Title I-A: Topics Roundup Karl Koenig and Ed Peltz · April 3, 2014
Around the Horn Timeline Primary Goal Guidance Building Eligibility Page School Allocations Eligibility Criteria Title I Fiscal Requirements Around Title I Topics Onsite Reviews
Federal Programs TimelineCCIP Doc Library • Planning/Evaluation • Data • HQT/Qualifications of Paraprofessionals • Fiscal • ESEA Flexibility Waiver 20% Set-Aside Requirement • Parent Involvement
Primary Goal of Title I-Part A To provide supplemental instruction… to the students most at risk of failing to meet the State’s academic content standards… in the buildings with the highest percentage of low-income students.
Title I General Information Targeted Assistance School (ESEA Sec. 1115) Schoolwide School (ESEA Sec. 1114, U.S. Department of Education Guidance on Designing SW Programs, March 2006)
Know What You Can & Can’t Do U.S. Department of Education (ED.gov) Non-Regulatory Guidance: • Identification/Selection of School Attendance Areas and Allocation of Title I Funds, 2003 • Nonpublic Services, 2003 • Title I Fiscal Issues, 2008 • Parent Involvement, 2004 • School Wide, 2006 • Preschool, 2012
Know What You Can & Can’t Do CCIP Doc Library/Help Links ESEA Flexibility Waiver –ODE Homepage OMB Circular A-87 – Cost Principles Education Department General Administrative Regulations (EDGAR)
Know What You Can & Can’t Do Substantially Approved Date Uniform School Accounting System (USAS) Annual Carryover: 15 percent of allocation for allocations of $50,000 or more • Once in three years waiver request
Know What You Can & Can’t Do Time and Effort vs. Semi Annual Certification OMB’s New Uniform Guidance for Federal Grants – stay tuned! Decision Framework to inform the Needs Assessment
Fiscal Issues Failure to meet program objectives • Failure to demonstrate compliance with program requirements Serving ineligible students Unallowable/inadequately documented costs
Necessary and Reasonable Proposed cost relates to a valid educational or administrative decision Does the cost make sense in light of Title I Requirements Adequate Documentation
Title I, Part A Funding • State grants funds to LEAs based on statutory formula • LEA allocates funds to schools based on ranking and serving • Allocations based on low income data (same for nonpublic) • Service based on academic need (same for nonpublic)
Eligibility Criteria At/above 35% low income At/above district-wide low income average Rounding, feeder patter, previously served (one time), less than 1,000 students in district
Eligible School Attendance Areas • Must rank all schools based on percentage (not the number) of low-income children eligible for free and reduced-priced lunches. • CCIP Doc Library Title I-A, USDE Guidance: Eligible School Attendance Areas
75% Rule 75% Rule: Must first serve, in rank order of low-income percentage, its schools above75percent
Rank Order Exceptions Title I Eligible High Schools identified as a Priority School Districts with less than 1,000 students
Eligible School Attendance Areas Default sort order by low income. May Sort Order by grade span for eligible schools below 75% low-income. If sort order, each group must be ranked in order of low-income percentage.
**Building Eligibility Page *Claims Reimbursement and Reporting System-Office of Child Nutrition **Doc Lib: Title I-A, USDE 2003 Guidance, Eligible School Attendance Areas
Building Eligibility Page Use these columns only to serve buildings that do not qualify on their own.
Building Eligibility CEO • Sort order is by default, highest to lowest low income percentage.
Building Eligibility Sort Order • What determines the sort order?
Building Eligibility Sort Order • Sort Order by Grade Span
Building Eligibility Sort Order • Can the LEA sort by Grade level? • Are they required to serve the 75% building?
Building Eligibility Sort Order • What “other” factor qualifies School B?
Building Eligibility Sort Order • How does the 5-8 school qualify as SW-New?
Building Eligibility Sort Order • Feeder Pattern qualifies the high school
Skipped Schools Must provide “Comparable Services Supplement with state/local funds for Title I-like program equal to district per pupil amount Comply with comparability assurances and provides nonpublic services
School Allocations • School Allocation PPA Page (Help link references) • Based on school’s total low income number • Higher PPAs must be in higher schools on ranked list • 125 vs. 100 Percent Rule • Non-public allocation • Remaining balance
School Per Pupil Allocations Determines School Budget Based on school’s total low income number Higher PPAs must be in higher schools on ranked list
School Allocation PPA List 125% Rule • Per Pupil Amount (PPA) = $548.32
School Allocation PPA List 100% Rule • Per Pupil Amount (PPA) = $527.73
School Allocation PPA List 100% Rule • Per Pupil Amount (PPA) = $548.32
Title I Fiscal Requirements Maintenance of Effort (MOE) Comparability of Services Supplement, Not Supplant
Comparability CE To be eligible to receive Title I funds, districts must use state and local funds to provide services in Title I schools at least comparable to services provided in non-Title I schools.
Comparability • If all schools in an LEA are Title I schools, an LEA must use State and local funds to provide services that, taken as a whole, are substantially comparable in each school.
Exempt from Comparability E Districts with only one building per grade span, e.g., K-5, 6-8, 9-12.
Grade-Span Overlap Rule Comparability applies if grade spans overlap by at least two grade levels. Does not apply if there are three or more grade levels outside of the overlap, either above or below, but not combined.
Methods for Determination 3 Student-Instructional Staff Ratio Expenditures Per Pupil Student/Instructional Staff Salary Ratio
Written Procedures Update Annually Identify the Method to Determine Comparable Services Establish Procedures for Making Adjustments if Schools are not Comparable
Documentation PDF Reports – saved in web-based system Signed/Dated Records – 3 years Include District Organizational Chart
Early Determination Enables Districts to make Adjustments with the Least Amount of Disruption CCIP Doc Library includes EXCEL Templates that can be used to Test Comparability (Financial-Comparability-Title I)
Comparability & MOE Website ACCESS CCIP Funding Option in left Menu Bar CCIP Funding Option in left Menu Bar SAFE Account Superintendent, Treasurer, Data Entry Funding-CCIP Superintendent, Treasurer, Data Entry Funding-CCIP
Maintenance of Effort Districtmay receive funds under Title I, Part A for any fiscal year only if the Ohio Department of Education finds that either the combined fiscal effort per student or the aggregate expenditures of the district’s state and local funds for preceding fiscal year was not less than 90 percent of combined fiscal effort or aggregate expenditures for the second preceding fiscal year. - ESEA 9521
Maintenance of Effort Ohio Department of Education must reduce amount of allocation of funds under covered programs in any fiscal year in exact proportion by which the district fails to maintain effort by falling below 90 percent of combined fiscal effort per student and aggregate expenditures (using measure most favorable to the district.)
Supplement Not Supplant District must use Part A funds to supplement, notsupplant regular non-federal funds. – ESEA 1120A (b)