Exercising Greater Flexibility in Administering Federal Grant Funds Nora Hancock, EdD Associate Commissioner Grants and Federal Fiscal Compliance Association for Compensatory Educators of Texas October 10, 2014

Flexibility Closing the Student Achievement Gap

Demographic Landscape (who we are) Over 5 million Texas students in 2012–2013 school year64% African American and Hispanic30% white60% economically disadvantaged

National Assessment of Educational Progress (NAEP) Results: Rankings and Gaps Fourth-Grade Reading Ranking White: 12th African American: 14th Hispanic: 35th Fourth-Grade Reading Gaps Between white and African American: 24 points Between white and Hispanic: 27 points

NAEP Results: Rankings and Gaps Eighth-Grade Reading Ranking White: 9th African American: 14th Hispanic: 29th Eighth-Grade Reading Gaps Between white and African American: 26 points Between white and Hispanic: 24 points

NAEP Results: Rankings and Gaps Fourth-Grade Math Ranking White: 6th African American: 5th Hispanic: 14th Fourth-Grade Math Gaps Between white and African American: 24 points Between white and Hispanic: 20 points

NAEP Results: Rankings and Gaps Eighth-Grade Math Ranking White: 5th African American: 4th Hispanic: 4th Eighth-Grade Math Gaps Between white and African American: 27 points Between white and Hispanic: 19 points

Writing Performance STAAR Writing English I: 30% gap English II: 28% gap between economically disadvantaged and non-economically disadvantaged students

Writing Performance STAAR Writing English I - 27% Gap English II - 30% Gap between White students and African American students

2013 Graduation Rates Texas high school graduation rate: 88% Gaps: African American student graduation rate is 8.9% lower than the white student rate Hispanic student graduation rate is 8.7% lower than Asian student rate

Implementing Flexibility in Administering Federal Grant Funds and Title I, Part A Schoolwide Programs

Guiding Principles Allowing local discretion Providing clear guidance Removing barriers Improving performance Ensuring grant funds spent appropriately Strengthening accountability

Federal Flexibility Initiative Focus 1.TEA policy changes 2.Title I, Part A schoolwide programs 3.Uniform Guidance

TEA Policy Changes 1.Grant administration 2.Title I, Part A Schoolwide Programs 3.Uniform Guidance

1. Grant Administration Policy Changes Grant application Grant application negotiation Grant accounting process Federal fiscal subrecipient monitoring

Grant Application Streamlined Applicants no longer required to submit certain information and documentation TEA staff do not automatically deny late or retroactive amendments

Grant Application Negotiation TEA staff will no longer negotiate applications and amendments with a “one size fits all” approach

Grant Accounting Process Detailed documentation only required upon request TEA staff will no longer assume that large reimbursement requests made at the very end of the grant period are not allowable

Substitute Time and Effort Deadlines TEA now has three submission periods for management certification form (which allows an LEA to use the substitute system) Deadlines for 2014–2015 school year: o September 4, 2014 for fall, spring, and summer semesters o December 15, 2014 for spring and summer semesters o May 15, 2015 for summer semester

Federal Fiscal Subrecipient Monitoring TEA monitors only conduct reviews of current- year grants that have not closed TEA provides for settlement conferences to resolve federal fiscal monitoring findings that could result in enforcement actions

2. Title I, Part A Schoolwide Programs Encouraging schoolwide programs Schoolwide background data TEA support for schoolwide programs Title I, Part A consolidation options

Encouraging Title I, Part A Schoolwide Programs Flexibility offered by schoolwide program model o Easing of some programmatic requirements o Allowing campuses to consolidate funds into a single budget “pool” Clear guidance given on web pages o Continuously updated information

Title I, Part A Schoolwide Programs (2014–2015) 1,200Number of LEAs eligible for Title I, Part A funds (out of 1,216 LEAs) 6,613Number of campuses eligible to operate a Title I, Part A schoolwide program (out of 8,177 campuses) 5,854Number of Title I, Part A schoolwide campuses 5,037 consolidate Title, Part A funds 234 consolidate federal funds 583 consolidate all federal, state, and local 134Number of Title I, Part A targeted assistance campuses

TEA Support for Title I, Part A Schoolwide Programs Clear guidance Models and examples Technical assistance

Title I, Part A Schoolwide Options Full consolidation Federal funds consolidation Title I, Part A funds only

Key Issues for Schoolwide Programs Specific programmatic and fiscal requirements Account code structure and PEIMS reporting Consolidating funds vs. coordinating funds Carryover Monitoring and documentation

Federal Subrecipient Monitoring Monitoring process Documentation required of LEAs with campuses that operate schoolwide programs

High-Risk Grantee Designation High-risk grantee designation and special conditions apply to LEA Affects reimbursement requests to campuses operating a schoolwide program Required documentation Uniform Guidance

3. Uniform Guidance Reasons for change Final regulations: December 26, 2014

Uniform Guidance Goals Streamline guidance for federal awards to ease administrative burden Strengthen oversight of federal funds to reduce risks of waste, fraud, and abuse

Most Significant Changes Time and effort requirements “Specific conditions” option Subrecipient monitoring requirements Monitoring findings and resolution requirements

Uniform Guidance: Time and Effort Requirements Certifications Substitute system

Uniform Guidance: Specific Conditions “High-risk” grantee designation Review of each subrecipient’s risk level

Uniform Guidance: Subrecipient Monitoring Requirements Scope of monitoring determined by each subrecipient’s risk Possible monitoring activities

Uniform Guidance: Audit Findings and Resolution Requirements Raising thresholds for: o Required single audit o Questioned costs

Next Steps Responding to questions Tools to assist LEAs

Questions and Feedback

Contact Information Title I, Part A schoolwide programs: Anita Villarreal Division of Federal and State Education Policy Federal flexibility initiative: Terry Reyes Office for Grants and Federal Fiscal Compliance

More Contact Information FASRG account code structure: PEIMS reporting: