September 19, 2012
BULLETIN NO. 054-12
( ) Action Required
(X) Informational
TITLE I/LAP & CONSOLIDATED PROGRAM REVIEW
K–12 FINANCIAL RESOURCES
TO:
Educational Service District Superintendents
School District Superintendents
Assistant Superintendents for Business and/or Business Managers
School District Title I, Part A Program Directors
School District Special Education Directors
FROM:
Randy I. Dorn, State Superintendent of Public Instruction
RE:
Combining Funds in Title I, Part A Schoolwide Programs
CONTACT: Gayle Pauley, Director, Title I/LAP and Consolidated Program Review
(360) 725-6100; Agency TTY: (360) 664-3631
Email: [email protected]
PURPOSE
This bulletin provides guidance to school districts choosing to combine funds in a Title I,
Part A schoolwide program. Schoolwide programs are optional and are intended to
provide flexibility for serving students in eligible school buildings by combining certain
federal, state, and local revenues to more effectively address the needs of all
academically struggling students.
School districts may only operate schoolwide programs in Title I, Part A buildings that
have been identified in the district Title I, Part A iGrants application. Schools in which at
least 40 percent of the students are from low income families may combine Title I,
Part A with certain other federal, state, and local funds in order to improve academic
performance of all students, particularly the lowest achieving students [Elementary and
Secondary Education Act (ESEA) 1114(a)(1)].
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Prior to implementing a schoolwide program, buildings must have engaged in a thorough
planning process, conducted a comprehensive needs assessment of the entire school,
and used data to develop a comprehensive plan containing the ten required components
of a schoolwide plan [ESEA 1114(b); 34 CFR 200.27]. This process generally takes at
least one year.
RESOURCES
 The United States Department of Education (ED) provides guidance on
schoolwide programs in Section 1114 of the 2001 reauthorization of ESEA that is
available at: http://www2.ed.gov/policy/elsec/leg/esea02/pg2.html#sec1114.
 Final regulations found in Sections 200.26–200.29 of Title 34 of the Code of
Federal Regulations—Title I-Improving the Academic Achievement of the
Disadvantaged; Final Rule, December 2, 2002, are available at:
http://www.access.gpo.gov/nara/cfr/waisidx_04/34cfr200_04.html.
 Schoolwide Non-Regulatory Guidance (March 2006) is available at:
http://www.ed.gov/policy/elsec/guid/designingswpguid.doc.
 Title I, Part A Fiscal Issues Non-Regulatory Guidance, revised February 2008, is
available at: http://www.ed.gov/programs/titleiparta/fiscalguid.pdf.
 Designing Schoolwide Programs Non-Regulatory Guidance, May 8, 2006, is
available at: http://www2.ed.gov/policy/elsec/guid/edpicks.jhtml?src=ln.
OVERVIEW
A schoolwide program is a comprehensive reform strategy designed to upgrade the
entire educational program in a Title I, Part A school. The schoolwide program’s primary
goal is to ensure that all students, particularly those who are low achieving, demonstrate
proficient and advanced levels of achievement on the state’s annual measurable
objectives. This schoolwide reform strategy requires that a school:
 Conduct a comprehensive needs assessment.
 Identify and commit to specific goals and strategies that address those needs.
 Create a comprehensive plan.
 Conduct an annual review of the effectiveness of the schoolwide program and
revise the plan as necessary.
Adopting this strategy should result in an ongoing, comprehensive plan for school
improvement that is owned by the entire school community and tailored to its unique
needs. (Source: Designing Schoolwide Programs Non-Regulatory Guidance, May 2006.)
Schoolwide programs are authorized under ESEA to better serve all children in a
building by intentionally coordinating instructional programs and combining financial
resources rather than operating categorical programs as separate services.
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September 19, 2012
A schoolwide program:
 Is built on schoolwide reform strategies rather than separate, add-on
services. A schoolwide program permits a school to use Title I, Part A funds and
a number of other federal ED programs along with local and certain state funding
sources to upgrade the entire educational program of the school in order to raise
academic achievement for all students, particularly those who are lowest
achieving [ESEA 1114(a)(1)].

Provides flexibility in spending Title I, Part A funds. Schoolwide program
schools have great latitude in determining how to spend their Title I, Part A funds.
Schoolwide program staff are not required to identify particular children as
eligible for services, but must demonstrate that Title I, Part A funds are paying for
supplemental services that would otherwise not be provided. If this cannot be
demonstrated, Title I, Part A funds must be separately tracked [ESEA
1114(a)(2)].

Permits flexibility to combine other federal funds in support of the
schoolwide program. In addition to Title I, Part A funds, schoolwide programs
may include funds from most other federal ED programs (see Federal Revenues
section below). A schoolwide program that includes other federal education
programs does not have to conform to the specific statutory or regulatory
requirements for each separate program so long as the intent and purposes of
those programs are met in the schoolwide plan [ESEA 1114(a)(3)(A)-(B)].
A school that chooses to use funds to support Title I, Part A schoolwide
programs is not exempt from federal requirements relating to:
1. Health, safety, civil rights, and gender equity.
2. Student and parental participation and involvement.
3. Services to private school children.
4. Maintenance of effort.
5. Comparability of services.
6. Uses of federal funds to supplement and not supplant.

Focuses on results. Flexibility in the use of funds is tied to increased academic
achievement by all children (with particular emphasis on those who are most atrisk of not meeting the state’s academic achievement standards) in a school
building and not just to individual, targeted student groups.
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
Meets supplement not supplant requirement. In a schoolwide program, Title I,
Part A funds and other federal education program funds may be used only to
supplement the total amount of funds that would, in the absence of federal funds,
be made available from non-federal sources for that school, including funds
needed to provide services that are required by law for children with disabilities
and children with limited English proficiency.
It is the district’s responsibility to ensure the schoolwide program school receives
all the state and local funds it would receive if it were not a schoolwide program
and that state and local funds are distributed fairly and equitably to all schools in
the district, including schoolwide program schools [ESEA 1114(a)(2)(B)].
REVENUES FOR SCHOOLWIDE PROGRAMS
Federal Revenues
The Secretary of Education authorizes a schoolwide program building to use funds or
services that the school receives from certain federal education programs administered
by the Secretary to upgrade the school’s entire educational program as long as the
intent and purposes of each program are met.
Federal programs that may be consolidated in schoolwide programs include:
 Title I, Part A—Improving the Academic Achievement of the Disadvantaged.
 Title I, Part B—Even Start Family Literacy Programs. Note: Congress is no
longer funding this program. Remaining carryover may be used.
 Title I, Part C—Education of Migratory Children (funds provided under ESEA,
Title I, Part C to state agencies for services to migratory children). Title I, Part C,
Migrant Education funds may be combined in a schoolwide program only if the
district first documents that it has met all identified student needs that result from
a migratory lifestyle. In addition, any inclusion of Title I, Part C funding is
contingent upon approval by the Office of Superintendent of Public Instruction’s
(OSPI’s) Migrant Education office.
 Title I, Part D—Prevention and Intervention Programs for Children and Youth
who are Neglected, Delinquent, or At-Risk (programs under ESEA, Title I, Part D,
Subpart 1 to state agencies for services to children in state institutions for
neglected or delinquent children, unless funds are used for transition services
involving a schoolwide program school).
 Title II, Part A—Highly Qualified Teachers and Principals.
 Title III—Language Instruction for Limited English Proficient and Immigrant
Students.
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Title VII, Part A—Indian, Native Hawaiian, and Alaska Native (funds provided
under ESEA, Title VII, Part A to local school districts for Indian Education
services). Title VII, Part A, Indian Education funds may be combined in a
schoolwide program as long as they are used to assist Indian students in
meeting state academic standards and are approved by an appropriately
constituted committee.
Title VIII—Impact Aid.
Individuals with Disabilities Education Act (IDEA), Part B (formula or discretionary
grant programs under IDEA and funds provided for eligible children with
disabilities under Section 8003(d) of the ESEA).
Exception: As of June 4, 1997, Public Law 105-17 authorized IDEA-B funds to
be combined in a Title I, Part A schoolwide campus budget but restricted the
amount to the proportion of funding for students with disabilities attending the
schoolwide campus. See OSPI Bulletin No. 049-11.
Title X—Stewart B. McKinney Homeless Assistance Act: Education for Homeless
Children and Youth.
Carl D. Perkins Career and Technical Education Improvement Act.
School Improvement Grants under ESEA Section 1003(g) and ARRA. (Tier 1
schools must operate schoolwide programs.)
Exclusions
The ESEA schoolwide program authority to combine federal revenues is generally not
allowed for the following programs:
1. Funds provided under the School Facilities Infrastructure Improvement Act to
ensure the health and safety of students through the repair, renovation,
alteration, and construction of school facilities.
2. Programs under the Adult Education Act or ESEA, Title IX, Part A, Subpart 3
(Adult Indians) unless adult literacy services are integrated within a schoolwide
program plan. Adult education funds could be included, for example, if they
provide adult literacy as part of a family literacy activity under a schoolwide
program plan.
3. The ED funds awarded to institutions of higher education, unless those funds
support elementary or secondary schools (e.g., the School, College, and
University Partnerships Program).
4. Federal programs that are not administered by the Secretary, such as the
National School Lunch Program and Head Start.
Note: The authority to use funds under other programs in schoolwide program schools
does not apply to funds that are allocated by formula to non-schoolwide program
schools in a district. This is not an authority to redistribute funds among schools. Any
redistribution of funds would have to be consistent with the authorizing statute.
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State Funds
State basic education allocation and state levy equalization revenue (local effort
assistance) may be included in a schoolwide program. In addition, Washington State
Session Laws allow districts to coordinate the use of state Learning Assistance Program
(LAP) revenue as long as it can be shown services are provided only to students who
have not met annual measurable objectives or are at-risk of not meeting state/local
graduation requirements. Other state funds, such as state Transitional Bilingual
Instructional Program, Highly Capable Programs, Early Childhood Education and
Assistance Program, and state special education, may not be combined in a
schoolwide program.
Local Funds
Local levy revenue may be combined in schoolwide programs. If local levy dollars are
combined in a schoolwide program, the expenditures should be assigned to Program
01-Basic Education.
FISCAL OPTIONS
Separate fiscal accounting records by program identifying specific activities supported
by each funding source combined in a schoolwide program are allowable, but are not
required [ESEA 1114(a)(3)(C)]. However, schoolwide program schools must identify
each program consolidated and the amount combined [ESEA 1114(b)(2)(A)(iii)]. In
addition, they must keep records to document that the intent and purpose of each
program combined under the schoolwide program have been met [ESEA 1114(a)(3)(C)].
Good communication between business managers and schoolwide program staff is
important in the application, budgeting, reporting, and accounting process for a
schoolwide program. Although combined funds lose their identity when combined
in a schoolwide program, expenditures and revenues must address the
population of students for whom the funds were provided. For F-195 budgeting, S275 personnel reporting, F-196 annual financial reporting purposes, and the Schedule of
Expenditures of Federal Awards, districts must distribute schoolwide program costs to
the individual programs that are included in the schoolwide program.
The district may use a subsidiary account or coding in accounting for schoolwide
building revenues and expenditures for internal tracking. Such accounts or coding may
be by program, subprogram, location, or combination using user-defined fields. Districtlevel budgeting and financial reporting to OSPI will not change.
The district may use any reasonable method to demonstrate how the funds in a
schoolwide program have been expended.
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Three options are illustrated below. State, local, and federal funds combined in a
schoolwide program lose their specific program identity at the building and may be used
for any costs of the schoolwide program (with some exceptions for LAP). Districts must
show the amount of revenue received from each federal, state, and local education
program for each year the funds were allocated and combined into a schoolwide
program.
Districts are also required to show how the funds were expended pursuant to a
schoolwide program to satisfy federal reporting requirements, cash management, and
availability of funds. Districts may want to consider the use of a holding or clearing
account at the district level. Such an account, comprised of the revenues combined into
the schoolwide program, would be zeroed out by year-end. Journal vouchers would be
needed monthly, quarterly, and/or annually to accomplish this.
For example, if basic education money is included in a schoolwide program, initial
charges could be made to basic education and journal vouchered to the portion
pertaining to federal programs. In developing the school district budget, the business
office may choose to make expenditure allocations in proportion to revenue sources.
Option 1—Distribution of Expenditures Based on Revenues
A building has a schoolwide program with a total of $1,000,000 in revenues from
programs as follows:
Program
Basic Education Allocation
Title I, Part A—Improving the Academic Achievement of
the Disadvantaged
Title II, Part A—Highly Qualified Teachers and Principals
IDEA, Part B—Special Education, see note below
Carl D. Perkins Career and Technical Education
Improvement Act
Total
Amount
Percent
$500,000
50%
$250,000
25%
$100,000
$50,000
$100,000
10%
5%
10%
$1,000,000
100%
Under this option, the district may allocate all building schoolwide program expenditures
for the included revenues in the same proportions (percentages) as are consistent with
the building’s budgeted schoolwide revenues. Expenditures are allowable without
regard to individual program allowability as long as they are incurred in the conduct of
the schoolwide program.
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Note: The formula for calculating the amount of IDEA, Part B is to divide the amount the
district receives for Part B by the number of eligible students in the district and then
multiply that per student allocation by the number of eligible students participating in the
schoolwide program consistent with Title I, Part A.
For additional guidance regarding this formula, see OSPI Bulletin No. 049-11, Use of
Funds: Individuals With Disabilities Education Improvement Act (IDEA 2004), Part B.
Option 2—Predistribution of Labor
Salaries and benefits typically constitute approximately 85 percent of a school building’s
expenditures.
In order to facilitate both the recording and reporting of expenditures across individual
fund sources that have been combined under a schoolwide plan, the district could elect
to code/charge each schoolwide program employee’s salary and benefits in the same
proportions as budgeted revenues within a schoolwide building.
Allowable non-employee schoolwide program costs could be allocated to each
combined fund source by similarly coding such transactions proportionally across these
fund sources. In lieu of using proportional, multiple fund source codes for non-employee
costs, the district may use another reasonable allocation basis, including the direct
charging of individual transactions to particular revenues.
Using the fund source combination in Option 1, each schoolwide program employee’s
payroll would be coded in the human resource/payroll distribution systems as follows:
Program
Basic Education Allocation
Title I, Part A—Improving the Academic
Achievement of the Disadvantaged
Title II, Part A—Highly Qualified Teachers and
Principals
IDEA, Part B—Special Education
Carl D. Perkins Career and Technical Education
Improvement Act
Total
Program
Code
01
51
Revenue
Code
10%
52
6152
5%
10%
24
38
6124
6138
Percent
50%
25%
6151
100%
Option 3—Sequence Charging
Using the fund source combination in Option 1, schoolwide program expenditures could
be coded as follows:
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
All employees and non-employee schoolwide costs could be charged 100
percent to Title I, Part A until these funds are spent in their entirety or until the
maximum carryover amount is all that remains unexpended. This same
methodology would be similarly applied to each of the other combined fund
sources during the remainder of the fiscal year.
Employees could be directly charged to particular fund sources so as to expend all
combined fund sources. Carryover and any limitations to it should be considered. For
example:
Individual
Employee Percent
A, B, C, D 100%
E, F, G, H 100%
J, K
L
M, N, P*
M, N, P*
100%
100%
33%
67%
Program
Charged
Basic Education
Title I, Part A—Improving the Academic Achievement of
the Disadvantaged
Title II, Part A—Highly Qualified Teachers and Principals
IDEA, Part B—Special Education
Basic Education
Carl D. Perkins Career and Technical Education
Improvement Act
*Note: Staff paid out of particular program funds need not work in that same program in
order to meet the specific intent and purposes described in the schoolwide plan. (See S275 Personnel Reporting.)
Materials, supplies, and operating costs (MSOC) could be directly charged to particular
fund sources without regard to federal allowability requirements.
S-275 Personnel Reporting
Staff employed in schoolwide programs are reported with assignments in the various
programs included in the schoolwide program. A separate program assignment code
does not exist for schoolwide programs. The assignments may be made by assigning
individual staff among programs or by split-coding staff to achieve the necessary
distribution. Staff paid out of particular program funds need not work in that same
program in order to meet the specific intent and purposes described in the schoolwide
plan.
The S-275 report should reflect an estimate of staff as of October 1, which will allow the
district to distribute schoolwide costs in appropriate proportions as based on the
contributing revenue sources.
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Maintenance of Effort
The schoolwide program expenditures allocated to a program are included in the fiscal
maintenance of effort calculation and test for the program.
Districts operating schoolwide programs should ensure that the appropriate expenditure
levels are maintained and that the district is not in jeopardy of failing maintenance of
effort under the federal cross-cutting, Special Education, or Indian Education tests
[ESEA 9521(c)].
Time and Effort
Schoolwide buildings have unique time distribution requirements. A schoolwide program
is considered to be a single cost objective. If a school district has implemented a
schoolwide program in any of its buildings, time and effort documentation is required. A
semi-annual certification may be used for those employees who work solely on
programs included in the schoolwide program and who are charged only to revenue
sources that have been combined in a schoolwide plan. Semi-annual certifications must
be completed at least twice a year, reflect actual time, and be signed by either the
employee or a supervisor having first-hand knowledge of the employee’s work activities.
This exception only applies to a building in which a schoolwide plan has been
incorporated.
Monthly time and effort records are required for any staff funded by both schoolwide
and non-schoolwide revenue sources. District administrative officers are not eligible to
be included under the schoolwide single cost objective. See OSPI Bulletin No. 051-11
for additional guidance on time and effort reporting at:
http://www.k12.wa.us/BulletinsMemos/bulletins2011.aspx.
Federal Carryover
ED programs generally include a statutory maximum limit on the amount of unobligated
subrecipient award funding that may be carried forward from the initial award period to
the subsequent program and/or fiscal year. For example, Title I, Part A prohibits a
district from carrying over more than 15 percent of its allocation from the initial award
period to a subsequent period. However, there may be specific carryover circumstances
under which the maximum carryover limit for a federal program can be waived. OSPI’s
Title I, Part A office should be contacted to determine waiver availability.
A district can calculate its maximum carryover amount for a program by applying the
statutory percentage cap for that federal education program to the total fiscal year
program allocation for the district.
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Any district that has combined all or part of its capped federal education program funds
in schoolwide program(s) must base the carryover calculation on both targeted
assistance funding and the actual amount of program funds combined in schoolwides.
The sum of these various allocations must equal the district's total fiscal year award for
any affected federal program.
State Carryover
There are also state funds that allow for a capped percentage carryover at the close of
the fiscal year. However, the carryover of such unobligated state funds is not subject to
submission (to OSPI) of any formal request for expenditure authorization. Otherwise,
the calculation methodology for the amount of state funds to be carried over is the same
as described under “Federal Carryover” (above) when any portion of those funds has
been combined in a schoolwide program. OSPI program directors should be contacted
to determine if waivers are available.
ASSISTANCE
For questions regarding schoolwide programs, contact Gayle Pauley, Director,
Title I/LAP and Consolidated Program Review, at (360) 725-6100 or email
[email protected]. For assistance with accounting, maintenance of effort, or
other fiscal issues, contact Jennifer Carrougher, Director, Audit Resolutions/iGrants at
(360) 725-6288 or email [email protected]. The agency TTY number is
(360) 664-3631.
This bulletin is also available on the OSPI website at
http://www.k12.wa.us/BulletinsMemos/bulletins2012.aspx.
K–12 EDUCATION
K–12 FINANCIAL RESOURCES
Alan Burke, Ed.D.
Deputy Superintendent
JoLynn Berge
Chief Financial Officer (Interim)
SPECIAL PROGRAMS AND
FEDERAL ACCOUNTABILITY
Jennifer Carrougher, Director
Audit Resolution/iGrants
Bob Harmon
Assistant Superintendent
Gayle Pauley, Director
Title I/LAP and CPR
RD:ps:jc
OSPI provides equal access to all programs and services without discrimination based on sex, race, creed, religion, color, national
origin, age, honorably discharged veteran or military status, sexual orientation including gender expression or identity, the
presence of any sensory, mental, or physical disability, or the use of a trained dog guide or service animal by a person with a
disability. Questions and complaints of alleged discrimination should be directed to the Equity and Civil Rights Director at
(360) 725-6162 or P.O. Box 47200 Olympia, WA 98504-7200.