Transcript SES RFA PowerPoint 2008 draft 2.8.08

Fiscal Considerations
for
Categorical Programs
Categorical Directors Meeting
March 25, 2008
Presented By:
Richard Graham
Maria Reyes
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction
Agenda
JACK O’CONNELL
State Superintendent
of Public Instruction
• 85 – 15 Requirements
– Direct Services
– Direct Costs
– Administrative Costs
• Allowable Costs
• Timekeeping Requirements
• Fiscal Schoolwide Programs
Guidance
2
85% – 15%
Expenditure Rule
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction
85% – 15% Expenditure Rule
JACK O’CONNELL
State Superintendent
of Public Instruction
For Title I, Part A
• At least 85% of program allocations must
be budgeted and expended at school sites
for direct services to students.
(Education Code, Section 63000-63001)
• Up to 15% may be spent for administrative
costs, including indirect costs, incurred at
the school and district office in support of
these programs.
Note: Some categorical programs may have additional, more
stringent requirements. The 85 – 15 rule does not
supersede those requirements.
4
Expenditures
• What are direct services to students?
JACK O’CONNELL
State Superintendent
of Public Instruction
Services delivered to students at the school
site in which the student is the direct
recipient or beneficiary of the service:
– Personnel providing “hands-on” instruction
or
– Services that are integral to the quality of the
instructional program and the academic
success of the students
– For example, research supports activities
that involve parents in the education of
their children, and quality professional
development opportunities as leading to
student academic success
5
15% Expenditure Cap
JACK O’CONNELL
State Superintendent
of Public Instruction
• What does the 15% administrative cap
mean?
– Indirect costs and direct administrative costs
cannot exceed 15%.
For example: If an LEA has already spent 12
percent on direct administrative costs, then it
can claim only 3% for indirect costs, even if
the approved indirect cost rate exceeds 3%.
6
Program Costs are either:
JACK O’CONNELL
State Superintendent
of Public Instruction
• Direct Costs=
• Indirect Costs=
Costs that can
Costs not readily
be identified with identifiable with a
a specific goal or particular program
cost objective.
but necessary for the
overall operation of
the LEA.
(CSAM 2007, 915-12)
(CSAM 2007, 915-13)
7
What are administrative
costs?
JACK O’CONNELL
State Superintendent
of Public Instruction
• Any costs, direct or • Examples of direct:
indirect, that are
salaries of district
administrative in
administrative
nature and support
personnel, program
the management of a
monitoring, preparing
program.
program plans,
purchasing of supplies
• Examples of indirect:
Payroll, accounting,
budgeting,
warehousing
(CSAM 2007, 915-12 and 13)
8
85 – 15 Expenditure Rule
JACK O’CONNELL
State Superintendent
of Public Instruction
85% Direct Services
at school site
15% Administrative
Administrative
Costs
Direct Costs
Indirect
Costs
9
85% Expenditures
JACK O’CONNELL
State Superintendent
of Public Instruction
• Examples of expenditures that are within the
85% direct services to students include:
– Personnel providing “hands on”
instruction/services to students (i.e. math or ELA
coaches, resource teachers, school nurses, school
librarians, counselors, instructional aides, etc.)
– Instructional material/equipment that meet the
specific needs of eligible students (i.e., books,
supplies, and computers)
– Professional development for teachers and other
staff who are assigned eligible students
– Supplemental student assessment or student
data analysis tied to informing and improving
instruction
– Parental involvement activities to support
student achievement
10
Examples Outside 85%
JACK O’CONNELL
State Superintendent
of Public Instruction
• Examples of expenditures that are outside the
85% direct service limitation include:
– District administrative personnel
– District program personnel
– Itinerant staff, except for the time directly related to the
purposes of the categorical program, or travel to school
sites to deliver instruction or staff development
– School program administrators, to the extent they do
not provide direct instruction or conduct staff
development activities at schools sites to meet specific
pupil needs consistent with the purpose of the program
– District program evaluation
– District advisory councils
– General staff development not related to specific pupil
instructional needs
11
Questions to Ask for 85% - 15%
JACK O’CONNELL
State Superintendent
of Public Instruction
• Expenditures can fall into a gray area, so
carefully evaluate the nature and extent of
the expenditure’s benefit to the student.
Ask yourself:
– How direct is the educational benefit to student?
– Does the expenditure have a clear education
impact on the instructional program and the
academic success of the students?
12
Questions to Ask for 85%-15%
(Con’d)
JACK O’CONNELL
State Superintendent
of Public Instruction
• Other questions to ask yourself:
– Was decision to expend funds made
at the school site or at the district
level? (Determine the origin of the
decision to make the expenditure.)
– Is the educational objective of the
categorical program furthered by the
expenditure? (Evaluate the
expenditure in relation to the
categorical program objectives.)
13
Not Sure?
JACK O’CONNELL
State Superintendent
of Public Instruction
• Suggestions to clarify uncertain
expenditures:
– Prepare written statement justifying
and supporting your decision to include
the item as a direct service (85%).
– Maintain the written statement on file.
– Also, maintain additional
documentation to support your
decision.
14
Allowable Costs
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction
Program Expenditures Under
SWP Plan (Section 1114)
JACK O’CONNELL
State Superintendent
of Public Instruction
1.
Needs assessment
2. Schoolwide reform strategies that:
a. Increase the amount & quality
of learning time (extended year,
before- and after-school)
b. Address needs of all, but
particularly low-achieving
students
16
Expenditures in SWP (cont’d)
JACK O’CONNELL
State Superintendent
of Public Instruction
3. Instruction by “highly qualified”
teachers
4. Professional development
5. Strategies to attract high quality
teachers
6. Parental involvement
7. Transition from pre-school
8. Include teachers in assessment
decisions
9. Timely, effective additional assistance
10. Coordination and integration
17
Reminder!:
Supplement/Supplant
JACK O’CONNELL
State Superintendent
of Public Instruction
TAS:
• Funds used for services that
supplement, and do not supplant, the
services that would be provided, in the
absence of Title I, from non-federal
sources.
• SWP:
Fiscal analysis only; “Use Title I funds
only to supplement the amount of funds
that would, in the absence of federal
funds, be made available from nonfederal sources for the school.”
18
JACK O’CONNELL
State Superintendent
of Public Instruction
19
JACK O’CONNELL
State Superintendent
of Public Instruction
Timekeeping Requirements
20
Timekeeping Requirements
JACK O’CONNELL
State Superintendent
of Public Instruction
• Salaries and wages, direct or indirect,
must be substantiated by payroll
documentation in accordance with
generally accepted practice
• No further documentation is required for
salaries and wages of employees working
in a single indirect cost activity
• Salaries and wages charged to federal
and state restricted programs will require
additional documentation
21
Timekeeping Requirements
(Cont’d)
JACK O’CONNELL
State Superintendent
of Public Instruction
The level of documentation required
is based on:
– How an employee is funded (federal
vs. state)
– How many “cost objectives” the
employee worked on (single vs.
multiple cost objectives)
22
Timekeeping Requirements
(Cont’d)
JACK O’CONNELL
State Superintendent
of Public Instruction
What is a “cost objective?”
OMB Circular A-87 defines a cost
objective as a function, contract, grant
award, or other category of costs that
requires the grantee to track specific
cost information.
23
JACK O’CONNELL
State Superintendent
of Public Instruction
Timekeeping Requirements:
Federally Funded Programs
24
JACK O’CONNELL
State Superintendent
of Public Instruction
If federal funds are used for
salaries:
• Time distribution records must
be kept
• Employees must show that they
actually worked on the federal
program
25
Time distribution records for federally
funded programs include:
JACK O’CONNELL
State Superintendent
of Public Instruction
• Periodic Personnel Certification (at
least semi-annually)
• Personnel Activity Report (PAR) or
equivalent documentation
• Other (e.g. substitute system)
26
JACK O’CONNELL
State Superintendent
of Public Instruction
If employee works 100% on
single cost objective or
federal award:
• Semi-Annual Certification
– Signed every six months by
supervisor or employee
27
JACK O’CONNELL
State Superintendent
of Public Instruction
This sample is for informational purposes only.
28
If employee works on
multiple cost objectives:
JACK O’CONNELL
State Superintendent
of Public Instruction
• Personnel Activity Reports (PAR)
– Signed every month by employee
• Examples:
– More than one federal award
– A federal award and a non-federal award
– An indirect cost activity and direct cost
activity
– 85/15—direct services and administrative
services
29
JACK O’CONNELL
State Superintendent
of Public Instruction
This sample is for informational purposes only.
30
TIME ACCOUNTING FOR MULTI - FUNDED PERSONNEL
School/Department: Charlie Brown Middle School
Program
Activities for (month/yr)
2
Title I
EIA
Title I
State Superintendent
of Public Instruction
General
General
Title: Resource Specialist
School Yr.
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Total Hours
Reading Coach
Parent conference
Prep work
Title I
JACK O’CONNELL
Name: Lucy Schultz
4
6
3 3
6
2
2
4
Interpretation
2.5
2 3 1
8.5
Master Teacher observation
Time management training
1.5
2 2 2
7.5
TOTAL
8
8
8 8 8 8 8
40
I hereby certify that the above information is a true and correct representation of the actual time spent by me in support and compliance of the above Federal and State Categorical programs and General Education
Programs operated by the District.
EMPLOYEE SIGNATURE
DATE
Directions:
To be completed each month
Enter time in half hour increments
Enter funding source in program column
Enter one activity per row under the Activity column
SUPERVISOR SIGNATURE
DATE
Program Name % A. Hours Funded B. Hours Worked Difference (A - B)
Title I
50%
90
16
74.00
EIA
25%
45
8.5
36.50
General
15%
27
15.5
11.50
21st Century 10%
18
0
18.00
Total
100%
180
40
This sample is for informational purposes only.
31
Timekeeping Requirements
(Cont’d)
JACK O’CONNELL
State Superintendent
of Public Instruction
In order to meet documentation requirements the
PAR (or equivalent documentation) must:
• Reflect an after-the-fact distribution of the
actual activity of each employee
• Account for the total activity for which each
employee is compensated
• Be prepared at least monthly and coincide
with one or more pay period
• Be signed by the employee
OMB Circular A-87, Attachment B, Section 8(h)(5) and the CSAM,
Procedure 905
32
Maintenance of
Effort
Legal Authority:
NCLB: Section 9521
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction
Maintenance of
Effort
Shifting an expenditure from a nonFederal account to a Federal account
would constitute supplanting.
An LEA may rebut this presumption by
demonstrating that, in the absence of
Federal funds, it would not fund this
expenditure in the subsequent year.
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction
Maintenance of
Effort (cont.)
The reason provided by an LEA for
shifting an expenditure in any particular
circumstance would be critical in
determining whether Federal funds
were used to supplant State or local
funds that would have been made
available in the absence of Federal
funds.
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction
Maintenance of
Effort (cont.)
The LEA must maintain clear
contemporaneous records of why the
shift in funding source occurred.
Example: LEA governing board
eliminated position. Minutes from
meeting.
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction
MOE: Waiver
JACK O’CONNELL
State Superintendent
of Public Instruction
• USDE Secretary may waive if:
– Exceptional or uncontrollable
circumstances such as natural
disaster
OR
– Precipitous decline in financial
resources of the LEA
37
JACK O’CONNELL
State Superintendent
of Public Instruction
38
JACK O’CONNELL
State Superintendent
of Public Instruction
New Guidance on Fiscal
Requirements in SWP
39
Records Required in SWP
JACK O’CONNELL
State Superintendent
of Public Instruction
If school consolidates* Federal, state, and
local funds, then it is not required to
maintain separate fiscal accounting
records, by program, that ID the specific
activities supported by those particular
funds as long as it maintains records
that demonstrate the SWP, considered
as a whole, addresses the intent and
purposes of each federal program.
*Note: current California statute prohibits
consolidation of state and federal funds
40
Records in SWP (con’td)
JACK O’CONNELL
State Superintendent
of Public Instruction
• If LEA consolidates only Federal, LEA
must keep records to demonstrate
Federal funds were used for activities
supporting specific educational needs of
school
– ID in needs assessment
– Included in SWP description in SPSA
• Need not identify, by program, specific
activities supported by those funds
41
Records in SWP (con’td)
JACK O’CONNELL
State Superintendent
of Public Instruction
• If LEA does not consolidate anything, it
must maintain separate records for
each federal program showing activities
supporting educational needs.
• Re Title I, need not show
supplementary activities* for identified
Title I students.
*(Calif. Ed Code 64001- SPSA requires activities to be
described in plan developed by SSC)
42
Questions:
JACK O’CONNELL
State Superintendent
of Public Instruction
• In CA can schools consolidate federal,
state and local funds in one single
schoolwide pool?
• If a school consolidates all federal funds
in one single schoolwide pool, how do
you document 85%/15%?
• What role does SWP plan play in
consolidation?
43
Ranking and Allocations to
Title I Schools
JACK O’CONNELL
State Superintendent
of Public Instruction
• (A) annually rank, without regard to grade
spans, such agency's eligible school
attendance areas in which the
concentration of children from low-income
families exceeds 75 percent from highest
to lowest according to the percentage of
children from low-income families; and
• (B) serve such eligible school attendance
areas in rank order.
44
Ranking and Allocations to
Title I Schools
JACK O’CONNELL
State Superintendent
of Public Instruction
•If funds remain after serving all eligible school
attendance areas above 75% poverty a local
educational agency shall—
– `(A) annually rank such agency's remaining
eligible school attendance areas from highest to
lowest either by grade span or for the entire
local educational agency according to the
percentage of children from low-income families;
and
– `(B) serve such eligible school attendance areas
in rank order either within each grade-span
grouping or within the local educational agency
as a whole.
45
Ranking and Allocations to
Title I Schools
JACK O’CONNELL
State Superintendent
of Public Instruction
75%
35%
100
90
80
70
60
50
40
30
20
10
0
Percent
Poverty
Rank
East
West
North
South
Sand Dunes
Sand Pile
Sand Dollar
Lotsa Sand
Sand Paper
46
Ranking and Allocations to
Title I Schools- Using School Poverty
JACK O’CONNELL
State Superintendent
of Public Instruction
Percent
Poverty
Serve with
Title I
Poverty
Rank
Grade
Span
East
99.7
must serve
1
K-6
West
North
South
Sand Dunes
92.2
75.5
64.5
48.9
must serve
must serve
may serve
may serve
2
3
4
5
K-6
7-8
7-8
9-12
Sand Pile
Sand Dollar
38.7
35.3
may serve
may serve
6
7
K-6
K-6
Lotsa Sand
26.1
not eligible
8
K-8
Sand Paper
17.5
not eligible
9
K-6
School
47
Ranking and Allocations to
Title I Schools- Using Gradespan
JACK O’CONNELL
School
% Pov.
Eligible
Rank
Gradespan
64.5
may
serve
4
7-8
48.9
may
serve
5
9-12
38.7
may
serve
6
K-6
35.3
may
serve
7
K-6
State Superintendent
of Public Instruction
South
Sand
Dunes
Sand Pile
Sand
Dollar
48
Ranking and Allocations to
Title I Schools
JACK O’CONNELL
State Superintendent
of Public Instruction
In this example schools below 35% poverty may not be served
School
% Pov.
Eligible Grade
Gradespan
Lotsa Sand
26.1
no
8
K-8
Sand Paper 17.5
no
9
K-6
49
Grandfathering school(s)
JACK O’CONNELL
State Superintendent
of Public Instruction
To protect schools that may lose eligibility
for one year due to fluctuations in
attendance and percent poverty rate, the
LEA may designate and serve that school
attendance area or school that is not eligible
under this section, but that was eligible and
that was served in the preceding fiscal year,
but only for 1 additional fiscal year
`USC 6313 (b)(1)(C)
50
Skipping Title I School
Attendance Areas
JACK O’CONNELL
State Superintendent
of Public Instruction
A local educational agency may elect not
to serve a school attendance area if
other state or local funds (in an amount
equal to the Title I allocation) are used
to meet the requirements of TAS or
SWP.
USC 6313 (c)(2)(B)
51
Financial Incentives and Rewards (permissive- not required)
JACK O’CONNELL
State Superintendent
of Public Instruction
A LEA may reserve such funds as are
necessary, not to exceed 5% of the
entitlement, to provide financial incentives
and rewards to teachers who serve in
schools identified for school
improvement, corrective action, and
restructuring for the purpose of attracting
and retaining qualified and effective
teachers.
52
Questions?
CALIFORNIA DEPARTMENT OF EDUCATION
Jack O’Connell, State Superintendent of Public Instruction