Uses and Budgeting of Title I, II, III and VI Funds

January 13, 2010Bambi Perrigin and Edmund Moore

Needs AssessmentCoordinate with other members of

LEAUse comprehensive dataResults should reflect the needs of

the system and should be prioritized

Collaboration should drive how funds can be best leveraged to meet the needs in the best possible way

Planning and BudgetingThe LEA should work collaboratively with a

team during the planning and budgeting process

Develop goals, strategies and detailed action steps based on needs

Identify allowable funds to support the goals, strategies and action steps

All expenditures must be in compliance with all federal regulations and guidance (NCLB, EDGAR, GAAP, etc.)

Resources are a finite amount and should be used wisely and in accordance with allowable uses

LEA should not have isolated decision-making.

Administrative CostsTitle I – 15%

Title II – 5%

Title III – 2%

Title VI – 5%

Supplement, not Supplant

Consider….◦What does the state provide?◦What does the LEA provide?◦SUPPLEMENT with federal funds!

Which fund sources can meet the need?◦Include information in grant

relationships…

Circular A-87All costs must be:

Necessary Reasonable Allocable Legal under state and local law

In addition all cost principles must: Conform with federal law & grant terms Be consistently applied Adequately documented Be in accordance with Generally

Accepted Accounting Principles (GAAP)

What does necessary and reasonable mean?

Must be necessary for the performance or administration of the grant

Must follow sound business practices

Fair market price

Be PracticalPractical aspects of “reasonable”

◦ Is the expense targeted to valid programmatic/administrative considerations?

◦ Do I have the capacity to use what I am purchasing?

◦ Did I pay a fair rate? Can I prove it?◦ If I were asked to defend this purchase,

would I be comfortable?Practical aspects of “necessary”

◦ Do we really need this?◦ Is this the minimum amount I need to

spend to meet the need?

Be PracticalPractical aspects of “allocable”

◦ Can I prove the program benefited? Time and effort records

◦ Can I prove other programs are not benefiting? Ensuring only authorized use

Practical aspects of “adequate documentation”◦ Award amount◦ Details of how funds are used◦ Total cost of project◦ Records showing compliance with rules

and regulations◦ Records showing performance

Title I – Allowable Uses of FundsInstructional Materials and SuppliesEquipmentPersonnelBefore and After School ProgramsSummer SchoolPreschoolProfessional DevelopmentParent InvolvementTechnology

Title I Targeted Assistance ProgramsTitle I funds in a targeted

assistance programs may only be used to benefit targeted assistance (TA) students (as identified on the eligibility list).

Supplement not supplant applies. Therefore, the TA students must receive additional services from Title I.

Title II Uses of Funds(NCLB Section 2123)

A local educational agency that receives a subgrant under section 2121 shall use the funds made available through the subgrant

to carry out one or more of the following activities:

(1) Developing and implementing mechanisms to assist schools in effectively recruiting and retaining highly qualified teachers, including specialists in core academic subjects, principals, and pupil services personnel, except that funds made available under this paragraph may be used for pupil services personnel

(2) Developing and implementing initiatives to assist in recruiting highly qualified teachers (particularly initiatives that have proven effective in retaining highly qualified teachers), and hiring highly qualified teachers, who will be assigned teaching positions within their fields

(3) Providing professional development activities that improve the knowledge of teachers and principals and, in appropriate cases, paraprofessionals

(4) Developing and implementing initiatives to promote retention of highly qualified teachers and principals, particularly within elementary schools and secondary schools with a high percentage of low-achieving students

(5) Carrying out programs and activities that are designed to improve the quality of the teacher force

(6) Carrying out professional development activities designed to improve the quality of principals and superintendents, including the development and support of academies to help talented aspiring or current principals and superintendents become outstanding managers and educational leaders.

(7) Hiring highly qualified teachers, including teachers who become highly qualified through State and local alternative routes to certification, and special education teachers, in order to reduce class size, particularly in the early grades.

(8) Carrying out teacher advancement initiatives that promote professional growth and emphasize multiple career paths (such as paths to becoming a career teacher, mentor teacher, or exemplary teacher) and pay differentiation.

(10) Carrying out programs and activities related to exemplary teachers.

*NCLB does not have a (9)

Title II eGAP Budget Details

Title III Purpose of Subgrants(NCLB Section 3115)

A State educational agency may make a subgrant to an eligible entity from funds received by the agency under this subpart only if the entity agrees to expend the funds to improve the education of limited English proficient children, by assisting the children to learn English and meet challenging State academic content and student academic achievement standards. In carrying out activities with such funds, the entity shall use approaches and methodologies based on scientifically based research on teaching limited English proficient children and immigrant children and youth.

Title III Required Activities - An eligible entity receiving funds under section 3114(a) shall use the funds(1) to increase the English proficiency

of limited English proficient children by providing high-quality language instruction educational programs that are based on scientifically based research demonstrating the effectiveness of the programs in increasing — ◦(A) English proficiency; and◦(B) student academic achievement in the

core academic subjects; and

Title III Required Activities - An eligible entity receiving funds under section 3114(a) shall use the funds

(2) to provide high-quality professional development to classroom teachers (including teachers in classroom settings that are not the settings of language instruction educational programs), principals, administrators, and other school or community-based organizational personnel.

Title III eGAP Budget Details

Title III Allowable Activities - An eligible entity receiving funds under section 3114(a) may use the funds to achieve one of the purposes described in subsection (a) by undertaking one or more of the following activities

(1) Upgrading program objectives and effective instruction strategies.

(2) Improving the instruction program for limited English proficient children by identifying, acquiring, and upgrading curricula, instruction materials, educational software, and assessment procedures.

(3) Providing tutorials and academic or vocational education for limited English proficient children; and intensified instruction.

(4) Developing and implementing elementary school or secondary school language instruction educational programs that are coordinated with other relevant programs and services.

(5) Improving the English proficiency and academic achievement of limited English proficient children.

(6) Providing community participation programs, family literacy services, and parent outreach and training activities to limited English proficient children and their families to improve the English language skills of limited English proficient children; and to assist parents in helping their children to improve their academic achievement and becoming active participants in the education of their children.

(7) Improving the instruction of limited English proficient children by providing for the acquisition or development of educational technology or instructional materials; access to, and participation in, electronic networks for materials, training, and communication; and incorporation of the resources described in subparagraphs (A) and (B) into curricula and programs, such as those funded under this subpart.

(8) Carrying out other activities that are consistent with the purposes of this section.

Immigrant Children and YouthAn eligible entity receiving funds

under section 3114(d)(1) shall use the funds to pay for activities that provide enhanced instructional opportunities for immigrant children and youth, which may include —

(A) family literacy, parent outreach, and training activities designed to assist parents to become active participants in the education of their children;

(B) support for personnel, including teacher aides who have been specifically trained, or are being trained, to provide services to immigrant children and youth;

(C) provision of tutorials, mentoring, and academic or career counseling for immigrant children and youth;

(D) identification and acquisition of curricular materials, educational software, and technologies to be used in the program carried out with funds;

(E) basic instruction services that are directly attributable to the presence in the school district involved of immigrant children and youth, including the payment of costs of providing additional classroom supplies, costs of transportation, or such other costs as are directly attributable to such additional basic instruction services;

(F) other instruction services that are designed to assist immigrant children and youth to achieve in elementary schools and secondary schools in the United States, such as programs of introduction to the educational system and civics education; and

(G) activities, coordinated with community-based organizations, institutions of higher education, private sector entities, or other entities with expertise in working with immigrants, to assist parents of immigrant children and youth by offering comprehensive community services.

Title III eGAP Budget Details (con’t)

Total from all the

sections

Title VI Uses of Funds(NCLB Section 6222)

LOCAL AWARDS- Grant funds awarded to local educational agencies under this subpart shall be used for any of the

following:

(1) Teacher recruitment and retention, including the use of signing bonuses and other financial incentives.

(2) Teacher professional development, including programs that train teachers to utilize technology to improve teaching and to train special needs teachers.

(3) Educational technology, including software and hardware, as described in part D of title II.

(4) Parental involvement activities. (5) Activities authorized under the Safe and Drug-Free

Schools program under part A of title IV. (6) Activities authorized under part A of title I. (7) Activities authorized under title III.

Title VI Accountability(NCLB Section 6224)

DETERMINATION REGARDING CONTINUING PARTICIPATION- Each State educational agency or specially qualified agency that receives a grant under

this subpart shall —

(1) after the third year that a local educational agency or specially qualified agency in the State receives funds under this subpart, and on the basis of the results of the assessments described in subsection (d) — ◦ (A) in the case of a local educational agency, determine whether the local educational

agency made adequate yearly progress, as described in section 1111(b)(2); and◦ (B) in the case of a specially qualified agency, submit to the Secretary information that

would allow the Secretary to determine whether the specially qualified agency has made adequate yearly progress, as described in section 1111(b)(2);

(2) permit only those local educational agencies or specially qualified agencies that made adequate yearly progress, as described in section 1111(b)(2), to continue to receive grants under this subpart; and

(3) permit those local educational agencies or specially qualified agencies that failed to make adequate yearly progress, as described in section 1111(b)(2), to continue to receive such grants only if the State educational agency disbursed such grants to the local educational agencies or specially qualified agencies to carry out the requirements of section 1116.

Title VI eGAP Budget Details

Private School Participation

Equitable ParticipationTitle I – ChildTitle II – Geographic AreaTitle III – Geographic AreaWorksheets for each grant are in the eGAP Document Library and must be

completed and uploaded prior to eGAP approval

Title VI is not eligible for Private School Participation

Points to Remember:Identified as a needs on the LEA

Comprehensive Needs Assessment (CIP Needs Assessment)

Based on a decision of the LEA Advisory Committee (School Level Advisory Committee)

Must be SRB and SupplementalIncluded in the LEA Title I Plan

and eGAP System Plan (CIP Plan)

References:NCLB Law and Program GuidanceEDGAR Circular A-87EDGAR Circular A-133

EDGAR – Education Department General Administrative Regulations