title i, part a: allowable use of fundsbisd.us/federalprograms/docs/2015-2016/nclb/title i...•...

©2014, Region One Education Service Center

Title I, Part A: Allowable Use of Funds

Office of School Improvement, Accountability & Compliance


Sources

• Electronic Code of Federal Regulations

• Unallowable Costs by Class/Object Code

• Title I, Part A Allowable & Unallowable Costs

• TEA Guidelines Related to Specific Costs

• Title I, Part A Allowability of Costs ACET Spring Conference 2015

• The New EDGAR

http://www.ecfr.gov/cgi-bin/retrieveECFR?gp=&SID=f47debe7878113355e1825296ffdb5cb&n=pt2.1.200&r=PART&ty=HTML

http://www.region10.org/r10website/assets/File/Unallowable Costs by Class Object Code_09-17-2012.pdf

http://www.region10.org/r10website/assets/File/NCLB_AllowableCosts(120414)(2).pdf

http://www.esc1.net/site/default.aspx?PageType=14&DomainID=108&PageID=2243&ModuleInstanceID=3033&ViewID=1e008a8a-8e8a-4ca0-9472-a8f4a723a4a7&IsMoreExpandedView=True

http://www.acetx.org/documents/2015_Spring/ACET_2015Spring_03_a_AllowabilityofCosts.pdf

http://www.acetx.org/documents/2015_Spring/ACET_2015Spring_03_a_AllowabilityofCosts.pdf

http://tea.texas.gov/Finance_and_Grants/Grants/Administering_a_Grant/The_New_EDGAR/


Comprehensive Needs Assessment (CNA)

Campus Improvement Plan (CIP)

Allowable Costs

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• The school district must have written procedures for determining the allowability of costs in accordance with EDGAR

• Describe planning process, budget process, how to determine program allowability, and how to closeout project


Allowability of Costs Procedures 200.302

• Procedures to include determining allowable costs from the planning process, procurements, time and effort and expenditure of funds


Factors Affecting Allowability of Costs 200.403

• Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: – (a) Be necessary and reasonable for the

performance of the Federal award and be allocable thereto under these principles


In regards to accomplishing the objectives of the program and for implementing activities as described in the funding application… 1. Is the cost “necessary?” In other words, are the costs

necessary for the operation or proper and efficient performance of the federal award?

2. Is the cost “reasonable?” In other words, is the cost more than what a prudent person would spend under the circumstances at the time the decision was made to incur the cost ?


Necessary Costs

Consider This……

• Is this identified in the plan?

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

• If I were asked to defend this purchase, would I be able to?

• Would it just be nice to have?


Reasonable Costs

Consider This….

• Whether cost is a type generally recognized as ordinary and necessary for the operation of the non-federal entity or the proper and efficient performance of the federal award

• Is it in line with federal, state and local laws and the terms of the grant award

• Market prices for comparable goods or services in the geographic area

• Whether the individuals acted with prudence under the circumstances considering their responsibilities

• No significant deviation from established procedures and policies


Reasonable Costs

Other Practical Questions/Considerations….

• Do I really need this?

• Is the expense targeted to valid programmatic/administrative need?

• Is this the minimum amount I need to spend to meet my need?

• Did I pay a fair rate?

• Again, If I were asked to defend this purchase, would I be able to?


Allowable Costs

Must meet the following criteria:

• Be reasonable for the performance of the grant and be allocable under the applicable cost principles

• Conform to limitations or exclusions set forth in applicable cost principles to the grant agreement as to types of amount of costs

• Be consistent with policies and procedures that apply uniformly to federally or state-funded activities and activities funder from other sources

• Be accorded consistent treatment among all grant programs, regardless of funding sources

• Be in accordance with Generally Accepted Accounting Principles (GAAP)

• Not be included as a cost or used to meet cost-sharing or matching requirements of any other federally or state-funded program in the current or a prior period

• Not be used for lease-purchases (i.e, debt service) if for discretionary grants


Allocable Costs

• Benefits both award and other work and can be distributed in proportions that may be approximated using reasonable methods; and

• Necessary to the overall operation of the entity and assignable to that Federal award or cost objective in accordance with relative benefits received

• Can only charge in proportion to the value received by the program

• Eg. Agency purchases a computer to use 50% on the Federal grant program and 50% on a state program – can only charge half of the cost to the federal grant


Beginning Date of Project

All goods must be received and all services must be rendered

between beginning and end of the project

End Date of Project

Duration of the Grant



Services by an employee: When the services are performed by an employee

An obligation occurs depending on the expenditure, as follows:



Services by a contractor: The date of a binding written commitment, such as a contract or other written agreement, to obtain services from the contractor




Travel: When the travel is taken




Approved Pre-Agreement Cost: On the first day of the grant or subgrant performance period




Acquisition of Property: Date of binding written commitment



I would like to buy…….

Is it reasonable and necessary to carry out the intent and purpose of the program?

What need in our CNA does this address?

From the CIP, can you describe program,

activity, or strategy addressed by this expenditure?

As we are a schoolwide campus, how will

this upgrade the entire educational program?

How is the expenditure supplemental to

other nonfederal programs?

How will the expenditure by evaluated to measure a positive impact on student

achievement?


Ok, forget it.

Have a great day!


Reasonable

Necessary

Allocable

Properly Documented

Asset Safeguards

Assets used only for

authorized purposes


• Controls over and accountability for all funds, property, and assets

• Must adequately safeguard all assets and assure solely used for authorized purposes

• Supplies and computing devices technically not on inventory, but must be safeguarded and tracked


Comprehensive Needs Assessments and Improvement Plans

• Title I, Part A funds must be expended for programs, activities, and strategies that are scientifically based on research and meet needs identified through the CNA process.

• The CNA must be completed prior to applying for the funding because the application for funding must address the needs identified through the CNA process.

• These expenditures must also be tied to the LEA or campus improvement plan, depending on how the expenditure will be used and coded (e.g., at the LEA or campus level).

• Must be addressed in the improvement plan prior to obligations, expenditures and encumbrances being made.


Payroll Costs (6100)

• The following employee payroll costs are not allowed:

• Personal liability insurance

• Employer contributions to voluntary retirement plans such as 403(b) or 401(k)

• Substitute pay for private nonprofit school teachers

• Payroll costs that exceed local policy


Professional and Contracted Services (6200) A consultant shall not be used in the conduct of this application if the services to be

rendered by such consultant could have been rendered by the grantee’s employees.

Grant funds may not be used for the following: • Training or technical assistance on grant writing or obtaining grant funds • Fundraising activities or training on fundraising • Multicolor printing costs that are not reasonable and necessary to accomplish the

objectives of the grant program (applies to printing costs incurred under 6200 and 6400)

• Legal retainer fees • Tuition and fees for courses not directly related to the grant program • New building construction or renovating or remodeling of buildings • Conducting required annual audit and report of financial activities • Audit fees and expenses for state-funded grants • Audit fees


Supplies and Materials (6300) Grant funds may not be used for the following: • Supplies and materials, including electronic devices, for personal

use. Must be used only for grant-related activities. • Costs associated with awards banquets, ceremonies, celebrations,

and social events • Cell phones for personal use • Gifts or items that could be construed as a gift • Souvenirs, memorabilia, or promotional items (such as T-shirts,

caps, tote bags, key chains, or imprinted pens)

NOTE: Refer to the TEA Guidelines Related to Specific Costs for information on incentives to participate and awards for recognition.


Other Operating Costs (6400) • Grant funds may not be used for the following: • Out-of-state training when the same type and quality of training is available in state • Gifts or items that can be construed as a gift • Souvenirs, memorabilia, or promotional items (such as T-shirts, caps, tote bags, key chains, or

imprinted pens) • Door prizes (movie tickets, gift certificates, amusement park passes, and other similar items

may be donated by others, but not purchased with grant funds) NOTE: Refer to the TEA Guidelines Related to Specific Costs for information on incentives to

participate and awards for recognition. • Food, meals, snacks, beverages, and refreshments as awards • Multicolor printing costs that are not reasonable and necessary to accomplish the objectives

of the grant program • Membership dues in organizations substantially engaged in lobbying or in social organizations • Memberships in social organizations • Memberships in civic or community organizations (for colleges and universities) • Professional or personal liability insurance for individual employees • Tuition and fees for courses not directly related to the grant program


Other Operating Costs (6400) Travel costs that are not allowed are the following:

• Alcoholic beverages

• Tips or gratuities

• Entertainment, recreation, or social events

• Travel allowances, where per diem is paid to the employee regardless of the amount actually expended

• First-class airfare

• Any expense for other persons

• Meals and lodging for persons who live in the same city or town where the meeting, conference, or workshop is held

• Costs that are not reasonable and necessary to meet the objectives of the grant

• Costs related to training or technical assistance on grant writing or obtaining funds

• Field trips (under new EDGAR only allowed with pre-approval in grant application by Department of Education; TEA awaiting guidance on whether they can pre-approve)


Capital Outlay (6600) • Unless specifically permitted in the authorizing

statute and approved by TEA in the grant application, the following costs are unallowable:

• Land purchase and improvements to land • Construction, renovation, or remodeling • Ground leveling, site preparation, foundation,

plumbing, wiring, and sidewalk for a portable building are considered construction costs. Therefore, these costs are not allowable to be charged to the grant.


Title I, Part A: Campus Responsibilities

Office of School Improvement, Accountability & Compliance


Title I campuses with percentages of students from low-income families of at

least 40% may use Title I funds, along with other federal, state and local funds and may operate a schoolwide program to:

Upgrade the entire

educational program

Raise academic achievement for

ALL students


Title I campuses with less than 40% of students from low-income families or that choose not to

operate a schoolwide program can operate a targeted assistance program

The campus identifies a select group of students who are failing, or most at risk of failing to meet the state’s

challenging academic achievement standards and designs an instructional program to meet their needs


• Campus administration is knowledgeable about:

– allowable and unallowable costs and the use of funds for Title, Part A campus allocation

– Campus budget, and campus administration and staff provided input on how funds are to be expended

• Schoolwide funds must be supplemental (in addition to) the equitable amount of state and local funds allocated to the campus and used to upgrade the entire educational program


I would like to buy…….

Is it reasonable and necessary to carry out the intent and purpose of the program?

What need in our CNA does this address?

From the CIP, can you describe program,

activity, or strategy addressed by this expenditure?

As we are a schoolwide campus, how will

this upgrade the entire educational program?

How is the expenditure supplemental to

other nonfederal programs?

How will the expenditure by evaluated to measure a positive impact on student

achievement?


Section 1119 of the Elementary and Secondary

Act (ESEA) focuses on improving teacher and

paraprofessional quality at the local level

Teachers are required to be highly qualified (HQ) if they are the Teacher of Record – providing direct instruction

to students in any core subject area

Highly Qualified Staff


Core Academic

Subject Areas

English, reading or language arts,

mathematics, science, foreign languages

(languages other than English), civics and

government, economics, arts, history, and

geography.



Courses that are outside of the core academic subject

areas (including some Career and Technical

Education Courses and some Technology

Application Courses) that are accepted by SBOE for

graduation credit in a specific core academic

subject area require the teacher of record to be

highly qualified



At the beginning of each school year, the district

must notify the parents of each student attending any school receiving Title I, Part

A funds that the parents may request information

regarding the professional qualifications of the student’s classroom

teachers •This is sometimes referred to as

“The Right to Know” notification



Whether the teacher has met the state qualifications and

licensing criteria

Whether the teacher is teaching under an emergency

or other provisional status

The type of degree and certification the teacher has

Whether the child is provided services by paraprofessionals,

and if so, what their qualifications are



The principal of each campus must attest, in writing (Principal Attestation) as to the status of each campus being in compliance with the requirements for highly qualified teachers

Copies of the signed attestation forms need to be on file at the campus level and at the district level




If a campus does not have 100% core academic subject area classes taught by highly qualified teachers, the campus is required to complete a Highly Qualified Continuous Improvement Plan (HQTCIP) detailing actions that will be taken to assist the not HQ teacher in becoming highly qualified for that assignment

http://tea.texas.gov/About_TEA/Laws_and_Rules/NCLB_and_ESEA/Highly_Qualified_Teachers/Highly_Qualified_Teacher_Continuous_Improvement_Plan_Process/



Parent Notification for any Teacher NOT HQ: The campus principal must also provide timely written notice to the parent if the paren’t child has been assigned or has been taught for four or more consecutive weeks by a teacher who is not highly qualified

http://tea.texas.gov/About_TEA/Laws_and_Rules/NCLB_and_ESEA/Highly_Qualified_Teachers/Highly_Qualified_Teacher_Determination_Forms/



On a Title I Schoolwide campus - all paraprofessionals that perform instructional support duties must be HQ, without regard to whether the position is funded with federal, state, or local funds

On a Title I Targeted Assistance campus – only paraprofessionals who perform instructional duties and are funded through Title I, Part A must be HQ


Highly Qualified Staff Pa

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s Have completed 2 years of study at an institution of higher ed. (48

Semester hours)

Or

Have obtained an associate’s degree

or

Have met a rigorous standard of quality and can demonstrate, through a formal

state or local assessment knowledge and ability to assist in instruction



The campus principal must ensure that paraprofessionals who provide instructional support are working under the direct supervision of a highly

qualified teacher The campus and the district must have copies of the list of paraprofessionals

and designated teachers



http://tea.texas.gov/About_TEA/Laws_and_Rules/NCLB_and_ESEA/Highly_Qualified_Teachers/Highly_Qualified_Teac

hers /

http://tea.texas.gov/About_TEA/Laws_and_Rules/NCLB_and_ESEA/Highly_Qualified_Teachers/Highly_Qualified_Teachers






Parent Involvement/Family and Community Engagement

Parents, families, educators, and communities form a

partnership and are accountable for improving

student achievement by fully participating in the

education of all children Partnership is defined as the

participation of parents in regular, two-way, and

meaningful communication involving student academic learning and other school

activities


Parent Involvement Policy

Includes how parents may have input on the plan including submitting complaints if not satisfactory Builds capacity toward a strong parent, family, and community program Provides for annual evaluation of content and effectiveness including identification of barriers to participation by any particular ethnicities or economic groups


Parent Involvement Policy

The Parental Involvement Policy: Includes descriptions and explanations of curriculum, assessment, and proficiency expectations

Includes how the campus will be responsive to parents’ requests to participate in their child’s education


Each campus must develop a school-parent compact to clarify what families and schools will do to ensure that students reach high academic achievement standards The requirement to develop the compact is applicable for all Title I Schoolwide and Targeted Assistance programs


The school-parent compact must be jointly developed by the campus with the involvement of parents of participating children. The school-parent compact should outline how parents, school staff, and students will share responsibility for improved student achievement

The compact will also outline the means by which the school and parents will build and develop a partnership to help children achieve high academic standards


Each campus must ensure that the school-parent compact addresses the importance of ongoing communication between teachers and parents on a regular basis through, at a minimum: Annual parent-teacher conferences in elementary schools during which the compact shall be discussed in relation to the child’s achievement


Each campus must ensure that the school-parent compact addresses the importance of ongoing communication between teachers and parents on a regular basis through, at a minimum: Frequent reports to parents on their children’s progress Reasonable access to staff Opportunities to volunteer and participate in their child’s class Observation of classroom activities


Comprehensive Needs Assessment and Planning

The Elementary Secondary Education Act (ESEA) statute requires that each funded program conduct a comprehensive needs assessment to determine priorities for the intended program recipients

The Elementary Secondary Education Act (ESEA) statute requires that each funded program conduct a comprehensive needs assessment to determine priorities for the intended program recipients



For both Schoolwide and Targeted Assistance Campuses, the CNA should examine: Performance of children in relation to state content and student performance standards

ALL students, as well as required subgroups: Economically Disadvantaged students, students from major racial and ethnic groups, students with disabilities, students with limited English proficiency, and Migratory students



A Title I, Part A campus plan should be: Developed with the involvement of parents and other community members, and individuals who will carry out the plan (administrators, teachers)

Made available to the district, parents, and the public, and the information contained in the plan should be in an understandable and uniform format


Campus Improvement Plan Title I, Part Schoolwide



Address the educational needs of economically disadvantaged students with comprehensive strategies for improving the whole school so every students achieves at high levels of academic proficiency

Do NOT have to identify particular children as being eligible for services



Developed with the involvement from parents and other members of the community to be served and individuals who will carry out the plan : Teachers Principals Administrators Administrators of other Title I programs Pupil services personnel Technical assistance providers School staff Secondary students *(if secondary campus plan)



Describe how the campus will implement the ten schoolwide components

Include a list of state and LEA programs and other federal programs that will be included in the schoolwide program

Describe how the campus will use Title I, Part A and other resources to implement program



Describe how the campus will provide individual assessment results in a language that parents can understand, including the interpretation of those results



http://www.esc1.net/site/default.aspx?PageType=14&DomainID=108&PageID=2243&ModuleInstanceID=3033&ViewID=1e008a8a-8e8a-4ca0-9472-a8f4a723a4a7&IsMoreExpandedView=True


Districts that receive Title I, Part A funds for any of the campuses in the district are required to set-aside or reserve Title I, Part A funds for homeless students on any campuses that are not served with T-I funds

The district makes the determination of the amount that is reserved for services to homeless students on non T-I campuses


To improve educational services for homeless children and youth by assisting them in meeting social and academic challenges

To provide homeless children and youth services needed to make a successful transition from their state of homelessness to school or employment


To prevent homeless youth from dropping out of school, and to provide a support system to ensure their continuing education

A student who is homeless and attending any campus served by the LEA is eligible for Title I, Part A services


Homeless students who attend a non-Title I, Part A campus should receive Title I, Part A services through an LEA-level program provided through the required homeless set-aside

The LEA may also choose to set aside additional Title I funds to provide services to homeless students at its Title I campuses


Every school district is required to have a Homeless Education Liaison

The liaison is required by law to perform specific tasks


Assists with identification and Enrollment

Assists in settling enrollment disputes

Connect students to district and community resources including

nutrition, transportation, tutoring, special education, immunization, medical, dental, mental health,

housing, food, and post-secondary

opportunities

Has autonomy to make decisions for qualifications

for services


Other Requirements


Other Requirements

The purpose of the tool is to provide LEAs and campuses with a systematic process to evaluate the impact of federal

program funding

To evaluate the effectiveness and impact of federal

programs on student achievement

outcomes.

To guide future program decisions.

To assess the impact of federally funded

strategies on campus

performance objectives (CPOs).

To determine the degree to which

program funds met the intended

purposes.

http://www.region10.org/state-and-federal-initiatives-sfi/title-i-part-a-nclb-programs/title-i-part-a-compliance/


Other Requirements

Results of the annual review of student data from all participating schools must be publicized and disseminated to parents, teachers, principals, schools, and the community

Each campus must inform parents and organizations of the existence and purpose of parent information and resource centers


Region One Resources

http://www.esc1.net/domain/108


Rubén Degollado

School Turnaround Specialist Foster Care Champion

Region One Education Service Center Office of School Improvement, Accountability & Compliance

http://www.esc1.net/Domain/19

O: 956-984-6185

C: 956-332-3685

F: 956-984-7646

E: [email protected]

tel:956-984-6185

tel:956-984-6185

tel:956-984-6185

tel:956-984-6185

tel:956-984-6185

tel:956-332-3685

tel:956-332-3685

tel:956-332-3685

tel:956-332-3685

tel:956-332-3685

tel:956-984-7646

tel:956-984-7646

tel:956-984-7646

tel:956-984-7646

tel:956-984-7646

mailto:[email protected]

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