The Mechanics and Benefits of Consolidating Funds Under a Schoolwide Program Leigh Manasevit, Esq. and Mike Bender, Esq. Brustein & Manasevit, PLLC www.bruman.com May 13, 2015
Agenda • LEA ‐ Level Consolidated Admin • Basics of a Schoolwide Program – Requirements to Operate Schoolwide Program – Schoolwide Plans • Consolidation of Funds – Types of Consolidation – Accounting Methods • Benefits of Consolidation – Allowability – Time and Effort • General Fiscal Requirements – Supplement, Not Supplant – Maintenance of Effort Brustein & Manasevit, PLLC 2
Consolidated Administration • Similar Concept BUT NOT Part of Consolidated Schoolwide Program • What is Consolidated Administration? – An LEA may consolidate administrative funds under the ESEA, but only with approval from SEA. – Up to statutory cap, SEA ‐ established limitation, or “necessary and reasonable” standard – No additional admin • Similar flexibilities to schoolwide program – Not required to keep separate records, by individual program, to account for administrative costs for programs in consolidation. – Do not need to track time and effort spent on individual covered programs Brustein & Manasevit, PLLC 3
Consolidated Administration • Use the funds for the administration of participating programs • Additional use of funds in consolidated administration: – Any acceptable use for administration under – Coordination of the consolidated programs with other federal and non ‐ federal programs; – Establishment and operation of peer ‐ review mechanisms under ESEA; – Administration of Title IX (Consolidated planning, administration, waivers); – Dissemination of information regarding model programs and practices; – Technical assistance under any ESEA program; – District ‐ level activities designed to implement Title IX; – Training personnel engaged in audit and other monitoring activities; and – Implementation of CAROI. Brustein & Manasevit, PLLC 4
BASICS OF A SCHOOLWIDE PROGRAM Brustein & Manasevit, PLLC 5
Laws, regulations, & guidance • Laws and Regulations – ESEA § 1114, 34 C.F.R. 200.25 ‐ 200.29 • Describes the legal foundation of the schoolwide program – 67 Fed. Reg. 40360 ‐ 64 (July 2, 2004) • Lists programs that can be consolidated • Guidance – Designing Schoolwide Programs, Non ‐ Regulatory Guidance, ED (March 2006) – Title I Fiscal Issues, Non ‐ Regulatory Guidance, ED (February 2008) Brustein & Manasevit, PLLC 6
Targeted Assistance Programs v. Schoolwide Programs • ESEA authorizes two program designs for Title I Schools – Targeted Assistance Programs – Schoolwide Programs Brustein & Manasevit, PLLC 7
Targeted Assistance Programs v. Schoolwide Programs (cont.) Targeted Assistance Programs • – School Eligibility • Any school that receives a Title I allocation is eligible • May serve all grades or only some grades; all subjects or only certain subjects. – Student Eligibility • Provide supplemental educational services only to those “failing, or most at risk of failing, to meet the state’s challenging student academic achievement standards.” • Must use multiple educationally related objective criteria to select students. Brustein & Manasevit, PLLC 8
Targeted Assistance Programs v. Schoolwide Programs (cont.) • Schoolwide Program – School Eligibility • Must meet required poverty threshold of 40% – Waiver available – Student Eligibility • Comprehensive reform strategy to upgrade entire educational program of a Title I school • All students eligible for services. – Consolidation of funds Brustein & Manasevit, PLLC 9
So how do you become a schoolwide school? Brustein & Manasevit, PLLC 10
Step 1 – Receive a Title I Allocation • First, the school must receive a Title I allocation – Must meet the required poverty threshold – High enough on the district’s ranked list of eligible schools. Brustein & Manasevit, PLLC 11
Step 2 – Meet the required poverty threshold • In addition to receiving a Title I allocation, school must also meet required poverty threshold of at least 40% – School must serve an eligible school attendance area where at least 40% of the children are from low ‐ income families – Alternative method is to count children enrolled in school • Exceptions! Brustein & Manasevit, PLLC 12
Exceptions to Poverty Threshold • U.S. Secretary of Education can waive 40% threshold – ED ‐ Flex Waiver – SIG schools – ESEA Flexibility Brustein & Manasevit, PLLC 13
Step 3 – Planning – Planning ‐ Planning • Any eligible school that desires to operate a schoolwide program must then undertake a one year planning process, unless the LEA determines that less time is needed. – Comprehensive Needs Assessment – Schoolwide Plan Brustein & Manasevit, PLLC 14
Year ‐ Long Planning Process • Comprehensive Needs Assessment – Based on the academic achievement information of all school’s students – Must determine the needs of the school in relation to each of the required key schoolwide program components – Conducted with input from broad array of sources – Must document how the assessment was carried out, the results, and the conclusions. Brustein & Manasevit, PLLC 15
Year ‐ Long Planning Process • Schoolwide Plan – Importance of a compliant plan cannot be overemphasized. – Use the needs assessment and develop in consultation with LEA, school support team, parents, teachers, principals, and administrators. – Must be available to LEA, parents and public – TEA Characteristic (Campus Improvement Plan) Brustein & Manasevit, PLLC 16
Year ‐ Long Planning Process • Schoolwide Plan – Must include: • How will school implement mandatory schoolwide program components; • How will the school use resources; and • List of federal, state, and local programs that will be consolidated. (Critical!) – Statute does not say how often plan must be revised. – But must review annually and revise as necessary. Brustein & Manasevit, PLLC 17
The importance of the schoolwide plan • Provides information to auditors and monitors about which programs are included if there is a consolidation. • Auditors will hold the school accountable in accordance with whether: – The plan’s activities meet the intent and purposes of the consolidated federal programs; – The school is implementing the activities detailed in the plan • LEA may attribute expenditures to particular fund sources without regard to whether they actually support particular fund source as long as the expenditures support the schoolwide plan . – Use of funds also affected by level of consolidation Brustein & Manasevit, PLLC 18
Annual Evaluation • Must annually evaluate the implementation of, and the results achieved by, the program. • TEA’s Guidance asks LEAs to consider two basic questions – Is your campus implementing the schoolwide program as it was intended? – Did you campus improve student achievement in meeting the state’s academic standards to the desired level, particularly for those students who had been furthest from achieving the standards? Brustein & Manasevit, PLLC 19
Annual Evaluation • Use data from state’s annual assessments and other indicators of academic achievement. – Empirical data (test scores); and – Qualitative data (personal interviews, observations). • Monitoring findings for not using annual evaluation to update plan. Brustein & Manasevit, PLLC 20
Required Components of Schoolwide Programs • Comprehensive needs assessment • Schoolwide reform strategies Instruction by highly qualified teachers • • High ‐ quality and ongoing professional development • Strategies to attract HQTs to high ‐ need schools • Strategies to increase parental involvement • Plans for assisting preschool students in the successful transition Measures to include teachers in decisions regarding the use of academic • assessments • Activities to ensure that students who experience difficultly attaining proficiency receive effective and timely additional assistance • Coordination and integration of federal, state, and local services and programs Brustein & Manasevit, PLLC 21
Types of schoolwide programs • Only Title I funds support the schoolwide plan; no funds are consolidated – Least amount of flexibility – EDGAR applies • Consolidates only federal funds – Moderate amount of flexibility – EDGAR applies • Consolidates state, local and federal funds – Most amount of flexibility – Loss of federal identity but state/local rules still apply Brustein & Manasevit, PLLC 22
Mechanics of Funding Consolidation Brustein & Manasevit, PLLC 23
How should the process of consolidation begin? • Who makes the decision to consolidate? • Starting points? • School responsibilities? • District responsibilities? • Training and policies and procedures Brustein & Manasevit, PLLC 24
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