IDEA Grants Overview
Directors’ Conference – August 5, 2015
Egrants
Timelines
Amendments
Carryover
CEIS
Proportionate Share
Audits
Excess Cost
MOE
Questions
FY15 – Presented Many Challenges
Illinois Districts/Cooperatives
Met Each Challenge
MOE Eligibility - MOE eligibility page
was added to the IDEA grant application.
 100% completion by Illinois districts and
cooperatives.
 Illinois implemented prior to July 1, 2015
regulatory change.
IDEA Excess Cost – The initial year for the
IDEA excess cost documentation process.
 100% completion by Illinois districts and
stand-alone charter schools.
“Forfeiture Clause” Prohibition – Districts
and cooperatives were notified that
special education Articles of Joint
Agreement cannot include a provision
requiring any member districts
withdrawing from the cooperative to
forfeit unexpended and unobligated IDEA
funds.
 Several cooperatives requiring revision to
their Articles of Joint Agreement promptly
contacted ISBE regarding the process and
timeline for completion.
FY16 – Off to a Good Start
• MOE worksheets were available early (April 2, 2015)
• IDEA grant applications were early (May 13, 2015)
– No significant changes to the grant application process
• July 1, 2015 revisions to 34 CFR Part 300 - We do not
anticipate any needed revisions to Illinois IDEA MOE
policies/procedures.
• Excess cost finding – we are cautiously optimistic that
documentation will verify that Illinois addressed the
requirement prior to receiving the finding.
ISBE Contacts
for
IDEA Grant
Questions
Question
IWAS Technical Difficulties, e.g. problems
with:
• Passwords
• Adding new users
• Locked pages
• Adding amendments or subgrants
Programmatic IDEA Grant Questions
• Allowable expenses
• Grant timelines
• Excess Cost
• CEIS
• IDEA proportionate share
• On-going audits
Contact
Please reference the instructions in the
egrant application.
If additional assistance is needed, please
contact the HELPDESK at 217/558-3600.
Special Education Services – Grant
Coordinators
[email protected]
[email protected]
[email protected]
217/782-5589
IDEA Maintenance of Effort (MOE)
Special Education Services – Pam Jurkoshek
217/782-5589
Fiscal Questions
• IDEA allocations
• IDEA proportionate share calculations
• Expenditure reports
• Indirect costs
Funding and Disbursements Division
http://www.isbe.net/funding/html/special
ed.htm
217/782-5256
Managing
the
IDEA Grants
US Department of Education
IDEA Allocation
(Generated by District Population)
State Education Agency
(ISBE)
Special Education Cooperative
Member District
Member District
Member District
Stand-alone District
IDEA Funds Moving Between
Cooperatives & Member Districts
• Keep track of the IDEA funds – must be able to
show the money trail and verify how the funds
were spent, this includes IDEA carryover funds
• Any funds budgeted for payment to
districts/cooperatives, must include a clear and
detailed explanation
– Tuition is specific to students, i.e. not salary
reimbursement to avoid federal TRS payments
IDEA Funds Moving Between
Cooperatives & Member Districts
(cont.)
• Nonpublic proportionate share funds must
flow to the districts
• IDEA funds used for CEIS (voluntary and
required) must flow to the districts
IDEA Funds - Follow the Students
IDEA funds must be expended on the students/districts
that generated the federal funds.
• IDEA funds expended by a district through an IDEA
subgrant.
• IDEA funds expended by a cooperative on behalf of
the member district.
Carryover funds are attached to the district that
generated the funds.
Unexpended and unobligated IDEA funds, including
carryover, cannot be forfeited upon withdrawal from a
cooperative.
IDEA Funds Moving Between
Cooperatives and Member Districts
Cooperative
(pass-through entity for IDEA funds)
Funds Expended on Behalf
of Member Districts
•
•
Member District Subgrants
(IDEA funds allotted to member districts)
•
expenditures in the cooperative
AFR
cooperatives tracks expenditures
and carryover by district
unexpended funds are district
carryover
Special Education Expenditures
•
•
•
expenditures in the district AFR
audit trail for the IDEA funds,
including payments made to the
cooperative
unexpended funds are district
carryover (coop. and district
track)
When a district purchases
a service from a
cooperative through an
IDEA subgrant, the IDEA
funds are no longer
attached to the district.
Walking the Line
IDEA grants are for special education expenses:
• Expenses must be reasonable and necessary for
the provision of special education services.
• Grantees must be able to verify that IDEA funds
expended were for special education costs:
– Track the money
– Withstand an audit
• School districts are required to expend local funds
for special education services.
Control What You Can
• Timelines - ISBE cannot back date or approve after the fact
• Track IDEA allocations, expenditures, and any carryover
• Staff training and notifications
– Have procedures in place to train new staff members
– Share listserv announcements
• Amend the grant as needed
– Keep current
– Cooperatives and member districts coordinate amendments
• Use available resources
– Instruction links in the egrants, FRIS, ISBE website
Prepare for What You Can’t Control
• Allocations can change during the fiscal year
• State funding can change during the fiscal year
• Be aware of and verify funding source options for
expenditures – flexibility without supplanting.
• Keep current with federal and state regulations.
• Read the notices from the IDEA grant team and
share with staff in the district/cooperative.
Know the Grant Timelines
July 1
Earliest start date for the IDEA grants
September 30 Timeline for completing MOE
May 31
Last date to submit an amendment for the regular
IDEA grant period
June 30
End date for the IDEA grants
August 1
Last date to submit an amendment for any IDEA
grant that has an approved extension
Timelines that Impact IDEA Grants
Timely and Meaningful Consultations (TMC)
• Meetings conducted by May 31
• TMC documentation submitted to ISBE by June 15
MOE Reduction – Eligible districts that seek to take the
MOE reduction, must submit the MOE Reduction form
to ISBE by September 30.
Excess Cost - Due at ISBE by the last working day of
January (January 29, 2016 for FY16).
CEIS Annual Reporting – Due at ISBE by the end of
February.
Stay Within the Grant Period
• Obligating funds - substantially approvable grant
(including subgrants) submitted to ISBE
• Start date for salaries/benefits is tied to the start
date of the grant
• Budget for the current grant period
– Length of licenses, leases, etc.
– ESY and summer expenditures (note the timelines)
• Liquidation period – 90 days from the end of the
grant
Avoid Common Errors
Provide sufficient details in grant applications
– Double check CEIS and budget details
– Complete the GEPA and FFATA sections, NA is not an
option
– Only note “shipping/handling” costs when those costs are
billed separately
– Note per unit cost for equipment
– Include district threshold for non-capitalized equipment
(object 700)
Avoid This Less Common Error
Private special education school/facility tuition and
travel expenses are NOT allowable costs in the IDEA
grants. Information on nonpublic special education
programs (14-7.02) is available at
http://www.isbe.net/spec-ed/html/nonpublic_se.htm.
Equipment Purchases
• Use
– Project/program purchase
– Possible additional project/program
– Nonpublic limitations (34 CFR 300.144)
• Management Requirements
– INVENTORY TRACKING SYSTEM
• Disposition
– More than $5,000 (per unit) – use equipment deletion
process in IWAS
34 CFR Part 80 (EDGAR) 80.32 – Equipment
http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html
Amending the Grant
Amendments are required for:
– significant changes in program scope; or
– budgeting for more available funds (i.e. carryover); or
– purchases exceed the ISBE expenditure variance of
20% or $1,000 per budgeted cell, whichever is
greater; or
– adding new expenditure items.
*This includes changes in purchases of previously
approved equipment.
Note changes in the amendment page
- Include subgrants with amendments
Carry Over of IDEA Funds
Unused IDEA funds carry over to the next
fiscal year. Carry over funds must be spent
within the one-year carry over period. Carry
over funds are attached to the districts that
generated the funds.
Carry over funds are:
– Generally loaded in late summer/early fall
– Noted on the allotment page of the grant
– Expended first
Better Safe than Sorry
Errors with the federal grants can result in
repayment of funds or adjustments to budgets.
When you encounter a new situation or don’t
fully understand a grant related issue; email or call
your grant coordinator.
With grants, it is wiser to ask permission first than to
beg forgiveness later.
Audits
Audits
• A-133
– Respond in a timely manner, contact your grant
coordinator with any questions
– District and cooperative communication
– Follow through on corrective action to avoid a repeat
finding
– Audit findings can impact LEA determinations
• State – ISBE Federal and State Monitoring
– Generally cyclical
– Can be in response to “red flags”
• Federal - If no notification from ISBE, contact your grant
coordinator
A-133 Audits
• When ISBE receives the A-133 audit findings the
districts have already signed agreement to the
findings and the plan of action.
• Any audit finding with questioned costs will be
subject to repayment or budget adjustments.
• Districts can contact their grant coordinators during
the audit process. Please provide a detailed
explanation, so that we can provide an accurate
response.
Sample of Audit Findings
• Time/effort and certification not completed
• Inaccurate sub-recipient monitoring resulted in
questioned costs for the cooperative and/or district
• Lack of segregation of duties over cash receipts and
cash disbursements
• Payments to other districts exceeded the budgeted
amount
• Payments to staff:
– staff member(s) did not meet the qualifications
– stipends paid lacked review and approval
– salaries claimed for reimbursement did not agree to total
wages in the grant application
A Few More Audit Findings
• Errors in expenditure claims
– Claimed too early
– Claimed in two fiscal years
– Over-claimed
– Not filed in a timely manner
– Did not match the general ledger
• Unallowable expenses paid from the grant
• Discrepancies with the general ledger
• Equipment purchases that exceeded $5,000 were not
tracked in an inventory list
Coordinated Early Intervening Services
(CEIS)
Coordinated Early Intervening
Services (CEIS)
• Voluntary for most grantees
• May use up to 15% of funds for CEIS:
for professional development, and
to provide evaluations, services and supports
including scientifically-based literacy instruction.
• Must document and report to ISBE
OSEP:
how many students are served, and
how many students are later determined eligible
under the IDEA.
CEIS (cont.)
CEIS is for students who have not been identified as
special education eligible.
• RtI can be included in the grant as a CEIS expense.
• PBIS and progress monitoring in IDEA grants (e.g.
AIMSweb, DIBELS):
at-risk population receiving early intervention services
– budget in CEIS
OR
special education population only - budget as ordinary
IDEA grant expenditures.
CEIS (cont.)
IDEA CEIS funds cannot be used to supplant any activity that was
previously funded by federal ESEA funds e.g. can use IDEA CEIS funds
to supplement/add on to existing activities, but cannot replace
previous funding with IDEA CEIS funds.
*If a district is eligible for voluntary MOE reduction:
• any use of CEIS will count toward that total
AND
• the combined dollar amount for the MOE reduction and CEIS
will be limited to the smaller amount (usually 15%).
Any district opting to take a MOE reduction must complete and submit the
IDEA MOE Reduction form to its IDEA grant coordinator by September 30,
2015.
34 CFR 300.205
Appendix D to Part 300
Professional Development
IDEA Funded
Professional Development
• At least 5% of the IDEA flow-through budget must
be dedicated to professional development
activities.
• IDEA-focused is the standard for all professional
development activities.
• IDEA funded out-of-state travel for professional
development is limited to LEA/cooperative
employees.
IDEA Funded
Professional Development (cont.)
• Any equipment provided as part of a
conference is the property of the
district/cooperative, e.g. pre-loaded ipad
• Out-of-state travel
– Requires prior approval, submit the approval
request at least one-week in advance of the
event
– All requirements apply, including reasonable
and necessary for the purpose of the grant
• Use the federal funds wisely
Supplement
Not
Supplant
IDEA funds are to supplement, not
replace, local spending on students
with disabilities.
Excess cost and MOE requirements
are two prongs of IDEA supplement
not supplant.
Excess Cost
of
Special Education
34 CFR 300.202
• IDEA funds are for the excess costs of providing
special education and related services to children
with disabilities.
• IDEA funds must be used to supplement state,
local, and other federal funds and not to supplant
those funds.
• The excess cost requirement prevents an LEA
from using funds provided under Part B of the
IDEA to pay for all of the costs directly
attributable to the education of a child with a
disability.
Excess Cost Determination
Each district must determine its excess cost
threshold.
• Appendix A to Part 300 of the CFR
• FY15 – Initial year for the IDEA excess cost
documentation and verification process.
• FY16 – The second year will include steps for IDEA
excess cost verification.
FY15 - IDEA Excess Cost
• It was a new process for all of us.
• 100% of Illinois districts and stand-alone charter
schools completed and submitted the excel
worksheets.
• It was a learning process for districts, cooperatives, and
the IDEA grant coordinators.
– We had some bumps on the road
– We used those problems as a basis for FY16 revisions
• We made it through the first year, we will all have a
better idea of what to expect for future years.
FY16 - IDEA Excess Cost
• Revisions to instructions and prompts in the
worksheets – clearer directions
• Added a line to Section A for entering IDEA
expenditures “made by the cooperative on behalf of the
district.” Cooperative member districts will enter
expenditure detail report form data in two places on the
excess cost worksheet.
• Overhaul to Section D:
– formatted the state/local section to match Sections A and B
– included lines for districts to note where the expenditures
are located in the AFR
• Added Section H, Excess Cost Check
Section H – Excess Cost Check
Section H, of the FY16 excess cost worksheet, uses the FY15
AFR expenditure data and the FY15 final, verified child count
data to determine the average annual per pupil expenditure.
(APPE X students with IEPs = district costs for special education)
That amount is then compared to the excess cost threshold
from the FY15 excess cost worksheet.
(FY15 costs – FY15 excess cost threshold)
A positive number or a zero means the district met the FY15
excess cost threshold. No other action is needed for FY15,
keep monitoring FY16 spending.
A negative number means the district did not meet the FY15
excess cost threshold. The negative amount must be resolved
to avoid repayment of the federal shortfall.
Excess Cost Check – Negative Amount
• Don’t panic
• Double check for any errors
• If the amount is still negative, the district should
contact the IDEA grant coordinator. The IDEA
grant coordinator will work with the district to
identify any errors in the FY16 and FY15 excess
cost worksheets.
As with IDEA MOE, if the negative amount cannot
be resolved the district must repay the federal
shortfall with local funds.
The worksheet includes a link to the FY15
final, verified child count with each district’s
student population separate by elementary
and secondary.
SECTION H - Excess Cost Check
Elementary (K-8)
Secondary (9-12)
Total
FY15 # of Students with IEPs (final verified list - www.isbe.net)
FY15 Special Education Costs (APPE X students with IEPs)
Enter the FY15 IDEA Excess Cost Threshold (line 81 of the FY15 worksheet)
H FY15 Check (line 77 - line 78 )
$0.00
$0.00
$0.00
$0.00
The district met the FY15 IDEA excess cost threshold if the final amount is zero or a positive number. A negative amount
indicates the district did not meet the FY15 IDEA excess cost threshold.
The final amount verifies whether or not the district met the FY15 IDEA excess cost threshold.
Any district that did not meet the FY15 excess cost threshold should contact its IDEA grant
coordinator.
45
Federal Finding – March 19, 2015
Citation: Excess costs are those costs that are in excess of the
average annual per-student expenditure in an LEA during the
preceding school year for an elementary school or secondary
school student, as appropriate, and that are computed using
the method described in 34 CFR 300.16. As part of its general
supervisory responsibilities under 34 CFR 300.149 and
300.600, the SEA must ensures that LEAs: (1) as part of their
application for Part B funds, include an assurance to the SEA
that it will comply with the requirements related to excess
costs, and (2) are computing excess costs in a manner
consistent with Appendix A of the IDEA regulations and using
IDEA funds only for the excess cost of providing special
education and related services for children with disabilities as
required by 34 CFR 300.16 and 300.202.
Status of the Excess Cost Finding
• The letter of findings acknowledged that “given the
length of time between OSEP’s monitoring and this
letter, the State may have changed policies and/or
procedures.”
• ISBE provided corrective action documentation
(policies/procedures, excess cost worksheets,
instructions, webinars, tip sheets, notifications).
• We are waiting on a response from OSEP.
Excess Cost – An Ongoing Process
August/September – release of the IDEA excess cost
worksheets/instructions. This timeframe allows for the revised AFR
forms and final, verified fall enrollment and child count data from
the previous fiscal year. FY16 will also include the release of an
excess cost webinar.
October – AFRs are due to ISBE, districts will have the data to
complete most of the excess cost worksheet.
December – special education child count is due to ISBE, districts
will have the final data needed to complete the IDEA excess cost
worksheet.
January – the IDEA excess cost forms are due to ISBE.
When the IDEA excess cost worksheets are complete, the districts
will have the excess cost threshold for the current year, i.e. the
amount of local (state/local) funds that must be expended on
students with disabilities. District should track local spending.
Maintenance of
Effort
(MOE)
34 CFR 300.203 – 300.205
MOE in a Nutshell
• Local (local or state/local) spending on students with
disabilities cannot decrease from year-to-year.
• Regulations specify allowable MOE exceptions:
– Voluntary departure of staff
– Termination of obligation to provide an exceptionally
expensive program to a student or students with disabilities
– Termination of costly expenditures for long-term purchases
• Also, if per capita remains the same, MOE is met.
• Failure to meet MOE requires repayment of federal funds in
the amount of the MOE shortfall.
July 1, 2015 - 34 CFR 300.203
The MOE regulations were amended July 1, 2015.
• MOE eligibility and MOE compliance
– Illinois districts documented MOE eligibility prior to the
regulatory revision
• Detailed four methods for meeting MOE
– Local only option was available for Illinois districts prior
to the regulatory change
• Clarified that failure to meet MOE does not lower
the MOE level (2012 letter to Kathleen Boundy)
– Did not impact Illinois districts
– Districts were notified and the letter to K Boundy was
posted on the IDEA grant webpage in 2012
MOE - Eligibility and Compliance
MOE Eligibility – A district is eligible to receive IDEA
funds by maintaining local effort. This is based on a
comparison of the most recent complete fiscal year
(up to 2 years) with the current budgeted amounts.
MOE Compliance - Verification that a district
maintained local effort based on a comparison of
the finalized fiscal records for two years.
(MOE worksheets are mailed to districts/cooperatives)
Local Effort
When comparing fiscal years, IDEA maintenance of local
effort can be achieved through four options:
•
•
•
•
The state and local expenditures are the same or greater than the previously
expended state and local expenditures
The local expenditures are the same or greater than the previously expended
local expenditures.
The state and local per capita costs are the same or greater than the previously
expended state and local per capita actual costs.
The local per capita costs are the same or greater than the previously expended
local per capita actual costs.
The MOE compliance data provided by ISBE is based on
the AFR, which does not separate expenditures by
state and local. Any computation of IDEA MOE
compliance based on local (no state) expenditures,
must be completed at the local level.
Keeping It Timely
• Don’t let a negative MOE delay submitting an
otherwise substantially approvable grant.
• Resolve the MOE issue as soon as possible
– Work with the ISBE grant team (Pam!!)
– Avoid holding up approval and/or amendments
• MOE resolved by September 30th .
• Before throwing in the towel, contact the grant
team.
Additional Resource Links
ISBE – www.isbe.net
Special Education Services www.isbe.net/spec-ed
IDEA Grants http://www.isbe.net/spec-ed/html/idea_part-b.htm
Rules - www.isbe.net/rules
Part 100 - accounting/budgeting/financial reporting/audits)
http://www.isbe.net/rules/archive/pdfs/100ARK.pdf
Fiscal Procedures Handbook -
http://www.isbe.net/funding/pdf/fiscal_procedure_handbk.pdf
Contact Information
Special Education Services – 217/782-5589
IDEA Grant Coordinators
• Dawn Camacho [email protected]
• Tammy Greco [email protected]
• Felicia Malloy [email protected]
MOE Consultant
• Pam Jurkoshek [email protected]
Questions