Coordinating State & Federal Funds: Tennessee’s Journey AEFFA Conference, October 20, 2016

Renee Palakovic Director of Planning Consolidated Planning & Monitoring Renee.Palakovic@tn.gov

Introduction

OUR VISION Districts and schools in Tennessee will exemplify excellence and equity such that all students are equipped with the knowledge and skills to successfully embark upon their chosen path in life. This is our unifying vision – success for all students post graduation from high school. This is how Tennessee Succeeds.

Early Foundations & Literacy: building skills in early grades to contribute to future success High School & Bridget to Postsecondary: Preparing significantly more students for postsecondary completion All Means All: Providing individualized support and opportunities for all students with a focus on those who are furthest behind Educator Support: supporting the preparation and development of an exceptional educator workforce District empowerment: Providing districts with the tools and autonomy they need to make the best decisions for students. District empowerment is where I will focus today…but first, lets talk about some characteristics of our school districts and the communities they serve.

Tennessee’s Landscape Tennessee is an extremely rural state. The pockets of red and pink are the large urban areas of the state—Memphis, Nashville, Chattanooga and Knoxville. The green shades that you see on the map represent the more rural areas of the state. The darker green, the more rural. The lightest green represents less than 100 people per square mile and the darkest green less than 1. Currently, 60% of the state’s counties are rural. Need to add statistics on the numbers of students in these rural areas… Tennessee is below the national average in median household income and per capita income and higher than the national average of families living below the poverty line. The northeastern portion of the state (Appalachia) has significant poverty (some counties as much as 50%) and little access to resources. However, we also have some extremely affluent counties, many falling in the middle of the state, Middle TN. West TN 42 K square miles

School Districts in Tennessee County school systems 141 LEAs serving nearly 1 million students 1,830 schools (57% avg. poverty) 1,223 Title I schools Average poverty percentage of Title I schools is 70% 600,000 served in Title I schools Only 17 of these schools are targeted assistance

District Empowerment Flexibility to make decisions to meet their unique and specific needs Reduction of barriers to utilizing available resources Creation of tools and supports for effective resource management

Funding Considerations

Basic Education Requirement of state to provide basic education Districts distribute basic education funding differently: Staffing model Per-pupil Weighted student formula Basic education funds are often budgeted independently of federal funds and the use of funds is not well-coordinated

Federal Funds Federal funds are supplemental to the basic education funds to provide additional resources and supports Each federal grant has a purpose, and often rules, of how funds can be used and what students can/must benefit from services Allowable uses Eligible students

Unintended Consequences Because of all of the rules, LEAs are reluctant to use federal funds in coordination with other funds. Audit findings Lawsuits Repayment of funds Unfavorable attention This results in programs being operated in silos. Operating programs in isolation, often times, results in duplication of efforts as well as failure to provide services at all due to a lack of coordination.

Strategy #1: Online Grants Management--ePlan

What is ePlan? Comprehensive, online grants management system Transparent to the public and to all LEA users Includes Funding applications School and LEA plans Reimbursement requests Allows for comprehensive and collaborative planning across many funding streams Allows for the sharing of information across many departments and with the public

Funding Sources in ePlan 2013-14 school year: ESEA and IDEA program applications submitted through ePlan 2014-15 school year: 11 additional programs added including – CTE, PreK, CSH, Safe and Supportive Schools, 21st Century, LEAPS, School Improvement and all remaining ESEA and IDEA discretionary grants 2015-16 school year: all remaining federal programs and state basic education funding added

School Plans in ePlan 2014-15 school year: optional use of the planning tool in ePlan for school-wide plans 2015-16 school year: all Title I schools required to use planning tool in ePlan for school-wide plans 2016-17 school year: ALL schools required to use planning tool in ePlan for school-wide plans

Strategy #2: Coordinated Spending Guide

Coordinated Spending Guide What it is A guide to help LEA leaders make the most out of the more than $700 million Tennessee receives each year from the U.S. Department of Education A resource for identifying possible options to support instructional initiatives What it is not New requirements, directives or rules that must be followed Step-by-step list of how to allocate resources

Coordinated Spending Guide We must put aside our turfs and our purse-strings, in order to overcome the challenges that dwindling resources present… It is critical for all leaders at the district level to support this effort, in order to empower all personnel to collaborate in new and effective ways... Managing change is difficult and to be successful, we have to meet the needs of all children, regardless of the ways we choose to fund programs. Far too often, in our silos we have said, "No, we can't do that because…," rather than working together to eliminate the silos. We are [too] comfortable with the inflexibility we have created. Center for Mental Health in Schools at UCLA, Rethinking District Budgets to Unify and Sustain a Critical Mass of Student and Learning Supports at Schools, available at: http://smhp.psych.ucla.edu/pdfdocs/financebudget.pdf. Center for mental health in schools at UCLS—Rethinking budgets to unify and sustain a critical mass of student and learning supports at schools. This process requires imagination, courage, flexibility and collaboration.

Permitted by Federal Law Such coordination is permitted by federal law and encouraged by the Tennessee Department of Education (TDOE). The manual provides guidance to LEAs in coordinating funds by: defining braiding vs. blending funds, addressing barriers that may discourage LEAs from coordinating funds, providing overviews of the largest federal grant programs – Title I, Title II, and IDEA – with a focus on how districts can maximize these funds to support district priorities, and providing examples of how federal grants can be coordinated to support promising initiatives.

Utilizing the Guide SECTION I: Coordinated Spending to Maximize Funds SECTION II: Framework for Coordinated Spending SECTION III: Comprehensive Initiatives – Funding Quick Guides SECTION IV: Considerations When Braiding or Blending Funds APPENDIX: Supplement Not Supplant Program Overviews Section I defines blending and braiding and explains the flexibility that is possible with options and the impact it could have on instructional programs. Section II provides steps for making good resource decisions

Section I: Maximizing Funds Braiding Funds Using multiple funding sources in a collaborative manner to support educational initiatives to ensure consistency and eliminate duplication of services while maintaining individual program identity. Braiding funds is a way for LEAs and schools to use multiple federal grants to support various pieces of an initiative. Activities are allowable under each applicable grant and the grants continue to maintain their identity and expenditures for each are maintained by the LEA or school. Funds maintain their original award-specific identity.

Section I: Maximizing Funds Blending Funds Combining multiple funding sources to support educational initiatives to ensure consistency, eliminate duplication of services, and reduce burden. Blended funding allows for maximum flexibility. In Title I school-wide programs, eligible grants and other resources are combined into a single pool under a single set of reporting requirements. Funds lose their original award-specific identity.

Available Funding Sources

Braiding Funds

Blending of Funds

Section II: Framework Provides a five-step process for making coordinated funding decisions Needs assessment Breaking down the initiative Identifying possible federal funding sources Reasonable and necessary test Alignment with plans

Section III: Funding Quick Guides The guides illustrate how state, local, and federal funds can be used to support the sample comprehensive initiatives detailed in this section. Note that in some cases it may be possible to support a component cost with more than one federal funding source. It is important to note that both the school and district level examples presume that Title I schools within the district are operating school-wide programs.

Section III: Funding Quick Guides

Section III: Funding Quick Guides

Section IV: Considerations Permissive use of funds Eligible students Supplement not supplant Time and effort Financial management/support Inventory control

Appendices Program overviews What it is Intent and purpose What it can fund Supplement not supplant requirements for each program included in the guide and the legal citation for each

Strategy #3: School-wide Consolidation Pilot

Blending of Funds Maximum flexibility for schools to budget and spend federal resources Permitted by law Necessary with shrinking resources and varied needs across districts But how is it actually done? And how can we implement it in TN?

Available Funding Sources

Braiding Funds

Blending of Funds

Consolidation Options Consolidate only school level federal funds Funds lose their identity School level program-specific requirements no longer applicable Must meet the intent and purpose of programs included Funds can be used to address the educational needs identified in the school-wide plan

Consolidation Options Consolidate school level state, local and federal funds Funds lose their identity School level program-specific requirements no longer applicable Must meet the intent and purpose of programs included No distinction between federal and non-federal funds Funds can be used to address any needs identified in the school-wide plan (may be non-educational)

Federal Funds Eligible for Consolidation Any federal funds administered by the United States Department of Education (USEd) that can be used to support students in public schools Formula funds such as Title I, Part A Title II, Part A Title III IDEA, Part B Perkins Discretionary (competitive) funds Must still complete activities within the funding application Head Start and National School Lunch CANNOT be included because they are not administered by USEd

School-wide Pool of Funds A comprehensive needs assessment must be completed annually and used as the basis for the school-wide plan The school-wide plan identifies the programs and amounts to be consolidated Funds are combined into a single, school-wide pool of funds Funds from the pool are used to support the activities outlined in the school-wide plan Expenditures are not “tracked” back to specific programs within the pool

School-wide Plan Importance Because school-wide programs that consolidate funds are not required to meet program-specific requirements, the school-wide plan is of premier importance. Auditors will hold the school-wide program accountable for ensuring The plan’s activities meet the intents and purposes of the consolidated federal programs; and The school-wide program is implementing the activities detailed in the plan.

IDEA in the School-wide Pool of Funds If IDEA, Part B funds are being consolidated The maximum amount of funds consolidated must be calculated based on the number of students with disabilities in the school School must comply with all other requirements of IDEA, Part B to the same extent as it would if funds were not included in the consolidation IDEA funds included in the consolidation must be used to implement the school-wide plan IDEA funds NOT consolidated in school-wide programs are handled/tracked at the district level and used to ensure FAPE IDEA Allocation # of SWDs in LEA # of SWDs in School LEA Per Pupil Maximum School Amount for Consolidation $500,000 500 50 $1,000 $50,000 (50 X $1,000)

School-wide Pool of Funds School Building Title I Part A Title II Part A IDEA Part B State/Local Funds Building Total School A $182,535 $25,000 $94,462 $2,048,115 $2,350,112 School B $115,455 $27,709 $1,380,884 $1,549,048 School C $181,780 $69,272 $1,940,161 $2,216,213 Total Funds Distributed to Individual Schools $479,770 $75,000 $191,443 $5,369,160 $6,115,373

School-wide Pool of Funds Reimbursement requests must separate the amount spent from the school-wide pool Amounts requested from each program are based on Total expenditure from the pool Percentage of contribution to the pool Total pool expenditure: $350,000 School Building Title I Part A Title II Part A IDEA Part B State/Local Funds Building Total School-wide Pool $479,770 $75,000 $191,443 $5,369,160 $6,115,373 Percent of Total Contribution 7.8% 1.2% 3.1% 87.9% 100% Percent of Expenditures to be Reimbursed $27,300 $4.200 $10,850 $307,650 $350,000

Intent and Purpose Schools consolidating funds are not required to meet most statutory or regulatory requirements of the program, but must meet the intents and purposes of the programs included in the consolidation For example: Title II, Part A: the intent and purpose of this program is to increase student achievement through strategies such as: Improving teacher and principal quality Increasing the number of highly qualified teachers, principals and assistant principals in schools Holding LEAs and schools accountable for improvements in student academic achievement

Intent and Purpose A school-wide program would meet the intent and purpose of Title II, Part A if: The school-wide plan contains activities and strategies that promote increased student achievement, such as On-going and sustained professional development for teachers and administrators Strategies to recruit and retain highly effective, highly-qualified teachers Teacher mentoring programs Induction programs for new teachers

Intent and Purpose Title I, Part A (school-wide program) Programs and services designed to meet the educational needs of all students in a school, particularly those who are not meeting state standards. Title III, Part A Programs to help ensure that children with limited English proficiency become proficient in English, develop high academic attainment in English, and meet the same challenging state academic content and achievement standards in core academic subjects that all other children are expected to meet. Increase the capacity of schools to establish, implement and sustain high-quality language instruction programs, and English language development programs that assist schools in effectively teaching students with limited English proficiency.

Intent and Purpose IDEA, Part B Perkins To ensure that all children with disabilities have available to them a free appropriate public education designed to meet their individual needs. Perkins Programs and services to more fully develop the academic and career and technical skills of secondary education students and postsecondary education students who elect to enroll in career and technical education programs.

Statutory and Regulatory Requirements Several federal statutory and regulatory requirements are eased through school-wide consolidation at the school level Time and effort Pool of funds is a single cost objective Procurement & equipment inventory If consolidating state, local and federal Can use state and local procurement rules Federal equipment tracking rules do not apply Fiscal accounting of expenditures Not tracked back to individual grant programs Tracked only as part of the school-wide pool of funds

Statutory and Regulatory Requirements Several federal statutory and regulatory requirements remain, but are handled differently Maintenance of effort Expenditures calculated based on percentage of funds contributed to the pool Comparability Percentage of federally paid staff based on percentage of funds contributed to the pool Carryover limits Calculated based on LEA total award Carryover amounts based on total expenditures and percentage of funds contributed to the pool

Now, find some volunteers! Conducted informational sessions at conferences and meetings Sent out information through communication channels to educate on the option Solicited volunteers for One year of planning and training—no commitment up front

Engage Partners Internal stakeholders State auditors OESE and OSEP

Changes in ePlan to Allow Consolidation Created mechanisms for the creation of a school-wide pool section within the consolidated funding application Developed cross-checks within the system to ensure that IDEA maximum amounts were not exceeded Developed separate budget and functionality to ensure reimbursements are done correctly, using the percentage method

Implementation in 2016-17 Started with eight LEAs; ended with three committed to implementing in four schools All have completed the fiscal requirements in the funding applications All are working on school-wide plans that contain required components No schools opted to consolidate state funds in 2016-17

Summary

District Empowerment The Tennessee Department of Education (TDOE) believes maximum flexibility, as permitted by the law, must be made available to LEAs in order to empower them to make the best decisions for students. The TDOE has acted to make it possible for LEAs to effectively and collaboratively plan the use of funds and to utilize the maximum flexibility permitted.

Next Steps Share success stories from 2016-17 with LEAs in Tennessee Solicit new participants for the 2017-18 school year Work with state auditors as they begin to review consolidated pilot schools beginning in July 2017 Continue to refine and update planning processes to align and better support collaborative and coordinated planning and resource allocation

Contact Information Renee Palakovic Director of Planning TN Department of Education Division of Consolidated Planning & Monitoring Renee.Palakovic@tn.gov (615) 906-7539 (m) (615) 253-3786 (w)

Excellence | Optimism | Judgment | Courage | Teamwork Districts and schools in Tennessee will exemplify excellence and equity such that all students are equipped with the knowledge and skills to successfully embark on their chosen path in life. Excellence | Optimism | Judgment | Courage | Teamwork

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