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Illinois State Board of Education Individuals with Disabilities Education Act (IDEA) Excess Cost: Step-by-Step Completion September - 2016 1

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Page 1: IDEA Excess Cost: Step By Step Completion Webinar PowerPoint

Illinois State Board of Education

Individuals with Disabilities Education Act

(IDEA)

Excess Cost: Step-by-Step Completion

September - 2016

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Each Illinois school district and independent charter school must complete an IDEA excess cost worksheet. The completed worksheets are emailed to the IDEA grant coordinators at the Illinois State Board of Education (ISBE).

The completed worksheet:

• identifies the district’s current year IDEA excess cost threshold

and

• verifies whether the district met the IDEA excess cost established the previous fiscal year.

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IDEA Excess Cost Calculation

The federal excess cost calculation uses expenditures and student populations from the previous fiscal year to determine an average annual per pupil expenditure (APPE). That amount is then multiplied by the current year special education student count to determine the excess cost threshold for the current fiscal year.

The excess cost threshold is the amount of state/local funds that must be expended on students with individualized education programs (IEPs) in that current fiscal year.

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FY17 (July 1, 2016 – June 30 – 2017)

Excess Cost Worksheet Data Sources

FY18 (July 1, 2017 – June 30, 2018)

Excess Cost Worksheet Data Sources

FY19 (July 1, 2018 – June 30, 2019)

Excess Cost Worksheet Data Sources

Data from current (FY17) and prior (FY16) fiscal years

Data from current (FY18) and prior (FY17) fiscal years

Data from current (FY19) and prior (FY18) fiscal years

Expenditure data from the FY16 AFR Expenditure data from the FY17 AFR Expenditure data from FY18 AFR

Total student population count from the prior year – FY16 (October 2015) count provided by ISBE

Total student population count from the prior year – FY17 (October 2016) count provided by ISBE

Total student population count from the prior year – FY18 (October 2017) count provided by ISBE

Special education count from the current year – FY17 (December 2016) Child Count, reports available through I-Star

Special education count from the current year – FY18 (December 2017) Child Count, reports available through I-Star

Special education count from the current year – FY19 (December 2017) Child Count, reports available through I-Star

Special education count from the prior year – FY16 final, verified Child Count provided by ISBE

Special education count from the prior year – FY17 final, verified Child Count provided by ISBE

Special education count from the prior year – FY18 final, verified Child Count provided by ISBE

Excess cost threshold from the prior year (FY16 excess cost worksheet)

Excess cost threshold from the prior year (FY17 excess cost worksheet)

Excess cost threshold from the prior year (FY18 excess cost worksheet)

Excess Cost Data Sources - Fiscal Years • The excess cost calculation and verification check require data sources from the current and

previous fiscal years. • The instructions and worksheet direct users to the correct data sources.

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Excess Cost Check

The IDEA excess cost worksheet also calculates and documents whether the district met the excess cost threshold established the previous fiscal year – Section H, Excess Cost Check.

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34 CFR 300.202 and Appendix A IDEA Excess Cost Worksheet

Calculate the total expenditures from the previous fiscal year

Section A – Use the AFR

Subtract the previous fiscal year’s capital outlay, non-capitalized equipment, and debt services

Section B – Use the AFR Section C – The worksheet calculates the new total

Subtract the previous fiscal year’s expenditures for ESEA Title I & III and special education expenses

Section D – Use the AFR Section E – The worksheet calculates the new total

Calculate the average annual per pupil expenditure by dividing the previous year expenditures by that year’s total population (expenditures ÷ total population = APPE)

Section F – Enter the total student population from the list provided on the IDEA grant webpage, the worksheet calculates the average annual per pupil expenditure (APPE)

Multiply the APPE by the current year’s special education population for the current year’s excess cost threshold

(APPE X current IEP population = excess cost)

Section G – Enter the special education population, the worksheet calculates the excess cost threshold (reports available in iePoint/I-Star). That is the amount of state/local funds the district must expend in the current fiscal year.

Verification Process – 34 CFR 300.202(2)(i) An LEA meets the excess cost requirement if it has spent at least a minimum average amount for the education of its children with disabilities before funds under Part B of the Act are used.

Section H – Enter the previous year’s excess cost threshold (last year’s worksheet) and the final verified special education child count provided on the IDEA grant webpage. The worksheet will calculate to verify whether the district met the excess cost threshold.

IDEA Excess Cost Calculation

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Elementary and Secondary

Districts with kindergarten through grade 12 populations must calculate separately for elementary and secondary IDEA excess cost.

The IDEA excess cost worksheet has separate columns for elementary (K-8) and secondary (9-12) expenditures and student counts. Districts complete the columns that encompass their population.

The excel worksheet will calculate the total for as the elementary and secondary data is entered.

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Separating Elementary and Secondary Costs

Unit districts must use their local records to separate the elementary and secondary expenditures.

Some costs, e.g. elementary and secondary staff salaries/benefits can be clearly separated.

Some expenditures do not have “distinct and separate elementary or secondary costs,” e.g. superintendent salary/benefits, school service personnel serving all grade levels. In those instances, the district may prorate the expenditures.

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PreKindergarten (PreK)

PreK expenditures and students are excluded from the IDEA excess cost calculation. The worksheet includes prompts to exclude PreK.

The IDEA expenditures are specific to the IDEA flow-through grant, not the IDEA preschool grant.

*Exception - Any expenditures for 5-year-old kindergartners with disabilities paid with IDEA preschool funds would be included in the calculation.

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Forms and Resources

The IDEA excess cost worksheet, instructions, and resource materials are located on the IDEA grant webpage.

http://www.isbe.net/spec-ed/html/idea_part-b.htm

The webpage is updated August/September of each year to provide the forms and resources needed to complete the current year IDEA excess cost worksheet.

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Data Sources (1) Annual Financial Report (AFR)

The bulk of the IDEA excess cost calculation and worksheet (Sections A – E) is based on the district’s expenditures.

Districts must use the AFR from the most recent finalized fiscal year to complete the excess cost worksheet, for example:

• FY17 excess cost worksheet – FY16 AFR

• FY18 excess cost worksheet – FY17 AFR

• FY19 excess cost worksheet – FY18 AFR

The AFRs are due by October 15 each year - by that date the district should have the all of the expenditure data needed to complete the excess cost worksheet.

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Data Sources (2) Previous Year Student Counts

• The average annual per pupil expenditures calculation uses the total student population. (Section F)

• The IDEA excess cost check uses the final, verified special education Child Count from the previous year. (Section H)

ISBE provides the student lists on the IDEA grant webpage. Those lists are available when the IDEA excess cost worksheet is released each year.

The student lists are separated by elementary (K-8) and secondary (9-12) and exclude PreK students

The IDEA excess cost worksheet includes a link to the IDEA grant webpage to access the student lists.

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Data Sources (3) Current Year Special Education Population

The determination of the excess cost threshold requires the special education population for the current fiscal year (Section G).

That is the December special education Child Count. The Child Count data, is due to ISBE by December 15. By that date the district should have the final data source needed to determine the IDEA excess cost threshold. Reports for separating the Child Count by elementary and secondary are available through I-Star (iePoint).

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Data Sources (4)

The district must use the completed IDEA excess cost worksheet from the previous year to complete the final section of the worksheet (Section H).

The district will enter the excess cost threshold that it calculated the previous year.

The excess cost worksheet includes a prompt directing the district to the specific line in Section G of the prior year IDEA excess cost worksheet for that year’s excess cost threshold.

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Question

Q. Must a district wait until all data sources are available to complete the IDEA excess cost worksheet? A. No. When the district’s AFR is completed in October the only data source not yet available is the December Child Count. A district could complete the excess cost worksheet in October or November and then just plug in the special education Child Count data in December. The district could then submit the completed IDEA excess cost worksheet to ISBE.

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Completing the Worksheet

http://www.isbe.net/spec-ed/html/idea_part-b.htm • Excel worksheet • Instructions • Student data lists • Technical assistance resources

AFR

I-Star/iePoint

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District Identification Section

Please include: • the district name and number, • the RCDT code, and • contact information (name and phone number)

for the person who completed the IDEA excess cost worksheet.

*Please do not submit any form with just a district number. Illinois has over 800 districts, many with duplicate district numbers. The district name and RCDT code are necessary to identify the correct district. 17

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This is the district identification section for the FY17 IDEA excess cost worksheet. A link to the IDEA grant webpage is also provided so that districts can easily access instructions and student population lists.

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Section A – Total Expenditures

Section A identifies/collects expenditures from the AFR.

The IDEA excess cost instructions and prompts in the excel worksheet will direct users to the correct locations in the AFR.

The instructions and prompts also remind districts to exclude expenditures for the PreK population.

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Section A collects the total AFR expenditures from five areas. The worksheet directs the district to the specific AFR lines and columns where the expenditure totals are located. Districts with PreK populations must exclude the PreK expenditures. A district may not have expenditures for all lines (e.g. Tort), in such cases, either enter a zero (0) or leave the line blank.

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Here is an example from the FY16 AFR that is used to complete the FY17 excess cost worksheet. Line 114, column K(900) is the Educational Fund total. That amount, minus any PreK expenses, is used to complete the Educational Fund line of the excess cost worksheet.

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Districts with PreK populations must subtract the PreK expenditures from the line totals for Section A of the IDEA excess cost worksheet.

This page shows where some PreK expenditures are located in the Educational Fund section of the AFR.

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Section B – Gen. Ed. Capital Outlay, Non-capitalized Equipment, and Debt

Section B identifies/collects the capital outlay, non-capitalized equipment, and debt services expenditures so that those expenditures can be subtracted from the total expenditures.

The IDEA excess cost instructions and prompts in the excel worksheet will direct users to the correct locations in the AFR. The worksheet also directs users to exclude:

• Title I, Title III, and special education costs

• PreK costs

A district may not have expenditures for all lines, in such cases, either enter a zero (0) or leave the line blank.

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Section B collects the general education capital outlay, non-capitalized equipment and debt service expenditures. Those costs are subtracted from the district’s total expenditures. To make certain that no expenditures are subtracted twice, districts are directed to exclude Title I, Title III, and special education expenditures from Section B.

The district must exclude PreK expenditures.

A district may not have expenditures for all lines, in such cases, either enter a zero (0) or leave the line blank.

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Question

Q. Why does Section B require the district to subtract Title I, Title III, and special education costs?

A. The federal calculation subtracts costs for capital outlay, non-capitalized equipment, debt service, and special populations (Title I & III and students with IEPs).

The IDEA excess cost worksheet collects the capital outlay/non-cap. equipment/debt expenditures in Section B and the special populations expenditures in Section D. Removing the special populations expenditures from Section B prevents a district from subtracting those same costs again in Section D.

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The capital outlay costs are in column G(500) and the non-capitalized equipment costs are in column I(700). This page shows where some special education and Title I & III capital outlay and non-capitalized equipment costs could be located.

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The Debt Service total is two lines above the Total Direct Disbursements/Expenditures for each expenditure section of the AFR. The debt service expenditures are in column H(600) – other objects. It is possible that a district will not have any debt service expenditures for Title I, Title III, or special education.

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Section C – Total Expenditures Less Cap. Outlay, Non-Cap. Equipment, and Debt.

Section C subtracts the general education capital outlay, non-capitalized equipment, and debt service from the total expenditures.

Section A – Section B = Section C

As data is entered in sections A and B the excel worksheet will complete the calculation and enter that amount in Section C.

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Total expenditures are entered in Section A. General education capital outlay, non-capitalized equipment, and debt service expenditures are entered in Section B. The excel worksheet subtracts Section A from Section B in Section C. (A – B = C).

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Section D – ESEA: IDEA and Title I/III

Section D identifies/collects special education and Title I & III expenditures so that those “special population” expenditures can be subtracted from the total.

Placement of these expenditures in the AFR can vary from district to district. The excel worksheet prompts districts to enter the expenditures and note the location in the AFR (i.e. list the AFR lines and columns where the expenditures are located).

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This slide shows possible ways to document the AFR locations of the special populations expenditures in Section D of the IDEA excess cost worksheet.

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Question

Q. Is entering the AFR locations in Section D optional or required?

A. Entering the AFR locations in Section D is required. The IDEA excess cost worksheets will be returned to the district if the AFR data is not included in Section D.

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Section D – ESEA: IDEA and Title (cont.)

Section D has two subsections: • ESEA IDEA & Title Expenditures and • All Other Special Education Expenditures.

Districts may not have expenditures for each line. However, ALL districts will have some expenditures for “other” special education costs. Those are the state and local funds spent on students with IEPs.

Districts should account for all costs, but only claim each cost one time in Section D, e.g. if a cost is paid with IDEA funds, do not duplicate that cost in the second subsection (All Other Special Ed. Costs).

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Question Q. The AFR does not separate special education expenditures as federal, state, or local. How do districts make that separation for Section D of the IDEA excess cost worksheet?

A. Districts should use local fiscal records, including IDEA expenditure claims/reimbursement to separate the special education expenditures as either IDEA (federal) or state/local in Section D.

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IDEA and Title I/III Expenditures Districts may not have expenditures for all of the Section D lines.

• ALL districts will have some Other Special Education Expenditures (i.e. local special education costs).

• Most districts will have IDEA Part B expenditures. A few member districts of special education cooperatives do not have IDEA subgrants and therefore do not have any IDEA expenditures in the district AFR.

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Question

Q. May a district use the special education transportation claim as a data source for state/local special education costs in Section D.

A. Yes, however, the district must:

• ensure that the elementary and secondary costs are not duplicated in another line of Section D

and

• note the transportation claim as a data source on the transportation line of Section D.

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Special Education Transportation

A district using the state transportation claim to complete the transportation line of Section D must ensure that no costs are duplicated.

IDEA expenditures aren’t included in state transportation claims, so any IDEA transportation expenditures wouldn’t be duplicated in Section D.

State transportation claims do include the PreK population, so districts would need to subtract those expenditures.

The transportation claims can include salaries/benefits, payments to other districts, etc. Districts must ensure that none of those special education costs are duplicated in Section D. 37

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Districts using the Transportation Claim must exclude PreK costs and ensure that costs are not duplicated in Section D of the excess cost worksheet. For example, do not include salaries/benefits in both the Educational Fund line and the Transportation Fund line of Section D.

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Districts can note the AFR lines where the transportation costs are located. Districts can note that the transportation claim was used for the expenditures.

Excluding PreK

Excluding PreK

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Section E – Adjusted Total Expenditures less Special Populations

Section E subtracts the special education and Title I & III expenditures from the total expenditures.

Section C – Section D = Section E

As data is entered in sections C and D, the excel worksheet will complete the calculation and enter that amount in Section E.

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The special populations expenditures in Section D are subtracted from the running total in Section C. The worksheet enters that adjusted total in Section E.

(C – D = E)

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Section F – Average Annual Per Pupil Expenditure

Section F uses the prior year total student data to

calculate the average annual per pupil expenditure.

The district must enter the total student population, separating elementary and secondary. The Total Student Enrollment for all districts is provided on the IDEA grant webpage.

When the student enrollment is entered, the excel worksheet will calculate and enter the APPE.

Expenditures÷ Total Student Enrollment = APPE

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When the prior year total student enrollment is entered in Section F, the worksheet will use that student count and the expenditures amount (Section E) to calculate the APPE.

(expenditures ÷ total population = APPE) The worksheet prompts the district to the use the link at the top of the page to access the Total Student Enrollment list on the IDEA grant webpage.

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Districts must use the student enrollment data provided on the IDEA grant webpage. The student lists are separated by elementary and secondary. ISBE excludes the PreK students from the count.

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Section G – (Excess Cost) Minimum District Must Expend Per

Pupil With Disabilities

Section G completes the final calculation for the district’s

current year excess cost threshold.

The district must enter the current year December special

education Child Count, separating elementary and secondary.

When the special education student count is entered,

the excel worksheet will calculate the excess cost. The total

in Section G is the excess cost threshold for the current

fiscal/school year. The district must expend at least that

amount of local (state/local) funds on students with

individualized education programs (IEPs) during that current

fiscal year.

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Section G –APPE and Current Year Excess Cost Threshold When the current year special education population (# of students with IEPs) is entered in the worksheet, Section G will calculate the average annual per pupil expenditure AND the excess cost threshold for the current fiscal year. The Harrisburg Project provides a tool to report the Child Count by elementary and secondary. That tool is available in I-Star/iePoint. Districts should go to Reports Release and select Reports for IDEA Excess Cost Worksheet.

The excess cost threshold is the amount of local (state/local) funds the district must expend in the current fiscal year for special education and related services.

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Section H – Excess Cost Check Section H calculates whether the district met the excess cost threshold identified the previous year.

1. The district must enter the final, verified child count data from the previous year (ISBE provides that data) and the excess cost amount from the previous excess cost worksheet.

2. As the data are entered in the excess cost worksheet, the worksheet will calculate the amount expended on special education in the previous year.

3. The worksheet will calculate the difference in the two amounts (actual costs – prior year excess cost threshold). 47

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Districts must use the Student with IEPs data provided on the IDEA grant webpage. The student lists are separated by elementary and secondary. ISBE excludes the PreK students from the count.

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Section H – Excess Cost Check The Excess Cost Check is a comparison of the excess cost threshold calculated in the prior fiscal year (last year’s excess cost worksheet) and the spending reported in the current excess cost worksheet. The worksheet prompts the district to: • use the link at the top of the worksheet to access the Students with IEPs list (final, verified

Child Count) on the IDEA grant webpage and • enter the excess cost threshold from the prior year excess cost worksheet.

The final amount in Section H verifies whether or not the district met the IDEA excess cost threshold established the prior year. Any district that did not meet the excess cost threshold should contact its IDEA grant coordinator.

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Question Q. What if the Excess Cost Check has a negative comparison?

A. A negative amount in Section H indicates that the district did not meet the IDEA excess cost threshold. Any unresolved negative comparison would result in repayment of the federal shortfall with local funds. If the district has a negative comparison:

• double check for typos, incorrect entries, and

• contact an IDEA grant coordinator for assistance in identifying and resolving the negative comparison.

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Submitting the Worksheet

The IDEA excess cost worksheets are submitted via email to the IDEA grant coordinators.

The IDEA excess cost worksheets can be submitted as early as December 1 and no later than the last working day of January.

Any supporting documentation should be maintained at the local level as part of the fiscal record.

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Record Retention

The IDEA excess cost worksheets are part of the district’s IDEA records.

• Subject to audits

• Must be retained for a minimum of three years

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Contact Information

IDEA Grant Coordinators

Tammy Greco – [email protected]

Felicia Malloy – [email protected]

Division of Special Education Services

(217)782-5589

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