Title I Coordinator Training Fiscal and Internal Controls October

Essential Questions How are LEA allocations for Title I determined? How can Title I funds be used? What are the steps to creating a Title I budget? What internal controls must be in place to ensure compliance? 2

Title I Allocation Timeline 3 March Preliminary Title I, Part A allocations received from US DOE to DEDOE June Final Title I, Part A allocations received from US DOE to DEDOE July DEDOE loads final allocations into Consolidated Grants DEDOE calculates allocations based on derived poverty census December US DOE provides census poverty data for 16 geographic districts

Calculating LEA Title I Allocations Inputs Poverty Census data Foster care children count Unit count free and reduced lunch Unit count enrollment Students lost to vocational districts Students lost to charter schools 4

Allocation Process Step 1: Determine Poverty Rates 1.Use students lost to vocational schools and charters to reduce the census poverty estimates of the 16 geographic districts 2.Redistribute lost census poverty to the vocational and charter schools using free and reduced lunch 3.Add foster care children to census poverty for the 16 geographic school districts 4.Use unit count enrollment data to calculate final poverty rates for all districts and charter schools Step 2: Determine Eligibility 1.Determine which LEAs are eligible for Title I, Part A (10 poverty children and 2% poverty rate or hold-harmless) 5

Allocation Procedures Step 3: Allocate Funds 1.Allocate funds to eligible LEAs from the four funding grants that comprise Title I, Part A using the eligibility rules below : 6 Basic Grants 10 children in poverty 2% poverty rate Targeted Grants 10 children in poverty 5% poverty rate Concentration Grants 6,500 children in poverty 15% poverty rate Education Finance Incentive (EFIG) Grants 10 children in poverty 5% poverty rate

Title I Budget Parameters Supplement Not Supplant A State educational agency or local educational agency shall use Federal funds received under this part only to supplement the funds that would, in the absence of such Federal funds, be made available from non- Federal sources for the education of pupils participating in programs assisted under this part, and not to supplant such funds. (Section 1120(b)(1)) 7

Presumption of Supplanting Supplanting is presumed to have occurred when Title I funds are used to provide services that are: required by Federal, State or local law Examples: –Using Title I funds to meet state class size reduction requirements. –Using Title I funds to provide services that must be provided under a childs IEP provided in previous years with other non-federal funds. provided to children in a Title I program and provided to children in non-Title I programs with non-federal funds. Example: –Purchasing a reading software program for a Title I school and using State or local funds to purchase the software for non-Title I school. 8

Allowable Costs Title I, Part A funds must be used to support academic achievement and assist students in meeting the states challenging academic achievement standards. (Section 1001 of the ESEA) Regulations that govern the use of Title I, Part A Funds EDGAR (Education Department General Administrative Regulations) Part 76 OMB A-133 Compliance Supplement OMB A-87 9

EDGAR and A-133 EDGAR prohibits the use of funds for: religious activities the acquisition of real property or construction Directs grantees to A-87 for general cost principles A-133 Provides an audit guide for auditors to audit financial statements and monitor compliance 10

OMB Circular A-87 To be allowable, a cost must generally: Be necessary and reasonable for the proper performance and administration of the grant award. Be allocable to a specific allowable costs under the cost principles Be authorized or not prohibited under state or local laws or regulations Conform to any applicable statutory or regulatory limitations Be consistent with policies, regulations and procedures that apply uniformly to both Federal awards and other activities of the governmental unit Be accorded consistent treatment Be determined in accordance with generally accepted accounting principles (GAAP) Not be included as a cost used to meet cost sharing or matching requirement Be the net of all applicable credits Be adequately documented 11

Required Set-Asides LEA level set-asides 1% for parent involvement if total allocation exceeds $500, % for professional development if LEA is under improvement 20% for Choice/SES if LEA has any schools in year 1 + of school improvement Funds to provide educationally related support services to eligible homeless children School level set-asides 10% for professional development for any school in year 1 + of school improvement 12

Optional Set-Asides Funds to administer programs for public and private school children LEA level instructional set-asides Examples: –The LEA purchases a software program for use by all Title I schools to track student performance –The LEA purchases and operates an educational television program for use by all Title I schools 13

Other Important Fiscal Rules LEAs must provide equitable services to participating private schools on the following set-asides: –Parent Involvement –Non improvement-related professional development –LEA Instructional set-asides LEAs must distribute 95% of the 1% parent involvement set-aside (after equitable services are taken) to schools LEAs must ensure that schools identified for corrective action or restructuring do not have an allocation reductions of more than 15 percent as compared to previous years. 14

Important Fiscal Rules Continued LEAs budgeting funds for audit costs must ensure that Title I, Part A isnt paying a disproportionate share of the total audit costs LEAs serving schools with poverty rates below 35% must allocate to all its schools at least 125% of the LEAs Per Pupil Allocation (PPA) Note: The PPA must be calculated before any set-asides are taken. LEAs must serve schools in rank order based on the percent of poverty either on an LEA-wide or grade span basis. 85% of Title I funds must be obligated/spent by September 30 of the second year of the grant. 15

Calculating Equitable Services LEAs must provide an equitable share of funds reserved for: parent involvement; non-improvement related professional development; and LEA-wide instructional activities to participating private schools. LEAs calculate the proportion of low income private school children to the total of all low-income children (public and private) in participating attendance areas. This proportion is then applied to the total set-aside to calculate the amount that must be made available to the private schools. Low income private school students from participating public schools generate the same PPA as public school students from that participating public school. 16

17 Lets take a 10 minute break

Rethinking the Budgeting Process 1.Determine LEA distributions and set asides 2.Determine school eligibility using school level poverty data 3.Determine how you will decide what schools to serve (single tier on ranked poverty, two or more poverty tiers on ranked poverty, two or more grade span tiers on ranked poverty) 4.Determine PPA(s) 5.Allocate money to schools using tier(s) and PPA(s) 6.Determine private school equitable share from LEA distributions and equitable share from school allocations 7.Determine school distributions and set asides 8.Determine specific budgeted items from LEA and school distributions. 18

Overview of Title I Budgeting Tool Dynamic based on different LEA scenarios (i.e. improvement status, grade span makeup, etc.) Limited LEA data entry Calculates required set-asides automatically Calculates equitable services automatically 19

Lets 20 Group Activity on Developing a Title I, Part A Budget

Internal Controls Semi- Annual Certifications and Time & Effort Logs Equipment Records retention Annual and final reports 21

Semi Annual Certifications Required for employees who work on one federal program Prepared twice a year No required format Signed by the employee OR supervisor having first-hand knowledge of the work performed Acknowledges that the employee worked solely on the Federal program for the period covered by the certification. 22

Sample Semi-Annual Certification TO: Whom it May Concern SUBJECT: Verification of Time and Effort I verify by my signature that I spent 100% of my time on the designated program during the during the time period from July 1, 2002 through December 31, Employee Name ProgramEmployee Signature Jane Doe100% IDEA (L) TQM Jane Doe Joe Smith100% Title I, Part A Joe Smith I Concur: [Supervisors Signature] [Supervisors Name] [Supervisors Title] 23

Time and Effort Logs Employees who work on multiple federal programs Completed monthly and coincide with one or more pay periods DEDOE has a required form Reflects an after-the-fact distribution of actual activity of employee Must account for total activity for which employee is compensated Must be signed by the employee Required Time and Effort form available here: S/TimeandEffortLog.xls 24

Equipment Equipment definition: an article of personal property having a useful life of more than one year and acquisition cost which equals or exceeds $1,000. Inventory records must be kept for all equipment purchased Inventory must be taken least once every 2 years Control system must be in place to prevent loss, damage or theft All equipment, whether it is federal or state owned, must be disposed of through the Delaware Office of Management and Budgets Government Support Services, Surplus Services Office. 25

Equipment Records Equipment records must include: A description of the equipment A serial # or other id # The source of equipment Who holds the title Acquisition date and cost Location, use and condition of equipment Any disposition data (including date of disposal and sale price) All equipment at private schools must be marked Property of XXXX School District 26 Additional guidance on equipment available here: ES/DISPOSITION.pdf

Records Retention Records must be maintained for three years from the date the grantee submits its last expenditure report Equipment records must be kept for three years from the date of disposition, replacement or transfer. 27 Additional guidance on records retention available here: ES/RECORDSRETENTION.pdf

Annual and Final Reports Annual reports are due July 15 of the second year of the grant Final reports are due March 31 of the second year of the grant DEDOE has a required format for annual and final reports 28

Additional Resources US ED Non-Regulatory Guidance on Title I Fiscal Issues A/TitleIFILES/fiscalguid2008.doc Section 1120A of the ESEA 20A DEDOEs Title I Technical Assistance Session Materials Sample Semi-Annual Certification A/TitleIFILES/SAMPLECERTIFICATION.doc A/TitleIFILES/SAMPLECERTIFICATION.doc Required Time and Effort Form A/TitleIFILES/TimeandEffortLog.xls A/TitleIFILES/TimeandEffortLog.xls Government Support Services equipment disposal 29

30 Thanks for coming!