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IDEA Part B ARRA Allocations and Funding Issues 2009 Special Education Directors Conference Presented by: Tim Imler

IDEA Part B ARRA Allocations and Funding Issues 2009 Special Education Directors Conference Presented by: Tim Imler. Presentation Outline. FY 10 IDEA Regular and ARRA Grant Awards Excess Cost and MOE Requirements Allowance for Federal Funds to reduce Local Expenditures (50% excess rule)

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IDEA Part B ARRA Allocations and Funding Issues 2009 Special Education Directors Conference Presented by: Tim Imler

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  1. IDEA Part B ARRA Allocations and Funding Issues2009 Special Education Directors ConferencePresented by:Tim Imler

  2. Presentation Outline • FY 10 IDEA Regular and ARRA Grant Awards • Excess Cost and MOE Requirements • Allowance for Federal Funds to reduce Local Expenditures (50% excess rule) • Payment Schedules & Expenditure Reports • ARRA Reporting • Helpful Internet Sites • Division Contact Information

  3. IDEA Part B Grant Awards FY 10 RegularARRA* Flow Through$503,378,371 $506,479,753 Preschool $17,369,463 $18,311,491 * ARRA funds must be obligated by September 30, 2011

  4. IDEA PART B – FEDERAL SPECIAL ED.

  5. 34 CFR 300 Assistance to States for the Education of Children with Disabilities 300.705(b) Permanent formula • Went into effect when the federal appropriation reached $4,924,672,200 • Base Year: established in the fiscal year preceding the first fiscal year the federal appropriation reached the $4.9 billion mark (FY 2000)

  6. 34 CFR 300 Assistance to States for the Education of Children with Disabilities 300.705(3) Increase in funds (Amount over the Base) • 85% distributed on the basis of the relative population of children 3-21 who are of the same age children with disabilities for whom the State ensures the availability of FAPE under Part B Act; • 15% distributed for the same population of children but who are living in poverty (Ill uses Dept of Human Services poverty count).

  7. IDEA Allocation Variables • BASE YEAR - PART B FLOW THROUGH -- Calculated from the Dec 1, 1998 Child Count -- Each district’s count multiplied by $518.66 -- Since FY 00 the special education child count has not been used to determine IDEA PART B FLOW THROUGH district allocations IDEA Part B Flow Through Base Year Amount is $145,798,830

  8. IDEA Allocation Variables • BASE YEAR - PART B PRESCHOOL --Calculated from the Dec 1, 1996 Child Count -- Each district’s count multiplied by $485.55 -- Since FY 98 the special education child count has not been used to determine IDEA PART B PRESCHOOL district allocations IDEA Part B Preschool Base Year Amount is$12,582,011

  9. IDEA Allocation Variables • PUBLIC ENROLLMENT (FALL HOUSING) -- All public students ages 3-21 -- Enrollment taken as of September 30 -- Due to ISBE by October 31 -- Subtracts Tuitioned In Students (non-resident pupils) -- Includes Tuitioned Out Students (resident district students)

  10. IDEA Allocation Variables • NON-PUBLIC ENROLLMENT -- Non-public Registration, Enrollment & Staff Report -- All non-public students ages 3-21 -- Voluntary -- Enrollment taken as of September 30 -- Must be a Not For Profit school -- Special Education Private Facilities are not counted -- REPORTED ENROLLMENT DOES NOT TAKE INTO ACCOUNT THE STUDENT’S RESIDENCE

  11. IDEA Allocation Variables • 2008-09 Enrollment files are closed • Public and Non-Public Enrollment questions should be directed to the Division of Data Analysis and Progress Reporting • Jim Sweeney – Public Fall Housing Report • Shafique Azam – Non-Public Enrollments www.isbe.net/research Phone 217-782-3950

  12. IDEA Allocation Variables • POVERTY -- Obtained from the Department of Human Services -- 3 Yr Running Average -- Included in the count are recipients of Food Stamps, Temporary Assistance for Needy Families (TANF), Kid Care and Medicaid

  13. FY 10 IDEA Flow Through Allocation Example FY 10 IDEA Part B Grant Award to LEAs = $448,161,695 Subtract LEA Grant Base $145,798,830 = $302,362,865 At 85% = $257,008,435 At 15% = $45,354,430 Entity Receiving Funds [District/Cooperative #1] December 1, 1998 child count 405 Base IDEA Flow Through allocation for 99-00 yr calculated at $518.66 times the child count $210,058 Public Enrollment (08-09 school year) 2,001 Non-Public Enrollment (08-09 school year) 27 Total Enrollment 2,028 Percentage of State enrollment .08846% Funding = % of state enrollment * $257,008,435 $227,360 Low Income Count (DHS 3yr Average) 464.66 Percentage of State Low Income Count .05848% Low Income funding = % of low income * $45,354,430 $26,524 Allotment (FY 10) = Base+Enrollment+Low Income $463,942

  14. ARRA IDEA Flow Through Allocation Example Combine FY 10 Regular and ARRA Grant Amount = $954,641,448 Subtract LEA Grant Base $145,798,830 = $808,842,618 At 85% = $687,516,225 At 15% = $121,326,393 Entity Receiving Funds [District/Cooperative #1] December 1, 1998 child count 405 Base IDEA Flow Through allocation for 99-00 yr calculated at $518.66 times the child count $210,058 Public Enrollment (08-09 school year) 2,001 Non-Public Enrollment (08-09 school year) 27 Total Enrollment 2,028 Percentage of State enrollment .08846% Funding = % of state enrollment * $687,516,225 $608,205 Low Income Count (DHS 3yr Average) 464.66 Percentage of State Low Income Count .05848% Low Income funding = % of low income * $121,326,393 $70,953 Base + Enrollment + Low Income $889,216 Subtract FY 10 Regular IDEA FT Allocation ($463,942) ARRA IDEA FT Allocation until Sept 30, 2011$425,274

  15. 34 CFR 300 Assistance to States for the Education of Children with Disabilities 300.16 Excess Cost Definition Excess costs means those costs that are in excess of the average annual per-student expenditure in an LEA during the preceding school year and that must be computed after deducting amounts received • Under Part B • Under Part A of title I of the ESEA • Under Parts A and B of title III of the ESEA and; • Any State or local funds expended for programs that would qualify for assistance under any of the parts of this section, but excluding any amounts for capital outlay or debt service. 300.202(a)(3) Supplement Not Supplant • Part B funds will be used to supplement State, Local and other Federal funds; not to supplant those funds If the LEA maintains (or exceeds) its level of local, or state and local expenditures for special education and related services from year to year, either in total or per capita, then the Part B funds are in fact, supplementing those local or state and local expenditures and the LEA has met its MOE and supplement/not supplant requirements.  In other words, if you’ve met the MOE requirements, you’ve also met the supplement/not supplant requirements.

  16. 34 CFR 300 Assistance to States for the Education of Children with Disabilities 300.203 Maintenance of Effort • Funds provided to an LEA under Part B must not be used to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds below the level of those expenditures for the preceding fiscal year. • To verify LEA eligibility, the amount of local funds budgeted for the education of children with disabilities in the current year is at least the same, either in total or per capita, as the amount spent for that purpose in the previous year. • LEA must have on file with the SEA information to demonstrate that the requirements of this section are met (Local Audit & MOE Worksheet).

  17. 34 CFR 300 Assistance to States for the Education of Children with Disabilities 300.204 Exceptions to Maintenance of Effort • An LEA may reduce the level of expenditures under Section 300.203 per the following conditions: -- Voluntary departure, retirement of special education personnel who are replaced by qualified, lower- salaried staff -- A decrease in the enrollment of children with disabilities -- Termination of the obligation of the agency for a child that was exceptionally costly as determined by the SEA -- Termination of costly expenditures for long-term purchases such as the acquisition of equipment or the construction of school facilities

  18. 34 CFR 300 Assistance to States for the Education of Children with Disabilities 300.205 Adjustments to local fiscal efforts in certain fiscal years For any fiscal year for which the allocation received by an LEA exceeds the amount the LEA received for the previous fiscal year, the LEA may reduce the level of expenditures otherwise required up to 50% of the amount of that excess. Use of Amounts To Carry Out ESEA Activities If an LEA exercises authority to use federal funds in that manner, the LEA must use an amount of local funds equal to the reduction in expenditures to carry out activities that could be supported with funds under ESEA regardless of whether the LEA is using funds under ESEA for those activities. This includes any activities allowed under Title I, Impact Aid, and other ESEA programs. An LEA could use these funds to pay for activities that are currently being funded with other state or local funds or for new activities.

  19. 50% Supplant Eligibility • Per 34 CFR 300.600(a) of IDEA, States are required to make "Determinations" on the performance of LEA and Early Intervention Service programs.  • LEA Determinations are made in one of four categories: (1) Meets Requirements, (2) Needs Assistance, (3) Needs Intervention and (4) Needs Substantial Intervention • An LEA cannot utilize the 50% supplant rule unless they are determined as “Meets Requirements”.

  20. 50% Supplant Calculation Example FY 2009 Allocation $400,000 FY 10 Regular & ARRA $900,000 Excess Amount $500,000 50% of Excess $250,000

  21. Implementing the 50% Rule An LEA choosing to take advantage of this flexibility is only required to maintain expenditures at the reduced MOE level in subsequent years, until that LEA increases the level of special education expenditures, using state or local funds, on its own. For example, if the LEA expended $1,500,000 of local and state funds on special education and related services in FY 2009 and lowered that amount by $250,000 (from the previous slide) in FY 2010, the LEA must expend at least $1,250,000 in state and local funds on special education and related services in FY 2010 to meet the MOE requirement. In FY 2010, the year the LEA took the MOE reduction, it also must ensure that $250,000 is expended on activities allowable under the ESEA. In FY 2010 and subsequent years, the LEA does not have to continue to separately “track” the $250,000 expended for ESEA activities.

  22. Payment Schedules & Interest • Monthly Payment Schedules must reflect anticipated expenditures to avoid potential excess cash. • Excess cash will be withheld from future scheduled payment(s). • Federal interest must be returned to the appropriate Federal Agency if > $100. (34 CFR 80.21)

  23. Expenditure Reports • Cooperatives that subgrant funds to their member districts does not constitute an expenditure. • Cooperatives must ensure member districts have expended funds that were subgranted and report the aggregated expenditures on their quarterly and final expenditure reports.

  24. ARRA Reporting Variables First Steps • All districts and cooperatives must have a Nine Digit Dun and Bradstreet (DUNS) number assigned http://fedgov.dnb.com/webform • All districts and cooperatives must register with the Central Contractor Registration site www.ccr.gov. All Federal vendors, suppliers, contractors and grant recipients are required to register in this database and are required to have a DUNS# issued to them.

  25. ARRA Reporting Variables • Timelines All expenditure and other ARRA data must be reported CUMULATIVE or year-to-date from the point that each LEA began expending ARRA funds through the end of each quarterly reporting period. Each subsequent quarterly report will also be cumulative. In other words, the report due January 2010, will include the data reported through September 2009 and be updated to include data that accumulated through December 2009. ISBE will aggregate all ARRA expenditures across fiscal years for each LEA.

  26. ARRA Reporting Variables • Jobs Created and Retained A job created is a new position created and filled; a job retained is an existing position that would not have been continued were it not for ARRA funding. FTE – Full Time Equivalency Enter the FTE for each position. This is calculated as total hours worked divided by the number of hours in a full-time schedule. The figure should be reflected to two decimal places. The number reported should represent a reasonable average of FTE’s created and retained for the quarter. Such an estimate would ideally be done by taking FTE’s for each pay period in the quarter and averaging them. It could also be done at a single point in time, as long as care is taken that the single point is representative of the quarter for the position.

  27. ARRA Reporting Variables • Awards made to a vendor greater than $25,000 A vendor is defined as a dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of the program. A vendor: (1) Provides the goods and services within normal business operations; (2) Provides similar goods or services to many different purchasers; (3) Operates in a competitive environment; (4) Provides goods or services that are ancillary to the operation of the Federal program; and (5) Is not subject to compliance requirements of the Federal program. If a sub-recipient (i.e. district or cooperative) awards ARRA funds greater than $25,000 to a vendor for services required needed to carry out the project or program, the sub-recipient must report the identity of the vendor by reporting the DUNS number, if available, or otherwise the name and zip code of the vendor’s headquarters.

  28. Helpful Internet Sites ARRA Recovery Site : http://www.recovery.gov/ ARRA Department of Education Guidance http://www.ed.gov/policy/gen/leg/recovery/index.html ARRA-IDEA Part B Department of Education Guidance http://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.pdf State or Federal Project and Payment Information: http://206.166.105.128/FRISInquiry/ IDEA 2004 http://idea.ed.gov/explore/home USDE – Office of Special Education http://www.ed.gov/about/offices/list/osers/osep/index.html

  29. Division of Funding and Disbursement Services Phone: 217/782-5256 Fax: 217/782-3910 IDEA Flow Through & Preschool Grants, Expenditure Reports and Payments Sharon Conrath sconrath@isbe.net Division of Special Education Services Phone: 217/782-5589 Fax: 217/782-0372 IDEA Flow Through and Preschool Program Consultants Bonnie Douglas Penny Kelly bdouglas@isbe.net gkelly@isbe.net

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