Federal Programs

1. Federal Programs Coordinator Session TuesdayBon Secour BR 1

2. Things are Awesome in Federal Programs…!

3. What Exactly Does A “Federal Programs” Coordinator Do? Provides oversight of federal funds and…. • Leads the development of the district and school needs assessments • Coordinates the development of plans to meet identified needs • Facilitates the development of budgets to support the plans • Ensures compliance with federal rules and regulations by monitoring and evaluating the implementation of plans and - • Other duties as “assigned…..”

4. How do you do all you are required to do? • Just like in sports - it takes teamwork… Let’s Meet Your ALSDE Team:

5. ALSDE STAFF Introductions

6. Pass the Torch!

7. How Do You Kick Off the Year? • Work with Central Office Leaders and School Faculties to identify the needs of the system. • Lead discussions on how funds can be effectively leveraged to meet the needs in the best possible way. • Plan for evaluating the effectiveness after applying funds to needs

8. Suggestions for Planning • Based on needs, develop goals that are… • S - specific • M - measurable • A - attainable • R - related to student achievement • T - time bound • Identify effective strategies to meet goals. • Develop action steps that provide DETAILED information regarding planned uses of funds. • Include realistic baseline data as part of performance measures (“From…to…”).

9. Work with Key Players - CSFO Provides oversight of federal funds by …. • Collaborates with Federal Programs coordinator on fund allocations. • Coordinates development of planning and budgets among all program coordinators. • Ensures all funds budgeted/spent as allowed by law also match information in the Electronic Grant Application (eGAP). • Adheres to LEA Financial Assistance rules for requesting timely reimbursement of federal funds.

10. Key Player – The Superintendent • Is ultimately responsible for all system budgets. • Makes the final decisions based on sound advice from - You! • Clicks the “Assurances” Page in eGAP.

11. You - Work to Coordinate With Other Sections… • Special Education • Career Technical Education • Reading, Science, Math Coaches

12. Figure Out the Game Plan… • eGAP • Consolidated Application • Title I, Parts A, C, D, • Title II, Part A • Title III, Part A • Title V, Part B-subpart 2 • Competitive/Separate Grants • 21st Century Community Learning Centers • Homeless Education

13. Current Resources for the Management of Federal Funds • Title I Fiscal Issues Guidance • Maintenance of Effort • Comparability • Supplement, Not Supplant • Carryover • Consolidating Funds in Schoolwide Programs http://www.ed.gov/programs/titleiparta/fiscalguid.doc • SDE Web Site (www.alsde.edu; click on eGAP button; click on Document Library; scroll down) • Report Manager Electronic System • Professional Learning Sessions this week • Your TAG Team Specialist

14. What is Maintenance of Effort (MOE)? • SDE reviews MOE annually • LEAs not meeting requirements will be notified by LEA Accounting

15. What is Comparability? • LEAs review annually • Prerequisite for receiving Title I funds • LEAs should report to SDE : • City Systems – in years ending with odd numbers • County Systems – years ending with even numbers • New form can be found in eGAP

16. An LEA may receive Title I, Part A funds only if it uses State and local funds to provide services in Title I schools that, taken as a whole, are at least comparable to the services provided in schools that are not receiving Title I funds. • If the LEA serves all of its schools with Title I funds, the LEA must use State and local funds to provide services that, taken as a whole, are substantially comparable in each Title I school. [Section 1120A(c)]

17. Meeting Comparability Under the statute, an LEA is considered to have met the comparability requirement if the LEA files with the SEA a written assurance that it has established and implemented a— • District-wide salary schedule; • Policy to ensure equivalence among schools in teachers, administrators, and other staff; and • Policy to ensure equivalence among schools in the provision of curriculum materials and instructional supplies. [Section 1120A(c)(2)(A)] An LEA may also meet the comparability requirement if it establishes and implements other measures such as— • Student/instructional staff ratios; • Student/instructional staff salary ratios; • Expenditures per pupil; or • A resource allocation plan based on student characteristics such as poverty, limited English proficiency, or disability, etc.

18. * In order to be comparable, the student/instructional staff ratio for each Title I elementary school may not exceed 14.1. (12.8 x 1.1) (Non-Reg Fiscal Guidance pg.19)

19. Supplement Not Supplant The SNS test under ESSA: • Focuses on and requires demonstration of the local education agency’s (LEA’s) methodology used to allocate Foundation Program and local funds (non-Federal) to each school receiving Title I assistance • Ensures that it is receiving the same amount it would have received regardless of whether the school received Title I assistance.

20. ARE SNS REQUIREMENTS THE SAME AS COMPARABILITY REQUIREMENTS? No. • Comparability requires that Foundation Program and local funds are used to provide services that, taken as a whole, are comparable between Title I and non-Title I schools. • SNS requires LEAs to distribute Foundation Program and local funds to schools without taking into account a school’s participation in the Title I program. • Though the source of funds for both fiscal tests are similar (i.e. Foundation Program and local funds), situations may occur where the LEA satisfies the requirements within one while failing those of the other.

21. Supplement not Supplant • This stipulation does not mean that districts must allocate the same resources to all schools. Allocations might vary for a variety of reasons. • grade spans • size • educational programming • student characteristics • other factors • The key for SNS compliance is to ensure that any variations in allocations are not due to a school’s participation in Title I.

22. Supplement not SupplantDemonstration Process ALSDE is responsible for verifying that each LEA is in compliance with the demonstration requirements regarding SNS under ESSA. To ensure all LEAs in Alabama meet these requirements, each LEA will be required to submit the following: • An assurance stating the LEA is in compliance with the provisions of section 1118(b) of ESSA; • An indication of the type of methodology the LEA has adopted and is implementing in regard to the allocation of Foundation Program and local funds (non-Federal) to all schools; and, • A narrative description of the methodology or a reference to the LEA’s Financial Transparency document in which the methodology is described.

23. Supplement not SupplantDemonstration Process The LEA is required to provide the demonstration requirements to ALSDE one time for the duration of the Title I, Part A program under ESSA, unless the LEA adopts or implements a revised methodology for allocating Foundation Program and local funds (non-Federal) resources.

24. Supplement not SupplantDemonstration Process • LEAs that have a single school code (i.e. Elementary, Middle and High School levels all have the same school code or Charter School) are required to submit an assurance, but need not provide additional demonstration requirements. • These LEAs should select the appropriate box on the demonstration template and return it to ALSDE.

25. Supplement not SupplantDemonstration Process (Timeline) ALSDE has implemented the following timeline with regard to the SNS requirements: • LEAs will demonstrate compliance with the SNS requirements by September 13, 2019 through the demonstration process outlined above IF CHANGING METHODOLOGY. • LEAs that are unable to meet the demonstration requirements through the process will alternatively submit a plan by September 13, 2019 detailing how the LEA intends to come into compliance.

26. Supplement not SupplantDemonstration Process (Timeline) The LEA’s eGAP will not be approved until the ALSDE is able to verify the LEA is in compliance with the demonstration requirements.

27. Comparability and Supplement, Not Supplant While comparability and supplement not supplant requirements both examine how the LEA distributes Foundation Program and local funds and/or resources to schools, they are separate tests and are intended to measure different aspects of the supplemental nature of Title I, Part A funds. As such, the demonstration requirements for comparability may not be used to meet the demonstration requirements for supplement, not supplant, or conversely. The following examples provide scenarios where LEAs may satisfy the requirements of one while violating the requirements of the other.

28. Comparability and Supplement, Not Supplant Example: Supplement, Not Supplant compliance is met, but Comparability is violated The LEA demonstrates compliance with supplement, not supplant because it can demonstrate that it did not consider the Title I status of schools when distributing Foundation Program and local funds to schools; however, the LEA does not satisfy comparability requirements because the LEA’s non-Title I schools have lower student/ instructional staff ratios than its Title I schools.

29. QUESTIONS ABOUT COMPARABILITY OR SUPPLEMENT NOT SUPPLANT Federal Programs Regional Specialist 334-694-4516

30. General InformationAdministrative Costs • Title I Cap of 15% (Admin plus Indirect Costs) • Title II Cap of 5% • Title III Cap of 2% • Title V Cap of 5%

31. Federal Cost Principles • Uniform Guidance (2 Code of Federal Regulations CFR) part 200) • Consolidates Eight Existing OMB Circulars • Emphasis on Performance • Strengthening Oversight • Targeting Waste, Fraud, Abuse

32. Also known as the…Super Circular • Internal controls • Oversight including risk assessment for monitoring plans and tools • Performance expectations and results

33. What does reasonable and necessary” mean? • Expenditure necessary for the performance or administration of the grant • Purchaser follows sound business practices • Object or service obtained at a fair market price

34. Be Practical Practical tests of “reasonable-ness”: • Is the expense targeted to valid programmatic/administrative considerations? • Do I have the capacity to use what I am purchasing? • If I were asked to defend this purchase, would I be comfortable? Practical tests of “necessary”: • Do we really need this? • Is this the minimum amount I need to spend to effectively meet the need?

35. Implementation… Follow the guidelines and regulations for all programs, for example: • Parental Involvement – Parents Right-to-Know, Home/School Compacts, etc. • English Language Learners • Migrant • Homeless • Neglected and Delinquent

36. Carryover Notes • Schools do not “earn” carryover. • Three options for the use of Title I carryover: • Disburse carryover funds to schools; use a set formula to allocate funds to schools with the highest concentration of poverty, thus providing a higher per-pupil amount to those schools, OR… • Provide additional funds to any of the activities supported by the reservations for district-wide initiatives already approved in eGAP on the Title I Set Aside Page, OR… • BOTH!

37. Federal Programs 101

38. THE PYRAMID OFFEDERAL RULES Letters and Press Releases Issued by ED

39. STATUTES… Dictate: • How funds are generated • How funds must be allocated • Who is eligible to be served • How the program must be designed • What uses of funds are permissible • What types of reports or evaluations are required

40. Statutes…For example… ESEA- Elementary and Secondary Education Act now (ESSA) IDEA- Individuals with Disabilities Education Act

41. Regulations…For example… • Uniform Guidance (2 Code of Federal Regulations (CFR) part 200)

42. PURPOSE OF NON-REGULATORY GUIDANCE • Non-Regulatory Guidance is used by the U.S. Education Department to provide informal advice to grantees and sub-grantees regarding education requirements. • Guidance does not carry the “force of law.”

43. Letters and PRESS RELEASES ISSUED by the U.S. Department of Education (USED) The USED issues “Dear Colleague” letters and press releases to notify states and districts about policy changes or clarifications regarding federal law.

44. Every Student Succeeds Act (ESSA) Federal Programs Alabama State Department of Education

45. The Every Student Succeeds Act (ESSA) - signed on December 10, 2015 • Reauthorizes the 50-year-old Elementary and Secondary Education Act (ESEA), the nation’s national education law and longstanding commitment to equal opportunity for all students.

46. Title I-A Funding and Set-Asides • ESSA keeps 1% cap on State administrative funds • Totals for both Administrative and Indirect Costs are both no more than 15% of the total Title I allocation

47. Title I-A Within-District Allocations • An LEA’s ranking and serving of schools occurs after the LEA has first allocated Title I-A funds for equitable services and then made required reservations for public school students (e.g., reserving funds to provide services to homeless student in non-Title I schools). (ESSA section 1011(4)(A)(ii).) (ESEA section 1117(a)(4).) • Exception to the ranking and serving requirement for high schools. (ESSA section 1007 (3)(B).) (ESEA section 1113(a)(3)(B).) • Option for an LEA to use a feeder pattern to determine the poverty percentage of a secondary school for ranking and serving. (ESSA section 1007(5)(B)(ii).) (ESEA sections 1113(a)(5)(B) and (C).)

48. Title I Within-District AllocationsOverview of Continuing Requirements Section 1113 (a) (3) • The general ranking and serving requirements from the ESEA, as amended by the No Child Left Behind Act (NCLB), remain in the ESEA, as amended by the ESSA. • These requirements include: Ranking schools by their percentage of children from low-income families: • Serving schools above 75% in rank order of poverty without regard to grade span; and • Basing school eligibility on a school having a poverty rate that is at least as high as the LEA’s poverty rate or 35%, whichever is lower; • Ensuring that a higher-poverty school receives at least as much per child as a lower-poverty school.

49. Equitable Services to Private SchoolsSection 1117

50. Title I Equitable Services Highlights • Ombudsman • Funding Title I Equitable Services • Consultation • New SEA Compliance Role