Choosing a Consolidation Option for Schoolwide Programs Local educational agencies (school districts and charter schools) that would like their campuses to take advantage of the flexibility offered by a Title I, Part A schoolwide program must choose the best way to consolidate funds. The chart below can help you and your local educational agency (LEA) decide which of the three possible consolidation options would be most beneficial for your campus. Campuses can consolidate their Title I, Part A grant funds, or their Title I, Part A funds and other funds, into a single budget “pool.” Funds in the pool belong to the schoolwide program budget instead of many individual budgets, and the campus can use the pool to pay for any activity that improves the entire educational program of the campus. This consolidation eases some of the usual fiscal and programmatic requirements that apply to federal grant funds. The options are as follows: Full consolidation. This option involves pooling some or all of your campus’s federal funds with state and local funds, and provides the most flexibility in terms of operating schoolwide programs. Federal consolidation. This option involves pooling some or all of your campus’s federal funds, but does not involve state or local funds. Title I, Part A. This option does not pool any funds, but allows your campus to use its Title I, Part A allocation on a schoolwide basis. Local educational agencies can choose different options and include different fund sources for each campus. Please note that you must account for all expenditures for any federal funds that are not consolidated. SEE CHART Additional Requirements for Certain Federal Programs The following are additional requirements that your campus must meet if you consolidate funds from certain programs: Individuals with Disabilities Education Act, Part B (IDEA‐B). A schoolwide campus may consolidate IDEA‐B funds, but the amount of funds consolidated may not exceed the amount of IDEA‐B funds received by the campus’s LEA for that fiscal year divided by the number of children with disabilities in the LEA’s jurisdiction multiplied by the number of children with disabilities participating in the schoolwide program. In addition, LEAs must consider consolidated IDEA‐B funds as federal IDEA‐B funds for the required calculations that ensure compliance with the excess costs and maintenance of effort provisions of IDEA‐B. A campus may also consolidate funds it receives for students with disabilities under Section 8003(d) of the Elementary and Secondary Education Act (ESEA). A campus that consolidates section 8003(d) funds or IDEA‐B funds may use those funds for any activities included in its schoolwide program campus improvement plan, but the campus and LEA must comply with all other requirements of IDEA‐B to the same extent that they would if they did not consolidate funds. For example, LEAs must ensure that each schoolwide campus provides services to children with disabilities in accordance with a properly developed individualized education program and provides all the rights and services guaranteed to children with disabilities under IDEA. Indian Education. A schoolwide campus may consolidate Indian Education funds received under Subpart 1 of Part A of Title VII of ESEA only if the parent committee established by the campus’s local educational agency to help develop the Indian education program approves the inclusion of those funds. Migrant Education. Before consolidating Title I, Part C Migrant Education funds, a schoolwide campus must, in consultation with parents of migrant children or organizations representing those parents, or both, document that it has met TEA's 11 migrant student performance criteria. The campus must have written approval from Migrant Education program staff at TEA. 1
TEA Consolidation Options
Applicable Requirements
Option 1
Option 2
Option 3
Full Consolidation
Federal Consolidation
General fiscal activities
Title I, Part A Only
Most flexibility
Some flexibility
Least flexibility
Local control
Some flexibility
Least flexibility
Ability to try innovative programs
Some flexibility
Most flexibility
Least flexibility
BEFORE IMPLEMENTATION
Eligible funds
All federal education funds (formula and discretionary) that come from programs Only Title I, Part A funds are eligible.
administered by the U.S. Department of Education are eligible. These funds must be used to carry out activities in a public elementary or secondary school. The U.S. Department of Education does not administer Head Start and National School Lunch programs so their funds cannot be consolidated in a schoolwide program.
Most flexibility
IDEA, Indian Education, and Migrant Education grants are eligible but have additional requirements. Specific information about these requirements is given below this chart.
Identification of funds
Your campus improvement plan (CIP) must identify the specific programs being consolidated and the dollar amount each program contributes to the consolidated schoolwide budget.
Your CIP must demonstrate that your schoolwide program contains sufficient resources and activities to reasonably address the intents and purposes of each of the consolidated federal programs, particularly as they relate to your campus's lowest‐performing students.
IMPLEMENTATION
How you must use the funds
For consolidated formula funds, you must address the intents and purposes of the programs and the needs of the intended beneficiaries of the programs. You do not need to meet most of the individual statutory and regulatory requirements of each program for funds that are consolidated.
For consolidated discretionary funds, you must carry out all of the activities described in the discretionary program grant application.
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Your CIP must include the dollar amount of all Title I, Part A funds in the schoolwide budget.
Your CIP must specify each activity you will provide using Title I, Part A funds.
You must use Title I, Part A funds to address the specific educational needs of the campus that were identified in your needs assessment and listed in your CIP. Activities and services are allowable as long as they meet the intents and purposes of the Title I, Part A program.
Option 1
Option 3
Option 2
Full Consolidation
Title I, Part A Only
Federal Consolidation
Specific allowable costs
The schoolwide budget may only support a service or activity that supports the educational The schoolwide budget may support any service or activity of or instructional needs of the campus that were identified in your comprehensive needs your schoolwide program that was assessment and included in your CIP. identified in your comprehensive needs assessment and included in your CIP, and that is allowed by Costs must meet any additional requirements given in Office of Management and Budget state and federal law.
(OMB) Circular A‐87.
Allowability of basic operational expenses (such as maintenance, repairs, and landscaping)
Consolidated funds can only pay for educational or instructional expenses, so you may not Fund sources lose their use schoolwide budgets for basic operational expenses.
programmatic identity and it is impossible to know which specific funds paid for specific activities. Basic operational expenses are also not allowable under OMB Circular A‐87.
Therefore, you may use schoolwide budgets for basic operational expenses. However, to comply with the supplement not supplant requirement, your campus must receive its full allocation of state and local funds, which must be sufficient to provide for these expenses.
Accounting
You do not need to track consolidated federal funds to activities that are allowable under individual programs.
Because Title I, Part A funds are not consolidated with other federal, state, and local funds, you must account for and track the Title I, Part A funds separately, identifying the activities supported by the funds.
Records That Must Be Maintained
If you consolidate only Title I, Part A funds, If you consolidate only federal funds, Your campus does not need to maintain separate fiscal accounting including Title I, Part A funds, you must keep you must keep records that demonstrate that you use the Title I, Part A funds to support records that demonstrate that you use records, by federal program, to federal funds, including Title I, Part A funds, activities that address the specific educational demonstrate that an activity in needs of your campus identified by your to support activities that address the your CIP may be supported by specific educational needs of your campus comprehensive needs assessment and consolidated federal funds.
included in your CIP.
identified by your comprehensive needs assessment and included in your CIP.
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Option 1
Option 2
Full Consolidation
Title I, Part A Only
Federal Consolidation
ADVANTAGES
Time and Effort Documentation
Employees paid entirely from the schoolwide pool must maintain signed semi‐annual certifications. However, if the campus consolidates funds from programs covered by Ed‐
Flex, the semi‐annual certification required is waived.
Employees paid entirely from the schoolwide pool are not required to maintain signed semi‐annual certifications or any other form of time and effort records.
Employees paid partially from a federal fund that is not consolidated must maintain time and effort records in accordance with OMB Circular A‐87 or a substitute time and effort system approved by TEA.
Option 3
Employees paid partially from a federal fund that is not consolidated (or from a federal program not covered by Ed‐Flex) must maintain time and effort records in accordance with OMB Circular A‐87 or a substitute time and effort system approved by TEA.
Budget amendments to the NCLB Consolidated Application
Amendments are not required if you use the class‐object code 8911, Operating Amendments are required because funds Transfer Out. However, for funds not budgeted under class‐object code 8911, are budgeted by program fund source and amendments may be required.
class‐object code.
Supplement not Supplant
Federal funds must supplement the Federal funds must supplement the state and Federal funds must supplement the state local resources the campus would receive in and local resources the campus would state and local resources the the absence of Title I, Part A.
receive in the absence of Title I, Part A.
campus would receive in the absence of Title I, Part A.
In other words, the campus does not need to demonstrate that any particular service is supplemental to state or locally funded services.
In other words, the campus does not need to demonstrate that any particular federally funded service is supplemental to state or locally funded services.
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In other words, the campus does not need to demonstrate that any particular Title I, Part A–funded service is supplemental to state or locally funded services.