rate.
16
Electronic Data ProcessingAllowable
But see Equipment
17
Bad DebtsUnallowable
Unless specifically provided for in federal program award regulations.
18
Bonding CostsAllowable
Costs of bonding employees and officials if in accordance with sound business practice.
19
BudgetingAllowable
Costs for development, preparation, presentation and execution of the budget.
20
CommunicationsAllowable
Costs of telephone, mail, messenger, etc.
21
Compensation for Personal ServicesAllowable
If follow time and effort requirements and documentation.
Are reasonable for services rendered and conform to established policy of district consistently applied to both federal and non-federal employees.
Hired in accordance with district rules and meets merit system or other federal requirements.
22
ContingenciesUnallowable
Contributions to contingency reserve for events which cannot be predicted.
AllowableSelf-insurance reserve.Pension plan reserves.Post retirement health and other benefits
computed with acceptable actuarial cost method.
23
Contributions and DonationsUnallowable
All contributions and donations, including cash, property, and services by governmental units to others, regardless of recipient.
24
Defense and Prosecution of Criminal and Civil Proceedings and ClaimsUnallowable
Costs incurred in defense of any civil or criminal fraud.
Costs incurred by a contractor in connection with any criminal, civil or administrative proceedings commenced by the United States or a state.
Legal expenses for prosecution of claims against the federal government.
AllowableLegal expenses required to administer federal
program.
25
Depreciation and Use AllowancesAllowable
Use one or the other, not both for asset class.Follow district policy and GAAP.
UnallowableLand.Buildings or equipment purchased or donated
by federal government or used as part of match.
See Circular for additional guidance
26
Disbursing ServiceAllowable
Cost of disbursing funds.
27
Employee Morale, Health and Welfare CostsAllowable
Costs of health, first-aid clinics and/or infirmaries, recreational facilities, employee counseling services, employee information publications, related expenses consistent with district policy.
Income from any of these activities will be offset against expenses.
28
EntertainmentUnallowable
Costs of entertainment, including amusement, diversion and social activities and any costs directly associated with such costs. Examples: tickets to shows or sports events, meals,
lodging, rentals, transportation, gratuities
29
Equipment and Capital ExpendituresAllowable
Through depreciation or use allowances, ORCharged directly.
Includes equipment, replacement equipment, other capital assets and improvements which materially increase the value or useful life of equipmentFederal agencies may waive or delegate
approval.
30
Equipment and Capital ExpendituresEquipment with acquisition cost of less then
$5,000 are considered supplies allowable as direct costs
Change in capitalization levelMay continue to follow use or depreciation or
amortize amount to be written off over period negotiated with cognizant agency (OSPI)
Trade in for replacement equipment may be used to offset cost of new
31
Fines and PenaltiesUnallowable
Unless incurred as a result of compliance with specific provisions of federal award or written instructions by awarding agency authorizing (rare).
32
Fundraising and Investment Management CostsUnallowable
Costs of organized fund raising, including financial campaigns, solicitation of gifts and bequests, and similar expenses incurred to raise capital or obtain contributions.
Costs of investment counsel and staff to enhance income from investments.
AllowableCosts associated with pension, self-
insurance or other funds which include federal participation.
33
Gains and Losses on Disposition of Depreciable Capital AssetsAllowable in year they occur as credits or
charges Limited to difference between amount realized
on property and undepreciated basis.Unallowable
Amount depreciated, amortized, or use allowance.
When property given in exchange as part of the price of similar item.
Losses from failure to maintain insurance.34
Gains and Losses on Disposition of Depreciable Capital AssetsSubstantial relocation of federal awards from
a facility where federal participation to another facility prior to expiration of useful life requires federal approval
Does not usually apply to ED grants
35
General Government ExpensesUnallowable
Salaries and expenses of chief executives (superintendent's office, principal’s office)
Salaries and expenses of school boards whether incurred for purposes of legislation or executive direction
Cost of prosecutorial activities unless authorized by program regulations (rare)
36
Idle Facilities and Idle CapacityUnallowable unless
Necessary to meet fluctuations in workloadWere necessary when acquired (limit 1 year)
Does not usually apply to ED grants
37
Insurance and IndemnificationAllowable
Costs of insurance required, approved or maintained pursuant to the federal award
Costs of other insurance (allocable to program) Follow district policy and sound business practice
Costs due to losses not covered due to nominal deductible insurance coverage if follow sound management practice
Minor losses not covered by insurance which occur in ordinary course of operations
38
Insurance and IndemnificationAllowable
Contributions to reserve for self-insurance programs (including workers compensation, unemployment compensation, and severance pay) subject to: Type of coverage, extent of coverage and rates would
have been allowed has insurance been purchased to cover the risks
Earnings and investment income on reserves credited Contributions to reserves based on sound actuarial
principles and updated at districtst biennially Other (see section 25)
39
Insurance and IndemnificationAllowable (conditions)
Actual claims paid to or on behalf of former or current employees must be allowable in the year of payment Consistent policy followed Allocated as general administrative expense to all
activities of districtInsurance refunds must be credit against costsOnly to extent provided in federal award
40
Insurance and IndemnificationUnallowable
Costs of insurance or contributions to a reserve covering risk of loss of or damage to federal government property unless agency has specifically required or approved.
Actual losses which could have been covered by permissible insurance.
Cost of commercial insurance that protects against costs of contractor for contractor’s defects in materials or workmanship.
41
InterestUnallowable
Costs incurred for interest on borrowed capital or the use of district’s own funds.
AllowableFinancing costs of allowable costs of
building acquisition, construction , reconstruction or remodeling if: Financing from bona fide third party external to
district Assets used in support of federal awards Earnings on debt service reserve and interest offset
42
LobbyingUnallowable!!!
43
Maintenance, Operations and Repairs
Allowable, if:Not prohibited by law.Keeps property in efficient operating condition.Does not add to value or prolong life of
property.Are not included in rental or charges for space.
Costs which add to permanent value or prolong life should be treated as capital expenditures
44
Materials and SuppliesAllowable
Charge actual price after deducting discounts, rebates and allowances.
Stockroom withdrawals at cost.Incoming transportation charges are part of
materials and supplies costs.
45
Memberships, Subscriptions and Professional ActivitiesAllowable
Districts memberships in business, technical, and professional organizations.
District’s subscriptions to business, technical and professional periodicals.
Meetings and conferences where primary purpose is dissemination of technical information (includes meals, transportation, rental of meeting facilities and incidental costs).
Membership in civic and community social organizations with approval of federal agency.
46
Memberships, Subscriptions and Professional ActivitiesUnallowable
Membership in organizations substantially engaged in lobbying.
47
Motor PoolsAllowable
Costs of service organization which provides automobiles to district at mileage or fixed rates and/or provides vehicle maintenance, inspection, and repair services.
48
Pre-Award CostsUnallowable, unless
Necessary to comply with the proposed delivery schedule or period of performance.
Only to extent they would have been allowable if incurred after award date.
Only with written approval of awarding agency.
49
Professional Service CostsAllowable
Professional and consultant services, including retainer fees, by persons or organizations that are members of a particular profession or possess a special skill, if: Reasonable Not contingent upon recovery of costs from the
federal governmentUnallowable
Defense and prosecution of criminal and civil proceedings and claims.
50
Proposal CostsAllowable
Costs to prepare proposals for potential federal awards. Treat as indirect costs unless prior approval of
federal awarding agency
51
Publication and Printing CostsAllowable
Must be reasonable and allocable.
52
Rearrangements and AlterationsAllowable
Ordinary and normal rearrangement and alteration of facilities.
Special arrangements and alterations specified in the federal award or with prior approval.
53
Reconversion CostsAllowable
Restoration or rehabilitation of district’s facilities to approximately same condition immediately prior to federal awards, less costs related to normal wear and tear.
54
Rental CostsAllowable
Must be reasonable.Sale and district back limited to what it would
have cost if district owned the property.Less than arm’s length transactions limited to
amount if district had title to property.Districts must be treated as capital districts
under GAAP (follow FASB Stmt 13).See interest section.
55
TaxesAllowable
If legally required.Gasoline taxes, motor vehicle fees other taxes
which are user fees for benefits to federal program.
UnallowableSelf-assessed taxes and/or policies that
disproportionately affect federal programs.If deemed inappropriate by federal agency.
56
TrainingAllowable
Reasonable for professional development of employees.
57
Travel CostsAllowable
Transportation, lodging subsistence and related items for employees on official business.
May be charged based on actual cost, per diem or combination in accordance with district policy.
Travel costs for general government employees are allowable when specifically related to federal awards.
All charges must be reasonable and not exceed normally allowed costs.
58
Travel CostsUnallowable
Costs in excess of normal costs permitted by district policy (use federal guidance if no district policy).
Commercial airfare must be coach rate or equivalent.
Non-commercial air travel is generally not allowable.
59
Underrecovery of Costs under Federal AgreementsUnallowable
Excess costs over federal contribution of one award are not permitted to be charged to other awards.
60
61
Where is the Requirement?Time and effort reporting is required under
the Federal Office of Management and Budget’s Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments
Attachment B, Selected Items of Cost, Item 11, Compensation for personnel services
62
When is Time and Effort Required?Time and effort reporting is required when
any part of an individual’s salary is charged to a federal program.
Charge may be “direct” or “indirect”.
63
What type of reporting is needed?
Single cost objective →Semi annual certification
Multiple cost objectives →Monthly time reports or Personnel Activity Reports (PARs)
64
What is a cost objective?
Work activities allowable under the terms and conditions of a
funding source
65
What are some examples of a single cost objective?
100% charged to a single federal program activity
Exceptions Title I, Part A and LAP.Federal Special Education and State Special
Education.Schoolwide programs.Multiple activities in a single federal program.
66
What are some examples of multiple cost objectives?
Salary charged to more than one activity in a single federal program
Salary charged partially to federal program and partially to state and/or local sources
Salary charged partially to sources combined into a schoolwide program and partially to those not included
67
What is a semi-annual certification?
Statement individual(s) worked solely on activities related to single cost objective
Completed at districts every six monthsSigned by employee or supervisor with first-
hand knowledge of work performed
68
What is a monthly time report?(PAR)Accounts for total activityPrepared at district monthlySigned by employeeReflects actual work performed (not budget)Agrees to supporting documentation
69
When are adjustments to actual made?
If payroll is initially based on budgeted or estimated time/amounts, payroll and time and effort reports must be compared at districts quarterly
If the difference is 10% or more and any needed adjustments made Payroll records must be adjusted to actual Following quarter’s estimates must be adjusted
70
What time and effort is reported?
Report time actually worked in a specific activity not time budgeted
Budgets are reconciled to actual at districts quarterly
71
Who should sign the reports?
Monthly reports (PARs) should be signed by the employee
Semi annual certifications should be signed by employee or supervisor having first-hand knowledge of work performed
For internal control purposes, districts may require both the employee and supervisor to sign
72
What type of supporting documentation is needed?Documentation is VERY important.
Examples include, but are not limited to:Class schedulesNumber of studentsNumber of minutes
Remember DOCUMENT! DOCUMENT! DOCUMENT!
73
Supplemental Contracts, Stipends, Extra Hours
Primary contract and additional contracts may be considered separately
Based upon whether or not charged to federal programTime and effort may be required for primary
contract but not supplemental (or vice versa).
74
Administrators
Superintendent, assistant superintendent, principal, assistant principal usually not allowable charge to federal programRequires good documentation to support.Could be a supplant issue.
75
Schoolwide ProgramsSchoolwide plan must specify programs
to be included (not all programs may be included)
A schoolwide program is a single cost objectiveIf employee works 100% on programs
combined → Semi annual certification.If employee works partially on programs
combined and partly on those not combined → Monthly time report (PAR).
76
Schoolwide Program
Schoolwide ProgramTitle I, Part A (Disadvantaged)LAPBEALocal FundingTitle IV (Safe/Drug-Free)Title V (Innovative)Most US Dept Ed Programs
except Reading First
Cannot IncludeTransitional BilingualState Special EdReading FirstI-728State Highly Capable
RestrictedMigrantIndian EducationFederal Special Ed
77
What is a substitute system?Other method for determining time and effort
report based on sample of work performedMust be approved by OSPI prior to use
JoLynn Berge is responsible for approvalMust be statistically soundShould be periodically reviewed to determine
if still appropriate
78
For Additional InformationOSPI Bulletin 048-08 (Time and Effort
Reporting)ExamplesSample forms
OSPI Bulletin 046-08 (Combining Funds in Schoolwide Programs)
OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments (2 CFR Section 225)
79
80
Maintenance of Effort
District Requirement
Section 1120A(a) and 9521 of NCLB34 CFR 299.5
81
Maintenance of Effort
The district has maintained fiscal effort if eitherThe combined fiscal effort per student or
The aggregate (total of included) expenditures of the district were at districts 90% of that of the preceding year.
This shows the district maintained its non-federal funding within 90%.
82
Maintenance of Effort“Preceding fiscal year” = the federal fiscal year
or the 12 month fiscal period used for reporting purposes prior to the beginning of the federal fiscal year in which funds become available.
Example: For funds available July 1, 2009Preceding fiscal year is 2003 (SY 2007-2008)Second preceding fiscal year is 2002 (SY 2006-
2007)Third preceding fiscal year is 2001 (SY 2005-2006)
83
Maintenance of EffortExpenditures included for MOE
AdministrationInstructionAttendance and health service personnelPupil transportation servicesOperation and maintenance of buildingFixed chargesNet expenditures to cover deficits for food
services and student body activities
84
Maintenance of EffortExpenditures excluded for MOE
Community servicesCapital outlayDebt serviceSupplemental expenses made pursuant to a
disaster declared by the President of the USAAny expenditures made for funds provided by
the federal government
85
Maintenance of Effort
When a district does not meet the maintenance of effort test its allocation is reduced in the exact proportion by which it fell below 90% (combined fiscal effort per student and aggregate expenditures)
The measure most favorable to the district is used
86
Maintenance of Effort
In determining maintenance of effort for the year following a failure to maintain effort, OSPI considers the district’s expenditures in the year the failure occurred to be 90% of the expenditures for the third preceding year.
OSPI does not use the expenditures for the
year in which the failure occurred.
87
Maintenance of EffortDistrict may apply to the US Department of
Education for a waiver for
Exceptional or uncontrollable circumstances, such as a natural disaster,
orPrecipitous decline in the financial resources of
the district.
88
Supplement Not Supplant
Considers services
Section 1120A(b) and (d) of NCLB
34 CFR 200.79
89
Supplement Not SupplantTargeted Assistance Schools
Title I funds must be used only to supplement the level of funds that would, in the absence of Title I, be available from non federal (state and local) sources for Title I students
The district is not required to provide Title I services using a particular instructional method (i.e. pull out programs, in class, etc.)
Based on services
90
Supplement Not SupplantProgram meets the intent and purposes of a
Title I program in a targeted assistance program if
It serves only children who are failing or most at risk of failing to meet the state’s performance standards.
It provides supplementary services designed to meet the educational needs of the children who are participating in the program.
It uses the state’s assessment system to review the effectiveness of the program.
91
Supplement Not Supplant
Targeted Assistance BuildingsPresumptions of supplanting
The district has used the Title I funds to provide services that the district was required to make available under federal, state or local law.
The district used Title I funds to provide services it provided with non-federal funds in the prior year(s).
The district has used Title I funds to provide services for participating children that it provided with non-federal funds for non-participating children.
Rebuttals may be possible
92
Supplement Not Supplant
Exclusions
The district may exclude supplemental state or local funds expended in any school for programs that meet the intent and purposes of Title I, Part A (e.g., Learning Assistance Program)
93
Supplement Not SupplantSchoolwide Program Schools
Must use Title I funds only to supplement the amount of funds that would, in the absence of Title I funds, be made available for that schoolwide program (including funds needed to provide services required by law for disabled children and LEP children)
Similar to MOE
94
Supplement Not SupplantProgram meets the intent and purposes of Title
I in a schoolwide program if:It is implemented in a school with 40% or more
poverty.
It is designed to promote schoolwide reform and upgrade the entire educational operation of the school.
It is particularly designed to meet the educational needs of at-risk students.
It uses the state’s assessment system to review the effectiveness of the program.
95
ComparabilityBuilding level
Section 1120A(c) and (d)
34 CFR 200.79
OSPI Bulletin 011-04
96
Comparability
A district may receive Title I, Part A funds only if it uses state and local funds to provide services in Title I schools that, taken as a whole, are at district comparable to services provided in non-Title I schools.
97
Comparability
If all schools in the district are Title I schools, the district must use state and local funds to provide services that, taken as a whole, are substantially comparable in each school.
98
Comparability Comparability is met if the district provides
written assurance it has established and implemented
1. A district wide salary schedule2. A policy to ensure equivalence among
schools in teachers, administrators, and other staff
3. A policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies
99
ComparabilityAlternative criteria
The district may meet the comparability requirement if it establishes and implements other measures for determining compliance such as student/teacher rations, student/instructional staff salary ratios or total expenditures per school.Staff salary differentials for years of employment may
not be included in comparability determinations.
The district need not include unpredictable changes in student enrollment or personnel assignments that occur after the beginning of a school year.
100
ComparabilityDocumentation
Report comparability each year on iGrant 361.The district must develop procedures/policies for meeting the comparability requirement and maintain records that are updated at district biennially.
101
ComparabilityExclusions
Bilingual education for children of limited English proficiency (State Transitional Bilingual).
Excess costs of providing services to children with disabilities (State Special Education).
Supplemental state and local funds spent for programs that meet the intent and purposes of Title I, Part A (LAP).
102
Targeted Assistance and Schoolwide Programs
103
Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs
Targeted Assistance Programs target Title I, Part A services to the students at greatest risk of not meeting the state’s student academic achievement standards
Students Pre-K through grade 12 are eligible for Title I, Part A services
104
Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs
Building staff must decide what content areas (Reading, Math, Language Arts, etc.) and grade levels to be served with Title I, Part A funds
Decision based on greatest need
105
Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs
Students in the identified subject areas and grade levels are selected for Title I, part A services based on “…multiple, educationally related, objective criteria established by the local educational agency and supplemented by the school”
This usually means the use of results from standardized tests, parent request, grade level academic performance, teacher and other administrative recommendations, and other discretionary criteria
106
Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs
A composite score can be developed using the test results, classroom performance and teacher recommendations
The students’ names are then rank-ordered, by subject area and grade level, on a list beginning with the most at-risk students
The district and/or building Title I staff then determine how many students can be served based on the amount of Title I, Part A funds that have been allocated to the building
107
Targeted Assistance and Schoolwide Programs
Targeted Assistance Programs
Instructional programs are then developed to meet the academic needs of the most at-risk students
Students who qualify for services can be homeless, migrant, special education students, and former Head Start, Even Start and Early Reading First students who participated in those programs within the past two years
The Title I, Part A staff then must decide whether the services will be delivered via an in-class or pullout model, or a combination of both
108
Pullout and In-Class Instructional Delivery Models
Targeted Assistance Programs
Title I, Part A regulations strongly encourage minimizing the removal of students from the regular classroom to provide Title I, Part A services
Extended learning opportunities (before and after school, Saturday school, summer programs) are also encouraged
109
Targeted Assistance and Schoolwide Programs
Schoolwide Programs
Designed for schools with 40% or higher povertyRequires a year of planningA schoolwide plan, which includes ten (10)
required components, must be completedThe plan must include the names and the dollar
amounts of the federal and state programs that have been combined into the schoolwide program
110
Targeted Assistance and Schoolwide Programs
Schoolwide Programs
The schoolwide program must address the intent and purpose of each of the federal programs that have been included in the program
Schoolwide programs must still meet all requirements relating to health, safety, civil rights, student and family participation and involvement, services to private school children, maintenance of effort, and comparability of services
111
Targeted Assistance and Schoolwide Programs
Schoolwide Programs
Although all students in the schoolwide program are eligible for Title I, Part A services, the students who are at greatest risk of not meeting the state academic achievement standards are the main focus
Annual evaluation of the program/plan effectiveness is required
112
New RegulationsNovember 2008
113
Districts must notify parents of students about public school choice options no later than 14 calendar days before the start of the school year.
[34 CFR 200.37(b)(4)(iv) & 34 CFR 200.44(a)(2)]
NotificationNEW
114
Parent OutreachA district may count in the amount required for choice-
related transportation and SES (20% obligation) the cost for parent outreach and assistance to meet these requirements.
A district may count up to an amount equal to 0.2% of the district’s Title I, Part A allocation (1% of the 20% obligation). Examples of allowable costs include
Parent notices Communication through the media, internet, and
community partners Displaying information on the district’s website Parent fairs
[34 CFR 200.48(a)(2)(iii)(C)
NEW
115
Student informationThe district must prominently display on its
website, in a timely manner:The number of students who were eligible for and the
number of students who participated in public school choice and SES, beginning with data from the 2007-08 school year and each subsequent school year.
For the current school year, a list of SES providers approved by the state to serve the district and the locations where services are provided.
For the current school year, a list of available schools to which students eligible to participate in public school choice may transfer.
[34 CFR 200.39(c)(1)]
NEW
116
Transparency for ParentsFor each district, states must post on their Web sites
The amount of funds available for choice-related transportation and SES as required in §200.48(a)(2) (the 20% obligation).
The per-child amount for SES as calculated under §200.48(c)(1).
States must indicate on the list of approved providers those SES providers that are able to serve students with disabilities or those students are limited English proficient
[§200.47(a)(3)(iii)].
NEW
117
To spend less than the amount needed to meet the 20% obligation, a district must meet, at a minimum, the following criteria:Partner, to the extent practicable, with outside
groups, such as faith-based organizations, other community-based organizations, and business groups, to help inform eligible students and their families of opportunities to transfer or to receive SES [§200.48(d)(2)(i)(A)].
Ensure that eligible students and their parents have a genuine opportunity to sign up to transfer or to obtain SES, including: Providing timely, accurate notice to parents. Ensuring that sign-up forms for SES are distributed directly
to all eligible students and their parents, and are made widely available and accessible through broad means of dissemination, such as the Internet, other media, and communications through public agencies serving eligible students and their families [§200.36 & §200.37].
118
Ensure that eligible students and their parents have a genuine opportunity to sign up to transfer or to obtain SES, including by: Providing a minimum of two enrollment “windows,” at
separate points in the school year, that are of sufficient length to enable parents of eligible students to make informed decisions about requesting SES and selecting a provider [§200.48(d)(2)(i)(B)].
Ensure that eligible SES providers are given equal access to school facilities, using a fair, open and objective process, on the same basis and terms as are available to other groups that seek access to school facilities [§200.48(d)(2)(i)(C)]
119
District Responsibilities to Document and Notify the State
To spend less that the amount needed to meet its 20% obligation, an district must: Maintain records demonstrating that it has met the
criteria in §200.48(d)(2)(ii), and Notify the state that it:
Has met the criteria in §200.48(d)(2)(i); and Intends to spend the remainder of its 20% obligation on
other allowable activities, specifying the amount of that remainder [§200.48(d)(2)(iii)].
NEW
120
Consequences for Non-ComplianceIf a state determines that an district has failed to meet
any of the criteria in §200.48(d)(2)(i), the district must: Spend an amount equal to the remainder of its 20%
obligation in the subsequent year, in addition to its 20% obligation for that year, on choice-related transportation costs, SES, or parent outreach and assistance, or
Meet the criteria and obtain permission from the state before spending less than the required amount in that subsequent school year. The state must confirm the district’s compliance with the criteria before granting such permission [§200.48(d)(4)].
NEW
121
American Recovery and Reinvestment Act (ARRA)
122
Education Stabilization FundsTwo types
Funds that go to the Governor Based on set formula To address shortfall in K-12 and Higher Education Leftover, if any, divided proportionally between
school districts based on proportion of Title I, Part A funding formula Note: These are NOT Title I, Part A funds May be spent on ESEA, IDEA, Perkins, Building
Modernization
123
Education Stabilization FundsFunds that go to the USED
To be distributed as Targeted and EFIG Title I, Part A funds
These ARE Title I, Part A funds Other
School Improvement McKinney-Vento Homeless Education IDEA Early Childhood Educational Technology—Title II, Part D Innovation and Improvement (Teacher Incentive)
124
Education Stabilization FundsOne Time Funding
Give careful thought to efficient and effective use Staffing may not be best use since cannot be
sustained Possible uses
Summer school Professional development activities Additional curriculum Tutoring
30 month availability
125
Education Stabilization FundsConsider pitfalls
Supplement Not SupplantMaintenance of EffortComparabilityCarryoverSustainability
126
Education Stabilization FundsSet asides will apply
Parent involvementProfessional development due to not making
AYPPrivate school equitable share
Set asides may applySupplemental Educational ServicesChoice for public school transportation
127
CPR IssuesTitle I, Part ADistrict Parent Involvement Policy is current
and contains all required componentsBuilding Parent Involvement is current and
contains all required componentsNotice to parents they may request
information regarding professional qualification of student’s classroom teacher
District report card to parentsInstructional paraprofessionals must be under
the direct supervision of a certificated teacher
128
Schoolwide plan must contain all ten components.
Matrix of funding sources Intent and purposes of combined program funds
Targeted Assistance Model
Evidence of eight componentsRank order listEvidence of entrance and exit
129
CPR IssuesLearning Assistance Program (LAP)Eligibility of students.Evidence that only students achieving below
state and district assessments are served.Accelerated student learning plans contain all
four components.Expanded learning opportunities for grades
eight, eleven and twelve.
130
CPR IssuesFiscalMaintenance of Effort
Reconciliation of T/E to budget
Capital Asset PolicySmall and Attractive
ProcurementPersonal Service Contracts(Sole Sourcing)
131
CPR IssuesSet- Aside Compliance
Set-Aside /Earmarks on iGrantsSeparate Sub-codes
Track Expenditures
Ranking of allocations
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iGrant RevisionsTitle I, Part AiGrant Package 201: Title I, Part A (Regular Year)
Request for Substantial Approval: (The following pages only to be completed for SA.)– Complete Page 1 (Request for SA and complete matrix for preliminary budget))– Complete Page 2 (Assurances)– Complete Page 3 (Plan)
Page 2: Program Narrative• Q 1: Types of additional assistance-Summer School box indicated requires
completions iGrant 465)• Q 8: Updated link to N/D facilities• Q 14-15: Change in order of District and Building Parent Involvement policy
questions
Page 3: Set-Aside PageA 3: Update link to N/D FacilitiesE. Schoolwide Programs: Eliminate box
Public School Page:Remove box on profile: Number of years in Schoolwide
133
iGrant RevisionsTitle I, Part A
iGrant Package 244: Title I, Part A (End of Year) Regular Year
Section 1A, 1B, 1C, 1D, 1E: Added in unduplicated count:
Category: Not Identified Category
Section IIIB: Instructional Program-Social Studies deleted
134
iGrant RevisionsTitle I, Part A
iGrant Package 246: Title I, Part A (End of Year) Summer School
Section 1A, 1B, 1C, 1D, 1E: Added in unduplicated count:
Category: Not Identified Category
Section IIB/IIC: Instructional ProgramSocial Studies deleted
Section IIID: Program Staff Data Delete # 7 Other (e.g. volunteers)
135
iGrant RevisionsTitle I, Part A
iGrant Package 246: Title I, Part A (Summer School Program Application)
Page 1: Program DescriptionPage 2: Program Staff data
136
iGrant RevisionsLearning Assistance Program (LAP)
iGrant Package 218: Learning Assistance Program (Regular Year)
Application changes may vary depending on legislative decisions.
iGrant Package 245: Learning Assistance Program
(End of Year) Regular YearSection IB: Student Data: Count for race/ethnicityNot Identified
137
iGrant RevisionsLearning Assistance Program (LAP)
iGrant Package 247: Learning Assistance Program (EOY) Summer School Section IB: Unduplicated count by race/ethnicityAdded Not Identified category
iGrant Package 466: Learning Assistance Program (Summer School Application)Page 1: Program DescriptionPage 2: Program Staff data
138
Questions?????????
139