Schoolwide Pooling Presented by: Marsha Ruettgers, Supervisor Nancy Brannon, Supervisor Jennifer Frank, Supervisor Shelley Woods, Coordinator Angie Nickell, Director Missouri Departmentof Elementary and Secondary Education May 1-3, 2011
Purpose of Schoolwide • The underlying purpose of the schoolwide approach is to enable schools with high numbers of at-risk children to integrate the services they provide to their children from Federal, State, and local resources.
Schoolwide Eligibility • 40% or more students qualify for Free and Reduce lunch • Conduct a comprehensive needs assessment and develop a schoolwide plan • Describe how it will upgrade educational program • Strategies for upgrading educational program • Plan should be developed during a one-year period.
Title I Schoolwide Program • The LEA must ensure that, of the non-federal funds available to the LEA in a given year, the school building receives all of those funds it would otherwise have received if it were not operating a schoolwide program. (This may be verified if the district meets the Comparability and the Maintenance of Effort requirements.)
Title I Schoolwide Program • Not required to identify eligible students • Not required to demonstrate that the services provided with Title I funds are supplemental to services that would otherwise be provided
Title I Schoolwide Program • Implementing a Schoolwide program: • Schoolwide pool consolidating State, Local and Federal funds • Consolidating federal funds only • Title I only
Schoolwide Pool – Consolidating Funds • Treat funds like a “single pool of funds” • Lose individual program identity • School has more flexibility • Supports any activity of the schoolwide program without regard to which program contributed the specific funds used for a particular activity
Consolidating Funds • Does not need to meet most of the statutory and regulatory requirements of the Federal programs but must meet the intent and purposes of those programs • Eases the requirements of accounting of funds
Consolidating Funds • Must identify programs being consolidated • Must identify the amount being consolidated per each LEA • Must address the intent and purposes of the Federal program funds
Schoolwide Pooling • District-wide Set asides • Time/Effort • Supplement not Supplant • Maintenance of Effort • Comparability • Carryover Limitations
District-wide Set Asides • LEA is required to set aside funds on the district-wide Title I budget • Schoolwide is building level • Set aside funds must be accounted for separately • The 20% SES/Choice set-aside may come from funds other than Title I. If funding is other than Title I, the LEA must document the source of funds in the textbox on step 3 of the BOA
Time and Effort • If school consolidates Federal, State and local funds in a single account, not required to file single funding certification • If school does NOT consolidate State, Local and Federal funds into a single account, must complete single funding certification or time & effort log for federal employees
Supplement not Supplant • LEA’s must ensure that such a school meets the supplement not supplant requirement as it relates to a schoolwide program, i.e. each school operating a schoolwide program must receive all the State and local funds it would otherwise receive to operate its educational program in the absence of Title I, Part A or other Federal education funds • The actual service need not be supplemental
Maintenance of Effort • LEA’s combined fiscal effort per student or the aggregate expenditures of the LEA from state and local funds for free public education for the preceding year is not less than 90 percent of the combined fiscal effort or aggregate expenditures for the second preceding year
Comparability LEAs having multiple attendance areas serving same or similar grade spans must demonstrate compliance with comparability requirements annually State and local funds used to provide services in Title I schools are at least comparable to services provided in schools not receiving Title I funds Guidance is available at http://www.dese.mo.gov/divimprove/fedprog/financialmanagement/ComparabilityofServices.html
Carryover Limitations • 15% carryover still applies to Title I allocation
Special Education Considerations • Districts may use Part B IDEA (611) funds for any activities under its schoolwide program plan but must comply with all other requirements of Part B of the Individuals with Disabilities Education Act (IDEA) to the same extent as it would if it did NOT consolidate funds under Part B of the IDEA in the schoolwide program. This is for both fiscal and compliance related requirements.
Part B IDEA Pooling Options • Districts may pool a portion of their Part B IDEA allocation or the entire allocation, given there are no set-asides. • Districts may pool a portion of their state/local funds for special education, or all of their state/local funds for special education. • Districts may do both Part B IDEA and state/local funds for special education. • Districts may not consolidate their ECSE (619) funds into the schoolwide pool.
Part B (Spec Ed) Requirements • Budget Application for Part B IDEA • Proportionate Share Obligations • Coordinated Early Intervening Services • Payment Requests • Maintenance of Effort/Supplement Not Supplant • Excess Cost (calculated by the Department) • Final Expenditure Report for Part B IDEA • Compliance Requirements
Budget Application • Whether pooling all or a portion of Part B IDEA allocation, districts must submit both a Schoolwide budget application and a Part B IDEA budget application. • These budgets will “feed” into each other and transfer data. • Any amendments to one application will result in the need for an amendment to the other program’s application.
Proportionate Share Obligation • Proportionate Share obligations act like a set-aside. • Districts may not use this set-aside amount in the schoolwide pool. • Proportionate share is the district’s obligation to provide special education services to parentally-placed private/parochial school students and home-schooled students.
CEIS • Coordinated Early Intervening Services (CEIS) funds will only be treated like a set-aside when the district is mandated to use the funds because of significant disproportionality issues. Otherwise, they may be pooled. • CEIS are services provided to students in grades K-12 who are not currently identified as needing special education or related services, but who need additional academic and behavioral supports to succeed in a general education environment.
Payment Requests • Payment requests will depend on how the district chooses to pool funds. • If pooling all Part B IDEA funds, payment requests will be made through the Schoolwide system. • If pooling a portion of Part B IDEA funds, payment requests will need to be made through both systems for each portion.
Maintenance of Effort (MOE) • Districts must still meet MOE requirements for Part B IDEA, meaning they must spend the same amount of state/local funds on special education as they did the prior year. • MOE will be calculated using the amounts entered on both the Schoolwide pool FER and the Part B IDEA FER.
Excess Cost • Districts must continue to meet Excess Cost requirements. This is a calculation run at the Department. If the district does not meet Excess Cost, they will not be eligible for the Part B funds; thus they won’t be able to put any funds into the schoolwide pool. • To meet excess cost, the district/LEA must spend the same amount of state/local funds on special education students as it does on regular education students before accessing federal funds.
Final Expenditure Report (FER) • Districts will have to complete both the Schoolwide Pool FER and the Part B IDEA FER. • These FERs will “feed” into each other and transfer data. • Any amendments to one FER will result in the need for an amendment to the other program’s FER.
Compliance Requirements • All compliance requirements apply.
Record Keeping for SW Pooling • Not required to keep separate accounting records • Districts must show separation of SW pooling salaries, benefits, purchase services, and material and supplies, etc. • Code teachers in Core Data with program code 13
Payment Request • To complete a Schoolwide Pool payment request, the LEA enters a single funds requested amount on the Schoolwide Pool Payment Request screen. The requested amount is divided proportionately between the source programs that contributed money to the Schoolwide Pool. These portioned amounts per program determine which funds are used to make the Schoolwide Pool payment.
Resource The following websites provide guidance on requirements and questions regarding the development and implementation of schoolwide programs: http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf (pages 49-67) http://www.ed.gov/policy/elsec/guid/designingswpguid.doc (whole document) http://www2.ed.gov/policy/gen/leg/recovery/guidance/titlei-reform.pdf (pages 4-7)