Comparability supplement, not supplant




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NON-REGULATORY GUIDANCE


TITLE I FISCAL ISSUES:


MAINTENANCE OF EFFORT

COMPARABILITY

SUPPLEMENT, NOT SUPPLANT

CARRYOVER

CONSOLIDATING FUNDS IN SCHOOLWIDE PROGRAMS GRANTBACK REQUIREMENTS




REVISED

February 2008



PURPOSE OF THIS GUIDANCE
This non-regulatory guidance updates section E of the Title I fiscal issues guidance released in May 2006 and addresses consolidating funds in schoolwide programs. In addition to revising the introduction to section E, this guidance adds several new questions that clarify the purpose for consolidating funds in a schoolwide program, provides more detail on what it means to consolidate funds in a schoolwide setting, and describes how an LEA might account for State, local, and Federal funds that are consolidated in a schoolwide program. This guidance does not impose any requirements beyond those that the law specifies. Any requirements referred to in this guidance are taken directly from the statute and the Title I regulations, with citations provided throughout. The examples shown in this revised guidance illustrate possible ways to account for Federal funds in a schoolwide setting and do not constitute endorsement of the processes shown or imply that there is a requirement to use those processes. The guidance in this document supersedes all prior non-regulatory guidance issued by the Department concerning Title I fiscal issues

Summary of New and Revised Items

The following are new questions that were not in the May 2006 guidance: E-1, E-2, E-3, E-4,

E-5, E-6, E-7, E-8, E-11, E-16, E-19, and E-25. Additionally, E-3 provides three examples of procedures to account for funds that have been consolidated. The remaining questions have not changed but have a new numbers: E-9, E-10, E-12, E13, E-14, E-15, E-17, E-18, E-20, E-21,

E-22, E-23, E-24.



MAINTENANCE OF EFFORT; COMPARABILITY; SUPPLEMENT, NOT SUPPLANT; CARRYOVER; CONSOLIDATING FUNDS IN SCHOOLWIDE PROGRAMS; AND GRANTBACK REQUIREMENTS

CONTENTS






Page


INTRODUCTION…………………………………………………..…………

9


A. MAINTENANCE OF EFFORT……………………………………………

10


A-1.

When an SEA determines maintenance of effort for its LEAs, must the SEA use the same measure for all its LEAs?


15

B. COMPARABILITY……………………………………….…………………

16


B-1.

Must an LEA determine comparability every year?

30

B-2.

When should comparability be determined?

30

B-3.

May an SEA determine the method that LEAs will use to determine comparability?

32

B-4.

If an LEA elects to skip an eligible school when allocating Title I funds because that school is receiving supplemental funds from other State or local resources that are spent according to the requirements of section 1114 or 1115 of Title I, must that school be comparable?

32

B-5.

If an LEA chooses to measure compliance with the comparability requirement by comparing student/instructional staff ratios or student/instructional staff salary ratios, which staff members should be included as "instructional staff"? Which staff members should be excluded?

32

B-6.

If an LEA uses student/instructional staff ratios or instructional staff salaries/pupil ratios to measure comparability, how can the LEA determine which staff are paid with State and local funds in a schoolwide program in which there is no requirement to track Federal funds to particular activities?

33

B-7.

Must an LEA include charter schools that are schools within the LEA when determining whether its Title I and non-Title I schools are comparable?

33

B-8.

May an LEA use a different method for determining comparability to account for differences between its charter schools and “regular” schools?

34

B-9.

If an LEA is using the student/instructional staff ratio method to demonstrate comparability, should all figures used (enrollment and instructional staff FTE) reflect data from the same day in the school year?



34

B-10.

If all schools in an LEA or in a grade span grouping receive Title I funds, must the LEA demonstrate that these schools are providing comparable services?

34

B-11.

The Title I statute provides that comparability may be determined on a district-wide or grade span basis. Are there limitations on the number of grade spans an LEA may use?

34

B-12.

In addition to grade span groupings, does the LEA have the option to divide grade spans into a large school group and a small school group?

34

B-13.

Are there any circumstances in which the comparability requirement might not apply?

35

B-14.

If an LEA files a written assurance with the SEA that it has established and implemented a district-wide salary schedule and policies to ensure equivalence among schools in staffing and in the provision of materials and supplies, is that sufficient to demonstrate comparability?

35

B-15.

What are an SEA's responsibilities for monitoring the comparability requirement?

35

B-16.

Is an SEA required to collect LEA comparability information each year? If an LEA submits a yearly written assurance that it has met comparability, is that sufficient?

35

B-17.

May an SEA use the single audit process to monitor comparability?

36

B-18.

Are preschool staff and student enrollment included when determining a school’s student-to-instructional-staff ratios?


36

C. SUPPLEMENT, NOT SUPPLANT………………………………………..

37


C-1.

An LEA has hired a Director of Literacy as a K-12 administrative position. All the Title I schools in the LEA are K-5 targeted assistance schools. Thirty percent of the students in the LEA receive Title I services. May Title I pay for 30 percent of the Literacy Director’s salary?

40

C-2.

May Title I funds be used in a targeted assistance program to pay for Title I students’ participation in an extended- day kindergarten program?

40

C-3.

May an LEA use State and local funds to pay for non-Title I students’ participation in an extended-day kindergarten?

41

C-4.

May an LEA use State and local funds to pay for non-Title I students’ participation in an extended-day kindergarten?

41

C-5.

Does the supplement, not supplant requirement apply to indirect costs?

41


D. CARRYOVER………………………………………………………………

42


D-1.

What actions must an SEA take with respect to an LEA that exceeds the 15 percent carryover limitation?

43

D-2.

On what amount is the 15 percent limitation on carryover based?


43

D-3.

Does an LEA include funds carried over from the previous fiscal year in the current year’s allocation base to determine statutory reservations?

43

D-4.

Do funds an LEA transfers into its Title I, Part A program from other ESEA programs under the transferability authority in Title VI, Part A, Subpart 2 of the ESEA affect the base on which the 15 percent carryover limitation is calculated?

44

D-5.

If a State’s fiscal year is not the same as the Federal fiscal year and ends June 30 rather than September 30, may the SEA apply the percentage limitations on carryover funds as of June 30?

44

D-6.

May an SEA waive the 15 percent limitation on carryover funds?

45

D-7.

Does the percentage limitation on carryover funds apply to all LEAs?

45

D-8.

What happens to excess funds carried over by an LEA?

45

D-9.

Does the carryover limitation apply to school improvement funds an LEA may receive from the four percent an SEA reserves under section 1003 of Title I?

45

D-10.

Does the carryover limitation apply to funds an LEA may receive under the State Academic Achievement Awards program under section 1117(b)?

45

D-11.

May an SEA carry over State administration funds authorized in section 1004?

45

D-12.

How does an LEA handle Title I, Part A funds that are carried over when allocating funds to school attendance areas?

46

D-13.

If an LEA is required in a given year to reserve a specific amount of funds for a particular purpose but does not spend all of those funds in that year, may the LEA carry over those unspent funds and spend them in accordance with the flexibility noted in D-12?

46

D-14.

If an LEA reserves 20 percent of its Title I, Part A allocation for supplemental educational services (SES) and choice-related transportation, but spends less than that amount, is the LEA required to carry over the unspent funds for SES and choice-related transportation costs in the following year?

47

D-15.

Are unspent funds from required reservations included in the carryover limitation?

47

D-16.

Do funds carried over from reserves affect the amount of money an LEA must reserve in the following year?

48

D-17.

How does the carryover provision apply to equitable services to private school children?


48

E. CONSOLIDATING FUNDS IN SCHOOLWIDE PROGRAMS……….

49


Consolidating Funds




E-1.

What are the purpose and benefits of consolidating Federal, State, and local funds in a schoolwide program? (New question)

50

E-2.

What does it mean to consolidate funds, including Title I, Part A funds, in a schoolwide program? (New question)

50

E-3.

Are there examples of procedures SEAs can establish that enable an LEA with schools operating schoolwide programs to account for funds that have been consolidated? (New question)

51

E-4.

May a schoolwide program school consolidate only its Federal funds? (New question)

57

E-5.

On what activities in a schoolwide program may consolidated Federal funds, including Title I , Part A funds, be used? (New question)

57

E-6.

If all the Title I, Part A schools in an LEA operate schoolwide programs, may the LEA consolidate funds it is required to reserve under Title I, Part A and other Federal programs into one districtwide pool? (New question)

57

E-7.

If a school operating a schoolwide program does not consolidate its Title I, Part A funds with other Federal, State, and local funds, what activities may Part A funds support? (New question)

58

E-8.

May Title I, Part A funds in a schoolwide program school be used for basic operational expenses such as building maintenance and repairs, landscaping, and custodial services? (New question)

58

E-9.

Which Federal education program funds may be consolidated in a schoolwide program?

59

E-10.

May a schoolwide program school consolidate funds it receives under the Individuals with Disabilities Education Act (IDEA)?

59

E-11.

May individual schools operating schoolwide programs in an LEA include different programs in their schoolwide consolidations? (New question)

60

E-12.

May a schoolwide program school consolidate funds it receives from discretionary grant programs?

60

E-13.

The July 2, 2004 Federal Register notice states that it is permissible for a schoolwide program school to consolidate the Title I, Part D (prevention and intervention programs for children and youth who are neglected, delinquent, or at-risk) funds it receives. Part D consists of two programs. Subpart 1 authorizes the State Agency Neglected and Delinquent program, and Subpart 2 authorizes the Local Agency program. Which of these programs may a schoolwide program school consolidate with other Federal, State, and local funds?

61

Meeting Intent and Purposes




E-14.

How may a school that is operating a schoolwide program meet the intent and purposes of the programs for which it consolidates funds?

61

Record Keeping




E-15.

What fiscal record-keeping requirements apply to an LEA or a school with respect to Federal funds that are consolidated in a schoolwide program?

62

E-16.

If an LEA consolidates Federal, State, and local funds into a consolidated schoolwide pool, and the LEA, for example, must return unspent State funds, how would the LEA distinguish unspent State funds that remain at the end of the year from Federal funds that have been combined in a consolidated schoolwide pool? (New question)


63

E-17.

How does an LEA document employee time and effort in schools that operate schoolwide programs?

63

General Fiscal Questions




E-18

How can a schoolwide program demonstrate that it supplements, and does not supplant, State and local funds?

64

E-19.

How can an LEA determine whether a school operating a schoolwide program is comparable with non-Title I schools when staff and funding resources from State and local sources are combined with Federal resources and there is no requirement to track Federal funds separately? (New question)

65

E-20.

When an LEA calculates whether it has maintained fiscal effort, it excludes expenditures from Federal funds. If a schoolwide program can consolidate Federal education funds, and those funds “lose their program identity,” how can the LEA determine the amount of Federal expenditures to exclude in calculating maintenance of effort?

65

E-21.

Some programs have limitations on the use of funds for certain activities within the program. For example, section 4115(c)(1) of Title IV (Safe and Drug-Free Schools) limits expenditures for certain activities (supporting "safe zones of passage," acquiring and installing metal detectors, and hiring security personnel) to not more than 40 percent of the funds made available to an LEA under Part A, Subpart 1 of Title IV. How does this limitation apply in the following scenarios?

65

E-22.

At least two Federal education programs limit the amount of funds that may be carried over to the subsequent fiscal year. Section 1127(a) of Title I prohibits an LEA from carrying over more than 15 percent of the amount of funds allocated to it for any fiscal year under Part A. Similarly, section 4114(a)(3)(B) of Title IV (Safe and Drug-Free Schools) prohibits an LEA from carrying over more than 25 percent of the allocation it receives under Title IV for that fiscal year unless approval to carry over a greater amount is given by the SEA. How are the amounts of these caps calculated in the following scenarios? (New question)

66

E-23.

An SEA must exclude expenditures by its LEAs of Federal funds under Title I and Title V, Part A of the ESEA in calculating “current expenditures” for the purpose of determining the State per pupil expenditure (SPPE). If a schoolwide program school consolidates Title I and Title V, Part A funds and they thus lose their specific program identity, how can the LEA determine its expenditures of those funds so that the SEA may exclude them in calculating SPPE?

66

E-24.

What is an SEA’s responsibility regarding the consolidation of funds at the school level for schools operating schoolwide programs?

67

E-25.

What are an SEA’s and LEA’s responsibilities to ensure that schoolwide plans are administered in accordance with the statute?


67










F. GRANTBACKS…………………………………………………………….

68


F-1.

What requirements must be met for the Secretary to award a grantback?

68

F-2.

What is the period of availability for the use of grantback funds?

69

F-3.

Will the Department consider approving grantbacks on all misused Federal education funds?

69

F-4.

What are the terms and conditions to which a grantback payment is subject during and after the project period?

70

F-5.

What public notification is made that the Secretary intends to award a grantback?

70



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