USED Monitoring Schedule

1. Monitoring Issues & Other Hot TopicsFall 2009Presented by: Bette Morff, CoordinatorFederal Grants and Financial Managementbette.morff@dese.mo.gov 573-751-8280

2. USED Monitoring Schedule • Title I - March 12-15, 2007 (Title I.A, Title I.D, Homeless, Even Start) • Title III – March 30-April 1, 2009 • Title II.A – May 5-6, 2009 • Title I -- June 2010 (Title I.A, Title I.D, Homeless, Title III)

3. Major Finding of USED Monitoring of Title I • Status:Finding.DESE’s monitoring procedures are insufficient to ensure compliance with all NCLB requirements. The ED team found that DESE failed to identify numerous compliance issues in the LEAs visited by the ED team.

4. Action Required of USED Monitoring of Title I Further action required:DESE must revise its monitoring procedures to ensure that they are sufficient to identify and correct compliance issues in its LEAs. At a minimum, these procedures must include: • A process to require LEAs to annually submit evidence of compliance with NCLB fiscal requirements, such as within district allocations (including ranking of eligible schools and set-aside requirements) and comparability; • Procedures to enable DESE to conduct targeted monitoring of its LEAs; • Procedures to ensure timely correction of all compliance issues identified through any DESE monitoring procedures; • Procedures to require LEAs to submit the results of all self-monitoring activities, as well as evidence of correction of any identified non-compliance.

5. DESE’s Corrective Action Plan • Refined the Title I BOA to include additional requirements. • Revised our Self-Monitoring Checklist to cover areas addressed during our monitoring review. • Set a monitoring cycle based on the 5-year MSIP review.

6. DESE’s 5-Year Monitoring Plan • Monitor each LEA scheduled for an MSIP review, regardless of review type. • Monitor LEAs on the NCLB “High Risk List.” • Use the revised Self-Monitoring Checklist as our review guide. • Assign a person to track monitoring visits through a database. • Database is used to track the date of the review, when the review letter was mailed, when LEA corrects compliance issues or when payments are withheld if corrections have not been made.

7. DESE’s 5-Year Monitoring Plan • We are establishing criteria to identify LEAs for a NCLB High Risk list. Criteria include: • Amount of money allocated • Late submission of application or reports • Severe monitoring issues (including audits) • Released federal funds • Maintenance of Effort • Financially Stressed • Other Concerns – DESE discretion (unaccredited, key staff changes, federal or state investigation, complaints or anonymous tips, etc.)

8. Title III Review March 30-April 1, 2009

9. Major Findings and Corrective Action Based on the USED Monitoring of Title III • No evidence of Title III plans • DESE requires LEA to submit Title III plan before NCLB consolidated application is approved. • LEAs used Title III funds to employ teachers who provided “core instruction” to LEP students (Supplement, Not Supplant) • DESE is reviewing the NCLB consolidated applications for staff hired with Title III funds. Will call LEAs to discuss supplanting issues. Mandatory training for Title III recipients.

10. Major Findings and Corrective Action Based on the USED Monitoring of Title III • No evidence that the English proficiency of all LEP children is assessed on an annual basis. • Sent e-mail notifying LEAs of this requirement. • No evidence that the State ELP assessment (LAS-links) is aligned with the State ELP standards. • DESE is working on this now.

11. Major Findings and Corrective Action Based on the USED Monitoring of Title III • State did not notify LEAs of their AMAO status or ensure that LEAs that did not make all three AMAOs notified parents of this fact. • DESE has instituted a system to notify all LEAs that have LEP students of their AMAO status and their requirement to notify parents of failure to meet AMAOs if the LEA is Title III funded. DESE also has instituted a system to notify all LEAs that have LEP students of their AYP LEP subgroup status and their requirement to notify parents under Title I. • Procedures for collecting and calculating LEA data on the number of LEP students used to determine eligibility for Title III funds was accurate. • MOSIS system has been updated to provide better guidance on how to record LEP students.

12. Major Findings and Corrective Action Based on the USED Monitoring of Title III • State did not ensure funds awarded for Immigrant children were used for appropriate activities. • Separate budget for Immigrant on 2009-2010 application. • State did not have a process in place to ensure the LEAs identify students as immigrant children and youth correctly. • MOSIS system has been updated to provide better guidance on how to record Immigrant students.

13. Major Findings and Corrective Action Based on the USED Monitoring of Title III • State did not have a process to ensure teacher fluency in English and any other language of instruction. • There is an assurance on the Title III plan that “Certifies that all teachers funded are fluent in English and any other language used , including written and oral communications.” • Monitoring was not sufficient, checklist did not include all the essential requirements. • DESE revised our Self-Monitoring Checklist to cover areas addressed during our monitoring review.

14. Title II.A Review May 5 - 6, 2009

15. Major Findings and Corrective Action Based on the USED Monitoring of Title II.A • Finding- The State has not established appropriate HQT requirements for elementary special education teachers. • Response: By January 1, 2010 all special education teachers who teach core academic content will be identified as HQT. • Through the HOUSSE form • By passing the Elementary Certification Praxis test.

16. Major Findings and Corrective Action Based on the USED Monitoring of Title II.A • Finding - Provisional and/or temporary license do not require subject matter competency. • Response – By the end of September 2009 the DESE will send a letter to LEAs notifying them of the HQT status of teachers with provisional or temporary certificates.

17. Major Findings and Corrective Action Based on the USED Monitoring of Title II.A • Finding – The State must ensure that all teachers hired after the first day of 2002 – 2003 school year teaching in a Title I program be HQ at the time of hire. • Response - By January 1, 2010, the DESE will compile a report of Title I teachers not meeting the HQT criteria. If any of the teachers not meeting HQT are being paid with federal funds, the district will have to remove them from the federal pay status and notify parents that the teachers do not meet the highly qualified status.

18. Major Findings and Corrective Action Based on the USED Monitoring of Title II.A • Finding – The State does not require districts who have not met HQT for 2 consecutive years to have an improvement plan nor does the State provide technical assistance to the districts in formulating a plan. • Response – The Instructional Improvement staff will work with districts to develop strategies to reach 100% HQT. Grants Management staff will follow-up during on site Monitoring visits.

19. Major Findings and Corrective Action Based on the USED Monitoring of Title II.A • Finding - The state has not implemented its Equity Plan to ensure poor and minority students are not taught at higher rates than other students by inexperienced, unqualified or out-of-field teachers. • Response - the Federal Instructional Improvement staff will provide assistance to LEAs in developing strategies to discuss the concern of students in their district being taught by a large number of teachers with five years or less experience, teachers who are not highly qualified, and if the distribution of highly qualified teachers is equitable.

20. Upcoming USED Monitoring Visit in June 2010 Programs: Title I.A, Title I.D, Title III, and Homeless The use of ARRA Funds will be monitored during this visit. Items to be monitored at both State and LEA level: • Allocation of Funds • Title I Waiver Requests • Reporting and Tracking • Allowable Uses of Funds

21. ARRA Funds The ARRA funds are one time allocations. Four principles guide the use of ARRA funds: • Spend funds quickly to save and create jobs. • Improve student achievement through school improvement and reform. • Report fiscal and programmatic information in order to ensure transparency and accountability. • Invest the one-time ARRA funds thoughtfully to minimize the “funding cliff.”

22. Title I Allocations Title I Regular Allocation - $234,623,705 Title I ARRA Allocation - $147,728,408 4% of both is reserved for School Improvement (a) Funds <1% of the regular Title I allocation is reserved for Administration >$5.5 million is reserved for Title I bypass services for nonpublic schools.

23. Allocation Criteria – Title I • NCLB law requires the use of census data • Large districts (total populations of 20,000 or more) receive their allocation based solely on census poverty data. • Smaller districts – Missouri uses alternative poverty data (State Board Approved & USDE Approved) • 80% census poverty data and foster child counts • 20% January free/reduced lunch counts as reported on Core Data

24. Allocation Criteria – Title I • Title I allocation consists of four separate funding calculations: • Basic Grant • Concentration Grant • Targeted Grant • Education Finance Incentive Grant (EFIG). • Each funding category has different criteria and formula to distribute these funds. • Has hold-harmless criteria – no less than 85% if criteria are met and funding is sufficient • School Improvement and Administration Set-Asides

25. Allocation Criteria – Title I ARRA • Title I ARRA allocation was based on the two parts of the Title I formula. These two funding parts give greater weight to poverty counts: • Targeted Grant • Education Finance Incentive Grant (EFIG). Ten LEAs did not receive ARRA funds (3 were too small to meet minimum number of poverty children; 7 did not meet the minimum poverty percentage). Some of the seven that did not meet the minimum poverty percentage, received an ARRA allocation based on Desegregation students. • 4% School Improvement Set-Asides --1003(a) • No Administrative Set Asides

26. Other ARRA Funds • Title II.D – Education Through Technology – $9,731,919 minus bypass withholding 50% formula and 50% competitive Formula portion of allocation is based on the proportionate share of the Title I ARRA allocation. • Homeless - $1,054,392 75 LEAs received the grant – Based upon a minimum of 15 homeless students reported last year, received approximately $91 per student.

27. Other ARRA Funds • School Improvement 1003 (g) - $45,954,726 Will not receive this award until December or January. New guidance on the use of 1003(g) funds. Specifically, the Secretary of Education proposes that States identify three tiers of schools to be served:   • The lowest-achieving five percent of Title I schools in improvement, corrective action, or restructuring in the State, or the five lowest-achieving Title I schools in improvement, corrective action, or restructuring, whichever number of schools is greater (Tier I schools); • Equally low-achieving secondary schools (both middle and high schools) that are eligible for, but do not receive, Title I funds, which would be served through a waiver under section 9401 of the ESEA (Tier II schools); and • Other Title I schools in improvement, corrective action, or restructuring (Tier III schools).

30. Waiver Requests • DESE requested and received approval for all Title I waivers. • Some waivers are Statewide and the LEA does not need to request the waiver. • Some of the waivers are used to decrease the amount of Title I funds set aside for specific purposes.

31. Waiver Requests • LEAs may not request to waive the 1% requirement for Parent Involvement. • LEAs may not request to waive the 5% requirement for Highly Qualified Teachers. DESE provided Sample Waiver Templates to assist the LEA in requesting the appropriate waivers.

32. Which waiver do I request if my district is in LEA Improvement Level 1 or Level 2? 10 Percent Professional Development for LEA Improvement Waiver • Note: LEAs in Corrective Action are encouraged, not required to use the 10 % for PD

35. Which waiver do I request if one or more of my schools are in School Improvement Level 1? SES in addition to Choice Waiver Request Per Pupil Amount for SES Waiver Request

36. Which waiver do I request if one or more of my schools are in School Improvement Level 2? Per Pupil Amount for SES Waiver Request 10 Percent PD for School Improvement Waiver Request 20 Percent Choice and SES Waiver Request

38. Which waiver do I request if all of my schools identified for improvement are in Corrective Action or Restructuring? Per Pupil Amount for SES Waiver Request 20 Percent Choice and SES Waiver Request Note: LEAs in Corrective Action or Restructuring are encouraged, not required to use the 10 % for PD

39. Maintenance of Effort LEA’s combined fiscal effort per student or the aggregate expenditures of the LEA from state and local funds for free public education for the preceding year is not less than 90 percent of the combined fiscal effort or aggregate expenditures for the second preceding year.

40. Maintenance of Effort • Title I Maintenance of Effort is based upon state and local expenditures. Missouri will request the waiver to count the SFSF as state and local funds for MOE calculations. • An increase in the amount of federal funds used will not affect the MOE calculation. However, if the LEA decreases their state and local effort, this could cause them to not meet MOE.

41. Through ePeGS, DESE will calculate Maintenance of Effort for every LEA each year. LEAs have access to this report. These printouts can be shared with the district’s independent auditor.

44. Waiver of Fiscal Requirements Maintenance of Effort – USDE Secretary may waive the requirements if it is determined that a waiver would be equitable due to exceptional and uncontrollable circumstances, such as a natural disaster; or a precipitous decline in the financial resources of the LEA.

45. ePeGS Application

47. Current Funds Available Page

50. Current Funds Available Page – Nonpublic Bypass