Managing Federal Funds

Edmund Moore

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Partnership in practiceThe following behaviors illustrate the three kinds of partnership:

CooperationEffectively communicate and:

• reach out in a helpful way.• actively respond in a helpful way.• assist and share.• follow through.

CoordinationEffectively communicate, cooperate, and:

• build intentional relationships.• plan efforts and create synergy.• produce action and collectively implement plans.• collectively review and report results.

CollaborationEffectively communicate, cooperate, coordinate, and:

• equally and jointly work together intentionally and spontaneously.• have intertwined layers of peer interaction.• have opportunities for continuous dialogue and deliberation.• provide information supported by facts, data, and scientifically based research.• objectively inquire and critique, leading to new understandings and solutions.• strategically plan and measure expected outcomes, progress, and results at the

highest professional levels and within relevant legal requirements.Adapted from Hale & Rodin (in press)

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Title I 2012 Final Amount

2013 Final Amount

2014 Amount

Basic Grant 101,880,809 102,880,416

Concentration Grant 23,647,077 23,196,806

Targeted Grant 47,045,339 49,381,048

EFIG Grant 52,855,830 55,572,730

Total 225,429,055 231,031,000 215,102,204

(15,928,796)

-6.89

%

School Improvement (4%) 9,017,162 9,241,240 8,604,088 (637,152) -6.89

%

State Administration (1%) 2,101,426 2,147,277 2,151,022 3,745 0.17%

State Academic Achievement Awards Program

0 280,097 0

Flow Thru 214,310,467 219,362,386 204,347,094

(15,015,292)

-6.84

%

State Carryover – Title I, Part A 1,025,000.00 250,000.00

State Carryover – Title I, Part D 170,000.00 0

Total 215,335,467.00

219,612,386.00

*Section 1004 of ESEA provides that if the sum of the amount allocated to all States under Title I, Part A, Part C, and Part D, Subpart 1 exceeds $14,000,000,000 an SEA may not reserve more than one percent of the amount the State would receive if $14,000,000,000 had been allocated among States under those parts.

Allocation based on $14,000,000,000214,727,735Administration (not to exceed 1%) 2,147,277

Needs Assessment Coordinate with other members of

LEA Use comprehensive data Results should reflect the needs of

the system and should be prioritized

Collaboration should drive how funds can be best leveraged to meet the needs in the best possible way

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Title I – 15%

Title II – 5%

Title III – 2%

Title VI – 5%

Administrative Costs

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The LEA should work collaboratively with a team during the planning and budgeting process

Develop goals, strategies and detailed action steps based on needs

Identify allowable funds to support the goals, strategies and action steps

All expenditures must be in compliance with all federal regulations and guidance (NCLB, EDGAR, GAAP, etc.)

Resources are a finite amount and should be used wisely and in accordance with allowable uses

LEA should not have isolated decision-making.

Planning and Budgeting

THE PYRAMID OF

FEDERAL RULES

Statutes

Regulations and OMB Circulars

Non-Regulatory Guidance

Letters and Press Releases Issued by ED

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STATUTES

Statutes dictate:

• How funds are generated• How funds must be allocated• Who is eligible to be served• How the program must be designed• What uses of funds are permissible• What types of reports or evaluations are required

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Examples of Statutes

• ESEA- Elementary and Secondary

Education Act • NCLB- No Child Left Behind • IDEA- Individuals with Disabilities

Education Act

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REGULATIONS

Examples: • EDGAR-Education Department

General Administrative Regulations • OMB –Office of Management and

Budget - Circulars A-87 & A-133

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PURPOSE OF NON-REGULATORY

GUIDANCE• Non-Regulatory Guidance is used

by the Education Department to provide informal advice to grantees and sub- grantees regarding education requirements.

• Guidance does not carry the “force of law.”

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Letters and PRESS RELEASES

ISSUED by the USDOE

The USDOE uses “Dear Colleague” letters and press releases to notify states and districts about policy changes or clarifications regarding federal law.

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Title I – Allowable Uses of Funds

• Instructional Materials and Supplies• Equipment• Personnel• Before and After School Programs• Summer School• Preschool• Professional Development• Parent Involvement• Technology

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Title I Targeted Assistance Programs

• Title I funds in a targeted assistance programs may only be used to benefit targeted assistance (TA) students (as identified on the eligibility list).

• Supplement not supplant applies. Therefore, the TA students must receive additional services from Title I.

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Title II Uses of Funds(NCLB Section 2123)

A local educational agency that receives a subgrant under section 2121 shall use the funds made

available through the subgrant to carry out one or more of the following activities:

• (1) Developing and implementing mechanisms to assist schools in effectively recruiting and retaining highly qualified teachers, including specialists in core academic subjects, principals, and pupil services personnel, except that funds made available under this paragraph may be used for pupil services personnel

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• (2) Developing and implementing initiatives to assist in recruiting highly qualified teachers (particularly initiatives that have proven effective in retaining highly qualified teachers), and hiring highly qualified teachers, who will be assigned teaching positions within their fields

• (3) Providing professional development activities that improve the knowledge of teachers and principals and, in appropriate cases, paraprofessionals

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• (4) Developing and implementing initiatives to promote retention of highly qualified teachers and principals, particularly within elementary schools and secondary schools with a high percentage of low-achieving students

• (5) Carrying out programs and activities that are designed to improve the quality of the teacher force

• (6) Carrying out professional development activities designed to improve the quality of principals and superintendents, including the development and support of academies to help talented aspiring or current principals and superintendents become outstanding managers and educational leaders.

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• (7) Hiring highly qualified teachers, including teachers who become highly qualified through State and local alternative routes to certification, and special education teachers, in order to reduce class size, particularly in the early grades.

• (8) Carrying out teacher advancement initiatives that promote professional growth and emphasize multiple career paths (such as paths to becoming a career teacher, mentor teacher, or exemplary teacher) and pay differentiation.

• (10) Carrying out programs and activities related to exemplary teachers.

*NCLB does not have a (9)

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Title II eGAP Budget Details

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Title III Purpose of Subgrants(NCLB Section 3115)

A State educational agency may make a subgrant to an eligible entity from funds received by the agency under this subpart only if the entity agrees to expend the funds to improve the education of limited English proficient children, by assisting the children to learn English and meet challenging State academic content and student academic achievement standards. In carrying out activities with such funds, the entity shall use approaches and methodologies based on scientifically based research on teaching limited English proficient children and immigrant children and youth.

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Title III Required Activities - An eligible entity receiving funds under section 3114(a) shall use the funds

• (1) to increase the English proficiency of limited English proficient children by providing high-quality language instruction educational programs that are based on scientifically based research demonstrating the effectiveness of the programs in increasing — – (A) English proficiency; and– (B) student academic achievement in the core

academic subjects; and23

Title III Required Activities - An eligible entity receiving funds under section 3114(a) shall use the funds

• (2) to provide high-quality professional development to classroom teachers (including teachers in classroom settings that are not the settings of language instruction educational programs), principals, administrators, and other school or community-based organizational personnel.

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Title III eGAP Budget Details

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Title III Allowable Activities - An eligible entity receiving funds under section 3114(a) may use the funds to

achieve one of the purposes described in subsection (a) by undertaking one or more of the following activities

• (1) Upgrading program objectives and effective instruction strategies.

• (2) Improving the instruction program for limited English proficient children by identifying, acquiring, and upgrading curricula, instruction materials, educational software, and assessment procedures.

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• (3) Providing tutorials and academic or vocational education for limited English proficient children; and intensified instruction.

• (4) Developing and implementing elementary school or secondary school language instruction educational programs that are coordinated with other relevant programs and services.

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• (5) Improving the English proficiency and academic achievement of limited English proficient children.

• (6) Providing community participation programs, family literacy services, and parent outreach and training activities to limited English proficient children and their families to improve the English language skills of limited English proficient children; and to assist parents in helping their children to improve their academic achievement and becoming active participants in the education of their children.

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• (7) Improving the instruction of limited English proficient children by providing for the acquisition or development of educational technology or instructional materials; access to, and participation in, electronic networks for materials, training, and communication; and incorporation of the resources described in subparagraphs (A) and (B) into curricula and programs, such as those funded under this subpart.

• (8) Carrying out other activities that are consistent with the purposes of this section.

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Immigrant Children and Youth

• An eligible entity receiving funds under section 3114(d)(1) shall use the funds to pay for activities that provide enhanced instructional opportunities for immigrant children and youth, which may include —

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• (A) family literacy, parent outreach, and training activities designed to assist parents to become active participants in the education of their children;

• (B) support for personnel, including teacher aides who have been specifically trained, or are being trained, to provide services to immigrant children and youth;

• (C) provision of tutorials, mentoring, and academic or career counseling for immigrant children and youth;

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• (D) identification and acquisition of curricular materials, educational software, and technologies to be used in the program carried out with funds;

• (E) basic instruction services that are directly attributable to the presence in the school district involved of immigrant children and youth, including the payment of costs of providing additional classroom supplies, costs of transportation, or such other costs as are directly attributable to such additional basic instruction services;

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FEDERAL PROGRAMS FUNDING ISSUES

• Supplement not Supplant• Maintenance of Effort• Comparability• Time and Effort• 100% Certifications• Budgeting funds by Cost Center and PPA• Expenditures Matching CIPs Budgets• Paying Non-HQ Teachers with Federal Funds• Flexing

Supplement not Supplant

• In the absence of Federal Funds would I have the funds to support this position, or is the position required by the state?

• When I monitored recently and started checking for supplement vs. supplant I found a unique situation. A district had taken central office positions (an elementary curriculum director, an attendance officer, and psychologist, and psychometrist) and divided them among schools at per rata shares using foundation units. This was considered supplanting because the district came back with federal units and all foundation units were not in place. It was also a problem with comparability.

Time and Effort

• Time and Effort should be completed for all employees on split funds each month. The form should include all fund sources the employee is paid from and signed by the employee or their supervisor.

While on a consolidated monitoring review, we asked the school district for their time and effort sheets and 100% certification documents on all personnel paid with Federal Funds. When comparing the list of district personnel paid with Federal Funds with the time and effort documents presented, it was discovered that Title II personnel had neither time and effort documents nor 100% certification documents. The district had the documentation for Title I paid personnel only. When we asked how long this had been done this way, they said for the past 3 years. When we calculated the pay pack for this situation, we estimated 1.2 million would need to be paid back to the federal fund source.

100 % Certifications

• All employees paid with 100% federal funds are required to sign certifications at least twice a year.

100 % Certification Document LEA ____________________________________________________________________________________________________

School__________________________________________________________________________________________________(if applicable)

Please indicate the current employment quarter for _____________

(school year)Documented by checking the appropriate box below:

Quarter 1. August thru October Quarter 2. November thru January

Quarter 3. February thru April Quarter 4. May thru July

__________________________________________________ spends 100% of my time as a _______________________

Employee (please print) (position)

Salary funding sources and percentages: •

••

_________________________________________ _________________________________________ Employee’s Signature Date

________________________________________ _________________________________________Supervisor’s Signature Date

<INSERT SYSTEM NAME>CERTIFICATION OF 100% TIME WORKED ON A SINGLE

FEDERAL AWARD (OR COST OBJECTIVE)OR STATE FUNDS IF REQUIRED FOR MATCH

AND/OR MAINTENANCE OF EFFORT

I, <INSERT NAME>, at <INSERT SCHOOL/WORKPLACE> certify that for the period beginning <INSERT MONTH, DAY, YEAR>

and ending <INSERT MONTH, DAY, YEAR>, worked 100% time on the <INSERT SPECIFIC PROGRAM> program and/or activity. ______________________________________________ / _____________Employee’s Signature Date

______________________________________________ / _____________Supervisor’s Signature Date

100 % Certification

Supplement not Supplant• In this case study, we will explore what happened recently in a small rural school

district where several central office staff had been assigned multiple duties. Although no funds are directly allocated for a position, the state requires that school districts make provisions to have a testing coordinator which is beneficial because the state requires that districts participate in state assessments. In a particular rural district, the test coordinator was also the Highly Qualified/Professional Development Coordinator with salary portions of .10 FTE of salary/benefits from Title II and .78 FTE from General Fund/OCE.During the regularly scheduled Consolidated Compliance Review, it was also revealed that .12 of the test coordinator’s salary was actually being paid from Title I, with the justification that, “…after all, I deliver tests to Title I schools.” In conversation with the district, the test coordinator expressed shock and dismay replying that they had indeed “…done this over several years.” The district received a finding in this case for this supplanting issue and state staff was asked to research the cost of salary and benefits erroneously paid over the last three years. The request was then made to repay Title I an amount over $34,000.00.

Supplement not Supplant

• School visits revealed that copier rental leases are paid from Title I funds for the sole copier in the schools. In the absence of federal funds, schools would still require a copier

COMPARABLITY

• Evidence revealed that the LEA did not use state funds in Title I schools that were substantially comparable to services in non-served schools. Reading Coaches at non-served schools are paid with 100% state funds while Reading Coaches at Title I schools are paid with 78% state funds.

Cost Center Budgeting

• Expenditure Reports do not match the Per Pupil Allocation budgeted in e-GAP. The Expenditure Reports should be reviewed monthly by the Federals Programs Coordinator.

Expenditures Matching CIPs

• An onsite monitoring review revealed that the school expenditure was not in compliance with the application approved by the SDE. Services delivered to migrant students did not match the .75 FTE used from the Migrant Program fund source which resulted in the amount of $39,365.37.

Paying Non-HQ Teachers with Federal Funds

• Non Highly Qualified Teachers should not be paid with Federal Funds.During a recent federal programs compliance monitoring in and LEA, a Title I paid teacher was found to be non-highly qualified in her assigned position. The teacher had valid professional certificates in Special Education including Specific Learning Disability and Mental Retardation. The teacher’s highly-qualified eligibility is for Special Education: Core Academic Subjects, Including Reading grades P-12.

It was reported by the LEA that the teacher had been in the position at least three years and was paid an average salary and benefits of $71,000. The district failed to realize that in order for this teacher to be deemed highly-qualified for the assigned Title I reading position, the teacher would have to demonstrate competence for her assigned position by taking the Elementary Praxis II test for Elementary Education.A special education teacher is non-highly qualified to teach a regular elementary subject area unless that teacher has demonstrated competency in the regular elementary teaching field and grade level of the core academic subject she is assigned to.