The Special Education Budget

Office of Special Programs

MAY 2013

Goals and Objectives

• • • • Overview of allowable costs Complete a draft budget spreadsheet – Matching to categories within the plan – Budget spreadsheets and coding Review of financial data report-WVEIS report of revenue, budget and expenditures – Helpful in assuring budget aligns with plan, monitoring carryover, preparation of budget revisions Review of Obligation and Liquidation Definitions and Dates

IDEA Part B and OMB Circular A-87 OSEP Clarifications

OMB Circular A-87 IDEA Part B and OMB Circular A-87

• • •

U.S. Dept. of Ed Requirements

EDGAR – Education Department General Administrative Regulations – Gives authority to OMB circulars General Education Provisions Act - GEPA Office of Management and Budget (OMB) – OMB Circular A-133 – Single Audit – Compliance Supplement Part 4 – OMB Circular A-87

Allowable Cost

• • •

§ 300.202 Use of amounts.

Must be expended in accordance with the applicable provisions of this part.

Must be used only to pay the excess costs of providing special education and related services to children with disabilities.

Must be used to supplement State, local, and other Federal funds and not to supplant those funds.

Allowable Cost

• • • • §300.208-Permissive Use of Funds (1) Services and aids that also benefit

nondisabled children --

when incidental to services already being provided to students with disabilities (2) Early intervening services

(3) High cost special education and related services.

(b) Administrative case management. – Purchase appropriate technology for recordkeeping, data collection, and related case management activities

• • • • •

Helpful Questions to Ask to Determine if a Cost is Allowable

Is the proposed cost consistent with federal cost principles?

Is the proposed cost allowable under the relevant program?

Is the proposed cost consistent with an approved program plan and budget?

Is the proposed cost consistent with program specific fiscal rules?

Is the proposed cost consistent with EDGAR?

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•

Basic Guidelines of Cost Principles All costs must be:

o

Necessary

o

Reasonable

o

Allocable

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Basic Guidelines: Necessary

Do I need to spend these funds to meet the purposes and needs of the program?

 Costs must be necessary and reasonable for proper and efficient performance  Costs are necessary and reasonable if, in nature and amount, they do not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost 9

Basic Guidelines: Reasonable

• Practical aspects of “reasonable” – Is the expense targeted to a valid programmatic or administrative consideration?

– Do I have the capacity to use what I am purchasing?

– Did I pay a fair rate? Can I prove it?

– Would I be comfortable defending this purchase?

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Basic Guidelines: Allocable

• Practical aspects of “allocable” – Can I prove the program benefited?

– Can I prove other programs are not benefiting?

•

Ensuring only authorized use

•

Incidental benefit

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Basic Guidelines: Allocable

• • Can only charge in proportion to the value received by the program Example: LEA purchases a computer to use 50% in federal program and 50% in a state program – Can only charge half of the cost to the federal program 12

OMB Circular A-87 Allowable Costs

 Establishes principles and standards for determining allowable costs  You have to read A-87 in conjunction with the IDEA to understand how it applies  To the degree there is any conflict, IDEA requirements take precedence 13

Selected Items of Cost – Examples of Unallowable Costs • Advertising & Public Relations Costs • Generally not allowable, except as specified in OMB Circular A-87, Attachment B • Entertainment • Amusement, field trip or social activities (tickets to shows or sporting events, meals, lodging, etc.) are generally not allowable 14

• • •

Selected Items of Cost – Examples of Allowable Costs

Salaries and Wages • Allowable if proper time distribution records are maintained Travel Costs • Transportation, lodging, subsistence, and related items, when traveling on business are allowable with certain restrictions Training • Training for employee development is allowable; for IDEA, professional development for special education personnel or for general education teachers regarding how to teach students with disabilities EXCEPTION: WV code does not authorize LEAs to purchase food for staff except for travel reimbursement 15

OMB Circular A-87 Allowable Costs-Appendix B

Complete document may be reviewed at: • Office of Management & Budget (OMB) Circulars : A -87; A- 133 http://www.whitehouse.gov/omb/circulars

OMB CIRCIULARS ARE BEING REVISED INTO ONE GUIDANCE DOCUMENT CURRENTLY ON COMMENT – GUIDANCE ANTICIPATED IN FY 14

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IDEA Part B

• IDEA Part B specific examples of use of funds: – FAPE – Special education teachers and administrators – Related services providers – Materials and supplies for students with disabilities – Professional development for special education personnel or to assist general education personnel in teaching special education students

IDEA Part B

• • Specialized equipment or devices to assist children with disabilities Two exceptions: – Title I/IDEA schoolwide programs – Coordinated early intervening services for students without disabilities needing academic or behavioral support to succeed in general education

Coordinated Early Intervening Services (CEIS)

Purpose from Congressional Committee Report:

…and early intervening services to reduce the need to label children as disabled in order to address the learning and behavioral needs of such children

U.S. Department of Education Office of Special Education Programs Building the Legacy 2004 19

CEIS

With an approved plan, the LEA may (or in some cases is required to) use up to 15% of IDEA funds for: – Professional development – Providing educational and behavioral evaluations, services, and supports, including scientifically-based literacy instruction U.S. Department of Education Office of Special Education Programs Building the Legacy 2004 20

• • •

Categories Within the On-line Plan – Action Steps/Subtasks

Within each action step category, specify the activity being funded/item purchased May need to specify source of funds when needed for clarity (IDEA B, IDEA Preschool, State aid); Specify it is for students with disabilities or exceptionalities when needed for clarity

Sections/Program Codes Across IDEA and State Aid

Chart of Accounts • • • • Program/function codes: 2xxxx- Special Education Services (Public) 1xxxx - Coordinated Early Intervening Services 5xxxx - Services for Students with Disabilities Parentally Placed in Private Schools Project Codes funds ( 43Y1X School Age & 43Y2X Preschool Entitlement) and 02Y1X will identify State Aid – 43YXX will identify IDEA Project 00Y83 – Medicaid reimbursement funds

Action Step/Budget

Personnel

– Program/function code, FTE and type of position • • • •

Examples:

multicategorical sp. ed teacher – 21210 speech language pathologist – 22150 teacher of autism 21232 Preschool developmental delay - 21282

Action Step/Budget

Services

– Describe the contracted services to be provided (e.g. physical therapy/ occupational therapy; speech) Object code – 341 – other professional services Program/function codes: - 22150 speech/language - 22160 occupational/physical therapy Budget program/function codes specific to the type of service to be identified in the WVEIS budget

Action Step/Budget

•

Services

Includes tuition for students placed out of state by DHHR/Courts (state aid) Object Code – 563 – Tuition to private schools Program Function - 21210

Action Step/Budget

•

Materials/Supplies/Equipment

– Be specific; describe what will be purchased – Break down large amounts into specific types identified by object code • • • Examples: Supplemental materials – Wilson Reading Technology hardware- computers for SWD General supplies – for special ed classrooms Equipment When individual item is $5,000 or over, the Equipment Section under Compliances must be completed.

Action Step/Budget

Materials/Supplies/Equipment (cont’d)

– Budget object codes, specify supplemental materials, software, hardware, general supplies • • • • 611 – General supplies 651 – General technology supplies (diskettes, toner) 652/656 – Hardware for students/staff (below control level and capitalization threshold) 653/657 – Software for students/staff (below control level and capitalization threshold) – For IDEA preschool funds, program/function should be specific to preschool (e.g. 21282) – For IDEA school age funds used for general supplies and materials, multi-categorical code is permitted (21210)

Action Step/Budget

•

Professional Development

– Professional development activities entered into the Five-Year Strategic Plan and linked to IDEA or State Aid funding.

Reference the staff development activity and how the funding will be expended (i.e. presenter, teacher stipends, etc.) – Program/function 22213 – Identify expenditure by object code • Travel (580 general/581 in county/582 out of county) • • Substitutes (131 Professional/141 Service) Stipends (114 Professional/124 Service)

Action Step/Budget

•

Coordinated Early Intervening Services

– Include Action Step/Subtask, then describe in full in the Early Intervening Section under Compliances – Budget program function codes will begin with 1xxxx to indicate this is a general education expenditure

Action Step/Budget

Services to Students Parentally Placed in Private Schools – Required for Proportionate Share

• Subtasks specify the services provided to implement service plans • May include expenditures for professional development for teachers to work with private school students with disabilities • May include materials/supplies/equipment to implement service plans • All items remain in control of the public schools and are returned to public schools when no longer needed to provide services to SWD – Budget program/function code 5xxxx allows tracking of required expenditures

Action Step/Budget

Facilities

• If funds are spent on facilities/construction, must include detailed plan under the Compliances section

Action Step/Budget

Other

• Expenditures not included in other steps (e.g., indirect, travel, CSADA teams) • Indirect amount is provided by OSP (Budget code 7xxxx)

• • •

Budget Spreadsheet & Coding

Submitted budget from WVEIS will populate the Budgets – LEA Special Education tab in the On-line plan sometime after June 1 in the plan Work with your Chief School Business Official to get it right the first time Grant awards will not be forwarded until WVEIS budget is accurate • • • •

Chart of Accounts

http://wvde.state.wv.us/finance/ Revisions needed must be made after July 1 through the budget revision process Grant awards will not be forwarded until the needed changes are approved by OSP.

• • • •

Budget Spreadsheet

Excel spreadsheet updated for FY13 – e-mail to Sandra McQuain to assist in review of WVEIS budget WVEIS budget FTEs, program/function and object codes must be specific and match activities described in the subtasks Use WVDE Chart of Accounts for codes

• • • •

Project Financial Reports

Good tool to assist in monitoring budget/expenditures Select county Select project – 02 – state special education – 43 – IDEA funds Select fiscal year May select specific months

http://wveis.k12.wv.us/surveys/genledger_projects_years.cfm

Budget Revisions

Expenditure of IDEA funds should align with the special education online plan that is submitted to the SEA and approved for use of funding and subsequent approved budget revisions.

– A cumulative deviation from the purpose as outlined in the online plan in excess of 10% of the total award amount must be supported by an approved budget revision request.

– Watch ending obligation dates and submit budget revision to realign activities as needed to secure approval prior to deadlines to avoid losing expiring funding. – May need to complete a budget revision at year end to realign remaining budget balances rather than just carrying over unexpended balances into the new year in the same accounts.

Budget Revisions

• • • • Follow process outlined in OSP budget revision memo • http://wvde.state.wv.us/osp/BudgetRevisionReque sts2010.pdf

Submitted by finance office Special education director should approve (LEA determines process) CSBO creates budget journal entry and submits via through WOW (WVEIS on the WEB) OSP reviews and CSBO will receive an e-mail with approval or explanation of required corrections.

Budget Revisions Examples Reasons for Revision

• • •

EXAMPLE 1

Insufficient – This revision is to “clean up” accounts at end of year.

Acceptable – Transfers to cover under budgeted items in related services by reducing the amounts in accounts that had excess funds due to over budgeting. (This would be appropriate for small balances

and deficits in accounts at the end of the year. Larger deficits or balances should be explained more specifically.)

Acceptable – Excess funds in accounts due to over budgeting are being transferred to cover the salaries and fixed costs for two new multi-categorical special education teachers and to technology to purchase laptop computers and printers for the teachers to facilitate online IEP development. (Example for larger amounts.)

Budget Revisions-Examples

• • •

EXAMPLE 3

Insufficient – Moving funds from supplies to equipment (or vice versa).

Acceptable – Funds budgeted for supplies are being transferred to purchase an assistive technology device for a special education student. Acceptable – Additional funds are required in supplies for the implementation of students’ IEPs. The excess funds are being taken from equipment as the number of computers purchased was less than originally budgeted .

OBLIGATION AND LIQUIDATION-Definitions • Obligation – EDGAR §76.707

If the obligation is for- The obligation is made--

(a) Acquisition of real or personal property (b) Personal services by an employee On the date on which a binding written commitment to acquire the property.

When the services are performed.

(c) Personal services by a contractor who is not an employee (d) Performance of work other than personal services (e) Public utility services On the date on which a binding written commitment is made to obtain the services.

On the date on which a binding written commitment is made to obtain the work.

When the services are received.

(f) Travel When the travel is taken.

(g) Rental of real or personal property When the property is used.

•

Liquidation

-The issuance of payment for an obligation.

Obligation and Liquidation

Cash Management Improvement Act • LEAs must draw down cash from grant awards to pay expenses only as they are incurred. Interest earned on federal cash draws held in excess of three days require the remission to the SEA of interest earned on that excess.

• Exhaust FY 12 funding before using FY 13 funding.

• Check balances of FY 12 funding – Ending obligation date is September 30, 2012 and ending liquidation date is

October 31, 2013.

Obligation and Liquidation Availability of IDEA Funds

FY 12



Obligation period

› July 1, 2011 – September 30, 2013 

Ending liquidation date

› October 31, 2013 (note change from previous years)

FY 13



Obligation period

› July 1, 2012 – September 30, 2014 

Ending liquidation date

› October 31, 2014 Timelines

FY 14



Obligation period

› July 1, 2013 – September 30, 2015 

Ending liquidation date

› October 31, 2015

Questions

Janice Hay, Coordinator Office of Internal Operations (304) 957-9833, ext. 53423 [email protected]

Sandra McQuain, Ed. D., Assistant Director Office of Special Programs (304) 558-2696 [email protected]