Financial Accounting/OCAS/Auditing Nancy Hughes, Executive Director 2500 North Lincoln Blvd. Room 420 Oklahoma City, Oklahoma FEDERAL AND STATE COMPLIANCE CALCULATIONS

Special Education Maintenance of Effort IDEA 613(a)(2)(A)(iii) Funds provided to the LEA under IDEA Part B may not be used to reduce the level of state and/or local funds used to provide special education and related services. Federal requirements mandate that federal grant funds supplement (increase) not supplant (replace) existing funding for special education programs. An LEA may reduce the level of expenditures according to 34 CFR §

Special Education Maintenance of Effort The voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel. A decrease in the enrollment of a child with disabilities. (SEA already takes this into consideration for districts) The termination of costly expenditures for long-term purchases, such as the acquisition of equipment or the construction of school facilities.

Special Education Maintenance of Effort The termination of the obligation of the agency, consistent with this part, to provide a program of special education to a particular child with a disability that is an exceptionally costly program, as determined by the SEA, because the child- (1) Has left the jurisdiction of the agency; (2) Has reached the age at which the obligation of the agency to provide FAPE to the child has terminated; or (3) No longer needs the program of special education.

Special Education Maintenance of Effort The assumption of cost by the high cost fund operated by the SEA under §

§ Adjustment to Local Fiscal Efforts in Certain Fiscal Years. For any fiscal year for which the allocation received by an LEA under § exceeds the amount the LEA received for the previous fiscal year, the LEA may reduce the level of expenditures otherwise required by § (a) by not more than 50 percent of the amount of that excess. Special Rule. The amount of funds expended by an LEA for early intervening services under § shall count toward the maximum amount of expenditures that the LEA may reduce.

Example of Adjustment In FY 13, Project 621 Allocation was$150, In FY 14, Project 621 Allocation was$100, Difference$ 50, % Rule$ 25, In FY 14, the district can reduce the local and state expenditures for special education by $25,000.00

Example of Adjustment with Early Intervening Services In FY 13, Project 621 Allocation was:$150, In FY 14, Project 621 Allocation was:$100, Difference:$ 50, % Rule:$ 25, Minus Early Intervening Set Aside:$ 10, In FY 14, the district can reduce the local and state expenditures for special education by $15,000.00

FY Districts did not meet Maintenance of Effort for Special Education. State Aid will be reduced for those district who do not have exceptions and those funds will be sent to the U. S. Department of Education.

FY 15 Special Ed. MOE Calculation Funds 11 through 60, Excluding 12 and 41 Project Codes Function Codes 1000 through 3200 Object Codes 100 through 899 Program Code 239

Special Ed. MOE Calculation Old Regulation Compare Previous Years Expenditures to Current Year Expenditures. Expenditures Must Meet or Exceed Previous Years Expenditures by 100%.

FY 2015 New Regulation IDEA section 613 (a)(2)(A)(iii) and 34 CFR § The level of effort a local education agency must meet under section 613 (a)(2)(A)(iii) of IDEA, in the year after it fails to maintain effort is the level of effort that would have been required in the absence of that failure and not the LEA’s reduced level of expenditures. Under this provision, if an LEA failed to maintain effort in , the level of effort that the LEA must maintain in is the level of effort that it would have been required in in the absence of that failure, and not the LEA’s reduced level of expenditures in

FY 2015 New Regulation Example

In FY 13, this District met MOE. In FY 14, the District will have to meet the expenditure level of FY 13.

FY 2015 New Regulation Example In FY 13, this District did not MOE. In FY 14, the District will have to meet the expenditure level of FY 12.

FY 2015 New Regulation Example In FY 13, this District did not MOE. The District filed for an exemption of $37, based on the voluntary departure of special education personnel. In FY 14, the District will have to meet the expenditure level of FY 13.

NCLB MAINTENANCE OF EFFORT Section Maintenance of Effort (a) IN GENERAL- A local educational agency may receive funds under a covered program for any fiscal year only if the State educational agency finds that either the combined fiscal effort per student or the aggregate expenditures of the agency and the State with respect to the provision of free public education by the agency for the preceding fiscal year was not less than 90 percent of the combined fiscal effort or aggregate expenditures for the second preceding fiscal year.

NCLB MAINTENANCE OF EFFORT Section Maintenance of Effort (b) REDUCTION IN CASE OF FAILURE TO MEET- (1) IN GENERAL- The State educational agency shall reduce the amount of the allocation of funds under a covered program in any fiscal year in the exact proportion by which a local educational agency fails to meet the requirement of subsection (a) of this section by falling below 90 percent of both the combined fiscal effort per student and aggregate expenditures (using the measure most favorable to the local agency). (2) SPECIAL RULE- No such lesser amount shall be used for computing the effort required under subsection (a) of this section for subsequent years.

NCLB MAINTENANCE OF EFFORT Section Maintenance of Effort (c) WAIVER- The Secretary of Education may waive the requirements of this section if the Secretary determines that a waiver would be equitable due to — (1) exceptional or uncontrollable circumstances, such as a natural disaster; or (2) a precipitous decline in the financial resources of the local educational agency.

FY Districts did not meet Maintenance of Effort for NCLB.

NCLB MOE Calculation Total Expenditures Funds 11 through 60, Excluding 12 and 41 Function Codes 1000 through 3200 Object Codes 100 through 899 Deductions Adult Education Expenditures Community Services Capital Outlay Payments to LEA’s Federal Funds Student Activities

NCLB MOE Calculation Inputs Teacher Retirement Career Tech Co-op Funds Net Current Expenditures Must be matched by 90% from year to year.

NCLB MOE Calculation Three ways to Calculate Maintenance of Effort. Expenditures Average Daily Attendance Per Student Expenditure October 1 Enrollment Per Student Expenditure

This school met MOE by the expenditures

This school did not meet MOE. Their federal funds will be reduced.68%

This school did not meet MOE but applied for an exemption with the Secretary of the US Dept. of Education and it was granted on the basis of a Natural Disaster.

FEDERAL FUNDS TO BE REDUCED Title I, Part A Title I, School Improvement Program Title I, Part B, Subpart 3, Even Start Title I, Part D, Prevention and Intervention Programs for Children and Youth who are Neglected, Delinquent, or At Risk Title II, Part A, Improving Teacher Quality Title II, Part D, Educational Technology Title III, Part A, English Language Acquisition Title IV, Part B, 21st Century Learning Centers Title VI, Part B, Subpart 2, Rural Education Programs Title VII, Indian Education Title X, Part C, McKinney-Vento Education of Homeless Youth

ADMINISTRATIVE COST Title 70, Chapter 1, Section Amount Withheld From Foundation and Salary Incentive Aid. Expenditures cannot exceed more than 5% for any school district with an ADA or more than 1,500 students Expenditures cannot exceed more than 7% for any school district with an ADA or more than 500 to 1,500 students Expenditures cannot exceed more than 8% for any school district with an ADA or fewer than 500 students

ADMINISTRATIVE COST EXPENDITURES D. For purposes of this section, “administrative services” means costs associated with: 1. Staff for the board of education; 2. The secretary/clerk for the board of education; 3. Staff relations; 4. Negotiations staff; 5. Immediate staff of the superintendent; any elementary superintendent or any assistant superintendent; 6. Any superintendent, elementary superintendent, or assistant superintendent; 7. Any employee of a school district employed as a director, coordinator, supervisor, or who has responsibility for administrative functions of a school district; and 8. Any consultant hired by the school district.

ADMINISTRATIVE COST EXPENDITURE CODES 1. Staff for the Board of Education; Functions:2313 (Board Treasurer Services) 2318 (Audit Services) 2319 (Other Board of Education Services) Objects:100 and 200 Series (Salaries and related burdens and benefits) 310 (Official/Administrative Services) 330 Series (Other Professional Services)

ADMINISTRATIVE COST EXPENDITURE CODES 2. The secretary/clerk for the Board of Education; Function:2312 (Board Clerk/Deputy Clerk/Minute Clerk Services) Objects:100 and 200 Series (Salaries and related burdens and benefits) 310 (Official/Administrative Services) 330 Series (Other Professional Services)

ADMINISTRATIVE COST EXPENDITURE CODES 3. Staff relations; Function:2316 (Staff Relations and Negotiations Services) Objects:100 and 200 Series (Salaries and related burdens and benefits) 310 (Official/Administrative Services) 330 Series (Other Professional Services)

ADMINISTRATIVE COST EXPENDITURE CODES 5. Immediate staff of the superintendent; any elementary superintendent or any assistant superintendent; Function:2321 (Office of the Superintendent Services) Objects:100 and 200 Series (Salaries and related burdens and benefits) 310 (Official/Administrative Services) 330 Series (Other Professional Services) Job Classes:615 (Regular or Substitute Secretary/Clerk) 690 (Superintendent’s Secretary)

ADMINISTRATIVE COST EXPENDITURE CODES 7. Any employee of a school district employed as a director, coordinator, supervisor, or who has responsibility for administrative functions of a school district; Function:All Objects:100 and 200 Series (Salaries and related burdens and benefits) Job Classes:101 Administrative/Supervisory/Ancillary Services Officer 107 Executive Assistant 109 Manager 301 Accountant 303 Administrative Intern 332 Network Administrator 513 Supervisor 601 Bookkeeping/Accounting/Auditing Clerk 612 Office Manager

ADMINISTRATIVE COST EXPENDITURE CODES 8. Any consultant hired by the school district; Function:All Objects:100 and 200 Series (Salaries and related burdens and benefits) Job Classes:108 Instructional Program Director/Coordinator /Consultant 110 Non-instructional Program Director/ Coordinator/Consultant 325 Grant Developer

ADMINISTRATIVE COST PENALTY State Aid will be reduced by the amount exceeded. State Aid funds are redistributed to other school districts in the state. There is no waiver for Administrative Cost Penalty.

OCAS MANUAL All of the Federal and State Compliance Calculations are in the Policy and Procedures Guide in the OCAS manual. All but one of the Compliance Reports are available to districts through the Oklahoma Cost Accounting System in the Single Sign on System or the Transparency Website.

SCHOOL DISTRICT TRANSPARENCY ACT Title 70, B. The State Department of Education shall make school district expenditure data available on its website. Data shall be made available in an open-structured data format that may be downloaded by the public and that allows the user to systematically sort, search, and access all data without any fee or charge for access.

SCHOOL DISTRICT TRANSPARENCY ACT Title 70, C. The database shall provide information on school district expenditures of state, federal, and local funds, whether appropriated or non-appropriated, excluding payments of voluntary payroll deductions for employees to receiving parties. The database shall further provide information, including, but not limited to, the following: 1. Identification of the school district; 2. The Oklahoma Cost Accounting System (OCAS) code designation for each expenditure;

SCHOOL DISTRICT TRANSPARENCY ACT 3. The name and principal location of the entity or recipient of the funds, excluding release of information relating to an individual’s place of residence and release of information prohibited by subsection D of Section 24 A.7 of Title 51 of the Oklahoma Statutes or by federal law relating to privacy rights; 4. The amount of funds expended; 5. The type of transaction; 6. A descriptive purpose of the funding action or expenditure;

SCHOOL DISTRICT TRANSPARENCY ACT 7. Copies of all credit card statements, identified by department responsible for each credit card; 8. The budgeted and audited actual expenditure figures for each fiscal year, ensuring each set of figures can be identified as budgeted or audited figures; and 9. The per-pupil spending figure, derived by dividing total expenditures by the total number of students enrolled for each school year. D. The Department shall make the data available on its website within one hundred twenty (120) days of transmission of the expenditures to the Department by the school district.

SCHOOL DISTRICT TRANSPARENCY ACT E. School districts shall provide information requested by the Department to accomplish the purposes of this section. F. If a school district maintains a website, the district shall provide the information required in subsection C of this section in the manner prescribed in subsection B of this section on the district website. G. Nothing in this section shall require the disclosure of information which is required to be kept confidential by state or federal law. H. The disclosure of information required by this section shall create no liability whatsoever, civil or criminal, to the State of Oklahoma, the State Department of Education, school districts, or any employee thereof for disclosure of required information or for any error or omission in the disclosure.

SCHOOL DISTRICT TRANSPARENCY ACT F. If a school district maintains a website, the district shall provide the information required in subsection C of this section in the manner prescribed in subsection B of this section on the district website. Copies of all credit card statements, identified by department responsible for each credit card; The budgeted and audited* actual expenditure figures for each fiscal year, ensuring each set of figures can be identified as budgeted or audited* figures. *Note: State Auditor and Inspector’s website is linked to SDE website for school audits.

Transparency Website Address

QUESTIONS

Financial Accounting/OCAS/Audit Contact Information Nancy Hughes, Executive Director Mykella Clouse, Financial Specialist Katherine Black, Financial Specialist-Auditing Pam Honeysuckle, Financial Specialist Iona Martin, Financial Specialist Amy Morgan, Administrative Assistant