2018-19 Universal Review: Fiscal Requirements December 19, 2018

Purpose of Monitoring Fiscal Indicators Topics Purpose of Monitoring Purpose of Monitoring Fiscal Indicators Comparability Supplement not Supplant (SNS) Maintenance of Effort (MOE) PPTs on Comparability, SNS, and MOE

Monitoring Process Fiscal Requirements Topics Continued LEA Monitoring Report LEA Corrective Action Plan Follow-up to the Corrective Action Plan Fiscal Requirements Overview FR 9.1 SNS in Title II-Part A and Title IV-Part A FR 1.4 Rank Order

Purpose of Monitoring Monitoring the use of funds and program implementation under the Elementary and Secondary Education Act (ESEA) is an essential function of the Colorado Department of Education’s (CDE) Unit of Federal Programs Administration (UFPA). Monitoring of ESEA programs is conducted in order to ensure: (1) All children have a fair, equitable, and significant opportunity to obtain a high-quality education, with a focus on access and opportunity for historically underserved students; (2) Compliance with ESEA requirements and open opportunities to increase ESEA program impacts on improving student outcomes; and (3) Taxpayer dollars are administered and used in accordance with how Congress and the U.S. Department of Education (ED) intended. Monitoring serves as a vehicle to help LEAs achieve high-quality implementation of educational programs and enable CDE to better advise and partner with LEAs in that effort. Monitoring also formalizes the integral relationship between CDE and Colorado LEAs in implementing ESEA programs. It emphasizes, accountability for using resources to educate and prepare the nation’s students. A set of clear monitoring indicators clarifies for LEAs, and CDE monitoring personnel, the critical components of this accountability and provides a standard against which LEA policies and procedures can be measured. Monitoring enables CDE to gather accurate data about LEA and local needs, and use that data to design technical assistance initiatives and leadership activities.

Purpose of Monitoring: Fiscal Indicators CDE reviews Comparability, SNS, and MOE indicators to ensure that LEAs are compliant with ESSA and that Federal funds are supplemental, increase the dosage or intensity of services to historically underserved populations, and result in equitable outcomes. Comparability ensures that Title I schools receive similar services as non-Title I schools, and that Title I provides “extra” resources to underperforming students from low-income neighborhoods. SNS (Title I Allocation Methodology Demonstration) ensures that all schools receive their fair share of funding; Title I schools receive all State and local funds they would have received had they not participated in Title I. State and local allocations are Title I-neutral, assuring that Title I provides services over and above the base level of funding. MOE looks at State and local funds expended year-to-year to ensure LEAs maintain their level of effort and Federal funds are supplemental.

Fiscal Indicators Transition to the PPTs for Comparability, Supplement and Not Supplant, Maintenance of Effort

Monitoring Process: LEA Monitoring Report At all levels of review, CDE will provide a comprehensive LEA monitoring report to delineate LEA compliance, recommend next steps based on best or promising practices implemented by other LEAs, and detail any findings or required actions. Together, the report and recommendations provide a snapshot of Federal requirements implementation. These reports will be compiled, with LEA input, within 45 days of monitoring. A CDE contact will work with the LEA primary contact to get this input. The report draft will be shared with the LEA after 30 days and the LEA will have 5 days to provide feedback or request additional details. CDE will take LEA feedback into consideration when finalizing its report.

Monitoring Process: LEA Corrective Action Plan When required, CDE will partner with LEAs to design a corrective action plan that is reasonable for the LEA to implement within an agreed-upon timeline. Upon receiving the report, LEAs have 45 days to respond to any required actions, unless otherwise noted, or request support from CDE to develop its action plan. LEAs that do not require additional support/time to develop a corrective action plan will submit their plan to CDE within 45 days of receiving the monitoring report. If support is requested, the LEA and CDE will develop a timeline and action steps for finalizing the LEA Corrective Action Plan, not to exceed 60 days post- monitoring. The corrective action plan must provide the timeline within which all actions will be completed. LEAs may work with CDE to establish a timeline that is reasonable for implementation and follow-through.

Monitoring Process: Follow-up to the Corrective Action Plan CDE will approve the LEA’s final corrective action plan within 30 business days of receiving it, if the monitoring team determines the corrective action plan adequately addresses the required actions. If CDE determines the plan is not sufficient for compliance, the LEA will be notified of the consequences for failure to take corrective action and asked to provide additional corrective actions. Such consequences may include CDE authority to apply conditions to current or future grant awards. CDE program consultants will monitor LEA progress toward fulfilling the identified corrective action plan within the timeline stipulated. Program consultants will update the LEA’s CDE-maintained monitoring portfolio to reflect compliance status, and include documents, memoranda, a copy of the monitoring report, and other supporting materials as needed. If necessary, CDE may schedule a follow-up review within the year.

Fiscal Requirements: Overview Fiscal Requirements monitored as part of 2018- 19 Universal Review: FR 9.1 SNS in Titles II- and IV- Part A FR 1.4 Rank Order Fiscal Requirements monitored through existing processes: FR 9.2 MOE FR 1.1 Title I-Part A SNS FR 1.2 Title I-Part A Carryover FR 1.6 Title I-Part A Comparability

Fiscal Requirements: Existing Processes For requirements being monitored through existing processes: CDE will review results of that existing process. Any required follow-up action will be included in the LEA Monitoring Report. Example: Comparability is reviewed by CDE. If a district is unable to meet comparability requirements, a plan is developed in collaboration with the ESEA Program team. Details of this plan, including support to be provided by CDE, will be included in the LEA Monitoring Report.

Fiscal Requirements: Universal Review For requirements being monitored as part of Universal Review, CDE will: Review information from the Consolidated Application. Request additional documentation to demonstrate implementation. Review evidence of compliance. Any required follow-up action related to Universal Review will be included in the LEA Monitoring Report.

Fiscal Requirements: FR 9.1 SNS in Titles II-Part A and IV-Part A Statutory Indicator: Title II-Part A and Title IV-Part A funds shall be used to supplement, and not supplant, non-Federal funds that would otherwise be used for activities funded by ESSA. Demonstration of Compliance: ESEA funds are not used to implement required, funded, or unfunded State or local policies. LEA did not use Title II or IV to pay for activities or supplies that were previously paid with State and local funds, except in cases where LEA can demonstrate precipitous decline in local resources. Required Evidence: Two years of expenditure detail from LEA/BOCES accounting system. Examples of Additional Evidence: Narrative description of how Titles II- and IV-funded activities enhance or are provided in addition to basic programs or initiatives funded with State and local funds. Methodology of state and local funds provided to schools. As applicable: Narrative description of the reason for the precipitous decline in local resources. Board minutes that document the approval of diminished budget.

Fiscal Requirements: FR 9.1 Review Process Additional evidence will be needed to verify FR 9.1 compliance. CDE will use 2 years of expenditure detail from LEA/BOCES accounting system to verify that Titles II-Part A and IV-Part A funds are supplementing, not supplanting, non-Federal funds. LEAs submit 2 years of expenditure detail from the LEA/BOCES accounting system. CDE samples Title II-Part A and Title IV-Part A expenditures from the “current” year (2017-18). Expenditures are cross-referenced with prior year (2016-17) non-Federal expenditures. If an expenditure currently sourced from Titles II-Part A or IV-Part A was previously funded with non-Federal funds, CDE will request additional information regarding how the expenditure is supplemental or, if applicable, justifying a precipitous decline in non-Federal funding sources. CDE will provide feedback based on the submitted evidence and narrative response (if applicable). Any required follow-up will be included in the LEA Monitoring Report.

Fiscal Requirements: FR 1.4 Rank Order Statutory Indicator: The LEA serves all of its schools with poverty rates above 75% in rank order (without consideration of grade-span) with a higher per pupil allocation at the schools with higher poverty rates. The LEA serves all schools with poverty rates below 75% in rank order or ranks such schools by grade span and serves all schools within each grade span in rank order. The LEA serves only schools with poverty rates above 35%; or with poverty rates above the district average; or for each grade span, the LEA serves only schools with poverty rates above the grade span average. Demonstration of Compliance Schools with higher poverty rates are served with equal or greater PPA than schools with lower poverty rates. All schools with poverty rates above 75% are served. The LEA serves only schools with poverty rates above 35% or the district average; or for each grade span, the LEA serves only schools with poverty rates above the grade span average. Expenditure reports align with budget provided in the Consolidated Application Examples of Evidence Approved Consolidated Application/LEA Plan FY 17-18 audited expenditure detail reports, PPA calculation.

Fiscal Requirements: FR 1.4 Review Process Additional evidence will be needed to verify compliance for FR 1.4. CDE will use school-level End-of-Year (EOY) expenditure details and per-pupil amount (PPA) calculation based on expenditure details to verify compliance with Title I-Part A Rank Order requirements. LEA calculates PPA based on school-level FY 17-18 expenditures (CDE template available). LEA submits FY 17-18 expenditure detail reports (post-audit) and PPA calculation via the data management system (DMS). CDE verifies that expenditure detail and PPA reflect that Title I schools were served in rank order. Any required follow-up action will be included in the LEA Monitoring Report.

Click the link for more information on Monitoring Contacts: Questions or Comments? Click the link for more information on Monitoring Contacts: DeLilah Collins at Collins_D@cde.state.co.us Nazie Mohajeri-Nelson at Mohajeri-Nelson_n@cde.state.co.us Joey Willett at Willett_J@cde.state.co.us