1. Improving LEA MOE Data through Procedure and Practice
Steve Smith and Sara Doutre, Center for IDEA Fiscal Reporting
Lisa Morrissette, New Hampshire Department of Education
Mary Ellen Parrish, Washington Office of Superintendent of Public Instruction

2. Improving LEA MOE Data through Procedure and Practice
Outcome
Participants will gain an understanding of the importance of high quality procedures and practices for collecting, validating and reporting MOE data.
Agenda
Outline LEA MOE basics and reporting requirements (see LEA MOE Quick Reference Guide handout)
Learn from states and TA providers about importance of procedures
Examine guiding questions for high quality LEA MOE procedure content
Discuss how CIFR and other TA tools and resources support LEA MOE procedure and practice

3. LEA MOE Basics – What we know

4. What is LEA MOE?
IDEA obligates any LEA receiving IDEA Part B funds to budget and spend at least the same amount of local – or state and local – funds for the education of children with disabilities on a year-to-year basis.
Requirements are complex
Four tests
Subsequent years, intervening years
Very specific requirements for exceptions
LEA MOE is high stakes
Eligibility test to get IDEA funds
Failing compliance test can lead to paying money back

5. What are the required LEA MOE data elements?
Current LEA MOE Data Elements
LEA/ESA 611 and 619 allocations for the reference and previous FFY
MOE reduction includes:
Determination under 34 CFR § (a)(2) for each LEA/ESA and
Amount of reduced funds taken under Section 613(a)(2)(C) for the reference school year

6. What are the required LEA MOE data elements? (cont.)
New LEA MOE Data Elements
Did the state determine whether the LEA/ESA met the MOE compliance standard in the reference year?
Did the LEA/ESA meet the MOE compliance standard in the reference year?
By the date of the referenced data submission, did the state return non- federal funds to ED based on the failure of the LEA/ESA to meet the MOE compliance standard in the reference year?
What amount of non-federal funds did the state return to ED based on the failure of the LEA/ESA to meet the MOE compliance standard in the reference years

7. Data Quality Considerations
How do you know if LEAs/ESAs reduced MOE correctly?
If LEAs/ESAs:
received a federal IDEA 611 allocation for the current FFY;
had an increase in federal IDEA 611 allocations;
had a “meets requirements” determination;
were not required to reserve CEIS funds; and
established and maintained programs of free appropriate public education (FAPE) that meet the requirements of Section 613(a)
Then, LEAs/ESAs may reduce MOE by 50% of the increase in IDEA 611 allocation depending on whether or not the CEIS is voluntarily implemented.

8. CIFR State Interviews on LEA MOE
Data based on interviews with 35 states conducted by CIFR staff in 2015
What did we learn?
Almost all states have sufficient, trained staff.
Best practices include plans for transition to new staff and back-up staff assigned and trained.
60% of states do have written procedures, does not always equate to high quality data.
Procedures are also in the form of instructions for forms or reports.

9. CIFR State Interviews on LEA MOE (cont.)
Summary of State Strengths
Data tools and systems (16 states)
Communication with LEAs (12 states)
Staff knowledge and collaboration (10 states)
Data validation procedures (5 states)
Only a few states mentioned resources for LEAs as a strength
Summary of State Challenges
Building LEA capacity (9 states)
SEA staff capacity (5 states)
Data collection systems (5 states)
Lack of documented procedures (11 states identified by CIFR)

10. Requirements beyond the data elements
LEA MOE Eligibility Determinations
LEA MOE Compliance Determinations

11. TA on High Quality Written Procedures

12. LEA MOE Procedures Community of Practice
Objective:
Each state will finish the series with draft written LEA MOE procedures that will assist the state to collect and report valid and accurate LEA MOE data.
Outcomes:
Several states developed procedures, others used the experience to evaluate and revise their existing procedures
Lessons learned about topical communities of practice
Potential CIFR products including a sample outline for written LEA MOE procedures

13. State Perspective on the CIFR LEA MOE Procedures CoP – New Hampshire

14. State Perspective
Why did NH choose to participate in the LEA MOE Procedures CoP?
What has the process been in your state to develop written procedures?
What benefits have come of your work?
What challenges have you faced?
What lessons have you learned from the work?

15. State Perspective on LEA MOE Procedures – Washington

16. State Perspective Why has WA made LEA MOE a priority?
What has the process been in your state to develop LEA MOE procedures?
What benefits have come of your work?
What challenges have you faced?
What lessons have you learned from the work?

17. Working Session – What should be in each state’s written LEA MOE procedures?

18. LEA MOE Requirements, Required Data Elements
Guiding Questions
What is LEA MOE?
What are the federal regulations related to LEA MOE?
Are there any state regulations or policies related to LEA MOE?
What are the reporting requirements?
Resources
CIFR LEA MOE Quick Reference Guide

19. Timeline, Applicability to LEAs, Responsibilities
Guiding Questions
What is the state’s fiscal year?
What is the timeline for the eligibility standard? The compliance standard? Reporting?
To whom do these requirements apply? (LEAs, Charter Schools, Special Schools, etc.)
Resources
CIFR IDEA MOE Regulations Crosswalk
CIFR Implementation Considerations

20. Four MOE Calculation Methods
Guiding Questions
Who calculates each of the four methods?
What is included in/excluded from each calculation?
How does the SEA or LEA separate local from state expenditures?
Resources
OSEP Guidance – Section A
Letter to Kennedy
Letter to Copenhaver
Letter to White

21. Eligibility Standard, Compliance Standard – who, what, when, how?
Guiding Questions
When are data collected for eligibility? Compliance? What is collected and from whom?
How are the data collected? Validated? Stored? Decisions documented?
How does the SEA determine eligibility? Compliance?
Resources
OSEP Guidance – Sections B&C
CIFR LEA MOE Calculator
Video: LEA MOE: Mechanics of the Revised Regulations
Letter to a Chief State School Officer (2014)
Letter to Anonymous

22. Exceptions, Intervening Year, Subsequent Years Rule
Guiding Questions
What is the process for exceptions? Documentation required?
How does the state define terms in the exceptions?
What is the process for approving or denying exceptions?
How does the state implement the intervening year and subsequent years rules?
Resources
OSEP Guidance – Section D
CIFR LEA MOE Calculator
Letter to Lovato
Letter to Gonzales
Letter to Boundy
Letter to Andrejack

23. MOE Adjustment, Tracking Freed-up Funds, Interaction with CEIS
Guiding Questions
What is the process for collecting data on and approving LEA MOE adjustments?
How is this coordinated with program offices (determinations, disproportionality)?
What is required for the freed-up funds when an adjustment is taken?
Resources
MOE Reduction Eligibility Decision Tree and Worksheet
Letter to Michelson and Mayes

24. EMAPS Data Reporting Guiding Questions Resources
Who is responsible? What is the timeline? What are the steps?
How is each data element verified or validated?
Who writes any required data notes? Is there a process?
Resources
EMAPS IDEA Part B MOE Reduction and CEIS – User Guide
Data Notes Practice Guide
618 Data Pre-submission Edit Check Tool – Part B MOE and CEIS

25. Consequences of Failure, Payback Procedures
Guiding Questions
How does the SEA calculate the amount of MOE shortfall?
What is the process for notifying the LEA and returning funds to the US Dept of Education?
Resources
OSEP Guidance – Section E
CIFR LEA MOE Calculator
Letter to Baglin

26. Training and Communicating with LEAs
Guiding Questions
What training materials are made available to LEAs? How? When?
Who is/are the SEA contact/s for LEA MOE?
Is there a standard reporting tool? With instructions? Training?
Resources
All of the above!

27. CIFR Tools
Local Educational Agency Maintenance of Effort (LEA MOE) Calculator: (
Data Notes Practice Guide: ( content/uploads/2016/08/CIFR-Program-Model_Notes.pdf)
Quick Reference Guide on IDEA Local Educational Agency Maintenance of Effort: ( content/uploads/2015/12/CIFR-LEA-MOE-QRG.pdf)

28. IDC Tools
IDEA Data Training Modules: (
Collecting and Reporting the New Data Elements Related to the Local Education Agency Maintenance of Effort Provisions (
618 Data Pre-submission Edit Check Tool — Part B MOE and CEIS: (
MOE Reduction Eligibility Decision Tree and Worksheet: (

29. Questions? Comments?

30. Contact Us
Visit CIFR’s website at Steve Smith: Sara Doutre: Lisa Morrissette: Mary Ellen Parrish:

31. Thank you!
The contents of this presentation were developed under a grant from the U.S. Department of Education, #H373F However, those contents do not necessarily represent the policy of the U.S. Department of Education, and you should not assume endorsement by the Federal Government. Project Officer: Daniel Schreier. July 2017.