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Maintenance of Effort, Comparability, and Supplement/Supplant. PAFPC April 2011. USDE Title I Fiscal Guidance (May 06). fiscalguid.doc This guidance covers these areas: Maintenance of Effort (MOE) Comparability Supplement not Supplant Carryover

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maintenance of effort comparability and supplement supplant

Maintenance of Effort, Comparability, and Supplement/Supplant

PAFPC April 2011

usde title i fiscal guidance may 06
USDE Title I Fiscal Guidance (May 06)
  • fiscalguid.doc

This guidance covers these areas:

  • Maintenance of Effort (MOE)
  • Comparability
  • Supplement not Supplant
  • Carryover
  • Grantbacks
maintenance of effort

Maintenance of Effort

Legal Authority:

NCLB: Section 9521

moe the nclb rule
MOE: The NCLB Rule
  • LEA may receive funds only if SEA finds the combined fiscal effort per student or the aggregate expenditures of the LEA from state and local funds from preceding year is not less than 90% for second preceding year.
moe preceding fiscal year
MOE: Preceding Fiscal Year
  • Need to compare final financial data
    • PDE Uses Annual Financial Report (AFR)
  • Compare “immediately” PFY to “second” PFY
  • EX: To receive FY 2005 funds (available July 2005), compare FY 2004 (2004-05) to FY 2003 (2003-04)
expenditures included
Expenditures Included
  • “Expenditures from state and local funds for free public education”
  • Administration; instruction; attendance and health services; pupil transportation services; operation and maintenance of plant; fixed charges; and net expenditures to cover deficits for food services and student body activities
expenditures excluded
Expenditures Excluded
  • Funds from federal government
  • Community services; capital outlay; debt service; or supplemental expenditures made as a result of a Presidentially declared disaster
moe failure
MOE: Failure
  • ESEA: If LEA fails MOE, SEA must reduce amount of allocation in the exact proportion by which LEA fails to maintain effort below 90%.
  • Reduce all applicable NCLB programs, not just Title I
years after failure
Years after Failure
  • SEA uses 90% of the prior year amount rather than the actual expenditure amount
moe waiver
MOE: Waiver
  • USDE Secretary may waive if:
    • Exceptional or uncontrollable circumstances such as natural disaster


    • Precipitous decline in financial resources of the LEA


Legal Authority:

Title I Statute: §1120A(c)

general rule 1120a c
General Rule- §1120A(c)
  • An LEA may receive Title I Part A funds only if it uses state and local funds to provide services in Title I schools that, taken as a whole, are at least comparable to the services provided in non-Title I schools.
  • If all are Title I schools, all must be “substantially comparable.”
timing issues
Timing Issues
  • Guidance: Must be annual determination
  • YET, LEAs must maintain records that are updated at least “biennially” (1120A(c)(3)(B))
  • Review for current year and make adjustments for current year
  • Assurances are due November 15.
  • Egrants changes for 08/09.
written assurances
Written Assurances
  • LEA must file with SEA written assurances that state:
    • The LEA is exempt from demonstrating Comparability because it has only 1 building per grade span or;
    • The LEA has successfully documented the comparable staff to pupil ratio in the district using the Detailed School Data Sheet.
how to measure in a district with non title i buildings

Average of all non-Title I schools

Each Title I school

How to measure in a district with non-Title I buildings


Average of all non-title I schools=10:1

Title I schools:

Lincoln: 10:1 Washington: 9:1 Madison: 11:1 Jefferson 12:1

how to measure in a district with all title i buildings
How to measure in a district with all Title I buildings


  • Average of one or more of the lowest poverty Title I schools to each higher poverty Title I school
  • Lincoln 30% poverty, Washington 50%, Madison 55%, Jefferson 60% Chose only Lincoln as the comparison school
  • Lincoln 30%, Washington 32%, Madison 55%, Jefferson 60%, chose both Lincoln and Washington as the comparison schools
basis for evaluation
grade-span by grade-span


school by school (district-wide basis)

Basis for evaluation:
  • Federal Funds
  • Private Funds
  • Need not include unpredictable changes in student enrollment or personnel assignments that occur after the start of a school year
who is instructional staff
Who is “instructional staff”
  • Administrators (principals and assistant principals)
  • Art Teachers
  • Classroom Teachers
  • Guidance Counselors
  • Librarians
  • Music Teachers
  • Physical Education Teachers
  • Project Directors (Non-federally funded)
  • Psychologists
  • Social Workers
  • Speech Therapists
not included
Not included…
  • Bus Monitors
  • Consultants
  • Crossing Guards
  • Maintenance Staff
  • Security Staff
  • Federally paid Staff
optional staff
Optional staff…
  • Bilingual Teachers
  • Special Education
  • Title I “Like” Staff
  • Teachers Aides (instructional)
  • Although the LEA has the discretion to count or not count these types of staff, it must be done consistently across the grade spans being compared.
how to access the data sheet and assurance page
How to access the Data Sheet and Assurance page
  • and click on the eGrants link at the left of the page.
  • Then click on the Division of Federal Programs link at the left of the screen.
  • Enter your Login ID and password, then click on the “Consolidated Application” link.
  • At the main Consolidated Application page you’ll see the link for Comparability towards the bottom of the screen.
supplement supplant
  • Targeted Assisted – program level supplanting. “Reasonable and necessary.” Very situationally dependent
  • Schoolwide – fiscal level supplanting only, but must meet “intents and purposes.”

School must receive all the state and local funds it would otherwise need to operate in the absence of Federal funds

    • Includes routine operating expenses such as building maintenance and repairs, landscaping and custodial services
can title i be used for basic operational expenses
Can Title I $ be used for basic operational expenses?
  • If only federal combined –
    • No, must be for educational needs
  • If federal and non-federal combined –
    • No, but impossible to determine which is federal
    • Be sure sufficient state and local funds allocated to school to meet basic operational needs
what is educational need
What is “educational need”?
  • Not addressed in guidance
    • Instruction – yes
    • Instructional support – probably yes
    • Administration – possibly yes
    • Operational – no
closing thoughts
Closing Thoughts
  • The SWP is VERY important!
  • Targeted versus SWP which is better?