Title I Directors Workshop Trisha Schock, Executive Director of Admin Services
Title • Fiscal requirements 2018 and beyond • Braiding Funds • SNS Methodology • Lap & Title Allowable Expenses • Time and Effort • LAP HP Allocations • Transferability & REAP • Combining funds in SW Title I Program
Fiscal Requirement 2018 and beyond • LAP HP Carryover – 10% • Migrant Carryover – 100% • Federal Outlook – reallocation to charter schools • ESSA Pupil Spending per Building • Monthly Grant management • Increased compliance on grant award date expenditures
Monthly Grants Management
Monthly Grants Management
Monthly Grants Management
Braiding Funds – OSPI Presentation • Requires district initiatives to be developed as teams • Conduct needs assessment • Allows multiple federal and state grants to support initiative while maintaining award-specific identity • Several allowable initiatives – provides examples • Multi-Tiered System of Supports • Grade-Level Literacy Rates • Professional Learning • Positive School Climate • Regular Attendance • 9 th Graders on Track • Dual Credit Programs
SNS Methodology • Initial guidance intended to be more flexible to implement comprehensive plans and demonstrate compliance • Draft regulations proposed in 2016 were not adopted after congress determined they were beyond the requirement. • Dept. of Ed withdrew rulemaking guidance in July 2018 • January 2019 Dept. of Ed proposed new regulatory guidance, is open for public comment
SNS Methodology • Proposed Guidance • No longer required to identify any individual cost or service supported with Title I, Part A funds is supplemental. • Must have a methodology to allocate State and local funds to schools in each Title I school receiving State and local funds it would otherwise receive if it were not receiving Title I funds. • Must be “Title I Neutral” • Other non-Federal funds not included in determining compliance
SNS Methodology Example
SNS Methodology Example
SNS Methodology • FAQ • Do not have to adjust allocation of State and local resources to account for changes during the year that might result in non-compliance • Compliance under new methodology required for 18-19 school year • Not required to allocate Impact Aid or similar Federal Funds • 3 instances schools are not required to meet SNS requirements • If they are One School • A grand span with a single school • Only Title I schools • If State and local funds are considered supplemental funds to Title I then they are excluded from the SNS calculation Example: State funds used in non-Title school for after-school tutoring, but Title I funds used in Title school for same program – not violation
Title I Allowable Expenses • Common Misconceptions of Title I • Funds may only be used to support reading / language arts and math instruction • May be used to support academic areas that the schools’ needs assessment identifies as needing improvement • Fund may only be used to provide remedial instruction • May be used to upgrade the entire education program in the the school in order to raise the achievement of the lowest-achieving students. This does not need to be achieved through remedial instruction. May be best achieved by preparing low- achieving students to take advanced courses • Funds may only be used to serve low-achieving students • May be used to upgrade the entire education program in a schoolwide program, in which all students benefit and improve achievement of low-achieving students
Title I Allowable Expenses • Common Misconceptions of Title I • Funds may not be used to support preschool-aged children • Schoolwide program may use funds to operate, in whole, or in part, a preschool program to improve cognitive, health, and social-emotional outcomes for children from birth to age of free public elementary education. All preschool-aged children who reside in schools attendance area are eligible for attendance • Allowable activities for Title: • Provide eligible students with a well-rounded education • Instructional Supports • Non-instructional services that supports behavior, mentoring and social and emotional learning that improves academic growth • Improving school quality
LAP Allowable Expenses • LAP offers supplemental services for K-12 students scoring below grade level standard in English language arts and mathematics. • Supports may include academic readiness, skill development, or behavior supports to address barriers preventing students from accessing core instruction. • Utilizing research-based best practices designed to increase student achievement, students should see an increase in academic growth during the period of time supports are provided • Must focus first on needs of K-4 students in reading or reading readiness • Must use data to develop programs that are most effective and efficient
LAP Allowable Expenses • Allowable Activities • Extended Learning Time – before or after school, Saturdays or Summer • Tutoring – including pull-out, push-in double-dosing support that occurs during the school day • Extending learning opportunities program for students in 8, 11, & 12 • Professional Learning – all educators working with LAP students explicitly tied to student learning goals, student achievement, needs of diverse student populations, specific literacy and math content and instructional strategies, and suing student work to guide instruction • Consultant Teachers – content and/or instructional coaches who work with teachers serving LAP students • Family Engagement – activities/support for families of LAP students – including family engagement coordinators • Community Partnerships – to increase student engagement and enhance students’ readiness to learn
Time & Effort - Single Cost Objective Time & Effort reporting is important in ensuring that federal program funds are used to pay only their proportionate share of personnel costs. An employee whose salary is supported by only one federal program or single cost object may be prepared on a semi-annual basis. Single Cost Objective: a single function, single grant or single activity. It is possible to work on a single cost objective even if an employee works on more than one Federal award or on a Federal award and a non- Federal award. They key to determining whether an employee is working on a single cost objective is whether the employees salary & wages can be supported in FULL from each of the federal awards on which the employee is working, or from the federal award alone if the employees salary is also paid with non-Federal funds.
Time & Effort - Multi-Cost Objective An employee whose is supported by multi-cost objectives must provide a monthly PAR or equivalent documentation supporting their time & effort. Instances of multiple activities or cost objectives for which a PAR is required: More than one Federal award Federal award and non-Federal award. Unallowable activities Completed quarterly, signed for each month. Must be signed and dated by employee & supervisor
Duty Form / Schedule
PAR Form
PAR Form
Semi-Annual Cert
Time & Effort – Substitute Option Standard Requirements for substitute system Indicate the specific activity or cost objective that the employee worked on for each segment of the employee’s schedule; Account for the total hours for which each employee is compensated during the period reflected on the employee’s schedule; and Be certified at least semiannually and signed by the employee and a supervisory official having firsthand knowledge of the work performed by the employee. Revisions to an employee’s schedule that continues for a prolonged period of time must be documented and certified. Any significant deviations from an employee’s established schedule that require the employee to go back to a PAR form. Have to apply for substitute option with OSPI, not allowed until approved.
Time & Effort – Substitute Option Can use the substitute option, employees must: Currently work on a schedule that includes multiple activities or cost objectives that must be supported by monthly PAR’s Work on specific activities or cost objectives based on a pre-determined schedule; and Not work on multiple activities or cost objectives at the exact same time on their schedule. Under the substitute system, in lieu of PAR, eligible employees may support a distribution of their salaries and wages through documentation of an established work schedule that meets the standards.
LAP HP Allocations
Transferability • Transferability – can transfer all or a portion of the funding by formula under certain Federal programs to their allocations under other programs so they can address more effectively their unique needs • General Rules: • May only transfer funds from Title II, Part A and Title IV, Part A • No limits on percent of funds you can transfer • Must consult private schools and local Tribal government as applicable • Must notify OSPI 30 days prior with FP 821 • Once funds are transferred, they take on the identify of the Title to which they were transferred and must be spent under the applicable rules
Transferability
Transferability
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