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Understanding Supplement not Supplant
November 15, 2018 Eve Carney, Executive Director Consolidated Planning and Monitoring
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Objectives of the Session
Provide overview of the supplement not supplant (SNS) provision Explain how Every Student Succeeds Act (ESSA) changed the application of SNS Discuss the new requirement for Title I Define and discuss the funding methodology Review sample methodologies Review frequently asked questions Preview resource allocation review process
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What is Supplement not Supplant?
Supplement, not supplant (SNS) is a provision across many federal grant programs. The general rule is the same, but the test differs across the federal grant programs. Some programs apply SNS to state/local Other programs apply SNS to state/local and other federal Generally, federal grant funds must add to (or supplement) and not replace (or supplant) other funds in providing general educational services.
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The Why: Supplement not Supplant?
Equity Schools receiving Title I funds educate more than two-thirds of low-income children and children of color. On average, these title I schools are shortchanged by about $440,000 per year Federal funds are being used to make up for that shortfall, instead of providing the additional resources needed in high poverty schools Source: FACT SHEET: Supplement-not-Supplant under Title I of the Every Student Succeeds Act, August 31, 2016
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ESSA Title I Implications on SNS
“(1) IN GENERAL.—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 State and local sources for the education of students participating in programs assisted under this part, and not to supplant such funds. (2) COMPLIANCE.—To demonstrate compliance with paragraph (1), a local educational agency shall demonstrate that the methodology used to allocate State and local funds to each school receiving assistance under this part ensures that such school receives all of the State and local funds it would otherwise receive if it were not receiving assistance under this part.” (ESSA 1118b) But, ESSA changed the demonstration for Title I school-level expenditures
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To which ESSA Titles does it apply?
The supplement not supplant provision applies to every program in the Every Student Succeeds Act as well as other federal grant programs: Individuals with Disabilities Education Act Carl D. Perkins School Improvement Other competitive grant opportunities But, ESSA changed the demonstration for Title I school-level expenditures These federal funds are given to states to supplement the state requirement to provide a basic education
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ESSA Title I Implications on SNS
ESSA has worked to increase transparency across federal programs ESSA intended to simplify the SNS test and to move away from the expenditure-by-expenditure analysis at the school level. ESSA changed how a local educational agency (LEA) must demonstrate compliance with the rule.
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Title I and SNS Once this test is met, and evidence is provided that each Title I school received its “fair share” based on the LEA’s funding methodology; items supported by Title I in a targeted or school-wide program are deemed to be supplemental. Thus, complying with supplement not supplant for Title I schools becomes a funding test, not an expenditure-by-expenditure test.
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Title I Neutral Funding
The funding methodology referenced in the legislation is the manner in which a LEA distributes state and local funds to all schools. Schools must be funded in a “Title I” neutral manner, meaning the LEA does not make state and local funding decisions based on the Title I funds schools will receive.
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What is Required for Title I?
Written Methodology Must specify how state and local dollars are distributed to schools Can be based on student enrollment, student/teacher ratios, student characteristics, or a combination of these factors Beginning in , must be submitted to the state education agency (SEA) annually as part of the Consolidated Funding Application
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Title I – Unchanged LEAs must continue to meet other Title I requirements school eligibility student eligibility maintenance of effort comparability intent and purpose of Title I Materials and services funded by Title I must be reasonable, allocable, necessary, and appropriately documented.
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Exclusions from the Title I SNS Methodology
Excluded from SNS Methodology Test: Single-school LEAs LEAs with only one school per grade span A LEA that meets one of the exemptions does not need to provide a written methodology but should upload a signed letter on district letterhead explaining why no methodology is required. LEAs must provide a methodology for all schools if there are multiple elementary schools and only one middle school and one high school.
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Specific Cost Test Specific cost test continues to apply for district level expenditures, state-mandated requirements, and for same services to Title I students/schools and Non-title I students/schools. In the specific cost test districts must examine each of the following to determine if it meets the supplement not supplant test: state-mandated activities or requirements positions, initiatives, or other expenditures funded with state and local dollars in non-Title schools positions, initiatives, or other expenditures funded with non-Title dollars in the preceding year
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Quick Check for Understanding
Which titles were impacted by ESSA’s supplement not supplant requirements? What is the primary difference between the “old test” and “new requirement?” How are school-level and district-level expenditures treated differently?
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Title I-like Activities
LEAs may exclude supplemental state and local funds used for any program that meets the intent and purpose of Title I-A. In other words, although an LEA may not reduce its allocation of general, state and local funds to a Title I-A school because the school receives Title I-A money, ESSA requirements allow for a degree of flexibility when it comes to supplemental state and local funds.
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Title I-Like Activities
The questions below can be used to determine if the program is Title I-Like. If the answer is yes to all of the first round questions the program is Title I-Like. If the answer is no to any of the first round questions, move onto the second round questions. First Round Questions Is the program implemented in a school with at least 40% poverty? Is the program designed to promote schoolwide reform and upgrade the entire educational operation of the school? Is the program designed to meet the educational needs of all students in the school, particularly those who are not meeting state standards? Will the program use the state’s assessment system to review the effectiveness?
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Title I-Like Activities
If the answer is yes to all second round question then the program is supplemental. Second Round Questions Does the program serve only students who are failing, or most at risk of failing to meet state standards? Does the program provide supplementary services to participating students designed to improve their achievement? Will the program use the state’s assessment system to review the effectiveness?
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SNS Funding Methodology
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Funding Methodology – Acceptable or Not Acceptable?
Review the funding methodology provided on the slide Consider the components used in the methodology Determine if the methodology is acceptable Remember: Title I neutral funding methodology!
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Methodology 1 The LEA uses a formula to determine how much money each school needs to operate. The form makes clear that each school should receive enough funds to support the following: 1 principal 1 assistant principal per 300 students 1 school counselor per 100 students 1 advisor per 75 students, etc. At the end of the calculations, the LEA determines the total amount of money each school needs. It then looks to see how much Title money each school has and makes up the difference using the local funds.
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Methodology 1 – Unacceptable!
Why? “It then looks to see how much Title money each school has and makes up the difference using the local funds.” Remember – the funding must be Title I neutral
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Methodology 2 The LEA distributes its state funds based on the characteristics of students in each school so that students with characteristics associated with educational disadvantage generate additional funding for their school. The LEA provides: $25 for every student; An additional $25 for each economically disadvantaged student; An additional $50 for each student with a disability; and An additional $35 for each English learner.
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Methodology 2 - Acceptable!
Why? While student characteristics can be used for additional funding (i.e., student-based budgeting), this methodology was applied without mention of Title I status. Further, economically disadvantaged students attending a low-poverty school would benefit the same.
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Resource: SNS Methodology Samples
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SNS Resource – Methodology Samples
Sample 1: Enrollment and grade level Enrollment and per pupil calculation - positions Additional supports (technology, professional development, etc.) Sample 2: Student enrollment Positions assigned Average salary for position used Additional costs may be per pupil or per building Sample 3: Student enrollment with supplements for student designations Base amount of state and local funds established Supplements above the base
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Sample Narrative Volunteer County Schools funds schools in a "Title 1 neutral manner" by utilizing a methodology to allocate state and local funds to each school within the district without regard to the Title I - Part A status of each school. Volunteer County Schools base the allocation of state and local funds equitably on type of personnel, resources, programming and supplies to all schools within the LEA based on average daily membership (ADM) as outlined in the Education Improvement Act. The adopted methodology ensures that Title I-Part A funds supplement and do not supplant state and local funds. In addition, this methodology ensures that Title I-part A funds are not used to provide services that would, in the absence of federal funds, be supported with state or local resources. Example pulled from Warren County. The narrative is as important as the explanation of the calculations.
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General Points to Remember
Date enrollment data are collected should be included May be helpful to align with BEP data Date used should be the same across all schools Could differentiate by grade bands due to class size ratio requirements Submission should be on letterhead and include the signed assurance noted in the samples Actual funding calculations are not required in the methodology
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State-mandated Class Size
of TCA requires that class averages for grade level units not exceed a certain number and that no individual class within the grade level unit exceed a certain maximum class size. Grade Level Unit Average Class Size Maximum Class Size K-3 20 25 4-6 30 7-12 35 CTE
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Frequently Asked Questions
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Is there a list of what must be included in the methodology?
Methodologies must include: Name of schools Student enrollment Grade levels served Student demographic data Factors being used to determine the funding allocations, including if there are differences by grade bands Assurance (see methodology examples) Signature of director of schools or designee School year Date signed The methodology must detail how state and local funds are being allocated in a “Title I neutral” manner for items included in providing academic supports for students. The methodology does not need to include operational costs.
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What is the difference between the Title I SNS methodology and the Basic Education Program (BEP) formula? Is it by per pupil or enrollment? The BEP is a funding formula provided to the district, and each district has the flexibility in determining the most appropriate use of state funds. There is flexibility within the formula on how BEP funds are used. The BEP may be utilized as a starting point for the methodology, but the methodology is the actual system by which funds are awarded to each school. The BEP formula is generated based on the district as a whole, whereas the SNS methodology is at the school level.
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If the district is only serving (with Title I funds) one grade span (e
If the district is only serving (with Title I funds) one grade span (e.g., K-4), does the written methodology have to address middle and high school? Yes; unless your district has only one school OR only one school per grade span, districts must submit a written methodology for all schools in the district, even if only one school is being served with Title I funds. Additionally, districts must provide a methodology for all schools if there are multiple elementary schools and only one middle school and one high school.
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Should Education Assistants be included in the methodology?
Yes, education assistants should be included in the methodology with educators, administration, instructional assistants, counselors, and nurses.
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If our system is exempt, do we upload a statement that explains why we are exempt?
Yes, a district that meets one of the exemptions does not need to provide a written methodology but should upload a signed letter on district letterhead explaining why no methodology is required.
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Are there any exclusions of state and local funds from the methodology?
Districts may exclude supplemental state and local funds (state/local funds above the funding methodology) used for any program that meets the intent and purpose of Title I-A (Title I-like funds). In other words, although an LEA may not reduce its allocation of state and local funds to a Title I-A school because the school receives Title I-A money, ESSA requirements allow for a degree of flexibility when it comes to supplemental state and local funds.
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Available Resources Resources are available on the ESSA Title I department webpage, under Part A, Basic Supplement not Supplant Guidance (NEW RESOURCE) Contains information on supplement not supplant for all the federal programs and sample scenarios on when items are supplemental versus not supplemental.
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Available Resources Resources are available on the ESSA Title I department webpage, under Part A, Basic Supplement not Supplant Checklist Supplement not Supplant Methodology Supplement not Supplant Sample Methodologies Supplement not Supplant FAQ
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Available Resources Resources are available on the ESSA Title I department webpage, under Part A, Basic Supplement not Supplant Guidance (NEW RESOURCE) Contains information on supplement not supplant for all the federal programs
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CPM Regional Consultant District Map
LAKE OBION WEAKLEY DYER GIBSON LAUDERDALE HAYWOOD FAYETTE CROCKETT BENTON SHELBY TIPTON HENRY CARROLL HUMPHREYS HENDERSON MADISON HARDEMAN McNAIRY HARDIN HOUSTON STEWART ROBERTSON MONTGOMERY DICKSON CHEATHAM PERRY HICKMAN WILLIAMSON DAVIDSON MAURY LEWIS WAYNE LAWRENCE MARSHALL GILES SUMNER MACON TROUSDALE WILSON RUTHERFORD BEDFORD LINCOLN SMITH DEKALB WHITE PUTNAM JACKSON CLAY CANNON COFFEE FRANKLIN MOORE PICKETT OVERTON FENTRESS CUMBERLAND BLEDSOE WARREN VAN BUREN GRUNDY SEQUATCHIE MARION SCOTT MORGAN CAMPBELL ROANE LOUDON RHEA HAMILTON BRADLEY McMINN POLK MEIGS MONROE BLOUNT SEVIER KNOX ANDERSON CLAIBORNE GRAINGER JEFFERSON HANCOCK HAWKINS SULLIVAN JOHNSON CARTER UNICOI HAMBLEN GREENE COCKE WASHINGTON UNION CHESTER DECATUR Southwest Northwest Mid-Cumberland South Central Upper Cumberland Southeast East First TN Trudy Hughes Michelle Mansfield Lynn Dotson Salena Burress John Stults VACANT Heather Farley Henry LaFollette 120 Chester 200 Decatur 240 Fayette 350 Hardeman 360 Hardin 380 Haywood 390 Henderson 391 Lexington 490 Lauderdale 550 McNairy 570 Madison 792 Shelby 793 Arlington 794 Bartlett 795 Collierville 796 Germantown 797 Lakeland 798 Millington 840 Tipton 960 West TN School for Deaf 985 ASD 030 Benton 090 Carroll 092 Hollow Rock-Bruceton 093 Huntingdon 094 McKenzie 095 South Carroll 097 West Carroll Crockett 171 Alamo 172 Bells 230 Dyer 231 Dyersburg City Gibson 274 Bradford SSD 271 Humboldt City 272 Milan SSD 273 Trenton Henry 401 Paris SSD 480 Lake Obion 661 Union City 920 Weakley 110 Cheatham 190 Davidson 220 Dickson 420 Houston 430 Humphreys 630 Montgomery 740 Robertson 750 Rutherford 751 Murfreesboro 830 Sumner 810 Stewart 940 Williamson 941 Franklin SSD 950 Wilson 951 Lebanon SSD 020 Bedford 160 Coffee 161 Manchester 162 Tullahoma 260 Franklin 280 Giles 410 Hickman 500 Lawrence 510 Lewis 520 Lincoln 521 Fayetteville 590 Marshall 600 Maury 640 Moore 680 Perry Wayne 970 Dept of Children’s Serv. 971 Dept of Corrections 963 TN School for the Blind 040 Bledsoe 080 Cannon 140 Clay 180 Cumberland 210 DeKalb 250 Fentress 440 Jackson 560 Macon 670 Overton 690 Pickett 710 Putnam 800 Smith 850 Trousdale 880 Van Buren 930 White 890 Warren 961 York Institute Bradley 061 Cleveland Grundy Hamilton Marion 581 Richard City McMinn 541 Athens City 542 Etowah City 610 Meigs 700 Polk Rhea 721 Dayton City 770 Sequatchie 010 Anderson 011 Clinton 012 Oak Ridge 050 Blount 051 Alcoa City 052 Maryville 070 Campbell 130 Claiborne 290 Grainger 450 Jefferson 470 Knox Loudon 531 Lenoir City 620 Monroe 621 Sweetwater 650 Morgan 730 Roane Co Scott 761 Oneida 780 Sevier 870 Union Co 964 East TN School for the Deaf 100 Carter 101 Elizabethton 150 Cocke 151 Newport City 300 Greene 301 Greeneville 320 Hamblen 340 Hancock 370 Hawkins 371 Rogersville 460 Johnson County 820 Sullivan 821 Bristol 822 Kingsport 860 Unicoi Co 900 Washington 901 Johnson City
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Fiscal Regional Consultant District Map
LAKE OBION WEAKLEY DYER GIBSON LAUDERDALE HAYWOOD FAYETTE CROCKETT BENTON SHELBY TIPTON HENRY CARROLL HUMPHREYS HENDERSON MADISON HARDEMAN McNAIRY HARDIN HOUSTON STEWART ROBERTSON MONTGOMERY DICKSON CHEATHAM PERRY HICKMAN WILLIAMSON DAVIDSON MAURY LEWIS WAYNE LAWRENCE MARSHALL GILES SUMNER MACON TROUSDALE WILSON RUTHERFORD BEDFORD LINCOLN SMITH DEKALB WHITE PUTNAM JACKSON CLAY CANNON COFFEE FRANKLIN MOORE PICKETT OVERTON FENTRESS CUMBERLAND BLEDSOE WARREN VAN BUREN GRUNDY SEQUATCHIE MARION SCOTT MORGAN CAMPBELL ROANE LOUDON RHEA HAMILTON BRADLEY McMINN POLK MEIGS MONROE BLOUNT SEVIER KNOX ANDERSON CLAIBORNE GRAINGER JEFFERSON HANCOCK HAWKINS SULLIVAN JOHNSON CARTER UNICOI HAMBLEN GREENE COCKE WASHINGTON UNION CHESTER DECATUR 1 2 3 4 5 6 Cindy Smith Brad Davis Rob Mynhier Brian Runion Dustin Winstead Jackie Broyles 120 Chester 200 Decatur 240 Fayette 350 Hardeman 360 Hardin 380 Haywood 390 Henderson 391 Lexington 490 Lauderdale 550 McNairy 570 Madison 680 Perry 792 Shelby 793 Arlington 794 Bartlett 795 Collierville 796 Germantown 797 Lakeland 798 Millington 840 Tipton 960 West TN School for Deaf 030 Benton 090 Carroll 092 Hollow Rock-Bruceton 093 Huntingdon 094 McKenzie 095 South Carroll 097 West Carroll Crockett 171 Alamo 172 Bells 230 Dyer 231 Dyersburg City Gibson 274 Bradford SSD 271 Humboldt City 272 Milan SSD 273 Trenton Henry 401 Paris SSD 420 Houston 430 Humphreys 480 Lake Obion 661 Union City 810 Stewart 920 Weakley 985 ASD 110 Cheatham 140 Clay 180 Cumberland 190 Davidson 210 DeKalb 220 Dickson 250 Fentress 440 Jackson 560 Macon 630 Montgomery 670 Overton 690 Pickett 710 Putnam 740 Robertson 800 Smith 830 Sumner 850 Trousdale 930 White 950 Wilson 951 Lebanon SSD 970 Dept of Children’s Serv. 971 Dept of Corrections 963 TN School for the Blind 890 Warren 961 York Institute 020 Bedford 040 Bledsoe 080 Cannon 160 Coffee 161 Manchester 162 Tullahoma 260 Franklin 280 Giles 310 Grundy 410 Hickman 500 Lawrence 510 Lewis 520 Lincoln 521 Fayetteville 580 Marion 581 Richard City 590 Marshall 600 Maury 640 Moore 750 Rutherford 751 Murfreesboro 770 Sequatchie 880 Van Buren Wayne 940 Williamson 941 Franklin SSD 010 Anderson 011 Clinton 012 Oak Ridge 050 Blount 051 Alcoa City 052 Maryville 060 Bradley 061 Cleveland 070 Campbell 330 Hamilton 530 Loudon 531 Lenoir City McMinn 541 Athens City 542 Etowah City 610 Meigs 620 Monroe 621 Sweetwater 650 Morgan 700 Polk Rhea 721 Dayton City 730 Roane Co Scott 761 Oneida 100 Carter 101 Elizabethton 130 Claiborne 150 Cocke 151 Newport City 290 Grainger 300 Greene 301 Greeneville 320 Hamblen 340 Hancock 370 Hawkins 371 Rogersville 450 Jefferson 460 Johnson County 470 Knox 780 Sevier 820 Sullivan 821 Bristol 822 Kingsport 860 Unicoi Co 870 Union Co 900 Washington 901 Johnson City 964 East TN School for the Deaf
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SNS Next Steps SNS methodologies will be required each spring in the Consolidate Funding Application In fiscal regional consultants will be providing support and reviewing methodologies to provide feedback with select districts In LEAs selected for on-site fiscal monitoring will be required to discuss the methodology and provide appropriate supporting evidence of compliance
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Resource Allocation Review Process
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Resource Allocation Review Process
In addition to the SNS requirement, ESSA also outlined a requirement on conducting a resource allocation review process for districts (§ 1111(d)(3)(A)(ii) and § (a)) The goal of the resource allocation review (RAR) is to ensure that sufficient support and resources are being provided for schools identified for comprehensive or targeted support and improvement This is a prev
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Resource Allocation Review Process
The regional finance consultants will annually be conducting the RAR process with districts identified as intensive additional targeted support and improvement (ATSI) districts. RAR expectations for districts: Upload required documentation to the LEA document library (such as staff list) Participate in an interview with finance regional consultants (CFO, federal programs director, federal programs bookkeeper, and academic officer) Facilitate an interview for the finance regional consultants with 2-3 principals (if deemed necessary) Year 1: Districts will be provided recommendations This year there are 14 identified districts.
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Resource Allocation Review Process
Davidson County Shelby County Hamilton County Knox County Putnam County Madison County Bedford County Montgomery County Campbell County Haywood County Johnson County Robertson County Smith County Union County
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Questions? Dr. Eve Carney, Executive Director CPM
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Notifications can also be submitted electronically at:
FRAUD, WASTE, or ABUSE Citizens and agencies are encouraged to report fraud, waste, or abuse in State and Local government. NOTICE: This agency is a recipient of taxpayer funding. If you observe an agency director or employee engaging in any activity which you consider to be illegal, improper or wasteful, please call the state Comptroller’s toll-free Hotline: Notifications can also be submitted electronically at:
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