1. NCLB TITLE GRANT MANAGEMENT
ISBE Illinois Association of Title I Directors Annual Fall Conference 2014
Good Morning. My name is Santita Nunn and I am a principal Consultant in the Title Grants division at ISBE
I would like to take some time to share information with you regarding Grant Management for your Title I & Title II grants.
Let’s start with the purpose of Title I

2. Purpose of Title I
The purpose of Title I is to ensure that all children have a fair, equal, and significant opportunity to obtain a high-quality education and reach, at a minimum, proficiency on challenging State academic achievement standards and state academic assessments.
Statement of Purpose from currently authorized
Elementary and Secondary Education Act (2001)
The Elementary and Secondary Education Act clearly defines the purpose of Title I.
Title I provides funds for use in high-poverty schools to improve the achievement of the lowest-performing students—those who are failing, or most at risk of failing, in order to meet the academic achievement standards of that state.
Title I is just one of a number of programs funded under the ESEA, which has been in existence since 1965.
The US Dept. of Education’s most recent data on participation from school year shows that more than 56,000 public schools across the country used Title I funds to provide additional academic support and learning opportunities to help low-achieving children master challenging curricula and meet state standards in core academic subjects.

3. Title I Fiscal Requirements
Three fiscal requirements related to the expenditure of regular State and local funds. The LEA must:
Maintain fiscal effort with State and local funds
Provide services in its Title I schools with State and local funds that are at least comparable to services provided in its non-Title I schools
Use Part A funds to supplement, not supplant regular non-Federal funds.
- Department of Education: Non-regulatory Guidance – Title I Fiscal Issues (p.9)
To ensure that the Title I Part A fund are used to provide services that are SUPPLEMENTAL or IN ADDITION to services normally provided by a local education agency for participating children, there are three fiscal requirements that must be met by a district.
A district cannot reduce its own spending for public education, whether from state or local funds, and replace those funds with Federal funds.
A district may not “discriminate,” so to speak, against its Title I schools when distributing resources funded from State and local sources simply because these schools receive Federal funds.
Services from Title I resources cannot replace or supplant services that a district would ordinarily provide to all its students.
These requirements are critical to the success of Title I, Part A, because they ensure that the Federal investment has an impact on at-risk students the program is designed to serve.

4. Know the Governing Documents
Education Department General Administrative Requirements (EDGAR)
Office of Management and Budget (OMB) Circular A-87 *
OMB Circular A-133 Compliance Supplement *
* Combined into Super-circular (available July 2014)
There are three main documents that govern Federal programs. In this case we will be focusing on Title I Part A
You will see EDGAR, OMB A-87 Circular and the OMB A-133 Circular.
EDGAR: Governs how funds are to be distributed to the LEA’s, any program or fiscal conditions that must be met on the state/local level, the development of applications and amendments that identify the activities, which support the purposes of an act, and how grant recipients are accountable for fiscal reporting and for reporting of program performance.
A-87 defines the parameters for the use of federal funds. And the A-133 is your Compliance Supplement.
The good news is that these last two will be combined into a Super Circular; with a few exceptions most of the main requirements and components will remain the same for the FY15 grant application. Mark will speak more about this during his presentation.
These documents are the foundation of how we must go about making our decision for Title I. The following slides will provide more detail regarding some common
fiscal issues.

5. Review: What Can You Do? All costs charged to federal funds must be:
Necessary for the administration of the grant
Reasonable in light of the goals of the federal programs, the cost of the item, and the needs of the district
Allocable the cost benefits the grant in proportion to the amount charged
Authorized under state and local laws and policies
Adequately documented
While the Circular does provide specific examples of items not allowed, it is not very specific regarding what costs are allowed or not allowed.
What the Circular does do, however, is provide basic regulations. These regulations maybe tweaked a little with the new Circular but the basic principals will remain the same.
To test whether an expenditure is allowable, a district should ask itself the following questions to “test” what it can do: (Read Slide)
Is this cost necessary? For example, would it be necessary for a district to use Title I, Part A, funds for the purchase of laptop computers for targeted students?
Does it exceed the amount a reasonable and prudent person would spend on an item or salary? If the targeted students mentioned in previous example receive services spread throughout the day, is it more reasonable to buy a few laptops for them to share than to buy every student his/her own laptop?
Can the cost be allocated appropriately to a cost object in accordance with relative benefits received? Does the cost of a laptop provide a direct and proportional benefit to the cost area (e.g., instruction, media services, assessment) to which it was assigned?
Are the costs authorized or not prohibited under State and local laws? Has the district investigated any potential state and local barriers to purchase the desired laptops?
Is there sufficient documentation pertaining to the cost incurred? Does the district have documentation or data for bids, technical specifications, intended number of users, storage and security, insurance, staff training, electrical and other use requirements, internet and other child safety policies, software, site licenses, etc.?
If a cost can pass all 5 tests, it is, in all likelihood it is an allowable use of federal funds.

6. Food for Meetings and Conferences
Are meals disallowed from Title I? Even for parent meetings?
May Title I professional development funds be used for meals at workshops and conferences?
So let’s look at Food for meetings and conferences.
Are meals for parent conferences are acceptable?
So, Let’s talk about this. How many of you have 100% parent participation? How many of you have begged, and called, and prepped, and prepared for parent meetings to have 5 parents show up? We all know that if parents get home, and cook a meal for their families they will not come back to the school to see you! So for the purposes of Title I serving a meal to ensure parent participation is pertinent to the objective of the grant and is allowed.
Let’s look at the second one. Can we use Title I professional development funds for meals at workshops and conferences.
Yes. Federal grant funds may be used to host a meeting or conference if doing so is:
a. Consistent with its approved application or plan;
b. For purposes that are directly relevant to the program and the operation of the grant, such as for conveying technical information related to the objectives of the grant; and
c. Reasonable and necessary to achieve the goals and objectives of the approved grant.

7. Review Use of Grant Funds for Food
A grantee hosting a meeting or conference may NOT use grant funds to pay for food for attendees UNLESS doing so is necessary to accomplish legitimate meeting or conference business.
For example, a working lunch MIGHT be allowable if attendance at the lunch is needed to ensure the full participation by conference attendees is essential discussions and speeches concerning the purpose of the conference and to achieve the goals and objectives of the project.
However, serving breakfast on Institute Day would not be an allowable expense as it is not necessary to accomplish the meeting purpose.
If food is provided, auditors will scrutinize the agenda, documentation, and question the necessity of food purchase and its direct relationship to achieving the goals
and objectives of the meeting.
Just like we are working through lunch today. If we were to allow you to go out to purchase food, it would disturb the flow of the meeting. Therefore, in this situation, it is allowable. Additionally, going out for lunch would take away from the objectives of this meeting.

8. TALK TIME!
Scenario #1 – Background Information
Ace School District has a district-wide initiative to institute Professional Learning Communities (PLC) in all 3 of its targeted assistance buildings.
Total Title I Allocation: $300,000
The Title I coordinator finds a PLC workshop presented by Rick and Rebecca DuFour, the leading experts on PLC’s in Seattle, WA. The participant registration is $700/person and doesn’t include airfare, lodging, meals, and so forth.
The Superintendent purchases all administrators a copy of DuFour and DuFour’s book and takes them through a book study that can be used in each of the buildings.
Now that we’ve done some review, let’s do a little more exploration and work together through some scenarios.
Questions:
The Title I coordinator finds a PLC workshop presented by Rick and Rebecca DuFour, the leading experts on PLC’s. The workshop is in Seattle, WA. The participant registration is $700/person. This doesn’t include airfare, lodging, meals, and so forth. (Reasonable and necessary?) As you are considering if this will be an allowable cost what are some questions that may need to be investigated? (Possible questions: Is there a workshop closer in the area? Can you bring in someone to do a workshop for the staff on PLCs’?)
The Superintendent purchases all administrators a copy of DuFour and DuFour’s book and takes them through a book study that can be used in each of the buildings. (Reasonable?) yes.
Regardless of District-wide initiatives PD is only to be used for buildings and teachers in buildigs that receive Title funds.

9. When Does Supplanting Occur?
The OMB A-133 Compliance Supplement details three
general situations where an auditor will presume that
the use of federal funds violates the “supplement, not
supplant” requirement.
Required by law
Supported last year with state and/or local funds
Provided to everyone (including building not funded by Title I)
A good question in any “supplement, not supplant” analysis should be, “Could this program or expenditure be implemented if federal funds were not available?”
When in doubt, auditors “presume” that supplanting has occurred until it is established that this has not happened. A-133 outlines three general situations when supplanting is presumed to have occurred.
The first presumption concerns whether the expense is required by law. For example, using Title I funds to provide accommodations for students with disabilities would be considered supplanting since such accommodations are required by federal and state law as well as court mandates.
The second presumption concerns whether an expense was supported by federal funds in the previous year. For example, if the district provided after-school tutoring with local funds in the prior year, to move those program costs now to federal funds would be supplanting.
The final presumption concerns whether the expense was incurred by a program for all students. For example, if a district offers kindergarten to all students, federal funds may not be used to cover costs for some of the students in a later school year.

10. Overcoming Presumptions of Supplanting
A presumption of supplanting can be overcome by providing written documentation proving:
State and local funding were significantly reduced.
The position would have been eliminated in the absence of NCLB funds.
The grant allows the expenses.
Funding decisions are made on an annual basis.
Overcoming presumptions of supplanting may be illustrated by the following examples:
If a district had title I reading specialist whose salary was 50% locally funded the last year…. The district has received their current year allocation and noticed a small increase. Is it considered supplanting to add this teacher into the Title I grant. (This is normally considered supplanting. )
If a district uses Title I funds for allowable costs in the grant, such as homeless student supply costs, this is not supplanting. The district may have used other funds for homeless students in the past. However this cost is allowable within Title I.
If a district proposes in its Title I application to do professional development about middle school reading, then the needs assessment in the application should reflect a need for such instructional support. Likewise, the goals/activities/evaluation page in the application should appropriately address this professional development. In other words, the annual application should reflect funding decisions that are made thoughtfully, supported by data, and are complimentary to the needs identified in the various improvement plans.

11. TALK TIME!
Scenario #2 – Supplement or Supplant
Targeted Assistance Building – Purchase of RtI intervention kit
Schoolwide Building – Aimsweb testing materials for all students
Targeted Assistance Building – 1.0 FTE 3rd grade General Education Teacher
Targeted Assistance Building – Computer adaptive tests for Special Education Students
Ok…So let’ take a look at these four examples
Questions:
Supplant because RtI is a state mandate.
Supplemental because all students in a schoolwide building are Title I
Supplanting because General Ed teachers serves all students through Targeted Assistance Program. An interventionist would be required at a Targeted Assistant School.
Supplanting because accommodations for SPED are required by law.

12. TALK TIME! Scenario #3 – Supplement or Supplant
This year, Very Special School District is experiencing a large reduction in local funds and 10% of the staff will be RIF’d, including 2 Title I teachers that were previously funded by local dollars.
Can Very Special School District use Title I funds this year to pay for these 2 Title I teachers? Why or Why not?
Questions:
1. Yes, you can use Title I funds to pay for the very special teachers. Under ordinary circumstances, this would be considered supplanting. However, remember slide 10, you can overcome the presumptions of supplanting. So, in this case, the district can recall those 2 teachers. Keep in mind, it is imperative that the district maintains pertinent documentation regarding the matter. Documentation can include again the board minutes and the budget.

13. Schoolwide Programs Comprehensive reform strategy
Designed to upgrade the entire educational program in Title I, Part A
It ensures that all students, particularly those who are low achieving, demonstrate proficient and advance levels of achievement.
Let’s talk about Schoolwide programs!
Schoolwide programs are part of a comprehensive reform strategy designed to upgrade the educational system by addressing low-achieving students and helping them become proficient.
According to the April issue of the Title I Monitor, over 70% of all schools receiving Title I, Part A funds operate schoolwide buildings, which means the school has reached a threshold of 40% poverty, completed a thorough planning process, which can take up to one year, and there’s an approved schoolwide plan to implement.
How many of you have gone from targeted Assistance to Schoolwide?
How has that impacted your district?

14. TALK TIME! Scenario #4 – Schoolwide:
Do you have to provide pull-out instruction if your school is schoolwide?
Can a school provide benefits/services to students who are not struggling?
Happy Elementary School wants to use their Title I funds to purchase items that would help to improve attendance, and behavior. Can they use their Title I funds to make the purchases?
Let’s talk!!
No. You can do pull-out instruction if it makes the most sense instructionally, but it is not required.
Yes. Under a schoolwide implementation, all students can benefit from Title I investments.
Yes. Title I funds can be used for more than just academics. The funds may be used for school climate, anti-bullying efforts, and positive behavioral and intervention supports.

15. Schoolwide Flexibility
ISBE is introducing the option of consolidation of funds to increase the flexibility in use of these funds to support comprehensive reform work as described in the Title I, Part A schoolwide program plan. More information:
Schoolwide buildings will have the option to consolidate their Title I, Part A and Title II, Part A funds.
• Schools participating in flexibility have the traditional supplement not supplant test is removed.
Unfortunately, if your school is Targeted Assistance, you will still have to abide by the supplement vs. supplant
• All children in the schoolwide building may participate in activities funded with consolidated funds (consistent with the school’s comprehensive schoolwide program plan), and the school does not need to demonstrate that those activities are supplemental to ones that would otherwise be provided by the school.
You may go to the link that is shown on the bottom of this slide for further information. Melina will also talk more about this in her presentation.

16. Schoolwide Flexibility
Schoolwide flexibility expenditures are governed by three principles:
is the expenditure reasonable and necessary,
does it meet the intent and purpose of the law and is aligned with the schoolwide plan, and
does the school receive at least as much state and local resources as non-Title I schools.
Title I, Part A funds must still be used to ensure that all students, particularly those who are low achieving, demonstrate proficient and advanced levels of achievement relative to the state’s academic achievement standards.
Therefore, extraneous costs (football fields, excessive travel, etc.) would still be prohibited, but schools would be able to maximize the consolidated funds to meet its schoolwide reform goals.
With Schoolwide flexibility, it now becomes allowable to use Title I, Part A funds for activities related to state-mandated initiatives ….
(e.g., Common Core, RtI, textbooks), provided those activities and costs align with the schoolwide plan.

17. TALK TIME!
Scenario #5 – Background Information SDN School District #1 has set aside $50,000 for Professional Development, but they have only used $25,000 and would like the Health teachers to participate in several training opportunities regarding new statewide initiatives. Is this allowable?
OK…TALK TIME!
Take a minute and read this scenario!
According to Title I guidelines funds are to be used “to ensure that all students, particularly those who are low achieving, demonstrate proficient and advanced levels of achievement relative to the state’s academic achievement standards.” 
Under the new flexibility-Title I funds must still be used to meet the intent of the law. However, if they have unspent funds, then they can use the remaining funds for other Title I costs.

18. DRAFT - ISBE INTERNAL USE ONLY
5/15/2018
COMMON BUDGET PROBLEMS
Function/object name NOT a sufficient/acceptable itemization or description.
Function 1000: Direct STUDENT instruction (not admin, not secretaries, not janitors).
Object 100: Fiscal agent’s employees. Do not include names
Object 200: “Benefits” not a sufficient nor acceptable itemization. Please itemize what benefits are being requested. Include amounts.
The next few slides give you some helpful hints for the budget section of the grant.
Function 1000 is for DIRECT student instruction.
 Including instructional Summer School/after & before school instructional activities.
 Staff names are not required in the details in object 100 – salaries. Social security numbers and FEIN numbers should not be included.
 Please elaborate on what benefits are being requested. Percentages are not required, but if multiple benefits are included in one cell, they must equal the line total.
For example, 30,000, 5,000, 5,000 = 40,000.
Salaries/Stipends paid to certified staff should include TRS in object 200
TRS- Teachers’ Retirement System
IMRF- IL Municipal Retirement Fund
FICA- Fed. Insurance Contributions ACT

19. COMMON BUDGET PROBLEMS
Object 300: Workers/Unemployment Compensation are a purchased services not a fringe benefit. Software licenses and ON-LINE subscription services
Object 400: Purchase of software, equipment costing less than $500/unit, and ALL supplies/materials (no matter what the cost).
Object 500: Equipment costing more than $500/unit. BUDGET details should include: items requested, per unit and total price, location of items, purpose of items and proration, if any.
Object 300: would be workers/unemployment compensation – these are employer insurances – NOT fringe benefits.
Also included in object 300 would be software site licenses; and on-line subscriptions services. (learning A-Z; Renaissance Learning; BrainPop; Ipad/Itune Apps
Object 400: SUPPLIES/MATERIALS are always budgeted in object 400 (no matter what the price).
-purchase of a software package would be budgeted in object 400. Itune cards
  -Equipment costing < $500/unit should also be budgeted in object Include the per unit cost on any equipment purchased.
If equipment is being requested (object 500 or object 700) – you must complete the budget details with all the required info:
-list items requested; list unit price and total cost; location of items; purpose of items; proration, if any
-so I would expect to see in the budget details in function 1000/obj 500: 3 Dell $800/unit for $2400, that are housed in classroom for direct student instruction. And if there is a proration, for example - 1/2 Title I, ½ district funds - then only $1200 would be on the T1 budget.
-if the piece of equipment costs > $500/unit but the grant will be paying only a portion, the item still should be budgeted in object 500 WITH AN EXPLANATION that the equipment is $1000, but this grant will be paying only $400 of the cost.

20. DRAFT - ISBE INTERNAL USE ONLY
5/15/2018
COMMON BUDGET PROBLEMS
Object 700: IF AND ONLY IF there is a BOARD-APPROVED, ENTITY-WIDE threshold for non-capitalized equipment of > $500/unit. Budget details MUST include approved threshold. Example: District #100 BOARD-APPROVED, ENTITY-WIDE threshold for non-capitalized equipment is $5000.
-Object 700 is to be used IF and ONLY IF the district has a BOARD-approved – district-wide equipment threshold of greater than $500/unit;
IF you have a board-approved, district-wide equipment threshold of > $500; this equipment threshold MUST also be included in the budget detail description.
Example: BOARD-approved – district-wide equipment threshold = $5000.
-Equipment purchased = $3000 (so this piece of equipment is greater than $500 and less than $5000) would be in object 700.
-any equipment costing more than your threshold ($8000 for example) then this item would be budgeted in object 500.
-as ALWAYS, equipment costing less than $500/unit should be budgeted in object 400.

21. COMMON BUDGET PROBLEMS
Function 2210: Improvement of Instruction: STAFF development and CURRICULUM planning (for staff – NOT direct student instruction).
Function 2220: Media services. The costs budgeted here are for services/supplies/equipment housed in a central location. Library/lab/media center.
1. Staff Development/curriculum planning budgeted in function Covers in-services, conferences, planning time all would be in function It is NOT for direct student instruction.
2. Function 2220: Media services. The costs budgeted here are for services/supplies/equipment housed in a central location. Library/lab/media center.

22. COMMON BUDGET PROBLEMS
Function 3000: Community Services: Parent activities and non-public school services/activities.
Function 4000: Payments to other LEAs and governmental units: PUBLIC governmental units being paid. Budget details must include what governmental unit is being paid.
Function 3000: parent activities and private school students/staff costs should be budgeted here.
Function 4000: payments to other LEAs and PUBLIC governmental units would be budgeted here.
- include what governmental unit being paid and what services are being requested. If applicable, the private school share of costs paid to another PUBLIC, GOVERNMENTAL UNIT should also be included here…
Example: payment to the U of I for staff development activities - one row for public school share/one row for private school share including the amount for each.

23. TALK TIME! Scenario #6 – Common Budget Problems
Benedictine University in Springfield is conducting a staff development workshop “School improvement for Learning Growth.” What are the function and object codes?
School ABC is purchasing I-Read software for Title I students for $700. What are the function and object codes?
Ok . So let’s talk out a few scenarios. What are the function and object codes
Take a look at the first Scenario. What would the function and object code be? The guideline stipulates “ Payments to other LEAs and governmental units: PUBLIC governmental units being paid… This is a purchased service. Benedictine is a private school…so it would be 2210/300. If it were University of Illinois then it would be 4000/300.
So in your line description please make sure the Budget details include what governmental unit being paid.”
Take a look at the second one. This would be 1000/400. Software is software is software and goes under 1000/400 no matter the cost!

24. Final Thoughts
Contact your designated ISBE consultant if you have questions.
Consult the documents and publications for guidance.
Frequently check the ISBE website for updated e-bulletins.

25. Questions/Comments

26. Thank You abates@isbe.net snunn@isbe.net
Agurann Bates, Principal Consultant
Santita Nunn, Principal Consultant