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IDEA 2004 Program Requirements and Funding Eligibility

IDEA 2004 Program Requirements and Funding Eligibility. Office of Special Programs April 13, 2011. What do you know?. IDEA Entitlement Funding. Section 611(school age) and 619 (preschool)

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IDEA 2004 Program Requirements and Funding Eligibility

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  1. IDEA 2004 Program Requirements and Funding Eligibility Office of Special Programs April 13, 2011

  2. What do you know?

  3. IDEA Entitlement Funding Section 611(school age) and 619 (preschool) To provide students with disabilities aged 3-21, including students who have been suspended or expelled from school, a free appropriate public education, which includes special education and related services, to meet their unique educational needs and to meet other requirements under the act. FAPE must include special education and related services designed to meet a student’s unique needs and prepare him or her for further education, employment, and independent living.

  4. Section 611, Part B Section 619, Preschool Students 3-21 Students 3-5 School Age Preschool CFDA: 84.027 CFDA: 84.127 PROGRAM OBJECTIVESIDEA 2004 Special Education • children with disabilities have available to them a free appropriate education (FAPE) • protect rights • assist agencies, districts with the education of students with disabilities (SWDs) • assess and ensure effectiveness of efforts to educate children with disabilities

  5. LOGISTICS – Flow Through • October – Public School Enrollment Count and Low SES Count completed • Previous May – Private School Enrollment Count Requested • March/April – Allocations received from OSEP • March 31 - Out-of-state DHHR student count completed • March/April - State and federal allocations released • Instructions for completion of on-line plan and funding amounts for the upcoming year are distributed to LEAs

  6. LOGISTICS – Flow Through • April-LEAs complete District Self-Assessment as part of needs assessment for strategic plans/LEA application • April/May – LEA Budget Completed include LEA state/local expenditures for MOE • May 1 – Online plan rolls over to next fiscal year • June1-- LEA online plans due to OSP for review. • June-July - Submitted applications are reviewed & upon approval grants are issued. • NOTE: SEA receives federal awards in July and October. LEA may obligate up to 25% of total award prior to October 1.

  7. LEA Entitlement - “Flow Through” Entitlement Amount = Base + Population + Poverty • Base Allocation (students with disabilities 1998/1996) • Population/Poverty Amount = Entitlement – Base • Population Amount = 85% [Entitlement – Base] • (allocated to LEAs based on most recent public and private school enrollment – all students ) • Poverty Amount =15% [Entitlement – Base] (allocated to LEAs based on most recent count of “low SES” students eligible for free/reduced lunch)

  8. Example Total Entitlement = $61,649,797 Base $22,891, 709 Population 85% [$61,649,797 - $22,891,709 ] = $32,944.375 Poverty 15% [$61,649,797 - $22,891,709 ] = $5,813,713

  9. FUNDING ALLOCATIONS

  10. USE OF FUNDS • Allowable Cost • RTI and Coordinated Early Intervening Services • High cost fund • Excess Cost • Maintenance of Effort • Private Schools

  11. IDEA Part B and OMB Circular A-87OSEP Clarifications Allowable Costs IDEA Part B and OMB Circular A-87 IDEA Part B and OMB Circular A-87

  12. U.S. Dept. of Ed Requirements • EDGAR – Education Department General Administrative Regulations • Gives authority to OMB circulars • General Education Provisions Act - GEPA • Office of Management and Budget (OMB) • OMB Circular A-133 – Single Audit • Compliance Supplement Part 4 • OMB Circular A-87

  13. Allowable Cost § 300.202 Use of amounts. • Must be expended in accordance with the applicable provisions of this part. • Must be used only to pay the excess costs of providing special education and related services to children with disabilities. • Must be used to supplement State, local, and other Federal funds and not to supplant those funds.

  14. IDEA Permissive Use of Funds • §300.208 • (1) Services and aids that also benefit • nondisabled children. • (2) Coordinated Early intervening services • High cost special education/ related services. • (b) Administrative case management. • Purchase appropriate technology for recordkeeping, data collection, and related case management activities

  15. Basic Guidelines of Cost Principles • All costs must be: • Necessary • Reasonable • Allocable

  16. Helpful Questions to Ask to Determine if a Cost is Allowable • Is the proposed cost consistent with federal cost principles? • Is the proposed cost allowable under the relevant program? • Is the proposed cost consistent with an approved program plan and budget? • Is the proposed cost consistent with program specific fiscal rules? • Is the proposed cost consistent with EDGAR?

  17. OMB Circular A-87Allowable Costs • Establishes principles and standards for determining allowable costs • You have to read A-87 in conjunction with the IDEA to understand how it applies • To the degree there is any conflict, IDEA requirements take precedence

  18. Do I need to spend these funds to meet the purposes and needs of the program? • Costs must be necessary and reasonable for proper and efficient performance • Costs are necessary and reasonable if, in nature and amount, they do 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

  19. Basic Guidelines: Reasonable • Practical aspects of “reasonable” • Is the expense targeted to a valid programmatic or administrative consideration? • Do I have the capacity to use what I am purchasing? • Did I pay a fair rate? Can I prove it? • Would I be comfortable defending this purchase?

  20. Basic Guidelines: Allocable • Practical aspects of “allocable” • Can I prove the program benefited? • Can I prove other programs are not benefiting? • Ensuring only authorized use • Incidental benefit

  21. Basic Guidelines: Allocable • Can only charge in proportion to the value received by the program • Example: LEA purchases a computer to use 50% in federal program and 50% in a state program • Can only charge half of the cost to the federal program

  22. OMB Circular A-87Allowable Costs • Appendix B of A-87 lists 43 selected items of cost – examples • Alcoholic beverages are unallowable • Conference/meeting costs are allowable if primary purpose is dissemination of technical information (meals, transportation, rental of facilities, speakers’ fees, etc.) but see Appendix B, item 14 regarding Entertainment Costs • Costs of professional organizations and subscriptions are allowable • Memberships in civic, community or social organizations are allowable with the approval of the Federal awarding agency • Costs of membership in organizations whose primary purpose is lobbying are unallowable

  23. Selected Items of Cost(examples) • Advertising & Public Relations Costs • Generally not allowable, except as specified in OMB Circular A-87, Attachment B • Entertainment • Amusement, field trip or social activities (tickets to shows or sporting events, meals, lodging, etc.) are generally not allowable

  24. Selected Items of Cost(examples) • Salaries and Wages • Allowable if proper time distribution records • Travel Costs • Transportation, lodging, subsistence, and related items, when traveling on business are allowable with certain restrictions • Training • Training for employee development is allowable; for IDEA, professional development for special education personnel or for general education teachers regarding how to teach students with disabilities

  25. NCRTI/OSEP Clarification • IDEA Part B specific examples of use of funds: • FAPE • Special education teachers and administrators • Related services providers • Materials and supplies for students with disabilities • Professional development for special education personnel or to assist general education personnel in teaching special education students

  26. NCRTI/OSEP Clarification • Specialized equipment or devices to assist children with disabilities • Two exceptions: • Title I/IDEA schoolwide programs • Coordinated early intervening services for students without disabilities needing academic or behavioral support to succeed in general education

  27. Coordinated Early Intervening Services Purpose from Congressional Committee Report: …and early intervening services to reduce the need to label children as disabled in order to address the learning and behavioral needs of such children Building the Legacy 2004

  28. CEIS With an approved plan, the LEA may (or in some cases is required to) use up to 15% of IDEA funds for: • Professional development • Providing educational and behavioral evaluations, services, and supports, including scientifically-based literacy instruction • Providing educational and behavioral evaluations, services, and supports including scientifically based literacy instruction Building the Legacy 2004

  29. A Conceptual Framework for RTI High Need Increasingly Intensive Instructional Interventions Level of need for student to be successful in core instruction Services for Students with IEPs Core Instruction Low Need Students may receive services in all areas of the pyramid at any one point in time

  30. RTI and CEIS • CEIS (and IDEA) funds may notbe used for Tier 1 • CEIS (and IDEA) funds may not be used for universal screening • CEIS funds may be used for Tier 2 and Tier 3, but special education students should not be included • CEIS may be used for RTI training

  31. CEIS and Supplement Not Supplant • CEIS funds may be used to supplement but not to supplant services provided with funds available under the ESEA (e.g. after school tutoring, school improvement activities) • Violations include: • Funding services otherwise required by state, federal or local law • Funding services paid in prior year, e.g. previously paid by Title I • This may be rebutted if the services would not have been funded from other sources if CEIS were not available

  32. Progress Monitoring • Progress monitoring is a scientifically based practice that is used to assess students’ academic performance and evaluate the effectiveness of instruction and instructional interventions. • Generally, Title I, Title III, and CEIS funds may be used to fund progress monitoring (but not universal screening) if the progress monitoring is used to determine the response to an intervention that is supportable with Title I, Title III, or CEIS funds.

  33. RTI and IDEA Funding (not CEIS) • A special education teacher fully funded by IDEA (non-CEIS) funds who is providing special education to students with disabilities may include one or more “at-risk” students in this group. • E.g. – if a replacement reading program, such as Wilson, is being taught to special education students in a pull-out period, Tier 3 RTI students could participate for a limited period of time, provided this arrangement does not exceed the Policy 2419 per period caseload and does not displace any special education student from IEP services

  34. RTI and IDEA Funding (not CEIS) • The special education teacher or related services personnel fully-funded by IDEA cannot be scheduled to provide special education services part of the day and other duties (e.g., interventions for students without disabilities) during another part of the day. • IDEA funds may not be used for universal screening (conducted for all students) for RTI

  35. High Cost/High Acuity Funds

  36. High Cost Fund For the purpose of assisting districts in addressing the needs of high need students with disabilities, each State has the option to reserve for each fiscal year 10% of the amount it reserves for State-level activities. • Each State must: • develop and make available a high cost plan • consult with districts • develop a funding mechanism and schedule for fund distribution WV includes state high acuity funds in this plan Division of Instructional & Student Services

  37. High Cost Fund • Stakeholder involvement • Definition: Individual application for an eligible SWD who: • is 3-21 years of age • has a current IEP • lives within the LEA requesting funds or receives special education and related services within the LEA • cost is equal to or greater than $45,000 per year

  38. IDEA 2004 Excess Cost

  39. Excess Cost The excess cost requirement prevents an LEA from using funds provided under Part B of the Act to pay for all of the costs directly attributable to the education of a child with a disability, subject to paragraph (b)(1)(ii) of this section. • Excess costs are those costs for the education of an elementary school or secondary school student with a disability that are in excess of the average annual per student expenditure in an LEA during the preceding school year for an elementary or secondary student.

  40. Excess Cost – Elementary vs. Secondary • Section 602(8) of the Act and §300.16 require the LEA to compute the minimum average amount separately for children with disabilities in its elementary schools and for children with disabilities in secondary schools. The formula for these calculations are provided in 34 CFR, Appendix A to Part 300. • The form and calculations to meet this requirement are in Section VIII of the LEAs on-line strategic plan.

  41. Excess Cost – Elementary vs. Secondary Data on the form is primarily self-filling and calculating and is pulled from the LEA’s general ledger information stored in WVEIS. To calculate the amounts required for elementary vs. secondary, as required by law, total expenditures for the provision of special education services are pro-rated and entered in the form from a table that was developed in conjunction with the Office of Technology and the Office of School Finance.

  42. Excess Cost – Elementary vs. Secondary This table was established based upon the following premises: • Sums the salary expense of teachers by location within the general ledger. • Pre-kindergarten through grade six was defined as elementary • Grades seven through 12 were defined as secondary. • Using the above definitions to segregate total salary expense, a prorated percentage to total expenses was assigned to each elementary and secondary. • The total expense pulled from WVEIS in each of the fund categories was then multiplied by the resulting factor which provides the amounts to be used in each of the calculations for elementary or secondary results. • The child counts used in the calculations were divided based on the assumption of ages 3-12 as elementary and 13-21 as secondary.

  43. IDEA 2004 Maintenance of Effort

  44. IDEA’s MOE Requirements • SEA – IDEA prohibits a state from reducing state financial support for special education below the amount of that support for the preceding fiscal year. (34 CFR §300.163) • LEAs – IDEA requires that LEAs must budget the same amount of local funding for special education as it expended in the previous fiscal year. (34 CFR §300.203)

  45. MOE – Two Comparisons • Eligibility • Determining whether an LEA is “eligible” to receive the IDEA Part B Funds • Budget to Actual Expenditure Comparison • Estimate based on most recent year reviewed in June 1 submission • Reviewed and revised after year is closed • Compliance • Determine if the LEA met the requirements of IDEA’s maintenance of effort • Actual to Actual Expenditure Comparison

  46. SO IMPORTANT TO UNDERSTAND • This is the eligibility test based on expenditures pulled from the WVEIS financial management system from the most recent year compared to the LEA-provided budget amount. • COMPLIANCE is met through actual to actual expenditure comparison. If compliance is not met, the LEA must pay back the difference in non-federal funds. REPAYMENT

  47. Part B LEA MOE Requirement: Supplement/Not Supplant 47 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 IDEA does not require a “particular cost” test – This is contrary to Title I and confusing to many WV LEAs

  48. Four Tests to Meet MOE • An LEA needs to only meet ONE of the following comparison tests: • Local & State expenditures in total for SWD • Local Only expenditures for SWD • The per student capita amount of Local & State expenditures for SWD • The per student capita amount of Local Only expenditures for SWD

  49. Medicaid and MOE § 300.154 .(g)(2) Methods of ensuring services If a public agency spends reimbursements from Federal funds (e.g., Medicaid) for services under this part, those funds will not be considered ‘‘State or local’’ funds for purposes of the maintenance of effort provisions Medicaid revenues and expenditures must be specifically coded in WVEIS accounting

  50. Other Post Employment Benefits – OPEB • Beginning with FY10, LEAs are required to account for future post employment benefits for employees • Expenditures are recorded; should be attributed to 2xxxx as applicable • When OPEB expenditures are recorded, they are pulled when WVDE calculates MOE • Procedures for recording expenditures must be consistent year to year to avoid complications with MOE calculation

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