5/9/2019

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Special Education Funding

and Reporting

Mike Jacoby, Executive Director, IASBO

Julie Jilek, NSSEO Assistant Superintendent - CSBO

May 8, 2019

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Special Education Funding

AgendaOverview

State Funding

• Evidence Based Funding (EBF)

• Personnel Reimbursement

• Remaining Mandated Categorical Pupil Reimbursements

• Private Tuitions

• Orphanage

• Transportation

• Excess Cost Reimbursement

Federal Funding:

• IDEA Flow-Through Grant & Preschool Grant and Claims

• Medicaid – Administrative Outreach and Fee for Service

Funding for Transition Age Students 2

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Objectives:

➢To gain an understanding of the current special education funding sources in Illinois.

➢To gain an understanding of the ISBE Special Education Approval and Reimbursement process and timelines.

➢To gain an understanding of current issues and initiatives in the area of funding reform in Illinois.

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State Funding

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Funding Streams

In Illinois, school districts receive their state special education funding through formulas from the following funding sources:

◦ Evidence Based Funding

◦ Orphanage Tuition Reimbursement

◦ Private Tuition Reimbursement

◦ Excess Cost Reimbursement

◦ Special Transportation Reimbursement

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Evidence Based Funding

Public Act 100-0465

(Effective August 31, 2017)

Public Act 100-0465 comprehensively changed education funding

distribution to local education agencies and included significant changes

to the method of funding special education.

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Evidence Based Funding (EBF)

Base Funding Model (BFM):

The EBF consolidates and replaces five grants received in FY17 into the BFM:

• Gross General State Aid + Stop Loss Grant (if applicable)

• English Learner Education

• Funding for Children Requiring Special Education Services

• Special Education Personnel

• Special Education Summer School

The appropriations for these programs, populations and services were rolled into the new Evidence Based Funding program. 105 ILCS 5/18-18.5

Included a hold-harmless provision

Payments are distributed twice per month (22 payments/year) 7

EBFM Summary points regarding special education:

• EBF provides for students with mild, high-incidence special education needs.

• The EBFM does not address the needs of students with more significant needs.

The Illinois School Funding Reform Commission Report (ISFRC) dated 2.1.17 stated:

“the funding of the majority of the special education services

will be incorporated into the elements of the integrated formula.”

EBF does not provide for high-cost, low-incidence students with disabilities.

The Outstanding Issues Requiring Resolution in the ISFRC Report indicates that:

“ISBE staff will work collaboratively with the members of the General Assembly to

determine how to ensure, through possible changes to the School Code and/or the

funding formula, that funding does not influence whether students are placed in

private or public special education settings.”

Evidence-Based Funding

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Special Education State

Mandated Categorical Appropriations

ProgramFY17

Appropriation

FY18

Appropriation

FY19

Appropriation

Personnel $442,400,000 $0 $0

Funding for Children

Requiring Sp. Ed

Services

$303,829,700 $0 $0

Orphanage Tuition $103,472,500 $73,477,600 $73,000,000

Private Facility

Tuition

$233,000,000 $135,265,500 $135,265,500

Summer School $11,700,000 $0 $0

Transportation $450,500,000 $387,682,600 $387,682,600

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CPS Block Grant

Chicago Public Schools (CPS)

Beginning with fiscal year 2018, Chicago District 299

receives funding for all special education programs in the

same manner as all other school districts.

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Personnel Reimbursement105 ILSC 14-12.01 and 14-13.01

While Personnel Reimbursement has been eliminated, the State Board of Education is still

required to collect and report data under the authority of the Individuals with Disabilities

Education Act (IDEA), Section 618. This data is used for monitoring the program and

activities under IDEA.

• Districts and special education joint agreements will continue to report approved special

education personnel (as of December 1st of each year) in the ISBE I-Star System by

August 15 of each year.

• Districts are advised to continue to use the ISBE Special Education Personnel Approval

Procedures

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Remaining Mandated Categoricals

The State of Illinois continues to provide three state categorical

reimbursement fund sources for districts serving students with

disabilities who require special education and related services.

• Private Facility to 105 ILCS 5/14-7.02

• Orphanage 105 ILCS 5/14-7.03

• Transportation 105 ILCS 5/29-5

Reporting requirements remain the same.

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Orphanage Tuition

Reimburses 100% of the current year tuition costs for eligible students with

disabilities who are wards of the State under the guardianship of a public

agency or who reside in state residential facilities. This includes regular

term and summer term.

Regular Orphanage Tuition Claim Due: July 15th

Summer Orphanage Tuition Claim Due: November 1st

Reimbursed Quarterly

Reimbursement Formula

Education Costs + Required Transportation =

Reimbursement

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Private Facility Tuition Reimbursement

Provides reimbursement for a portion of the private facility

tuition costs incurred by the district from the prior school year.

Private Tuition Claim Due: August 15th

Reimbursed Quarterly

Reimbursement Formula

Reimbursement Level Costs exceeding 2x the district

per Capita cost

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Special Transportation Claim

The state program pays a maximum of 80% of

the district’s allowable costs for transporting

pupils with disabilities.

Transportation Claim Due: August 15th

Reimbursed Quarterly

Reimbursement Formula

Eligible Costs *80% = Reimbursement

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Federal Room & Board Reimbursement

District must have an approved ISBE Private Residential

Placement Room & Board Reimbursement Form to

transmit a claim.

Claims should be submitted monthly through IWAS

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Excess Cost Reimbursement

• Reimbursement for educational costs of high-cost,

high-need students whose costs are in excess of

4x the district per capita tuition charges

• There is no dedicated budget line-item allocation

for Excess Cost Students.

• Reimbursed from excess federal room & board

funds.

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Continuing Efforts to Address

Funding for Students with

Significant Needs

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Federal Funding

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Federal Funding

IDEA and PreSchool Grants

The IDEA Flow Through Grant provides supplemental funds to districts so that

all eligible children ages 3 through 21 receive a free appropriate public

education in the least restrictive environment.

The IDEA Pre School Grant provides supplemental funds for a comprehensive

special education program for children ages 3 through 5 with disabilities.

FY19 Preschool Allocation: $ 17,657,300

FY19 IDEA Allocation: $530,733,900

* All funds must be spent to supplement (not supplant)

special education services21

Federal Revenue

IDEA Grant Guidance

• Allowable expenditures:

– Special education staff salaries & benefits

• Para-professionals, occupational therapists, physical therapists

• Teachers, social workers, psychologists, speech language = 10.1% TRS

Penalty

• Percent of benefits allowable must be equal to percent of staff salary

• Acceptable to expend salaries with no benefits, but it is not acceptable to

expend benefits without a salary

– Supplies & equipment used for special education students

– Travel expenses for personnel

– Professional development, in-service & presenter fees

– Tuition (not attributable to TRS salaries)

– Proportionate Share22

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Maintenance of Effort and

Excess Cost Requirements

Maintenance of Effort

• A Year-to Year Comparison

• Requirement: A district is required to

expend at least the same amount of

local, or state and local funds for the

education of children with disabilities

as it expended in precious years on a

total or per capita basis.

Excess Cost

• Not a Year-to-Year Comparison

• Requirement: Districts must use IDEA

funds to pay only the excess cost of

providing educational services for

children with disabilities.

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Excess Cost Worksheet

Federal Regulation requiring districts to calculate, document and verify

the excess cost of educating students with disabilities based on an annual

per pupil expenditure.

IDEA excess cost worksheet collects district expenditure and student

population data to calculate an average annual per pupil expenditure

(APPE) and IDEA excess cost threshold.

Excess Cost Worksheet – Due January 31st to ISBE

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Special Education Reporting

Maintenance of Effort

Federal Regulation requiring districts to expend at

least the same year-over-year on educating students with

disabilities based on total year Special Education

expenditures.

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Maintenance of Effort Requirement

Four Ways to meet the Maintenance of Effort

Requirement

1. Local expenditure comparison,

2. State and local expenditure comparison

3. Per capital comparison

4. By exceptions.

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Maintenance of Effort Exceptions

Exception #1

The voluntary departure, by retirement, resignation, or for just cause, of special education or

related services personnel

• Does not include contract non-renewal, reassignment or staff lay-off due to RIF

Exception #2

The termination of the obligation to provide an exceptionally costly special education

program to a child with a disability

• Leaves the district

• Ages out of the district (from 8th Grade into High School)

• Graduates

• No longer needs the program due to IEP change

Exception #3

The termination of costly expenditures for long-term purchases

• acquisition of equipment (with a unit cost of at least $5,000)

• construction of school facilities

Alternative Way to Meet MOE

• Increase in per capita spending

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MOE Calculations

FY16 Expenditures $1,000,000

FY17 Expenditures $1,500,000

Met MOE by $ 500,000

FY16 Expenditures $1,000,000

FY17 Expenditures $ 950,000

Missed MOE by $ 50,000

District would be required to reimburse Federal Government for $50,000

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IDEA Grant Guidance/Tips

• Funds are specific to the fiscal year, all expenditures must take

place within the grant period

• May begin to obligate funds when a substantially approvable

grant has been submitted to ISBE

• Liquidation period – 90 days from end of grant

• Start date for expenditures is tied to the start of the grant and

approved amendments

• Only working lunches, no snacks, water, etc. Keep proof of the

necessity for a working lunch. No refreshments.

• Maintain backup to be Audit and MOE ready29

Medicaid Claiming

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Medicaid

School personnel may be involved in identifying, coordinating, delivering and monitoring students’ needs for health and related services. Many of these activities are covered by

Medicaid and are reimbursable through the school-based Medicaid programs.

There are two Medicaid programs that districts can participate in to get reimbursed for Medicaid services: Medicaid Administrative Claiming (MAC) and Fee for Service (FFS).

Administrative Outreach• Allows districts to receive partial reimbursement for the administrative costs

related to the identification and assistance of students who are considered at-risk and in need of service.

Fee For Service• Allows for reimbursement to schools for health-related services provided to

Medicaid eligible students who are receiving special education services.31

Administrative Outreach

• The Illinois Department of Healthcare and Family Services (HFS) partners

with Fairbanks LLC in the implementation of a statewide Medicaid

Administrative Claim (MAC) Program through a Random Moment in Time

Study (RMTS) process.

– Staff are selected for Random Moments in Time throughout the quarter.

– A moment represents one minute at a particular time.

– 4 Quarters – October, January, April, July

– Staff receive notification of time and date – they log on and answer 4

simple questions

– Results of this study determine reimbursement rates for activities.

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Fee for Service

• Federal reimbursement for direct therapy services.

• Student must be Medicaid eligible, have an IEP, and have services that are necessary for development of the IEP or are specified in the IEP.

• Services eligible for federal Medicaid reimbursement:

Audiology

Physical Therapy

Developmental Assessments

Speech Therapy

Social Work

Psychologist Services

Occupational Therapy

Nursing Services

Health Aide Services

Transportation

Medical Equipment, Services and

Supplies

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Medicaid Claiming Tips

• Before the quarter starts, identify all of your positions that qualify and the employees assigned to those positions.

• Make sure staff are not being funded through IDEA if possible

• Identify the expenditures that will be needed for the claim.

o Fairbanks has excellent resources on their website

• Third Party Vendors

• Collaboration between Special Education and the Business Office

o Collecting Data

• Being Audit Ready

o System for maintaining documents (staff logs, parent consents, referrals/scripts)

o Errors found from previous federal audits include:

• Missing / Insufficient Documentation

– Service not on IEP, Student not Present on Date of Service, etc.

• Procedure Coding Errors

• Medically Unnecessary Services

• Services Rendered by Excluded Provider 34

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Funding for Transition Age Students

(post high school, up to age 22)

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Transition

Funding is available for transition age students (post high school, up to age 22)

through:

• The Department of Rehabilitative Services (DRS),

• The Secondary Transitional Education Program (STEP), and

• The Workforce Innovation and Opportunity Act (WIOA) grant funded by

the Department of Labor.

These grant dollars help offset program costs and more importantly, provide

students with disabilities access to education, training, and employment

opportunities. It is the goal of the transition program to prepare the students to

be competitively employed by the time they reach the age of 22.

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Aligning Resources to Student Needs

• District Priorities and Goals

• Identified Student Needs

• Resource Identification and Allocations

• Economy of Scale

• Evaluate Effectiveness and Efficiency

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Legislative Update

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Questions

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Disclaimer

This presentation provides information based on the

interpretation of current information from the

Illinois State Board of Education (ISBE) and may

change based on information and guidance put

forward by ISBE.

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