1. SPECIAL EDUCATION FINANCE FY 2015-16 Revised October 27, 2015 1

2. Prior to August 31, review all SPED AFRs in COGNOS to ensure that appropriate special education function and object codes have been used, that Function/Object expenditures do not exceed the 10% variance that State/Local Maintenance of Effort has been met. Prior to September 30, review all SPED budgets in COGNOS to ensure that appropriate special education function, object and program codes have been used, that State/Local Maintenance of Effort has been budgeted, that 100% of Title VI-B funds available have been budgeted and that Medicaid and ARMAC projected and carryover funds have been budgeted. REVIEW APSCN/COGNOS REPORTS 2

3. Budgets due in APSCN before October 1 All budgets listed below will reflect the use of SPED program codes and must be budgeted in the APSCN system before the October 1 deadline. State/Local VIB section 611 (School Age) VIB, section 619, Federal Preschool (if applicable) State Preschool (if applicable) Medicaid ARMAC 3

4. Accessing Reports via COGNOS 4 A detailed guide, which describes how to access Special Education Budget and AFR Reports, can be found on the ADE Special Ed website. It is important to read the descriptors at the bottom of each COGNOS Report in order to know what fund and program codes are included in the report pull. https://arksped.k12.ar.us/FundingAndFinance/Workshops.html

5. Important Due Date Special Education Budget Submissions School-Age, section 611 Preschool, section 619 Due October 1, 2015 Complete Budget Signature Sheets 1. Statement of Intent 2. Assurances & Agreements 3. ED 80-0013—Certification of Lobbying https://arksped.k12.ar.us/FundingAndFinance/FinanceForms.html FY 2015-16 Special Education Budget Checklist (in MYSPED Resource) FY 2014-15 Special Education Annual Financial Report Checklist (in MYSPED Resource) CEIS Application (if applicable) 5

6. Budget and Annual Financial Reports FY 2015-16 Budget Data will be pulled from Cycle 1 Submission to APSCN—Due September 30, 2015. FY 2014-15 Annual Financial Report Data will be pulled from Cycle 9 Submission to APSCN—Due August 31, 2015. AFR Reports are expenditures 6

7. CODING Commissioner’s Memo FIN-15-100 announces change in coding An updated list of commonly used SPED codes and Non- allowable SPED codes is posted on the web https://arksped.k12.ar.us/FundingAndFinance/Workshops.html Please refer to the Arkansas Financial Accounting Handbook as a reference for codes (available in APSCN). 7

8. Special Education forms Due Oct 1 Forms below are required for each Special Education Program Budget State/Local, VIB, Medicaid and ARMAC https://arksped.k12.ar.us/FundingAndFinance/FinanceForms.html https://arksped.k12.ar.us/FundingAndFinance/FinanceForms.html AFR forms for 2014/15: These forms should match the COGNOS AFR Report amounts Report of Equipment / Technology Purchased or Bus Purchased form Report of Construction, Renovation or Repair form Budget forms for 2015/16: These forms should match the COGNOS Budget Report amounts Request to Purchase form for Equipment, Technology or Bus Request to Purchase form for Construction, Renovation or Repair All Requests must be in the budget before submitting. All Requests Forms must be preapproved before purchase. 8

9. MAIL ORIGINAL DOCUMENTS OFFICE: 501-682-4223 FAX: 501-682-4313 Special Education Unit Attn: Grants & Data 1401 West Capitol, Suite 450 Little Rock, AR 72201 9

10. Payment Suspension All Budget Applications should be submitted by the due date of October 1, 2015. After October 31, Title VI-B payments could be suspended for districts that have submitted budgets with inaccuracies, or have not submitted all required budget items. Suspended payments will be resumed for these districts when all inaccuracies have been corrected or when all required information is provided and the district’s budget application is approved. 10

11. EXCESS COST Part B 11

12. Federal Definition of Excess Cost §300.16 Excess costs means those costs that are in excess of the average annual per-student expenditure in an LEA during the preceding school year for an elementary school or secondary school student. §300.202 The excess cost requirement prevents an LEA from using funds provided under Part B to pay for all of the costs directly attributable to the education of a child with a disability. 12

13. Excess Cost Intent At both the elementary and secondary school levels (computed separately), the excess cost requirement stipulates the district must spend (in state and local funds) at least as much (average amount per pupil) on special ed students, as the district is spending on all students (average amount per pupil). 13

14. Excess Cost Intent In summary, a district must document that it is spending at least as much (in state and local funding) on disabled students, as the district spends on non-disabled students. By meeting both the MOE and EC requirements… a district is in compliance with the non-supplanting provisions of federal law and regulation. 14

15. Excess Cost Calculation Four components to the Excess Cost Calculation: 1. Compute total expenditures 2. Subtract certain expenditures 3. Compute average annual per pupil amount 4. Determine minimum amount of funds to spend for Students With Disabilities 15

16. Excess Cost v. MOE Excess Cost: Spending on Special Education students compared to non- Special Education students By grade range Expenditures compared in same year MOE: Spending only on Special Education students At district level Expenditures compared to prior year 16

17. EXCESS COST Excess Cost Calculation should be calculated by the district and kept onsite. Districts are not required to submit Excess Cost calculation in the October 1 submission but should be aware of the impact this requirement has on the use of Part B funds in conjunction with the use of State or Local funds. Links to more information concerning Excess Cost are posted on the web https://arksped.k12.ar.us/FundingAndFinance/Workshops.html 17

18. MOE MAINTENANCE OF EFFORT 18

19. Legal Expenses Legal expenses, including attorney fees and other related hearing expenses, may not be included when calculating a district’s Maintenance of Effort (MOE). As stated in the relevant federal regulation, 34 C.F.R. § 300.203, an LEA complies with the MOE requirement, “if the LEA budgets, for the education of children with disabilities, at least the same total or per capita amount……. as the LEA spent for that purpose….. for the most recent prior year for which information is available.” (emphasis added) The education of children with disabilities includes special education and related services as defined in federal regulations, 34 C.F.R. §§ 300.34 and 300.39. Neither legal fees nor attorney fees are included in either definition and therefore, may not be included in a district’s calculation of MOE. 19

20. State and Local Test For the 2015-16 year, districts will continue to meet MOE with State and Local funds, test #1. COGNOS Budget and Annual Financial Reports (AFR) give the MOE status in the upper left of the report. Use the AFR (expenditure) report for current status. 20

21. IDEA Fiscal Requirements Individuals with Disabilities Education Act (IDEA) Fiscal Requirements: Maintenance of Effort (MOE) Excess Costs Private School Proportionate Set Aside Coordinated Early Intervening Services (CEIS) 21

22. IDEA Fiscal Requirements Districts should consider their MOE status (Eligibility and Compliance), Excess Cost requirement, Private School Proportionate Set Aside amount and Coordinated Early Intervening Services possible set aside when developing annual budgets. All four of these additional fiscal requirements impact a district’s use of its Part B funds. 22

23. MOE Requirement IDEA Maintenance of Effort The Individuals with Disabilities Education Act (IDEA), §300.203, requires the Arkansas Department of Education to determine that a school division complies with the maintenance of effort requirement to spend at least the same total amount of either local or local plus state dollars or per capita amount of either local or local plus state dollars for the education of children with disabilities that the school division spent from the same source for that purpose in the previous year. 23

24. MOE Eligibilty Standard The first MOE requirements for districts to meet is the Eligibility/Budget Standard Eligibility Standard: a district must budget, for the education of children with disabilities, at least the same total or per capita amount of local or local plus state dollars as the district spent for that purpose from the same source for the most recent prior year available Districts provide the documentation that demonstrates a plan to budget the required amount in their Local Application for Part B funds. 24

25. MOE Compliance Standard The second MOE requirement for districts to meet is the Compliance/Expenditure Standard. Compliance Standard: a district must expend at least the same total or per capita amount of local or local plus state dollars for a current school year on the delivery of special education and related services, as were spent the previous year (comparison year). ADE will determine whether a district has met its MOE Compliance requirement by reviewing final district expenditures reported in the Cycle 9 data collection. 25

26. COMPARISON YEAR: ELIGIBILITY STANDARD : The comparison year is "the most recent fiscal year for which information is available”, regardless of which method the LEA uses. COMPLIANCE STANDARD: The comparison year is “the preceding fiscal year”, regardless of which method the LEA uses. 26

27. Using Allowable Exceptions for Eligibility Standard To the extent the information is available; The (exceptions) the LEA took in the intervening year, or years between the most recent fiscal year for which information is available, and the fiscal year for which the LEA is budgeting; and The (exceptions) the LEA reasonably expects to take in the fiscal year for which the LEA is budgeting 27

28. The 4 Tests of MOE Section §300.203 of the IDEA Regulations specifies the four MOE tests districts can use to meet the Eligibility and Compliance Standards status: 1. Local expenditures only 2. Local and State combined expenditures 3. Local per pupil expenditure 4. Local and State per pupil expenditure 28

29. New Clarification on Passing MOE Tests The level of effort a district must meet in the fiscal year after it fails to maintain effort is the level of effort that would have been required in the absence of that failure, not the LEA’s reduced level of expenditures Districts must figure all 4 “tests” for MOE compliance and keep track of these amounts (AFR) for reference in each subsequent year (see Compliance example). Districts must meet at least one MOE test. 29

30. : 4 TESTS MOE form Complete and mail the NEW “4 Tests” form for MOE to Grants & Data by October 15. https://arksped.k12.ar.us/FundingAndFinance/FinanceForms.html 30

31. Impact of Method of the Subsequent Years Rule To determine required level of effort, the district must look back to the most recent fiscal year in which LEA maintained effort. and must look back to the most recent fiscal year in which the LEA met MOE using the same method. 31

32. Impact of Method of the Subsequent Years Rule For example, LEA wants to use State and local funds (total) to meet the compliance standard in FY 2016-2017. LEA failed to meet MOE in FY 2015-2016 using that method. LEA met MOE in FY 2014-2015 using that method. LEA must use FY 2014-2015 as the comparison year. 32

33. Eligibility/Budget Example Fiscal YearLocal OnlyState + LocalLocal per CapitaState + Local per capita Child Count 2011 – 2012$400 *$1,100 *$40 *$110 *10 2012 – 2013$450 *$1,300 *$45 *$130 *10 2013 – 2014$550 * $1,200 **$55 *$120 **10 2014 – 2015 $500 **$1,300 * $50 **$130 *10 2015 – 2016 Required Amount to Budget for 2016 – 2017 Met MOE ** Failed MOE $550 $1,300 $55 $130 33

34. Compliance Example/AFR Fiscal YearLocal OnlyState + LocalLocal per CapitaState + Local per capita Child Count 2011$10,500$21,000$1,050$2,100 10 2012$10,400 **$21,600 *$1,040 **$2,160 * 10 2013$10,650 *$21,500 **$1,065 *$2,150 ** 10 2014$10,800 *$22,200 *$ 1,080 *$2,220 * 10 2015$ 8,900 **$22,000 **$ 890 **$2,200 ** 10 Required MOE 2015-2016 *Met MOE **Failed MOE $10,800 $22,200 $1,080 $2,220 34

35. Exceptions to IDEA MOE §300.204a A school division may reduce the level of expenditures below the previous year’s spending if the reduction is attributable to the voluntary departure, by retirement or otherwise, or departure for just cause, of special education or related service personnel. Excludes positions eliminated through RIF Includes positions eliminated through attrition from State/Local funds Includes savings between high salary of departing teaching and low salary of new teacher (only from State/Local funds) 35

36. Exceptions to IDEA MOE §300.204b A school division may reduce the level of expenditures below the previous year’s spending if the reduction is attributable to a decrease in the enrollment of children with disabilities. (The 2 most current years of Child Count loss is the only allowable exception for decrease of enrollment on the AFR Checklist form.) 36

37. Exceptions to IDEA MOE §300.204c A school division may reduce the level of expenditures below the previous year’s spending if the reduction is attributable to the termination of the obligation of the agency to provide a program of special education to a particular child with a disability that is an exceptionally costly program, as determined by the state’s education agency. 37

38. Exceptions to IDEA MOE §300.204d A school division may reduce the level of expenditures below the previous year’s spending if the reduction is attributable to the termination of costly expenditures for long-term purchases. 38

39. Adjustment to MOE In accordance with section §300.205 of the IDEA regulations, in any fiscal year that a district’s sub-grant allocation exceeds the amount that the LEA received in the previous fiscal year, that district may reduce the level of local, or state and local, expenditures otherwise required by the district’s MOE requirements in IDEA, section 613(a)(2) by up to 50 percent of the increase in the district’s sub- grant allocation. 39

40. Adjustment to MOE The district must spend the ‘freed-up’ local (or state and local) funds on activities that are authorized under the Elementary and Secondary Education Act (ESEA) of 1965. This provision cannot be used by any district that has been identified as having significant disproportionality and is required to reserve 15 percent of their federal Part B award for Coordinated Early Intervening Services (CEIS). However, if a district voluntarily chooses to set aside up to, but not to exceed, 15 percent of its federal Part B grant award, the amount the district chooses to set aside is reduced by the amount taken for the allowable exception under this provision. 40

41. Consequences of MOE Failure If school division doesn’t meet its MOE requirement: ADE pays back the US Department of Education using non-federal funds ADE may require the district to pay back The threshold for the next MOE calculation will revert back to the last year that the district did meet MOE. 41

42. 1) Review the COGNOS State & Local Annual Financial Reports before the Cycle 9 submission to APSCN to determine whether MOE has been met for the 2014-2015 year. 2) Review the COGNOS State/Local Budget Reports before the Cycle 1 submission for purposes of MOE for the 2015-2016 year. MAINTENANCE OF EFFORT (REVIEW COGNOS REPORTS) 42

43. Maintenance of Effort If a district’s COGNOS Budget Report shows the MOE status is in the negative, the district must list allowable exemptions in the Budget Checklist on MySPED or increase the State/Local budget. 43

44. MOE Exemptions Exemptions for 2014- 15 should be listed on the AFR Checklist form. Exemptions for 2015- 16 should be listed on the Budget Checklist form. 44

45. MAIL ORIGINAL DOCUMENTS OFFICE: 501-682-4223 FAX: 501-682-4313 Special Education Unit Attn: Grants & Data 1401 West Capitol, Suite 450 Little Rock, AR 72201 45

46. COORDINATED EARLY INTERVENTION SERVICES CEIS http://www2.ed.gov/policy/speced/guid/idea/ceis_pg3.html 46

47. Required Coordinated Early Intervening Services (CEIS) As permitted by section § 300.226 of the IDEA regulations, a school district may use 15 percent (or up to 15 percent) of their Part B award to provide certain services to students who ARE NOT identified under the IDEA as students with disabilities. A school district identified as having significant disproportionality is required to set aside 15 percent of its Part B award for CEIS. 47

48. REQUIRED CEIS Based on the provisions of individuals with Disabilities Education Act (IDEA) of 2004 a district that has been identified with significant disproportionality is: Required to budget and use 15% of the IDEA FY 2015-16 allocation for the provision of Coordinated Early intervening Services (CEIS) for at risk children in the district, particularly those in groups that were significantly over-represented in the special education population. Required to complete a review of policy, procedures, and practices. Prohibited from reducing its Maintenance of Effort (MOE) under 34 CFR 300.205. 48

49. Voluntary Coordinated Early Intervening Services (CEIS) A school district may choose to voluntarily set aside up to 15 percent of their Part B award for Coordinated Early Intervening Services (CEIS). Districts that voluntarily set aside up to 15 percent of its Part B award will have to be aware of the implications with Section § 300.205 and a possible adjustment to its MOE status. 49

50. Coordinated Early Intervening Services (CEIS) Each LEA that develops and maintains coordinated, early intervening services must annually report to the SEA on: The number of children served under this section who received early intervening services; and The number of children served under this section that received early intervening services and subsequently receive special education and related services under Part B of the Act during the preceding two year period. 50

51. CEIS Data in APSCN The CEIS data are a component of the special education module in the Arkansas Public School Computer Network (APSCN). This data dictionary at the link below explains the APSCN data fields and codes that are required for federal reporting. Not all situations are covered in the Guide. If after consulting this data dictionary you still have questions about data entry and coding, please contact the Arkansas IDEA Data & Research Office at 501-683-7219. https://arksped.k12.ar.us/DataAndResearch/DataDictionaries.html 51

52. CEIS Data Dictionary https://arksped.k12.ar.us/DataAndResearch/DataDictionaries.html https://arksped.k12.ar.us/DataAndResearch/DataDictionaries.html 52

53. Caution: Possible CEIS Supplant Issues Cautions should be taken before coding a program as CEIS. Consider using the guiding questions below and involve district administration to avoid supplant issues. Is the CEIS program required by law ? If the CEIS program is not a new program, how was it funded in the past? Do all students participate in this program (or all 6 th graders, or all 2 nd graders…) ? If all students receive this service, how is this a CEIS program? 53

54. CEIS Application Form- A form for Required and Voluntary CEIS Program Application is posted on the web and should be submitted before the October 1 deadline. https://arksped.k12.ar.us/FundingAnd Finance/FinanceForms.html In the future, the CEIS Application will be submitted in June to allow districts to budget accordingly. 54

55. CEIS Program Description Research based What is the research base for the program? Program Description: Does the program description address at-risk students in the district, particularly those groups that were significantly over-represented in the special education population? How many students are being served? What amount of time do these students spend in the program daily/weekly? What materials are used? If funds are being used for purposes other than direct student services, please provide an explanation. Program Evaluation What tool is being used to measure progress? 55

56. Required CEIS—Districts found to have significant disproportionality based on race or ethnicity are required to use 15% of its IDEA funds (Total Title VI-B, § 611 School Age and Title VI-B, § 619 Preschool funds) for CEIS Activities. Required CEIS funds must be coded to program 269. Required CEIS funds that are not spent during the current year must be carried over to the next year. Required CEIS carryover funds must be coded to program 267. Voluntary CEIS—Title VI-B funds used for CEIS activities cannot exceed 15% of your Total Title VI-B, § 611 (School Age) and Title VI-B, § 619 (Preschool) funds for voluntary CEIS activities. Voluntary CEIS funds must be coded to program 265. Voluntary CEIS carryover funds must be coded to program 264. V oluntary CEIS funds must be coded to function 1297 (instruction,) or function 2213 (staff development). Coordinated Early Intervening Services Coding 56

57. Important Budget Codes for Required CEIS: Example: FUNCTION CODE 1297 used for Direct CEIS Instruction FUNCTION CODE 2213 used for all Professional Development FUNCTION CODE 1297 or Program codes 264, 265, 267, or 269 should not be budgeted or expended from State/Local, Medicaid, or ARMAC funds. Coordinated Early Intervening Services (CEIS) FundFunctionSubjectProgram Code LocationObject Code 6702-1297-XXX-269 (REQUIRED) -XX-6XXXX 6702-1297-XXX-267 (CARRYOVER) -XX-6XXXX 57

58. VOLUNTARY CEIS: An LEA may voluntarily use up to the maximum amount (15% of 611 and 619 funds) The LEA may reallocate any unspent voluntary CEIS funds during the time that the funds are available for obligation. Fund/Source 6702 and Program code 265 must be used for current year voluntary CEIS funds while program code 264 must be used for carryover funds for voluntary CEIS. FUNCTION CODE 1297 used for Direct CEIS Instruction FUNCTION CODE 2213 used for all Professional Development, including CEIS FUNCTION CODE 1297 or Program codes 264, 265, 267, or 269 should not be budgeted or expended from State/Local, Medicaid, or ARMAC funds. Coordinated Early Intervening Services (CEIS) FundFunctionSubjectProgram Code LocationObject Code 6702-1297-XXX-265 (CURRENT YR) -XX-6XXXX 6702-1297-XXX-264 (VOLUNTARY CARRYOVER) -XX-6XXXX 58

59. PRIVATE SCHOOL PROPORTIONATE SHARE PSPS Link to PSPS Chart https://arksped.k12.ar.us/FundingAndFinance/SchoolAge.htmlhttps://arksped.k12.ar.us/FundingAndFinance/SchoolAge.html 59

60. Private School Proportionate Set Aside Under section § 300.132 of the IDEA regulations, districts are required to complete a formula to identify the amount they must set aside of their Part B award to be used to provide special education and related services, through a Services Plan, to children whose parents have placed their child in a private school but who still want their child to receive some special education. 60

61. Districts are required to spend a proportionate amount of IDEA Part B funds to provide services to parentally-placed private school or home schooled children with disabilities. Private School Proportionate Share information is pulled from Cycle 4 reports. Required PSPS funds must be coded to program 268. Required PSPS funds that are not spent during the current year must be carried over to the next year. Required PSPS carryover funds must be coded to program 266. Private School Proportionate Share (PSPS) 61

62. Title VI-B Regular Funds—Fund/Source 6702 and Program Code 268 must be used for current year Private School Proportionate Share funds and Program Code 266 must be used for carry over funds for Private School Proportionate Share. Only function codes 1218, 1228, 2158, and 2168 should be used for Private School Proportionate Share funds. Private School Proportionate Share (PSPS) FundFunctionSubjectProgram Code LocationObject Code 6702-2158-XXX-268 (Current Year) -XX-6XXXX 6702-2158-XXX-266 (Carryover) -XX-6XXXX 62

63. Private School Proportionate Set Aside Number of eligible children with disabilities in the District (December 1, 2014 Child Count) 148 Number of parentally placed or home school eligible children with disabilities in private schools or home school located in the district and number identified as needing services but services not being provided. Use Dec. 1, 2014 Child Count and Private School Survey Questions 4 & 5. 2 Total Title VI Part B allocation to the District (current year only) 246,269.34 Average allocation per eligible child (#3 divided by #1) 1,663.98 Amount to be expended for parentally placed children and home school children with disabilities (PSPS) (#4 multiplied by #2) 3,327.96 63

64. PSPS Set-Aside The PSPS Chart posted on the web is based on the Preliminary Allocation amount for VIB in Commissioner’s Memo FIN-16-011. https://arksped.k12.ar.us/FundingAnd Finance/SchoolAge.html It is not necessary to include a set aside for the 2014-15 Additional Reserve. 64

65. PRIVATE SCHOOL SURVEY The Private School Survey is required for all districts. The survey is necessary to ensure that all private school or home school students that have been identified as needing special education and/or related services are included in the calculation of Private School Proportionate Share. Private school AND/OR home school students that were 1)being served or 2)identified as needing special education and/or related services as of December 1, 2015, should be included in this survey. 65

66. PRIVATE SCHOOL SURVEY The Private School Survey will open Dec. 1, 2015 and must be completed online by December 18, 2015. The completed survey should be printed after submission and mailed to: Special Education Private School Survey Grants & Data Management Arkansas Department of Education 1401 W. Capitol, Suite 450 Little Rock, AR 72201 66

67. TITLE VIB IDEA PART B 67

68. Title VI, Part B for disabled students only 34 C.F.R. § 300.202 Use of amounts. (a) General. Amounts provided to the LEA under Part B of the Act— (1) Must be expended in accordance with the applicable provisions of this part; (2) Must be used only to pay the excess costs of providing special education and related services to children with disabilities, consistent with paragraph (b) of this section; and (3) Must be used to supplement State, local, and other Federal funds and not to supplant those funds. 68

69. Title VI-B Permanent Formula [34CFR 300.705] 69 Base Allocation – 1999 Base Year Population – Prior year October 1 enrollment plus private school enrollment (85% after state set-aside and base allocation) Poverty – F/R lunch eligibility of all school age students (15% after state set- aside and base allocation) (Refer to Commissioner’s Memo FIN-16-024 for allocation disbursement procedures.)

70. ADE Finance ADE Finance announces federal awards through Commissioner’s Memos. The award/budget amount is a set amount and should not be increased/decreased by the district. Preliminary Award amounts are announced in August of 2015. PSPS and CEIS percentages will use these amounts. Districts should also consider the Cash on Hand, Additional Reserves awarded and Carryover funds from previous years when arriving at Total Funds Available for budgeting the October 1 submission. Throughout the year, ADE Finance will continue to announce updates to awards. Districts should be mindful in checking Commissioner’s Memos. When Final Allocations are announced, districts should amend the budgets accordingly before the announced amendment deadline. 70

71. Commissioner’s Memos Preliminary Allocations FIN-16-011 VIB, Section 611 School Age FIN-16-009 VIB, section 619 Federal Preschool FIN-16-010 State Preschool http://www.arkansased.gov/

72. PREAPPROVED REQUESTS TO PURCHASE Grants and Data must preapprove purchases for Equipment, Technology, Buses and/or Construction/Renovation for amounts $1000 or over.. Before approval of a purchase can be granted, the item(s) on the Request Form must be included in the budget under object code 67000 for Equipment, Technology and Buses. Object code 64000 should be budgeted for Construction/Renovation requests. 72

73. TITLE VI-B FUNDS AVAILABLE = BUDGET AMOUNT 73 (+) COH (Cash-on-Hand) from FY 2014-15* *See APSCN Board Report at the end of the Fiscal Year (2014-15) to determine the COH (will be $0 for most districts) (+) Carryover funds from previous year (+) ANY ADDITIONAL RESERVE announced in Commissioner’s Memos (+) FY 2015-16 PRELIMINARY ALLOCATION in Commissioner’s Memo = TOTAL FUNDS AVAILABLE (amount to budget for FY 2015-16) TOTAL FUNDS AVAILABLE MUST BE BUDGETED before a budget can be approved.

74. IDEA Title VI-B grants have a 27-month window of time to obligate funds and three additional months to liquidate funds. For 14/15 additional reserve distribution allocations, please note the following: Obligation deadline: September 30,2016 Liquidation deadline: December 30, 2016 Title VI, Part B Section 611: Source Code 6702, Revenue Code 45613 For 2015-16 allocations, please note the following: Obligation deadline: September 30, 2017 Liquidation deadline: December 30, 2017 Title VI, Part B, Section 611: Source Code 6702,Revenue Code 45613 74

75. HOW TO CODE VI-B REVENUE FOR JUNE 2015 EXPENDITURES Accrued revenue that districts are required to use for Title VI- B federal funds since ADE has gone to the “REIMBURSEMENT” method for sending federal funds for this program. If the district had a negative balance of $100,000 for Title VI-B funds (F/S 6702) on the board report on June 30 (end of Period 12 or 13 of FY 2015), the correct entry would be: Debit 6702 – 01410 ( Intergovernmental Receivables ) $100,000 Credit 6702 – 45613 (Title VI-B Revenue) $100,000 *Note: This amount of revenue CANNOT cause the Year- to-Date (YTD) revenue for the district to exceed the total funds available. If this occurs, expenditures MUST be moved from F/S 6702 to other sources. 75

76. HOW TO CODE VI-B REVENUE FOR JUNE 2016 EXPENDITURES On or after July 1, 2016 (during Period 1 of FY 2016), the correct entry is: Debit 6702 – 45613 (Title VI-B Revenue) $100,000 Credit 6702 – 01410 (Intergovernmental Receivables) $100,000 Then when the money is received, it is receipted as normal revenue with a CR to revenue and a DR to cash. This is the preferred method by ADE and Audit. Debit 6702 – 01010 (CASH) $100,000 Credit 6702 – 45613 (Title VI-B Revenue)$100,000 76

77. VIB REMINDER When the VIB final allocation is announced through Commissioner’s Memo, Districts must amend the budget total, based on the final allocation before the amendment deadline. 77

78. Time certification forms are required for all Federal employees: Full-time federal employees require certification forms to be completed two times per year. Employees who work in more than one federal program or work part time in a federal program and part in state, local or other programs require time certification forms to be completed each month the employee works. Time Certification 78

79. KEY CHANGES Post award and sub-award changes 79

80. Key Changes in Post-Award Activities  Notable Key Changes: Greater emphasis on internal controls to ensure compliance and fiscal responsibility; Enhanced oversight requirements of subrecipients, which includes risk assessment to develop an appropriate monitoring plan and tools; Enhanced oversight of contracts; and Greater focus on performance expectations and results 80

81. Key Changes in Post-Award Activities 81  Longstanding grantee flexibilities known as the “Expanded Authorities” are still there, just moved to 2 CFR 200.308: Pre-award costs allowable up to 90 days before award Extension one time, up to 12 months “Carry forward” of unobligated balances Budget transfers

82. Key Changes for Pass-Through Entities 82  Under 2 CFR 200.331, pass-through entities are required to: Provide sub-award information to their sub-recipients, including the indirect cost rate for the Federal award Perform a risk assessment for the purpose of sub-recipient monitoring Verify that every sub-recipient is audited (as required by the Single Audit Act)

83. Key Changes: Risk-Based Monitoring 83  Increased responsibilities for pass-through entities: 2 CFR 200.331 (b) Pass-through entities must evaluate each sub- recipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the sub-award for the purpose of determining the appropriate monitoring actions. Risk Assessment does not have to be completed before sub- awards are made, but recipients can decide to make assessments before making the sub-awards.

84. Key Changes: Risk-Based Monitoring (cont.) 84  Considerations for pass-through entities in evaluating sub-recipient risk: History of Maintenance of Effort issues or failure to meet MOE Evidence of financial instability New Director and/or business manager History of late submission of required data or financial information (Part B application, Annual Report) History of audit findings Inaccurate or unverifiable reporting of actual expenditures and carryover on previous year budgets Issues related to timely obligation and liquidation of funds Relevant Federal monitoring

85. Key Changes: Risk-Based Monitoring (cont.) 85  Increased responsibilities for pass-through entities: Under 2 CFR 200.331 (d) Pass-through entity monitoring must include: Review of financial and performance reports; Issuance of management decisions for audit findings on sub-recipients; and Follow-up activities ensuring sub-recipients take timely, appropriate action to cure deficiencies

86. Key Changes: Risk-Based Monitoring(cont.) 86  Under 2 CFR 200.331 (e) the pass-through entity must assess risk to determine monitoring approach. Monitoring and follow up may include: Providing training and technical assistance, Performing an on-site review of entity’s program operations, and Arranging for agreed-upon-procedures for audit services

87. Required Risk-Assessment In November, SPED Finance will post a Risk Assessment Survey on the Survey Tab on the SPED web page to be completed before December 18, 2015. https://arksped.k12.ar.us/index.html The Risk Assessment will provide baseline data for the monitoring process. Questions on the Risk Assessment reflect the Fiscal Monitoring Protocol. 87

88. PRESCHOOL SERVICES EARLY CHILDHOOD 88

89. IDEA (Individuals with Disabilities Education Act) requires school districts to provide all eligible children with disabilities with a free appropriate public education, from ages 3 to 21 years. Districts have the option of providing special education services to eligible preschool children themselves, working with another district(s), or working with an educational service cooperative (ESC) to provide the required services. The Early Childhood Provider Survey, due in March, establishes the flow of funds to the appropriate providers of service for ADE Finance. Accurate entries in the survey are important. Special Education Preschool Services 89

90. Preschool funds from State Preschool Grant Funds and Title VI-B Section 619 federal grant funds are sent to districts providing their own preschool services and to Educational Cooperatives for providing services to participating districts. ESCs also invoice districts for costs not covered by the funding mentioned above. Special Education Preschool Services 90

91. ADE Finance ADE Finance announces Federal Preschool and State Preschool awards through Commissioner’s Memos. Preliminary Award amounts are announced in the summer of 2015. Districts and Co-ops should also consider the Cash on Hand, Additional Reserves awarded and Carryover funds from previous years when arriving at Total Funds Available for budgeting the Oct. 1 submission Throughout the year, ADE Finance will continue to announce updates to awards. Districts and Co-ops should be mindful in checking Commissioner’s Memos. When Final Allocations are announced, Districts and Co-ops should amend the budgets accordingly. 91

92. Title VIB, Section 619 PRESCHOOL (+) COH (Cash-on-Hand) from FY 2014-15* *See APSCN Board Report at the end of the Fiscal Year (2014-15) to determine the COH (will be $0 for most districts, but Cooperatives will likely have COH) (+) Carryover funds from previous year (+) ANY ADDITIONAL RESERVE announced in Commissioner's Memos (+) FY 2015-16 PRELIMINARY ALLOCATION announced in Commissioner’s Memos = TOTAL FUNDS AVAILABLE (amount to budget for FY 2015-16) Starting in year 2015-16, Federal Preschool will change to the reimbursement system with ADE Finance. The current COH will be deplenished first before ADE Finance will reimburse from current funds. 92

93. STATE PRESCHOOL (+) COH (Cash-on-Hand) from FY 2014-15* *See APSCN Board Report at the end of the Fiscal Year (2014-15) to determine the COH (will be $0 for most districts, but Cooperatives will likely have COH) (+) Carryover funds from previous year (+) FY 2015-16 PRELIMINARY ALLOCATION announced in Commissioner’s Memos = TOTAL FUNDS AVAILABLE (amount to budget for FY 2015-16) TOTAL FUNDS AVAILABLE MUST BE BUDGETED 93

94. The amount each district will be invoiced by most co-ops will be $610 per child for their children served by the co-op on December 1, 2015 (some ESCs charge a different amount than $610 per child). Children served in Head Start, ABC, day care programs, etc. are included in the preschool child count; therefore, the districts will no longer be charged an additional amount for children served in Head Start centers. School districts receive no Title VI-B (Section 611), funds for their preschool children that receive services through ESCs, but Title VI-B (Section 611) funds can be used by districts to provide special education preschool services. The account code that should be used if Title VI-B funds are used to pay the ESC is: ESCs will provide a list of each districts’ children that received preschool services and are included in the invoice if requested to do so. Charges to Districts for Preschool Services 670212906982000065910 94

95. PREAPPROVED REQUESTS TO PURCHASE Grants and Data must preapprove purchases for Equipment, Technology, Buses and/or Construction/Renovation for amounts $1000 or over.. Before approval of a purchase can be granted, the item(s) on the Request Form must be included in the budget under object code 67000 for Equipment, Technology and Buses. Object code 64000 should be budgeted for Construction/Renovation requests.

96. Federal and State Preschool REMINDER Preschool Final Allocations are announced through Commissioner’s Memo. Districts must amend the budget totals, before the announced amendment deadline. Please be mindful to check Commissioner’s Memos. 96

97. Preschool Survey due March 4, 2016 All Districts must complete the Early Childhood Survey in MySPED before the March 4, 2016 deadline. The Early Childhood Survey is necessary for participating in Educational Cooperative Preschool Provider Services, for providing district preschool services or for announcing a change in Preschool service provider. The Early Childhood Provider Survey establishes the flow of funds to the appropriate providers of service for ADE Finance. Accurate entries in the survey are important. 97

98. MEDICAID www.armits.org 98

99. Budgets are required for Medicaid and ARMAC (Arkansas Medicaid Administrative Claiming). Budget any Cash-on Hand and Projected Funds for Medicaid and ARMAC Funds can be carried over into subsequent years. Medicaid and ARMAC funds can be used for special education or non-special education activities: Special Education activities should be coded to program code 200-260. Non-Special Education activities should not be coded to program codes 200-269. Medicaid & ARMAC 99

100. Districts’ Medicaid Match must be paid from State/Local funds. The account code for payment of a district’s Medicaid Match should be: Medicaid/ARMAC Questions? 1.866.280.8300 501.375 MITS (6487) 501.375.6488 (fax) Medicaid Match 200029900002000065900 100

101. AMENDMENTS Established dates 101

102. Amendments will now be deadlines State/Local, VIB, Medicaid, ARMAC After the October 1 submission and approval, amendments will become budget pulls on established dates. Grants and Data will pull COGNOS budget reports on these dates. These established dates will be COGNOS budget pulls for all districts. Districts should update total funds available and any changes to the budget prior to the announced deadline. No amendment form is required. 10% Variance still applies. Grants and Data will send corrective information after the amendment deadline for districts to correct before the next deadline or year end, which ever is applicable. Announcements and reminders will be posted on MySPED. 102

103. Amendments will now be deadlines State/Local, VIB, Medicaid, ARMAC Districts will continue to use the Request for Purchase of Equipment form, if there is a change in object code 67000 from the October 1 approved budget. Districts will continue to use the Request for Bus Purchase form, if this was not a part of the approved budget. Districts will continue to utilize the Request for Construction/Renovation form if this was not a part of the approved budget. 103

104. 10% Variance BEGINNING WITH THE 2015-16 SCHOOL YEAR (as of July 1, 2015) 10% variance in special education funding will follow the same procedure as other federal programs. Refer to Commissioner’s Memo LS-16-023. EDGAR 80.30© allows budget changes up to 10% of the total approved budget without ADE approval. The 10% Variance in federal fund expenditures refers to when actual expenditures exceed budgeted expenditures. It is not considered a ‘variance’ when actual expenditures are less than budgeted expenditures. Districts may make budget changes of up to 10% of the total budget amount without ADE approval. 104

105. 10% Variance of Function code Commissioner’s Memo LS-16-023 Compare each Function Total Actual Expenditures to Budgeted Expenditures. LINE ITEM Actual expenditure Variance cannot exceed 10% of Total Budget Total budget is $300,000. 10% variance would be $30,000. Look at each line item to determine if the line item is out of compliance EX: Function 1220, Resource services total line item is $40,000. If the final expenditure is $44,000, it is in compliance because the final expenditure was only $4000 more which is less than 10% of the total budget. If the function line expenditure is greater than the budget by 10%, it is out of compliance. EX : Function 2292, supervisor total line item is $125,000. The final expenditures are $167,000. The variance in the budget of $125,000 to the actual $167,000 is $42,000 which is out of compliance because the function line expenditure is more than the allowed $30,000. (10% of the total budget) 105

106. 10% Variance of Object Code Commissioner’s Memo LS-16-023 If an object column total actual expenditure is greater than the budgeted expenditure, then determine if the column is out of compliance. Check the OBJECT Column Totals: 61000, Salaries: Variance cannot be greater than 10% of Total Budget Total budget is $300,000. 10% variance would be $30,000. Variance for the Total Object column for Salaries cannot be more than 10% of the total budget ($30,000) 62000, Variance cannot be greater than 10% Total budget, etc. Summary: Function Row Totals and Object Column Totals cannot be greater than 10% of the Total Budget 106

107. LEA SUPERVISOR FUNDING 2240 107

108. LEA Special Education Supervisor Funding Supervisor funds must be coded to Fund/Source 2240 and Revenue 32310. LEA Supervisor funds can be used for Salary and Benefits of special education supervisors (or purchase of the services of special education supervisors.) Expenditures from current year or carryover funds should be coded F/S 1240 or F/S 2240. State/Local, Title VI-B or Medicaid funds can be used to support LEA Special Education Supervisor Salaries & Benefits. 108

109. EXTENDED SCHOOL YEAR ESY Link to ESY Guide https://arksped.k12.ar.us/FundingAndFinance/ExtendedSchoolYear.htmlhttps://arksped.k12.ar.us/FundingAndFinance/ExtendedSchoolYear.html 109

110. Two payments will be made: Part I for services from end of school year through June 30, 2015: reimbursed in August. Superintendent’s Certification due July 17, 2015 Part II for services after July 1, 2015: reimbursed in September or October. Superintendent’s Certification due September 11, 2015 Extended School Year (ESY) Services 110

111. Part I ESY services through June 30, 2015: Funding will be $74 per day for each child served. Superintendent’s Certification forms are due July 17th for the actual number of days ESY services were provided through June 30 th. Part I ESY reimbursements will be made in August or September. Anticipated revenue for ESY services through June 30 must be recoded as accrued revenue. ESY expenditures that exceed the revenue that will be received plus carryover must be coded to some other fund. ESY revenue must be coded to Fund/Source 2244 and revenue 32314. Extended School Year (ESY) Services 111

112. The correct entry that ESCs/Districts may be required to use to record accrued revenue for Extended School Year services (F/S 2244) provided in June is shown below: If the ESC/District had provided ESY services that would have generated $10,000 for ESY revenue in June ($74 per day times the number of days served by June 30 for all students served), during period 12 or 13 of FY 15, the correct entry would be: Debit 2244-01410 (Intergovernmental Receivable) $10,000 Credit 2244-32314 (ESY Revenue) $10,000* On or after July 1, 2015 (or after the start of period 1 of FY ‘16), the correct entry is: Debit 2244-32314 (ESY Revenue) $10,000 Credit 2244-01410 (Intergovernmental Receivable) $10,000 Extended School Year (ESY) Services 112

113. When funds are received, they should be recorded as a normal deposit with a CR to revenue and a DR to cash. Debit 2244-01010 (CASH) $10,000 Credit 2244-32314 (ESY Revenue) $10,000 *Note: This amount of revenue CANNOT exceed the amount of ESY revenue that will be received. If a negative fund balance exists for F/S 2244 after anticipated revenue has been accrued, expenditures must be moved to another funding source. Extended School Year (ESY) Services, cont. 113

114. Part II ESY services after July 1, 2015: Funding will be $74 per day for each child served. Superintendent’s Certification forms are due September 11 th for the actual number of days ESY services were provided after July 1, 2015. Part II ESY reimbursements will be made in September or October. ESY revenue must be coded to Fund/Source 2244 and revenue 32314. ESY expenditures that exceed the revenue that will be received plus carryover must be coded to some other fund. Extended School Year (ESY) Services 114

115. 2015-16 Reporting Deadlines Please refer to the SPED Reporting Deadlines posted on the web for ESY and Residential 2015-16 deadlines. https://arksped.k12.ar.us/FundingAndFinance/Workshops.html 115

116. RESIDENTIAL REIMBURSEMENT Link to Residential Guides https://arksped.k12.ar.us/FundingAndFinance/ResidentialPlacement.html https://arksped.k12.ar.us/FundingAndFinance/ResidentialPlacement.html 116

117. In-State Reimbursement School districts with approved residential facilities are eligible for reimbursement of education costs for disabled and non-disabled students. Out-of-State Reimbursement The school district where the student is a resident is eligible for reimbursement of education costs for disabled students only who are provided services at approved Out-of-State residential treatment facilities. Residential Reimbursement 117

118. In-State Reimbursement Approved residential facilities will be able to log into the RPR system to enter student information, including dates served. School district personnel are required to review data entered by in-state residential facilities. Superintendent’s Certification forms are due at the end of each quarter. Timely website submission required. $60 per day reimbursement rate. Due to the number of days that services are provided by residential facilities, the per day amount might be adjusted for the fourth quarter of FY 2015-16. Residential Reimbursement 118

119. Out-of-State Reimbursement School district personnel are required to log into the RPR system to enter student information, including days served, for disabled students placed at approved out-of-state residential facilities each quarter. Superintendent’s Certification forms are due at the end of each quarter.. Timely website submission required. $60 per day reimbursement rate. Due to the number of days that services are provided by residential facilities, the per day amount might be adjusted for the fourth quarter of FY 2015-16. Residential Reimbursement 119

120. Residential Funding—Disabled Students FY 2015-16 Funding — $60 Per Day Revenue must be coded as Fund/Source 2255 Revenue Code 32340. Expenditures for Residential Funding — Disabled students Must be coded as Fund/Source 2255 and Program Code 200. These expenditures should equal but not exceed residential finding for disabled students that is received from the state. The function code for residential expenditures for disabled students is 1270. Coding for Residential Funding - Disabled Students 120

121. Residential Funding—Non-Disabled Students FY 2015-16 Funding—$60 Per Day Revenue must be coded as Fund/Source 2250 Revenue Code 32330. Expenditures for Residential Funding—Non- disabled students Must be coded as Fund/Source 2250 and Program Code 000. These expenditures should equal but not exceed residential funding for non- disabled students that is received from the state. The function code for residential expenditures for non-disabled students is 1197. Coding for Residential Funding Non-Disabled Students 121

122. COMING SOON A worksheet for Excess Cost, a Fiscal Accountability Manual and a Fiscal Monitoring Procedure Protocol are in process. Continue to check the website for postings. https://arksped.k12.ar.us/FundingAndFinance/Workshops.html 122

123. SPED Finance Staff Christina.Foley@arkansas.gov Mikki.Eubank@arkansas.gov Jamila.Ford@arkansas.gov Camile.Wyllia@arkansas.govCamile.Wyllia@arkansas.gov “Pepper” Questions? Special Education Unit Attn: Grants & Data 1401 West Capitol, Suite 450 Little Rock, AR 72201 OFFICE: 501-682-4223 FAX: 501-682-4313 123

124. Area Assignments Mikki.Eubank@arkansas.govMikki.Eubank@arkansas.gov 501-682-4293 LEA # 0101-3001, LRSD, NLR, ESY, JDC, Residential Jamila.Ford@arkansas.govJamila.Ford@arkansas.gov 501-682-4295 LEA# 3002-5604 Camile.Wyllia@arkansas.govCamile.Wyllia@arkansas.gov “Pepper” 501-683-3449 LEA# 5605-7510, PCSSD, Charter districts, Preschool 124