Two aspects to IDEA MOE: 1. Eligibility Process Determines eligibility to receive IDEA-B funds ...

Special Education (IDEA-B) Maintenance of Effort (MOE)

Update

Denise DusekEducation Service Center, Region 20

April, 2014

IDEA MOE Processes Two aspects to IDEA MOE:

1. Eligibility Process

Determines eligibility to receive IDEA-B funds

Compares upcoming year’s Budget to prior year Expenditures* (Clarification in other slides)

Prior to receipt of IDEA-B entitlement

2. Determinations Process

Determines compliance with MOE requirement

Compares actual Expenditures from one year to the next

After-the-factEducation Service Center, Region 20 | April 2014 2

NEW eGrants Schedule Fiscal Compliance Requirements

schedule:

› Part 1: LEA MOE (Maintenance of Effort) for Eligibility

New Data Collection

› Part 2: MOE Reduction and Coordinated Early Intervening Services (CEIS) Requirements

Existing Data Collection

Moved from BS6006 Budget Summary to this new schedule

Education Service Center, Region 20 | April 2014 3

Purpose of Part 2 of Schedule

Part 2: MOE Reduction and Coordinated Early Intervening Services (CEIS) Requirements

› Purpose of moving these sections to new schedule is for validation.

› System will validate that amounts entered do not exceed maximum allowable:

1. MOE Voluntary Reduction amount;

2. CEIS amount;

3. Combination of Voluntary Reduction and CEIS amounts (combination cannot exceed the lesser of CEIS maximum or Voluntary Reduction maximum)


Draft of Fiscal Compliance Schedule


Purpose of Part 1 of Schedule

Part 1: LEA MOE for Eligibility

› As a requirement for receiving IDEA-B funds, the LEA must first certify they will budget enough in the new year to be in compliance with MOE

› Must provide the following:

Special education Expenditures from prior year

Special education Budget for upcoming year

Identify whether meeting MOE based on “state and local” or “local only” funds


Part 1: LEA MOE Eligibility

If budget is less than prior year expenditures:

› LEA must provide a justification for the decreased budget amount:

Example: “Using Federal Exception for Departure of Special Education Personnel. We have budgeted $<amt> less due to the retirement of <qty> special education teachers paid from the general fund.”


Eligibility vs Compliance Determinations

Information provided in this schedule is for purposes of grant eligibility only

Actual MOE compliance will be performed during determinations process (after-the-fact):

› Actual expenditure comparison

› Assertions for decline in effort will be reviewed and approved or rejected during the determinations process


Prior Questions Concerning NEW eGrants Schedule

Questions from prior guidance concerning the new schedule:

› If the LEA enters estimated amounts during initial submittal, will the LEA need to submit an amendment when actual amounts are known?

› Should the LEA enter estimated expenditure amounts from the prior year OR final amounts from the most recent year completed (two years ago)?


NEW Guidance Regarding New eGrants Schedule

New Guidance resulting from TEA’s consideration of the questions:

› The year being used for prior year expenditure data for the Fiscal Compliance schedule must be the year in which:

Expenditure data are final, AND

The LEA was in compliance with MOE


Example for 2014-2015 Schedule


No

2013-2014 Expenditures

Final?Look at 2012-2013 Expenditures. Was LEA compliant in

FY13?

Use 2012-2013 Expenditures in 2014-2015

Schedule

Look at 2011-2012

Expenditures. Was the LEA compliant in

FY12?

Yes

YesUse 2011-2012 Expenditures in

2014-2015 Schedule

No

Was LEA compliant in

FY14?

Use 2013-2014

Expenditures in

2014-2015 Schedule

Yes

YesNo

Implications of New Process

Implications:

› LEA will need to know which prior years they were in compliance with MOE and which test demonstrated compliance (combination of state and local funds or local only funds)

› Won’t be able to start fresh with the comparison of FY14 to FY15

› LEA must maintain documentation of all expenditure and budget data referenced in the schedule and be able to provide the documentation to TEA upon request.


Considerations for Prior Years Calculations

1. Retroactive: No longer use ECI (Early Childhood Intervention) set-aside from SOF (used to be included in ISDs’ MOE calculations to lower the amount of decline; N/A for charter schools)

2. Retroactive: Must use new method of imputing “local only” expenditures

3. Allocation of PIC 99 used in years prior to FY14; Not used beginning with FY14

4. Boundy letter effective FY11 (if prior year is noncompliant, must compare current year to most recent previous year when compliant)



5. Retroactive: For child count data, use only Child Count Funding Type Code 3 (IDEA-B) from the PEIMS Fall Collection EDIT+ PRF5D010 Special Education Child/Counts by Funding Type.

(Previously, the total of Codes 3 and 0 were used.)



6. Additional Revenue specific to a certain year, if used for special education:

SFSF (State Fiscal Stabilization Funds, Fund 287/368) 2009-2010 and/or 2010-2011

Education Jobs Funds (Fund 287/368) 2010-2011 and/or 2011-2012

SHARS Reimbursement Revenue (Revenue Code 5931) any year, if used for additional special education expenditures



7. Special Education Program Intent Codes (PICs):

Prior to 2011-2012, PIC 23 was the only PIC used for special education expenditures.

Effective 2011-2012, PIC 32 was added for all PreK expenditures.

LEAs would have to use a locally defined option code to distinguish PreK special education (PPCD) expenditures from other PreK expenditures.

Effective 2013-2014, PIC 33 was added for PreK special education (PPCD) expenditures.

PIC 32 is now only used for PreK expenditures that are not special education, compensatory education, or bilingual education.


NEW eGrants Schedule

Question sent to TEA in April 2014:

› What does an LEA do if they don’t have final budget data available at the time of the eGrants submission?

› TEA Response 4/15/14: “Use the budgeted amount at the time of completion/submission of the application and keep the appropriate documentation of that amount in the event the LEA is randomly selected for validation.”


NEW eGrants Schedule Question sent to TEA in April 2014:

› How does the data requirement for assuring eligibility for IDEA-B funds affect SSAs?

The draft schedule does not have a drop down box to select member districts

If it did, how can a Fiscal Agent be responsible for reporting member districts’ local data?

› TEA Response 4/14/14:

“Yes, the schedule will need to be completed for each member of an SSA and there will be various validations in the schedule to help let the applicant know if there are corrections to be made or other information needed, etc.”


New Schedule is in Draft

Remember: The Fiscal Compliance Requirements schedule being presented in this power point is a draft version

May change before finalized



MOE Workshop

Sign up in iLearning via www.esc20.net to attend a full day IDEA MOE workshop to learn the basics of MOE and the new guidance and methodology released by TEA to date

Presenter: Denise Dusek

iLearning workshop #PD140611-A37

Registration Fee: No Charge

May 2, 2014 9:00 am to 3:00 pm

Lunch on your own

http://www.esc20.net/

Questions?

Contact:› Denise Dusek› (210) 370-5378› [email protected]

› Sherry Marsh› (210) 370-5411› [email protected]


mailto:[email protected]

mailto:[email protected]

Two aspects to IDEA MOE: 1. Eligibility Process Determines eligibility to receive IDEA-B funds ...

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