Federal Program and Fiscal Compliance. LEA Administrative Responsibilities. An LEA shall comply with applicable statutes, regulations, and approved applications. An LEA shall use federal funds in accordance with those statutes, regulations, and applications. EDGAR § 76.700
The federal government allows three different ways to calculate Maintenance of Effort for NCLB. A LEA meets MOE on either their average daily attendance (ADA), enrollment, or expenditures based on the 90 percent rule)
The Secretary may waive the MOE requirement if it is determined that:
At the building level
An LEA must develop procedures for complying with the Comparability requirements. [Section 1120A(c)(3)] These procedures should be in writing and should, at a minimum, include the LEA’s timeline for demonstrating comparability, identification of the office responsible for making comparability calculations, the measure and process used to determine whether schools are comparable, and how and when the LEA makes adjustments in schools that are not comparable.
However, there is a limitation on the 100 percent transferability for Title II, Part A funds. ESEA Section 9501(b)(3)(B) requires an LEA to provide, at a minimum, equitable services to private schools teachers and students based on an amount of the LEA’s overall allocation under Title II, Part A.
Current year funds are FY2012 funds in FY2012 7/1/11-6/30/12 12 months
LEA 1st year carryover funds are FY2012 funds in FY2013
7/1/12-6/30/13 12 months
LEA 2nd year carryover funds are FY2012 funds in FY20147/1/13-9/30/13 3 months
Major Audit Finding of one LEA in FY2013
Major Federal Award Programs Audit
Time and effort reporting is required under the Federal Office of Management and Budget’s Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments
1. An employee who works a 100% from a SINGLE program (single cost objective) must report:
2. An employee whose work is split between more than one federal program (multiple cost objectives) must report:
Maintenance of Effort, Comparability, Supplement, Not Supplant, Carryover, Consolidating Funds in Schoolwide Programs, and GrantBack Requirements, Revised 2008