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Fiscal Fun

Fiscal Fun. ESEA Odyssey 2011. Agenda. The Big Three Maintenance of Effort Comparability Supplement Not Supplant Carry Over Time Distribution Reporting. The Big Three. Maintenance of Effort Comparability Supplement Not Supplant. Maintenance of Effort. Maintenance of Effort.

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Fiscal Fun

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  1. Fiscal Fun ESEA Odyssey 2011

  2. Agenda The Big Three • Maintenance of Effort • Comparability • Supplement Not Supplant Carry Over Time Distribution Reporting

  3. The Big Three • Maintenance of Effort • Comparability • Supplement Not Supplant

  4. Maintenance of Effort

  5. Maintenance of Effort • Demonstrate level State and Local funding of schools from one year to the next. • A district may continue to receive Title funds only if the district has maintained fiscal effort.

  6. Title IA – Basic Title IC – Migrant Title ID – Neglected/ Delinquent Title IIA – Teacher Quality Title III – ELL Title IV-B – 21st Century Title VI-B – Rural Low Income Schools Maintenance of Effort

  7. Maintenance of Effort ODE runs 4 tests to check MOE: • General Fund Expenditures • Per pupil Expenditures • ADM per pupil Expenditures • ADA per pupil Expenditures

  8. ABC School District Test 1 Example: General Fund Expenditures 09 -1008 -09 $3,007,242 $3,631,494 District needs to spend at least 90% 90% Funding level required for 09 -10$3,268,344 Result: Fiscal Effort Not Maintained 8.0% difference

  9. ABC School District Test 2 Example: ADM Expenditure per pupil: 09 -10 08 - 09 $10,194 $10,776 90% Per Pupil Funding level required for 09 -10$9698 Result: Fiscal Effort Maintained

  10. Maintenance of Effort • If districts fail to maintain effort can appeal to USDE. • USDE may waive the MOE requirement if: • Exceptional or uncontrollable circumstances, such as natural disaster • Precipitous decline in the financial resources

  11. Comparability

  12. Comparability An LEA may receive funds under this part only if State and local funds will be used in schools served under this part to provide services that are at least comparable to services in schools that are not receiving funds under this part. No Child Left Behind Fiscal Requirements Section 1120 A (c)

  13. Comparability If the LEA is serving all of its students under this part, the agency may only receive funds if it will use State and local funds to provide services that are substantially comparable in each school. No Child Left Behind Fiscal Requirements Section 1120 A (c)

  14. Comparability - Exclusions • LEA that has only one school per grade span • LEA may exclude schools with fewer than 100 students

  15. Comparability • Comparability Worksheets • Written Assurance • District Wide Salary Schedule • Policy of equivalence in staffing • Policy of equivalence in materials and supplies • Criteria and Guidance located at :http://www.ode.state.or.us/search/page/?id=1940

  16. Comparability • Comparing Title IA to non-Title IA—Title IA schools need to be within 110% • Comparing Title IA to Title IA—Schools need to be within 90%-110% of each other

  17. Supplement Not Supplant

  18. Supplement Not Supplant • Must use federal funds only to supplement what is being done • Supplant is using federal dollars to provide: • A required program • A program that was provided by non-federal funds in the prior year • Services to some students while using local sources to provide the same services to others

  19. Targeted Assistance Programs Provide support only to targeted students and teachers of targeted students Additional services Supplement Not Supplant

  20. Supplement Not Supplant Schoolwide Programs • Must have current, compliant plan • Must support goals in plan • Must use Title IA funds only to supplement the amount of funds made available from non-Federal sources.

  21. Scenarios - Expenditures • Professional development workshop in behavior management • Support staff such as a media specialist, cafeteria manager or secretary • Paperback books, text books • Art supplies

  22. Supplement Not Supplant • A district can overcome the presumption of supplanting if: • Demonstration of a reduction in non-Federal funds • District eliminates the activity without taking into consideration Title IA funds • The activity is allowable • Necessary and reasonable

  23. Carryover

  24. Carryover • May be because: • Late start of program, change in personnel costs, changed plan • Congress assumes… We don’t need the funding!

  25. Carryover • Carryover must be requested through CIP Budget Narrative • Expenditures through September 30 • Carryover pages open in CIP Budget Narrative around November 17 • 15% LIMIT – Title I-A • Can have more than 15% once every 3 years

  26. CIP Budget Narrative • Assurances • Prayer Certification • Contacts • Consolidated Spending • Due No Later Than September 15th

  27. Time Distribution

  28. Time Distribution:Why is this important? • Salary costs are material to many grants • Absence of adequate documentation is a basis for repayment of funds • Considered explicitly as a “risk factor” by OMB • Numerous grantees have had to repay millions because of T&E issues.

  29. OMB A-87 Rules • If federal funds are used for salaries then Time Distribution records are required. • Must demonstrate • If employee is paid from federal funds, then employee worked on that specific federal program/cost objective.

  30. Terminology • Time and attendance records • Payroll records • Monday Worked 8:00-4:00 • Semi-Annual Certification • Time and effort records • Monday worked 50% on Title IA and 50% on general fund activities

  31. Adequate Reporting • Retained by district • Prepared After-the-Fact • Full disclosure – Report of full time worked • Credible endorsement

  32. Semi-Annual Certification • Signed every six months by supervisor or employee • “From August 23, 2011, until December 31, 2011, Janet Bubl spent 100% of her time on Title IA Schoolwide program implementation at Frolic Fields Elementary School.”

  33. Time and Effort • Time and Effort (Aka…Personnel Activity Reports --PAR) • Signed and dated every month by employee • Actual accounting of time after the fact • Showing total effort • Should have report and back up documentation to verify • calendar, work product, time log

  34. Time Distribution • Comparison and Adjustment • Quarterly comparison of actual costs • If difference is more than 10% adjust quarterly • If difference is less than 10% adjust annuall

  35. Questions??

  36. Contacts Janet Bubl Janet.bubl@state.or.us 503-947-5687

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