2017 Fall Regional Workshop Division of Federal Programs
PA Department of Education Division of Federal Programs 333 Market St. 7th Floor Division of Federal Programs Harrisburg, PA 17126 Tel : (717) 783-2193 Fax : (717) 787-8634 www.education.state.pa.us Then follow these links to find our page: • Teachers and Administrators • More… • Federal Programs
Fall Regional Workshop Agenda • Appropriately State Certified • Contracts • Fiscal • Uniform Grants Guidance • ESSA • Monitoring • DFP structure • If you are getting monitored this year, stay after for a Preparing for Monitoring session
Proposed State Plan Updates • CSI/TSI • Future of School Improvement funding • Link to plan -http://www.education.pa.gov/K-12/ESSA/Pages/default.aspx#tab-1 • State Plan summary for highlights
HQT Change to ASC in ESSA • Highly Qualified Teacher requirements gone effective August 1, 2016 • Must hold appropriate State certifications for teachers working in a Title I and Title II program • Emergency permits are not considered Appropriately State Certified for federally funded positions • Must send out four week parent letter • Updated FAQ that addresses these common questions • PDE 425 no longer required
ASC Paraprofessionals in ESSA • ALL Instructional Paraprofessionals working in Schoolwide schools need to meet one of the requirements below (a-c). Instructional Paraprofessionals in Targeted Assistance schools paid with Title I funds must also meet one of the requirements below (a-c). • a. Have completed at least two years of postsecondary study. • b. Possess an associate degree or higher. • c. Meet a rigorous standard of quality as demonstrated through a State or local assessment. • Special Education requirements for paraprofessionals remain • Instructional paraprofessionals, each school year, shall provide evidence of 20 hours of staff development activities related to their assignment.
Parent Right to Know • Parent Right to Know letter regarding teacher qualifications • Parents should be directly notified of this information no later than 2 weeks after the start of the school year. • Website posting is insufficient. • Pertains to all teachers in any Title I school. • Notification to parents informing them that their child’s teacher is not “appropriately state certified.” • Parents should be directly notified on an as-needed basis after 4 consecutive weeks. • Pertains to all students that will have a teacher that is not appropriately state certified participating in a Title I program. • SWP – all teachers • TA – Title I teachers • Keep a copy of the letter even though it does not need to be sent out.
Contracting under UGG • What is a contract? • A contract provides goods/services as needed by the program • Contractors (aka vendors) are NOT responsible for carrying out the responsibilities of the federal program • Contractors carry out terms of their contracts • Non-federal entities must have a contract administration system to ensure contractors are complying with the terms of the contract
Subgrant vs. Contract • Subgrantee: • Determines who is eligible to participate in the federal program • Measures performance against objectives of the federal program • Is responsible for programmatic decision-making • Is responsible for complying with federal program requirements • Uses federal funds to carry out the program (not just provide specific goods/services)
Subgrant vs. Contract • A contractor: • Provides goods/services within normal business hour operations (after-school hours count) • Provides similar goods/services to different purchasers • Operates in a competitive environment • Provides goods/services ancillary to operation of federal program • Is NOT subject to compliance requirements of the federal program **** • e.g. - performance reporting – includes goals set for Non-public programs
Subgrant vs. Contract • Each program statute sets out when an entity can subgrant funds to eligible entities • LEAs are subgrantees of SEAs • Subrecipient monitoring has to occur when there is a subgrant • LEAs may not subgrant a subgrant
Contracting • If an LEA cannot provide goods/services, it may enter into a contract to provide the necessary goods/services for the program • Non-federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of the contract
Contracting • There must always be an agreement • Subgrant (PDE and LEA) • Contract (LEA and contractors – IUs, Third-party providers, Companies, etc.) • Includes agreements with other LEAs or IUs to provide services • Must document the use of funds for accountability and allowability purposes
UGG Requirements • Emphasis on IMPLEMENTING LEA policies and procedures • Conflict of Interest policy • Travel Reimbursement policy • Allowability of Costs procedures • Cash Management procedures • Procurement procedures – REFER TO MAY GUIDANCE DOCUMENTATION • Must be implemented by July 1, 2017 • Federal Programs Monitoring • Will result in a “Not Met” and Corrective Action Plan will need to be developed.
Allowability of Costs • In order to determine if a grant cost is allowable for federal grants, the following three tests must be taken into consideration: • Costs must meet the following general criteria in order to be allowable under Federal awards: (a) be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles (2 CFR 200.403 ). • Necessary costs are those that are required in order to carry out the program and activities contained in an approved grant application. • Reasonable costs. A cost is reasonable if, in its nature and amount it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost. … Consideration must be given to: (a) whether the cost is of a type generally recognized as ordinary and necessary for the operation of the subgrantee or the proper and efficient performance of the Federal award (2 CFR 200.404) • Allocable costs. (a) A cost is allocable to a particular Federal award or other cost objective if the goods or services involved are chargeable or assignable to that Federal award or cost objective in accordance with relative benefits received (2 CFR 200.405).
UGG Procurement • UGG promotes full and open competition for the costs of goods and services, including nonpublic services, for federal grant programs. • See Procurement Thresholds for Federal Funds handout • When procuring goods and/or services from an IU or another LEA, you must document that UGG procurement requirements were followed (bids, quotes, etc.) • See PDE Guidance for Intergovernmental Agreements (IGAs) handout • Because each LEA has unique procurement procedures, consult with your LEA Solicitor to ensure that your procedures are being followed and that your process complies with UGG requirements.
Procurement manual • Developed by PDE • Used by all PDE Programs and Offices • Provide consistent and comprehensive guidance for grantees regarding procurement policies and procedures for all grant funds.
Additional Procurement Extension • In the Spring, LEAs received notification allowing the option of delaying the UGG procurement requirements for another year (December 31, 2017). • If this option was chosen, the LEA must have documentation they are electing to delay the UGG requirements. • Documentation must be made available to auditor • If not UGG procurement, LEAs must follow more restrictive pre-UGG requirements under A-87
Performance Goals • Every federal grant needs performance goals (UGG) that meet the intent of the grant. • LEAs must report on progress toward meeting the performance goals established and approved in their grants in the Fall of 2017. • Separate reporting tool
Performance Goal Report • Will be released in eGrants • Opens October 2nd • Due January 5th • Reporting period will be October to December. • LEAs must report progress toward meeting the goals established in each grant application using the data sources that are listed in the performance goals section. • Based on last approved grant application goals, yes/no response. • If performance goals are not met, must explain why and what will be done differently next year to help ensure goals are met.
PIMS Data Collection • Title I Staff and Student Participation Data for the 2016-17 School Year • Submitted through PIMS • Collection Window - October 2 through October 17, 2017 • Follow up, review and editing window - October 20 through November 1, 2017 • Correction Window - November 2 through November 15, 2017 • Accuracy Certification Statement (ACS) due date - December 6, 2017
PIMS Resources • Title I Staff and Student Participation collection appears on: • 2017-18 PIMS Collection Calendar available on PIMS website: www.education.pa.gov • Select “Teachers & Administrators” >> PIMS >> Data Reporting Dates>>Elementary/Secondary Data Collection Calendar 2017-18 • PIMS Manual: www.education.pa.gov • Select “Teachers & Administrators” >> PIMS >> PIMS Manuals (links for Vol. 1 or Vol. 2 as needed) • PIMS Help Desk: • 1-800-661-2423
Title III PD Survey • “Long-term and job-embedded PD” is one of the only statutorily established mandates within Title III. • This requirement pertains to any EL portions of a Title III award. It is not a required spending area for IMM portions of Title III.
Title III PD Survey • 16-17 professional development information is reported in October 2017 via the PIMS upload labeled “District Fact Template”. • This data is reported at the LEA level. This means that if an LEA is a member of a consortium they will need to obtain this data from the program consortium lead.
Supplement Not Supplant • Statutory language eliminated use of 3 presumptions of supplanting for Title I part A • An LEA used Title I funds to provide services that the LEA was required to make available under federal, state or local law. • An LEA used Title I funds to provide services that the LEA provided with nonfederal funds in the prior year. • An LEA used Title I funds to provide services for children participating in Title I program that the LEA provided with nonfederal funds to children not participating in Title I. • Only applies to Title I. • Title II, III, and IV supplanting rules stay the same.
Supplement Not Supplant • At its most basic, supplement not supplant means that Title I, Part A funds should “add to” (supplement) not “replace” (supplant) state and local funds. • This federal policy objective – to lessen the compliance burden and to encourage the use of Title I funds for comprehensive and innovative programs for Title I students – could provide important context for SEAs as they revise their SNS oversight processes. • The ESSA law does not require LEAs to use the same methodology for each school; instead it only requires that the LEA demonstrate its methodology does not deprive a Title I school of state/local funds because of its Title I status. • In short, the methodology should be Title I-neutral.
Supplement Not Supplant SIMPLE EXAMPLE FROM ED 2015 SWP GUIDANCE ON SNS (p.10) Assume: • 1 teacher per 22 students ($65,000/teacher) • 1 principal/school ($120,000) • 1 librarian/school ($65,000) • 2 guidance counselors/school ($65,000/guidance counselor) • $825/student for instructional materials and supplies (including technology) In a school of 450 students, the school would be expected to receive $2,051,250 in non-Federal resources based on the following calculation: To meet the [NCLB schoolwide program SNS test, known as the] supplemental funds test, an LEA would need to distribute non-Federal resources according to the assumptions above to all of its schools, regardless of whether a school receives Title I funds and operates a schoolwide program. This example does not, however, suggest that non-Federal funds must be used to support the activities in the table above; rather, Title I funds may be used to support any activity identified by the comprehensive needs assessment and articulated in the comprehensive schoolwide plan.
Comparability • General Rule - 1120A (c) • An LEA may receive Title I Part A funds only if it uses state and local funds to provide services in Title I schools that, taken as a whole, are at least comparable to services provided in non-Title I schools • If all are Title I schools, all must be “substantially comparable” • If only one building per grade span, exempt • Opens October 2nd • Assurances due November 15 • Late submission will receive points on Subgrantee Risk Assessment
Comparability (Teacher/Student Ratio) • Compare each Title I school to average of all non-Title I schools (Current Year 17-18) Or • Compare higher poverty Title I schools to lower poverty Title I schools • Excluded staff • Bus drivers • Consultants • Crossing guards • Maintenance staff • Security staff • Federally paid staff • Title I like staff
Comparability Submission • STEP 1 – Setting Up • Go to: pa.ESSAComparability.com • You may use any browser • Access is not granted immediately, a DFP Administrator must approve the account • Once the DFP Administrator approves the account the requester receives an email to create their password and login • STEP 2 – Group Comparisons • Districts complete the comparability wizard • At the last step they print, sign and upload the compliance document
Comparability Submission, cont. • STEP 3 – Compliance • Districts must complete Student to Staff Ratio method • if you have questions contact your regional coordinator or email@example.com. • Districts manage where they are in the process • Signed up for access • Completed the assurance wizard • LEAs signed and uploaded their assurance documents • This includes Charters and LEAs that are exempt
Maintenance Of Effort (MOE) • The combined fiscal effort per student or the aggregate expenditures of the LEA • from state and local funds • Collected from Annual Financial Report (AFR) • from preceding year must not be less than 90% of the second preceding year • LEAs are notified September/October • Letters sent to Superintendent/CEO
MOE Consequences • SEA must reduce amount of allocation in the exact proportion by which LEA fails to maintain effort below 90%. • Calculate using total expenditures and per pupil • The amount of the reduction would be the lesser penalty of the two calculations • Affects final 2017-18 allocation • (NEW) LEA is not subject to reductions for failing to maintain 90% effort for one year provided it has not failed to meet MOE for one or more of five immediately preceding fiscal years
MOE Waiver • USDE Secretary of Education may waive MOE if: • Exceptional or uncontrollable circumstances, such as a natural disaster; or • (NEW) a change in the organizational structure of the LEA; or • A precipitous decline in the financial resources of the LEA.
Reports – Due Dates – 2017-2018 • Comparability • Submitted electronically • http://pa.essacomparability.com/Login.aspx • Opens October 2 • November 15 • Neglected and Delinquent Counts • Submitted electronically via 3048 form • https://www.ndprogramspa.com/ • closes December 20
Fiscal Reports • Final Expenditure Reports • Submitted online via eGrants • Grant Applications • Consolidated Application • Click on Subprojects • Questions? Contact your Administrative Technician in DFP • Quarterly Reports • Submitted online via the PDE Web Portal/FAI System • PDE website • Submitted to the Labor, Education Comptroller’s Office * Failure to submit on time will stoppayments
Admin and Indirect Costs • Administrative costs – costs associated with administering a component of a grant program • Administrative costs for non-public equitable services (reasonable and necessary out of Title I non-public set-aside) • Indirect costs – general costs for running an agency that can be prorated across various funding sources • Electricity, rent for office space, administrative/clerical salaries when they supports various grants, etc.
Time and Effort • All employees paid with Federal funds must maintain documentation showing that their salaries are allocable to a federal program • Documentation must be based on records that accurately reflect the work performed
Time and Effort Documentation • Semi Annual Certifications • If an employee works on a single cost objective or a pro-rated fixed schedule: • After the fact • Account for the total activity • Signed by employee OR supervisor • Every six months (at least twice a year) • Personnel Activity Report • If an employee works on multiple cost objectives: • After the fact • Account for total activity • Signed by employee • Prepared at least monthly and coincide with one or more pay periods
School Improvement • Focus and Priority designations remain for 2017-18 • 2018-19 designations will be Targeted Support Intervention (TSI) and Comprehensive Support Intervention (CSI) • TSI and CSI criteria will be established according to the State plan
School Improvement/Intervention • Comprehensive Support is the most severe designation and is initially comprised of two groups of buildings: • (1) The lowest performing 5% of Title I schools across the Commonwealth. • (2) Any High School – Title I AND non-Title I – with a graduation rate below 67%.
School Improvement/Intervention • Targeted Support schools based on specific subgroups that are consistently underperforming • Title I AND non-Title I schools • oversight is primarily at the LEA-level • The four established sub-groups are: • economically disadvantaged, race, EL, and IEP. • Those buildings that are originally designated as “Targeted Support” but fail to achieve established benchmarks after three years • It is yet to be determined if non-Title buildings would move into a Comprehensive Support designation.
Eligible Title I Students - Targeted Assistance • Student eligibility: • Multiple; • Educationally related; and • Objective criteria developed by LEA. • NEW: If preschool-grade 2, criteria, including objective criteria, established by the LEA and supplemented by the school • Automatically Eligible: • If student in the previous 2 years received services in: • The Head Start program; • The literacy program; and • Migrant Children. • If the student is currently eligible under • Neglected or Delinquent; • or Homeless.
Targeted Assistance andSchoolwide • Title I, Part A funds can support a wide range of activities to help Title I students meet state academic standards. This includes: • Providing eligible students with a well-rounded education, • Instructional supports, • Non-instructional supports like behavior and mentoring supports, and social and emotional learning, and • Improving school quality.