Federal Fiscal Compliance 101 Texas Education Agency (TEA)

Major Federal Fiscal Compliance and Reporting Requirements  CEIS and MOE Voluntary Reduction Reporting  FFATA Reporting  Indirect Cost Rates  Title I, Part A Comparability  NCLB LEA MOE  IDEA-B LEA MOE  Special Education SSA Configuration Changes  Corrective Actions

Reports, Notifications and Submissions GFFC Reports and Data Collections  TEAL/TEASE Application  TEA Federal Compliance Determinations  LEA responses to Federal Compliance Determinations Ensure appropriate LEA staff have access!

Reports, Notifications and Submissions Grants and Federal Program Compliance (GAFPC) listerv Sign up for GAFPC at: Ensure appropriate LEA staff are subscribed to GAFPC!

CEIS and MOE Voluntary Reduction Reporting Requirement  Report on applicable CEIS Set-Aside amounts, students served, and MOE Voluntary Reduction taken by LEA’s.

CEIS and MOE Voluntary Reduction Reporting Common Errors to Avoid  CEIS Set-Aside amounts > 15%  MOE Voluntary Reduction > 50%  Combined, the CEIS Set-Aside and MOE Voluntary Reduction may not exceed lower of the two

CEIS and MOE Voluntary Reduction Reporting Common Errors to Avoid (Continued)  CEIS Set-Aside yet no CEIS Students Served  CEIS Students Served yet no CEIS Set-Aside  Special Education Consolidated Grant Application is not amended for CEIS Set-Aside changes

FFATA Reporting Requirement  Report on applicable federal subawards (i.e. TEA NOGAs to LEAs) Note: LEA data is tied to the LEA’s DUNS LEA’s must update SAM annually

FFATA Reporting Common Errors to Avoid  Incorrect 9-digit zip code for the physical address in SAM  Outdated address or business contact information in AskTED  Incorrect DUNS on file at TEA

Indirect Cost Rates Request Rate Via Annual Submission  ISDs – Exhibit J-2 of AFR (electronic submission)  Open-enrollment Charter – eGrant Special Collection SC5010  ESCs/Other Governmental Agencies – Indirect Cost Rate Proposal submitted directly to TEA

 LEA may apply its Indirect Cost Rate if allowable by the grant  The indirect cost rate cap may be less than the LEA’s approved Indirect Cost Rate  Administrative caps may limit the amount of indirect costs recovered Application of Indirect Cost Rates

Common Errors to Avoid  The indirect cost recovery is calculated when the LEA submits the final expenditure report  If the LEA has requested reimbursement in excess of the allowable indirect costs on its periodic expenditure reports, a refund due will be generated

Title I, Part A Comparability Requirement  LEAs required to annually submit Comparability Computation Form and Comparability Assurance Document using GFFC Reports and Data Collections  Submissions due November 12 th

Title I, Part A Comparability Common Errors to Avoid  Misclassification of Campus (either Title/Skipped or Non-Title)  Not reporting EE and/or PK campuses in Elementary Grade-span group  Not demonstrating compliance with one test for all grade-span groupings tested

Title I, Part A Comparability Common Errors to Avoid (Continued)  Subdividing Grade-span into High/Low enrollment and not meeting Significant Difference of Enrollment criteria  Uploading Comparability Computation Form as a PDF rather than Excel as required  Uploading Comparability Assurance Document without Superintendent Signature as required

NCLB LEA MOE Requirement  Determine LEA compliance with NCLB Maintenance of Effort (MOE)  Applies to LEAs receiving federal funds under covered NCLB (ESEA) programs

NCLB LEA MOE Common Misconceptions  MYTH: Similar to IDEA-B LEA MOE, there are federal statutory exceptions to NCLB LEA MOE. TRUTH: There are no federal statutory exceptions.  MYTH: TEA has authority to waive penalty for noncompliance. TRUTH: Only USDE has authority to waive penalty.

NCLB LEA MOE Common Misconceptions  MYTH: Receipt of USDE waiver constitutes compliance with requirement. TRUTH: Final Determinations DO NOT change; only the penalty is waived.  MYTH: Penalty only impacts only Title I, Part A. TRUTH: Noncompliance impacts all covered programs.

IDEA-B LEA Eligibility Requirement  LEA must certify it has budgeted in the current year an amount greater than or equal to the amount required to meet the MOE requirement.  Applies to LEAs receiving federal funds under an IDEA-B formula grant

Special Education Consolidated Grant Application Schedule BS Fiscal Compliance Requirements  Part 1: LEA MOE Eligibility  Part 2: CEIS Set-Aside and MOE Voluntary Reduction Amount

IDEA-B LEA MOE Requirement  Determine LEA compliance with IDEA-B Maintenance of Effort (MOE)  Applies to LEAs receiving federal funds under an IDEA-B formula grant

IDEA-B LEA MOE 2014 Updates to IDEA-B LEA MOE Handbook  SHARS Medicaid Cost Share is not included in the IDEA-B LEA MOE calculation  Exceptionally Costly Program is defined as amount greater than the average per-pupil (as defined in Section 9101 of ESEA)

IDEA-B LEA MOE Fiscal Agents and Member Districts  TEA has no authority to resolve SSA disputes  Member Districts must contact their Fiscal Agent for amounts reported on their behalf  State Reconsideration for Significant PEIMS Errors

Special Education Shared Services Arrangement (SSA) Configuration Changes Requirement  LEA must notify TEA of configuration changes annually by February 1 st  LEA must submit the new SSA Contracts annually by June 1 st

Requirement  LEA may owe a refund to TEA from a federal finding in an audit  LEA may have required corrective actions from a federal finding in an audit Corrective Actions

Common Errors to Avoid  Failing to send a check for any refund due to TEA by the deadline  Failing to provide corrective action documents to TEA by the required completion date

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