Presented by Larry Fazzari Petrea Stoddard 1. 34 Code of Federal Regulations (CFR) Section 76...

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Transcript of Presented by Larry Fazzari Petrea Stoddard 1. 34 Code of Federal Regulations (CFR) Section 76...

Presented byPresented by

Larry FazzariLarry Fazzari

Petrea StoddardPetrea Stoddard

1

34 Code of Federal Regulations (CFR) Section 76

State-Administered Programs Changes To iGrants 2011-2012 Anatomy of the iGrant Applications

Title I, Part A and Learning Assistance Program (LAP)

Consolidated Program Review (CPR) Most Common Non-Compliance Issues

Resources and Links

Title I, Part A/LAP Spring Training Agenda

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34 Code of Federal Regulations (CFR) Section

76

State-Administered Programs

3

Getting EDGAR

Education Department General Administrative Regulations (EDGAR)

http://www.ed.gov/policy/fund/reg/edgarReg/edgar.html

Section 76http://www.access.gpo.gov/nara/cfr/waisidx_10/34cfr76_10.html

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34 CFR § 76State Administered Programs

Subpart A—General Subpart B—How a State Applies for a Grant Subpart C—How a Grant is Made to a State Subpart D—How to Apply to the State for a Subgrant Subpart E—How a Subgrant is Made to an Applicant Subpart F—What Conditions Must Be Met By the State and

Its Subgrantees Subpart G—What Are the Administrative Responsibilities

of the State and Its Subgrantees Subpart H—How Does a State or District Allocate Funds to

Charter Schools Subpart I—What Procedures Does the Secretary Use to

Get Compliance

34 CFR Part 76Subpart A-General

76.1– Definition—State Formula Grant—a program whose

authorizing statute or implementing regulations provide a formula for allocating program funds among eligible states

– Regulations• Program implementation regulations, if available • Authorizing statute consistent with General Education

Provisions Act (GEPA)• Regulations in 34 Part 76

– Applies to all state-administered United States Department of Education (ED) programs

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34 CFR Part 76Subpart A-General

76.2—Exceptions to this part Will be identified in the implementing

regulations of individual programs If not identified in program’s implementing

regulations, 34 CFR provisions apply

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34 CFR Part 76Subpart A-General

76.50—Eligibility ED Secretary makes grant to appropriate state

agency- usually the Office of Superintendent of Public Instruction (OSPI)

Authorizing statute determines extent Grant used directly by OSPI Passed to eligible districts

76.52—Distribution (competitive, formula, or both) Dictated by program statute

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34 CFR Part 76Subpart A-General

76.52—Eligibility of faith-based organizations Apply for and receives on same basis with other

private organizations State may not discriminate (same basis)

Religious activities must be offered at separate time/location

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34 CFR Part 76Subpart D-Application

• 76.300—Contact State for Procedures– Most are available in iGrants

• 76.301—District Application (iGrants)– Must meet section 422 of GEPA

• 76.302—Notice to districts– Amount-iGrants– Period of obligation-iGrants– Requirements of grant

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34 CFR Part 76Subpart D-Application

76.303—Joint applications and projects If permitted by state May not exceed formula amount for those

included Follow requirements Accounting system must permit identification of

costs of grant

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34 CFR Part 76Subpart D-Application

76.304—District to make application available to public (includes private schools) Includes

Application Evaluation Periodic program plan Report related to program

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34 CFR Part 76Subpart E-Application

• 76.400—State procedures for reviewing an application– OSPI must review applications– Entitlement programs approved if• Applicant eligible, AND• Meets federal requirements and statutes of program

– Discretionary programs approved if• Applicant eligible• Applicant meets federal statutes and regulations• State determines project submitted should be funded

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34 CFR Part 76Subpart D-Application

• 76.401—Disapproval of application—opportunity for hearing– Programs for which district may request hearing

before state disapproves application• Title I, Part A• Title I, Part D• Title II, Part A• IDEA, Part B• IDEA, Section 619• Title III

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34 CFR Part 76Subpart F-Conditions

• 76.500—Federal statutes and regulations on nondiscrimination– Must comply with • Nondiscrimination on the basis of race, color or

national origin (34 CFR Section 100)• Nondiscrimination on the basis of sex (34 CFR

section 106)• Nondiscrimination on the basis of handicap (34 CFR

section 104)• Nondiscrimination on the basis of age (34 CFR

section 90)15

34 CFR Part 76Subpart F-Conditions

76.530—General cost principles 34 CFR 74.27 and 74.34 34 CFR 80.22

76.532—Prohibits using funds for religion Specifically prohibited

Religious worship, instruction, proselytization Equipment or supplies for above Construction, remodeling, repair, operation, or

maintenance of facilities used for above purposes

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34 CFR Part 76Subpart F-Conditions

76.533—Acquistion of real property; construction Not allowed unless specifically permitted by

authorizing statute or implementing regulations

76.534—Tuition and fees May not be used to meet matching, cost sharing

or maintenance of effort requirements of a program

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34 CFR Part 76Subpart F-Conditions

76.560-.561—Indirect cost rates Governed by 34 CFR Section 80.22 which

specifies OMB Circular A-87 should be followed Must have current indirect cost rate agreement

to charge indirect costs to a grant School Apportionment and Financial Services has

such an agreement and calculates these on behalf of districts based F-196

Incorporated into iGrants

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34 CFR Part 76Subpart F-Conditions

76.563—Restricted indirect cost rate Must be used for all programs with statutory

requirement prohibiting use of federal funds to supplant non-federal funds

76.564-569—Formula for indirect cost rate SAFS computes this based upon data in the F-196 See also Accounting, Budgeting and Financial

Reporting at http://www.k12.wa.us/safs/INS/ABF/1011/10-11_Ch02.pdf#Indirect_Rates

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34 CFR Part 76Subpart F-Conditions

76.580—Coordination with other activities Coordinate each project with other activities that

are in the same geographic area served by the project and that serve similar purposes and target groups

76.591-.592—Districts to cooperate during federal evaluations

76.600—Construction regulations Must be followed if authorizing statute permits

use of funds for this purpose20

34 CFR Part 76Subpart F-Conditions

76.650-.677—Private School Participation Follow if authorizing statute requires

76.651—Responsibilities Equitable participation District retains administrative direction and

control over funds and property used to benefit private school students

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34 CFR Part 76Subpart F-Conditions

76.652—Consultation with Private Schools Consult with representatives of students during

all phases of development and design of program and provide a genuine opportunity for input. Include- Which children will receive benefits How needs of children identified What benefits provided How benefits provided How program evaluated

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34 CFR Part 76Subpart F—Conditions

76.653—Needs, number of students, and types of services Comparable to public school students

76.654—Benefits for private school students Comparable in quality, scope, and opportunity

to participate

76.656—Level of expenditures for private school students Same average amount

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34 CFR Part 76Subpart F-Conditions

76.656—Application requirements Description of services provided to private

schools Number of private school students eligible Number of private school students served Basis of selection Places and times of services Differences between services in private and

public schools and reasons for differences

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34 CFR Part 76Subpart F-Conditions

76.657—Separate classes prohibited If at same site and contain both public and

private school students

76.658—Funds not to benefit private school Cannot finance existing level of instruction or

benefit private school Program to meet specific needs of eligible

students

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34 CFR Part 76Subpart F-Conditions

76.659—Use of public school personnel May be used to provide equitable program

benefits to private school students only if not normally provided by private school

76.660—Use of private school personnel May use program funds only if services

performed outside regular hours of duty and under the public school supervision and control

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34 CFR Part 76Subpart F-Conditions

76.661—Equipment and supplies If permitted by program, public school keeps

title Placed only for time needed for program Used only for program Can be removed without remodeling Removed if no longer needed for program or

needed or to prohibit use for other than program purposes

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34 CFR Part 76Subpart F-Conditions

76.662—Construction Program funds cannot be used for construction of

private school facilities

76.670-.677—Bypass Secretary may waive requirements for providing

services to private school children for certain programs; requires filing, notice and hearing

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34 CFR Part 76Subpart F-Conditions

76.681—Protection of human subjects

76.682—Treatment of animals

76.683—Facility health or safety

standards

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34 CFR Part 76Subpart G—Administrative

Responsibilities

76.700—Comply with statutes, regulations, state plan and applications

76.701—State administers and supervises

76.702—Fiscal control and fund accounting procedures Must insure proper disbursement and accounting

76.703—When State may obligate funds

76.704—State plans

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34 CFR Part 76Subpart G—Administrative

Responsibilities 76.707—When obligations are made

If the obligation is for When obligated

Personal services by employee

When services performed

Non-employee services Date of written commitment

Non-personal service work

Date of written commitment

Public utility services When services received

Travel When travel taken

Rental of real or personal property

When property used

Real or personal property Date of written commitment

34 CFR Part 76Subpart G—Administrative

Responsibilities

76.708—When obligation of funds begins Formula grants, later of

Date state may begin obligation Date application submitted in substantially

approvable form Subject to final approval of application State may approve pre-agreement costs

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34 CFR Part 76Subpart G—Administrative

Responsibilities

76.709—Obligation during carryover period Funds not used during year for which

appropriated or carryover period shall be returned to the federal government

76.710—Obligations during carryover period subject to statutes, regulations and applications

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34 CFR Part 76Subpart G—Administrative

Responsibilities

76.711—Identification by CFDA number Found on grant award notification Catalog of Federal Domestic Assistancehttp://cfda.gov

Find Department of Education CFDA numbers at www.cfda.gov

https://www.cfda.gov/?s=agency&mode=form&tab=program&id=c501e7fcea3b41e870f21a02a5c4f5db

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34 CFR Part 76Subpart G—Administrative

Responsibilities

76.720—State financial and performance reports

76.722—District reports required by OSPI OSPI may require district to submit reports to

enable the agency to meet its reporting responsibilities

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34 CFR Part 76Subpart G—Administrative

Responsibilities

76.730—Records related to grant funds Must keep records that show

Amount of grant funds Use of grant funds Total cost of program Share of program cost from other sources Other records to facilitate an effective audit

76.731—Records related to compliance Must keep records showing program compliance

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34 CFR Part 76Subpart G—Administrative

Responsibilities

76.740—Protection of and access to student records; student rights in research, experimental programs and testing Records governed under GEPA section 438; 34

CFR part 99 Research, testing and experimentation

governed under GEPA section 439; 34 CFR part 98

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34 CFR Part 76Subpart G—Administrative

Responsibilities

76.770—State shall have procedures to ensure compliance Reviewing and approving applications and any

amendments Providing technical assistance Evaluating Other as necessary to ensure compliance

76.783—District may request hearing

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Changes to iGrants2011-12

FP 201—Title I, Part AFP 218—LAP

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Page 2—Assurances no longer need to be mailed to

OSPI Page 3—Added new page-Affirmation of Consultation

with Private School Officials Upload one for each participating private school

Page 4—District Plan (formerly Page 3) pre-populated-Be sure to UPDATE for current information

Page 5—Allocations and Set Asides (formerly Page 4) shows 20% and 10% amounts

Page 6—Public Schools (formerly Page 5) shows total low income and enrollment (compare to Page 5)

Page 7—Private Schools (formerly Page 6)

Title I, Part A iGrant FP 201 Changes

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New Activities Added, Effective 2011-12 31—Instructional Professional Development 32 –Instructional Technology

iGrant Budget ChangesNew Activities

41

Used for the additional costs relating to

instructional professional development of school district personnel

Focus on extra costs: Travel Registration fees Payments to vendors for training Tuition reimbursement Substitute costs Other related costs

iGrant Budget ChangesActivity 31

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Salary costs:

Base salaries for attendees are not coded to this activity.

Assigned professional development staff base salaries may be coded here.

Contracted extra duty days for the express purpose of professional development may be coded here.

Direct-charged extra time related to professional development may be charged here.

Open in all programs EXCEPT 97,98,99.

iGrant Budget ChangesActivity 31

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Primary use is for recording General Fund

expenditures for computers and related equipment that is based in the schools.

General software that is installed on all school-based computers may be charged here. (For example, Microsoft Office.)

Computer-based curriculum (digital textbooks, educational software) should not be coded here. Use Activity 27.

iGrant Budget ChangesActivity 32

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Salary costs

Salaries and benefits for staff members whose assignment supports instructional technology may be charged here.

Districtwide technology support, IT department, Help Desk, etc., should not be charged here (Program 97, Activity 72).

Allowable objects 0,3,4,5,7,8,9. (Not object 2)

iGrant Budget ChangesActivity 32

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Charging of an IT person who also teaches

Split-code Portion of time teaching should be coded to

Activity 27-2 (certificated) Portion of time related to instructional technology

should be coded to Activity 32-3 (classified)

iGrant Budget ChangesActivity 32

46

Title I, Part A ARRA, FP 482—Eliminated

Note: All Title I, Part A ARRA funds must be obligated by September 30, 2011

Title I, Part AiGrant 482/ARRA Changes

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Anatomy of the Applications

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Title I, Part A

iGrant FP 201

49

Substantial approval

Page 1

50

June 1, 2011 District deadline to submit a substantially

approvable status (SAS) request to ensure notification by July 1. (Applies to all programs except for Special Education.)

June 2011 Throughout June districts are notified of

substantially approved status.

Substantially Approvable Status

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Assurances

Page 2

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Be sure date is current.

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Affirmation of Consultation with Private Schools

Page 3

56

57

District Program Plan

Page 4

58

59

Allocation/Set Asides

Page 5

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61

To Page 6

62

Section ARequired Set Asides

Required Set Asides (Section A, Page 5, iGrants) Parent Involvement [1118(a)(3)]

At least 1% if allocation more than $500,000 Homeless [1113(c)(3)(A); 1115(b)(3)]

Amount needed to serve homeless children who do not attend participating Title I, Part A schools

Neglected [1113(c)(3)(A); 1115(b)(3)]

Amount needed for neglected children placed in the care of individuals or facilities by DSHS

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Section ARequired Set Asides

Required Set Asides (Section A, Page 5, iGrants) Equitable Services to Private School Students of

eligible, participating private schools Equitable services to students (Page 7, individual) Equitable services to parents (parent involvement,

Page 5) Equitable services to teachers (professional

development, Page 5)

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95% remains in amount to allocate to buildings

5% is deducted from allocation

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Section BRequired Set Asides

Required Set Asides with Schools in School Improvement Transportation for Public School Choice (PSC)

(Step 1 and above) and Supplemental Educational Services (SES) (Step 2 and above) [1116(b)(10)(A)] Must equal 20% of district allocation

Minimum 5% for transportation for PSC, if needed Minimum 5% for SES, if needed Remaining 10% for either or both

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Section BRequired Set Asides

Required Set Asides with Schools in School Improvement (continued) To release unneeded amounts for other

allowable uses Meet all conditions (L-1 of SES Non Regulatory

Guidance) Submit FP 557 and receive OSPI approval Request and make application revisions to

reallocate

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Enter amount needed (up to 5%)

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Amount needed to equal 20%

Enter funding source. Amount will deduct.MUST be used if needed.

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Section CRequired Set Asides-Schools

Required Set Asides with Schools in School Improvement Professional development to address cause of

identification for school improvement [1116(3)(A)(iii)] 10% of building allocation May be part of district professional development

set aside if district is in Step 1 or above of improvement for building principal and teachers

Enter on Page 6

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Section CProfessional Development

• Required Set Asides with Districts in District Improvement– 10% of district allocation [1116(c)(7)(A)(iii)] for

district instructional staff

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Optional Set Asides

Summer school and/or extended day programs Preschool On-going professional development for

instructional staff—can be used to enable staff not meeting highly qualified to do so

Additional parent involvement Other

Should be small amount Must be defined

Title I, Part ARequired Set Asides

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Must equal amount allocated on Page 6

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75

Equitable Share

Minimum amounts of total

Total

76

Must be at least 100 in this example

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Public School Breakdown

Page 6

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Allocations to Buildings

Rank order all buildings according to poverty percent (usually based on free and reduced lunch percentage)

Must serve buildings over 75% in FTE order Then rank and serve by grade span or districtwide Can reach buildings down to 35% If district average is lower than 35%, can reach

buildings down to district (or grade span) average but must allocate at least 125% of district per pupil amount to every building in the rank order

Buildings with higher poverty must have per pupil allocation of at least as much as one with lower poverty

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Allocations to Buildings

Districts with enrollment of less than 1000 students or districts with only one building per grade span are not required to rank order their buildings

A building which was both eligible and served the prior year may be served an additional year even if not otherwise eligible

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MUST be equal

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New

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Individual Building Page

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Private School Breakdown

Page 7

84

Must be equal

Should approximate

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Needed for any school indicating intent to participate in Title I, Part A

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87

88

LAP

FP 218

89

90

New

91

Only grades 11 and 12

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93

94

Cannot be greater than allocation less indirects

95

Title I, Part A End of Year Report—Regular

Year

iGrant FP 244

96

Note: dates will change to September 1, 2010 throughJune 30, 2011

97

Must equal

98

Total number of buildings receiving Title I,

Part A funds in which Corrective Action was implemented. Of the above, buildings enter the number of

buildings implementing each type of corrective action Required implementation of a new research-

based curriculum or instructional program Extension of the school year or school day Replacement of staff members relevant to the

school’s low performance

Title I, Part A End of ReportAdditional Questions—Page 4

99

Corrective action (cont’d)

Significant decrease in management authority at the school level

Replacement of the principal Restructuring the internal organization of the

school Appointment of an outside expert to advise the

school

Title I, Part A End of ReportAdditional Questions—Page 4

100

Total number of buildings receiving Title I, Part A

funds implementing restructuring actions under ESEA Of the above buildings, enter the number of schools

implementing each type of restructuring action Replacement of all or most of the school staff (which

may include the principal) School closure Entering into a contract with a private entity to

operate the school Other major restructuring of the school, please

describe

Title I, Part A End of ReportAdditional Questions—Page 4

101

Was the District required to implement

corrective action? (Yes/No) If yes, indicate which corrective action was

implemented Implemented a new curriculum based on state

standards Authorized students to transfer from district schools

to higher performing schools in a neighboring district

Deferred programmatic funds or reduced administrative funds

Title I, Part A End of ReportAdditional Questions—Page 4

102

Replaced district personnel who are relevant to the

failure to make AYP Removed one or more schools from the jurisdiction

of the district Restructured the district

Title I, Part A End of ReportAdditional Questions—Page 4

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LAP End of Year Report—Regular Year

iGrant FP 245

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105

Common Errors

106

Page 1: Request SAS/indicate yes or no Page 2: Assurances signed and current Page 3:

Question B: Student achievement data/current assessment data-trend over

timeAnswer all questions completelyAnswer the question ASKED

Page 4: A2-Homeless Set AsideA4A-Set Aside-Private Schools/in districtA4B-Set Aside-Private schools/out of district

Title I, Part AMost Common Errors-iGrant 201

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Page 4: B1-4 School Identified in

ImprovementC-District identified for improvementD1-Administration of public and private schools-include indirect from budgetAmount available to public school buildings-must match page 5-buildings allocationAmount to public school page must match total on page 4

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Page 5: Complete all boxes for each building

BasisPPE-based on pct. low income-in rank

order Budget: FTE-Complete boxes at bottom of

budget page for Teaching/27-2 (Cert.) 27.3 (Class.) and Supervision/27.2 (Cert.) 27.3 (Class.)

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200/Carryover Calculation 201/Regular Year Application 244/Regular Year/EOY 246/Regular Year/EOY/Summer School 335 /Reallocation 361/Comparability 508/Waivers Request 557/Reauthorization of Choice/SES Set Aside

Title I, Part A iGrant Form Packages

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218/Regular Year Application 245/Regular Year/EOY Report 247/Regular Year/Summer School/EOY Report 418/Carryover Authorization

LAP iGrant Form Packages

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Page 1: A-Brief description of LAP program Page 1: B: District assessment/data trends

for prior three years Page 1: #2: Process to identify students

served with LAP Page 1: #8-Extended learning opportunities

for 11th and 12th grade students

LAP iGrant 218Application Common Errors

112

Page 2: Allowable expenditures-all six

allowable expenditure plus indirect from budget equals total LAP allocation.

Page 3: Student information-head count/content count

Public School Page: Complete all building boxes

Budget: FTE-Complete boxes at bottom of budget page [Teaching/27-2 (Cert.) 27.3 (Class.) and Supervision/21.2 (Cert.) 21.3 (Class.)]

LAP iGrant 218Application Common Errors

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Title I, Part A

Application Revisions and Carryover

114

May only be completed when application has

received final approval Send iGrant email requesting needed pages to

be unlocked Provide brief reason for request Example:

Revise SES and choice once all parental requests are received

Application Revisions

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ESEA §1127

Less than $50,000—No limit Over $50,00—Limited to 15% of allocation

May request waiver no more than once every three years if- Request is reasonable and necessary or Supplemental appropriations become available

Waiver for districts needing waiver due to ARRA funds can be used for 2010-11 funds into 2011-12 (One-in-three year clock starts when last waiver requested)

Carryover-Title I, Part AiGrant FP 200, Budget Revision 201

116

Carryover due to required set asides must be

used for those purposes. Examples: Parent involvement Professional development SES and PSC Private schools Homeless Neglected

Consider effect on rank order in buildings

Considerations For Use of Carryover

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Fiscal Issues

118

Maintenance of Effort

ESEA Sections 1120A(a) and 952134 CFR 299.5

ComparabilityESEA Section 1120A(c) and (d)

34 CFR 200.79

Supplement vs. SupplantESEA Section 1120(b) & 1114(a)(2)(B)

34 CFR 200.79

Time and Effort 2 CFR Section 225

Federal Office of Management and Budget’s Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments.

Fiscal Issues-Big Four

119

At the district level The district has maintained fiscal effort if

either of the tests below were met at 90 percent of the preceding year The combined fiscal effort per student or The aggregate (total of included)

expenditures of the district These tests are performed by OSPI based on

district information on the F-196 financial reports

SAFS provides interactive worksheet—use it

Maintenance of Effort

120

At the building level

All schools in the district are Title I, Part A schools, the district must use state and local funds to provide services that, taken as a whole, are substantially comparable in each school

Use iGrant report 361, due October 30, 2011Compare Title I, Part A buildings to Non-Title buildingsIf all Title I, Part A compare to each other

Comparability

121

Services to students

Presumptions of supplanting for districts and targeted assistance buildings-

Federal funds were used to provide services that the district was required to make available under federal, state or local law

Federal funds were used to provide services provided with non-federal funds in the prior year(s)

Title I, Part A or C funds were used to provide services for participating children that were provided with non-federal funds for non-participating children

Rebuttal may be possible in some cases

Supplement Not Supplant

122

Presumption of supplanting for Title I, Part A

schoolwide buildings

Must show each schoolwide building received all state and local funds to which it is entitled, including those for basic education, for children with disabilities and for limited English proficient children

Supplement Not Supplant

123

Time and effort reporting is required when

any part of an individual’s salary is charged to a federal program Single cost objective →Semi annual certification Multiple cost objectives →Monthly time reports

or Personnel Activity Reports (PARs) Time and effort reports show how time was

actually worked Must account for 100% of time worked Must reconcile to budget at least quarterly

Time and Effort

124

Schoolwide plan must specify programs to be

included (not all programs may be included)

A schoolwide program is a single cost objective If employee works 100 percent on programs

combined → Semi-annual certification If employee works partially on programs

combined and partly on those not combined → Monthly time report (PAR)

Schoolwide Time and Effort

125

Consolidated Program Review

(CPR)

Review CycleMost Common Non-Compliance Issues

Title I, Part A and LAP

126

2010-2011 Districts in ESDs 121 and 171 2011-2012 Districts in ESDs 105, 112,

and 113 2012-2013 Districts in ESDs 123 and 189 2013-2014 Districts in ESDs 101 and 114

CPR Monitoring Review Timeline

127

1.1 At beginning of each school year, the district notified

parents in all Title I, Served buildings that they may request the professional qualifications of the student’s classroom teacher. (Copy of notice with information may request and date sent)

1.3 The District Annual Report card to parents and community on the progress of each school and the district as a whole toward meeting requirements for (a) highly qualified staff and (b) student progress toward state and national goals (Description of how information is disseminated and contains all

required elements: 1. Reading, Mathematics, and Science assessment data. 2. Accountability data (AYP). 3. Teacher quality data. 4. NAEP results, if applicable.)

Title I, Part AMost Common Non-Compliance Issue

District Level

1.12 There is a District Parent Involvement

Policy containing all of the required elements. (Conduct with parents an annual review)

1.12b The district ensures that parents have the opportunity to be involved in the decisions regarding the 1% set aside for parent involvement funds. (Parent survey, meeting minutes, and/or

agenda)

Title I, Part AMost Common Non-Compliance Issues

District Level

1.17 The district ensures that each school identified for

improvement has developed or revised a school improvement plan, developed in consultation with parents, community, district, and outside experts. (All sanctions for each applicable step)

1.22 The district has revised, no later than three months after identification, a continuous district improvement plan in consultation with parents, school staff and others. (Copy of District Improvement Plan with all required

elements)

Title I, Part AMost Common Non-Compliance Issues

District Level

1.25 Charges to federal grants are charged &

documented appropriately. OMB Circular A 87, Attachment B. (Documentation for sub-coding for each

applicable set-aside)

Title I, Part AMost Common Non-Compliance Issues

District Level

1.6 Instructional paraprofessionals must be

under the direct supervision of a certificated teacher. (Evidence of supervision from highly qualified certificated staff)

1.7 Each Title I, Part A Schoolwide building has a Schoolwide/SIP building plan that contains the ten component requirements. (Documentation matrix of coordination of federal, state, and local services)

Title I, Part AMost Common Non-Compliance Issues

Building Level

1.8 Schoolwide program is evaluated annually.

(Documentation of ongoing evaluation) 1.10 The most-at-need students are identified.

(An example of a rank order list /entrance and exit procedures)

1.11 The Targeted Assistance program shall be reviewed on an ongoing basis. (Documentation of ongoing review, progress of participating children and revision of the targeted plan, if necessary)

Title I, Part AMost Common Non-Compliance Issues

Building Level

1.14 Building Parent Involvement Policy/Plan

are developed jointly, agreed on and disseminated to parents of Title I, Part A participating students. Copy of up-to-date policy containing all required

elements-example of compact)

Title I, Part AMost Common Non-Compliance Issues

Building Level

2.1 Selection of eligible students for LAP services. RCW

28A.165.025; WAC 392-162. (Evidence that only students achieving below state and

district assessment are served)

2.2 Accelerated Student Learning Plans are developed for participating students. RCW 28A.165.025(3); WAC 392-162. (Roles, Goals, Communication and Review/Adjustment)

2.3 Services are provided for eligible 11th and 12th grade students who are not on track to meet local or state graduation. RCW 28A.165. Evidence of services for selected participating students)

Learning Assistance Program (LAP)Most Common Non-Compliance Issues

District/Building Level

1.3.1 Time and Effort 1.5.1 Supplement Not Supplant 1.6.1 Program Income

SES Providers, CTE 1.7.1 Equipment, Capital and Theft Sensitive

Contain all components, theft-sensitive definition 1.8.1 Procurement

Address all four areas especially small purchases and sole sourcing

Fiscal Non-Compliance Issues

136

Resources Links

Title I, Part A and LAP

137

Title I, Part A Resource Links

138

LAPResource Links

139

Resource Links

OMB Circular A-87—Allowable Costs (Codified as 2 CFR 225) http://www.whitehouse.gov/omb/circulars_a087_2004/ OMB Circular A-102— Grants and Cooperative Agreements with State

and Local Governments http://www.whitehouse.gov/omb/circulars_a102/ OMB Circular A-133—Audit Requirements and the related Compliance

Supplement http://www.whitehouse.gov/omb/rewrite/circulars/a133/a133.html/ 34 CFR 80—Administrative Requirements http://www.access.gpo.gov/nara/cfr/waisidx_04/34cfr80_04.html 34 CFR 76—Requirements for grants passed to districts through the

state agency, OSPI http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/

ecfrbrowse/Title34/34cfr76_main_02.tpl

Director, Gayle Pauley: Gayle.Pauley@k12.wa.us

Program Supervisors Petrea Stoddard: Petrea.Stoddard@k12.wa.us Mary Jo Johnson: MaryJo.Johnson@k12.wa.us Reginald Reid: Reginald.Reid@k12.wa.us Jamilyn Penn: Jamilyn.Penn@k12.wa.us John Pope: John.Pope@k12.wa.us Larry Fazzari: Larry.Fazzari@k12.wa.us Jody Hess: Jody.Hess@k12.wa.us Bill Paulson: bill.paulson@k12.wa.us

Administrative Support Julie Chace: Julie.Chace@k12.wa.us Kevan Saunders: Kevan.Saunders@k12.wa.us Tony May: Tony.May@k12.wa.us

OSPI Title I, Part A/LAP Contacts

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