Title I, Part A
Fiscal
Considerations
Virginia Department of Education
Office of Program Administration and Accountability
2017 Coordinators’ Technical Assistance Academy
Roanoke: July 11-12, 2017
Williamsburg: July 25-26, 2017
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Disclaimer: The academy was planned
under a grant from the U. S. Department of
Education (USED). However, the content
does not necessarily represent the policy of
the USED, and you should not assume
endorsement by the federal government.
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Overview
• Allocations
• To divisions
• To eligible schools
• Carryover Provisions and Reallocation
Procedures
• The Community Eligibility Provision and
Title I
• Object Code Clarification
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Identification of Priority, Focus, and
Other Schools in Improvement
Superintendent’s Memo #080-16
 Virginia will:

Exit priority and focus schools that meet exit
criteria and identify new priority and focus
schools based on pass rate data.

Not identify “Other Title I Schools in
Improvement” for 2017-2018.
 It will no longer be possible to set aside funds
for “Other Title I Schools in Improvement.”
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Allocations
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Title I Funding for 2017-2018 –
Preliminary Allocations
Total Federal Funding Year (FFY) 2017 allocation is
$15.5 billion.
• Made available by Congress under Public Law
115-231, the Consolidated and Continuing
Appropriations Act, 2017
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Title I Funding for 2017-2018 –
Preliminary Allocations
U. S. Department of Education (USED) preliminary
allocation to Virginia is $264,573,159.
• 0.6 percent increase compared to FFY 2016
($262,990,814)
• 2015 U.S. census estimates
• State per-pupil expenditure data from school
year 2014-2015
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Preliminary Allocations
• NOTE: While the state’s overall preliminary Title I
allocation increased by 0.6 percent, this does not
mean that each school division will receive an
increase in Title I funds.
• Preliminary Title I, Part A, allocations from USED
do not reflect the state set-asides, changes in
final census data, and other adjustments required
by law.
• The final allocation for each school division is
likely to differ from the preliminary allocation.
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Determining State Allocations
Basic
Concentrated Targeted
EFIG
Allocation
Allocation
Allocation Allocation
Title I, Part A, Allocations
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Basic Allocation
• USED allocates FY 2017 Basic Grant funds to
divisions through a statutory formula based primarily
on 2015 estimates of the number of children, ages 5
through 17, from low-income families, which the
Census Bureau updates annually, and on the school
year 2014-2015 per-pupil expenditure data.
• In order to receive a basic grant, a school division
must have:
– at least ten formula children; and
– the number of those children must exceed two
percent of the school division’s total population of
children ages 5 through 17.
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Concentrated Allocation
• USED allocates concentration grant funds to
school divisions in which the number of children
counted for basic grant formula purposes exceeds
6,500 or 15 percent of the total population of
children ages 5 through 17.
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Targeted Allocation
• The targeted grants formula uses the same data
elements as basic and concentration grants.
• USED then adjusts the number of formula children
to give greater weight to those school divisions
with higher numbers or percentages of formula
children.
• In order to receive a targeted grant, the number of
formula children in a school division counted for
basic grant allocation purposes must be at least
ten and equal or exceed five percent of the
school division’s total population of children ages 5
through 17.
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EFIG Allocation
• The Education Finance Incentive Grants (EFIG)
formula, in addition to using the number of Title I,
Part A, formula children and each state’s perpupil expenditures, distributes funds to states
based on an:
• effort factor that measures a state’s effort to
provide financial support for education
compared to its relative wealth as measured
by its per capita income; and
• equity factor that measures the degree to
which education expenditures vary among
school divisions within a state.
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State Set-Asides:
School Improvement
• Section 1003(a) of ESEA – States are required
to reserve seven percent of the amount it
receives under Title I, Part A, for school
improvement activities authorized in section
1003(g).
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State Set-Asides:
Administration
Administration
• Section 1004(a) of the ESEA allows a state to
reserve not more than one percent for
administrative purposes.
Equitable Services Bypass
• Reservation for equitable services
• 14 school divisions participate
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Determining School Eligibility
1. Rank order all schools in the division by
poverty.
2. Serve, in rank order of poverty, schools above
75 percent poverty, including middle and high
schools.
NON-REGULATORY GUIDANCE: LOCAL EDUCATIONAL AGENCY
IDENTIFICATION AND SELECTION OF SCHOOL ATTENDANCE AREAS
AND SCHOOLS AND ALLOCATION OF TITLE I FUNDS TO THOSE AREAS
AND SCHOOLS
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Determining School Eligibility
• AFTER all schools above 75 percent poverty
have been served, the division may:
 Serve high schools with a poverty
percentage as low as 50 percent and pull
those schools out of rank order;
 Continue with division-wide ranking; or
 Rank remaining schools by grade span.
NON-REGULATORY GUIDANCE: LOCAL EDUCATIONAL AGENCY
IDENTIFICATION AND SELECTION OF SCHOOL ATTENDANCE AREAS
AND SCHOOLS AND ALLOCATION OF TITLE I FUNDS TO THOSE AREAS
AND SCHOOLS
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Ranking Schools by Grade Span
Divisions will use either the divisionwide poverty average
or grade-span average for selected grade span(s):
• In rank order of poverty, schools are eligible if they are
above the divisionwide poverty average or the gradespan average until all schools at or above the selected
poverty average are served or no funds remain.
•
If remaining funds are not sufficient to fully fund the
next ranked eligible school, the division may serve the
school if it determines the funds are sufficient to
enable children to make adequate progress toward
meeting state standards.
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Ranking Schools by Grade Span
• Divisions with enrollment of less than 1,000
students or with only one school per grade span
do not have to rank school attendance areas.
• Divisions define grade span grouping and
determine appropriate grade span for schools
that overlap grade spans.
• Division discretion to select schools based on:
• 35 percent rule
• Grandfather clause
• Skipped school provision
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Division Set-asides
Before allocating funds, the division may reserve funds
“off the top” for:
•
•
•
•
•
•
•
•
•
Parental involvement
School improvement (only Focus and Priority schools)
Division level program administration
Teacher quality
Title I preschool
Private school services
Homeless
Neglected
Foster care
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School Allocations
• Funds must be allocated to participating
schools in rank order based on poverty.
• Division does not have to allocate the same Per
Pupil Expenditure (PPE) to each school, but
must allocate in rank order.
• PPE amounts may vary for different grade
spans once all schools above 75% have been
served.
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USED Guidelines for Federal Awards
• Updates from Omni Circular have been
incorporated into the Education Department
General Administrative Regulations (EDGAR)
 2 CFR PART 200 — Uniform Administrative
Requirements, Cost Principles, and Audit
Requirements for Federal Awards
 Subpart E — Cost Principles
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USED Guidelines for Federal Awards
§200.438 Entertainment costs:
Costs of entertainment, including amusement,
diversion, and social activities and any associated
costs are unallowable, except where specific
costs that might otherwise be considered
entertainment have a programmatic purpose and
are authorized either in the approved budget for
the federal award or with prior written approval of
the federal awarding agency.
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Carryover Provisions
and Reallocation Procedures
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Carryover Provisions
• Total period of grant award is 27 months.
• 85 percent of funds must be obligated within
15 months.
• Up to 15 percent can be carried over for the
remaining grant award period.
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Definition of Obligation
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Definition of Obligation
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Carryover Timeline
Year of
Grant
Award
Total Grant
Award
Period
Deadline to
Deadline
Obligate 85% to Obligate
of Award*
100% of
Award
Deadline to
Request
Reimbursement
for ALL funds
Sept. 30,
2018
Sept. 30,
2019
Nov. 15,
2019
FFY 2016
July 1, 2016 - Sept. 30,
(2016-2017) Sept. 30,
2017
2018
Sept. 30,
2018
Nov. 15,
2018
FFY 2015
July 1, 2015(2015-2016) – Sept. 30,
2017
Sept. 30,
2017
Nov. 15,
2017
FFY 2017
July 1, 2017(2017-2018) Sept. 30,
2019
Sept. 30,
2016
*Some divisions may receive a waiver to carry over more than 15
percent of award.
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View Spending Progress Report
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Use of Funds by Grant Year
FFY 2017 (2017-2018)
Funds must be used for ESSA
compliant activities for the life of
the grant.
FFY 2016 (2016-2017)
Funds must be used for NCLB
compliant activities for the life of
the grant.
FFY 2015 (2015-2016)
Funds must be used for NCLB
compliant activities for the life of
the grant.
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Carryover Waiver Guidelines
•
School divisions may apply for a waiver to exceed
the 15 percent carryover limitation once every three
years if:
1. The state agency determines that the request is
reasonable and necessary; or
2. Supplemental appropriations become available.
• School divisions that receive less than $50,000 are
excluded from the carryover limitation.
Superintendent's Memo #107-17 -Title I, Part A, Carryover Provisions
and Reallocation Procedures under the Elementary and Secondary
Education Act of 1965 (ESEA), as Amended
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Carryover Waiver Requests
Superintendent's Memo #107-17
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Carryover Waiver Request Template
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Eligibility to Request
Carryover Waiver
Waiver Request from
Division
FY 2016
Eligible to Request
Waiver in Future
FY2019
FY 2015
FY2018
FY2014
FY2017
FY2013
FY2016
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Certification of Obligation
• Divisions that have not completed OMEGA
reimbursement transactions for at least 85 percent
of FFY 2016 funds by September 30, 2017, must
complete the Certification of Obligation.
• Superintendent’s Email (fall)
• Certification of Obligation form must be signed
by the division superintendent.
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Certification of Obligation
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Identification of Excess Funds
Attachment A to Superintendent's Memo #107-17
Excess Title I funds are identified as Title I funds from a
school division that has:
• Not participated in the Title I school division program;
• Had its allocation reduced because it failed to meet
the maintenance of effort requirements;
• Carryover funds that exceed the 15 percent
limitation;
• Had funds recovered by the SEA after determining
that a school division has failed to spend Title I funds
in accordance with applicable law; or
• Excess funds for other reasons.
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Determination of Eligibility
Attachment A to Superintendent's Memo #107-17
To be eligible to receive reallocated funds, a school
division must:
• Meet general eligibility requirements to receive Title I
funds;
• Not have received a waiver within the past three
years from the Department to carry over more than
the allowable 15 percent limitation;
• Not have exceeded the 15 percent limitation to carry
over funds in the year requesting reallocated Title I
funds; and
• Have less than the maximum allowed carryover
funds from the previous year.
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Reallocation Timeline
The following guidelines apply:
A. By July 15, the SEA shall notify all divisions to expend
or encumber a minimum of 85 percent of their previous
fiscal year’s allocation no later than September 30, and
that they may only carry over an amount equal to or
less than 15 percent of their allocation. Spend down
reminders for the 2015 and 2016 grants were sent out
in May.
B. By October 30, the SEA shall notify each division
determined to have excess funds and the estimated
amount subject to reallocation.
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Reallocation Timeline
Attachment A to Superintendent's Memo #107-17
Guidelines, continued:
C. By November 30, the division will submit to the SEA
documentation, approved by the division
superintendent, demonstrating that any excess
funds (subject to reallocation) have been
encumbered for later expenditure and/or will be
relinquished.
D. By December 15, the SEA will determine the eligible
divisions in greatest need of funds and notify the
divisions.
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Reallocation Timeline
Attachment A to Superintendent's Memo #107-17
Guidelines, continued:
E. By January 31, the divisions will submit an amended
application prior to reallocation of funds.
F. By February 28, the SEA will post reallocated funds
available for expenditure to the Online Management
of Education Grant Awards (OMEGA) system.
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Title I, Part A, and
The Community Eligibility
Provision
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The Community Eligibility Program
• Universal meal program designed by the National
School Lunch Program
• Response to the Healthy, Hunger-Free Kids Act of
2010
• Implementation began in 2011-2012 with all states
participating by the 2014-2015 school year
• Goal of providing more free meals to low-income
students
• In each participating school, all students are
provided free breakfast and free lunch
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The Community Eligibility Program
To be eligible, a school, group of schools, or
division must have at least 40 percent of its
students meet the definition below:
Identified Students are defined as students approved as
eligible for free meals through means other than
individual household applications. Definition includes:
• Students who are directly certified for free meals on the
basis of their participation in the Supplemental Nutrition
Assistance Program (SNAP) and Temporary Assistance
for Needy Families (TANF).
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The Community Eligibility Program
Identified Students (continued)
• Homeless students on the liaison list, runaways,
migrant youth, Head Start, Even Start and foster
children approved by means other than a meal
application.
• Does NOT include students who are categorically
eligible based on information submitted on a free and
reduced price application, such as a SNAP or TANF
case number.
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Sources of Data Used to Determine
Low-income Count
Select all sources that you used. CEP or “Direct
Certification” data may be used regardless of
whether the division participates in the CEP program.
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Eligible Attendance Areas Table
Columns 7, 8, and 9 account for schools
participating in CEP and/or using direct
certification data for ranking purposes.
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The Multiplier
• Used to account for low-income families not
reflected/ captured in identified student count
• Determines percent of federal reimbursement for
meals
• Set by USDA at 1.6
• Multiplier remains constant for schools and
divisions throughout the four year CEP cycle
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Examples of the Multiplier
School A
40 percent of
students identified
40 X 1.6 = 64
64 percent of meals
reimbursed at federal
“Free” rate
36 percent of meals
reimbursed at federal
“Paid” rate
School B
62.5 percent of students
identified
62.5 X 1.6 = 100
100 percent of meals
reimbursed at federal
“Free” rate
NOTE: 100 percent is
maximum
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CEP impact on
Title I School Ranking
• The division must use a common poverty metric to
rank order schools and allocate Title I funds on an
equitable basis.
• If a division selects National School Lunch data as
its poverty measure and participates in CEP, the
CEP data will be used by the division for withindivision allocations.
• A division is not required to use CEP data for Title I
school ranking until a school is in its second year
implementing CEP (2016-2017 or later).
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Object Code 1000
1000 PERSONAL SERVICES - All compensation for the
direct labor of persons in the employment of the local
government. Salaries and wages paid to employees for
full- and part-time work, including overtime, shift
differential, and similar compensation. Also includes
payments for time not worked, including sick leave,
vacation, holidays, and other paid absences (jury duty,
military pay, etc.), which are earned during the
reporting period.
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Object Code 2000
2000 EMPLOYEE BENEFITS - Job related benefits
provided employees are part of their total
compensation. Fringe benefits include the
employer's portion of FICA, pensions, insurance
(life, health, disability income, etc.), and
employee allowances.
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Object Code 3000
3000 PURCHASED/CONTRACTUAL SERVICES – Services
acquired from outside sources (i.e. private vendors, public authorities).
Allowable payments would be to individuals or firms that are
independent contractors such as: SW PD, guest author/speaker
Online subscriptions and site licenses
Food purchases: working meals purchased through a vendor.
Reimbursement is capped at the per diem rate for the meal. Examples for
this object code include meals provided during day long professional
development sessions, or meals provided to support attendance at family
engagement activities. Food purchased from catering services and
restaurants such as Pizza Hut, Panera Bread, and Subway.
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Object Code 4000
4000 INTERNAL SERVICES - Charges from an Internal Service
Fund to other functions/activities/elements of the local government
for the use of intergovernmental services, such as data processing,
automotive/motor pool, central purchasing/central stores, print shop,
and risk management.
Food purchases: food purchased from the food services department
of a school division or subgrantee equivalent to support professional
development or family engagement events. For example, internal
expenses for school cafeterias to provide meals to support attendance
at family engagement activities.
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Object Code 5000
5000 OTHER CHARGES - Includes expenditures that support
the program, including utilities (maintenance and operation of
plant), staff/administrative/consultant travel, office phone
charges, training, conference registrations and fees, leases/rental,
indirect cost, and other.
Food purchases: travel reimbursement for meals is included in
this object code. Reimbursement is capped at the per diem rate for
the meal listed according to the state travel regulations.
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Object Code 6000
6000 MATERIALS AND SUPPLIES - Includes articles and
commodities that are consumed or materially altered when used
and minor equipment that is not capitalized. This includes any
equipment purchased under $5,000, unless the LEA has set a
lower capitalization threshold. Therefore, computer equipment
under $5,000 would be reported in “materials and supplies.”
Food purchases: food purchased from a grocery store or its
equivalent for snacks or breaks is included in this object code.
Examples include bottled water, granola bars, cookies, and fruit
purchased from a store such as WalMart, Food Lion, Costco, etc.
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Object Code 8000
8000 Capital Outlay - All capital outlay expenditures over $5,000 per unit
must be approved in advance by the Virginia Department of Education. If the
school division has established a threshold of a lesser amount, items equal to
that amount or greater must also receive prior approval by the Virginia
Department of Education. Non-consumable items must be listed in the
application. Equipment quantities must be specified. The following items must
be specified below for ESEA programs, if applicable: parental involvement,
professional development for priority or focus schools, and division-level
allowable set-asides.
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Questions
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Contact Information
Title I, Part A
Dr. Lynn Sodat
Shyla Vesitis
Director, PAA
Lynn. [email protected]
Phone: (804) 225-2870
Title I Coordinator
[email protected]
Phone: (804) 225-3711
Tiffany Frierson
Louise Sutton
Title I Specialist
Title I/III Specialist
[email protected]
Phone: (804) 225-2901
[email protected]
Phone: (804) 225-2907