Transcript Governor’s Urban Academy

Maintenance of Effort,
Comparability, and
Supplement/Supplant
PAFPC April 2011
USDE Title I Fiscal Guidance
(May 06)
• www.ed.gov/programs/titleiparta/ fiscalguid.doc
This guidance covers these areas:
• Maintenance of Effort (MOE)
• Comparability
• Supplement not Supplant
• Carryover
• Grantbacks
Maintenance of Effort
Legal Authority:
NCLB: Section 9521
MOE: The NCLB Rule
• LEA may receive funds only if SEA finds
the combined fiscal effort per student or
the aggregate expenditures of the LEA
from state and local funds from preceding
year is not less than 90% for second
preceding year.
MOE: Preceding Fiscal Year
• Need to compare final financial data
– PDE Uses Annual Financial Report (AFR)
• Compare “immediately” PFY to “second”
PFY
• EX: To receive FY 2005 funds (available
July 2005), compare FY 2004 (2004-05) to
FY 2003 (2003-04)
Expenditures Included
• “Expenditures from state and local funds
for free public education”
• Administration; instruction; attendance
and health services; pupil transportation
services; operation and maintenance of
plant; fixed charges; and net expenditures
to cover deficits for food services and
student body activities
Expenditures Excluded
• Funds from federal government
• Community services; capital outlay; debt
service; or supplemental expenditures
made as a result of a Presidentially
declared disaster
MOE: Failure
• ESEA: If LEA fails MOE, SEA must reduce
amount of allocation in the exact proportion
by which LEA fails to maintain effort below
90%.
• Reduce all applicable NCLB programs, not just
Title I
Aggregate
expenditures
Amount per
student
SY 04
1,000,000
6,100
SY05 –
must spend 90%
900,000
5,490
05 –
Actual amount
850,000
5,200
Shortfall
-50,000
-290
Percent shortfall/
reduction
-5.6%
-5.3%**
Years after Failure
• SEA uses 90% of the prior year amount
rather than the actual expenditure amount
MOE: Waiver
• USDE Secretary may waive if:
– Exceptional or uncontrollable circumstances
such as natural disaster
OR
– Precipitous decline in financial resources of
the LEA
Comparability
Legal Authority:
Title I Statute: §1120A(c)
General Rule- §1120A(c)
• An LEA 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
least comparable to the services provided in
non-Title I schools.
• If all are Title I schools, all must be
“substantially comparable.”
Timing Issues
• Guidance: Must be annual determination
• YET, LEAs must maintain records that are
updated at least “biennially” (1120A(c)(3)(B))
• Review for current year and make adjustments
for current year
• Assurances are due November 15.
• Egrants changes for 08/09.
Written Assurances
• LEA must file with SEA written assurances that
state:
– The LEA is exempt from demonstrating
Comparability because it has only 1 building
per grade span or;
– The LEA has successfully documented the
comparable staff to pupil ratio in the district
using the Detailed School Data Sheet.
How to measure in a district with
non-Title I buildings
Compare:
• Average of all nonTitle I schools
TO
• Each Title I school
Average of all non-title I schools=10:1
Title I schools:
Lincoln: 10:1 Washington: 9:1
Madison: 11:1 Jefferson 12:1
How to measure in a district
with all Title I buildings
Compare:
• Average of one or more of the lowest poverty
Title I schools to each higher poverty Title I
school
• Lincoln 30% poverty, Washington 50%, Madison
55%, Jefferson 60% Chose only Lincoln as the
comparison school
• Lincoln 30%, Washington 32%, Madison 55%,
Jefferson 60%, chose both Lincoln and
Washington as the comparison schools
Basis for evaluation:
• grade-span by grade-span
OR
• school by school (district-wide basis)
Exclusions:
• Federal Funds
• Private Funds
• Need not include unpredictable changes in
student enrollment or personnel
assignments that occur after the start of a
school year
Who is “instructional staff”
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Administrators (principals and assistant principals)
Art Teachers
Classroom Teachers
Guidance Counselors
Librarians
Music Teachers
Physical Education Teachers
Project Directors (Non-federally funded)
Psychologists
Social Workers
Speech Therapists
Not included…
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Bus Monitors
Consultants
Crossing Guards
Maintenance Staff
Security Staff
Federally paid Staff
Optional staff…
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Bilingual Teachers
Special Education
Title I “Like” Staff
Teachers Aides (instructional)
• Although the LEA has the discretion to count or
not count these types of staff, it must be done
consistently across the grade spans being
compared.
How to access the Data Sheet
and Assurance page
• www.education.state.pa.us and click on the
eGrants link at the left of the page.
• Then click on the Division of Federal Programs
link at the left of the screen.
• Enter your Login ID and password, then click on
the “Consolidated Application” link.
• At the main Consolidated Application page you’ll
see the link for Comparability towards the
bottom of the screen.
Supplement/Supplant
• Targeted Assisted – program level supplanting.
“Reasonable and necessary.” Very situationally
dependent
• Schoolwide – fiscal level supplanting only, but
must meet “intents and purposes.”
School must receive all the state and local funds
it would otherwise need to operate in the
absence of Federal funds
– Includes routine operating expenses such as
building maintenance and repairs, landscaping
and custodial services
Can Title I $ be used for basic
operational expenses?
• If only federal combined –
– No, must be for educational needs
• If federal and non-federal combined –
– No, but impossible to determine which is
federal
– Be sure sufficient state and local funds
allocated to school to meet basic operational
needs
What is “educational need”?
• Not addressed in guidance
– Instruction – yes
– Instructional support – probably yes
– Administration – possibly yes
– Operational – no
Closing Thoughts
• The SWP is VERY important!
• Targeted versus SWP which is better?