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Presentation Transcript Presentation Transcript - CEIS and Monitoring Use of Funds IFF 2018 On-Demand Webinar, January 28, 2019 Welcome and Presentation Introduction 0:00 Sara Doutre Welcome everyone. My name is Sara Doutre, and I am with the


  1. Presentation Transcript Presentation Transcript - CEIS and Monitoring Use of Funds IFF 2018 On-Demand Webinar, January 28, 2019 Welcome and Presentation Introduction 0:00 Sara Doutre Welcome everyone. My name is Sara Doutre, and I am with the Center for IDEA Fiscal Reporting, and this is the third in a series of webinars featuring presentations of popular sessions from our face-to-face meeting, the IDEA Fiscal Forum, which was held in Atlanta in April of 2018. And the presentation today is on CEIS, coordinated early intervening services, and specifically monitoring the use of funds for CEIS. Presenter Information 0:36 Sara Doutre My presenters today, my co-presenters are myself, from the Center for IDEA Fiscal Reporting; Mary Ellen Parrish, who is a Program Fiscal Coordinator at the Washington Office of the Superintendent for Public Instruction in Washington state; John Andrejack, who's the Financial Manager for Program Finance at the Michigan Department of Education; and Daniel Schreier, who is our CIFR Project Officer at the Office of Special Education Programs at the U.S. Department of Education.. Session Overview 1:06 Sara Doutre So as a session overview, I'm just going to give you a little bit of the objectives and then our outline for today, our time today. 1

  2. Learning Objectives: Fiscal Focus 1:14 Sara Doutre So our objectives today are that participants will understand how funds for CEIS may be reserved, participants will be able to describe ways to encourage local educational agencies' timely use of CEIS funds. We're going to spend some time talking about the logistics of reserving and using the funds, including timelines. And then hopefully, areas where you all in the states can improve your procedures for monitoring the use of CEIS funds. So, again, we aren't going to get into some things, I'll talk about that, but really focus on the logistics of monitoring funds that are reserved for CEIS. Much of the conversation will apply to both voluntary coordinated early intervening services, and comprehensive coordinated early intervening services, which is often, we often use the acronym CCEIS. But most of it will apply to both of those, even though we don't have that acronym in this presentation as well. Session Outline 2:09 Sara Doutre So, on the next slide it outlines what we are going to talk about, is what we do know about monitoring funds. The requirements and guidance, and some common questions, and then probably the most beneficial thing for states, we have found over time, is state experiences with monitoring funds. And so that's where our presenters from Michigan and Washington come in. That, we're hoping they will share with you their experience and you'll be able to learn from that, or that will spark some questions. Regulations: Voluntary CEIS 2:36 Sara Doutre So with that, I am going to quickly talk about the regulations related to voluntary CEIS and comprehensive CEIS. The regulation allowing for voluntary coordinated early intervening services, or CEIS, can be found at 34 CFR, section 300.226. And these are the regulations that allow an LEA to use up to 15% of its IDEA Part B subgrant, 611, and 619 subgrant, to develop and implement CEIS. 2

  3. CEIS, voluntary CEIS, may be provided to students in grades kindergarten through grade 12, with an emphasis on grade 3, who are not currently identified as students with disabilities, but need additional support to succeed in the general education curriculum. Activities that are allowed for CEIS include professional development and educational and behavioral interventions, and those activities are required to supplement and not supplant activities that are provided, have been provided in previous years through funds under the Elementary and Secondary Education Act, or ESEA. So if there's an activity that is going to be expanded, or increased, that was previously funded, CEIS funds may be used for that, that they may not supplant those funds. Regulations: Comprehensive CEIS 4:05 Sara Doutre There are also regulations related to comprehensive CEIS. Those regulations can be found at 34 CFR §300.646(d) and these are the revised regulations from December 2016. These are the regulations that require that any LEA identified as having significant disproportionality to use the maximum amount, or 15%, of the IDEA Part B subgrant to provide comprehensive CEIS. There are additional details in those regulations related to identifying the root cause, and making sure the CEIS addresses a significant disproportionality, but activities also include professional development and educational and behavioral evaluations, services, and supports. Comprehensive CEIS, however, may be used for children age 3 through grade 12, not just kindergarten through grade 12, as is for voluntary CEIS. And must be used particularly but not exclusively for children not identified as students with disabilities, and who are in the subgroup that has been significantly over-identified in the finding of significant disproportionality. What to Look for: Before, During, and After 5:19 Sara Doutre On the next slide, we laid out a few things that we're going to get into on our presentation, and kind of how we've organized the questions that Dan is going to walk through with me. But what we should be looking at related to fiscal requirements. So what should the SEA be looking at, and what should LEAs be examining as they look at making decisions related to coordinated early intervening services? 3

  4. And we've looked at before, during, and after the use of funds. So, before they use funds, the state should be encouraging LEAs to examine what funds are available, how long are they available, what approvals are required, what type of plan and reporting is required, we're going to talk about that. During the use of CEIS funds, again, from the fiscal side, there are other pieces, but how are you tracking the use of the CEIS funds, how are you ensuring they're used appropriately, and what are the procedures for returning to IDEA uses if they're not used. And that applies only to the voluntary funds. The comprehensive funds must be used for CEIS, but we're going to talk a little bit about returning those funds to other uses if they're voluntary CEIS. And then after the use of funds, of course, what amounts are reported, and is there any follow-up needed on the use of those funds? What Do We Know? 6:38 Sara Doutre So with that, we're going to move into what we do know. So some OSEP and CIFR responses to common CEIS fiscal questions that we've received. And I am going to turn the mic over to Dan Schreier to help us walk through those. Before: Are CEIS Funds from Section 611 or 619? 6:53 Daniel Schreier Great, can everyone hear me? Yes? All right, so here are some of the questions, some are easier than others, but it's always good to consult either with CIFR or IDC's guidance on CEIS or significant disproportionality. We have some old guidance documents as well, but it can get tricky, because you have potentially multiple requirements all interplaying with each other. And I think that's what makes these requirements potentially challenging to implement. So this first question about where do the CEIS funds come from? The question is, I guess it's a two-part question. So, one is, where do the funds come from? Was it the 611, 619 grant? Both? And the answer is yes, that when an LEA is contemplating reserving, or is required to reserve funds, it's the total of both the 611 and 619 subgrant. However, when it actually comes to the use of funds, then the LEA has discretion in using it either from one or either or both, with the caveat that obviously the 619 funds have to still keep their focus on 3- to 5-year-olds. All right? 4

  5. Before: When are Funds Available for CEIS? 7:55 Daniel Schreier So the availability of funds, potentially, we try to give as much flexibility, especially recognizing that LEAs who are getting notified that they have to reserve funds, they may have already thought and had plans for those funds for a specific year. And then that 15% reduction, reservation, can be challenging. So when we're thinking about a specific year when a district's identified a significant disproportionality, or if they want to reserve funds, the answer we give is that essentially, and I guess it's also important for states to figure out too is that, we want to see evidence that 15% is reserved, of a grant. And that potentially can be stretched over multiple years. And we're going to see, I think on the subsequent slide, we'll see that because our grants have forward funding and because the tidings period, at any point in time there's always two grants of funds, two years of funds available. And then from July 1 to September 30, there's always a third year in play as well. So we want to see, is making sure that amount of reserve is, that total amount is reserved, and now what pots of funds, maybe the district wants to use to implement comprehensive coordinated early intervening services, we'd give them discretion. We can sort of see that on the next slide. Availability of Funds 9:09 Daniel Schreier I've kind of talked about this as the forward funding and the tidings. And then it's that last bullet is, of course—and this is where it's important for you to have consistency in working with your LEAs for those with significant disproportionality, while LEAs can always change their mind and go back to saying, you know what, we don't want voluntarily reserve the funds for CEIS, we want to use them just for special-education-related services. You know, if there's that finding of significant disproportionality, then 15% has to be budgeted and expended. So, there isn't that flexibility. 5

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