title grants division illinois state board of education 1 nclb title grant management isbe illinois...

Title Grants Division

Illinois State Board of Education

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NCLB TITLE

GRANT MANAGEMENT

ISBE Illinois Association of Title I Directors Annual Fall Conference 2014



Purpose of Title I

The purpose of Title I is to ensure that all children

have a fair, equal, and significant opportunity to

obtain a high-quality education and reach, at a

minimum, proficiency on challenging State academic

achievement standards and state academic

assessments.

Statement of Purpose from currently authorized

Elementary and Secondary Education Act (2001)2



Title I Fiscal Requirements

Three fiscal requirements related to the expenditure

of regular State and local funds. The LEA must:• Maintain fiscal effort with State and local funds

• Provide services in its Title I schools with State

and local funds that are at least comparable to

services provided in its non-Title I schools

• Use Part A funds to supplement, not supplant

regular non-Federal funds.

- Department of Education: Non-regulatory Guidance – Title I Fiscal Issues (p.9 )

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Know the Governing Documents

•Education Department General Administrative Requirements (EDGAR)

•Office of Management and Budget (OMB) Circular A-87 *

•OMB Circular A-133 Compliance Supplement *

* Combined into Super-circular (available July 2014)4



Review: What Can You Do?All costs charged to federal funds must be:

• Necessary for the administration of the grant• Reasonable in light of the goals of the federal

programs, the cost of the item, and the needs of the district

• Allocable the cost benefits the grant in proportion to the amount charged

• Authorized under state and local laws and policies

• Adequately documented5



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• Are meals disallowed from Title I? Even for parent meetings?

• May Title I professional development funds be used for meals at workshops and conferences?

Food for Meetings and Conferences



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Review

Use of Grant Funds for Food

A grantee hosting a meeting or conference

may NOT use grant funds to pay for food for

attendees UNLESS doing so is necessary

to accomplish legitimate meeting or

conference business.



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TALK TIME!Scenario #1 – Background Information

• Ace School District has a district-wide initiative to institute

Professional Learning Communities (PLC) in all 3 of its targeted

assistance buildings.

• Total Title I Allocation: $300,000

• The Title I coordinator finds a PLC workshop presented by Rick and

Rebecca DuFour, the leading experts on PLC’s in Seattle, WA. The

participant registration is $700/person and doesn’t include airfare,

lodging, meals, and so forth.

• The Superintendent purchases all administrators a copy of DuFour

and DuFour’s book and takes them through a book study that can

be used in each of the buildings.



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When Does Supplanting Occur?

The OMB A-133 Compliance Supplement details three

general situations where an auditor will presume that

the use of federal funds violates the “supplement, not

supplant” requirement.• Required by law• Supported last year with state and/or local

funds• Provided to everyone (including building not

funded by Title I)



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Overcoming Presumptions of Supplanting

A presumption of supplanting can be overcome by providing written documentation proving:

• State and local funding were significantly reduced.

• The position would have been eliminated in the absence of NCLB funds.

• The grant allows the expenses.

• Funding decisions are made on an annual basis.



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TALK TIME!

Scenario #2 – Supplement or Supplant

• Targeted Assistance Building – Purchase of RtI intervention kit

• Schoolwide Building – Aimsweb testing materials for all students

• Targeted Assistance Building – 1.0 FTE 3rd grade General Education Teacher

• Targeted Assistance Building – Computer adaptive tests for Special Education Students



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TALK TIME!Scenario #3 – Supplement or Supplant

• This year, Very Special School District is experiencing a large reduction in local funds and 10% of the staff will be RIF’d, including 2 Title I teachers that were previously funded by local dollars.

• Can Very Special School District use Title I funds this year to pay for these 2 Title I teachers? Why or Why not?



Schoolwide Programs• Comprehensive reform strategy

• Designed to upgrade the entire educational program in Title I, Part A

• It ensures that all students, particularly those who are low achieving, demonstrate proficient and advance levels of achievement.

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TALK TIME!Scenario #4 – Schoolwide:• Do you have to provide pull-out instruction if

your school is schoolwide?• Can a school provide benefits/services to

students who are not struggling?• Happy Elementary School wants to use their

Title I funds to purchase items that would help to improve attendance, and behavior. Can they use their Title I funds to make the purchases?

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Schoolwide Flexibility

ISBE is introducing the option of consolidation of

funds to increase the flexibility in use of these funds

to support comprehensive reform work as described

in the Title I, Part A schoolwide program plan.

More information:

http://www.isbe.net/grants/html/title1_schoolwide-prog

rams.htm

http://www.isbe.net/grants/html/title1_schoolwide-programs.htm

http://www.isbe.net/grants/html/title1_schoolwide-programs.htm



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Schoolwide Flexibility

Schoolwide flexibility expenditures are governed by

three principles:

(1) is the expenditure reasonable and necessary,

(2) does it meet the intent and purpose of the law and

is aligned with the schoolwide plan, and

(3) does the school receive at least as much state

and local resources as non-Title I schools.



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TALK TIME!

Scenario #5 – Background Information

SDN School District #1 has set aside $50,000

for Professional Development, but they have

only used $25,000 and would like the Health

teachers to participate in several training

opportunities regarding new statewide

initiatives. Is this allowable?



COMMON BUDGET PROBLEMS• Function/object name NOT a

sufficient/acceptable itemization or description.

• Function 1000: Direct STUDENT instruction (not admin, not secretaries, not janitors).

• Object 100: Fiscal agent’s employees. Do not include names

• Object 200: “Benefits” not a sufficient nor acceptable itemization. Please itemize what benefits are being requested. Include amounts.

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COMMON BUDGET PROBLEMS• Object 300: Workers/Unemployment

Compensation are a purchased services not a fringe benefit. Software licenses and ON-LINE subscription services

• Object 400: Purchase of software, equipment costing less than $500/unit, and ALL supplies/materials (no matter what the cost).

• Object 500: Equipment costing more than $500/unit. BUDGET details should include: items requested, per unit and total price, location of items, purpose of items and proration, if any.

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COMMON BUDGET PROBLEMS

Object 700: IF AND ONLY IF there is a BOARD-

APPROVED, ENTITY-WIDE threshold for non-

capitalized equipment of > $500/unit. Budget

details MUST include approved threshold.

Example: District #100 BOARD-APPROVED,

ENTITY-WIDE threshold for non-capitalized

equipment is $5000.

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• Function 2210: Improvement of Instruction:

STAFF development and CURRICULUM planning

(for staff – NOT direct student instruction).

• Function 2220: Media services. The costs

budgeted here are for

services/supplies/equipment housed in a central

location. Library/lab/media center.

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• Function 3000: Community Services: Parent activities and non-public school services/activities.

• Function 4000: Payments to other LEAs and governmental units: PUBLIC governmental units being paid. Budget details must include what governmental unit is being paid.

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TALK TIME!Scenario #6 – Common Budget Problems

• Benedictine University in Springfield is conducting a staff development workshop “School improvement for Learning Growth.” What are the function and object codes?

• School ABC is purchasing I-Read software for Title I students for $700. What are the function and object codes?



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Final Thoughts

• Contact your designated ISBE consultant if you have questions.

• Consult the documents and publications for guidance.

• Frequently check the ISBE website for updated e-bulletins.



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Questions/Comments



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Thank You

Agurann Bates, Principal Consultant

[email protected]

Santita Nunn, Principal Consultant

[email protected]

mailto:[email protected]

mailto:[email protected]

title grants division illinois state board of education 1 nclb title grant management isbe illinois...

Documents

success of title

regulatory guidance

state standards

state academic assessments

expenditure of regular

local education agency

local fundsprovide services

regular nonfederal funds