TITLE I, PART A/LAPSPRING WORKSHOP

May 2013

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Agenda

• Schoolwide Programs• Parent Involvement• Private Schools• Title I, Part A iGrant Application - FP201• Charter Schools• Allowable Costs – Basic Guidelines• Time and Effort• Learning Assistance Program (LAP)

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SCHOOLWIDE PROGRAMSTitle I, Part A

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Title I, Part A Schoolwide Programs

• The schoolwide program model is a comprehensive reform strategy designed to upgrade the entire reading and mathematics program for the Title I, Part A building

• The primary goal of the schoolwide program is to ensure that all students, particularly those who are low-achieving, demonstrate proficient and advanced levels in the state academic achievement standards

• To create schoolwide reform, the primary focus of the schoolwide program is to design and implement a well defined “schoolwide-system model”, of tiered/leveled additional interventions

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Step 1

• Readiness to Benefit: Schoolwide-Systematic Reform Based Model• Clarify the vision of reform/A clear focus• Discuss with staff shared vision• Analyze ten components of schoolwide plan

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Step 2

• Develop a comprehensive needs assessment for the entire building:• Modify schoolwide needs based on annual evaluation

and review of program• Determine where the building is now and where it

wants to be when its vision is realized• Collect, sort, analyze data • Reading, mathematics, language arts, and science

• Set priorities and concerns• Identify strengths and weaknesses

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Step 3• Build Schoolwide comprehensive component plan to identify reform

strategies:• Create a tiered/leveled model of additional intervention• Determine and identify proven researched-based strategies,

designed to facilitate reform and improvement • Accept a collective responsibility for reaching and teaching all

students• Tie all components to needs assessment (including which programs

to be combined in the schoolwide program)• Set measurable goals-define action plan for reform• Includes list of programs combined, amount combined and how

their intent and purpose of each combined program are met in the schoolwide plan and program (this will be used to determine appropriate time and effort) 7

Step 4

• Implement the plan• Ongoing review of action plans• Review effectiveness of systematic-intervention model• Keep documentation of implementation• Modify and make adjustments, as needed, during the

year

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Consolidating Funds

• Schoolwide programs may combine federal, state and local funds of programs consolidated

• Schools operating schoolwide programs are not required to maintain separate accounting records for combined programs if• Combined programs are identified in the plan• School maintains records documenting intents and

purposes of programs combined are met

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Purpose/Benefit of Consolidation

• To help schoolwide school effectively design and implement a comprehensive plan to upgrade the entire educational program in the school based on needs identified in the needs assessment

• When combining BEA funds, instructional staff become schoolwide staff• Instructional staff are part of an additional tiered-model of

interventions• Use of all available resources to meet needs• Flexibility in use of resources• Not required to account separately for funds used in program• Not required to meet most statutory and regulatory

requirements of specific program included in consolidation10

Consolidation of Funds

• Treat funds as a single “pool” of funds• Lose individual identity• Use funds to support any activity of the schoolwide program • But, must meet intent and purpose of each program

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Schoolwide Program

Title I, Part A Schoolwide ProgramTitle I, Part A (Disadvantaged)Title II, Part A (Professional Development)BEA (Basic Education)Local Funding, Levy, District, etc.Title III, (Immigrant)

Most ED Programs

Cannot IncludeTransitional BilingualState Special EducationState Highly CapableIOther State Programs which are

limited only to certain students (not available to allstudents in the building)

RestrictedMigrantIndian EducationFederal Special EducationLAP

Carl Perkins

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Consolidated Program Review: CPRSchoolwide Non-Compliance Issues

1.7: Each Title I, Part A schoolwide building has a schoolwide building plan that contains the 10 component requirements and evidence the plan has been implemented, Section 1114(b)(1); 34 CFR 200.25

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Supporting Documentation: Building Level-Schoolwide

• Building Level: A copy of a schoolwide plan that includes the following 10 required components and supporting evidence: 1. Comprehensive need assessment2. Schoolwide reform strategies3. Instruction by highly qualified teachers4. On-going professional development5. Strategies to attract highly qualified teachers6. Strategies to increase parent involvement7. Transition8. Measures to include teachers in assessment decisions9. Strategies for additional assistance10. Coordination and integration of federal, state and local services and

programs14

Common CPR-Non Compliance Issues Related to Schoolwide Plan

• Schoolwide plan not current-not updated from original plan submission

• Schoolwide plan not well-defined-statements with no evidence

• Schoolwide documentation evidence reveals schoolwide

model is in actuality a targeted-assistance program model

• Cannot provide schoolwide plan 15

Common CPR-Non Compliance Issues Related to Schoolwide Plan

Components

The following components missing or lack of evidence: • Instruction by highly qualified teachers • Strategies to attract highly qualified teachers to high

needs schools• Transition• Coordination and integration of federal, state and

local services and programs

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Common CPR-Non Compliance Issues Related to Schoolwide Plan Component

• Component 10: Coordination and integration of federal, state and local services and programs• Component missing completely• Evidence for component list names of programs only• No matrix: Does not list funds combined, amount of

funds, and the intent and purposes of combined funds• Matrix missing one or more of three required fields• Matrix lists all funds in

building-allowable/restricted/or not allowable to combine 17

Use Correct Order

1. Determine which funds will be combined2. Address intents and purposes in the plan3. Meet and document intents and purposes4. Determine how to charge

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Fiscal Flexibility

• Examples of ways to charge consolidated funds• Charge proportionately based on revenue• Charge sequentially• Charge based on activity (not use flexibility)

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Title I, Part A Schoolwide:Supporting Documentation

• OSPI Combining Funds Bulletin: Bulletin #054-12 http://www.k12.wa.us/BulletinsMemos/bulletins2012.aspx

• Designing Schoolwide Programs: Non-Regulatory Guidance-March 2006 http://www.k12.wa.us/TitleI/TitleI/SchoolwideModel.aspx

• ESEA/Section 1114(b)(1); 34 CFR 200.25

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PARENT INVOLVEMENT POLICYTitle I, Part A

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Parent Involvement CPR Issues

District and Building Policies containing all the required elements.•District & Building CPR Monitoring Checklist

Evidence of implementation:• Notification of meetings• Agendas• Sign-in Sheets

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Parent Involvement CPR Issues

1% (Districts who receive an allocation of $500,000 or greater)• The district ensures parents have the opportunity to

be involved in decisions regarding the 1% parent involvement funds.

Evidence at district level of:• Parent survey• Meeting minutes, and/or • Agenda

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FP 201-Updates

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FP 201-Updates

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FP 201-Updates

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Parent Involvement News

Title I, Part A Parent Involvement Webpage

1. Survey News2. OSPI Title I, Part A – New Parent

Involvement Website3. Parent involvement website with

requirements across all federal programs (long term goal)

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Parent Involvement -Resources

• Parental Involvement: Title I, Part A Non-Regulatory Guidance• http://www2.ed.gov/programs/titleiparta/parentinvguid.pdf

• Keys to Successful Partnerships: Six Types of Involvement• http://www.csos.jhu.edu/p2000/nnps_model/school/sixtypes.htm

• CISL Website – Family Engagement, translation/interpretation• http://www.k12.wa.us/CISL/FamilyEngagement/Communicating/

TranslationTips.aspx

• Spanish/English glossary of education terms• http://www.k12.wa.us/CISL/FamilyEngagement/Communicating/

Glossaries.aspx 28

PRIVATE SCHOOLSTitle I, Part A

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School District Responsibility to Provide Equitable Services for Eligible Private School

Students, Teachers and Parents

Equitable services must be provided whether the private school is within or outside school district boundaries.

•Students – Supplemental instruction in reading, language arts or mathematics •Teachers of Title I, Part A Served Students – Professional development in the area of Title I, Part A services•Parents of Title I, Part A Served Students – Parent involvement activities that assist parents with the learning of their children

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Eligibility Criteria for Funds and Services

• Funds: Funds are generated on the basis of the number of students from low-income families who reside in the participating Title I, Part A public school attendance areas and attend private schools, whether the private schools are located within the district or outside the district boundaries

• Services: Private school students who reside within a Title I, Part A attendance area and are failing or most at risk of failing to meet high standards are eligible for services

Establish Procedures to Ensure Equitable Services are Identified and Provided

• Process involves multiple entities who must establish an

agreeable procedure that works best for them, including the process to identify eligible students and determination and delivery of equitable services• Entities include:• Residing district of the private school student• District where the private school is located• Private school

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Possible Options for Equitable Services Process

1. Private school contacts the districts where students live• Residing district then conducts consultation to identify eligible students• Equitable services identified – residing district and private school may

work with district where private school is located to provide services

2. Residing district contacts private schools in the surrounding area to identify eligible students• Residing district consults with private schools and district where each

private school is located

3. School district where private school is located contacts the private school and proceeds to contact residing districts of identified students• Conducts consultation process• Identifies all low-income students• Identifies students out of district and contacts residing district• Districts and private school work together to determine services 33

Providing Equitable Services

Services may be provided by:• Employee of the residing district• Third party contract by residing district • District where the private school is located• Interlocal agreement between the residing district and

the district where the private school is located establishes the services to be provided along with the funding amounts to provide the services

• Services may be provided by an employee of the school district or a third party

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Title I Equitable Services Resources

• Title I Services to Eligible Private School Children, Non-Regulatory Guidance, October 2003 (Department of Education)

• Ensuring Equitable Services to Private School Children: A Title I Resource Tool Kit, September 2006 (PDF with downloadable tools) (Department of Education)

• Both documents available on the OSPI website at: http://www.k12.wa.us/ESEA/PrivateSchools.aspx

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IGRANT APPLICATION – FP 201Title I, Part A

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Title I iGrant Application (FP201) Changes

• Contact Page: Please update school district contact information

• Page 1: REAP Section removed• Page 2: Assurances updated• Page 3: Affirmation of Consultation form updated – If a

2012-13 affirmation form was completed for 2013-14 consultation process – okay to use for this year.

• Page 4: Questions 10 & 11 Priority, Focus or Emerging Schools expanded

• Page 4: Questions 14, 15 & 16 Parent Involvement updated• Pages 5-7: No changes

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CHARTER SCHOOLS 38

Title I, Part A

Charter Schools - Accountability

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• Accountability is overseen in accordance with state charter school law

• The charter authorizer is primarily responsible for holding charter schools accountable under the Title I, Part A provisions unless state law specifically gives the state educational agency (SEA) direct responsibility for charter school accountability

Section 1111(a)(2)(A)

Charter Schools - Allocations for Title I, Part A

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• If a charter school is authorized by an entity other than a traditional school district, the SEA will still be responsible for allocating Title I, Part A funds directly to the charter school, pursuant to federal and state laws

• If a charter school is, under state law, part of a district, the district will allocate federal funds to the charter school on the same basis as it provides funds to its other schools

Charter Schools - Corrective Action

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• As with other public schools, charter schools that are unable to make adequate yearly progress (AYP) by the end of the second full school year after identification are placed under corrective action

• The appropriate entity under state law has responsibility to reorganize a charter school’s management or take other corrective actions, consistent with state charter law and the state’s accountability plan for its charter schools

Section 1116(b)(7)(C)

Charter Schools - Teacher Qualifications

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• The law provides that a teacher who teaches core academic subjects in a charter school meets the certification requirement if he or she meets the requirements set forth in a state’s charter school law regarding certification or licensure

• Teachers in charter schools do not have to be licensed or certified by the state if the state’s charter law does not require such licensure or certification

Section 9101(23)(A)(i)

Charter Schools - Paraprofessional Qualifications

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• Paraprofessional aides hired to work in programs supported with Title I, Part A funds must have a high school diploma or its recognized equivalent

• Those who act as translators or conduct parent involvement activities must also have completed at least two years of study at an institution of higher education, possess at least an associate’s degree, or demonstrate subject-matter competence through a formal state or local assessment

Section 1119(c)-(e)

*This requirement applies only to paid paraprofessionals and not to parents or other volunteers. In addition, the term “paraprofessional” applies only to individuals who provide instructional support and not to school staff who have only non-instructional duties (e.g., providing technical support for computers, providing personal care services to students, carrying out clerical functions) [34 C.F.R. Section 200.58(a)(2)].

ALLOWABLE COSTS – BASIC GUIDELINES

Title I, Part A

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Allowability of Costs

To be allowable a cost must:•Be necessary and reasonable for proper and efficient performance and administration of federal awards•Be allocable to federal awards• Be authorized under state and local laws, policies and

procedures•Conform to any limitations in the A-87 circular•Be consistent and applied consistently (capital assets, direct vs. indirect costs, etc.)

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Allowability of Costs

Allowable if:•Follows generally accepted accounting principles•Not be used to meet cost sharing or matching of another federal award•Is net of all applicable credits•Is adequately documented

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Reasonable Costs

• Prudent Person Test• Ordinary and necessary for operation or performance of

federal awards• Follows sound business practices; arms-length

bargaining; follows laws/regulations federal terms• Market price for comparable goods and services• Administered with prudence• No significant deviations; consistent with non-federal• Benefits the program

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Presumptions of supplanting for districts and targeted assistance buildings-

•Federal funds were used to provide services that the district was required to make available under federal, state or local law

•Federal funds were used to provide services provided with non-federal funds in the prior year(s)

•Title I, Part A or C funds were used to provide services for participating children that were provided with non-federal funds for non-participating children

•Rebuttal may be possible in some cases

Supplement-Not-Supplant (Services to Students)

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• Presumption of supplanting for Title I, Part A schoolwide buildings

• Must show each schoolwide building received all state and local funds to which it is entitled, including those for basic education, for children with disabilities and for limited English proficient children

Supplement-Not-Supplant

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TIME AND EFFORT REPORTINGTitle I, Part A

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Why Does Time and Effort Continue to be an Audit Problem?

• Large percent of federal education funds used for staffing• Staff turnover• Decentralized responsibilities• Lack of adequate communication between program and

fiscal staff• Complexity of applying requirements to variety of

situations• People don’t like it!

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Where are the Requirements?

• Time and effort reporting is required under 2 CFR Section 225 (formerly Federal Office of Management and Budget’s Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments)

• Attachment B, Selected Items of Cost, Compensation for personal services

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When is Time and Effort Required?

• Time and effort reporting is required when any part of an employee’s salary is:• Charged to a federal program• Used as match for a federal program

• Employee’s time is split between an indirect and any direct cost objective

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What is an employee?

• Salaries, wages and benefits are charged under objects 2, 3, and 4

• An employee is NOT a vendor or independent consultant/contractor• No time and effort is needed for non-employees (See

OMB Circular A-133 __.210 for vendor criteria)

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What type of reporting is needed?

• Single cost objective→Semi-annual certification

• Multiple cost objectives→Monthly time reports or Personnel Activity Reports (PARs)

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What is a “cost objective”?

• A particular set of work activities for which cost data is accumulated

• For purposes of time and effort reporting: Define cost objectives according to the set of work activities allowable under the terms and conditions of each funding source (Examples: Parent Involvement or Professional Development in a Federal Program) 56

What are some typical examples of single cost objectives?

The set of work activities allowable under:• A single federal program• A single required set-aside/reserve in a federal

program• Federal Special Education and State Special

Education• A schoolwide program• A federal program and its state/local match

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What are some typical examples of multiple cost objectives?

The work activities of:• A federal program with multiple

set-asides/reserves• A federally-funded program and a state-and/or

locally-funded program• A schoolwide program and a program not

combined in the schoolwide program

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What is a semi annual certification?

• Statement (certification) individual(s) worked solely on activities related to a single cost objective during defined dates• Completed at least every six months• Signed and dated by employee or supervisor with

first-hand knowledge of work performed• For internal control purposes, district may request

both employee and supervisor sign

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What is a monthly time report?(PAR)

• Accounts for total worked time/activity (including non-federal time)• Prepared and signed at least monthly• Signed and dated by employee• Reflects actual work performed (not budgeted)• Agrees with supporting documentation

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What type of supporting documentation is needed?

• Requires a judgment call • Examples include, but are not limited to:• Class schedules• Number of students• Number of minutes• Calendars or work logs

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When is a “reconciliation” required?

Payroll records must be compared to time and effort reports at least quarterly to ensure no unallowable charges to federal awards

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When is an accounting adjustment required?

If the difference is 10 percent or more: • Payroll charges must be adjusted at the time of the

reconciliation

• AND: The following quarter’s budget estimates must be adjusted to more closely reflect actual activity

If the difference is less than 10 percent:• No accounting adjustment is required until the end of the

year

• BUT: At year-end any payroll charges to federal awards that exceed actual time and effort must be eliminated

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Who should sign the reports?

• Monthly reports (PARs) must be signed by the employee

• Semi-annual certifications must be signed by employee or supervisor having first-hand knowledge of work performed

• For internal control purposes, districts may require both the employee and supervisor to sign

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Schoolwide Programs

• A schoolwide plan must specify programs to be combined

• A schoolwide program is a single cost objective if an employee works 100 percent on programs combined→Group or individual semi-annual certification permitted

• If an employee works partially on programs combined and partly on those not combined→ Monthly time report (PAR) required

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Supplemental Contracts, Stipends, Extra Hours

• Primary contract and additional contracts may be reported separately

• Time and effort may be required for primary contract but not supplemental (or vice versa)

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Administrators

• Superintendent, assistant superintendent, principal, assistant principal are usually not allowable charges to federal programs• Exceptions require detailed documentation

to support• Generally a supplant issue

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What is a substitute system?

• Alternative method for calculating and supporting compensation charges to federal grant funds (usually based on a statistical sample of work performed)

• Used only for federal programs specified in approved substitute system plan

• Must be approved by OSPI prior to use• Must be statistically sound• Should be periodically reviewed to determine if

still appropriate68

New Substitute System

• Semi-annual certifications permitted for multiple cost employees with predetermined (fixed) schedules

• Employee MUST sign• Must notify OPSI prior to usehttp://www.k12.wa.us/SAFS/TT/Time%20and%20Effort/Sustitute

%20System%20Fixed%20Schedule%20Certification%20Form.pdf

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Other Requirements for Charging Compensation to Federal Programs

• Reasonable, necessary and allocable to the program charged• Compensation consistent with nonfederal

activities of the district• Leave buy-out at termination is an indirect charge• Supplement, not supplant applies to many

programs

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Tips……• Know the basics• Train and re-train:• Annual training in district• Explain the “why”• OSPI Bulletin – Keep it handy

• Assign central responsibility:• Ensure all reports are completed

• Communicate:• Who needs to communicate what changes to

whom• Ask for help if needed

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Additional Information on Time and Effort

• OSPI Bulletin 051-11 http://www.k12.wa.us/BulletinsMemos/bulletins2011.aspx • Examples• Sample forms

• 2 CFR Section 225 (OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments

• Time and effort FAQs (on CPR website at http://www.k12.wa.us/ConsolidatedReview/Fiscal.aspx )

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OSPI Title I/LAP Contacts

• Title I, Part A/LAP Program Director• Gayle Pauley, gayle.pauley@k12.wa.us, 360.725.6100

• Title I, Part A/LAP Program Supervisors• Bill Paulson, bill.paulson@k12.wa.us, 360.725.6104• Jody Hess, jody.hess@k12.wa.us, 360.725.6171• John Pope, john.pope@k12.wa.us, 360.725.6172• Larry Fazzari, larry.fazzari@k12.wa.us, 360.725.6189• Mary Jo Johnson, maryjo.johnson@k12.wa.us, 360.725.6103• Penelope Mena, penelope.mena@k12.wa.us, 360.725.6069• Petrea Stoddard, petrea.stoddard@k12.wa.us, 360.725.6169• Reginald Reid, reginald.reid@k12.wa.us, 360.725.6168

• Title I, Part A/LAP Support Staff• Julie Chace, julie.chace@k12.wa.us, 360.725.6167• Tony May, tony.may@k12.wa.us, 360.725.6231

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