Rules and Regulations Meeting

1. Rules and Regulations Meeting Office of Federal and State Accountability March 14, 2013

2. Welcome and Introductions Roy Stehle Title I Director

3. Sequestration Roy Stehle Title I Director

4. Sequestration The President was required by the Budget Control Act of 2011 to order sequestration on March 1, 2013 to enforce automatic spending cuts to Federal Government Programs. There are two other budget related Congressional votes looming: FY13 Budget approval or continuing resolution and a debt ceiling vote.

5. Sequestration Most ESEA programs will be affected for the 2013-14 school year. The USED has released tables which indicate a 5% reduction in ESEA programs nationally.

6. Sequestration Title I allocations to SEA’s and LEA’s are, in part, based on census poverty ages 5-17. The Title I reduction to LEA’s in S.C. could be from 1% to 15 % depending on the revised census poverty figures for counties and districts. In budgeting for Title I in 2013-14, the recommendation would be to plan for a reduction in the 5-10% range and no new FTE’s.

7. Questions

8. Fiscal Moves Roy Stehle Title I Director

9. Fiscal Moves to Consider Carryover: LEA’s, upon approval of the SEA, may carryover more than 15% of their allocation. This SEA carryover waiver may be granted to LEA’s once every three years. The SCDE received approval from the USED for districts to carryover more than 15% from 2011-12 into 2012-13 due to residual ARRA funding.

10. Fiscal Moves to Consider The USED waiver permits the SCDE to grant all LEA’s a carryover waiver of more than 15% for 2012-13 going into 2013-14 if they need it. If LEA’s requested a carryover waiver, it would start the once every three year clock. The SCDE would not be able to grant the same district another carryover waiver for 2013-14 going into 2014-15 or for 2014-15 going into 2015-16.

11. Fiscal Moves to Consider The SCDE will be requesting another carryover waiver from the USED due to sequestration for 2012-13 going into 2013-14. If granted, it would push the “once every three years” prohibition to 2013-14 going into 2014-15 allowing for greater flexibility in the use of carryover to cushion sequestration. The SCDE will be requesting comment from stakeholders prior to submitting the waiver.

12. Fiscal Moves to Consider Supplement, not Supplant: Testing for Presumptions of Supplanting: Is it required by the state, district, or another federal source? Are the same services provided for in non-Title I schools or students with (non-supplemental) state/local funds? Were these activities paid for in prior years with state/local funds?

13. Fiscal Moves to Consider Exclusion Rule - Similar activity (Schoolwide, TA) is funded in a non-Title school with supplemental funding, such as: State At-Risk Funding Palmetto Priority School Discretionary Grant Possibly, other funds that all schools are not eligible for.

14. Fiscal Moves to Consider Consolidation of federal funds in a Title I schoolwide project school. Consolidation of administrative funds from federal funds. If interested in exploring these fiscal moves, please contact us for more details on the pros and cons and the “how to.”

15. Fiscal Moves to Consider Transferability: Allows LEAS to transfer federal funds from one program to another. Funds that may be transferred include: Teacher Quality Title II, Part A, Education Technology Title II, Part D – subpart 1, Safe and Drug Free Title IV, Part A – subpart 1, and Innovative Programs Title V, Part A LEA must notify the SEA (30 days) but the authority to transfer is in the law.

16. Fiscal Moves to Consider These funds may be transferred within this cluster of funds. Funds may be transferred into Title I, Part A but may not be transferred out. Once the funding is transferred it becomes part of that program allocation (for that year) and is spent/reported according to the program guidelines.

17. Fiscal Moves to Consider Before transferring funds, an LEA must conduct consultations according to the guidance, determine which programs from which funds will be transferred and which programs will receive the funds, determine the amount and fiscal year, establish date of the transfer, modify affected program plans as needed, and notify the SEA (30 days). It is important to read the USDE guidance for details as the transfer of funds may affect set asides(parenting, private school, choice, and SES, etc.).

18. Fiscal Moves to Consider The fiscal moves may offer some flexibility for LEA’s that have lost funding. Always study the law and guidance. Always consult with your program office. The OFSA is willing to work with your district if you wish to explore any of these fiscal possibilities.

19. Questions

20. Contact Information Roy Stehle rstehle@ed.sc.gov 803-734-8118

21. Title VI Evelyn Towns Education Associate

22. Questions

23. Contact Information Evelyn Towns etowns@ed.sc.gov 803-734-8563

24. Title IIISupplement, Not Supplant Crystal Fields Education Associate

26. Allowable Expenses • Professional development for content teachers so that they may better serve ELLs in their classes • Paraprofessionals to assist ELLs in mainstream content classes • Additional hardware (listening stations, handheld translators, dictionary devices) • Additional software • Manipulatives • Additional reading materials (novels, magazines, newspapers, leveled readers) • Listening materials (Play aways, Books on CDs) • Visual aids (posters, pictures, flash cards)

27. Prohibited Title III Expenditures Include: • Salaries for teachers providing core instruction, or instruction in content areas for which students earn credit. • Translation and interpretation services for general and required school functions, including lunch menus, report cards. handbooks, NCLB-related parent notices, routine parent conferences, and IEP meetings and determination letters.

28. Prohibited Title III Expenditures Include: • Salaries for support staff providing transitional services for families, including registration and placement support. • Payment for teachers to attend LEP student meetings. • Purchase of computers for ESOL teachers; content teachers were provided computers with local funds. • Purchase of primary reading curricula. • Purchase of general office supplies and equipment, such as telephone installation.

29. Prohibited Title III Expenditures Include: • Consultants testing incoming kindergarten students. • Salary for an instructional coach who worked on schedules and helped content teachers arrange for test accommodations. • Title III-funded tutors and teachers who have the same job description as local and state-funded ESL and bilingual teachers. • A split-funded parent liaison whose job description does not differentiate between Title III and non-Title III activities

30. Translations • District personnel • Community (be cautious about confidentiality) • Local colleges and universities (stipend) • Translation companies

31. Supplanting --Travel Using state funds for ESOL teacher salaries while travel costs from one school to another were paid with Title III funds

32. Questions

33. Contact Information Crystal Fields cfields@ed.sc.gov 803-734-8306

34. Title II-A Updates Deborah Larkin Karen Cook

35. South Carolina’s Progress • The State reports > 97 percent of core academic classes taught by HQ teachers.

36. Improving Teacher Quality State Grants • 2012 - 2013 SOUTH CAROLINA $29,687,225.00 • 1 percent retained for SEA and SAHE administration The remaining 99% . . . • 2.5 percent set aside for SEA-administered State activities • 2.5 percent set aside for SAHE partnership grants • 95 percent reserved for LEA formula subgrants • $28,673,746.00 • 20% based on census data of ages 5-17 • 80% based on poverty

37. ESEA Flexibility and Title II - A • Waived • Requirements of §2141 • Improvement plans for Non-HQ Teachers • Employment of Title I Paraprofessionals

38. Not Waived • Highly qualified requirements for teachers of core academic subjects • Standards for Title I instructional paraprofessionals • Private school participation • Inclusion in planning before decisions are made • Equitable services under the programs towhich and from whichthe funds are transferred, based on the total available for each program after the transfer

39. Private Schools Calculations for “Hold Back” When Transferring Title II – A Funds • Divide the LEA “Hold Harmless” amount by the total number of students in public and private schools to determine a per pupil amount. • http://ed.sc.gov/agency/ac/Federal-and-State-Accountability/Title-II/documents/holdharmless.pdf • Multiply the per pupil amount by the private school enrollment for that school’s equitable funding. • “Hold back” the amount that will provide private schools with equitable participation. • There may be additional funding for private schools, depending on how monies are expended in the program to which Title II-A is transferred.

40. Title II – A Staff

41. Procedure for Claiming Title II Funds • No carryover • Two awards with partial simultaneous periods of availability, as 12TQ (7/01/11-6/30/13) and 13TQ (7/01/12-6/30/14) • Claims from 12TQ until exhausted • Claims from 13TQ if there are no funds in the appropriate accounting function in 12TQ • Claims from 12TQ and 13TQ simultaneously if 12TQ has insufficient funds to cover claim

42. Audit Procedures • Initial Contact • Fiscal Year 2012-13 • Those Involved in the Audit: • Title II contact • The person responsible for monitoring progress toward the goal of having 100 percent core academic classes taught by HQ teachers • Someone with fiscal responsibility

43. Be Aware of the Following…. • Travel for Non-Approved Employees • Food Purchases • CSR Teacher Consistency • CSR Teacher Salaries must supplement, not supplant • Consultant Services Rendered

44. After the District Visit • Opportunity for Clarification • Documentation • Audit Closes with Letter to Superintendent

45. QuestionsFeel free to contact us.

46. Contact Information Deborah Larkin dlarkin@ed.sc.gov 803-734-3454 Karen Cook kcook@ed.sc.gov 803-734-4040

47. Migrant Education NCLB Title I, Part C Jennifer Almeda Education Associate

48. SCMEP - Updates

49. An eligible migrant student : is younger than 22, has not graduated high school, nor has a GED; and has in the preceding 36 months moved : across school district lines, arrived from another state, or country; alone, with, or to join, a parent, spouse or guardian; in order to obtain (seek) qualifying agricultural work (see list on Web page). Many migrant students are eligible for McKinney-Vento Homeless and ESOL services.

50. Qualifying agricultural work can include activities related to: • Preparing/planting/picking/ packing/weeding crops • Nurseries • Sod farms • Livestock • Fishing/Seafood