School Improvement Grants (SIG) SIG Meeting July 26, 2011 Office of School Recovery Mississippi Department of Education

Procurement of Goods and Services 2

Allowable Cost Test (Questions to ask) United States Department of Education Website EDGAR – Education Department General Administration Regulations OMB Circular A Summary of State Purchasing Laws as compiled by the State Auditor’s Office 3

Cost Principles Basic Rules Necessary Reasonable Allocable Legal under state and local law Conform with federal law and grant terms Consistently treated In accordance with GAAP Not included as match Net applicable credits Adequately documented 4

5 Practical aspects of “necessary” Do I really need this? Is this the minimum amount I need to spend to meet the need? Practical aspects of “reasonable” Is the expense valid? Do I have the capacity to use what I am purchasing? Did I pay a fair rate? Can I prove it? If I were asked to defend this purchase, would I be comfortable? Necessary & Reasonable

Practical aspects of “necessary” Do I really need this? Is this the minimum amount I need to spend to meet the need? Practical aspects of “reasonable” Is the expense valid? Do I have the capacity to use what I am purchasing? Did I pay a fair rate? Can I prove it? If I were asked to defend this purchase, would I be comfortable? 6

Supplement not Supplant Federal funds must be used to supplement and in no case supplant (federal), state, and local resources 7

Legal under state and local law – If you can’t do it under state law, you can’t pay for it with federal funds Conform with federal law & grant terms – Example: Match Requirements 8 Basic Rules

Adequately documented: Allocation of Funds Usage of funds Share of costs provided by other sources Records that show compliance Records that show performance Other records to facilitate an effective audit 9 Basic Rules (cont.)

American Recovery and Reinvestment Act funds (ARRA) Things to Remember 10

Transparency Federal Funding Accountability and Transparency Act (FFATA) – 1512 (c)(4) SEC REPORTS ON USE OF FUNDS (c) RECIPIENT REPORTS.—Not later than 10 days after the end of each calendar quarter, each recipient that received recovery funds from a Federal agency shall submit a report to that agency that contains— (4) awarded by the recipient to include the data elements required to comply with the Federal Funding Accountability and Transparency Act of 2006 (Public Law 109–282),

Reporting under 1512 Recipient reports will answer: – Who is receiving Recovery Act dollars and in what amount? – What project or activities are being funded with Recovery Act dollars? – What is the completion status of such projects or activities and what impact have they had on job creation and retention?

ARRA Vendors Vendors should know when responding to a purchase request that ARRA funds will be used to pay for all or part of the purchase Vendors should be given the opportunity to opt out Vendors should understand that their acceptance of ARRA funds constitutes their agreement in the participation of ARRA which could include an audit by the federal government

ARRA Vendors

Federal Reporting Timeframes Days 1 – 10: Prime Recipients required to submit reports for all sub-recipients to FederalReporting.gov Days 11 – 21: Prime Recipients review submitted data, any changes are publically noted Days 21 – 30: Federal review Day 30: Reports published on Recovery.gov

Required Data for Prime Recipient – Federal Funding Agency Name – Award Identification – Recipient DUNS Number – Parent DUNS Number – Recipient CCR Information – CFDA Number – Recipient Account Number – Project/grant period – Award type, date, description, and amount Amount of Federal Recovery Act funds expended to projects/activities Activity Code and Description Job creation narrative and number Infrastructure expenditures and rationale Recipient Primary Place of Performance Recipient Area of Benefit Recipient Officer Names and Compensation (Top 5) Total number and amount of small sub-awards

Required Data for Sub-Recipient Sub-recipient DUNS Number Sub-recipient CCR Information Sub-recipient Type Amount received by Sub-recipient Sub-award Date Sub-award Period Sub-recipient Place of Performance Sub-recipient Area of Benefit Sub-recipient Officer Names and Compensation (Top 5)

Required Data for Sub-Recipient Vendor DUNS Number or Name and 9-digit Zip Code of Headquarters

Documentation Documentation for each ARRA grant award should be kept separately Check vendor’s DUNS Numbers - must match CCR data Keep all documentation for 5 years after end of grant (12/2017) - GEPA

Districts Should… Update Policies and Procedures for purchasing and contracting for ARRA Train staff in the updated ARRA Policies and Procedures Keep accurate and current time sheets

Recovery.gov Recovery.gov publishes the reports after the 30 th day of the end of each quarter

ARRA Reporting Prime Recipients are charged: – to set a process in place to ensure coordinated reporting – to design and implement a process to prevent double counting – to maintain an updated inventory of sub-recipient delegations – to cross check all data records

Data Quality Requirements Prime Recipient: – Owns recipient data and sub-recipient data – Initiates appropriate data collection and reporting procedures to ensure that section 1512 reporting requirements are met in a timely and effective manner – Implements internal control measures as appropriate to ensure accurate and complete information – Performs data quality reviews for material omissions and/or significant reporting errors, making appropriate and timely corrections to prime recipient data and working with the designated sub-recipient to address any data quality issues

Data Quality Requirements Sub-Recipient: – Owns sub-recipient data – Initiates appropriate data collection and reporting procedures to ensure that section 1512 reporting requirements are met in a timely and effective manner – Implements internal control measures as appropriate to ensure accurate and complete information – Reviews sub-recipient information for material omissions and/or significant reporting errors, and makes appropriate and timely corrections

Jobs Created or Retained New guidance issued December 18, 2009 Directed States to report ALL jobs funded with ARRA funds as Jobs Created/Retained Required States to begin reporting using new guidance for the report due January 10, 2010 Will allow States to update data reported to the federal government beginning in February MDE will ask Districts to update last quarters’ data in February to allow MDE to update federal report Guidance will be coming in the next couple of weeks

District Reporting Reporting for Districts begin when a grant award has been made AND the district draws down monies Districts reporting to OSE, for those required to report, will begin a monthly reporting process – Districts will report transactions that match amount drawn for the month from ARRA fund – Step-by-step reporting instructions coming soon

ARRA Resources

Remember for ARRA All ARRA funds must be tracked separately All ARRA documentation should be maintained separately for 5 years at the end of grant period

School Improvement Grants 1003(g) Performance Metrics Reporting Requirements 29 Leading Indicators

Reporting Requirements To inform and evaluate the effectiveness of the interventions identified in the School Improvement Grant (SIG) requirements, the Data will be collected on the performance metrics. The USDE already collects most of these data through EDFacts and will collect data on two metrics through SFSF reporting. 30

31 Number of Minutes and Types of Increased Learning Time Offered This data group is the number of minutes that all students were required to be at school and any additional learning time (before school, after school, or summer school) for which all students had the opportunity to participate. School minutes are the total of all full school days and half school days and any increased learning time provided to all students in the school. – Increased learning time is defined by the type of increased learning time that the school offered. The following types of increased learning times should be reported: longer school year, longer school day, before school, after school, summer school, weekend school. New Reporting Requirement 31

32 Performance Metrics and Reporting Requirements Leading Indicators Number and percentage of students completing advanced coursework (e.g., AP/IB), early-college high schools, or dual enrollment classes; – Advanced Coursework is defined as the number of students who complete advanced placement or International Baccalaureate classes. Completing the advanced coursework means that the student finished the class either during the school year or in combination with summer school and received course credit in accordance with state or local requirements. – Dual Enrollment refers to the number of high school students who complete at least one class in a postsecondary institution either during the school year or in combination with summer school and receive course credit. – Advanced Coursework and Dual Enrollment is defined as the number of students who complete advanced coursework AND complete at least one class in a postsecondary institution either during the school year or in combination with summer school and receive course credit. Data will be collected for this requirement via Survey for FY

33 Distribution of teachers and principals by performance level on an LEA’s evaluation system District will be required to identify the number of principals and number of teachers. Identify the labels used in the district’s evaluation system (up to six levels for example unsatisfactory, needs improvement, meets standards, exemplary) on the LEA’s evaluation instrument and report the distribution of teachers and principals by performance levels. 33

34 Teacher Attendance Rate What is your school’s target teacher attendance rate? – 98% ? – 95% ? – 90% ? – 85% ? – 80%? – 72%? – or less ????? 34

35 Teacher Attendance Rate Based upon a 187 day teacher contract: – 97% = Average of 5.61 days out per school year – 95% = Average of 9.35 days out per school year – 90% = Average of 18.7 days out per school year – 85% = Average of days out per school year – 80% = Average of 37.4 days out per school year – 72% = Average of days out per school year – or less ????? 35

36 Performance Metrics and Reporting Requirements Leading Indicators Number of minutes within the school year and school day; * Student participation rate on State assessments in reading/language arts and in mathematics, by student subgroup; Dropout rate; Student attendance rate; Number and percentage of students completing advanced coursework (e.g., AP/IB), early-college high schools, or dual enrollment classes; * Discipline incidents; Truants; Distribution of teachers by performance level on an LEA’s teacher evaluation system; and * Teacher attendance rate. * * New Reporting requirement 36

School Improvement Grants 1003(g) Performance Metrics Reporting Requirements 37 Achievement Indicators

38 Average Scale Scores on State Assessments in Reading/Language Arts and Mathematics Average Scale Scores are required to be reporting as follows: – By Grade, for the “all students” group, for each achievement quartile, and for each subgroup 38

39 College Enrollment Rates Identify the number and percentage of students who complete high school and enroll in postsecondary institutions. Data will be collected for this requirement via Survey for FY

40 Performance Metrics and Reporting Requirements Achievement Indicators Percentage of students at or above proficiency level on State assessments in reading/language arts and mathematics, by both grade level, and by student subgroup; Average scale score on State assessments in reading/language arts and mathematics, by grade, for the “all students” group, for each achievement quartile, and for each subgroup; * Percentage of limited English proficient students who attain English language proficiency; School improvement status and AYP targets met and missed; College enrollment rates; and * Graduation rate. * New Reporting requirement 40

Annual Grant Renewal While all grants are funded for three full years, there is an annual grant renewal process with continued funding contingent upon each school meeting established goals or on a trajectory to do so, as they implement rigorous interventions. School personnel are required to engage in continuous data analysis to drive their school improvement efforts. 41

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Linda C. Reeves Bureau Director Office of School Recovery Mississippi Department of Education SIG Making a SIGnificant Difference for Children! Contact Information 50 Questions