Part I – Acronyms and Basic Title I Requirements

1. Part I – Acronyms and Basic Title I Requirements 2015 GCEL Annual Conference March 2 - 4, 2015

2. Presenter Dr. Judy Alger Title I Education Program Specialist Georgia Department of Education School Improvement – Federal Programs jualger@doe.k12.ga.us (229) 321- 9305

3. SCHOOL IMPROVEMENT & DISTRICT EFFECTIVENESS

4. Topics for Review • Title I, Part A Program – Intent and Focus • Acronyms You Need to Know • Managing a Federal Grant • Fiscal Requirements • Program Models • Parental Involvement and Parent Engagement Requirements • Private School Requirements

5. Intent of Title I • To increase the achievement of all students, particularly those who are disadvantaged • To ensure all children have fair, equal, and significant opportunity to obtain high quality education • To reach, at minimum, proficiency on challenging state standards & assessments (English language arts, reading, mathematics, science, social studies)

6. Focus of Title I Title I, Part A Programs focus on: • Promoting reform in high-poverty schools and, • Ensuring student access to scientifically-based instructional strategies and challenging academic content

7. Acronyms You Need to Know Federal Grants – Title I, Part A

8. Acronyms You Need to Know • US ED U.S. Department of Education • SEA State Educational Agency • LEA Local Educational Agency • GEPA General Education Provisions Act • ESEA Elementary and Secondary Education Act • NCLB No Child Left Behind Act • EDGAR Education Department’s General Administrative Regulations

9. Acronyms You Need to Know • CFR Code of Federal Regulations • CFDA Code of Federal Domestic Assistance • OMB Office of Management & Budget • DUNS Data Universal Numbering System • OIG Office of Inspector General • FLP Flexible Learning Program • SIG School Improvement Grant • CEP Community Eligibility Provision

10. Fiscal Requirements ESEA provides several fiscal requirements that are applicable to Title I funds. • LEAs must maintain the financial effort previously provided to Title I schools. • LEAs may not use Title I funds to supplant or replace State or local funds. • LEAs must provide services to Title I schools that are comparable to those of non-Title I schools.

11. Maintenance of Effort (MOE) • A LEA may receive Title I funds only if the Georgia Department of Education (Department) determines that the LEA has maintained the level of funding of at least 90 percent of the preceding fiscal year of: • The combined state and local funds per FTE or • The aggregate expenditures of state and local funds

12. Maintenance of Effort (MOE) What happens when a LEA does not meet Maintenance of Effort? • If an LEA fails to meet the maintenance of effort standard, the Department is required by ESEA to reduce the amount of funds allocated in the same proportion by which the LEA failed to meet the 90 percent requirement • Districts will be sent notification after the submit their Consolidated Application but prior to approval by their Title I Education Program Specialist

13. Maintenance of Effort (MOE) • The U.S. Department of Education may waive the maintenance of effort requirements if it has determined that a waiver would be equitable due to exceptional or uncontrollable circumstances, such as natural disasters or a significant decline in the amount of local funds of the LEA • The Georgia Department of Education (Department) Title Programs office requests the waiver of the maintenance of effort requirement on behalf of the LEA

14. Supplement Not Supplant • Funds received under this part shall be used to supplement, and not supplant, non-Federal funds that would otherwise be used for activities authorized under this part. ESEA Section 1120A(b)

15. In Other Words: What would have happened in the absence of federal funds? Would other monies from the state or local resources have been used to pay for the item or service? If so, and you used Title I monies for the item or service……..you may have supplanted

16. Presumptions of Supplanting Supplanting is presumed if federal funds were usedto provide services that: • Were required to be made available under other federal, state, or local laws; • Provided with non-federal funds in the prior year; • Were provided to participating children, if those same services were provided with non-federal funds to non-participating children.

17. Comparability • Comparability requirements ensure that funds made available under Title I are used to provide services that are in addition to the regular services normally provided by an LEA for participating children. • An LEA may receive Title I funds only if it uses State and local funds to provide services in Title I schools that are at least comparable to the services provided in schools that are not receiving Title I funds.

18. Comparability • All LEAs must meet the Comparability requirement EXCEPT those LEAs that have only one building for each grade span.

19. Fiscal Requirements Keeping Track of Costs • Title I directors should keep track of expenses independently and reconciling expenses with the LEA’s financial system on a monthly basis. That way problems related to the Title I, Part A budget can be addressed early enough to find a way to deal with any issues May 2012 LRP Publications Managing Your Federal Education Funds

20. Regulations for Expenditures Level of Authority • Statute (GEPA-ESEA-NCLB) • Regulations including EDGAR (CFR) • Non-regulatory guidance • Policy letters • Office of Management & Budget (OMB) Circulars • US ED Web: www.ed.gov • Federal Register

21. Cost Principals All costs must be: • Necessary • Reasonable • Allocable • Be legal under state and local law • Conform with federal law & grant terms • Consistently treated

22. Cost Principals All costs must be: • In accordance with Generally Accepted Accounting Principles (GAAP) • Not included as match • Net of Applicable credits • Adequately documented

23. Non-allowable Costs for Title I, Part A • The following are examples of unallowable expenditures and CANNOT be included in the FY15 Title I school budget • School resource officer, security guard (exceptions may be allowable for specific Title I events conducted outside normal school hours) • Clinic aide, school nurse, clinic supplies • Custodian, custodial supplies (exceptions may be allowable for specific Title I events conducted outside normal school hours)

24. Non-allowable Costs for Title I, Part A • Cafeteria worker, cafeteria supplies • ELL coordinators, ELL required forms and tests • Behavioral intervention positions • Incentives, rewards, certificates, door prizes, raffle items, etc. • Marketing items such as brochures, banners, and flags (unless Title I Reward Schools, National Title I Distinguished Schools or Reward District)

25. Non-allowable Costs for Title I, Part A • Memberships for professional organizations not related to Title I • Field trips (all field trips must receive prior approval from the Department) • Food items (unless light snacks purchased for parent trainings)

26. Non-allowable Costs for Title I, Part A • Guidance counselors, unless the position is beyond district allocation, are allowable if 100-percent of their time is spent working on Title I related guidance/academic issues

27. Districts Must Exercise Internal Control Why Internal Control? • Is the first line of defense in safeguardingassets and detecting and preventingerrors and fraud • Includes processes for planning, organizing, directing, controlling, and reporting on school district/school operations • Helps achieve desired results through effective stewardship of public resources

28. Districts Must Exercise Internal Control Internal Control Five Components of Internal Control • Control Environment • Risk Assessment • Control Activities • Information and Communications • Monitoring

29. Time and Effort Reporting

30. Time and Effort Reporting Employees who are paid with federal funds must keep records of their time to ensure that a district does not use federal funds to compensate an employee for time spent on any other program. All individuals being paid with federal funds must document their time and effort, no matter their percentage of time or if they are working in a Title I targeted assistance or schoolwide program

31. Tracking Time and Effort What type of documentation is required? • Permanent Schedule – A permanent schedule is most often used for teachers or individuals who are being paid with federal funds and hold a fixed schedule every day of the week • A Title I teacher’s schedule could document he/she is being paid 100% with federal funds and 100% of his or her time is dedicated to Title I programming

32. Tracking Time and Effort What type of documentation is required? • A Title I teacher’s whose schedule is 50% Title I instruction and 50% reading coach could also use this method if his/her schedule is consistent day after day

33. Tracking Time and Effort • Daily Log – Individuals who work less than 100% for a particular federal program and whose schedule changes from day to day have the option of logging their time spent in the federal program each day • A Title I Director who is paid 45% from Title I to coordinate the district’s Title I program and 55% from the district’s general fund to implement the general curriculum could keep a daily log of the time spent on general curriculum versus Title I coordinator duties. Daily logs must be signed by the employee and their supervisor

34. Tracking Time and Effort • Permanent schedules must be on file and updated throughout the school year • Daily logs must be on filed and signed monthly • Periodic Certifications – Districts who have fully funded federal personnel or those that are partially funded with federal funds must have individuals submit an assurance every six months (at a minimum) documenting that they are aware the amount of time they are paid from each particular federal program must be dedicated to performing duties related to that program

35. Tracking Time and Effort Part time staff requires extra attention to documentation • Keep careful documentation that proves time was spend in accordance with what the grant requires Who else has to track their time if paid with federal monies? • Substitute Teachers • Part-time Employees

36. Tracking Time and Effort • Time and effort reporting is required when any part of an individual’s salary is charged to a federal program • Single cost objective → Semi annual certification • Completed at least every six months • After-the-fact record (dated) • Signed by the employee and supervisor • Accounts for the total activity for which employee was compensated • Must coincide with one or more pay periods

37. Tracking Time and Effort • Multiple cost objectives → Monthly time reports or Personnel Activity Reports (PARs) • After-the-fact record • Accounts for the total activity for which employee compensated • Completed monthly • Signed by employee • Must coincide with one or more pay periods

38. Tracking Time and Effort • Time and effort reports show how time was actually worked • Must account for 100% of time worked • Must reconcile to budget at least quarterly

39. Tracking Time and Effort • It is possible to work on a single cost objective even if an employee works on more than one federal award or on a federal award and a non-federal award. • The key to determining whether it is a single cost objective is whether the employee’s salary and wages can be supported in full from each of the federal awards on which the employee is working or from the federal award alone if the employee’s salary is also paid with non-federal funds. • The Administrator’s Handbook on EDGAR, page 322

40. Blanket Certifications • Multiple employees working on the same single cost objective can be identified on a single semi-annual certification • Provide flexibility • Identifies multiple employees working on the same single cost objective • Must be prepared at least semi-annually • Signed and dated by supervisor with firsthand knowledge of the employees’ work

41. Program Models • Targeted Assistance ModelProvides supplemental services to “identified” children who are low-achieving or at-risk of low achievement, ESEA Section 1115, Targeted Assistance • Schoolwide ModelEnsures all students, particularly those who are low- achieving, demonstrate proficient and advanced level in the state achievement standards, Section 1114, Schoolwide

42. Service Models Supplemental/additional assistance to core instruction for eligible students, particularly addressing the needs of low-achieving children and those students at risk of not meeting the state’s academic achievement standards: • In-class supplemental model (Push-in) • Pull-out class model • Before school-after school

43. Service Models • Saturday school • Extended school year • Summer school

44. Parental Involvement and Parent Engagement Requirements Title I, Part A – Section 1118

45. Parental Involvement Section 1118 • Districts receiving $500,000 or more in Title I, Part A funds must set aside, at minimum, 1% for parental involvement • Districts must solicit input from parents on how to spent the 1% set-aside

46. Parental Involvement Section 1118 • Each District must develop with all parents and distribute: District Parental Involvement Policy and the CLIP • Each Title I school must develop with all parents of participating student s and distribute: School Parental Involvement Policy, a Parent Compact, and a Schoolwide or Targeted Assistance Plan

47. Private Schools Title I, Part A - Section 1120

48. Private School -Participation If a Title I, Part A program is available to public schoolstudents, teachers and parents, then equitable, educational services are available to eligible private school students, teachers and parents, ESEA, Section 1120, and 34 CFR 200.62-67, Participation of Students Enrolled in Private Schools

49. To Participate a Private School Must BE • State approved • Not-for-profit • Completed the Intent to Participate process Title I Services to Eligible Private School Children Non-Regulatory Guidance October 2003

50. Private Schools Consultation Process • Consultation with eligible private schools must occur before the school district makes any decision that affects the services of eligible private school children, teachers and parents • Completed on an annual basis for private schools that service students from the District • Continue throughout the year for private schools that elect to participate