1. IDEA Fiscal Program, Technical Assistance, And Contingency Funding October 20, 2014 – IU 12 October 27, 2014 – IU 27 October 28, 2014 – PaTTAN KoP November 3, 2014 - PaTTAN Pgh November 14, 2014 - PaTTAN Hbg December 3, 2014 – IU 20 www.education.state.pa.us >

2. IDEA-B §611 State Performance Plan and Data Reporting Indicator 20: Local Education Agency Reported Fiscal Data Meet Requirements Needs Assistance – first year of non-compliance Needs Intervention – second consecutive year of non-compliance Needs Substantial Intervention – third consecutive year of non-compliance or at the determination of BSE Pennsylvania Department of Education Bureau of Special Education 2

3. Who will receive the determinations? All School Districts and Charter Schools receiving IDEA-B Section 611 Funding See example of determination letter in packet Pennsylvania Department of Education Bureau of Special Education 3

4. How can you “meet requirements” for timely fiscal determinations Have your signed Adoption Policies back to IU timely. If you receive a CEIS report, return correct information timely. If you receive a Maintenance of Effort letter with an exception worksheet, respond with correct information to the cut-off date on the letter. Respond to Table 8 Report on IDEA Part B Maintenance of Effort Reduction and Coordinated Early Intervening Services, timely Failure to meet the timelines in one or more of the above could result in a “needs assistance” determination letter from the department. An LEA must receive a “meets requirements” in order to take advantage of the reduction in fiscal effort in accordance with 34 CFR §300.205. 4 Pennsylvania Department of Education Bureau of Special Education

5. What can happen if you fail to “Meet Requirements”? Prepare a plan to “meet requirements” Additional in depth reporting by the LEA Additional on-site visits by the Bureau of Special Education BSE enforcement actions are initiated when persistent non-compliance is not resolved An on-site visit by OSEP 5 Pennsylvania Department of Education Bureau of Special Education

6. What are Coordinated Early Intervening Services (CEIS)? CEIS are services provided to students in kindergarten through grade 12 (with a particular emphasis on students in kindergarten through grade three) who are not currently identified as needing special education or related services, but who need additional academic and behavioral supports to succeed in a general education environment. 6 Pennsylvania Department of Education Bureau of Special Education

7. What amount of CEIS is allowed? LEAs may use up to 15 percent of IDEA Part B funds to develop and provide CEIS for students who are currently not identified as needing special education. 7 Pennsylvania Department of Education Bureau of Special Education

8. When is CEIS required? If a State identifies significant disproportionality based on race or ethnicity in a LEA with respect to: – The identification of children as children with disabilities – The identification of children in specific disability categories – The placement of children with disabilities in particular educational settings, or – The taking of disciplinary actions… Pennsylvania Department of Education Bureau of Special Education 8

9. If CEIS is Required? …LEA must use the maximum amount (15 percent) of the funds allowable for comprehensive CEIS for children in the LEA, particularly, but not exclusively, for children in those groups that were significantly over identified BSE will notify you if you fall into this category If identified under 300.646, expect additional monitoring and reporting, including public reporting Pennsylvania Department of Education Bureau of Special Education 9

10. What are allowable CEIS activities? Professional development for teachers and other school staff to enable such personnel to deliver scientifically based academic and behavioral interventions Educational and behavioral evaluations, services, and supports Pennsylvania Department of Education Bureau of Special Education 10

11. Professional Development CEIS funds may be used to provide professional development to all personnel who are responsible for students who need additional academic and behavioral supports to succeed in a general education environment, but who have not been identified as needing special education Pennsylvania Department of Education Bureau of Special Education 11

12. Professional Development Personnel who are solely responsible for students receiving special education services or students who do not need additional support may participate in professional development funded with CEIS funds so long as – The cost of the professional development does not increase – The quality of the professional development does not decrease, and – Including those personnel would not exclude other personnel who are responsible for students who need additional support but have not been identified as needing special education Pennsylvania Department of Education Bureau of Special Education 12

13. Evaluations LEAs may use CEIS funds to provide behavioral and educational evaluations to determine the supports that are needed by students to succeed in a general education environment Funds may not be used for evaluations that are intended for use in determining eligibility for special education and related services Pennsylvania Department of Education Bureau of Special Education 13

14. CEIS and RTII CEIS funds may be used to support RTII, Tier 2 and Tier 3, as long as the CEIS funds are used for services to nondisabled students in need of additional academic or behavioral support and supplement, not supplant, other funds used to implement RTII See a sample of the CEIS report in your packet Pennsylvania Department of Education Bureau of Special Education 14

15. What must be reported for CEIS? Each LEA that implements CEIS must report to the State on: – the amount of IDEA funds used – the number of children who received CEIS – the number of those students who subsequently received special education and related services under Part B during the preceding two-year period (ie., the two years after the child has received CEIS). – Description of activities that CEIS funds supported 15 Pennsylvania Department of Education Bureau of Special Education

16. What must be reported to Office of Special Education Programs (OSEP) States and LEAs must maintain these records for audit and monitoring purposes, but are not required to report the data until the Department or OSEP requests you to do so OSEP will review data collection methods and data during verification visits Pennsylvania Department of Education Bureau of Special Education 16

17. What do we mean by Maintenance of Effort (MoE)? The amount of local, or State and local, funds expended for the education of children with disabilities. This amount of funds establishes the level of expenditures to be maintained from year to year and establishes the MoE level. 17 Pennsylvania Department of Education Bureau of Special Education

18. What is the LEA MoE Requirement? With certain exceptions, funds provided to an LEA under Part B must not be used to reduce the level of expenditures for the education of children with disabilities below the level of the expenditures for the preceding fiscal year See 34 CFR §300.203(a) 18 Pennsylvania Department of Education Bureau of Special Education

19. What do we mean when we talk about LEA MoE Eligibility? In order to determine an LEA’s eligibility for a Part B allocation, the SEA must ensure that: – With certain exceptions, an LEA budgets for the education of children with disabilities at least the same total or per capita amount of either local, or State and local, funds as it spent from those same sources in the most recent prior year for which the information is available – See 34 CFR §300.203(b)(1) 19 Pennsylvania Department of Education Bureau of Special Education

20. Let’s show an example of MoE eligibility and compliance Eligibility: – LEA expends $900,000 in SY 2012-13 and budgets $1,000,000 in SY 2013-14; therefore, the LEA meets the IDEA MoE eligibility requirement for a SY 2013-14 grant award Compliance: – LEA expends $900,000 in the SY 2012-13 and expends $950,000 in the SY 2013-14; therefore, the LEA complied with the MoE requirement from SY 2012-13 to SY 2013-14 20 Pennsylvania Department of Education Bureau of Special Education

21. What does the SEA consider when running your MoE test? Most current budget 1200 expenditures Most current Annual Financial Report (AFR) 1200 expenditures (Exclude Early Intervention and Federal Expenditures) LEA allocations from both years to determine if MoE adjustment (50% Rule) could apply Child count from both years to determine per capita test 21 Pennsylvania Department of Education Bureau of Special Education

22. What if I fail the Department’s initial review on the MoE worksheet? Check the figures on the spreadsheet and report any discrepancies There might be a legitimate reason for a decrease in expenditures. (Next page exceptions under 34 C.F.R. §300.204) Respond within the requested time line. Failure to respond will be deemed as a concurrence with the Department’s initial determination If the figures are correct and you have no exceptions, your school will be required to repay the Federal Government an amount equal to the fiscal effort that was not maintained Pennsylvania Department of Education Bureau of Special Education 22

23. What do we mean by MoE Exceptions? An LEA may reduce the level of its expenditures (local, or State and local; in total or per capita) below the level of those expenditures (local, or State and local; in total or per capita) for the preceding fiscal year under certain circumstances… See 34 CFR §300.204 23 Pennsylvania Department of Education Bureau of Special Education

24. Here are some examples of MoE Exceptions 34 CFR §300.204 provides exceptions for: – Voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related services personnel; – Decrease in the enrollment of children with disabilities; – Termination of costly expenditures for long-term purchases, such as the acquisition of equipment… 24 Pennsylvania Department of Education Bureau of Special Education

25. More MoE exceptions Termination of an exceptionally costly obligation to a particular child with a disability because the child: – Has left the jurisdiction; – Has reached the age at which the obligation to provide a free appropriate public education (FAPE) to the child is terminated; or – No longer need the program of special education 25 Pennsylvania Department of Education Bureau of Special Education

26. What do we mean by LEA MoE Adjustments With certain exceptions, for any fiscal year for which an LEA’s Part B allocation under section 611 exceeds the amount the LEA received for the previous fiscal year, the LEA may reduce the level of expenditures otherwise required for MoE by not more than 50% of the amount of the excess See 34 CFR §300.205(a) 26 Pennsylvania Department of Education Bureau of Special Education

27. Am I Eligible to use the MoE Adjustment? An LEA is eligible to make the 50% reduction if the LEA: – Receives an increase in section 611 funds – “Meets requirements” under the sec. 616 determinations – Has not had action taken against it by the SEA under IDEA section 616 – Has not had responsibility for providing FAPE taken from it by the SEA – Has not been found by the SEA to have significant disproportionality under 34 CFR §300.646 27 Pennsylvania Department of Education Bureau of Special Education

28. What happens when I take the MoE reduction? The LEA must use an amount of local funds equal to the MoE reduction to carry out activities that could be supported with ESEA funds This will reduce the following year’s MoE as well If the LEA also uses funds for CEIS they must subtract any CEIS set-aside from a potential LEA MoE reduction Pennsylvania Department of Education Bureau of Special Education 28

29. Can an LEA take the maximum Moe adjustment and the maximum CEIS? Example 1: Moe and CEIS 2013-14 Allocations:$1,000,000 2012-13 Allocations:$ 900,000 Increase:$ 100,000 Maximum Available for MoE Reduction$ 50,000 Maximum Available for CEIS$ 150,000 (a)If the LEA chooses to set aside $150,000 for CEIS, it may reduce MoE by? (b)If the LEA chooses to set aside $100,000 for CEIS, it may reduce MoE by? (c)If the LEA chooses to set aside $ 50,000 for CEIS, it may reduce MoE by? (d)If the LEA chooses to set aside $ 30,000 for CEIS, it may reduce MoE by? (e)If the LEA chooses to set aside $0 for CEIS, it may reduce MoE by? Pennsylvania Department of Education Bureau of Special Education 29

30. How did you do? Example 1 (a)$0 MoE MoE $50,000 minus CEIS 150,000 = $0 MoE (b) $0 MoE Moe $50,000 minus CEIS $100,000 = $0 MoE (c) $0 MoE MoE $50,000 minus CEIS $50,000 = $0 MoE (d) $20,000 MoE MoE $50,000 minus CEIS $30,000 = $20,000 MoE (e) $50,000 MoE MoE $50,000 minus CEIS $0 = $50,000 MoE Pennsylvania Department of Education Bureau of Special Education 30

31. Try another one Example 2: Moe and CEIS 2013-14 Allocations:$2,000,000 2012-13 Allocations:$1,000,000 Increase:$1,000,000 Maximum Available for MoE Reduction$ 500,000 Maximum Available for CEIS$ 300,000 (a)If the LEA chooses to use no funds for MoE, how much for CEIS? (b)If the LEA chooses to use $100,000 for MoE, how much for CEIS? (c)If the LEA chooses to use $150,000 for MoE, how much for CEIS? (d)If the LEA chooses to use $300,000 for MoE, how much for CEIS? (e)If the LEA chooses to use $500,000 for MoE, how much for CEIS? Pennsylvania Department of Education Bureau of Special Education 31

32. Answers to example 2 Example 2 (a) $300,000 CEIS CEIS max. $300,000 minus $0 MoE = $300,000 CEIS (b) $200,000 CEIS CEIS max. $300,000 minus $100,000 MoE= $200,000 CEIS (c) $150,000 CEIS CEIS max. $300,000 minus $150,000 = $150,000 CEIS (d) $0 CEIS CEIS max. $300,000 minus $300,000 = $0 CEIS (e) $0 CEIS CEIS max. $300,000 minus $500,000 = $0 CEIS Pennsylvania Department of Education Bureau of Special Education 32

33. LEA MoE Requirement: Supplement/Not Supplant Funds under Part B must be used to supplement State, local and other Federal funds and not to supplant them See 34 CFR §300.202(a)(3) If an LEA maintains its fiscal effort, it will only be using Part B funds to supplement local, or State and local, funds, and not to supplant them 33 Pennsylvania Department of Education Bureau of Special Education

34. What do we mean by Supplement/Not Supplant Prior to 1992, the Part B regulations also included a “particular cost test” for determining whether supplanting occurred. This requirement meant, for example, that if an LEA spent Part B funds to pay for a teacher’s salary that was previously paid for with state or local funds, a supplanting violation would occur, even though the total amount of state and local funds spent on special education is greater than the amount spent the previous year. At that time, an LEA could maintain effort but still violate the supplement/not supplant provision. The particular “cost test” was removed from the regulations by an amendment published in the Federal Register on August 19, 1992 and became effective on October 3, 1992. Therefore, no requirement currently exists related to supplanting “particular costs” and if an LEA maintains local, or state and local, effort, it will not violate the supplement/not supplant requirements of the IDEA. 34 Pennsylvania Department of Education Bureau of Special Education

35. What are the Implications of Failure to Maintain Effort? Audit implications – Noncompliance with MoE requirements – Pay back the amount by which the LEA failed to meet MoE – Paybacks must be made out of non-Federal funds or funds for which accountability to the Federal government is not required Grant implications – Ineligibility for sub grant funds 35 Pennsylvania Department of Education Bureau of Special Education

36. Table 8 Part B IDEA-MoE Reduction and CEIS Developed under Section 618, part B of the Individuals with Disabilities Educational Act (IDEA) Was supposed to be a one time collection in 2009-10 It was continued because of increase interest of auditors Pennsylvania Department of Education Bureau of Special Education 36

37. What is collected in Table 8 LEA Allocation 2012-13 and 2013-14 BSE will put in allocations for all LEAs Increase in allocation (spreadsheet calculation) 15% of 2013-14 allocation (spreadsheet calculation) Pennsylvania Department of Education Bureau of Special Education 37

38. Information Collected For each LEA, specify the determination under 34 CFR §300.600(a)(2) that controls whether the LEA may be able to reduce MOE during SY 2013-14 BSE fills this column Pennsylvania Department of Education Bureau of Special Education 38

39. Information Collected Reduction of local and/or State funds taken pursuant to Section 613(a)(2)(c) by the LEA during SY 2013-14 This column will only be used if the LEA had an increase in allocation from 2012-13 to 2013-14 and if they had a determination of “meets requirements” If they had a decrease or did not “meet requirements”, this column was locked Pennsylvania Department of Education Bureau of Special Education 39

40. Information Collected Percent of the available reduction taken by LEA during SY 2013-14 (spreadsheet calculation) If an LEA took more then 50% of the increase in allocation, OSEP would investigate Pennsylvania Department of Education Bureau of Special Education 40

41. Information Collected Was the LEA required to use 15% of funds for CEIS due to significant disproportionality in SY 2013-14 This column was filled by BSE Pennsylvania Department of Education Bureau of Special Education 41

42. Information Collected Amount reserved for required CEIS in the LEA in SY 2013-14 This column was filled by BSE No LEAs were required to provide CEIS in 2013-14 Pennsylvania Department of Education Bureau of Special Education 42

43. Information Collected Did the LEA voluntarily use up to 15% of IDEA 611 for CEIS in SY 2013-14 BSE will fill this column based on your 2013-14 eGrant Amount reserved for voluntary CEIS in 2013-14 Only LEAs that BSE identified in the first bullet will put an amount here Percentage taken for voluntary CEIS during 2013-14 (spreadsheet calculates) If percentage is over 15% of allocation, OSEP will investigate Pennsylvania Department of Education Bureau of Special Education 43

44. Information Collected Total number of children receiving CEIS under the IDEA in the LEA during SY 2013-14 Only those that were identified as voluntarily using CEIS will enter a number Total number of children who received CEIS under the IDEA anytime in the past two school years (including SY 2011-12, SY 2012-13, and SY 2013-14) and received special education and related services in SY 2013-14 BSE will fill in this column per CEIS reports Pennsylvania Department of Education Bureau of Special Education 44

45. Information Table 8 has been posted to a Public Website since 2009-10 and can result in: – Inquiries by auditors – Inquiries by OSEP – Findings to the LEA – Findings to the SEA PA has not experienced any findings or inquires on Table 8 Where is it publicly reported? – http://tadnet.public.tadnet.org/pages/712 http://tadnet.public.tadnet.org/pages/712 Pennsylvania Department of Education Bureau of Special Education 45

46. OMB Time and Effort Rules If federal funds used for salaries, then time distribution records are required – Not contractors Must demonstrate – That the employee worked on that IDEA program/cost objective 46 Pennsylvania Department of Education Bureau of Special Education

47. A-87: If employee works 100% on single cost objective Semi-Annual Certification – Completed at least every six months – Signed by a supervisor with knowledge or the employee – After-the-fact record (dated) – Accounts for the total activity for which the employee compensated 47 Pennsylvania Department of Education Bureau of Special Education

48. A-87: If employee works on multiple cost objectives Personnel Activity Reports – After-the-fact record (dated) – Account for the total activity for which employee compensated – At least monthly – Signed by the employee 48 Pennsylvania Department of Education Bureau of Special Education

49. ACCESS Funds Request PDE 352 request forms were revised 2/2012 Common errors that will hold up reimbursements Contact information Short narrative explaining what funds will be used for Requesting benefits FAI Account Balances 49 Pennsylvania Department of Education Bureau of Special Education

50. PCG Contacts FAI reports are not available on LEA’s Easy Trac sites. PCG provides them upon request Training is provided and there is an open forum for attendees to ask questions LEAS can sign up at this address: http://www.publicconsultinggroup.com/client /paaccess/calendar.html. Pennsylvania Department of Education Bureau of Special Education 50

51. PCG contact IU's (and their districts) & other schools Patrick Cassidy - pcassidy@pcgus.compcassidy@pcgus.com 1, 2, 4, 5, 8, 12, 20, 25, 28 Amy Mirocco - amirocco@pcgus.comamirocco@pcgus.com 3, 7, 13, 19, 22, 23, 24, 29 Andy Martin - amartin@pcgus.comamartin@pcgus.com 9, 15, 27, CS, APS Allen Prendergast - aprendergast@pcgus.comaprendergast@pcgus.com 10, 14, 18, 21 Devin Best - dbest@pcgus.comdbest@pcgus.com 6, 11, 16, 17 Jennifer Taylor - jlotaylor@pcgus.comjlotaylor@pcgus.com 26 Pennsylvania Department of Education Bureau of Special Education 51

52. NOTE: Please continue to direct all general SBAP support questions and issues to SBAPsupport@pcgus.com or call 1-866-912- 2976 about SBAP, EasyTrac, RMTS, MCRCS, or Cost Settlement. This "centralized" support approach has enabled them to answer all incoming questions within a 48 hour (ie., two business day) window. SBAPsupport@pcgus.com Pennsylvania Department of Education Bureau of Special Education 52

53. When should you reach out to contact your PCG representative When you have a persistent issue that general support has not been able to resolve, or when you'd like to discuss scheduling either a conference call or onsite training for your IU and member districts, Charter Schools, and/or Approved Private Schools. Pennsylvania Department of Education Bureau of Special Education 53

54. Excess Cost Those costs in excess of the average annual per-student expenditure in an LEA during the preceding school year for an elementary or secondary school student with a disability An LEA must spend at least the average annual per-student expenditure before Part B funds are used to pay the excess costs of providing special education and related services. 54 Pennsylvania Department of Education Bureau of Special Education

55. Let’s break this down, so you can go back and calculate excess cost at your school First the LEA must determine the total amount of its expenditures for elementary school students from all sources – local, state, and federal (including Part B) – in the preceding school year. Only capital outlay and debt services are excluded From State and local tax funds$6,500,000 From Federal Funds 600,000 Total Expenditures$7,100,000 Less capital outlay and debt service -60,000 Total expenditures$7,040,000 (For elementary students less capital outlay and debt service) Pennsylvania Department of Education Bureau of Special Education 55

56. Don’t forget the deductions The LEA must subtract from the expenditures amounts spent for: (a) IDEA, Part B allocation (b) ESEA, Title I, Part A allocation (c) ESEA, Title III, Parts A and B allocation (d) State and local funds for children with disabilities (e) State or local funds for programs under ESEA, Title I, Part A, and Title III, parts A and B These are funds that the LEA actually spent, not funds received last year but carried over for the current school year. Pennsylvania Department of Education Bureau of Special Education 56

57. Let’s plug the deductions into our example The LEA spent the following amounts for elementary school students last year: (a) From IDEA, Part B allocation$200,000 (b) From ESEA, Title I, Part A$250,000 (c) From ESEA, Title III, Part A and B$ 50,000 (d) From State and local funds for children with disabilities$500,000 (e) From State and local funds for programs under ESEA, Title I, A, and Title III, Parts A and B$150,000 Total Other Deductions$1,150,000 Pennsylvania Department of Education Bureau of Special Education 57

58. Are we still having fun???? We need to calculate the total expenditures less capital outlay, debt service, and other deductions Total expenditures less capital outlay and debt$7,040,000 Less Other Deductions$1,150,000 Total expenditures less capital outlay, debt service, and other deductions$5,890,000 Pennsylvania Department of Education Bureau of Special Education 58

59. Let’s calculate the average annual per student expenditures In our example, the LEA had an average elementary school enrollment for the preceding school year of 800 (including 100 children with disabilities). The amount obtained through this computation is the minimum amount the LEA must spend (on the average) for the education of each of its elementary school children with disabilities. Funds under Part B of the Act may be used only for costs over and above this minimum. Total Adjusted Expenditures$5,890,000 Average number of students enrolled 800 Average annual per student expenditure$7,362 $5,890,000/800 students Pennsylvania Department of Education Bureau of Special Education 59

60. Let’s determine the minimum amount of funds the LEA must spend Except as otherwise provided, the LEA must multiply the number of elementary school children with disabilities, times the average annual per student expenditure Number of children with disabilities in the LEA’s elementary schools100 Average annual per student expenditure$7,362 Total minimum amount of funds the LEA must spend for the education of children with disabilities enrolled in the LEA’s elementary schools before using Part B funds$736,200 $7,362 x 100 students You will need to calculate the same for secondary (grades 7-12) Pennsylvania Department of Education Bureau of Special Education 60

61. Link to Excess Cost Calculator http://www.northcentralrrc.org/calculators/Ex cess_Cost_Calc_v1.html http://www.northcentralrrc.org/calculators/Ex cess_Cost_Calc_v1.html This link will give you all the regulations and will walk you through the calculation You must have a separate calculation for elementary and secondary Keep your calculation on hand for single audit 61 Pennsylvania Department of Education Bureau of Special Education

62. Federal Allocations-Transparent How are my SD or CS allocations calculated from the beginning to the end Is everything transparent? Am I treated the same as every other SD or CS? 62 Pennsylvania Department of Education Bureau of Special Education

63. First we have to start with the State’s IDEA allocation OSEP gives each state their allocation and how much will be allocated to each bucket Total allocation 420,403,039 Administration 8,391,220 Discretionary 41,624,060 Pass Through 370,387,759 63 Pennsylvania Department of Education Bureau of Special Education

64. IU Allocations In accordance with 34 CFR 300.705 b(1), Base payments – The State first must award each LEA what each LEA would have received under section 611 of the Act for fiscal year 1999 64 Pennsylvania Department of Education Bureau of Special Education

65. What is the rest of the calculation? In accordance with 34 CFR 330.705b(3)(i)(ii) 85% of the remaining funds are distributed based on the relative number of children (not just special education) enrolled in public and private elementary and secondary schools within the intermediate unit’s region. 15% of any remaining funds are distributed based on the number of students living in poverty within the intermediate unit’s region 65 Pennsylvania Department of Education Bureau of Special Education

66. How does that look? $420,403,039 Total Allocation ($8,391,220) Admin (41,624,060) Discretionary $370,387,759 Total Pass Through (117,401,428) Base Payment $252,986,331 Remaining amount to allocate 66 Pennsylvania Department of Education Bureau of Special Education

67. First we’ll complete the public/nonpublic allocation $252,986,331 x 85%=$215,038,381.35 The total public/nonpublic child count was 1,985,037 $215,038,381.35 / 1,985,037 = $108.3297 That would be $108.3297 per child 67 Pennsylvania Department of Education Bureau of Special Education

68. An IU has a public/nonpublic enrollment of 52,974 $108.3297 x 52,974 = $5,738,655 68 Let’s look at an IU Pennsylvania Department of Education Bureau of Special Education

69. On to the poverty piece $252,986,331 Amount after base payment $252,986,331 x 15% = $37,947,949.65 The total poverty child count is 813,505 $37,947,949.65 / 813,505 = $46.6475 per child 69 Pennsylvania Department of Education Bureau of Special Education

70. Looking at the same IU This IU has a poverty child count of 23,731 $46.6475 x 23,731 = $1,106,991 for the poverty piece of the calculation 70 Pennsylvania Department of Education Bureau of Special Education

71. What would be the allocation for this IU? $4,314,420 Base payment from FY 1999 $5,738,655 85% public/nonpublic amount $1,106,991 15% poverty amount 11,160,066 Total IU Allocation 71 Pennsylvania Department of Education Bureau of Special Education

72. It doesn’t stop here We call the preschool piece Component 1 Component 1 has their own 611 grant To calculate the Component 1, we use the entire 3- 21 child count to get a per child amount Ex. $11,160,066 Total IU Allocation/8,998= $1,240.2830 per child $1,240.2830 x 540 (3-eligible 5 year olds)= $669,753 72 Pennsylvania Department of Education Bureau of Special Education

73. Everything else is school age $11,160,066 IU Total ($669,753) Component 1 $10,490,313 IU School Age Allocation 73 Pennsylvania Department of Education Bureau of Special Education

74. Component 2 TaC Component 2 funds must be utilized to support a minimum of 5.0 FTE positions for training and consultation (TaC) This limitation does not apply to the Philadelphia IU, where amounts will be based on the number of FTE positions approved by the PDE It has been level funded at 8% of the total allocation since 2007-08 Approval to exceed the 8% will be made by the Bureau of Special Education upon written request 74 Pennsylvania Department of Education Bureau of Special Education

75. Calculation of Component 2 $11,160,066 IU Total Allocation ($892,805.28) 8% of allocation ($607,987.00) requested from IU to cover TaC $10,490,313 School Age Allocation ($607,987) Component 2 $9,882,326 Balance for Component 3 75 Pennsylvania Department of Education Bureau of Special Education

76. Equitable Participation Children with disabilities unilaterally enrolled in private schools by their parents Each IU must conduct a thorough and complete child find process to determine the child count Each IU must complete the proportionate calculation of federal funds as required in the grant application 76 Pennsylvania Department of Education Bureau of Special Education

77. EP Calculation with real numbers 8,998 IU 3-21 child count 50 EP eligible child count 9,048 total number of eligible child count 50/9,048 =.005526 (.55%) $11,160,066 x.55% = $61,671.45 EP Amount 77 Pennsylvania Department of Education Bureau of Special Education

78. We’re getting there $10,490,313 IU School Age Allocation ($607,987) Component 2 ($61,671.45) Equitable Participation $9,820,654.55 SD/CS Funding 78 Pennsylvania Department of Education Bureau of Special Education

79. SD/CS Allocation $9,820,654.55 SD/CS Funding Amount Divided by 8,458 School Age Child Count $1,161.11 per Child For the SD/CS allocation take each child count times $1,161.11 79 Pennsylvania Department of Education Bureau of Special Education

80. SD/CS Allocation Ex. $1,161.11 x 115 school district child count = $133,527.46 IDEA Allocation for School District $1,161.11 x 24 charter school child count = $27,866.60 IDEA Allocation for Charter School 80 Pennsylvania Department of Education Bureau of Special Education

81. Federal Register Update Modifications to make the Federal Gov’t guidance more efficient, effective and transparent Begins with any funding disbursed after 12-26- 14 IDEA will start with the 2015-16 funds Pennsylvania Department of Education Bureau of Special Education 81

82. Update Auditors will ask to see written procedures on cash management Threshold for single audit will be raised from $500,000 to $750,000 The threshold for questioned cost is $25,000 Pennsylvania Department of Education Bureau of Special Education 82

83. How will 2014-15 IDEA Funds be Disbursed? The IU will disburse funds using the Reimbursement Process SD’s and CS’s send in allowable invoices IU will approve invoices and send check for the amount Pennsylvania Department of Education Bureau of Special Education 83

84. Why Reimbursement? IU’s are required to do subrecipient monitoring IU’s must make sure all invoices are for allowable expenses It is the approved method according to the Office of Special Education Programs (OSEP) and The Office of Management and Budget (OMB) Pennsylvania Department of Education Bureau of Special Education 84

85. Payments and Disbursements Reimbursement is preferred method of disbursement Pass through entity must make payment within 30 calendar days after receipt of the billing, unless the entity reasonably believes the request to be improper Pennsylvania Department of Education Bureau of Special Education 85

86. Risk Assessments Pass through entity should do a risk assessment before disbursing funds Refer to handout Hold funds? – Provide subrecipient more training or technical assistance – Perform on-site reviews Pennsylvania Department of Education Bureau of Special Education 86

87. When can funds be held? The entity has failed to comply with: – Project objectives – Federal statutes – Regulations – Terms and conditions of the Federal award – Entity is delinquent in a debt to the United States Pennsylvania Department of Education Bureau of Special Education 87

88. Why is the system of debarment and suspension, for ED nonprocurement activities, important? To protect the public interest, the Federal Government ensures the integrity of Federal programs by conducting business only with responsible persons. Check the Excluded Parties List System (EPLS) to determine whether a person is excluded, at http://www.sam.gov Pennsylvania Department of Education Bureau of Special Education 88

89. Nation-Wide Fiscal Monitoring Office of Special Education Programs (OSEP) declared in 2009 that they would fiscal monitor every state on all fiscal regulations, and would include ARRA reporting PA was first to get the letter in December of 2013 with no findings Fiscal Monitoring Instrument (refer to handouts) Only 18 states have received their results So far 10 states had no findings and 8 had findings which required additional reporting and follow-up with OSEP http://www2.ed.gov/fund/data/report/idea/partbfymltrs/ind ex.html#pa http://www2.ed.gov/fund/data/report/idea/partbfymltrs/ind ex.html#pa Pennsylvania Department of Education Bureau of Special Education 89

90. Who can I contact with questions? Sue Leonard Email mleonard@pa.gov Phone 717-772-1114mleonard@pa.gov Karen Porambo Email kporambo@pa.gov Phone 717-705-5186kporambo@pa.gov Jim Tobias Email jatobias@pa.gov Phone 717-783-6925jatobias@pa.gov Pennsylvania Department of Education Bureau of Special Education 90