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Maintenance of Effort & Comparability Report

Maintenance of Effort & Comparability Report. Teresa Scott Director-Grant Management Albuquerque Public Schools scott_teresa@aps.edu NM ASBO Fall Conference Los Vaqueros Room September 13, 2012 1:30pm – 3:00pm. Please silence electronic devices.

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Maintenance of Effort & Comparability Report

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  1. Maintenance of Effort & Comparability Report Teresa Scott Director-Grant Management Albuquerque Public Schools scott_teresa@aps.edu NM ASBO Fall ConferenceLos Vaqueros RoomSeptember 13, 20121:30pm – 3:00pm Please silence electronic devices

  2. Changing things from the Winter Conference From Technical Laws To Practical Use

  3. A Few Lawful Reminders Supplement not Supplant • State & Local expenditures for Students with disabilities must remain equal to or greater than the expenditures for same in the previous year in total or per capita (IDEA-B MOE) Demonstrating comparability is a prerequisite for receiving Title I, Part A funds. Because Part A allocations are made annually, comparability is an ANNUAL requirement. Handouts with more technical language provided.

  4. IDEA B Maintenance Of Effort

  5. Expense object to include • 53211 Diagnosticians – Contracted • 53212 Speech Therapists – Contracted • 53213 Occupational Therapists – Contracted • 53214 Physical/Recreational Therapists – Contracted • 53215 Psychologists/Counselors – Contracted • 53216 Audiologists – Contracted • 53217 Interpreters – Contracted • 53218 Specialists – Contracted • 53219 Special Ed Assistants (Non-Instructional) – Contracted

  6. Expense object to include • Job codes under the Object 51100, 51200, 51300 • 1311 Diagnosticians • 1312 Speech Therapists • 1313 Occupational Therapists • 1314 Physical/Recreational Therapists • 1315 Psychologists/Counselors • 1316 Audiologists • 1317 Interpreters • 1318 Specialists • 1319 Special Ed Assistants (Non-Instructional) • 1412 Teachers – Special Education • 1712 Instructional Assistants – Special Education

  7. Operational Accounts

  8. Title I Maintenance Of Effort

  9. Expenditures to include when determining maintenance of effort for title I In determining whether an LEA has maintained fiscal effort, an SEA must consider the LEA's expenditures from State and local funds for free public education. These include expenditures for administration, instruction, attendance and health services, pupil transportation services, operation and maintenance of plant, fixed charges, and net expenditures to cover deficits for food services and student body activities. [34 CFR 299.5(d)(1)] Functions 1000, 2xxx, 3xxx

  10. Expenditures to exclude when determining maintenance of effort for title I Expenditures for community services, capital outlay, debt service, or supplemental expenses made as a result of a Presidentially declared disaster are not to be included in the determination. In addition, any expenditures made from funds provided by the Federal government are excluded from the determination. [34 CFR 299.5(d)(2)] Functions: 4000 = Capital Outlay 5000 = Debt Service

  11. Title I Maintenance of Effort Figured at SEA Level If the LEA does not maintain effort, they will be notified by the SEA.

  12. Title I Comparability Report

  13. Comparability Report Section 1120A(c) of the ESEA provides that 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)]

  14. How often is this report done? Demonstrating comparability is a prerequisite for receiving Title I, Part A funds. Because Part A allocations are made annually, comparability is an ANNUAL requirement. Procedures for how to complete this should be kept on file at your district

  15. Criteria for Meeting Comparability Because the SEA is ultimately responsible for ensuring that LEAs comply with the comparability requirement, the SEA may establish the method a district uses to determine comparability NM PED requires Student/Instructional staff (FTE) ratios and Student/Instructional staff salary ratios The PED forms for preparation are on the PED WebEPSS site on line.

  16. Steps to preparing Title I Comparability Report • Step 1: • Determine the “break-out” or “spanning” of the schools • Schools can be split by grade and then by size • Split the Schools by Title I and Non-Title I • Fill out the Signature page with these determinations

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  18. Steps to preparing Title I Comparability Report • Step 2: • Prepare the calculation sheet for each Grade Span and each size (small/large) • In this example for APS there are 14 calculation sheets

  19. The 14 sheets 1. Grade Span A (K-5th) small schools 200 to 600 students non-Title I 2. Grade Span A (K-5th) small schools 200 to 600 students Title I 3. Grade Span A (K-5th) large schools 601 to 1001 students non-Title I 4. Grade Span A (K-5th) large schools 601 to 1001 students Title I 5. Grade Span B (6th-8th) small schools 300 to 800 students non-Title I 6. Grade Span B (6th-8th) small schools 300 to 800 students Title I 7. Grade Span B (6th-8th) large schools 801 to 1332 students non-Title I 8. Grade Span B (6th-8th) large schools 801 to 1332 students Title I 9. Grade Span C (9th-12th) small schools 138 to 232 students non-Title I 10. Grade Span C (9th-12th) small schools 138 to 232 students Title I 11. Grade Span C (9th-12th) large schools 1152-2269 students non-Title I 12. Grade Span C (9th-12th) large schools 1152-2269 students Title I 13. Grade Span X non-Title I District schools all operational allocations 14. Grade Span X Title I Charter schools all operational allocations

  20. Information to include on each sheet • All schools that fit the span (Do not include pre-K) • Total number of students that the school reported on STARS 40th day • Total number of low income students that the school reported on STARS 40thday • FTE for employees paid from State/Local funds (can exclude Special Ed paid staff) pulled on 40th day • Salaries for employees paid from State/Local funds (can exclude Special Ed paid staff) pulled on 40th day

  21. Non-title I School Sheet Sheet #9 Instructions: Please complete this page first if your district has public schools that do not participate in Title I. Then complete the "Title I Schools" Worksheet. Use SY 11-12 40th day data. Do not include Pre-K students. List only operational FTEs do not include FTEs that are paid for with non-operational funds such as Title I. If all schools in your district participate in Title I, then complete the "Title I Schools" worksheet only. 9. Grade Span C (9th-12th) small schools 138 to 232 students non-Title I

  22. Title I School Sheet Sheet #10 Instructions: Please complete the table below for all Title I schools. Use SY 11-12 40th day data. Do not include Pre-K students. List only operational FTEs. If your district has schools that do not participate in Title I then make sure the "Non-Title I Schools" worksheet is completed FIRST. After completion the comparability formula will be pre-populated and auto-calculated. Choose one comparability measure, either Measure 7B or 8B (highlighted in green) in the Comparability Formula Option I and apply it consistently for each Title I School. If all schools in the district participate in Title I then complete the table below and choose Comparability Formula Option 2. Once the data is entered, the comparability measures will be auto- calculated and will appear in the green highlighted boxes. Choose one measure and apply it consistently for each Title I School. Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed. 10. Grade Span C (9th-12th) small schools 138 to 232 students Title I Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed.

  23. Steps to preparing Title I Comparability Report • Step 3: • The PED created sheets will auto fill the calculations once the data has been entered. • Go through each line of the Title I Pages to be sure that each school is in compliance. • To be comparable you may only choose one method of comparability, either by FTE or salary not a combination.

  24. Title I School Sheet Instructions: Please complete the table below for all Title I schools. Use SY 11-12 40th day data. Do not include Pre-K students. List only operational FTEs. If your district has schools that do not participate in Title I then make sure the "Non-Title I Schools" worksheet is completed FIRST. After completion the comparability formula will be pre-populated and auto-calculated. Choose one comparability measure, either Measure 7B or 8B (highlighted in green) in the Comparability Formula Option I and apply it consistently for each Title I School. If all schools in the district participate in Title I then complete the table below and choose Comparability Formula Option 2. Once the data is entered, the comparability measures will be auto- calculated and will appear in the green highlighted boxes. Choose one measure and apply it consistently for each Title I School. These FTE have to be less than the average below These Amounts have to be more than the average below OR Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed. Averages for non-title I schools entered automatically after "Non-Title I Schools" worksheet is completed.

  25. Steps to preparing Title I Comparability Report • Step 4: • For any school that is not comparable, journal entries or adjustments in staff must be made to bring the school into comparability. • The forms supplied for completion by the PED are to be uploaded to PED WebEPSS on a yearly basis. Due dates and notification will be established by PED. • All documents including the documents pulled to obtain the backup for the amounts used, are to be kept in the district (Charter) for a minimum of 3 years after release of auditor’s report for audit purposes.

  26. Helpful links • Code of Federal Regulations: • http://cfr.vlex.com/source/code-federal-regulations-34-education-1083 • Policy Sec 9521. Dept of Ed “Maintenance of Effort” (ESEA-NCLB) • http://www2.ed.gov/policy/elsec/leg/esea02/pg112.html • State MOE submission for Ed Job funds (PDF): • http://www2.ed.gov/programs/educationjobsfund/submissions.html • Policy Sec 5141 Maintenance of Effort: • http://www2.ed.gov/policy/elsec/leg/esea02/pg61.html • Title I Fiscal Issues: • http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf

  27. Questions? Thank you!!!

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