2017 Federal Programs Administrator Workshop University of Notre Dame May 23, 2017

1. 2017 Federal Programs Administrator WorkshopUniversity of Notre DameMay 23, 2017

2. Today’s Agenda • 8 am - 9 am Registration • 9 am - 9:45 am Welcome/Plenary Presentation • 10 am -10:45am Breakout Session I • 11 am -12 pm Group Topic Discussions • 12 pm - 1:30 pm Lunch (on your own) • 1:30 pm - 2:15 pm Breakout Session II • 2:30 pm - 3:15 pm Technical Assistance • 3:15 pm Dismissal

3. Access to Wi-Fi • Select ND-guest wifion your devices to access wifi while on campus. No password needed.

4. General Information • We will be using Padlets for questions, comments and general communication during the workshop. • To access the Padletsgo to:www.tinyurl.com/FedProgramsSouthBend • To add a question or comment simply click on the + sign in the lower right-hand corner. • Copies of all PowerPoint slides and resources are embedded in the Padlet. 

5. Breakout Sessions10:00 -10:45 a.m.; Repeated 1:30 - 2:15 p.m. • Required Documentation for Federal Programs • Carey Auditorium (where you are right now) • Allowable Activities and Coordination of Funds • Andrews Auditorium (in Geddes Hall which is the building west of Hesburgh Library) • Non-Public Equitable Share • Lower-Level Classroom B034 (in basement of Geddes Hall) • Title I Application Walkthrough • Lower-Level Classroom B036 (in basement of Geddes Hall) • Title II, A and Comprehensive Needs Assessments • Lower-Level Classroom There will be signs directing you to the rooms where each of the sessions will be taking place.

6. Group Topic Discussions11:00 a.m. – 12:00 p.m.; Carey Auditorium • Early Learning • New Directors • Title I in Secondary Schools • Best Practices • Audits/Monitoring • English Learners • Students with Disabilities • Budgeting • Schoolwide • Targeted Assistance Registrants identified additional topics that they would like to discuss and/or receive additional support. Select one topic in the designated areas and discuss with a small group.

7. IDOE Technical Assistance2:30 – 3:15 p.m.; Carey Auditorium • Participants may use this self-directed time to ask individual questions regarding local needs, grant writing, and program administration. • IDOE staff will be available to those utilizing this optional time.

8. Plenary • Objectives: • Address cross-cutting fiscal topics that impact all federal programs and generate common questions • Interact with the new supplement not supplant language for Title I, A • Understand the increased flexibility for identifying Title I high schools • Determine process for nonpublic school equitable share and services • Receive allocation updates

9. Cross-cutting Fiscal Topics • Uniform Grants Guidance (UGG) • Overarching fiscal administrative rules that apply to federal funding • Comprehensive requirements for fiscal topics, such as a procurement, documentation, allowability • 2 CFR 200 (Found at ecfr.gov) • Procurement & Contracts • Federal rules must apply. However, if the state or local rules are more prohibitive, then the most stringent rules must be followed

10. Cross-cutting Fiscal Topics • Procurement & Contracts (Federal Simplified Acquisition Threshold 2 CFR 200.88) • Micro Purchase – 2 CFR 200.320(a) • Currently under $3,500 • No quotes needed • Must distribute purchases equally among eligible vendors • Small Purchase – 2 CFR 200.320(b) • $150,000 and under • Obtain quotes (at least 3) • Large Purchase – 2 CFR 200.320(c,d,e) • Over $150,000 • Formal (RFP, IFB) • Publicly posted (IN publication requirements) • Required contract provisions (Appendix II to 2 CFR Part 200)

11. Cross-cutting Fiscal Topics • Disposition • If the item no longer benefits the intended federal program, then use for another federal program • Thresholds (fiscal handbook) • http://www.doe.in.gov/sites/default/files/titlei/title-i-fiscal-handbook-2015-2016.pdf • Responsibility to the awarding agency • Responsibility to the program • No responsibility

12. Cross-cutting Fiscal Topics • Internal Controls • Separation of Duties • Physical Audits • Documentation • Reasonable, Allocable, & Necessary (RAN) • Guides the approval of every activity or cost objective

13. Cross-cutting Fiscal Topics • Suspended/Debarred • LEAs must ensure that vendors are not suspended or debarred by the federal government before contracting • www.sam.gov/portal/SAM • Parent Involvement • Parents are vital to the implementation of any program • Title I: 1% requirement for parent engagement activities if allocation over 500k • Title III: Required portion • IDEA: CCC

14. Cross-cutting Fiscal Topics • Time and Effort • Personnel documentation for all staff that are split funded or less than 100% • School/District Wide Uses • Title I Schoolwide • Inventory • Equipment (threshold limit or intended use of longer than a year) • Indirect Cost • Accounts for the local burden of administering a program that cannot be directly charged to the program (i.e. % of utilities)

15. Supplement NOT Supplant ESSAhas changed the supplanting test for Title I (but not other programs). The proposed rulemaking for supplement not supplant was never finalized by the Obama administration and the rulemaking that was finalized by the Obama administration have been rolled back. So, we are left with statute only in many cases (Sec. 1118(b)(3): No local educational shall be required to: • Identify that an individual cost or service supported under this part is supplemental. • Provide services under this part through a particular instructional method or in a particular instructional setting in order to demonstrate compliance.

16. Supplement NOT Supplant However, ESSA still requires the federal funds to supplement the funds that would be made available from state and local funds. Which means… Instead of the Title I program administrator asking if each activity, personnel, book, program etc is supplemental (programmatic test), the LEA Chief Financial Officer will enact a locally-determined methodology to ensure Title I schools receive all of the state and local funds they would otherwise receive (fiscal test).

17. Supplement NOT Supplant Three presumptions of supplanting no longer apply to Title I, A • Paying for an activity that was required by state or local law • Paying for an activity that was supported with state or local funds in the past, or • Paying for the same services for eligible students that state and local funds support for non-eligible students However, the presumptions of supplanting still apply to Title II, Title III, and Title IV. Ask not if it is supplemental for Title I, A, but ask if… Is it designed to improve student achievement? Benefit eligible students/schools? Consistent with Title I-required plans? Consistent with federal spending rules?

18. Supplement NOT Supplant ESSA provides for a 2-year transition period before this fiscal test must be determined at the local level (Dec. 10, 2017). Title I Application for FFY 17 (SY 17-18) will require LEAs to assure that: • The LEA certifies that Title I, Part A funds will be used only to supplement the funds that would, in the absence of the federal funds, be made available from state and local sources for the education of students participating in the Title I, Part A programs. • The LEA certifies that they have developed and implemented a methodology to allocate State and local funds to each school receiving Title I, Part A funds that ensures that each school receives all of the State and local funds it would otherwise receive if it were not receiving Title I, Part A funds.

19. How does a school become Title I? • Schools within each LEA must be ranked by percentage of poverty from highest to lowest using free/reduced lunch data. • Schools that meet or exceed poverty averages (based on total F/R lunch counts) are eligible to be served. Schools over 75% must be served. . • New: An LEA may lower the threshold to 50 percent for high schools and serve those schools prior to elementary or middle schools with percentage at or below 75 percent.

20. Nonpublic Equitable Services • Provide services that are allowable and comparable to those provided to public school students and teachers participating in the program. • Services can be different from those provided to public school participants. • Needs of nonpublic school students and teachers must be assessed and evaluated. • No funds are provided directly to nonpublic schools.

21. Title I Funding Change for Nonpublic Allocation • NCLB: Proportion of funds after public school set asides that was equal to proportion of low incomechildren residing in Title I attendance area. • ESSA: Proportion of funds based on total allocation that is equal to proportion of low incomechildren residing in Title I attendance areas.

22. Title II Funding Change for Nonpublic Allocation • NCLB: Proportion of funds allocated by public school to professional development that was equal to proportion of nonpublic school students to all students in the district. • ESSA: Proportion of allTitle IIA funds that is equal to proportion of nonpublic school students to all students in the district.

23. The State Ombudsman The state education agency (SEA) must designate an ombudsman to monitor and enforce the requirements related to equitable services provided to non-public school children, teachers and other educational personnel in non-public schools. (Sec. 1117(a)(3)(B)).

24. Indiana’s Ombudsman andIDOE Title Grants & Support - Work as a Team • Title Grants & Support • Provide technical expertise to the Indiana Department of Education (IDOE), school divisions and others in interpreting, understanding and implementing accountability requirements for equitable services • Provide technical assistance to school divisions and non-public schools with consultations, as needed • Provide initial assistance with any issues that might arise BEFORE issuing an official complaint with the ombudsman • Ombudsman • If there are still issues to be addressed after Title Grants and Support assistance, complaints are filed to the ombudsman regarding consultation and/or service provisions

25. Allocation Updates Congress recently appropriated funds for programs under the Every Student Succeeds Act (ESSA) for FFY 2017 (SY 2017-2018). IDOE anticipates receiving preliminary allocations by the end of May for Title I, Title II, and Title III. While Title IV (new funds) received an allocation, we have not received a timeline for it. We will provide more information about this new grant in the near future. Most programs either are flatlinedor have a slight increase with the exception of Title II, which received an overall 13% reduction. The IDOE is collaborating with ED to provide information and allocations to LEAs in a timely manner. 

26. Thank You • University of Notre Dame and its staff for hosting the training • Participants and their dedication to Indiana’s schools, students, parents, and communities • IDOE staff for their involvement and leadership in offering this training

27. Breakout Sessions are Next!10:00-10:45 a.m.; Repeated 1:30-2:15 p.m. • Required Documentation for Federal Programs • Carey Auditorium (where you are right now) • Allowable Activities and Coordination of Funds • Andrews Auditorium (in Geddes Hall which is the building west of Hesburgh Library) • Non-Public Equitable Share • Lower-Level Classroom B034 (in basement of Geddes Hall) • Title I Application Walkthrough • Lower-Level Classroom B036 (in basement of Geddes Hall) • Title II, A and Comprehensive Needs Assessments • Lower-Level Classroom • There will be signs directing you to the rooms where each of the sessions will be taking place.