1. Title Grants Division Illinois State Board of Education 1 NCLB TITLE GRANT MANAGEMENT ISBE Illinois Association of Title I Directors Annual Fall Conference 2014

2. Title Grants Division Illinois State Board of Education 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) 2

3. Title Grants Division Illinois State Board of Education 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 ) 3

4. Title Grants Division Illinois State Board of Education 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) 4

5. Title Grants Division Illinois State Board of Education 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 5

6. Title Grants Division Illinois State Board of Education 6 Are meals disallowed from Title I? Even for parent meetings? May Title I professional development funds be used for meals at workshops and conferences? Food for Meetings and Conferences

7. Title Grants Division Illinois State Board of Education 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. 7

8. Title Grants Division Illinois State Board of Education 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. 8

9. Title Grants Division Illinois State Board of Education 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) 9

10. Title Grants Division Illinois State Board of Education 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. 10

11. Title Grants Division Illinois State Board of Education 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 3 rd grade General Education Teacher Targeted Assistance Building – Computer adaptive tests for Special Education Students 11

12. Title Grants Division Illinois State Board of Education 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? 12

13. Title Grants Division Illinois State Board of Education 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. 13

14. Title Grants Division Illinois State Board of Education 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? 14

15. Title Grants Division Illinois State Board of Education 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: http://www.isbe.net/grants/html/title1_schoolwide- programs.htm http://www.isbe.net/grants/html/title1_schoolwide- programs.htm 15

16. Title Grants Division Illinois State Board of Education Schoolwide Flexibility Schoolwide flexibility expenditures are governed by three principles: (1)is the expenditure reasonable and necessary, (2)does it meet the intent and purpose of the law and is aligned with the schoolwide plan, and (3)does the school receive at least as much state and local resources as non-Title I schools. 16

17. Title Grants Division Illinois State Board of Education 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? 17

18. Title Grants Division Illinois State Board of Education 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. 18

19. Title Grants Division Illinois State Board of Education 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. 19

20. Title Grants Division Illinois State Board of Education 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. 20

21. Title Grants Division Illinois State Board of Education 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. 21 COMMON BUDGET PROBLEMS

22. Title Grants Division Illinois State Board of Education 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. 22 COMMON BUDGET PROBLEMS

23. Title Grants Division Illinois State Board of Education TALK TIME! 23 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?

24. Title Grants Division Illinois State Board of Education 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. 24

25. Title Grants Division Illinois State Board of Education Questions/Comments 25

26. Title Grants Division Illinois State Board of Education Thank You Agurann Bates, Principal Consultant abates@isbe.net Santita Nunn, Principal Consultant snunn@isbe.net 26