1. 2015 Leadership Conference “All In: Achieving Results Together”
Leveraging Federal Funds to Improve Outcomes for Students with Disabilities
Lisa Pagano and Daniel Schreier
U.S. Department of Education, OSEP
and
Teri Chapman
Michigan Department of Education

2. Session Objectives
Provide examples of how Federal funds can be leveraged to improve student outcomes
Share an example of how an SEA analyzes and utilizes its IDEA State-level funds
Discuss perceived barriers to blending and braiding funds
Offer suggestions about how to work with auditors to ensure accountability for braided and blended funds

3. Blended Funding Blended funding:
Financial assistance from individual funding streams to States, local governments, and other pass-through entities is merged by all stakeholders into one award and each individual award loses its award-specific identity

4. Example of Blending Funds
LEAs that consolidate Title I, IDEA and Title III funds for schoolwide programs (see 34 CFR § )

5. Braided Funds Braided funding:
Financial assistance from individual funding streams to States, local governments, and other pass-through entities is coordinated by all stakeholders so each individual award maintains its award-specific identity

6. Example of Braiding Funding
An LEA has a multi tiered system of support (MTSS) where Federal program funds are used to serve each program’s subgroup of students. For example:
10% of the students participating in the MTSS are children with disabilities and the LEA uses 10% of its IDEA funds to serve those children.
15% of the students participating in the MTSS are English language learners and the LEA uses 15% of the Title III funds to serve those children.

7. Braided Funding Costs are assigned to the appropriate funding source
Allocation means the process of assigning a cost, or a group of costs, to one or more cost objective(s), in reasonable proportion to the benefit provided or other equitable relationship. See 2 CFR § 200.4

8. Sequencing Funds Sequenced funding:
Financial assistance from individual funding streams to States, local governments, and other pass-through entities is coordinated and sequentially used by all stakeholders while each individual award maintains its award-specific identity.

9. Example of Sequenced Funding
Transitions for children with disabilities
IDEA Part C to IDEA Part B
IDEA Part B to adult services supported by funds from other State and Federal sources, including vocational rehabilitation

10. Why Leveraging Funds is Important
Maximizes the impact of available funding
Avoids duplication
Promotes better planning of how available funding sources can be used to improve results for all students, including students with disabilities

11. Allowable Costs for All Federal Funds
Please keep in mind that the cost charged to Federal awards must be – 1) Reasonable 2) Necessary 3) Allocable See 2 CFR §§

12. Examples of Existing Flexibilities

13. Encouraging Blending Funds
(e) Other Provisions to Support Teaching and Learning – Each State plan shall contain assurances that –
(9) the State educational agency will encourage schools to consolidate funds from other Federal, State, and local sources for schoolwide reform in schoolwide programs under section 1114;
(10) the State educational agency will modify or eliminate State fiscal and accounting barriers so that schools can easily consolidate funds from other Federal, State, and local sources for schoolwide programs under section 1114;
ESEA, Section 1111(c)(9) and (10)

14. Schoolwide Programs
“…a comprehensive reform strategy designed to upgrade the entire educational program in a Title I school; its primary goal is to ensure that all students, particularly those who are low achieving, demonstrate proficient and advanced levels of achievement on State academic achievement standards.”
Designing Schoolwide Programs Non-Regulatory Guidance, pg. 2, March 2006, lead/account/swp.html

15. IDEA Funds in Schoolwide Programs
Blending Title I and IDEA funds in a schoolwide program has been permissible since the IDEA’s reauthorization in 1997
Blending is permissible as long as students with disabilities, included in such schoolwide programs:
receive services in accordance with a properly developed IEP; and
are afforded all of the rights and services guaranteed to children with disabilities under the IDEA
See 34 CFR § (c)

16. Calculating and Consolidating IDEA Part B Funds for Schoolwide Programs
Determine the amount of funds the LEA received for IDEA section 611 (ages 3-21) and IDEA section 619 (ages 3-5) programs
Calculate a per capita dollar amount
Divide the total of IDEA grants by the number of children with disabilities ages 3-21 in the LEA’s jurisdiction
Multiply the per capita amount by the number of children with disabilities who will participate in the schoolwide program

17. Calculating and Consolidating IDEA Part B Funds for Schoolwide Programs
Example
(1) Section 611 award (3-21)
$915,951
(2) Section 619 award (3-5)
$30,784
(3) Total Part B grant funds
$946,735
(4) Number of CWD in LEA (3-21)
502
(5) Per capita amount (line 3 divided by line 4)
$1,885.92
(6) Number of CWD to participate in the schoolwide program 52
(7) Amount of IDEA Part B funds that can be used for the schoolwide program (multiply line 5 by line 6)
$98,068

18. Compliance Supplement 2015: Schoolwide Programs
Explains to auditors the flexibility
A schoolwide program school that consolidates Federal, State, and local funds in a consolidated schoolwide pool may use those funds for any activity in the school. (Consolidating funds in a schoolwide program means that a school treats the funds like they are a single “pool” of funds—i.e., the funds lose their individual identity and the school has one flexible pool of funds.) However, the school still must ensure that funds from the schoolwide pool are used to address the specific educational needs of the school identified by the needs assessment and articulated in the schoolwide plan.
The school is not required to maintain separate records that identify by program the specific activities supported by those funds. Also, the school is not required to meet most of the statutory and regulatory requirements of the Federal programs included in the consolidation as long as it meets the intent and purposes of those programs.
Excerpt: U.S. Department of Education, A-133 Compliance Supplement Cross-Cutting Section, 2. Schoolwide Programs, Compliance Requirements, p

19. Compliance Supplement 2015 New Focus for Auditors - SEA
Determine whether the SEA has taken steps to (1) notify its LEAs of the authority to consolidate federal, state, and local funds in schoolwide programs; and (2) remove fiscal and accounting barriers preventing such consolidation of funds.

20. Compliance Supplement 2015 New Focus for Auditors - LEA
Determine whether (1) the schools operating schoolwide programs were eligible to do so, (2) the schoolwide programs included the core elements and components, (3) funds included in the schoolwide program were used to address specific educational needs that the school identified in the needs assessment and that were articulated in the schoolwide plan, and (4) the annual evaluation of the results achieved by the schoolwide program and revision of the schoolwide plan based on that evaluation were completed.

21. Discussion #1
The Department has issued guidance multiple times on blending funds for schoolwide programs, but we understand that few LEAs blend IDEA and Title I funds.
What are the barriers?
What else could the Department do to assist with use of this flexibility?

22. Coordinated Early Intervening Services
Coordinated Early Intervening Services (CEIS) is a set of coordinated services for students in kindergarten through grade 12 (with a particular emphasis on students in K-3) who are not currently identified as needing special education or related services, but who need additional academic and behavioral support to succeed in a general education environment.
IDEA Section 613(f); 34 CFR § (a)

23. Leveraging Resources: CEIS
FFY 2009/ SY
FFY 2010/ SY
FFY 2011/ SY
# of LEAs/ESAs required to reserve funds for CEIS due to significant disproportionality
405
(2.7%)
356
(2.4%)
345
# of LEAs/ESAs that voluntarily reserved funds for CEIS
1,597
(10.7%)
1,337
(9.1%)
1,270
(8.5%)
# of children who received CEIS during reporting period
1,124,9531
1,258,7631
1,008,488
# of children who received CEIS any time in past two school years and received special education and related services in reporting period
132,3511
178,8321
149,778
1 Data reflect an approximation due to some counts being suppressed for privacy protections in the public release data file. Data files may be found at:

24. Leveraging State-level Funds for SSIP Implementation
As States move to the planning and implementation phases of the SSIP, they will need to think creatively about how to use State-level funds and braid them with other funding sources.
The Analysis of State Infrastructure section of the SSIP requires States to describe the –
“capacity of its current infrastructure to support improvement and build capacity in LEAs to implement, scale up, and sustain the use of evidence-based practices to improve results for children with disabilities.”
See SPP/APR Indicator B-17

25. IDEA 611 and IDEA 619 State-level Activities
IDEA 611 and 619 State-level activities funds can both be used for direct services for ages 3-21 and 3-5, respectively. Other uses of funds must be in accordance 34 CFR § (b)(4) for 611 funds and 34 CFR § for 619 funds.

26. Other State-level Activities
Voluntary: “States may reserve a portion of their allocations”
§ (b)(1)
Approximately 10% of each State’s IDEA allocation is available for Other State-level Activities
This amount exceeds $1 billion available on a yearly basis

27. IDEA 611 other State-level Activities
State-level activities funds can be braided with other Federal/State funds for:
Assistance in meeting personnel shortages
Capacity building activities and improving the delivery of services
Alternative programming for children who have been expelled from school

28. Other State-level Activities
Technical assistance
Personnel preparation and professional development and training
Positive behavioral interventions and supports
Technology in the classroom

29. Other State-level Activities
OSEP Letter to DeTemple
For example, if school building leadership team activities are being supported and 10% of the children in the school building are children with disabilities, then 10% of the cost of the building leadership activities could be funded using funds available under 34 CFR § (b)(1).
“…allocating some of the funds available under 34 CFR
§ (b)(1) in a proportional manner would be permissible, along with other Federal and State funds, to the costs of technical assistance and capacity building activities.”

30. Other State-level Activities
OSEP Letter to Batson
“… [the] State’s use of Part B IDEA State set-aside funds to fully fund its PBS initiative, which provides professional development, training and technical assistance on positive behavioral interventions to general educators, administrators and support staff, as well as to staff who provide special education and related services to children with disabilities, is permissible.”

31. Discussion #2
What funds will your State use to implement its SSIP? (IDEA Part B, Part C, SPDG, etc., other Federal funds, State funds, etc.)
How has your State involved its funding partners in planning initiatives and activities?
How will the funds be allocated?
Who will track the funding?

32. IDEA 611 and IDEA 619 State-level Activities
OSEP plans to examine how States are using their IDEA Part B State-level activities funds in future monitoring.

33. Michigan’s Historical Practice known as: ‘Mandated Activities Projects (MAPs)’
Individual project work functioned autonomously
Not designed to complement each other
Projects were funded in 5-year cycles with ongoing renewal regardless of shift in MDE priorities
Lacked continuity with MDE and OSE priorities
Activities were not a mandate…misleading title
Major focus for many: COMPLIANCE

34. Current Status Renamed: OSE IDEA Grant Funded Initiatives
Project work is aligned with MDE/OSE identified priorities and resources are being leveraged differently
“Project Find” no longer funded as a project
“MI-TOP” and ‘RTSL’
(Secondary Transition)
Contract for marketing and communication regarding Child Find activities for pre-school ages 3-5
In process of being redefined in light of the 2020 Federal Interagency Strategic Plan
Established Build Up Michigan!

35. Moving Forward OSE IDEA Grant Funded Initiatives must:
Be collaborative and responsive
Combine evidence based practices in a tiered structure designed to strengthen and support district effort to improve student outcomes
Have a sustainable implementation model which includes scalability, and an evaluation plan tied to improved student outcomes

36. Combined Federal funding:
MiBLSi… Michigan’s Integrated Behavior and Learning Supports Initiative
Combined Federal funding:
State Personnel Development Grant (SPDG)
MDE federal funds as an OSE IDEA Grant Funded Initiative
School Climate Transformation Grant
In collaboration with the MDE Coordinated School Health & Safety Programs Unit and the Office of Educational Innovation & Improvement
Critical to the successful implementation of the State Systemic Improvement Plan (SSIP B-17)

37. Reframing Compliance Child Find Early Childhood Transition
Disproportionate Representation
Secondary Transition

38. Improving Student Results
Preschool Outcomes
Parent Involvement
Educational Environments

39. Improving Student Results (Cont’d)
Statewide Assessments
Dropout
Graduation
Post-secondary Outcomes

40. State Systemic Improvement Plan

41. Conceptual Framework for Improving Results for Children

42. Audit Considerations Identify compliance “deal-breakers” upfront
Know the applicable Compliance Supplement requirements
Share resource and guidance documents with auditors
Engage in cooperative audit resolution

43. Resources: Schoolwide Programs
U.S. Department of Education Guidance ESEA, Section 1114 Schoolwide Programs U.S. Department of Education Notice Authorizing Schoolwide Programs to Consolidate Federal Education Funds and Exempting Them From Complying with Statutory or Regulatory Provisions of Those Programs (July 2, 2004)

44. Resources - CEIS
Navigating Coordinated Early Intervening Services – White Paper, April 2015 (use Internet Explorer)
Navigating Coordinated Early Intervening Services – Frequently Asked Questions, April 2015 (use Internet Explorer)
OSEP Memo 08-09
OSEP Letter to Couillard
Implementing RTI Using Title I, Title III, and CEIS Funds: Key Issues for Decision-Makers
Enter “CEIS plans” in your browser to find examples of written LEA plans for using IDEA Part B funds for CEIS and SEA guidance documents

45. Resources: USDE Guidance
OSEP Letter to Batson OSEP Letter to DeTemple OSEP Letter to Dale Examples of Leveraging ESEA and IDEA Funds to Support Digital Learning (November 19, 2014) Maximizing Flexibility in the Use of Federal Grants (September 13, 2013)

46. Resources: Blended and Braided Funds
Blended and Braided Funds: A Guide for Policy Makers and Practitioners Making Better Decisions: Leveraging Resources in Challenging Financial Times

47. Resources: Audit Considerations
Cooperative Audit Resolution
OMB Circular A-133 Compliance Supplement 2015

48. Resources – Leveraging Funds
Leveraging Federal Funds Focus Group Proceedings, September 2014 and OSEP/OESE Letter Accompanying Report