Where Has All the Money Gone? Administrators’ Management Meeting September 17-19, 2008

1. Where Has All the Money Gone?Administrators’ Management MeetingSeptember 17-19, 2008

2. TOPICS • IDEA Funding and Use of Funds • Coordinated Early Intervening Services • Proportionate Share for PPPSS

3. Status of IDEA Entitlement Awards • 99% eligible applicants met 7/1/08 deadline • 19 districts completed electronic submissions by June 1 • 68% of applicants awarded projects by August 1 • 9 awards in June • 39 awards in July

4. Review of Applications Most applicants adequately addressed all required components of application with minimal edits • Budget • Assurances • Narratives (Required and Voluntary)

5. Permissive Use of Funds • Benefit to Nondisabled Students • Administrative Case Management • Coordinated Early Intervening Services (CEIS)

6. Benefit to Nondisabled Students • “Voluntary” provision • Permits flexibility when 100% IDEA-funded service or aide provided for SWD • Incidental benefit derived by nondisabled students from service or aid for SWD • Training for teachers/staff NOT a service or aid for SWD • 55 districts/agencies chose this option

7. Administrative Case Management • “Voluntary” provision • Purchase of technology (computer hardware and software) • Purposes restricted to • recordkeeping, • data collection, and • related case management activities • 34 districts/agencies chose this option

8. Fiscal and Program Accountability • Project records (3 year retention) • Fiscal project reports • Audit reports • Program reports

9. Keep records that show • How funds were used • Total cost of the project • Share of costs provided by other sources • Financial records documenting compliance • Program records documenting performance • All records needed to satisfy audit

10. Most Common Audit Findings • Inadequate Support of Salaries and Wages • Personnel Activity Reports (PARS) for Multi-funded • Semi-Annual Certifications for 100% IDEA-funded • Omission of Required Contractual Language/Forms (i.e., suspension/debarment language) • Inadequate Procurement Policies/ProceduresOR Noncompliance With Policies/Procedures

11. Obligation of Funds

12. Coordinated Early Intervening Services

13. CEIS (Voluntary) • Use no more than 15% of Part B • Develop and implement activities supporting “coordinated early intervening services” for nondisabled students needing academic and/or behavioral support • 22 districts chose this option

14. CEIS (Voluntary) Who is eligible? • Nondisabled students in grades K-12 (no preschool) • Need additional academic and behavioral support • May include students who received special education, but no longer receive special education

15. CEIS (Voluntary) How are children identified? • Performance on reading and math assessments • Disciplinary referrals • Suspensions and expulsions

16. CEIS (Voluntary) Caveats for school-wide interventions! • Must document CEIS funds used ONLY for students in need of support • Other funds must be used for school-wide interventions for special education students and students NOT in need of supplemental support

17. CEIS (Required) Significant disproportionality by race/ethnicity • identification of children with disabilities (11 districts), • placement of these children in educational settings (1 district), and • disciplinary actions, including suspensions and expulsions (0 districts)

18. CEIS (Required) • Calculations for 2008-09 grant • Risk Ratios calculated – see handout • Identification and Placement calculations based on October 2007 Survey 2 data • Discipline calculations based on 2006-07 Survey 5 data • Cut point of 3.5 applied to all categories

19. CEIS (Required) • Calculations for 2009-2010 • Hope to use same calculations • New guidance from OSEP may impact calculations

20. CEIS (Required) • Must use maximum amount (15%) of Part B funds for CEIS during the period of availability, regardless of whether disproportionality resolved • 15% calculated using sum of Part B (611) & Preschool (619)

21. CEIS (Required) • All CEIS expended from Part B (611) funds • Funds used for CEIS must be those appropriated for the FY following the date significant disproportionality determined or from the prior FY • Serve children in the LEA, but NOT exclusively, those who were significantly over-identified

22. CEIS (Required) • Districts must • review policies, practices, and procedures with respect to identification, placement, and disciplinary actions taken; and • report publicly any revisions to those policies, practices, and procedures

23. CEIS (Required) • CEIS NOT limited to ONLY students in those groups significantly over-identified

24. Fiscal Considerations (CEIS Required) Must use maximum amount of 15%------ calculate using both Part B and Preschool Part B Flow-through = $ 297,809 + Preschool Flow-through = $ 30,202 .15 X $ 328,011 = Set-Aside for CEIS = $ 49,202

25. Fiscal Considerations (CEIS Required) • May not reduce the amount LEA uses for this calculation by any other amount required by IDEA. Example: if flow-through is $1,098,422, this same amount is used to calculate CEIS and proportionate share.

26. Fiscal Considerations (CEIS Required • Set-aside funds (15%) must be used during the period of availability • Funds must be used for CEIS, even if significant disproportionality resolved during the time funds available

27. Fiscal Considerations (Voluntary and Required CEIS) CEIS affects compliance with “Maintenance of Effort” (MOE) requirement • Amount of funds expended for CEIS shall count toward the maximum amount that MOE may be reduced

28. Fiscal Considerations (Voluntary and Required CEIS) CEIS affects compliance with “Maintenance of Effort” (MOE) requirement • If LEA uses additional local funds for special education in place of the Part B funds for CEIS, this higher level of expenditures becomes the new MOE base for the subsequent year • See examples in Appendix D of Part B regulations

29. Reporting Considerations (Voluntary and Required CEIS) Districts must report • # children who received CEIS • # children received CEIS and received special education and related services during the preceding two-year period

30. Reporting Considerations (Voluntary and Required CEIS) • A code (I) has been added to indicate students receiving Early Intervening Services funded by IDEA, Part B dollars. • States are required to track by student those nondisabled children who received these services and whether or not they ultimately were found eligible for special education and related services. • Reported on Federal/State Indicator Status format in Survey 5.

32. Proportionate Share for Parentally Placed Private School Students

33. Private School Consultation • How are eligible students enrolled in non-profit private schools identified? • How are private school representatives and parents of children with disabilities informed of the process? • The amount of proportionate share determined and how funds will be used.

34. Private School Consultation • How are decisions made with regard to services offered in the consultative agreement? (types of services, including direct service, and any alternate service delivery) • How is this information (consultative agreement) shared with private schools and parents?

35. Private School Consultation • How are affirmations obtained from representatives of private schools?

36. Remember— You must have documentation on file that a “timely and meaningful consultation occurred” and is signed off by private school officials or by a representative of private schools.

37. Students enrolled in nonprofit private schools Students who are determined to be students with a disability Initial evaluation and re-evaluation Eligible Private School Students

38. Current Data Part B = 8,901 (36% reduction) Preschool = 361 (53% reduction) Source: FY 09 App’n FY 08 Data Part B = 13,871 Preschool = 770 Eligible Private School Students Source: FY 08 App’n

41. Proportionate Share Expenditures Districts must • track expenditures by FY (first and second “roll” year) • maintain records of expenditures • determine if roll satisfied

42. Important to Note-- • Proportionate share funds expended must meet the special education and related services needs of eligible students with disabilities • IDEA funds are NOT used for • Needs of a private school • Repairs, remodeling, or construction of private schools • General needs of students enrolled in the private school

43. Also…property, equipment, and supplies purchased under this provision must be • Administered and under control of district • Used ONLY for Part B purposes • Removed from the private school when no longer needed and/or to avoid unauthorized use

44. Where have the dollars gone? Set-aside Proportionate Share Funds • Part B = $11.9 million • Preschool = $176,576 Set-aside Coordinated Early Intervening Services • Part B = $22.1 million

45. Thank youKaren DenbroederExceptional Education and Student Services850.245.0475Karen.Denbroeder@fldoe.org