Federal Fiscal Compliance 101

1. Federal Fiscal Compliance 101 Texas Education Agency (TEA)

2. Major Federal Fiscal Compliance and Reporting Requirements • CEIS and MOE Voluntary Reduction Reporting • FFATA Reporting • Indirect Cost Rates • Title I, Part A Comparability • NCLB LEA MOE • IDEA-B LEA MOE • Special Education SSA Configuration Changes • Corrective Actions

3. Reports, Notifications and Submissions • GFFC Reports and Data Collections • TEAL/TEASE Application • TEA Federal Compliance Determinations • LEA responses to Federal Compliance Determinations • Ensure appropriate LEA staff have access!

4. Reports, Notifications and Submissions Grants and Federal Program Compliance (GAFPC) listerv Sign up for GAFPC at: http://miller.tea.state.tx.us/list/ Ensure appropriate LEA staff are subscribed to GAFPC!

5. CEIS and MOE Voluntary Reduction Reporting • Requirement • Report on applicable CEIS Set-Aside amounts, students served, and MOE Voluntary Reduction taken by LEA’s.

6. CEIS and MOE Voluntary Reduction Reporting • Common Errors to Avoid • CEIS Set-Aside amounts > 15% • MOE Voluntary Reduction > 50% • Combined, the CEIS Set-Aside and MOE Voluntary Reduction may not exceed lower of the two

7. CEIS and MOE Voluntary Reduction Reporting • Common Errors to Avoid (Continued) • CEIS Set-Aside yet no CEIS Students Served • CEIS Students Served yet no CEIS Set-Aside • Special Education Consolidated Grant Application is not amended for CEIS Set-Aside changes

8. FFATA Reporting • Requirement • Report on applicable federal subawards(i.e. TEA NOGAs to LEAs) • Note: • LEA data is tied to the LEA’s DUNS • LEA’s must update SAM annually

9. FFATA Reporting • Common Errors to Avoid • Incorrect 9-digit zip code for the physical address in SAM • Outdated address or business contact information in AskTED • Incorrect DUNS on file at TEA

10. Indirect Cost Rates • Request Rate Via Annual Submission • ISDs – Exhibit J-2 of AFR (electronic submission) • Open-enrollment Charter – eGrant Special Collection SC5010 • ESCs/Other Governmental Agencies – Indirect Cost Rate Proposal submitted directly to TEA

11. Application of Indirect Cost Rates • LEA may apply its Indirect Cost Rate if allowable by the grant • The indirect cost rate cap may be less than the LEA’s approved Indirect Cost Rate • Administrative caps may limit the amount of indirect costs recovered

12. Application of Indirect Cost Rates • Common Errors to Avoid • The indirect cost recovery is calculated when the LEA submits the final expenditure report • If the LEA has requested reimbursement in excess of the allowable indirect costs on its periodic expenditure reports, a refund due will be generated

13. Title I, Part A Comparability • Requirement • LEAs required to annually submit Comparability Computation Form and Comparability Assurance Document using GFFC Reports and Data Collections • Submissions due November 12th

14. Title I, Part A Comparability • Common Errors to Avoid • Misclassification of Campus (either Title/Skipped or Non-Title) • Not reporting EE and/or PK campuses in Elementary Grade-span group • Not demonstrating compliance with one testforall grade-span groupings tested

15. Title I, Part A Comparability • Common Errors to Avoid (Continued) • Subdividing Grade-span into High/Low enrollment and not meeting Significant Difference of Enrollment criteria • Uploading Comparability Computation Form as a PDF rather than Excel as required • Uploading Comparability Assurance Document without Superintendent Signature as required

16. NCLB LEA MOE • Requirement • Determine LEA compliance with NCLB Maintenance of Effort (MOE) • Applies to LEAs receiving federal funds under covered NCLB (ESEA) programs

17. NCLB LEA MOE • Common Misconceptions • MYTH: Similar to IDEA-B LEA MOE, there are federal statutory exceptions to NCLB LEA MOE. • TRUTH: There are no federal statutory exceptions. • MYTH: TEA has authority to waive penalty for noncompliance.TRUTH: Only USDE has authority to waive penalty.

18. NCLB LEA MOE • Common Misconceptions • MYTH: Receipt of USDE waiver constitutes compliance with requirement. • TRUTH: Final Determinations DO NOT change; only the penalty is waived. • MYTH: Penalty only impacts only Title I, Part A. • TRUTH: Noncompliance impacts all covered programs.

19. IDEA-B LEA Eligibility • Requirement • LEA must certify it has budgeted in the current year an amount greater than or equal to the amount required to meet the MOE requirement. • Applies to LEAs receiving federal funds under an IDEA-B formula grant

20. Special Education Consolidated Grant Application • Schedule BS6006 - Fiscal Compliance Requirements • Part 1: LEA MOE Eligibility • Part 2: CEIS Set-Aside and MOE Voluntary Reduction Amount

21. IDEA-B LEA MOE • Requirement • Determine LEA compliance with IDEA-B Maintenance of Effort (MOE) • Applies to LEAs receiving federal funds under an IDEA-B formula grant

22. IDEA-B LEA MOE • 2014 Updates to IDEA-B LEA MOE Handbook • SHARS Medicaid Cost Share is not included in the IDEA-B LEA MOE calculation • Exceptionally Costly Program is defined as amount greater than the average per-pupil (as defined in Section 9101 of ESEA)

23. IDEA-B LEA MOE • Fiscal Agents and Member Districts • TEA has no authority to resolve SSA disputes • Member Districts must contact their Fiscal Agent for amounts reported on their behalf • State Reconsideration for Significant PEIMS Errors

24. Special Education Shared Services Arrangement (SSA) Configuration Changes • Requirement • LEA must notify TEA of configuration changes annually by February 1st • LEA must submit the new SSA Contracts annually by June 1st

25. Corrective Actions Requirement • LEA may owe a refund to TEA from a federal finding in an audit • LEA may have required corrective actions from a federal finding in an audit

26. Corrective Actions • Common Errors to Avoid • Failing to send a check for any refund due to TEA by the deadline • Failing to provide corrective action documents to TEA by the required completion date

27. Additional Questions? Visit the FFCR website: http://www.tea.state.tx.us/index4.aspx?id=2147505847 For questions, please send an email to: Compliance@tea.state.tx.us