Regional Fall ESEA Program Directors’ Meeting

Morning Agenda

• Welcome & Updates• Fiscal Hot Topics• WV Educator Equity Plan• Open Dialogue on Use of ESEA Resources• Program Data Management (Website,

Percent Needy, Comparability, SMR, ZoomWVe)

Updates

• Reauthorization• WVBE Policies

Fiscal Updates

Laura Pauley, CPA

lepauley@k12.wv.us

WVDE Office of Federal Programs

Federal Procurement Standards

Procurement Standards

• Pass-through entities are required to follow the General Procurement Standards in Sections 200.318-200.326 for procurement transactions that include federal funds.

Procurement Standards

• All non-Federal entities must:– Have documented procurement procedures– Maintain oversight to ensure compliance– Maintain written standards of conduct

covering conflicts of interest (real and or perceived)

Conflicts of Interest

• A conflict of interest would arise when the employee, officer or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of those parties, has a financial or other interest in or receives a tangible personal benefit from a firm considered for a contract.

Conflicts of Interest

• LEAs may set standards for situations in which the financial interest is not considered substantial or the gift is an unsolicited item of nominal value.

• Standards of conduct must provide for disciplinary actions to be applied for violations of such standards.

Organizational Conflicts of Interest

• When the LEA is unable or appears to be unable to be impartial in conducting a procurement action involving a related organization.– Written standards must also address

organizational conflicts of interest – Does not apply when the related organization

is a local or state government

Economy and Efficiency

• Federal procurement must be completed in a way that fosters economy and efficiency– Avoid purchasing unnecessary or duplicative

items– Consider entering into agreements for shared

goods and services

Responsible Contractors

• Must award contracts only to responsible contractors who are able to perform successfully under the terms and conditions of the contract

• Consider the following:– Integrity, compliance with public policy– Record of past performance– Not suspended or debarred

Recordkeeping

• Procurement records must include the following:– Rationale for the method of procurement – Selection of contract type (ex. fixed price)– Contractor selection or rejection– Basis for the contract price

Procurement Methods

• Micro-Purchases (<$3,500)• Small Purchases (>$3,500 and

<$150,000)• Competitive Sealed Bids (>$150,000)• Competitive Proposals • Noncompetitive Proposals (severely

limited)

Micro Purchases

• The acquisition of supplies and services under $3,500 (Section 200.320)– May be awarded without soliciting competitive

quotations if the cost is reasonable.– To the extent practicable must distribute

equitably among qualified suppliers.

Small Purchases

• Purchases of goods or services >$3,500 but < $150,000 Simplified Acquisition Threshold – Must obtain price or rate quotes from an

adequate number of qualified sources (Section 200.320)

– Simple and informal

Non-competitive Proposals

• Section 200.320 Procurement by noncompetitive proposals may be used only when one or more of the following apply:– The item is available only from a single source– An emergency will not permit competitive solicitation– The awarding agency or pass-through expressly

authorizes noncompetitive proposals– After solicitation, competition is determined

inadequate

Competition

• Situations that are considered to be restrictive of competition and a violation of section 200.319:– Placing unreasonable requirements on firms in

order for them to qualify to do business– Requiring unnecessary experience– Non-competitive pricing practices– Non-competitive contracts to consultants on

retainer

Competition (Cont.)

– Organizational conflicts of interest– Specifying only a “brand name” product

instead of allowing “an equal” product to be offered

Geographical Preference

• Procurements must be conducted in a manner that prohibits the use of statutorily or administratively imposed state or local geographical preferences.– This does not include state licensing laws

Contract cost and price

• If a procurement exceed the Simplified Acquisition Threshold ($150,000), the non-Federal entity must perform a cost or price analysis.

• LEA must make an independent estimate before receiving any bids or proposals

Suspension and Debarment• For contracts over $25,000 you must verify

that the vendor is not excluded or disqualified

• This must be done by either:– Checking System for Award Mgt. (www.sam.gov)– Collecting a certification from that person, or– Adding a clause or condition to the transaction

Bidding Exemptions

• State bidding exemptions do not apply for purchases made with federal funds– State requirements can only be more

restrictive and not less restrictive

Food & Beverage Purchases

Allowable Cost – Food/Beverage

• Parent Involvement activities only – Utilizing Title I/III– Must extend through a mealtime – Supported with original receipts, event sign-in

sheets and agendas– Can provide a beverage and light snack

Unallowable Cost – Food/Beverage

• Title I/III cannot be used to pay for food/beverage for the following– Open Houses– Parent Teacher Conferences– Celebration, recognition or appreciation

events– PTA/PTO meetings– Meetings of the general public

Unallowable Cost – Food/Beverage

• Title II and RLIS (Title VI) funds cannot be used to purchase food and beverage

Travel Costs

• Federal funds may be used to pay for travel costs including a per diem meal cost – Must be in accordance with local travel policy– Amounts paid cannot exceed federal per diem

limits that were in place at the time of the travel

• $.575 per mile• Standard meal & incidental of $51/day

Conferences & Meetings

• When planning a conference/meeting to be paid for with federal funding, food and beverage may not be included in the meeting cost– It is not acceptable for the vendor to embed

these costs, which would be otherwise unallowable into the cost of the meeting space

Conferences & Meetings

• Indirect costs may not be used to pay for food/beverage since it would be easily considered a direct cost

Conferences & Meetings

• If other non-federal resources are being used to pay for food/beverage at a meeting or conference– Must have a written disclaimer (e.g. note on

the agenda) that Federal grant funds were not used to pay for the cost of food or beverages

NOW REQUIRED

Written Policies and Procedures

Policies & Procedures

• Now required to have certain written policies & procedures for the Financial Management System as it relates to Federal Awards

Cash Management

• LEA must use existing resources before requesting a drawdown on their federal award

• Policy must address the following:– Program income – Refunds– Rebates– Interest

Allowable Cost

• Written procedures for determining allowability in accordance with cost principles 200.400– From budget process to grant management

Allowable Cost

• All costs must be:– Necessary, reasonable and allocable– Conform with federal law & grant terms– Consistent with state and local policies– Consistently treated– In accordance with GAAP– Not included as match– Net of applicable credits (§200.406)– Adequately documented

Questions

WV EDUCATOR EQUITY PLAN

HTTP://WVDE.STATE.WV.US/SEARCH.HTML?Q=EDUCATOR+EQUITY+PLAN&X=0&Y=0

Inexperienced Teachers -Figure 6

In your county are your most inexperienced teachers at your highest poverty schools?

Is this a local or regional concern?

What regional solutions could be leveraged to assist with the issue?

How might ESEA funding be utilized to address within your county?

Out-of-Field Teachers -Figure 8

In which programmatic level does the county have the highest concentration of out-of-field teachers?

How is the county addressing this concern with ESEA resources?

Ineffective Teachers -Figure 11

In your county are your most ineffective teachers at your highest poverty schools?

Is this a local or regional concern?

What regional solutions could be leveraged to assist with the issue?

How might ESEA funding be utilized to address within your county?

SUPPORTING SCHOOL REFORM BY LEVERAGING FEDERAL FUNDS AND RESOURCES IN A

SCHOOLWIDE PROGRAM

Benefits of a Schoolwide Program

• Serving all students • Providing services that need not be

supplemental• Consolidating Federal, State and local

funds

Implementing a Schoolwide Program

• There are three basic components of a schoolwide program that are essential to effective implementation:

- Conducting a comprehensive needs assessment of the entire school,

- Preparing a schoolwide plan; and- Annually reviewing the schoolwide plan.

Use of Funds Examples Based on Needs Assessment

Increased learning time Evidence-based strategies to accelerate the acquisition

of content knowledge for English language learners Equipment, materials and training needed to compile

and analyze data to monitor progress, alert the school to struggling students and drive decision making

Devices and software for students to access digital learning materials and collaborate with peers and related training for educators

School climate interventions

Dispelling Myths

Safeguarding the Interests of Historically Underserved Populations

• A comprehensive schoolwide plan must include strategies for-

Meeting the educational needs of historically underserved populations; and

Addressing students and those at risk of not meeting the State’s standards who are members of the target population of any program included in the schoolwide plan.

• A school wide program must provide effective, timely additional assistance to students who experience difficulty mastering the State’s academic achievement standards.

Safeguarding the Interests of Historically Underserved Populations

• An LEA must ensure that each schoolwide program school receives a basic level of funds or resources from non-Federal sources to provide services that are required by law for students with disabilities and English language learners before using Title I funds in the school.

• An LEA operating a schoolwide program must comply with all other applicable laws, including: civil rights laws; laws affecting the education of English language learners; and laws affecting the education of students with disabilities, such as the IDEA and Section 504 of the Rehabilitation Act of 1973.

• If a schoolwide program consolidates Federal funds, it must ensure that it meets the intent and purposes of each Federal program whose funds it consolidates.

Consolidating Federal, State and Local Funds

• By consolidating funds in a schoolwide program, a school can more effectively design and implement a comprehensive plan to upgrade the entire educational program in the school as identified through a comprehensive needs assessment.

• When a school consolidates funds in a schoolwide program, those funds lose their individual identity and the school may use the funds to support any activity of the schoolwide program without regard to which program contributed the specific funds used for a particular activity.

Advantages of Consolidating Funds

• Flexibility to allocate all available resources effectively and efficiently.

• A school is not required to meet most of the statutory and regulatory requirements of the specific Federal programs in included in the consolidation, provided it meets the intent and purposes of those programs.

• A school is not required to maintain separate fiscal accounting by Federal program that identify the specific activities supported by each program’s funds.

• Simplified time and effort documentation.

Making a Difference: Using Federal Funds to Supplement School Reform

• The supplement not supplant requirement does not apply to a schoolwide program school.

• The presumptions used to determine if supplanting has occurred do not apply to the use of Title I funds in a schoolwide program school.

• However, in order for Federal funds to make a difference in supporting school reform in a schoolwide program, they must supplement those funds the school would otherwise receive.

Discussion

Program Data Management

Website Redesign

Percent Needy

Percent Needy

• The West Virginia Percent Needy Report is the state’s official public reporting of the percent of economically needy children by public school and school district which is used to determine school level Elementary and Secondary Education Act, Title I, Part A funding allocations. It is based on certified data collections made on the first day of October for each school year.

Percent Needy Prerequisites

• Your district should have already certified second month student enrollment

• Title I Directors should be granted access using the Title I Director role

• The menu option for Percent Needy Report WVR>WVRFP>PERC.NEED

Percent Needy Menu

• Access in WVEIS WOW• New WVRFP – Office of Federal

Programs• Menu PERC.NEED

Percent Needy

Percent Needy TermsTerm Definition

Community Eligibility Provision (CEP) Status

"CEP" stands for "Community Eligibility Provision." In CEP schools, all students receive free breakfast and lunch, regardless of their own family's economic status, due to a high proportion of students in the school being directly certified as eligible for free or reduced price meals.

Total Enrolled Students

The total enrollment includes the headcount of all students in the school, as certified on October 1 of the school year. These are primarily students in Kindergarten through Grade 12, although pre-kindergarten students who have Individual Education Plan (IEP) on file may be included in the enrollment as well. This number is the denominator in the calculation of "Percent Needy."

Non-CEP: Number of Free & Reduced Price Students

This total includes all students who are determined to be eligible for (and who are receiving) free or reduced-price meals (through direct certification, applications, or other methods). This data element is presented for non-CEP schools only.

Percent Needy Terms Cont.Term Definition

CEP: Number of Identified Student

"Total Students Directly Certified," presented for CEP schools only, includes the total number of students who are directly certified to be eligible for free or reduced-price meals (e.g., due to family eligibility for nutrition assistance programs).

CEP: Application of USDA Approved Multiplier

The function of the 1.6 multiplier is to provide an estimate of the percentage of students eligible for free and reduced-price meals in participating Community Eligibility schools, groups of schools, or LEAs that is comparable to the poverty percentage that would be obtained in a non- Community Eligibility school.

NSBLP County Used to Calculate Within District Title 1 Allocations (must be <= Enrollment)

The "Total 'Needy' Students for % Calculation" is the total number of students used as the numerator in the percentage calculation. For non-CEP schools, this is the number of students receiving for free or reduced-price meals ("F/R Meals Total"). For CEP schools, the total includes the number of directly certified students ("Total Directly Certified") multiplied by 1.6; if the result ("Total Directly Certified" * 1.6) is larger than the total number of students enrolled, then the total enrollment is used for calculation.

Percent Needy Terms Cont.Term Definition

Percent Needy Used to Rank Schools for Within District Allocations

The "Percent Needy" represents the percentage of students in a school who are economically disadvantages. The following calculation is used: Total "Needy" Students for % Calculation / Total Enrolled Students = Percent Needy

CEP: Percent of Identified Students Used to Determine Title 1 Rank for Schools at 100% Needy

A district may have more than one school who has percent needy equal to 100%. When this occurs this column can be used to determine the rank of the schools within the district. It is calculated

Accepting Percent Needy

• After reviewing the data within the percent needy report you must indicate that you have reviewed and accept the information

• The button is at the bottom of the report• Option to print the report is available.

How is Percent Needy Used

• Title I Funding Decisions• Loan Forgiveness• eRate Reporting• Public Reporting in ZoomWV

Percent Needy on ZoomWV

Questions on Percent Needy

Comparability Report

Comparability Report

• ESEA Section 1120A states that a LEA may receive Title I, Part A funds only if State and local funds are used in Title I schools to provide services that, taken as a whole, are at least comparable to the services provided to non-Title I schools. If the LEA serves all of the schools in its district with Title I funds, the LEA must use state and local funds to provide services that are substantially comparable in each school.

Comparability Prerequisites

• Your district should have already certified second month student enrollment, personnel list, and percent needy

• Title I Directors should be granted access using the Title I Director role

• The application can be found in the WOW menus at: WVR>WVRFP>COMP.RPT

Comparability Report

• Access in WVEIS WOW• New WVRFP – Office of Federal

Programs• Menu COMP.RPT

Comparability Report Step 1

Comparability Report Step 2 - Automated

Comparability Report Step 2 - Manual

First, select Manual

Then, click Run

Comparability Report Step 3• Review your spreadsheet for comparability• Review your Title 1 schools to ensure all are listed• Review Student Enrollment, this number should match (October Certification,

also known as Second Month Enrollment)• Review the list of Staff

Comparability Report Step 4

Comparability Report Step 5

First, select a file to upload

Then, click open

Comparability Report Step 6

Adjusting for Comparability

• Review personnel in conjunction to job assignment

• Adjust staffing and resources

Questions on Comparability Report

School Monitoring Report

General Information

• Worked with Office of Education Performance Audits (OEPA) and School Improvement (SI) to combine HQDS and SMR

• Provides one place to submit information to OEPA and SI

• Self reflection and evidence submitted at the function level

Combining HQSDC & SMR

• The application will be within WVEIS WOW

• Anyone submitting self reflection or uploading evidence will need an account– If you need an account, please contact your

County Contact or RESA Staff

School Profile

Upload Evidence

Review Evidence

Questions on School Monitoring Report