Transcript Read, wRite, and Report

Read, wRite, and Report
Applications
Rules and Regs
Reporting Requirements and
Auditors
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Read
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Available Information
• www.isbe.net
• http://www.isbe.net/speced/html/idea_part-b.htm
• http://www.isbe.net/arra/pdf/arra_r
eporting_inst.pdf
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Helpful Internet Sites
ARRA Recovery Site :
http://www.recovery.gov/
ARRA Department of Education Guidance
http://www.ed.gov/policy/gen/leg/recovery/index.html
ARRA-IDEA Part B Department of Education Guidance
http://www.ed.gov/policy/gen/leg/recovery/guidance/ideab.pdf
State or Federal Project and Payment Information:
http://206.166.105.128/FRISInquiry/
IDEA 2004
http://idea.ed.gov/explore/home
USDE – Office of Special Education
http://www.ed.gov/about/offices/list/osers/osep/index.html
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wRite
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Important Terms
• Excess Cost
• Supplant
• Maintenance of Effort (MOE)
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Excess Cost
• The LEA must maintain its local and state
fiscal effort (spending) for the education
of children with disabilities before federal
funds are used.
• This prevents LEAs from using federal
funds to pay for all costs of special
education
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Supplant
sup plant (transitive verb)
1. oust somebody
2. replace
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New Guidance on Supplanting
If the LEA maintains (or exceeds) its
level of local, or state and local,
expenditures for special education and
related services from year to year,
either in total or per capita, then the
Part B funds are, in fact,
supplementing those local, or state
and local, expenditures and the LEA
has met its MOE and supplement/not
supplant requirements.
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Maintenance of Effort
Spending the same or greater amount
of money (as was spent the previous
year) from local funds to support
special education.
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What is MOE?
The Federal Standard is:
“An LEA…must ensure that the amount
of local funds it budgets for the
education of children with disabilities in
that year is at least the same…as the
amount it spent for that purpose in the
most recent fiscal year for which
information is available…”
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Exceptions to MOE
• Through normal attrition, qualified lower-salaried
staff replace higher-salaried staff
• Decrease in enrollment of children with
disabilities
• Termination of obligation to a particular child
that is exceptionally costly
• Termination of costly expenditures
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Use of IDEA Funds
Federal and state funds may be used
for such expenditures as are
reasonably necessary for providing
appropriate programs and meeting
the requirements of the law.
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Allowable Expenditures
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Staff salaries/benefits
Supplies/materials
Equipment
Other items necessary to sp. ed.
program
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Costs not permitted
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Private school tuition
Matching funds for grants
Debt reduction
Attorney’s fees for representation
Other expenditures not directly
related to the grant activities
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Out of State Travel
• Requires pre-approval
• Complete form and fax or mail to
grant coordinator
(Page 29 in “Blue Book”)
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Early Intervening
Services (EIS)
• May use up to 15% of funds for EIS
• Use of funds is specific
(page 16 in “Blue Book”)
• Documentation will be needed
Who is targeted?
What happens?
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Proportionate Share
• Funds are to serve students with
disabilities in non-public schools. Figure is
calculated at ISBE and published at
http://www.isbe.net/funding/html/specialed.htm
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Grant Management
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There are rules . . .
Federal & State regulations
EDGAR & A133
(Pages 6-7 in “Blue Book”)
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Putting things in place
• Record keeping and office
procedures are important
• Pages 30-32 in “Blue Book”
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FRIS Inquiry
• Financial Reimbursement Information
System
• You can find budgets, payments,
expenditure reports and more
• Find it at www.isbe.net
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Expenditure Reports
• Due quarterly
• Sent electronically
• Contact Sharon Conrath
at 217/782-5256
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Frozen Funds!!!!
• Excess cash on hand
• Late expenditure reports
• Non-compliance with
regulations
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eGrant Application
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How to submit a grant:
In IWAS:
• Click “system listing”
• Select grant
• Click Yes
• Give your grant a title
• Click “create new project”
• Move through all tabs to complete
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A Few Tips . . .
• To start grant, click Yes
• Save early save often
• No save button – may be locked
• Hold down Ctrl for checklist
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Important Details
• Remember to list staff names
• Describe types of benefits
• Itemize supplies / materials
• Equipment is $500+ per unit
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Cooperative Grants
• The Cooperative is the AA
• The AA must allocate funds to
member districts (green zero)
• The AA is responsible for all
funds
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Things we’ve learned from
reviewing audit findings!
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Some findings are worse than others.
Some findings have questioned costs.
Findings affect LEA determination.
Findings always require an action plan.
Many people do not read the “Accounting
Procedures” section in the instructions.
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Uses of ARRA Funds
• Must be consistent with the current IDEA Part
B statutory and regulatory requirements.
• Funds should be used for short-term
investments that have potential for long-term
benefits
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Possible ARRA IDEA
uses:
• Assistive technology and training.
• Intensive district-wide professional
development for special education.
• Develop and expand the capacity to
collect and use data.
• Expand placement options for
preschoolers.
• Hire transition coordinators.
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ARRA IDEA Funding
All ARRA IDEA funds allocated to
cooperatives and districts will be
available until September 30, 2011.
ARRA IDEA funds cannot be obligated
after that date.
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Report
General Reporting Requirements
Note: Presentation is based on preliminary information
regarding reporting known as of 9/14/09 and is subject
to change.
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Tracking ARRA Funds
• The State (SEA) is required to report
ARRA funds separately
• SEA must maintain accurate
documentation of all expenditures
• SEA must ensure data quality and proper
expenditure of ARRA funds
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Questions Reports Must Answer:
• Who is receiving ARRA funds?
• How much are they receiving?
• What projects or activities are being
funded?
• What is the completion status of the
projects?
• What impact on job creation and
retention?
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When Are Reports Due?
• ARRA requires that the state’s report on
the use of ARRA funding is due no later
than the 10th day after the end of each
calendar quarter.
• Due to the short timeline, LEAs will need
to transmit ARRA data before the day
that the state’s report is due.
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Federal Oversight Authority
• OMB, Recovery Board, Office of
Inspector General
Establish data quality expectations
Establish data and technical standards
Coordinate any centralized reviews of
data
• Findings by a Federal agency can result in
termination of Federal funding
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Cautions
• No waivers will be granted regarding
required reporting
• Reporting elements cannot be combined with
other Federal reporting requirements
• Prime recipient (state) must avoid double
counting
• Non-compliance with reporting requirements
is considered a violation of the award
agreement and reports may be used to
assess compliance with award agreements
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Who Reports?
• Prime recipients (States) have the primary
responsibility for reporting all data.
• Sub-recipients (Districts) must report to
the state.
• Reports are expected to meet the
requirements of recent legislation
regarding reporting.
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Prime Recipient
• Owns recipient data
• Initiates appropriate data collection and
reporting procedures
• Implements internal control measures to
ensure accurate and complete information
• Performs data quality reviews and makes
appropriate and timely corrections
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Sub-recipients
• Own sub-recipient data
• Initiates appropriate data collection and
reporting procedures
• Implements internal control measures to
ensure accurate and complete information
• Reviews information and makes
appropriate and timely corrections
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Vendors
If a sub-recipient (i.e. district or cooperative) awards ARRA
funds greater than $25,000 to a vendor for services needed to
carry out the project or program, the sub-recipient must report
the identity of the vendor by reporting the DUNS number, if
available, or otherwise the name and zip code of the vendor’s
headquarters.
A vendor is defined as a dealer, distributor, merchant, or other
seller providing goods or services that are required for the
conduct of the program.
A vendor:
(1) Provides the goods and services within normal business operations;
(2) Provides similar goods or services to many different purchasers;
(3) Operates in a competitive environment;
(4) Provides goods or services that are ancillary to the operation of
the Federal program; and
(5) Is not subject to compliance requirements of the Federal program.
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Required Data Elements
• Sub-recipient
DUNS
• Sub-recipient type
• Amount received
• Amount awarded
• Sub-award date
• Sub-award period
• Place of
performance
• Area of benefit
• Officer names and
compensation
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ARRA Reporting Variables
• All districts and cooperatives must have a Nine
Digit Dun and Bradstreet (DUNS) number
assigned http://fedgov.dnb.com/webform
• Central Contracting Registration (CCR) – you must
have a DUNS number to register at CCR. More
information available at http://www.ccr.gov
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Expenditure Reports
• Transfer of funds by a cooperative to a
member district’s subgrant does not
constitute an expenditure.
• Cooperatives must ensure member
districts have expended funds that were
subgranted and report the aggregated
expenditures on their quarterly and final
expenditure reports.
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ARRA Reporting Variables
All expenditure and other ARRA data must be
reported CUMULATIVELY or year-to-date from the
point that each LEA began expending ARRA funds
through the end of each quarterly reporting period.
Each subsequent quarterly report will also be
cumulative. In other words, the report due January
2010, will include the data reported through
September 2009 and be updated to include data that
accumulated through December 2009. ISBE will
aggregate all ARRA expenditures across fiscal years
for each LEA.
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Jobs Created and Retained
A job created is a new position created and filled; a job retained
is an existing position that would not have been continued were it
not for ARRA funding.
FTE – Full Time Equivalency
Enter the FTE for each position. This is calculated as total hours
worked divided by the number of hours in a full-time schedule.
The figure should be reflected to two decimal places.
The number reported should represent a reasonable average of
FTE’s created and retained for the quarter. Such an estimate
would ideally be done by taking FTE’s for each pay period in the
quarter and averaging them. It could also be done at a single
point in time, as long as care is taken that the single point is
representative of the quarter for the position.
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Reporting on Jobs Creation
• Required to report an estimate of jobs
directly created or retained
• Number of jobs expressed as FTEs
• Report includes a job title or labor
category
• Report only on “direct” jobs
• Report on all jobs attributable to an award
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Federal Funding Accountability and
Transparency Act (FFATA)
Not later than January 1, 2008, the Office of Management and Budget
shall, in accordance with this section, section 204 of the E-Government
Act of 2002 (Public Law 107-347; 44 U.S.C. 3501 note), and the Office
of Federal Procurement Policy Act (41 U.S.C. 403 et seq.), ensure the
existence and operation of a single searchable website, accessible by the
public at no cost to access, that includes for each -(A) the name of the entity receiving the award;
(B) the amount of the award;
(C) information on the award including transaction type, funding
agency, the North American Industry Classification System code
or Catalog of Federal Domestic Assistance number (where
applicable), program source, and an award title descriptive of the
purpose of each funding action;
(D) the location of the entity receiving the award and the primary
location of performance under the award, including the city,
State, congressional district, and country;
(E) a unique identifier of the entity receiving the award and of the
parent entity of the recipient, should the entity be owned by
another entity; and
(F) any other relevant information specified by the Office of
Management and Budget.
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Reporting MOE
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Reporting Requirement
Districts that choose to supplant
must track these funds separately
so that it can be substantiated that
the supplanted funds were used for
other ESEA programs.
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New Guidance on Supplanting
If the LEA maintains (or exceeds) its level
of local, or state and local, expenditures for
special education and related services from
year to year, either in total or per capita,
then the Part B funds are, in fact,
supplementing those local, or state and
local, expenditures and the LEA has met its
MOE and supplement/not supplant
requirements.
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The 50% Rule
“An LEA may treat as local funds up to 50%
of the amount of funds it is eligible to
receive…from
that
appropriation
that
exceeds the amount from funds appropriated
for the previous fiscal year that the LEA was
eligible to receive…to carry out activities that
could be supported with funds under the
ESEA regardless of whether the LEA is using
funds under the ESEA for those activities.”
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For Example
FY 09 IDEA Allocation = $1,000,000
FY 10 IDEA Allocation = $1,000,000
FY 10 ARRA IDEA Allocation = $1,000,000
Total FY 10 = $2,000,000
Difference between FY 09 and FY 10 is
$1,000,000.
The 50% rule allows the district to use 50% of
this amount or $500,000 to supplant local
expenses.
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Maintenance of Effort and
the 50% Rule
The District’s MOE is $3,000,000 in FY 09
The District’s MOE is $3,000,000 in FY 10
$2,500,000
Since the 50 % rule allows the District to
use $500,000 to supplant local expenses, the
district can subtract this amount from MOE
and report the new total, $2,500,000, as the
FY 10 MOE.
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MOE Questions
• Total IDEA Flow Through and IDEA
Preschool Allocations to LEAs?
• What was the LEAs Determination status?
• Reduction of state and local funds taken in
dollars?
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Early Intervening
Services
(EIS) Reporting
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EIS questions
• Was the LEA required to use 15% for EIS due to
disproportionality?
• What was the amount the LEA was required to spend?
• Did an LEA voluntarily use up to 15% for EIS?
• What Amount was voluntarily reserved for EIS?
• Total number of children receiving CEIS under IDEA in FY
10?
• Total number of children who received EIS under IDEA
anytime in the past two school years (FY09 and FY10)?
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Contact Information
• IDEA Grant Coordinators – Bonnie Douglas
and Penny Kelly at 217-782-5589
– [email protected] and [email protected]
• Funding and Disbursements Consultants –
Kim Lewis or Sharon Conrath at 217-7825256
– [email protected] and [email protected]
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