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Title I/LAP Spring Workshop - Office of Superintendent of Public

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May 2013
• 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)
Title I, Part A
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
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
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
Step 3
• Build Schoolwide comprehensive component plan to identify reform
• 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
• 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)
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
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
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
• 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 consolidation
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
Schoolwide Program
Cannot Include
Transitional Bilingual
State Special Education
State Highly Capable
I ther State Programs which are
limited only to certain
students (not available to all
students in the building)
Indian Education
Federal Special Education
Title I, Part A Schoolwide Program
Title I, Part A (Disadvantaged)
Title II, Part A (Professional Development)
BEA (Basic Education)
Local Funding, Levy, District, etc.
Title III, (Immigrant)
Carl Perkins
Most ED Programs
Consolidated Program Review: CPR
Schoolwide 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
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 assessment
2. Schoolwide reform strategies
3. Instruction by highly qualified teachers
4. On-going professional development
5. Strategies to attract highly qualified teachers
6. Strategies to increase parent involvement
7. Transition
8. Measures to include teachers in assessment decisions
9. Strategies for additional assistance
10. Coordination and integration of federal, state and local services and
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
• Schoolwide documentation evidence reveals schoolwide
model is in actuality a targeted-assistance program
• Cannot provide schoolwide plan
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
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 buildingallowable/restricted/or not allowable to combine
Use Correct Order
Determine which funds will be combined
Address intents and purposes in the plan
Meet and document intents and purposes
Determine how to charge
Fiscal Flexibility
• Examples of ways to charge consolidated funds
• Charge proportionately based on revenue
• Charge sequentially
• Charge based on activity (not use flexibility)
Title I, Part A Schoolwide:
Supporting Documentation
• OSPI Combining Funds Bulletin: Bulletin #054-12
• Designing Schoolwide Programs: Non-Regulatory GuidanceMarch 2006
• ESEA/Section 1114(b)(1); 34 CFR 200.25
Title I, Part A
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
Parent Involvement CPR Issues
1% (Districts who receive an allocation of $500,000 or
• 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
FP 201-Updates
FP 201-Updates
FP 201-Updates
Parent Involvement News
Title I, Part A Parent Involvement Webpage
1. Survey News
2. OSPI Title I, Part A – New Parent
Involvement Website
3. Parent involvement website with
requirements across all federal
programs (long term goal)
Parent Involvement -Resources
• Parental Involvement: Title I, Part A Non-Regulatory Guidance
• Keys to Successful Partnerships: Six Types of Involvement
• CISL Website – Family Engagement, translation/interpretation
• Spanish/English glossary of education terms
Title I, Part A
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
• 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
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
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
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
Title I Equitable Services Resources
• Title I Services to Eligible Private School Children, NonRegulatory 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:
Title I, Part A
Title I iGrant Application (FP201) Changes
• Contact Page: Please update school district contact
• 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
Title I, Part A
Charter Schools - Accountability
• 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
• 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
• 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
• 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
• 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)].
Title I, Part A
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
• Conform to any limitations in the A-87 circular
• Be consistent and applied consistently (capital assets,
direct vs. indirect costs, etc.)
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
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
(Services to Students)
Presumptions of supplanting for districts and targeted assistance
• 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 nonfederal 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
• Presumption of supplanting for Title I, Part A schoolwide
• 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
Title I, Part A
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
• People don’t like it!
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
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
What is an employee?
• Salaries, wages and benefits are charged under objects 2,
3, and 4
• An employee is NOT a vendor or independent
• No time and effort is needed for non-employees (See
OMB Circular A-133 __.210 for vendor criteria)
What type of reporting is needed?
• Single cost objective→Semi-annual certification
• Multiple cost objectives→Monthly time reports
or Personnel Activity Reports (PARs)
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)
What are some typical examples of single cost
The set of work activities allowable under:
• A single federal program
• A single required set-aside/reserve in a federal
• Federal Special Education and State Special
• A schoolwide program
• A federal program and its state/local match
What are some typical examples of
multiple cost objectives?
The work activities of:
• A federal program with multiple setasides/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
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
What is a monthly time report?
• 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
What type of supporting documentation is
• Requires a judgment call
• Examples include, but are not limited to:
• Class schedules
• Number of students
• Number of minutes
• Calendars or work logs
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
When is an accounting adjustment required?
If the difference is 10 percent or more:
• Payroll charges must be adjusted at the time of the
• 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
• BUT: At year-end any payroll charges to federal awards
that exceed actual time and effort must be eliminated
Who should sign the reports?
• Monthly reports (PARs) must be signed by the
• 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
Schoolwide Programs
• A schoolwide plan must specify programs to be
• 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
Supplemental Contracts, Stipends, Extra
• Primary contract and additional contracts may
be reported separately
• Time and effort may be required for primary
contract but not supplemental (or vice versa)
• Superintendent, assistant superintendent,
principal, assistant principal are usually not
allowable charges to federal programs
• Exceptions require detailed documentation
to support
• Generally a supplant issue
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 appropriate
New Substitute System
• Semi-annual certifications permitted for multiple
cost employees with predetermined (fixed)
• Employee MUST sign
• Must notify OPSI prior to use
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
• Supplement, not supplant applies to many
• 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
• Ask for help if needed
Additional Information on Time and
• OSPI Bulletin 051-11
• 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 )
OSPI Title I/LAP Contacts
• Title I, Part A/LAP Program Director
• Gayle Pauley,, 360.725.6100
• Title I, Part A/LAP Program Supervisors
• Bill Paulson,, 360.725.6104
• Jody Hess,, 360.725.6171
• John Pope,, 360.725.6172
• Larry Fazzari,, 360.725.6189
• Mary Jo Johnson,, 360.725.6103
• Penelope Mena,, 360.725.6069
• Petrea Stoddard,, 360.725.6169
• Reginald Reid,, 360.725.6168
• Title I, Part A/LAP Support Staff
• Julie Chace,, 360.725.6167
• Tony May,, 360.725.6231
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