Managing Fiscal Components of Title I, Part A Coordinators’ Academy 2019
Disclaimer This academy was planned under a grant from the U.S. Department of Education (USED). However, the content does not necessarily represent the policy of the USED, and you should not assume endorsement by the federal government.
Scenarios In this presentation, we will share several scenarios related to managing the fiscal components of Title I, Part A.
Title I Funding for 2019-2020 Preliminary Allocations U. S. Department of Education (USED) preliminary allocation to Virginia is $279,184,039. • 4.5 percent increase compared to FFY 2018 ($267,149,467) • 2017 U.S. census estimates • State per-pupil expenditure data from school year 2016-2017
Preliminary Allocations • NOTE: While the state’s overall preliminary Title I allocation increased by 4.5 percent, this does not mean that each school division will receive an increase in Title I funds. • Preliminary Title I, Part A, allocations from USED do not reflect the state set-asides, changes in final census data, and other adjustments required by law. • The final allocation for each school division is likely to differ from the preliminary allocation.
Scenario: Determining Allocations In February, you receive a Supt’s Email entitled, “Preliminary Federal Fiscal Year (FFY) 2019 Title I Allocations.” What should you do with this information?
Potential Increase in Allocation Plan conservatively. Level funding in the application using the previous year’s allocation is recommended, but you may develop an internal spreadsheet to demonstrate how the additional funds will be distributed. Under ESSA, the state will reserve a 1% set aside for state level administration of the grant and a 7% set aside for school improvement. If your division received an allocation increase, your allocation is subject to both of these reductions.
Potential Decrease in Allocation Level funding in the application using the previous year’s allocation is recommended. In reserving funds under section 1003(a) from FY 2018 and subsequent years’ allocations, an SEA may not reduce an LEA’s Title I allocation below the prior year’s amount. (ESEA section 1003(h)) Your allocation is only subject to the 1% reduction.
Scenario: Determining School Eligibility In April, your school nutrition director provides you with the Community Eligibility Program (CEP) and/or free/reduced lunch counts. What should you do with this information?
The Community Eligibility Program To be eligible, a school, group of schools, or division must have at least 40 percent of its students meet the definition below: Identified Studentsare defined as students approved as eligible for free meals through means other than individual household applications. Students who are directly certified for free meals on the basis of their participation in Supplemental Nutrition Assistance Program (SNAP) or Temporary Assistance for Needy Families (TANF) or income eligible Medicaid recipients.
The Community Eligibility Program Under CEP, identified students are defined as students certified for free meals through means other than individual household applications including: 1) students who are directly certified for free meals on the basis of their participation in the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF); and 2) homeless, runaways, migrant youth, Head Start, Even Start and foster children approved by means other than a meal application.
The Multiplier • Used to account for low-income families not reflected/ captured in identified student count • Determines percent of federal reimbursement for meals • Set by USDA at 1.6 • Multiplier remains constant for schools and divisions throughout the four year CEP cycle
Both CEP and Non-CEP Option 1 Option 2 Use CEP data for all schools and apply the multiplier to all schools or no schools. Use CEP data for the CEP schools and apply the multiplier to those schools in the application. Use free/reduced lunch data for non-CEP schools.
All CEP Option 1 Option 2 Use CEP data for all schools and apply the multiplier to none of the schools in the application. Use CEP data for all of the schools and apply the multiplier to all of the schools in the application.
No CEP Option 3 Option 1 Option 2 Use CEP data for all of the schools and apply the multiplier to none of the schools in the application. Use CEP data for all of the schools and apply the multiplier to all of the schools in the application. Use free/reduced lunch data for all of the schools.
Rank Order • Rank order all schools in the division by poverty. • Serve, in rank order of poverty, schools above 75 percent poverty, including middle and high schools. NON-REGULATORY GUIDANCE: Local Educational Agency Identification and Selection of School Attendance Areas AND SCHOOLS and Allocation of Title I Funds to Those Areas AND Schools
Determining School Eligibility AFTERall schools above 75 percent poverty have been served, the division may: • Serve high schools with a poverty as low as 50 percent and pull those schools out of rank order; • Continue with division-wide ranking; or • Rank remaining schools by grade span. NON-REGULATORY GUIDANCE: Local Educational Agency Identification and Selection of School Attendance Areas AND SCHOOLS and Allocation of Title I Funds to Those Areas AND Schools
Ranking Schools by Grade Span Division will use either the divisionwide poverty average or grade-span average for selected grade span(s): In rank order of poverty, schools are eligible if they are above the divisionwide poverty average or the grade-span average until all schools at or above the selected poverty average are served or no funds remain.
Ranking Schools by Grade Span Division discretion to select schools based on: • 35 percent rule • Grandfather clause • Skipped school provision
Scenario: Setting Aside Funds You’re trying to decide how to leverage set aside funds in your division. What factors should you consider?
Optional Set Asides Before allocating funds to schools, the division may reserve funds “off the top” for: • School improvement • only for teacher incentives in schools identified as Comprehensive Support and Improvement or Targeted Support and Improvement that have been approved by the Office of School Quality • Division level program administration • Title I early childhood programs • Foster care
Required Set Asides Before allocating funds to schools, the division mustreserve funds “off the top” for: • Parental and family engagement • For divisions with allocations greater than $500,000 • Private school services • For divisions with participating private schools
Required Set Asides Continued Before allocating funds to schools, the division mustreserve funds “off the top” for: • Homeless • For divisions with one or more students identified in their annual count as homeless • Neglected • For divisions with one or more students identified as neglected in their October count whose facilities wish to participate
Scenario: Allowable Costs A principal in your division would like to fund a creative parent and family engagement activity that seems like entertainment. What do you need to consider before approving this activity and submitting it for reimbursement?
USED Guidelines for Federal Awards §200.438 Entertainment costs: Costs of entertainment, including amusement, diversion, and social activities and any associated costs are unallowable, except where specific costs that might otherwise be considered entertainment have a programmatic purpose and are authorized either in the approved budget for the federal award or with prior written approval of the federal awarding agency.
Allowable Cost Considerations • Is the activity tied to one of the Standards of Learning? • Is a need for this activity demonstrated in the needs assessment of the school’s schoolwide plan, if applicable? • Does the activity inform parents about strategies they can use at home to help their children academically? • Are the costs associated with the activity both reasonable and necessary?
Carryover Provisions • Total period of grant award is 27 months • 85% of funds must be obligated within the first 15 months • Up to 15% can be carried over for the remaining 12 months of the grant award period
Certification of Obligation Divisions that have not completed OMEGA reimbursement transactions for at least 85 percent of FFY 2018 funds by September 30, 2019, must complete the Certification of Obligation. • Superintendent’s Email (September) • Certification of Obligation form must be signed by the division superintendent and returned to Shyla Vesitis by the deadline (mid-November)
Scenario: Obligation of Funds Your finance office informs you on September 1, 2019 that your division may not be able to encumber 85% of it’s 2018 funds prior to the deadline of September 30, 2019. What are your options?
Obligation of Funds Option 1 Option 2 If your division has not requested a carryover waiver in the last three years, apply for a carryover waiver. Try to obligate down to 15% before September 30, 2019.
Obligation of Funds If the obligation is for: Personal services by an employee of the State or subgrantee The obligation is made: When the services are performed
Obligation of Funds If the obligation is for: Personal services by a contractor who is not an employee of the state or subgrantee The obligation is made: On the date on which the state or subgrantee makes a binding written commitment to obtain services
Obligation of Funds If the obligation is for: Performance of work other than personal services The obligation is made: On the date on which the State or subgrantee makes a binding written commitment to obtain the work
Obligation of Funds If the obligation is for: Public utility services The obligation is made: When the State or subgrantee receives the services
Obligation of Funds If the obligation is for: Travel The obligation is made: When the travel is taken
Carryover Waiver Guidelines • School divisions may apply for a waiver to exceed the 15 percent carryover limitation once every three yearsif: • The state agency determines that the request is reasonable and necessary; or • Supplemental appropriations become available. • School divisions that receive less than $50,000 are excluded from the carryover limitation.
Carryover Timeline for FFY 2017 Funds Total Grant Award Period: July 1, 2017 to September 30, 2019 Deadline to Obligate 85% of Award: September 30, 2018 Deadline to obligate 100% of Award: September 30, 2019 Deadline to Request Reimbursement for ALL Funds: November 15, 2019
Carryover Timeline for FFY 2018 Funds Total Grant Award Period: July 1, 2018 to September 30, 2020 Deadline to Obligate 85% of Award: September 30, 2019 Deadline to obligate 100% of Award: September 30, 2020 Deadline to Request Reimbursement for ALL Funds: November 15, 2020
Carryover Timeline for FFY 2019 Funds Total Grant Award Period: July 1, 2019 to September 30, 2021 Deadline to Obligate 85% of Award: September 30, 2020 Deadline to obligate 100% of Award: September 30, 2021 Deadline to Request Reimbursement for ALL Funds: November 15, 2021
Object Code 1000 • PERSONAL SERVICES - Includes all compensation for the direct labor of persons in the employment of the local government. Salaries and wages paid to employees for full‐ and part‐time work, including overtime, shift differential, and similar compensation. Includes payments for time not worked, including sick leave, vacation, holidays, jury duty, military leave, and other paid absences that are earned during the reporting period. • For the purposes of this report, the term “salaries” means all compensation including base wage. This also includes amounts paid through salary reduction plans, such as tax‐sheltered annuities and flexible benefit plans.
Object Code 2000 EMPLOYEE BENEFITS - Job related benefits provided to employees as part of their total compensation. Fringe benefits include the employer’s portion of FICA, pensions, insurance (life, health, disability income, etc.) and employee allowances. Consistency in application should be maintained at all times: • Allocation by percentage of payroll dollars • Allocation by Head Count • Direct to Program or Activity
Object Code 3000 PURCHASED/CONTRACTUAL SERVICES - Services acquired from outside sources (i.e., private vendors, public authorities, or other governmental entities). Purchase of the service is on a fee basis or fixed time contract basis. Allowable payments would be to individual or firms that are independent contractors and not employees of the grantee or sub‐grantee organization.
Object Code 3000 Food Purchases – Prepared meals, working meals, and/or catered services purchased through a vendor are included in this object code. Reimbursement is capped at the per diem rate for the meal listed according to the state travel regulations. Examples for this object code include meals provided during day‐long professional development sessions, or meals provided to support attendance at family engagement activities. Food purchased from catering services and restaurants such as Pizza Hut, Panera Bread, and Subway is included in this object code.
Object Code 3000 Transportation Services Public Carriers – Payments to public carriers for transportation of pupils on vehicles that are used by the public. Include payments for pupils transported in intra‐city transit buses, taxicabs, airplanes, and intercity/interstate passenger buses.