Welcome to the Orientation Session for New Federal Programs’ LEA Coordinators’

1. Welcome to the Orientation Session for New Federal Programs’ LEA Coordinators’ MEGA Conference Mobile, AL July 15, 2014 Get Ready to Jump In!

2. The Role of the LEA Federal Programs Coordinator… …So, you have taken on a new job….

3. …as a federal programs coordinator? Don’t panic…

5. Let’s Start… Introductions Overview of the Day

6. Let’s Throw Snowballs!

7. What Exactly Does A “Federal Programs” Coordinator Do? Provides oversight of federal funds and…. Leads the development of the district and school needs assessments Coordinates the development of plans to meet identified needs Facilitates the development of budgets to support the plans Ensures compliance with federal rules and regulations by monitoring and evaluating the implementation of plans and…. Other duties as “assigned…..”

8. This is how you get started each year…. Doesn’t sound too hard, does it?

9. How To Do A “Needs Assessment” Work in collaboration with school faculties and other LEA stakeholders to: Identify the needs of the system. Lead discussions on how funds can be effectively leveraged to meet the needs in the best possible way.

10. Planning Based on needs, develop goals that are… S - specific M - measurable A - attainable R - related to student achievement T - time bound Identify effective strategies to meet goals. Develop action steps that provide DETAILED information regarding planned uses of funds. Include realistic baseline data as part of performance measures (“From…to…”).

11. Chief School Financial Officer Provides oversight of federal funds by …. Collaborating with Federal Programs Coordinator on fund allocations. Coordinating the development of planning and budgets among all program coordinators. Ensuring all funds budgeted/spent as allowed by law also match information in the Electronic Grant Application (eGAP). Adhering to LEA Financial Assistance rules for requesting timely reimbursement of federal funds.

12. Applying for Funds eGAP Consolidated Application Title I, Parts A, C, D, Title II, Part A Title III, Part A Title VI, Part B-subpart 2 Competitive/Separate grants 21st Century Community Learning Centers Homeless Education

13. Other Sections Supported in eGAP Special Education Career Technical Education

14. The Superintendent… Is ultimately responsible for all system budgets. Makes the final decisions based on sound advice from - You! Clicks the “Assurances” Page in eGAP.

15. Key Resources for the Management of Federal Funds Title I Fiscal Issues Guidance Maintenance of Effort Comparability Supplement, Not Supplant Carryover Consolidating Funds in Schoolwide Programs http://www.ed.gov/programs/titleiparta/fiscalguid.doc SDE Web Site (www.alsde.edu; click on eGAP button; click on Document Library; scroll down) Report Manager Electronic System MEGA Sessions this week!

16. Maintenance of Effort (MOE) SDE reviews MOE annually LEAs not meeting requirements will be notified

17. Comparability LEAs review annually Prerequisite for receiving Title I funds LEAs should report to SDE : City Systems – in years ending with odd numbers County Systems – years ending with even numbers

18. Supplement not Supplant Always ask…. What does the state provide? What does the LEA provide? Are the activities/programs/staff a state or LEA requirement? How have programs/staff been funded in the past? What other fund sources can meet the need? Include information in eGAP grant relationships

19. Develop Partnerships in Practice Three kinds of partnerships: Cooperation – Effectively communicate and: • Reach out and actively respond • Assist and share • Follow through Coordination: Effectively cooperate, and coordinate work to: • Build intentional relationships • Plan efforts and create synergy • Produce and collectively implement plans Collaboration – Effectively cooperate, coordinate, and collaborate to: • Equally and jointly work together synergistically • Have intertwined layers of peer interaction • Have opportunities for continuous dialogue and deliberation • Provide information supported by facts, data, and SBR • Objectively inquire and critique ideas • Strategically plan and measure expected outcomesand progress

20. Developing the Budget Follow guidelines for money use! Expenditures must be supplemental. Expenditures must be “reasonable and necessary.” Are you getting the most bang for the buck? Remember…you have a CERTAIN timeframe in which to use certain funds (Tydings Amendment).

21. Administrative Costs • Title I Cap of 15% (includes Indirect Costs) • Title II Cap of 5% • Title III Cap of 2% • Title VI Cap of 5%

22. Federal Cost Principles Circular A-87 State, Local, and Indian Tribal Governments All costs must be: Reasonable Necessary Allocable Supplemental under state and local law Circular A-133 Single Audits EDGAR (Education Department General Administrative Regulations)

23. What does reasonable and necessary” mean? Expenditure is necessary for the performance or administration of the grant Purchaser follows sound business practices Object or service is to be obtained at a fair market price

24. Be Practical Practical tests of “reasonable-ness”: Is the expense targeted to valid programmatic/administrative considerations? Do I have the capacity to use what I am purchasing? If I were asked to defend this purchase, would I be comfortable? Practical tests of “necessary”: Do we really need this? Is this the minimum amount I need to spend to effectively meet the need?

25. Implementation Follow the guidelines and regulations for all programs, for example: Parental Involvement – Parents Right-to-Know, Home/School Compacts, etc. English Language Learners Migrant Homeless Neglected and Delinquent

26. Carryover Guidance Title I Carryover generally has limitations - like - percentage! Limited to a maximum of 15% for the current year, plus any funds transferred into Title I, Part A Other funds

27. Carryover Notes Schools do not “earn” carryover. Three options for the use of Title I carryover: Disburse carryover funds to schools using a set formula to allocate funds to schools with the highest concentration of poverty, thus providing a higher per-pupil amount to those schools, OR Provide additional funds to any of the activities supported by the reservations for district-wide initiatives already approved in eGAP on the Title I Set Aside Page, OR BOTH!

28. Consolidating Funds Schoolwide programs may consolidate funds for services, materials, and equipment Title I, Part A (Basic Programs) Title I, Part C (Migrant Education) Title I, Part D (Neglected and Delinquent Children) Title II, Part A (Teacher Training and Recruiting) Title III (English Language Instruction) Title VI (Rural Education) LEAs may request to “Consolidate Administration” funds…Check the box in eGAP!

29. Monitor and Evaluate Inspect what you expect Complete an Annual LEA Self-Assessment Comprehensive Compliance Assistance Visits FY15

30. Federal Programs 101

31. THE PYRAMID OFFEDERAL RULES Statutes Regulations and OMB Circulars Non-Regulatory Guidance Letters and Press Releases Issued by ED

32. STATUTES Statutes dictate: How funds are generated How funds must be allocated Who is eligible to be served How the program must be designed What uses of funds are permissible What types of reports or evaluations are required

33. Statutes ESEA- Elementary and Secondary Education Act NCLB- No Child Left Behind IDEA- Individuals with Disabilities Education Act

34. REGULATIONS Examples: EDGAR-Education Department General Administrative Regulations OMB –Office of Management and Budget - Circulars A-87 & A-133

35. PURPOSE OF NON-REGULATORY GUIDANCE Non-Regulatory Guidance is used by the Education Department to provide informal advice to grantees and sub-grantees regarding education requirements. Guidance does not carry the “force of law.”

36. Letters and PRESS RELEASES ISSUED by the U.S. Department of Education (USED) The USED issues “Dear Colleague” letters and press releases to notify states and districts about policy changes or clarifications regarding federal law.

37. Recent Communication from the U.S. Department of Education (USED) and other Agencies/Entities • ESEA Flexibility Waiver • Enrollment Policies • Dear Colleague Letter: “Supplement Not Supplant”

38. Community Eligibility Provision

39. What is the Community Eligibility Provision (CEP)? • Section 104a of the Healthy, Hunger-Free Kids Act • Provides an alternative to household applications for free and reduced price meals • Offers all students free meals in high poverty local educational agencies (LEAs) and schools.

40. Benefits of CEP • Increases access to school meals for children in high poverty areas • No household applications • Reduces the burden of verification • Compared to other special provisions: no base year

41. What is the eligibility threshold for participation in CEP? • Percentageof identified students must be at least 40% of enrollment • Eligibility is determined for an entire LEA, a group of schools within an LEA, or a single school within an LEA

42. Identified Students • Identified students - students certified for free meals without the use of a household application. • By definition this includes students directly certified through SNAP, TANF and Foster participation as well as Homeless, Head Start, Pre-K, Even Start, Migrant and Runaway students. • Identified Students are NOT the same as your Free & Reduced Eligibility numbers. • Identified Students are NOT those that were certified for free or reduced meals on a Household Eligibility Application

43. What Do You Need to Know? • If you choose to participate in CEP • Participation is required for the entire school year (August 31 cutoff) • All schools participating in CEP must serve breakfast and lunch to all students at no charge • All schools participating in CEP will not collect USDA Income Applications • Any financial loss must be reimbursed using non-federal funds

44. What is the Multiplier? • Analysis showed that on average for every 10 identified students there were 6 more students certified based on an income application • If you multiply the identified student percentage by 1.6 you are approximating the free and reduced price percentage • Based on USDA regulations, the multiplier can change each year and can fluctuate between 1.6 and 1.3

45. Multiplier/Reimbursements • The percentage of identified students as of April 1st of the prior year is multiplied by 1.6 to determine the percentage of meals reimbursed at the federal free rate. • The remaining percentage of meals not covered under the provision will be reimbursed at the federal paid rate. • Any meal costs in excess of the total federal reimbursement must be covered through non-federal sources.

46. CEP Claiming Percentages Example: Identified Student % = 50% Free claiming percentage = 80% (50% X 1.6) Paid claiming percentage = 20% (100% - 80%) Total meals = 1,000 Number of free meals = 800 (1,000 X 80%) Number of paid meals = 200 (1,000 – 800) **62.5% Identified Student Percentage (before the multiplier) = 100% Free Claiming Percentage

47. Things to Consider: • Financial status of each school in your district • Breakfast and Lunch participation • Anticipated level of Federal Reimbursement • Are Non-Federal resources available? • Is school meal application data used to distribute other sources of funding? (Title I, E-rate, Accountability, State, Local, etc.)

48. Determining Poverty Rates • Option 1- For LEAs using Option 1 to determine poverty rates (CEP and non-CEP schools ranking) • Direct certification in CEP schools • Free Reduced Paid Lunch (FRPL) application data in non-CEP schools • Option 2-For LEAs using Option 2 to determine poverty rates (CEP and non-CEP schools ranked solely on the basis of the percentage of students directly certified)

49. Within-district allocationCEP and Non-CEP schoolsOption 1 • When LEA has both CEP and Non-CEP schools USE • OPTION 1-Multiply the number of students identified by direct certification in a school by 1.6 multiplier and divide by the school enrollment to derive at the schools poverty percentage in the CEP school • LEAs continue to collect FRPL Applications in all NON-CEP schools

50. Within-district allocationCEP and Non-CEP schoolsOption 1 For CEP schools • Multiply the number of students identified through direct certification in a school by the 1.6 multiplier and…. • Divide by the enrollment in the school. • Using the multiplier for CEP schools: