1. ESEA FINANCIAL ISSUES September 16, 2014 WVDE Office of Federal Programs Laura Pauley, CPA lepauley@k12.wv.us

2. Helpful Links – OMB Circular: December 26, 2013 Federal Register Final Guidance http://www.gpo.gov/fdsys/pkg/FR-2013-12- 26/pdf/2013-30465.pdf http://www.gpo.gov/fdsys/pkg/FR-2013-12- 26/pdf/2013-30465.pdf – Education Department General Administrative Regulations (EDGAR) http://www2.ed.gov/policy/fund/reg/edgarReg/edgar. html http://www2.ed.gov/policy/fund/reg/edgarReg/edgar. html 2

3. ESEA Program Updates 3

4. Updates – New EDGAR finalized December 26, 2014 To be in line with new Omni Circular Draft was due out June 26, 2014 – FY 2015 grants issued prior to December 26, 2014 will still be governed by old regulations – New monitoring process being implemented Omni Circular requires additional monitoring and oversight of LEAs by SEAs Must do some monitoring of every LEA every year in additional to 5 year schedule 4

5. Updates Risk assessments must now be done on all LEAs prior to providing federal funding Certified 5-17 report 5-17 report coming out with certified reports (look for this with enrollment reports in the coming months) 5

6. Carryover Title II and Title VI Carryover – Increased from 15% limit to 40% (for 9/30/14 only to help offset Title I carryover confusion) – Need to start analyzing and moving expenses if necessary before Sept 30 th Title I limited to 15% (unless allocation < $50,000) 6

7. Carryover How to calculate carryover – Carryover is verified by WVDE running Project Financial Reports once counties have closed their books for September. – Payroll related encumbrances are not included in the calculation of carryover. – If a county has transferred Title II/VI funds into Title I these funds count towards carryover amounts 7

8. Carryover How to reduce your carryover – Transfer Title I eligible expenditures from other funds without carryover limits or with higher carryover limits into Title I – Must clean-up carryover over prior to closing September so that we can verify carryover amounts – Obligate funds by Sept 30 th – Practice “First In First Out” 8

9. Obligation If the obligation is for -The obligation is made- (a) Acquisition of real or personal property On the date the district makes the binding written commitment to acquire the property (b) Personal services by an employee or the district When the services are performed (c) Personal services by a contractor who is not an employee of the district The date the district makes a binding written commitment to obtain the services. (d) Performance of work other than personal services On the date the district makes a binding written commitment to obtain the work. (e) Public Utility ServicesWhen the district receives the services (f) TravelWhen the travel is taken (g) Rental of real or personal propertyThen the district uses the property 9

10. Liquidation Liquidation typically occurs 30 days after end of the obligation period. – Make sure funds are requested from WVDE prior to the ending liquidation date – WVDE cannot distribute funds after the ending liquidation date listed on the grant document Liquidation dates can vary by grant – Always double check your grant document 10