IDEA MOE Prior Years Expenditures Compliance Analysis Template …€¦ · · 2014-06-18Education...

Education Service Center, Region 20 | May 2014 (Revised June 11 2014) pg. 1

IDEA MOE Prior Years Expenditures Compliance Analysis Template

for

Special Education Maintenance of Effort (MOE)

The IDEA MOE Prior Years Expenditure Compliance Analysis Template (developed May 2014) is an Excel

spreadsheet that was adapted from TEA’s IDEA-B LEA MOE Calculation Tool (February 2014) but has

been modified to assist LEAs in determining their compliance with Maintenance of Effort for prior years.

Differences between the two tools:

ESC-20’s Prior Years Tool TEA’s MOE Calculation Tool

Function Codes Function Codes listed in the same order as PEIMS EDIT+ reports (Direct Costs are listed first in numerical order followed by Indirect Costs in numerical order).

Function Codes listed in numerical order.

Expenditures Columns for manual entry

Additional columns available for entering expenditure data for unique situations, i.e. SFSF funds, Education Jobs Funds. The headings for the additional columns can be edited.

Only two columns are available for the LEA to enter expenditure data: PIC 23 and PIC 33 columns.

Expenditures - Function Codes 34 and 41

Function Codes 34 and 41 color coded green to distinguish Indirect Cost Function Codes from Direct Cost Function Codes.

No distinguishing color.

Expenditures – Shared Services Arrangement

Shared Services Arrangement (FA expenditures made on behalf of SSA Members – for ISDs only) color coded in blue to distinguish this amount from the other expenditure data since they are obtained from a different source.

No distinguishing color.

Expenditures first page – SHARS Reimbursement Revenue Used for Additional Special Education Expenditures

Added row for SHARS Reimbursement Revenue Used for Additional Special Education Expenditures, color coded in pink. Since these expenditures must be subtracted from the total expenditures for a final determination, this provides a method to subtract during the initial analysis rather than subtracting later.

Not included in TEA’s tool. Instead, the LEA is required to submit the data to TEA as a State Reconsideration after receiving their Preliminary Letter of Findings. TEA then re-calculates the total expenditures by subtracting this self-reported amount.


Differences between the two tools, continued:

ESC-20’s Prior Years Tool TEA’s MOE Calculation Tool

Test Results Area Comparison years populate in this area so the LEA doesn’t have to scroll to the top of the page to see the comparison years.

Comparison years only show at the top of the page.

Test Results If an LEA has zero local funds in both years, the analysis will ignore Tests 3 and 4 and determine compliance based on Tests 1 and 2.

If an LEA has zero local funds in both years, the analysis will show the LEA to be compliant even if the LEA fails Tests 1 and 2 because Tests 3 and 4 show no decline between zero local funds in prior year and zero local funds in current year.

Comments Area Added two areas for comments so the LEA can add clarifying notes or comments, such as whether they will assert exceptions, adjustments, etc.

No area available to add comments.


Instructions for

IDEA MOE Prior Years Expenditures Compliance Analysis Template

Keep the template as a blank template and save a separate template for each Fiscal Year you wish to

track expenditures and determine compliance.

Steps 1 – 7 and 9-10 are performed in the IDEA MOE tab of the spreadsheet:


STEP ONE: LEA INFORMATION

Step 1 (Determination area of spreadsheet in IDEA MOE tab):

Manually enter the following in the appropriate orange cells:

LEA Name

CDN (County District Number)

Fiscal Year Analysis (For example, if comparing 2011-2012 to 2012-2013, enter FY13)


STEP TWO: PRIOR YEAR EXPENDITURES

Step 2 (Prior Year Data area of spreadsheet in IDEA MOE tab):

Manually enter the following data in the appropriate orange cells:

Prior Year (For example, if comparing 2011-2012 to 2012-2013, enter 2011-2012 in the cell)


In the PIC 23 Special Ed column, enter special education expenditures coded to PIC 23 for the

appropriate function codes.


These expenditure data can be found in:

PEIMS Mid-Year EDIT+ PRF1D007 (Actual Compliance Report – General Fund Allocated) if using

allocated data, or

PEIMS Mid-Year EDIT+ PRF1D008 (Actual Compliance Report – General Fund Unallocated) if

using unallocated data.

Per TEA, effective FY14 and beyond, use unallocated data. For prior years, use allocated data.

During the transition year between FY13 and FY14, use allocated data for 2012-2013 expenditures when

comparing 2011-2012 to 2012-2013, but use unallocated data for 2012-2013 expenditures when

comparing 2012-2013 to 2013-2014.

Note: When entering expenditure data on the BS6016 Fiscal Compliance Requirements schedule

associated with the Special Education Consolidated Grant application, always use unallocated

expenditure data regardless of which FY data is being reported for any prior year, regardless of whether

allocated data was used to determine compliance.


The date of the PRF1D007 and PRF1D008 reports are the PEIMS reports from the subsequent year of the

year of data being reported.

For example, the 2012-2013 PRF1D007 report contains 2011-2012 expenditure data.


In the PIC 33 PreK Special Education (PPCD) column, enter appropriate data if State and/or local funds were used for PPCD expenditures and coded to PIC 33. Note: PIC 33 appeared for the first time in the PEIMS Mid-Year 2013-2014 EDIT+ reports (for expenditure data from 2012-2013). PIC 33 was established by TEA in March 2013.

In the PIC 32 PreK column, enter appropriate data if State and/or local funds were used for PreK

Special Education (PPCD) expenditures and coded to PIC 32. Note: PIC 32 was established by

TEA effective 2011-2012 but was used for all PreK expenditures, with no distinction between

student population type. The LEA must use local records to determine if any of the PIC 32

expenditures were for PPCD purposes. If so, enter those amounts in this column. PIC 32

appeared for the first time in the PEIMS Mid-Year 2012-2013 EDIT+ reports. This column

heading may be edited if desired.

In the SFSF (Fund 266/366) column, if your LEA used State Fiscal Stabilization Funds (Fund 266/366) for special education purposes, enter that amount for the applicable years. SFSF funds were available in 2009-2010 and 2010-2011. It is possible that a portion of SFSF funds may have been used in FY12 since the funds were effective through 9/30/11. The LEA must use local records to determine the amounts of SFSF used for special education, if any.

If SFSF funds were used for special education, a portion of expenditures coded to PIC 99 for SFSF

must be allocated to PIC 23. The LEA must calculate the allocation portion themselves.

In the Education Jobs Fund (Fund 287) column, if your LEA used Education Jobs Funds (Fund

287) for special education purposes, enter that amount for the applicable years. Ed Jobs funds

were available in 2010-2011 and 2011-2012. It is possible that a portion of Ed Jobs funds may

have been used in FY13 since the funds were effective until 9/30/12. The LEA must use local

records to determine the amounts of Ed Jobs Funds used for special education, if any. This

column heading may be edited if desired.


If you are an ISD and are a member of a special education Shared Services Arrangement (SSA),

enter the amount spent on your behalf by the Fiscal Agent for special education expenditures

with State and/or local funds. Although the Fiscal Agent can obtain the data coded to Fund 437

from the PEIMS Mid-Year EDIT+ PRFBD001 (Actual SSA Financial Summary by Fund and SSA

Type), the SSA Member does not have access to this PEIMS report. Therefore, the Fiscal Agent

must provide the data to their SSA Members.

o This step is not applicable to Charter Schools because the members of the SSA already

receive the data from their Fiscal Agents. The amount spent on behalf of the SSA

Member is provided to the SSA Member prior to PEIMS submission and is, therefore,

already included in the member’s expenditure data in PRF1D007 or PRF1D008.


STEP THREE: CURRENT YEAR EXPENDITURES

Step 3 (Current Year Data area of spreadsheet in IDEA MOE tab):

Perform the same steps identified in Step 2, but enter data from the second year of the two comparison

years in the Current Year area of the spreadsheet.

For example, if the MOE analysis is for FY13 (comparing 2011-2012 expenditures to 2012-2013), enter

2012-2013 expenditure data in the Current Year area of the spreadsheet.


Example of 2012-2013 PIC 23 expenditures from PEIMS 2013-2014 Mid-Year EDIT+ PRF1D007:


Example of 2012-2013 PIC 33 expenditures from PEIMS 2013-2014 Mid-Year EDIT+ PRF1D007:


Example of 2012-2013 expenditures made on behalf of an ISD member district of a special education

SSA by the Fiscal Agent, as shown on the PEIMS 2013-2014 Mid-Year EDIT+ PRFBD001:


Example of entry of 2012-2013 expenditures onto the Current Year area of the MOE spreadsheet:


STEP FOUR: EXPENDITURE DATA AUTO-POPULATED IN COMPLIANCE DETERMINATION AREA

Step 4: (Determination area of spreadsheet, IDEA MOE tab):

All the expenditure data manually entered in the Prior Year and Current Year areas of the spreadsheet

will auto-populate into the Determination area of the spreadsheet in the IDEA MOE tab. No action

needed by the LEA for this step.

Please note: Expenditure amounts totaled on the spreadsheet may not match exactly with the totals on

the PEIMS reports due to rounding.

Note: Determination of compliance is not complete until child count data and Summary of Finances

data are manually entered into the spreadsheet – next steps.


STEP FIVE: SHARS REIMBURSEMENT REVENUE

Step 5 (SHARS Reimbursement Revenue Used for Additional Special Education Expenditures cells in

Determination area of spreadsheet, IDEA MOE tab):

If your LEA participated in the SHARS (School Health and Related Services) reimbursement option and

used the SHARS Reimbursement Revenue (Revenue Code 5931) for additional special education

expenditures, manually enter the expenditure amounts in the appropriate orange cells for Prior Year

and/or Current Year.

This amount will be subtracted from the total special education expenditures with State and/or local

funds.

Please note: It is possible that your LEA did not use the SHARS Reimbursement Revenue on additional

special education expenditures because the SHARS revenue can be spent on anything. Although the

funds are generated based on special education expenditures, the LEA is not required to spend the

SHARS revenue on additional special education expenditures.

The LEA must use local records to determine the amount of additional special education expenditures

with SHARS Reimbursement Revenue, if any.


Example of LEA NOT using SHARS Reimbursement Revenue for additional special education

expenditures:

Example of LEA using SHARS Reimbursement Revenue for additional special education expenditures:

In this example, prior to entering the SHARS data, the total State and Local Expenditures were $998,237

for Prior Year and $1,293,249 for Current Year.

After entering the SHARS data, the total State and Local Expenditures were reduced to $898,237 for

Prior Year and $1,143,249 for Current Year.


STEP SIX: CHILD COUNT DATA

Step 6 (Special Education Student Population cells in Determination area of spreadsheet, IDEA MOE

tab):

Manually enter child count data for prior year and current year in the appropriate orange cells.

These data are obtained from the PEIMS Fall EDIT+ PRF5D010 (Special Education Child/Counts by

Funding Type) reports. The date of the PEIMS report is the same year as the year of data being

reported.

For example, the 2011-2012 PEIMS Fall EDIT+ PRF5D010 report corresponds to the 2011-2012

expenditure data.

Use the Total from the IDEA-B row. Do not use the Grand Total child count.


Example of 2011-2012 as Prior Year and 2012-2013 as Current Year for entry into the MOE Calculation

tool:


STEP SEVEN: COMPLIANCE TESTS 1 AND 2

Step 7 (Test Results area for Test 1 and Test 2 in Determination area of spreadsheet, in IDEA MOE

tab):

Now that expenditure data and child count data for both years have been entered, the spreadsheet can

determine MOE compliance based on the first two tests:

Test 1: Total expenditures based on a combination of State and local funds

Test 2: Per capita (per pupil) expenditures based on a combination of State and local funds

If the Current Year equals or exceeds the Prior Year, the test results will show zero.

If the Current Year is less than the Prior Year, the test results will show the amount of the

decrease, as a negative number.

Example of LEA that passed both Tests 1 and 2 because the Current Year expenditures were equal to

or greater than the Prior Year expenditures:


Example of LEA that failed Tests 1 and 2 because the Current Year expenditures were less than the

Prior Year expenditures:


Please note: At this point, the analysis is not complete. You must also perform the analysis for Tests 3

and 4 based on local only funds, rather the combination of State and local funds.

Although the spreadsheet has auto-populated data into the fields for Tests 3 and 4, these results are not

accurate because the spreadsheet has merely auto-populated the same data from that used for Tests 1

and 2.

The data and results for Tests 3 and 4 will not be accurate until you manually enter data from your

Summary of Finances for the appropriate years.


STEP EIGHT: LOCAL ONLY EXPENDITURES

Step 8 data entry is performed in the Local Ratio tab of the spreadsheet:

Step 8 (Ratio of State and Local Funding in FSP worksheet, Local Ratio tab):

Manually enter SOF (Summary of Finances) data into the orange cells of the spreadsheet for both years

of the comparison.


The data are obtained from the Summary of Finances (SOF) dated 9/10 (or the closest date after 9/10)

for the year of analysis. For example, for 2011-2012 data, use the SOF from 9/10/12. For 2012-2013

data, use the SOF from 9/10/13. Always use data from the LPE column of the SOF.


For the SOF Special Ed Allotment field in the spreadsheet, use the amount from the LPE column of

the SOF for “23-Special Education Adjusted Allotment”

Please note: In years prior to 2012-2013, the SOF for Charter Schools looked different from that of

school districts. For a Charter School prior to 2012-2013, there were actually two amounts (Special

Education Block Grant and Mainstream Special Education Grant) in the SOF the Charter School would

need to sum for entry into the SOF Special Ed Allotment field of the spreadsheet.

Example of Charter School SOF prior to 2012-2013:


For the SOF Total Tier I field in the spreadsheet, use the amount from the LPE column of the SOF for

“Total Cost of Tier I”

For Charter Schools prior to 2012-2013, the “Total Cost of Tier I” in the SOF was titled “State Share of

Tier I”:


For the Tier I Local Share/Local Fund Assignment field in the spreadsheet, use the amount from the

LPE column of the SOF for “Less Local Fund Assignment.”

Although the number appears as a negative number in the SOF, always enter as a positive number in the

MOE spreadsheet.


For Charter Schools, always enter zero in the Tier I Local Share/Local Fund Assignment field.

Prior to 2012-2013, Charter School SOFs did not even have a category for “Less Local Fund Assignment.”

Beginning with 2012-2013, the SOF for Charter Schools includes the category, but the amount is always

zero.


Now perform the same steps for the Current Year data:


After entering the three sets of data from the SOF for each year in the orange boxes, the calculation tool

automatically computes the amounts in the unshaded boxes. No more action is needed by the LEA for

the determination of Local Only funds expended for special education.

The system takes data from the IDEA MOE tab of the spreadsheet and the Local Ratio tab of the

spreadsheet and auto-populates the fields in the Local Calculation tab of the spreadsheet.

No data entry is required by the LEA in the Local Calculation tab of the worksheet.


The Calculation tool automatically performs the Local Only calculations and then auto-populates the

Total Local Expenditures amount to the IDEA MOE tab of the worksheet in the Test 3 row.


STEP NINE: COMPLIANCE STATUS

Step 9 (Test Results area in Determination area of spreadsheet, in IDEA MOE tab):

Now that the LEA has manually entered all data necessary to perform the four compliance tests, the

spreadsheet’s display of the Compliance Results will be accurate.

The status will be displayed as either “Compliant” or “Non-Compliant.”

If zero is indicated as the result of a test, the LEA has passed that test.

Example of LEA that passed all four tests and is therefore Compliant:


If an LEA passes at least one of the four tests, the LEA is considered Compliant.

Example of LEA that failed at least one of the four tests but passed at least one test:


If an LEA fails all four tests, the LEA is considered Non-Compliant.

The test result that shows the smallest amount of decrease will be the amount of non-compliance that

the LEA may have to refund to TEA unless the LEA qualifies for an exception, adjustment, and/or State

Reconsideration.

Example of LEA that failed all four tests:


If an LEA, such as a Charter School, has zero local funds according to the spreadsheet’s calculation of

Local Only Expenditures, the results for Tests 3 and 4 will be indicated as N/A and the compliance

determination will be based on the results of Tests 1 and 2.

Example of LEA with zero local funds and fails Tests 1 and 2: The LEA is Non-Compliant.

Example of LEA with zero local funds and passes Tests 1 and 2: The LEA is Compliant.


STEP TEN: COMMENTS

Step 10 (IDEA MOE tab):

If you want to add any comments to the spreadsheet, such as whether you will assert an exception,

adjustment, or State Reconsideration, there are two Comments areas on the spreadsheet on the IDEA

MOE tab.


STEP ELEVEN: MOST RECENT PRIOR YEAR COMPLIANT WITH MOE

Step 11 (If Non-Compliant)

No Justification for Decrease:

If your analysis shows you are non-compliant and you do not have any exceptions, adjustments, or State

Reconsiderations to justify the decreased expenditures, you must compare current year to the most

recent prior year in which you were compliant with MOE.

Example:

FY 10 Analysis: Comparison between 2008-2009 to 2009-2010 shows FY10 to be compliant

FY 11 Analysis: Comparison between 2009-2010 to 2010-2011 shows FY11 to be non-compliant

FY 12 Analysis: Comparison would normally be 2010-2011 to 2011-2012 but since FY11 was non-

compliant, must compare 2009-2010 to 2011-2012 since FY10 was the last year in which the LEA was

compliant

Suggestion: Complete two versions of the FY12 template:

First template - compare 2010-2011 to 2011-2012 as an initial comparison

Second template - compare 2009-2010 to 2011-2012 as the official comparison

Justification for Decrease:

If the year of non-compliance qualified for exceptions, adjustment, or State Reconsideration, so the

decreased expenditures are allowable, the step described above is not applicable.

Example with allowable decline:

FY 10 Analysis: Comparison between 2008-2009 to 2009-2010 shows FY10 to be compliant

FY 11 Analysis: Comparison between 2009-2010 to 2010-2011 shows FY11 to be non-compliant

However, the LEA has allowable exceptions to justify the decline in expenditures

FY 12 Analysis: Comparison between 2010-2011 to 2011-2012 since FY11 is actually compliant since the

LEA has allowable exceptions for the decline

IDEA MOE Prior Years Expenditures Compliance Analysis Template …€¦ · · 2014-06-18Education...

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