Title II, Part A, Fiscal Considerations Under the Every Student Succeeds Act of 2015

1. Title II, Part A, Fiscal Considerations Under the Every Student Succeeds Act of 2015 Office of ESEA Programs 2019 Coordinators’ Technical Assistance Academy Blacksburg: June 17-19, 2019 Norfolk: July 15-17, 2019

2. Disclaimer The academy was planned under a grant from the U. S. Department of Education (USED). However, the content does not necessarily represent the policy of the USED, and you should not assume endorsement by the federal government.

3. Overview • Title II, Part A, allocations • Federal funding considerations: • Cost principles: reasonable, necessary, allowable, advisable • Supplement, not Supplant • Budget Do’s and Don’ts • Terms to use/terms to avoid: words that raise red flags • OMEGA • Transferability, carry-over, and spenddown

4. Allocations

5. Preliminary Allocations • 2018 Allocation: • Total Title IIA to all states: $2,025,095,342 • To Virginia: $37,195,548 • 2019 Preliminary Allocation • Total to all states: $2,025,095,342 • To Virginia: $37,815,494 • Difference: $619,946 • Percent difference to Virginia:+1.66% • Based on 2018 Census estimates (to be updated in June 2019; estimated figures will change)

6. Planning and administration

7. Considerations for Planning the Use of Federal Funds • Are the expenses allowable? • Not prohibited or required by other state or local regulations • Supplemental to the basic education program • Necessary and reasonable for proper and efficient performance and implementation • Are the expenses reasonable? • Not exceeding sensible limits; not exorbitant • Market cost for comparable goods

8. Considerations for Planning the Use of Federal Funds (Slide 2 of 2) • Are the expenses necessary? • To meet a clear and documented need • To carry out an approved program/activity or for the success of an approved/adopted initiative • To increase access, improve quality, support students, etc. • Are the expenses advisable? • Appropriate infrastructure in place to support the activity • Aligned with current division initiatives, strategic direction, policies, etc. • Sufficient time, personnel, funding to fully carry out the initiative

9. Supplement, Not Supplant Federal funds must be used to enhance or increase the level of funding which is normally available from state or local sources. Federal funds must not replace state and local funds.

10. Rebutting the Presumption of Supplanting – Title II, Part A Is other funding available for the item/activity/personnel? No Is the division providing the item/activity from state or local funds anywhere else? No In the case of professional development, is the funding over and above the amount required under state funding? Yes In the case of class-size reduction, has the division met the mandated staffing ratios outlined in the Standards of Quality ? Yes If your answers are as above, then Title II, Part Amay approve the purchase.

11. Supplement, Not Supplant Example • Consider an ice cream party. What’s absolutely necessary? • Dish (or cone) and ice cream represent basic required elements of program. (You just can’t have an ice cream party without them!)

12. Supplement, Not Supplant Example (Slide 2 of 3) • Consider an ice cream party. What’s absolutely necessary? • Additional elements (syrup, cherries, sprinkles, whipped cream, toppings, etc.) represent supplementary services available from federal programs. They add to the basic “ice cream party” – and hopefully make it even more successful!

13. Supplement, Not Supplant Example (Slide 3 of 3) When planning your program, ask yourself whether the desired activities are for BASICS… …or the EXTRAS!

14. FEDERAL FUNDING CONSIDERATIONS:Do’s and Don’ts

15. TheDo’s of Title II, Part A, Programs and Budgets When planning Title II, Part A, activities, do include in your budget… Clear, evidence-based links to improving student achievement and teacher/principal quality and effectiveness; and Activities designed to meet a particular need as determined through annual needs assessment and stakeholder feedback. When budgeting Title II, Part A, funds, do… Specify your proposed activities and how they are supplementary and connected to student achievement and/or teacher and principal quality; Attempt to accurately project budgets (rather than ballpark); and Be specific about expenditures

16. The Don’ts of Title II, Part A, Programs and Budgets When you plan Title II, Part A, activities, do not… • Plan to use Title II to pay for activities required under state law or division policy (e.g., professional development mandated by Standards of Accreditation; or teachers to meet staffing mandates in Standards of Quality); or • Request to pay for activities or materials that are core operating expenses to be used during the school day, such as copy machine toner, paper clips, white out, etc.

17. The Don’ts of Title II, Part A, Programs and Budgets (Slide 2 of 3) When budgeting Title II, Part A, funds, do not… • Attempt to pay for activities or items that are not in your approved plans; • Request that Title II, Part A, pay for equipment that is not clearly solely connected to a supplementary professional development program, and for which usage cannot be tracked, such as computers, LCD projectors, laminating machines, etc.

18. The Don’ts of Title II, Part A, Programs and Budgets (Slide 3 of 3) When budgeting Title II, Part A, funds, do not… • Request Title II, Part A, funds to be used for items that are not NECESSARY for professional development activities (e.g., refreshments). • Assume that you will be able to use your Title II, Part A, funds for items or services not specifically identified in your budget.

19. REIMBURSEMENTS

20. Reimbursement Basics • Reviewed programmatically and fiscally at VDOE • Include expenditure end-date • Cannot be in the future • Must only be submitted for checks that have already been cut • Requests cannot cross fiscal years • July 1-June 30

21. Reimbursement Basics (Slide 2 of 2) Spend down • Spend down “old funds” first, if possible • Submit application amendment and budget transfer requests to move funds between object codes • Submit on an ongoing basis throughout the award cycle (monthly or quarterly)

22. Reimbursement Terminology: Red Flags (Slide 1 of 8) Red flag term: “Required/mandated” Why it’s questionable: Suggests a supplant. Items required or mandated by state or local laws, regulations or policies cannot be paid for with federal funds Alternative wording: “Necessary for Title II, Part A, program”

23. Reimbursement Terminology: Red Flags (Slide 2 of 8) Red flag term: “Administrator” Why it’s questionable: Is this a principal? Superintendent? Transportation director? The term is vague and could raise supplanting or overall allowability questions. Be specific. Alternative wording: Title IIA Coordinator; Principal; Superintendent

24. Reimbursement Terminology: Red Flags (Slide 3 of 8) Red flag term: “Refreshments,” “Snacks,” “Food,” “Breakfast” Why it’s questionable: While these may be “nice to have,” they are not necessary in order for teachers to participate in professional development activities. Alternative wording: “Working lunches for full-day professional development activities” (only if agenda indicates PD during lunch)

25. Reimbursement Terminology: Red Flags (Slide 4 of 8) Red flag term: “lodging at conference hotel” Why it’s questionable: lf lodging charges are higher than allowable state rates, participants should seek other hotels within zip code search to find lower cost options (or make arrangements to pay the difference) Alternative wording: Specify lodging rate that is clearly within state travel regulation guidelines.

26. Reimbursement Terminology: Red Flags(Slide 5 of 8) Red flag term: “Coursework” Why it’s questionable: Term is vague. Be specific about the particular course/content area to ensure allowability. Alternative wording: “Coursework for foreign language teacher: French 320”; “Coursework for biology teacher: Coastal Ecology 825.”

27. Reimbursement Terminology: Red Flags(Slide 6 of 8) Red flag term: “Textbooks,” “classroom materials” Why it’s questionable: Could be misconstrued as core instructional materials or for student use. Alternative wording: “Materials for teacher use in coursework” or “Materials for biology professional development session on April 25.”

28. Reimbursement Terminology: Red Flags(Slide 7 of 8) Red flag term: “Equipment (e.g., laptops, tablets, Smartboards)” Why it’s questionable: Unless use of equipment is NECESSARY for PD and can be tracked to ensure it is ONLY used on PD, it should not be purchased with Title II, Part A, funds. Alternative wording: “equipment necessary to provide PD. Purchases are above and beyond local technology provision.This is new equipment (not replacement) that has never been purchased with other funding sources.”

29. Reimbursement Terminology: Red Flags(Slide 8 of 8) Red flag term: “Speaker,” “Convocation speaker” Why it’s questionable: Professional development should support a systemic, ongoing, sustained plan for improvement. Convocation speaker suggests supplanting. Alternative wording: “Contracted services to provide professional development on <topic>, held on <date>”

30. Object Code Clarification

31. Object Code Clarification Use correct object codes • 1000: Salaries • 2000: Benefits (health, FICA, etc.) • 3000: Purchased/contracted services (e.g., contracts with presenters, universities, vendors for professional development activities and associated costs; all tuition for coursework; contracts for working meals (full-day onsite training); subscriptions and organizational memberships

32. Object Code Clarification, (Slide 2 of 2) • 4000: Internal services (e.g., in-house copying; cafeteria services for full-day onsite training) • 5000: Other (e.g., reimbursements to individual teachers for registrations for conferences, travel (mileage/meals associated with conference travel, lodging); M&IE, lodging for presenters and participants; indirect costs • 6000: Materials for professional development or directly tied to program activities (e.g., “reasonable/necessary” PD materials; recruitment materials, etc.)

33. Food Expenses OC3000: ANY catered food services (typically procured through a contract), but also includes take out food from restaurants (even if not previously contracted) Example: boxed lunches for all-day PD, credit card payments directly to vendors OC4000: Food provided by the school division’s food services department as a working meal OC5000: Meals specifically related to overnight travel expenses, reimbursed to individual teachers OC6000: Food related materials and supplies (typically grocery store purchases of bottled water, plastic ware, etc., associated with working meals for full-day PD.)

34. Subscriptions and Licenses OC3000: Online subscriptions or site licenses that are handled through contracts. They may be one time purchases or renew on a revolving basis (monthly, annually, etc.)

35. Changes to Budget and/or Program

36. Revisions versus Amendments Revisions are made to the initial application if it has been denied. Amendments are submitted after an application has been approved.

37. To Amend, or not to Amend Application amendment – When is it necessary? • After final allocations are released (if the application has already been approved programmatically) • When programmatic changes are made during the grant award cycle • Before any budget transfer request is made throughout the grant award cycle

38. Budget Transfers Use to align budget and actual expenses between object codes. Write a complete justification. If programmatic or budget changes are required, an application amendment and budget transfer must be submitted.

39. OMEGA Requests: Make it Better(Slide 1 of 6) Action: Budget Transfer Request Comments: “Please approve moving available funds from object code 0000 to object code 5000 to close out the 2017-2018 grant. Thanks!”

40. OMEGA Requests: Make it Better(Slide 2 of 6) Action: Application amendment Comments: “6/3/2019 revision to 2017-2018, Title II, Part A, adjustment”

41. OMEGA Requests: Make it Better(Slide 3 of 6) Action: Budget Transfer request Comments: “Please approve this budget transfer so the amendment may be completed. Thank you!”

42. OMEGA Requests: Make it Better(Slide 4 of 6) Action: Application amendment Comments: “Transfer funds”

43. OMEGA Requests: Make it Better(Slide 5 of 6) Action: Reimbursement request Comments: “Funds requested must not be negative”

44. OMEGA Requests: Make it Better(Slide 6 of 6) Action: Reimbursement request Comments: “Expenditure start date: 7/1/17; Expenditure end date: 9/30/2019.”

45. ACTIVITY

46. Timeline

47. Carryover Provisions • Total period of grant award is 27 months for federal funds. • Title II funds are available throughout the entire 27 month period of availability. • Title II funds must be encumbered by September 30 of the 27th month. • Services for private schools should be encumbered within 15 months of award availability, but may be extended up to an additional 12 months, based on consultation.

48. Spenddown Review • Submit reimbursements on regular basis. (Monthly draw-down is ideal.) • Review spenddown for all open awards regularly. (Use OMEGA’s Spend Down Calendar Report.) • Submit reimbursements for “older funds” prior to accessing “newer funds.” • Review OMEGA requests regularly to ensure created requests are submitted and approved through local approval queue by all parties.

49. Carryover/Spenddown Timeline for 2017-2018 Award Award Period – from July 1, 2017 to September 30, 2019 Deadline to Obligate Funds: September 30, 2019 Deadline to Submit Final Reimbursements: November 15, 2019

50. Carryover/Spenddown Timeline for 2018-2019 Award Award Period – from July 1, 2018 to September 30, 2020 Deadline to Obligate Funds: September 30, 2020 Deadline to Submit Final Reimbursements: November 15, 2020