Federal Flexibility Initiative

DRAFT

Federal Flexibility Initiative

The federal flexibility initiative is one of Commissioner Williams’ priorities. The purpose of the initiative is to provide increased flexibility to subrecipients of federal education grants in ways that support one of Commissioner Williams’ other top priorities for Texas education, which is to close gaps in student achievement.

Federal Flexibility Initiative

The initiative is made up of new policies related to how TEA administers, manages, and monitors federal grants. These policies are designed to give subrecipients greater flexibility in how they administer federal grant funds so they can close student achievement gaps by operating effective programs that are based upon locally identified needs.

Federal Flexibility Initiative

Federal Flexibility Initiative Policy Changes to Assist Districts • • • • • • Allowing more discretion at the local level Providing clear guidance with examples/models Removing unnecessary and burdensome barriers Improving performance and program outcomes Ensuring that grant funds are spent in accordance with program statute and regulations Strengthening accountability for federal dollars

Federal Flexibility Initiative

Three main parts: • • • Schoolwide programs Other new policy changes Uniform guidance

Schoolwide Programs and the Federal Flexibility Initiative

Training Outline

Schoolwide Programs Overview Comprehensive Needs Assessment Campus Improvement Plan Evaluation Plan Consolidation Options Fiscal Issues

Schoolwide Programs

SCHOOLWIDE PROGRAMS OVERVIEW

TEA – Schoolwide Programs

Schoolwide Program Resources

• • • • • TEA web page on Schoolwide Programs Designing Schoolwide Programs , Non-Regulatory Guidance, March 2006 TEA Policy Guidance for Title I, Part A , February 2010 Title I, Part A Fiscal Issues , Non-Regulatory Guidance, February 2008 NCLB Title I, Part A Campus Responsibilities Region 20

Schoolwide Programs Overview

Federal Requirements Overview and Purpose Eligibility Consolidation of Funds Campus Requirements Continuation of Program

Federal Requirements for Schoolwide Programs Elementary and Secondary Education Act of 1965

Use of funds for Schoolwide Programs

A local educational agency may consolidate and use funds under this part, together with other Federal, State, and local funds, in order to upgrade the entire educational program of a school that serves an eligible school attendance area in which not less than 40 percent of the children are from low-income families, or not less than 40 percent of the children enrolled in the school are from such families.

Federal Requirements for Schoolwide Programs Elementary and Secondary Education Act of 1965 • • •

Use of Funds for Schoolwide Programs

Identification of students Exemption from statutory and regulatory requirements Professional development

Federal Requirements for Schoolwide Programs Elementary and Secondary Education Act of 1965 • •

Components of a Schoolwide Program

10 required program components Planning

Federal Requirements for Schoolwide Programs Federal Register - July 2, 2004 (Vol. 69, Number 127)

A schoolwide program is a comprehensive reform strategy to improve the academic achievement of all students in the school, particularly the lowest-achieving students…. Researchers have documented that when the

entire school is the target of change, schools serving even the most academically challenged

students can achieve success.

Federal Requirements for Schoolwide Programs Federal Register - July 2, 2004 (Vol. 69, Number 127) • • • • 3 core elements Identification of students Accounting Intent and purposes

Federal Requirements for Schoolwide Programs Federal Register - July 2, 2004 (Vol. 69, Number 127) • • • •

Inclusion of other federal education program funds

Improve academic achievement Meet intent and purposes Support campus’s schoolwide plan Address needs of all children

Federal Requirements for Schoolwide Programs Federal Register - July 2, 2004 (Vol. 69, Number 127) • •

Satisfying “Intent and Purposes”

Address needs of intended beneficiaries Fiscal accounting records •

Requirement for Schoolwide Program

A campus that consolidates is not exempt from certain requirements

TEA – Schoolwide Programs

Overview and Purpose for Schoolwide Programs

A Title I, Part A schoolwide program allows a campus to use its funds to improve the entire educational program and the academic performance of all of its students, particularly the lowest-achieving students.

Overview of Schoolwide Programs • • • A schoolwide program – Must comply with guidelines – Must maintain accountability – Receives greater flexibility – Serves all students TEA principles Current guidance

Eligibility for Schoolwide Programs • • • • The LEA determines which campuses are eligible to operate a schoolwide program based on specific criteria: Eligible for Title I, Part A funds 40% or more students are from low-income families Exceptions Shared Service Arrangements

Schoolwide Programs vs Targeted Assistance Programs • Title I, Part A Targeted assistance program – funds can be used only for supplementary educational services for children identified as being most at risk for not meeting state standards.

• Title I, Part A Schoolwide program – funds may be used to upgrade the entire educational program on the campus to improve the academic performance of all students.

Consolidation of Funds for Schoolwide Programs A campus that chooses to adopt a schoolwide program model can consolidate Title I, Part A grant funds, or their Title I, Part A funds and other funds, into a single budget “pool.” Funds in the pool belong to the schoolwide program budget instead of many individual budgets, and the campus can use the pool to pay for any

activity identified in its campus improvement plan that improves its entire educational program.

Consolidation of Funds for Schoolwide Programs Consolidating funds into a single budget “pool” does not mean that the campus puts all of its funds into one account. Instead, the pool concept means that the funds can be used for one purpose, which is to operate the schoolwide program.

The campus must keep documentation to show the amount of funds placed in the pool and expended from each particular program.

Consolidation of Funds for Schoolwide Programs A campus can consolidate most federal formula funds from programs administered by USDE: • • • • Title I, Part C Title II, Part A Title III, Part A Perkins Career and Technical Education

Consolidation of Funds for Schoolwide Programs • • • A campus cannot consolidate these funds in a schoolwide program: Head Start National School Lunch State Compensatory Education • A campus can consolidate: Some federal discretionary funds

Consolidation Program Requirements for Schoolwide Programs • • •

Federal formula funds:

Intents and purposes Needs of intended beneficiaries Statutory and regulatory requirements •

Federal discretionary funds:

Carry out all activities

Consolidation Program Requirements for Schoolwide Programs • • • • Must meet program requirements related to: Civil rights Health and safety Participation and involvement of parents and students Participation of private school children, teachers, and other educational personnel

Consolidation Fiscal Requirements for Schoolwide Programs • • • • • •

Must meet these fiscal requirements:

Comparability of services Distribution of formula funds to campuses Maintenance of effort Set-asides Supplement, not supplant Time and effort

Consolidation Options for Schoolwide Programs • • • Full consolidation - pooling some or all federal, state, and local funds in schoolwide program budget Federal consolidation - pooling only some or all federal funds in schoolwide program budget Title I, Part A only - only Title I, Part A funds in schoolwide program budget

Consolidation Accounting for Schoolwide Programs • • • Appropriate accounting systems Accommodate the flexibility of funds consolidation Maintain accurate records regarding amounts allocated from each program

Consolidated NCLB Application for Schoolwide Programs • On Schedule SC5000, indicate which campuses will operate a schoolwide program • Select how each campus will consolidate funds

Campus Requirements for Schoolwide Programs • Conduct a comprehensive needs assessment • Submit a schoolwide campus improvement

plan

• Develop an evaluation plan to assess the CIP on an annual basis, revise CIP as needed

Title I Principles for Schoolwide Programs • Accountability for results • Research-based practices • School and community engagement

Continuation of Schoolwide Programs To continue a schoolwide program from one year to the next, the campus must: • • • Follow the CIP Evaluate and update the CIP annually Refine the schoolwide program each year based on the results of the evaluation of student performance

Schoolwide Programs

DRAFT

COMPREHENSIVE NEEDS ASSESSMENT (CNA)

TEA – Comprehensive Needs Assessment

Resources for Comprehensive Needs Assessment • • • Comprehensive Needs Assessment TEA web page – Schoolwide Programs Designing Schoolwide Programs Non-Regulatory Guidance, March 2006 NCLB Comprehensive Needs Assessment Developed by Region 20 for TEA

Comprehensive Needs Assessment

Requirements Overview 5-Step Process Tools Purposes

Federal Requirements for Comprehensive Needs Assessment Elementary and Secondary Education Act of 1965

A schoolwide program shall include….

a comprehensive needs assessment of the entire school (including taking into account the needs of migratory children as defined in section 1309(2)) that is based on information which includes the achievement of children in relation to the State academic content standards and the State student achievement standards described in section 111(b)(1). (p. 49)

Federal Requirements for Comprehensive Needs Assessment

Federal Register - July 2, 2004 (Vol. 69, Number 127)

A school operating as a schoolwide program must conduct a comprehensive needs assessment of the entire school to determine the performance of its students in relation to the State’s challenging academic content and achievement standards. (p. 40361)

State Requirement for Comprehensive Needs Assessment Texas Education Code campus planning: Section 11.253 related to

The plan must include provisions for a comprehensive needs assessment addressing student performance on the student achievement indicators, and other appropriate measures of performance… Campus-level committees must assess the academic achievement for each student in the school using the student achievement indicator system.

Step 1 in Schoolwide Planning Process Comprehensive Needs Assessment Comprehensive Needs Assessment

What are our needs and where do we focus our efforts?

Campus Improvement Plan What strategies and activities will help us meet the needs?

Program Evaluation Were we successful in addressing our needs and focus areas?

Overview for Comprehensive Needs Assessment • • Required part of planning process Must include campus’s current status on: – Achievement of all students and student groups – Student demographics – Student needs – Curriculum and instruction – Professional development – Family and community involvement – Campus context and organization

Purposes of Comprehensive Needs Assessment • • • To examine multiple sources of data to get a true picture of the campus’s needs To help the campus monitor and assess the impact of programs, instruction, and other resources related to student achievement To help the campus identify strengths and weaknesses and set priorities

Five-Step Process for Comprehensive Needs Assessment • • • • • Establish a schoolwide planning team Clarify the vision for reform Create the campus profile Identify data sources Analyze data and create a summary report

Tools for Comprehensive Needs Assessment NCLB Comprehensive Needs Assessment - Region 20 • Questions for teams to ask in determining which data to collect and for identifying needs • Sample CNA Summary templates

Sample Questions for Discussion

• • • • • • Student Achievement 1. How is student achievement data disaggregated? 2. How does student achievement data compare from one data source to another? 3. What does the data indicate when disaggregated by ethnicity, gender, socioeconomic status, special program, or other category? 4. In which areas are we showing growth? At what rate? Compared to which standard of achievement? 5. Which students are making progress? Why? 6. What impact are intervention programs having on student achievement? Which students are benefiting or not? Why?

Summary Template

Data Sources Reviewed:

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Area Reviewed

Summary of Strengths What were the identified strengths?

Summary of Needs What were the identified needs? Priorities What are the priorities for the campus, including how federal and state program funds will be used?

Demographics Student Achievement School Culture and Climate Staff Quality/ Professional Development Curriculum, Instruction, Assessment Family and Community Involvement School Context and Organization Technology

Additional Tools for Comprehensive Needs Assessment • • • • Survey tips Parent surveys Teacher survey Data discussion tool

Survey Tips

• Keep the questions simple.

• Surveys need to be completed individually and without names.

• Participants should be able to respond easily.

• Balance the number of multiple-choice responses with opinion questions.

• Keep open-ended responses to a minimum.

• Accept the good and the not-so-good results. • Make no assumptions.

Parent Survey

Teacher Survey

Please select one option for each question below: Teachers in this school communicate to students and parents that the number one priority is that all students will become proficient in the state standards.

Teachers work collaboratively to develop curriculum, instructional strategies, and assessments aligned to state standards.

Teachers in this school collect, interpret, and use data related to student achievement to guide decision making.

Teachers in this school discuss data related to student achievement in regularly scheduled meetings.

Teachers in this school regularly analyze student work to determine the effectiveness of strategies.

Teachers in this school use space and time during school hours effectively to collaborate and learn about issues directly related to student achievement.

Very true of us Somewhat true of us Not true of us Don’t know

Data Discussion Tool

Data Discussion Tool WOW UH-OH Use this tool to review data in groups. Jot down your thoughts as you review the data individually, then compare your findings with the group. This will help get the conversation started so that needs can be identified.

QUESTIONS TO DO NEED TO KNOW

Schoolwide Programs DRAFT

CAMPUS IMPROVEMENT PLANS (CIP)

TEA – Campus Improvement Plan

• Resources for Campus Improvement Plans TEA web page Schoolwide Programs: Campus Improvement Plan • NCLB Improvement Plans – Region 20 • 10 Components of a Title I, Part A, Schoolwide Program - Region 16 • 10 Components to a Schoolwide Program – 20on20 Online Course – Region 20

Campus Improvement Plans

Requirements Overview and Purpose Accounting Components Program Components Developing the Plan Sample Plans and Checklists

Federal Requirements for Campus Improvement Plans Elementary and Secondary Education Act of 1965 • • • • How the campus will: Implement program components Use resources Consolidate funds Provide assessment results to parents

Federal Requirements for Campus Improvement Plans Elementary and Secondary Education Act of 1965 • • • • How the plan will be developed: Time requirement People involved Format and availability Coordinated with other fund sources

Federal Requirements for Campus Improvement Plans Federal Register – July 2, 2004 (Vol.69, Number 127)

Using data from its needs assessment, the school must then develop a comprehensive plan to improve teaching and learning in the school, particularly for those students farthest away from demonstrating proficiency on the State’s academic content and achievement standards.

State Requirements for Campus Improvement Plans Texas Education Code campus planning: Section 11.253 related to

Each school year, the principal of each campus, with the assistance of the campus-level committee, shall develop, review, and revise the campus improvement plan for the purpose of improving student performance for all student populations, including students in special education.

Step 2 in Schoolwide Planning Process Campus Improvement Plan Comprehensive Needs Assessment What are our needs and where do we focus our efforts?

Campus Improvement Plan

What strategies and activities will help us meet the needs?

Program Evaluation Were we successful in addressing our needs and focus areas?

Overview of Campus Improvement Plans After conducting the CNA, a campus must develop a comprehensive plan for reforming the total instructional program at the campus. There is no required format, but the plan must contain all required accounting and program components, and most plans also include the campus vision, mission, and campus profile.

Purpose of Campus Improvement Plans • • • Serve as a blueprint for addressing needs Bring focus, coherence, and accountability to reform activities Must include: – Summary of CNA – Required accounting components – Required 10 program components

Accounting Components for Campus Improvement Plans • • • The campus improvement plan: Must contain a description of how Title I, Part A and other resources will be used to implement the CIP Must contain a list of federal, state, and local programs that will be consolidated with the amount that each program will contribute to the schoolwide pool Campus must maintain records that demonstrate addressing intent and purpose of each program

10 Required Program Components for Schoolwide Campus Improvement Plans 1. Comprehensive needs assessment summary 2. Schoolwide reform strategies 3. Instruction by highly qualified teachers 4. High-quality and ongoing professional development 5. Strategies to attract HQ teachers to high needs campuses

10 Required Program Components for Schoolwide Campus Improvement Plans 6. Strategies to increase parental involvement 7. Transition plans from early childhood programs to elementary programs 8. Measures to include teachers in decisions regarding use of academic assessments 9. Effective and timely assistance for students

10 Required Program Components for Schoolwide Campus Improvement Plans 10. Coordination and integration of federal, state, and local services and programs

Schoolwide programs are expected to use the flexibility available to integrate services and programs with the aim of upgrading the entire educational program. A schoolwide program may combine most federal, state, and local funds to provide these services. This maximizes the impact of resources.

10 Program Components for Schoolwide Campus Improvement Plans For a good overview of the 10 program components, view this online course: 10 Components to a Schoolwide Program – 20on20 Online Course – Region 20

Developing the Schoolwide Campus Improvement Plan

Organizational Planning Tool

• • • • • • • • CNA Goals Objectives Strategies Actions Resources, persons responsible, timelines, evidence, assessment Implementation Evaluation

Planning Template

Goals

• • • Approved by the Board of Trustees Aligned with district goals Aligned with campus mission, vision, beliefs • Address priority needs

SMART Objectives

• • • • •

Specific Measurable Attainable, action-oriented Relevant, results-based Time-based

Strategies

• • • • • A plan of action to address an objective Addresses how objective will be met Identifies a sustained course of action Is small enough to be manageable Is significant enough to accomplish the objective Research-Based Best Practices

Action Steps

• • • • • • A detailed step-by-step process for implementing the strategy Who is responsible What resources are needed Expected completion date and checkpoints Evidence of implementation Evidence of impact

Evidence of Implementation and Impact Implementation • Did we do what we said we would do?

• Impact Did it make any difference? Did it result in expected outcomes?

Planning Template

Planning Checklists

• Campus Improvement Plan Checklist • Title I Schoolwide Plan Checklist • Campus Improvement Planning Requirements

State Federal – Schoolwide Program (SWP) State Compensatory Education (SCE) Campus Team: professional staff, parents, community members, business representatives

Campus Team: principals, teachers, other administrators, parents, community members, pupil services personnel, technical assistance providers, school staff, secondary students

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Assess academic achievement for each student in the school using the State’s indicators for performance Set the campus performance objectives based on State targets and school data including objectives for special needs populations, including student in special education programs Identify how the campus goals will be met for each student Determine the resources needed to implement the plan Identify staff needed to implement the plan Set timelines for reaching the goals Measure progress toward the performance objectives periodically to ensure that the plan is resulting in academic improvement Include goals and methods for violence prevention and intervention on campus Plan and conduct awareness education and training on Dating Violence for students, staff, parents Provide for a program to encourage parental involvement Review and revise annually

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Clearly incorporate the 10 Components of a SWP Describe how the school will use Title I, Part A resources and other resources to implement the 10 components Describe how the school will provide understandable student assessment information to parents Include a list of state and federal programs whose funds will be consolidated to implement the SWP Describe how the intent and purposes are met for all federal program funds combined on a SW campus Include sufficient activities to address the needs of intended beneficiaries of all federal programs whose funds are combined on a SW campus to upgrade the entire education program Develop initially during a one-year period, unless LEA and TEA together determine that less time is needed Review and revise annually Make plan available in a language and format that is understandable to LEA, parents, and public 1.

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SCE program must be described in the CIP if the program is implemented at the campus level. The CIP serves as the primary record supporting expenditures for the SCE program.

Include amount of SCE funds allocated Describe identified strategies aligned with CNA Identify supplemental resources for SCE Include measurable performance objectives Set timelines for monitoring strategies and reaching goals Establish formative and summative evaluation criteria

Sample Plans

• Sample #1 – Full consolidation • Sample #2 – Federal consolidation • Sample #3 – Title I, Part A only

Schoolwide Programs DRAFT

ANNUAL EVALUATION PLAN

CIP – Annual Evaluation Plan

Annual Evaluation Plan

Federal Requirement Overview and Purpose Planning the Evaluation Tools

Federal Requirement for Evaluation Federal Register – July 2, 2004 (Vol.69, Number 127) A school operating a schoolwide program must annually evaluate the implementation of, and the results achieved by, the schoolwide program and revise the plan as necessary based on the results of the evaluation to ensure continuous improvement of students in the school.

Step 3 in Schoolwide Planning Process Campus Improvement Plan Comprehensive Needs Assessment What are our needs and where do we focus our efforts?

Campus Improvement Plan What strategies and activities will help us meet the needs?

Program Evaluation

Were we successful in addressing our needs and focus areas?

Overview of Evaluation

• • • • • • Questions to be answered in the evaluation: Are our strategies and activities working?

Are we achieving the desired outcomes?

Are all students achieving academically?

Are our lowest-achieving students improving academically?

Were our CIP goals and objectives met?

Do we need to make any changes to the CIP?

Purposes of Evaluation

• • • • • Purposes of the evaluation: Use for decision making Increase stakeholder understanding of campus progress Determine usefulness of activities in CIP Promote interest and support of program Demonstrate campus achievement of CIP goals and objectives

Planning the Evaluation

• Questions for planning the evaluation: Is the campus implementing the schoolwide program as it was intended?

• Did the campus improve student achievement in meeting the state’s academic standards to the desired level, particularly for those students who had been furthest from achieving the standards?

Planning the Evaluation

• People who may conduct the evaluation: Campus staff • Other staff from the LEA • Staff from ESC or higher education • Other technical assistance provider

Planning the Evaluation

Purpose and Intended Audience Issues and Development of Review Questions Data Collection Instruments Collection of Data Analysis and Interpretation of Results Reporting

Purpose and Audience for Evaluation • • • • The evaluation must consider: Student academic proficiency Campus instructional strategies Participation of stakeholders Parental involvement • The audience is: Anyone who has an interest in the school’s success

Issues and Development of Review Questions for Evaluation Questions to answer in the evaluation: • • • • Inputs – Did we use the resources effectively?

Activities – Did we do what we said we’d do?

Short-term effects – What were the results?

Longer-term effects – How do we track results over time?

Data Collection Instruments for Evaluation • • • Quantitative data: Test scores Attendance and participation data Anything you can count • • • Qualitative data: Surveys Interviews Observations

Collection of Data for Evaluation

• Key points to remember during data collection: Communicate purpose of evaluation • Consider needs of participants • Maintain reliability • Include significant group sizes

Analysis and Interpretation of Results • Key points to remember during data analysis: Check data for accuracy • Analyze results on multiple levels • Look for data about the campus’s progress • Look for data that indicates areas of need

Evaluation Reporting

• • • • • • Parts of the evaluation report: Background information Review questions Description of evaluation procedures Explanation of how campus analyzed data Findings of the evaluation Conclusion with recommendations

Tools for Evaluation

• NCLB Program Evaluation Tool – Region 20 Evaluation requirements for each federal program and SCE • Suggested data for completing evaluation • Evaluation worksheets for each federal program and SCE

Program

NCLB Funding Application Provision and Assurances Title I, Part A NCLB Program Evaluation Tool Statutory Requirements

Evaluation Requirement

The applicant will adopt and use proper methods of administering each such program, including the enforcement of any obligations imposed by law on agencies, institutions, organizations, and other recipients responsible for carrying out each program and the correction of deficiencies in program operations that are identified through audits, monitoring, or evaluation.

The LEA will conduct an annual evaluation of programs assisted with Title I, Part A funds and will use the findings of this and other evaluations in modifying and improving the program. Evaluation results are to be disaggregated within each LEA and campus by the following: • gender • major racial and ethnic group • English proficiency status • migrant status • students with disabilities as compared to nondisabled students • economically disadvantaged students as compared to students who are not economically disadvantaged [P.L. 107 –110, Section 1111(b)(3)(C)]

NCLB Program Evaluation Tool Required Data to Complete Evaluation • Comprehensive needs assessment • District or campus improvement plan(s) • Student achievement data • Budget reports

• • • • • • • • • • • NCLB Program Evaluation Tool Added Value Data State assessment data TELPAS and AMAO results PBMAS and DVM reports SAT/ACT/PSAT results Advanced course/dual enrollment data Standardized tests Completion rate Promotion/retention rates Evidence of program implementation Climate surveys Demographic data

NCLB Program Evaluation Worksheet

NCLB Program Evaluation Worksheet – page 2

Schoolwide Programs DRAFT

CHOOSING A CONSOLIDATION PLAN

Choosing a Consolidation Option

Choosing a Consolidation Option Overview and Federal Requirements 3 Options Comparison of 3 Options Additional Requirements

Federal Requirement for Consolidation Federal Register –July 2, 2004 (Vol.69, Number 127) The U.S. Secretary of Education authorizes a schoolwide program…….to consolidate funds from Federal education programs that the Secretary administers and exempts the school from complying with many statutory or regulatory provisions of those programs, if the intent and purposes of the programs are met in the schoolwide program.

Federal Requirement for Consolidation Elementary and Secondary Education Act of 1965 • Exemption • Requirements • Records

Overview of Consolidation

Single Budget Pool - Campuses can consolidate their Title I, Part A grant funds, or their Title I, Part A funds and other funds, into a single budget “pool.”

Overview of Consolidation

Using Pool Funds - Funds in the pool belong to the schoolwide program budget instead of many individual budgets, and the campus can use the pool to pay for any activity that improves the entire educational program of the campus.

Overview of Consolidation

Requirements - This consolidation eases some of the usual fiscal and programmatic requirements that apply to federal grant funds.

3 Options for Consolidation

• Full consolidation • Federal consolidation • Title I, Part A

Full Consolidation

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Full consolidation for a schoolwide program:

Pooling some or all of the campus federal funds with state and local funds Provides the most flexibility in operating a schoolwide program

Federal Consolidation

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Federal consolidation for a schoolwide program:

Pooling some or all of the campus federal funds, but no state or local funds

Title I, Part A Consolidation

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Title I, Part A consolidation for a schoolwide program

Does not pool any funds for the campus Allows campus to use its Title I, Part A funds on a schoolwide basis

Decisions for Consolidation

Local education agencies can choose different options and include different fund sources for consolidation on each campus.

You must account for all expenditures for any federal funds that are not consolidated.

Comparison of Consolidation Options • • • • • • Flexibility Eligible funds Identification of funds Use of funds Specific allowable costs Basic operational expenses • • • • • Accounting Records Time and effort Amendments Supplement not supplant

Flexibility for Consolidation

Requirements

General fiscal activities

Option 1 Full consolidation

Most flexibility

Option 1 Federal consolidation

Some flexibility

Option 3 Title I, Part A only

Least flexibility Local control Most flexibility Some flexibility Least flexibility Ability to try innovative programs Most flexibility Some flexibility Least flexibility

Eligible Funds for Consolidation

Option 1 Full Consolidation and Option 2 Federal Consolidation

All federal education funds (formula and discretionary) that come from programs administered by USDE are eligible.

• Must be used to carry out activities on a public elementary or secondary campus

Option 3 Title I, Part A only

Only Title I, Part A funds are eligible.

• Does not include Head Start or National School Lunch programs • IDEA, Indian Education, Migrant Education grants are eligible but have additional requirements

Fund Identification for Consolidation

Option 1 Full Consolidation and Option 2 Federal Consolidation

CIP must identify specific program funds consolidated and dollar amounts contributed to schoolwide program budget.

Option 3 Title I, Part A only

CIP must include the dollar amount of all Title I, Part A funds in the schoolwide budget.

CIP must demonstrate that schoolwide program contains sufficient resources and activities to reasonably address intents and purposes of each consolidated program, particularly for lowest-performing students.

CIP must specify each activity that will be provided using Title I, Part A funds.

Use of Funds for Consolidation

Option 1 Full Consolidation and Option 2 Federal Consolidation

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Consolidated formula funds

Address intents and purposes of all programs Address needs of intended beneficiaries Do not need to meet most of the individual statutory and regulatory requirements for each program for funds that are consolidated •

Consolidated discretionary funds

Must carry out all the activities as described in the program grant application •

Option 3 Title I, Part A only

Must use Title I, Part A funds to address specific educational needs of campus as identified on CNA and listed in the CIP • Activities and services are allowable if they meet the intents and purposes of Title I, Part A

Allowable Costs for Consolidation

Option 1 Full Consolidation Option 2 Federal Consolidation and Option 3 Title I, Part A only

• • • Schoolwide budget may support any service or activity of the schoolwide program that was: • Identified in CNA included in the CIP Allowed by state and federal law Schoolwide budget may only support a service or activity that: Supports the educational or instructional needs of the campus as identified in CNA and included in CIP Costs must meet any additional requirements given in OMB Circular A-87.

Operational Expenses (Maintenance, Repairs, Landscaping)

Option 1 Full Consolidation

Consolidated funds: • Lose their programmatic identity •

Option 2 Federal Consolidation and Option 3 Title I, Part A only

Consolidated funds: Can pay only for educational or instructional expenses • May use schoolwide budgets for basic operational expenses Campus must still receive full allocation of state and local funds sufficient to provide for these expenses (supplement, not supplant) • Cannot be used for basic operational expenses Basic operational expenses are also not allowable under OMB Circular A-87.

Accounting

Option 1 Full Consolidation and Option 2 Federal Consolidation

You do not need to track consolidated federal funds to activities that are allowable under individual programs.

Option 3 Title I, Part A only

Because Title I, Part A funds are not consolidated with other federal, state, and local funds: • You must account for and track the Title I, Part A funds separately • You must identify the activities supported by Title I funds

Maintaining Records

Option 1 Full Consolidation

Campus does not need to maintain separate fiscal accounting records by federal program to demonstrate that an activity in CIP may be supported by consolidated federal funds.

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Option 2 Federal Consolidation

If you consolidate only federal funds, including Title I, Part A: You must keep records that demonstrate the use of federal funds including Title I, Part A to support activities that address the specific educational needs identified by CNA and included in CIP.

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Option 3 Title I, Part A only

If you consolidate only Title I, Part A funds: You must keep records that demonstrate use of Title I, Part A funds to support activities that address specific educational needs identified in CNA and included in CIP.

Time and Effort

Option 1 Full Consolidation

Employees paid entirely from the schoolwide pool are not required to maintain signed semi annual certifications or any other form of time and effort records.

Option 2 Federal Consolidation and Option 3 Title I, Part A only

Employees paid entirely from the schoolwide pool must maintain signed semi-annual certifications. However, if campus consolidates funds from programs covered by Ed-Flex, semi-annual certification requirement is waived.

Employees paid partially from a federal fund that is not consolidated must maintain time and effort records in accordance with OMB Circular A-87 or substitute time and effort system approved by TEA.

Employees paid partially from a federal fund that is not consolidated (or from a federal program not covered by Ed-Flex) must maintain time and effort records in accordance with OMB Circular 87-A or a substitute time and effort system approved by TEA.

Budget Amendments

Option 1 Full Consolidation and Option 2 Federal Consolidation Option 3 Title I, Part A only

Amendments are not required if you use class object code 8911, Operating Transfer Out.

For funds not budgeted under class-object code 8911, amendments may be required.

Amendments are required because funds are budgeted by program fund source and class-object code.

Supplement, not Supplant

Option 1 Full Consolidation

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

Option 2 Federal Consolidation

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

Option 3 Title I, Part A only

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

• Does not need to demonstrate that any particular service is supplemental to state and locally funded services • Does not need to demonstrate that any particular federally funded service is supplemental to state or locally funded services • Does not need to demonstrate that any particular Title I, Part A-funded service is supplemental to state and locally funded services

Additional Requirements for Certain Federal Programs • Individuals with Disabilities Education Act, Part B (IDEA-B) • Section 8003(d) of ESEA • Indian Education • Migrant Education

Additional Requirements IDEA-B • • May consolidate Amount consolidated must not exceed:

IDEA-B $ LEA X SWP

IDEA-B $ - current year LEA funding amount for IDEA-B LEA – number of children with disabilities in LEA SWP– number of children with disabilities participating in schoolwide program

IDEA-B Example

IDEA-B $ LEA X SWP

$100,000/500 disabled students in LEA = $200 $200 x 30 disabled students on schoolwide campus = $6,000 maximum that can be consolidated from IDEA-B

Additional Requirements IDEA-B • Consolidated IDEA-B funds must be considered federal funds to ensure compliance with excess cost and maintenance of effort for IDEA-B

Additional Requirements Section 8003(d) of ESEA • • • May consolidate funds for students with disabilities under Section 8003(d) of ESEA If consolidate IDEA-B or Section 8003(d) funds, may use those funds for any activities included in schoolwide CIP But must comply with all other IDEA-B requirements to the same extent as if they did not consolidate

Additional Requirements Indian Education • May consolidate Indian Education funds from Subpart 1 of Part A of Title VII of ESEA only if parent committee for Indian Education program approves

• Additional Requirements Migrant Education Schoolwide campus must consult with: – – Parents of migrant students and/or Organizations representing those parents • Schoolwide campus must document it has met TEA’s 11 migrant student performance criteria • Schoolwide campus must have written approval from TEA Migrant Education program staff

Schoolwide Programs DRAFT

FISCAL ISSUES

Fiscal Issues

Fiscal Issues for Schoolwide Programs Overview Consolidation Review Documentation Accounting Structure and Options Carryover Other Requirements

Overview of Fiscal Issues

The key decisions and overall fiscal accountability related to Title I, Part A schoolwide programs are in the hands of the LEA.

Overview of Fiscal Issues

The decision to consolidate funds and to select a specific consolidation option is made by the campus in consultation with the LEA.

Overview of Fiscal Issues

The LEA is responsible for ensuring that all campuses maintain appropriate accounting structures and documentation and that they comply with other fiscal requirements.

Consolidation Review

• Purpose • Advantages • Consolidation options

Documentation Review When consolidating federal funds, the campus must document the following: • Demonstrate that the schoolwide program contains sufficient resources and activities to reasonably address the intent and purpose of included programs, particularly related to lowest-performing students.

Documentation Review When consolidating federal funds, the campus must document the following: • Maintain records that demonstrate that the schoolwide program as a whole addresses the intents and purposes of each of the federal education programs whose funds were consolidated to support it.

Documentation Review When consolidating federal funds, the campus must document the following: • Identify in its schoolwide plan the programs that have been consolidated and address how it intends to meet the intents and purposes of those programs.

Documentation Review When consolidating federal funds, the campus must document the following: • Demonstrate that it received at least the same amount of state and local funds that, in the aggregate, it would have received in the absence of the schoolwide program.

Accounting Structure The LEA is responsible for ensuring that campuses operating schoolwide programs have appropriate accounting systems in place to: • • Accommodate flexibility of fund consolidation Maintain accurate records of percentages and amounts allocated from each program

Accounting Structure • Consolidating funds into one “pool” does not mean that a campus must put all of its funds into one account with its own accounting code, although that is an option.

• Pool concept means campus can use the consolidated funds for one purpose, to operate the schoolwide program, without regard to program identity of those funds.

Accounting Structure • 3 options available • Common element – consolidated funds are not tracked to specific activities allowable under a particular program • Any federal funds not included in the consolidated schoolwide pool must be tracked and accounted for separately

Accounting Structure • State accounting guidelines require LEA to: Be able to identify expenditures for the entire consolidated pool by functional categories (salaries, travel, supplies, etc.) • State accounting guidelines do not require LEA to: Track amount spent on each category back to an allowable activity in a specific program

Accounting Structure Regardless of accounting option, these are still requirements: • • All consolidated funds and services must support the CIP All expenditures must be coded with appropriate program intent code (PIC) based on source of funds

Accounting Structure • • • Option 1: Distribution of expenditure based on proportionality of revenues (LEA-level structure) Option 2: Distribution of expenditure based on proportionality of revenues (campus-level structure) Option 3: Sequence charging of schoolwide expenditures (campus-level structure)

Option 1: Distribution of Expenditures Based on Proportionality of Revenues – LEA Level

• The LEA creates a consolidated pool, with its own locally defined accounting code, for all of the campuses operating a schoolwide program.

• Program funds in the consolidation lose their programmatic identity and may be used for any activity consistent with CIP.

Option 1: Proportionality LEA Level

Campus

A B C D E F Total Percent of total

Title I, Part A Title II, Part A

182,535 25,000 115,455 181,780 141,900 25,000 25,000 110,437 229,460 169,860 1,020,990

8%

110,437 110,437 406,311 3%

Perkins CTE

10,685 20,071 23,686 22,351 27,546 23,796 128,135 1%

Title III, Part A

94,462 27,709 69,272 93,202 61,715 54,158 400,518 3%

State and Local

2,048,115 1,380,884 1,940,161 1,999,902 1,936,291 1,525,307 10,830,660 85%

Total by campus

2,360,797 1,569,119 2,239,899 2,367,792 2,365,449 1,883,558 12,786,614 11%

Option 2: Distribution of Expenditures Based on Proportionality of Revenues – Campus Level

• • The LEA establishes a consolidated schoolwide pool from which an individual campus uses all or a portion of the federal, state, and local funds it receives to support its schoolwide activities consistent with the schoolwide plan.

The LEA, for accounting purposes, still attributes expenditures of those funds back to a specific program regardless of what services those funds support.

Option 2: Distribution of Expenditures Based on Proportionality of Revenues – Campus Level

• • The LEA may use any reasonable method to demonstrate that the funds in a schoolwide program have been expended. This option uses proportionality.

The LEA allocates expenditures of federal funds in a schoolwide program in proportion to the funds provided to the campus.

Source of Funds

Total State and Local Funds (included in SWP) Federal Programs (included in SWP) Title I, Part A Title II, Part A Title III, Part A Perkins CTE Option 2: Proportionality Campus Level

Revenues

$1,000,000

Percent of Total

100% 520,000 240,000 40,000 120,000 80,000 52%

24%

4% 12% 8%

Expenditures $950,000

494,000

228,000

38,000 114,000 76,000

Option 3: Sequence Charging of Schoolwide Expenditures – Campus Level

• This option is similar to Option 2 except that the LEA charges 100% of all schoolwide expenditures in a campus first to state and local sources and then to Title I, Part A and other federal programs until these funds are spent in their entirety or until the maximum carryover amount is all that remains unexpended.

Option 3: Sequence Charging Campus Level

Source of Funds Revenues Total Expenditures ($950,000) charged to federal, state, and local programs Amount Remaining

Total in SWP pool State and Local Funds Federal Programs Funds Title I, Part A Title II, Part A Title III, Part A Perkins CTE $1,000,000 520,000 240,000 40,000 120,000 80,000 520,000 240,000 40,000 120,000 30,000 $50,000

Fiscal Issues – Carryover of Funds

• Must meet all programmatic carryover requirements • Certain grants do not permit carryover • Certain grants limit the amount of carryover

Carryover of Funds

• Campuses that operate schoolwide programs must calculate the actual amount of funds that can be carried over from each fund source based on the accounting structure in use.

Carryover – Proportionality

• The carryover amount for each program is based upon the same proportionate percentage contributed to the schoolwide budget.

• For example, if Grant A contributed 20% of its funds to the schoolwide budget, then 20 % of the unspent funds that are left in the schoolwide budget after all expenditures have been paid should remain in Grant A as carryover (if allowable and only up to the established limit, if applicable).

Carryover – Sequence Charging First Method • • • Estimate the carryover amount for federal grants at the beginning of the grant period.

Review spending data from previous years Estimate the percentage of the schoolwide budget that will be likely be spent Draw down funds through the grant period from each fund source up to that estimated percentage, leaving the remainder unspent

Carryover – Sequence Charging First Method - Example • • • Campus estimates it will likely spend 80% of its schoolwide budget Campus draws down funds from each federal fund source until 20% of each fund remains unspent The 20% remains in each grant as carryover

Carryover – Sequence Charging Second Method If the campus spends more than its estimated percentage, it must then use the second method to determine carryover for each program.

Carryover – Sequence Charging Second Method • • • Calculate the percentage of the total schoolwide budget left unspent at the end of the grant period Apply this percentage to the amount actually contributed to the schoolwide budget by each fund source This gives you the amount you should apportion to each program as carryover

Carryover – Sequence Charging Second Method - Example • • • Campus calculates that 3% of total budget was unspent You calculate 3% of the amount contributed by each fund source Apportion 3% for each fund source as its carryover amount

Other Requirements

• Comparability of services The LEA must ensure that it gives campuses that receive Title I, Part A funds the same level of services through state and local funds as campuses that do not receive Title I, Part A funding.

Other Requirements

• • Distribution of formula funds to campuses LEAs that have both schoolwide and non schoolwide campuses must distribute all formula funds according to the authorizing statute. The presence of schoolwide campuses does not give the LEA authority to redistribute formula funds among its campuses.

Other Requirements

• Maintenance of Effort (MOE) This requirement applies to LEAs that receive federal funds under the Elementary and Secondary Education Act of 1965 (ESEA).

• Schoolwide programs must comply with this requirement.

Other Requirements

Set-aside – professional development • Campuses that receive Title I, Part A funds are required to spend 10% of their Title I, Part A funds on professional development (if TEA has identified the campus or its LEA as being in need of improvement – priority and focus schools).

Other Requirements

Set aside – professional development • The campus must show that it spent an amount equal to 10% of its Title I, Part A allocation on professional development.

• This amount does not have to be taken from Title I, Part A funds.

Other Requirements

Set aside – parental involvement • Campuses that receive Title I, Part A funds are required to spend 1% of their Title I, Part A funds on parental involvement activities (if the entitlement of the LEA exceeds $500,000).

Other Requirements

• • Set aside – parental involvement The campus must show that its parental involvement activities consumed, at a minimum, an amount equal to the amount of Title I, Part A parental involvement funds the school received from its LEA.

The campus does not need to provide these activities with Title I, Part A funds, but must meet all the programmatic requirements specified in the law, not just the “intents and purposes.”

Other Requirements

Supplement, not supplant • A campus operating a schoolwide program is not required to demonstrate that any particular service is supplementary to the services regularly provided on that campus to all students.

Other Requirements

Supplement, not supplant • • The LEA is responsible for ensuring that the campus receives all of the state and local funding it would otherwise receive if it did not receive Title I, Part A funds.

The LEA must be prepared to demonstrate that state and local funds are distributed to campuses fairly and equitably.

Other Requirements

Time and effort • • Employees paid entirely from a schoolwide pool using full consolidation are not required to keep signed semi-annual certifications or any form of time and effort records.

See Comparison of Consolidation Options handout from previous training section for more information on time and effort.