special education funding 1 compliance and special education funding what’s moe got to do with it?
TRANSCRIPT
Special Education Funding 2
Acronyms and Abbreviations• American Recovery and Reinvestment Act of 2009ARRA
• Coordinated Early Intervening ServicesCEIS• Financial Accountability System Resource Guide (FAR Guide)FASRG
• Individuals with Disabilities Education Improvement Act of 2004IDEA
• Individualized Education ProgramIEP
• Foundation School Program FSP
• Local Education Agency (District or Charter)LEA
• Notice of Grant AwardNOGA
Special Education Funding 3
Acronyms and Abbreviations
• Maintenance of EffortMOE• Public Education Information Management SystemPEIMS
• Student Attendance Accounting HandbookSAAH
• Summary of FinancesSOF
• Shared Services ArrangementSSA
• Texas Education AgencyTEA
• Texas Education Agency Secure EnvironmentTEASE
• United States Department of EducationUSDE
Special Education Funding 4
Key Terms• Maintenance of Effort ( MOE)
• Excess Costs
• Coordinated Early Intervening Services (CEIS)
• Desk Audit
• Supplement
• Supplant
• Voluntary Departure
• High Cost
• Termination of Obligation
• EDGARIcon made by Yannick from www.flaticon.com is licensed under Creative Commons BY 3.0.
Special Education Funding 5
Objectives of this ModuleState Special Education Funding Compliance
52% Rule
Federal Special Education Funding
Compliance
Determination of Excess Cost to Establish
Need of Federal Funding
Maintenance of Effort (MOE)
IDEA Funding Audits/ReviewsIcon made by Freepik from www.flaticon.com is licensed under Creative Commons BY 3.0.
Special Education Funding 6
State Special Education Funding Compliance
At least 52% of state funds generated for
special education must be spent in support
of direct special education services.
(19 TAC §89.1121 (d) Distribution of State Funds and
19TAC §89.1125 Allowable Expenditures of State Special Education Funds
Special Education Funding 7
What Constitutes 52% of the State Special Education Basic Allotment?Specific Enhanced Program Intent Codes (PIC)
Special Education Funding 8
What About the 48%?No more than 48% of each school district's Foundation School Program (FSP) special allotments … may be expended for indirect costs related to the following programs: … special education... Administrative/indirect costs may be attributed to the following expenditure function codes34--Student Transportation
41--General Administration
81--Facilities Acquisition and Construction
Function 90 series of the general fund, as defined in the TEA publication, Financial Accountability System Resource Guide
Special Education Funding 9
What if we don’t spend it all?If state special education funds are
carried over from one year to the next,
entire amount must be budgeted and
expended on direct costs .
Administrative costs may not be taken
from carryover funds
Special Education Funding 10
Are we compliant? Maybe!State special education entitlement could go down one year(Example: poor attendance of students identified for special education services or significant changes to instructional arrangement FTEs)
Could satisfy the 52% requirement, but have a problem with maintaining effort for federal MOE purposes
Therefore, compliance with 52% Rule is not the same as compliance with federal MOEState special education dollars used to calculate the 52% requirement are part of the MOE formula, but only part
Special Education Funding 11
But our auditor says….
• Remember that this criteria of 52 % is the
current standard by which the auditor will
determine compliance for the state special
education allotment expenditures.
• Compliance with the 52% rule is not a
comparison of local/state support for the
program from one year to the next.
Special Education Funding 13
Eligibility to Apply for Federal FundsThe LEA is eligible to apply for a special education grant
if:• The LEA does not receive sufficient funds, including state and
federal funds, for the child with disabilities to pay for the special
education services provided to the child; or
• The LEA does not receive sufficient funds, including state funds
and federal funds, for all children with disabilities in the LEA to
pay for the special education services to the child…
TEC 29.018 (b-e)
The receipt of special education funds must be contingent upon the
operation of an approved comprehensive special education
program in accordance with state and federal laws and regulations.
TAC 89.1121(d)
Special Education Funding 14
Federal MOE and other IDEA-B Fiscal Compliance Requirements
MOE and
CEIS
Focuses on special education state and local expenditures in the current year as
compared to the previous year
Excess Costs
CEIS: an LEA may use up to 15% of the IDEA-B funds for any fiscal year
to develop and implement K-12
services for general education students who need additional
academic and/or behavioral support
Excess costs are those federal funds
necessary to provide the
program above and beyond those per-student state and
local funds expended the previous year
Special Education Funding 15
Part B Excess CostEducation Department Federal Administrative
Regulations(EDGAR) and IDEA
Subpart F: What are the administrative
responsibilities of the sub-grantee?
34 CFR 76.700 : Compliance with statutes
, regulations and applications
34 CFR 76.731: Records related to
compliance
Special Education Funding 16
How Do I Establish a Need for Federal Funds?
Excess Costs
The excess cost requirement mandates how much the LEA must
expend in state and local funds before it may begin expending
IDEA-B grant funds.
• Focuses on per-student spending in special education as compared
to per-student spending across all students.
• IDEA-B grant funds “must be used only to pay the excess costs of
providing special education and related services to students with
disabilities. ( 34 CFR 300.202(a)(2).
• An LEA must spend at least the average annual per-student
expenditure in an LEA during the preceding school year for an
elementary or secondary school student with a disability before
IDEA-B funds are used to pay the excess costs of providing special
education and related services. (34 CFR Appendix A to Part 300)
• http://tea.texas.gov/index2.aspx?id=2147499857
Special Education Funding 17
Worksheet for Excess CostsExcess Cost Worksheet - Elementary
Grades: (select)
Previous year's expenditures from all sources, for all elementary school students, minus capital outlay and debt service
State and local funds 0 Federal funds 0 Total 0 Capital outlay 0 Debt service 0 Total 0 Total adjusted previous year's expenditures 0
Previous year's elementary school expenditures from:
IDEA, Part B 0 ESEA, Title I, Part A 0 ESEA, Title III, Parts A and B 0 State and local special education funds 0 State and local funds for programs under ESEA Title I, Part A, and ESEA Title III, Parts A and B 0 Total 0
Previous elementary school enrollments:
Average number of elementary students enrolled, including students with disabilities 0 Average number of elementary students with disabilities 0 enrolled in the current year
Calculation results:
Average annual expenditure per elementary student 0
Minimum amount the LEA must spend for the education of elementary students with disabilities before using IDEA Part B funds 0
HELPHELPHELP
Special Education Funding 18
Excess Costs ActivityStep 1:
State and local tax funds $6,500,000
Federal funds $600,000
Total Expenditures $7,100,000
Less capital outlay and debt service relatingto the education of elementary school students
- 60,000
Total Adjusted Expenditures $7,040,000
Determine the total amount of expenditures for elementary school students from all sources – local, State and Federal (including IDEA-B) – in the preceding school year. Exclude capital outlay and debt services.
Special Education Funding 19
Step 2:Subtract from the Total Adjusted Expenditures amounts spent for:
(a) IDEA-B $200,000
(b) ESEA, Title I, Part A 250,000
(c) ESEA, Title III, Parts A & B 50,000
(d) State and local funds for children with disabilities
500,000
(e) State and local funds for programs under ESEA, Title I, Part A, and Title III, Parts A & B
150,000
Total Deductions $1,150,000
Total Adjusted Expenditures $7,040,000
Less Total Deductions -1,150,000
Total $5,890,000
From the amount determined in Step 1, subtract the previous year expenditures identified below (see Appendix 1 for a list of codes assigned to these expenditures). These are funds actually spent; not funds received and carried over to the current year. •(a) IDEA–B •(b) ESEA, Title I, Part A •(c) ESEA, Title III, Parts A and B State and local funds for children with disabilities, and •(d) State or local funds for programs under ESEA, Title I, Part A, and Title III, Parts A and B. These are funds that the LEA actually spent, not funds received last year but carried over for the current school year.
Special Education Funding 20
Step 3:
Total Amount from Step 2 $5,890,000
Average number of students enrolled in preceding year (October PEIMS snapshot)
÷800
Average annual per student expenditure
$7,362
Determine the average annual per student expenditure for elementary school students by dividing the average number of students enrolled in the elementary schools of the LEA during the preceding year (including children with disabilities) into the total amount computed in Step 2.The amount obtained through this computation is the minimum amount the LEA must spend (on the average) for the education of each of its elementary school children with disabilities with fund sources other than IDEA-B.
Special Education Funding 21
Step 4:
Number of students with disabilities in the LEA's elementary schoolsin the current year (October PEIMS snapshot)
100
Average annual per student expenditure (obtained from Step 3)
x $7,362
Total minimum amount of funds the LEA must spend for the educationof children with disabilities enrolled in the LEA's elementary schoolswith fund sources other than IDEA-B
$736,200
Determine the total minimum amount of funds the LEA must spend for e education of its elementary school children with disabilities in the LEA (not including capital outlay and debt service) with fund sources other than IDEA-B by multiplying the number of elementary school children with disabilities in the LEA times the average annual per student expenditure obtained in Step 3.Funds under IDEA-B can only be used for excess costs over and above this minimum.
Special Education Funding 22
But…The excess cost requirement does not
prevent an LEA from using IDEA-B funds to
pay for all of the costs directly attributable
to the education of a child with a disability
in any of the ages 3, 4, 5, 18, 19, 20, or 21, if
no local or State funds are available for
nondisabled children of these ages.
The LEA must comply with the non-
supplanting and other requirements of this
part in providing the education and services
for these children.
Special Education Funding 23
Supplement not SupplantFunds provided to the LEA under IDEA-B
must not be used to reduce the level of
expenditures for the education of
children with disabilities made by the
LEA from local funds below the level of
those expenditures for the preceding
fiscal year.
Icon made by Freepik from www.flaticon.com is licensed under Creative Commons BY 3.0.
Special Education Funding 24
Requirements for Compliance: MOE
The LEA budgets for the education of children
with disabilities from local or combination of
local and state funds;
Spends funds for the same purpose as the most
recent prior year for which information is
available; and
Ensures that the amount of local funds budgeted
is at least the same, either in total or per capita,
as the amount the LEA spent for that purpose in
the most recent fiscal year for which information
is available.
Special Education Funding 25
MOE for Fiscal Year 2014 and Beyond
TEA has published IDEA-B LEA Maintenance of Effort
Guidance Handbook which provides a detailed
description of the steps that TEA will use to calculate an
LEA’s compliance with the MOE requirement.
Please note that beginning with fiscal year 2014, the
PIC 99 allocation is not used in the MOE calculation.
For MOE calculation for fiscal year 2013, allocated funds
will be used to determine MOE compliance with
previous year.
http://tea.texas.gov/Finance_and_Grants/Grants/Federal_Fiscal_Compliance_and_Reporting/IDEA_Fiscal_Compliance/IDEA-B_LEA_Maintenance_of_Effort
/
Special Education Funding 26
34 CFR 300.203 provides the following four methods for
determining whether an LEA has met the IDEA-B MOE
requirement:
1. The total amount the LEA expended in state and local funds
must equal or exceed the amount it expended from those
sources for special education during the previous fiscal year.
2. The per-pupil amount the LEA expended in state and local
funds must equal or exceed the amount it expended per
capita from those sources for special education during the
previous fiscal year.
3. The total amount the LEA expended in local funds must equal
or exceed the amount it expended from that source for special
education during the previous fiscal year.
4. The per-pupil amount the LEA expended in local funds must
equal or exceed the amount it expended per capita from that
source for special education during the previous fiscal year.
An LEA only needs to pass one of the four tests to be compliant.
Special Education Funding 27
If the LEA was noncompliant in maintaining
effort in the preceding year, then the current
year must be compared to the second
preceding year rather than the preceding year
when the LEA was noncompliant.
For example, if the LEA was noncompliant in
the fiscal year 2013 final determination, then
the fiscal year 2014 determination must
compare fiscal year 2014 to fiscal year 2012.
Special Education Funding 28
Consequences for Noncompliance If an LEA fails all four tests, it will be notified of its preliminary
determination of noncompliance and given the opportunity to
respond by claiming allowable federal exceptions, voluntary MOE
reduction, and/or requesting state reconsiderations.
If an LEA does not have sufficient allowable federal exceptions, a
voluntary MOE reduction, and/or state reconsiderations to offset
the “decline in fiscal effort, the LEA must refund to TEA the
amount by which the LEA failed to maintain effort (i.e., the
difference between its prior and current year expenditures on
students with disabilities after all applicable federal exceptions,
voluntary MOE reduction, and state reconsiderations have been
applied).
If the refund amount exceeds the LEA's IDEA-B maximum
entitlement for the fiscal year under determination, the LEA will
only be required to refund the amount up to the LEA’s maximum
entitlement. The repayment must be made from nonfederal funds
or from funds for which accountability to the federal government
is not required, that is, from state and/or local funds.
Special Education Funding 29
Federal ExemptionsThe LEA may reduce the level of its state and/or local expenditures below the level
of those expenditures for the preceding fiscal year only if the reduction is
attributable to any of the following:
(a) The voluntary departure, by retirement or otherwise, or departure for just
cause, of special education or related services personnel.
(b) A decrease in the enrollment of children with disabilities.
(c) The termination of the obligation of the agency, consistent with this part, to
provide a program of special education to a particular child with a disability that is
an exceptionally costly program, as determined by the State Education Agency
(SEA), because the child—
(1) Has left the jurisdiction of the agency;
(2) Has reached the age at which the obligation of the agency to provide FAPE to
the child has terminated; or
(3) No longer needs the program of special education.
(d) The termination of costly expenditures for long-term purchases, such as the
acquisition of equipment or the construction of school facilities.
(e) The assumption of cost by the high cost fund operated by the SEA under34 CFR
300.704(c).
34 C
FR
300.2
04
Special Education Funding 30
Documentation for ExceptionsLEAs will complete TEA’s standardized assertion
forms to document any reductions attributable
to the allowable causes described above.
The assertion forms will be uploaded into the
Grants and Federal Fiscal Compliance (GFFC)
Reports and Data Collections application
available in TEASE/TEAL.
Special Education Funding 31
Departure of PersonnelIn order for the level of state and/or local
expenditures to be reduced on the basis of
departure of personnel, the LEA must provide the
following source documentation:
Source payroll record (e.g., personnel action
form, resignation letter signed and dated by the
employee) indicating the reasons why the
employee departed the LEA
Year-to-date payroll distribution journal
Employee’s State Board of Educator Certification
(SBEC) record (i.e., certification) Employee’s
signed and dated job description
Special Education Funding 32
Departure of PersonnelIn addition, the following conditions must be satisfied:
Departed personnel may no longer be employed by the LEA.
If a special education teacher has been reassigned to other
duties within the LEA, the reassignment does not qualify the
LEA to claim the “departure of personnel” exception.
The departure must be voluntary (that is, the employee
resigned or retired) or for just cause (the employee was
terminated as the result of misconduct or negligence). If the
LEA reduces the number of special education personnel as
the result of a reduction in force, the LEA may not claim the
“departure of personnel” exception.
The LEA may not claim the “departure of personnel”
exception when releasing or failing to renew the contract of
a probationary employee, as neither of those cases meets
the “just cause” requirement.
Special Education Funding 33
Decrease in Enrollment of Children with Disabilities TEA automatically accounts for a decrease in the enrollment of
children with disabilities when calculating the LEA’s IDEA-B MOE
in the following two ways:
1. If the number of students with disabilities decreases, and per-pupil
special education expenditures remain the same or increase, the LEA
will pass the second and fourth tests described in the Methods of
Determining Compliance section.
2. In addition, TEA implements allowable flexibility to reduce the
refund due by the percentage decrease in enrollment of children with
disabilities from the preceding comparison year to the most recent year.
For example, if the special education enrollment in the LEA decreased
by 5% and the LEA was determined to be noncompliant, then the refund
due would be decreased by 5%. This reduction is reflected on the LEA’s
MOE report.
Special Education Funding 34
Termination of Obligation In order for the level of state and/or local expenditures to be
reduced because the LEA no longer has an obligation to serve
a child with an exceptionally costly program, the LEA must
provide the following supporting documentation:
A schedule summarizing the total costs for each special
education student that participated in an exceptionally
costly program. The schedule must reconcile to the LEA’s
detailed general ledger and source records which must
include the fund/net asset code and object code for each
cost description.
A detailed general ledger and source records supporting
costs identified on the summary schedule provided.
TEA may also request a student’s individualized education
program (IEP). (If the IEP is requested, the LEA must provide it to TEA through a secure transmission
method (provided by TEA) within 24 hours of the request.)
Special Education Funding 35
Termination of Obligation An exceptionally costly program for serving a student with a
disability is defined as an amount greater than the average
per pupil expenditure (as defined in section 9101 of the
ESEA) in Texas. Examples of reductions in an exceptionally costly
program include, but are not limited to, the following:
A student in a residential placement graduates or moves out of the
LEA.
A residential facility closes.
A charter school or another school district begins providing educational
services for a student.
A student with a high number/level of personnel assigned to implement
the student’s individualized education program (IEP) leaves the LEA.
Such students would include but are not limited to students who are
identified as deaf, blind, deaf-blind, autistic, medically fragile,
emotionally disturbed, or having a severe disability across eligibility
categories.
A settlement agreement/corrective action ends.
Special Education Funding 36
Termination of Costly Expenditures
In order for the level of state and/or local expenditures
to be reduced because of a termination of costly
expenditures for long-term purchases, the LEA must
provide the following supporting documentation:
A schedule listing all of the items purchased,
description of the items purchased, and the general
ledger classification of the purchases, i.e., fund/net
asset code, function code and object code. The
schedule must agree to the LEA’s detailed general
ledger and source records, which must include the
fund/net asset code and object code.
A detailed general ledger and source records
supporting the costs identified on the summary
schedule provided.
Special Education Funding 37
Assumption of Cost by High Cost Fund
In order for the level of state and/or local expenditures to be
reduced because of assumption of cost by the high cost fund
operated by TEA, meaning the expenditure in the current year
was charged to the IDEA-B High Cost grant received from TEA,
the LEA must provide the following supporting documentation:
A detailed general ledger for the previous school year
indicating the cost was previously recorded under fund code
199 or 420.
A detailed general ledger for the current school year
indicating the cost was subsequently recorded under fund
code 226 (High Cost Grant).
The source records supporting costs identified on the
detailed general ledgers.
Special Education Funding 38
Voluntary Reduction of MOE
PL 108-446, Section 613(a)(2)(C)(i)for any
fiscal year for which the allocation received by
an LEA under section 611(f) exceeds the
amount received for the previous fiscal year,
the LEA may reduce the level of expenditures
otherwise required by subparagraph (A)(iii) by
not more than 50% of the amount of such
excess.
However…
Special Education Funding 39
Voluntary Reduction1. To be eligible :
The LEA must meet each of the state targets for the five
SPP compliance indicators (9, 10, 11, 12, and 13) and
Have a LEA Determination Level of “Meets Requirements” ,
and
Is not identified as having significant disproportionality.
2. The LEA will need to provide :
Form B: Assertion of Eligibility for Adjustment to Local Fiscal
Effort and supporting documentation (now in e-grant
application))
3. Will need to demonstrate and have evidence of eligibility:
Actual amount of adjustment
The amount of the adjustment expended on NCLB activities
Special Education Funding 40
PL 108-446, Section 613(a)(2)(C)(ii)
If an LEA exercises the authority
under clause (i), the LEA shall use an
amount of local funds equal to the
reduction in expenditures under
clause (i) to carry out activities
authorized under the Elementary
and Secondary Education Act.
Special Education Funding 41
Activities authorized under the Elementary and Secondary Education Act (ESEA)
Parental Involvement Activities
Drop out Prevention Programs for At-
Risk Children and Youth
Family Literacy Services
Activities to Promote Family Support
for Higher Education
Mentor Programs
Special Education Funding 42
ReportingThe reporting of any MOE Reduction on the
Special Education Consolidated Grant
application is only applicable to the Voluntary
MOE reduction for the grant application year.
Remember:
If the LEA failed to maintain effort (received a
letter of finding for MOE noncompliance), the
LEA must not report the noncompliance amount
on the Special Education Consolidated Grant
application.
MOE non-compliance is not Voluntary
MOE Reduction.Icon made by Freepik from www.flaticon.com is licensed under Creative Commons BY 3.0.
Special Education Funding 43
Relationship between Voluntary Reduction of MOE and CEIS There are two relationships between the
Voluntary Reduction option and CEIS:
1. Choosing to voluntarily reserve IDEA-B funds
for CEIS can limit the amount the LEA
voluntarily reduces MOE
2. Choosing to voluntarily reduce MOE can limit
the amount the LEA voluntarily reserves for
CEIS
Special Education Funding 45
CEIS
Remember:
If the LEA intends to use CEIS funds and is eligible
for voluntary reduction of MOE, both must be
planned for at the same time to ensure
compliance. If doing both the LEA must determine
which amount is the lesser; combined, the CEIS
set-aside amount and MOE reduction may not
exceed that lesser amount.
If the LEA is only doing one or the other, it is
unnecessary to consider the interconnection
between CEIS and MOE.
Special Education Funding 46
Federal Funds That May be Considered as State or Local Funds In years when the federal
government provides special
and/or additional federal funds
that TEA designates as state or
local funds (such as ARRA
SFSF, fund code 266), those
specific funds will be
automatically included in the
total aggregated expenditures
by function code for each
respective compliance year in
the MOE calculation. Icon made by Freepik from www.flaticon.com is licensed under Creative Commons BY 3.0.
Special Education Funding 47
Significant PEIMS Errors USDE approved TEA’s request to reconsider
significant PEIMS errors.Significant is defined as corrections that change the LEA’s
compliance status
To meet this definition the LEA must enter its self-reported
corrected data in to TEA’s IDEA-B LEA MOE calculation tool and
the results must reflect a change in the compliance status.
If a change results, TEA will recalculate a revised compliance
determination using the corrected data.
Any decision to use revised data will not change the
official PEIMS data. The official PEIMS data is final
and remain unchanged on all TEA products and
reports that rely on this information
Special Education Funding 48
Possible Consequences of a State Reconsideration Request Due to Significant PEIMS Errors TEA’s Federal Fiscal Compliance and Reporting (FFCR) division will
make the following notification of erroneous data submission:
Division of Financial Compliance– possible increased risk of audit,
investigation an/or review
Division of State Funding-possible effect on state funding
Division of Federal Fiscal Monitoring- possible identification as high-
risk resulting in a review of all reimbursements across grants
Office of Statewide Education Data Systems- possible identification
as high-risk
Department of Accreditation and School Improvement- risk for
investigation/review
Division of Enforcement Coordination and Governance-possible
recommendation for district-level interventions/sanctions based on
findings
Special Education Funding 49
Let’s Talk METHODOLOGY
The methodology for calculating IDEA-B MOE compliance is based on
both federal and state requirements. 34 CFR 300.203 provides the
following four methods for determining compliance:
The total amount the LEA expended in state and local funds must
equal or exceed the amount it expended from those sources for special
education during the previous fiscal year.
The per-pupil amount the LEA expended in state and local funds must
equal or exceed the amount it expended per capita from those sources
for special education during the previous fiscal year.
The total amount the LEA expended in local funds must equal or
exceed the amount it expended from that source for special education
during the previous fiscal year.
The per-pupil amount the LEA expended in local funds must equal or
exceed the amount it expended per capita from that source for special
education during the previous fiscal year.
Special Education Funding 50
Calculating State and Local FundsTo calculate the total amount expended in state and local funds,
TEA uses expenditures reported on PEIMS Record 032, Fund Code
199 for school districts, or 420 for charter schools, coded to
program intent code (PIC) 23 and PIC 33.
TEA also includes PEIMS Record 033, Fund Code 437 Shared
Services Arrangement – Special Education for Shared Service
Arrangements (Type 11) expenditures.
As described in the Federal Funds That May be Considered as
State or Local Funds section, in years when the federal
government provides special and/or additional federal funds that
TEA designates as state or local funds (such as ARRA SFSF, fund
code 266), those specific funds will be automatically included in
the total aggregated expenditures by function code for each
respective compliance year in the MOE calculation.
Special Education Funding 51
Function Codes Used in MOE Determination The function codes listed below meet the requirements of the
IDEA regulations and are used to aggregate state and/or local
expenditures within PIC 23 and PIC 33.
Function Code Description
11 Instruction
12 Instructional Resources and Media Services
13 Curriculum and Instructional Staff Development
21 Instructional Leadership
23 School Leadership
31 Guidance and Counseling Service
32 Social Work Services
33 Health Services
34 Student (Pupil) Transportation
36 Co-curricular/Extracurricular Activities
41 General Administration
51 Plant Maintenance and Operations
53 Data Processing Services
Special Education Funding 52
Function Codes Not Used in MOE Determination The function codes listed in the following table do not meet
the requirements of the IDEA regulations and are not used
to aggregate state and/or local expenditures within PIC 23
and PIC 33.
Function Code Description 35 Food Service
52 Security/Monitoring Service
61 Community Service
71 Debt Service
81 Facilities Acquisition and Construction
91 Contract Services
92 Cst/Sl WADA
93 PMT – SSA
95 PMT – JJAEP
97 PMT – TIF
99 Other Intragov Chgs
Special Education Funding 53
Special Education Student Count PEIMS Record 163 - Child-Count-
Funding-Type-Code 3 is used to identify
the Special Education Student
Population.
This special education student count is
also found on the line titled IDEA-B of the
PEIMS Edit+ report PRF5D010, Special
Education Child Counts by Funding Type.
Special Education Funding 54
Local Funds Imputing the total local portion of LEA
special education expenditures requires
the following:
The LEA’s total state and local special
education expenditures.
The LEA’s Tier 1 Special Education
Adjusted Allotment, total cost of Tier 1,
and local fund assignment from the
Legislative Planning Estimate (LPE)
column in the Summary of Finance (SOF)
dated September 10 or first date
thereafter in the year under
determination.
Special Education Funding 55
How do I do that? It is a 3 Step Process1. Determine the LEA’s local special education
expenditures that are in excess of its Tier I
Special Education Adjusted Allotment.
a. This determination is done by subtracting the Tier I
Special Education Adjusted Allotment from the LEA’s
total state and local special education expenditures.
b. If the LEA’s total state and local special education
expenditures is greater than the LEA’s Tier I Special
Education Adjusted Allotment, then the difference (the
expenditures made in excess of the Tier I Special
Education Adjusted Allotment) is considered to be
expended from local funds.
Special Education Funding 56
3 Step Process
2. Impute the LEA’s local special education expenditures
using the ratio of local funding within its total Tier I
Allotment.
a. First, determine the percentage of local funding within
the Tier I Allotment by dividing the LEA’s Local Fund
Assignment by the Total Tier I Allotment. If the Local Fund
Assignment is greater than
the Total Tier I Allotment, then the percentage of local
funding within Tier I is automatically adjusted to 100%.
b. Next, multiply that percentage by the total state and
local expenditures up to the Special Education Adjusted
Allotment. The result is the LEA’s imputed local special
education expenditures.
Special Education Funding 57
3 Step Process
3. Determine the LEA total local special
education expenditures for IDEA-B LEA MOE by
summing (a) the LEA’s local special education
expenditures that are in excess of its Special
Education Adjusted Allotment (determined in
Step 1 above); and (b) the LEA’s imputed local
special education expenditures (determined
in Step 2 above).
Icon made by Freepik from www.flaticon.com is licensed under Creative Commons BY 3.0.
Special Education Funding 58
IDEA-B MOE Calculation Tool To assist LEAs in complying with the MOE requirements for
FY2014 and beyond, TEA has developed a calculation tool
http://tea.texas.gov/Finance_and_Grants/Grants/Federal_Fiscal_Compliance_and_Reporting/IDEA_Fiscal_Compliance/IDEA-B_LEA_Maintenance_of_Effort
/
that LEAs may use to estimate their MOE compliance. To use the
tool, LEAs must be prepared to enter the following data:
Prior year and current year state and/or local expenditures in
relevant function codes as described in Appendix 3.
Special Education Student counts for the prior year and current
year (PEIMS Record 163, Child-Count-Funding-Type-Code=3).
Tier I Special Education Adjusted Allotment, Total Cost of Tier I,
and Local Fund Assignment data from the LPE Column of the
LEA’s Summary of Finance (SOF) dated September 10 or the first
date thereafter in the year under determination.
Special Education Funding 59
Things to think about: Reducing MOE Legally
1. Review current year expenditures before you “close
the ledgers” in light of the exceptions.
2. Using the information from previous year’s closed
budget and upcoming year’s program plan, are there
high dollar expenditures that may need to be
assigned to state and local special education funds in
your new budget?
3. Communicate with staff to determine future/
potential resignations and retirements
4. Anticipate capital outlay needs such as technology or
data management systems
5. Anticipate high cost student or program needs
Special Education Funding 60
Best Practices
• Calculate estimated MOE during budget development
process
• Track and document special education staff changes – HR
paper trail and PEIMS data accuracy
• Distribute and collect signed job descriptions for staff for
current position – keep current with changes in funding
and/or assignments (HR)
• Track and document expenditures related to exceptions –
use sub-object codes as appropriate
• Calculate actual MOE during the fiscal year
RemindersMaintenance of Effort – IDEA Part B
Special Education Funding 61
How do you maintain local effort when reducing
the LEA budget?
1. Calculate LEA’s MOE during the Budget
Process.
2. With Declining Financial Resources—Easier to
meet Per Pupil Expenditures rather than the
Aggregate Expenditures, but must monitor both.
3. With Declining Per Pupil Expenditures, must
monitor costs.
4. With Declining Per Pupil Enrollment, monitor
Per Pupil Expenditures in order to meet MOE.
What happens if we have overall budget reductions?
Special Education Funding 62
Federal Desk Audits/Review The objective of a review is to determine if
the sub-recipient complied with Title 34 CFR
80.20 and other applicable federal statues,
regulations and grant requirements.
Review focuses on fiscal practices developed
and implemented by the sub-recipient to
demonstrate compliance with the
requirements.
The review focuses on current grant and TEA
auditors will require LEA to submit prescribed
documentation.
Special Education Funding 63
Administrative Procedures Manual (APM)
The agency is expecting the LEA to have an approved APM in effect
and it must address the following fiscal and fiscal-related activities:Accounting for property and supplies purchased with federal funds
Budgeting and accounting for federal grants
Financial reporting and cash management for federal grants
Authorized uses for federal funds
Maintenance and retention of records pertaining to federal grants
Monitoring and reporting program performance for federal grants
Time and effort reporting requirements
Procurement of goods and services using federal grants
Program income generated from activities supported by federal grants
Support of salaries, wages, and related costs charged to federal grants
Travel reimbursement requirements applicable to federal grants
Use of credit and debit cards
Property management policy and property disposal policy
Administrative policies and procedures to help prevent and report fraud, waste,
and abuse of public funds.
Special Education Funding 64
Review
TEA will request the sub-recipient to submit the required documents
listed in the attachments to the letter no later than 10 business days
from the date of the letter.
All documents are to be submitted in electronic format, such as a CD
or flash drive.
Documents may include:
General ledger pages (specific)
Purchase orders ( specific)
Working papers for drawdown WebER request for specific dates
CEIS documentation
Comprehensive Needs Assessment and Program Plan
If requested documentation cannot be provided, a detailed
explanation is required.