The American Recovery and Reinvestment Act (ARRA) of 2009 Title I Part A and IDEA - PowerPoint PPT Presentation

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The American Recovery and Reinvestment Act (ARRA) of 2009 Title I Part A and IDEA


The American Recovery and Reinvestment Act (ARRA) of 2009. Title I Part A and IDEA ... In fiscal year (FY) 2009, the LEA spent a total of $100,000 local funds ... – PowerPoint PPT presentation

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Title: The American Recovery and Reinvestment Act (ARRA) of 2009 Title I Part A and IDEA

The American Recovery and Reinvestment Act (ARRA)
of 2009 Title I Part A and IDEA
South Dakota Department of EducationGrants
Guiding Principles
Balance Speed and Effectiveness
  • Balance speed and stimulus with careful planning
    and effective reforms
  • LEAs should use funds expeditiously but sensibly

Short-term Investments that Produce Lasting
  • Maximize short-term investments with lasting
  • Minimize unsustainable ongoing commitments
  • Avoid the funding Cliff

Accountability and Transparency
  • All ARRA funds must be tracked separately
  • Quarterly reports on both financial information
    and how funds are being used
  • Beginning July 1, 2009
  • Estimated number of jobs created or saved
  • US ED will issue specific guidance for preparing
    and submitting this recordkeeping and reporting
    information governing ARRA funds

Reporting ARRA Fund Use
  • The ARRA contains very stringent reporting
    requirements and requires that detailed
    information on the uses of funds by available

Reporting ARRA Fund Use
  • Separately from regular program
  • New CFDA Numbers for each program
  • Maintain accurate documentation of all ARRA
    expenditures and ensure
  • Accurate
  • Complete
  • Reliable

Fund distribution
  • Reimbursement basis as expenditures are reported
    to the State
  • Plan to use eGrant reimbursement system for both
    Title I and IDEA ARRA funds

Potential Uses of ARRA Funds
  • Will the proposed use of ARRA funds
  • Drive results for students?
  • Increase capacity?
  • Accelerate reform?
  • Avoid the cliff and improve productivity?
  • Track results?

Availability of ARRA Funds
  • Title I, Part A in absence of a waiver, 85
    until Sept 30, 2010 any remaining by Sept 30,
  • IDEA, Part B by September 30, 2011

Funding Periods Dates
  • ARRA Allocations are considered part of the SY
    2009-10 Allocation
  • But, costs are allowable beginning February 17,
  • Regular Grant Period July 1, 2009 to September
    30, 2010
  • Carryover Period October 1, 2010 to September 30,

Title I Part A Amounts
  • Regular Allocation 43,747,031
  • ARRA Allocation 34,650,000
  • Total SY 09-10 78,397,031

IDEA Part B 611
  • Regular Allocation 32,664,950
  • ARRA Allocation 31,630,863
  • Total SY 09-10 64,295,813

IDEA Part B 619 Preschool
  • Regular Allocation 1,442,067
  • ARRA Allocation 1,520,277
  • Total SY 09-10 2,962,344

Accepting Federal Grants Funds
  • The LEA accepts the legal responsibility for
    fulfilling all the program requirements.
  • The LEA is accountable for all federal program

Program requirements of ARRA funds
  • All provisions that currently apply to IDEA funds
    apply to the IDEA ARRA funds.
  • All applicable requirements that currently apply
    to the use of Title I, Part A apply to the Title
    I ARRA funds

Fiscal Requirements
  • Supplement, Not Supplant
  • Title I
  • Comparability
  • Title I
  • Maintenance of Effort Requirements Different
    Methods for Each Program
  • Title I
  • IDEA

Supplement Not Supplant Title I
  • Cannot use federal funds to pay for services,
    staff, programs, or materials that would
    otherwise be paid with state or local funds
  • Designed to ensure federal funds pay for
    something extra

Supplanting Presumptions
  • Presume supplanting in 3 situations
  • 1. Used federal funds to provide services the
    district is required to make available under
    other federal, state or local laws

Presumptions (cont.)
  • 2. Used federal funds to provide services the
    district provided with state or local funds in
    the prior year

Presumptions (cont.)
  • 3. Used Title I, Part A funds to provide the same
    services to Title I students that the LEA or SEA
    provides with state or local funds to
    nonparticipating students

Rebutting the Presumption
  • Presumption may be rebutted
  • If SEA or LEA demonstrates it would not have
    provided the services with state or local funds
    if the federal funds were not available

Rebutting the Presumption
  • To rebut presumption show
  • Fiscal and programmatic documentation to confirm
    that, in the absence of federal funds, would have
    eliminated staff/services in question
  • School Board action
  • Budget histories and information
  • Planning documents

Title I Exception to Supplement not Supplant
  • The LEA used State or Local funds to conduct
    supplemental Title I like activities.

Title I Exception to Supplement not Supplant
  • The activity previously paid with State or Local
    funds was allowable under Title I, Part A
  • Consistent with all Title I fiscal and
    programmatic requirements.
  • Meets the academic needs of Title I students

  • LEAs allocation was less than Title I teachers
    salary benefits
  • The LEA contributed the difference
  • Teachers activities were all allowable under
    Title I Part A
  • The LEA could use Title I ARRA funds to replace
    the State Local contribution to the teachers
    salary benefits.

Supplanting in Title I Schoolwide Programs
  • Presumptions do not necessarily apply to
    schoolwide programs however,
  • The LEA must provide the school with the same
    amount of state and local funds as it would have
    received had it not received Title I funds.
  • Do not shift State Local funds away from Title
    I schoolwide program to another school

Comparability Title I
  • Ensures that services provided with state and
    local funds in Title I schools are comparable to
    those provided in non-Title I Schools
  • In LEAs with all Title I schools ensures that
    services are substantially comparable between all
  • Annual Requirement for affected LEAs

Comparability Title I
  • Compare schools with similar grade spans
  • Required if more than one school per grade span
  • Excludes schools with less than 100 students
  • State supplies forms guidance to affected LEAs.

  • Each LEA that receives Title I ARRA funds must
    file with the SEA a school by school listing of
    its per-pupil educational expenditures from State
    and Local sources during the 2008-09 school year
    no later than December 1, 2009.

School by School Expenditures
  • Typical LEA has at least 3 schools
  • Elementary school
  • Middle school
  • High school
  • Waiting for more guidance from US ED

Maintenance of Effort - Title I
  • Requires that an LEAs expenditures from state
    and local funding remain relatively constant from
    year to year. (at least 90).
  • Either on an aggregate or per pupil basis
  • State must reduce a districts allocations in
    proportion to the they failed to meet the MOE

Title I Set asides
  • 1 for parental involvement if Title I
    allocation over 500,000
  • An amount up to 20 of the Districts allocation
    if any of its schools are in improvement
  • supplemental educational services
  • public school choice.

Districts must sub-allocate Title I funds to
Title I schools
  • Budget and Track Title I sub-allocations
    expenditures by participating school
  • Must follow the allocation procedures set out in
    the Consolidated Application
  • Ensure actual per low income student amounts are
    in compliance with rank order of schools.

Equitable Services for Private School Students
and Teachers
  • Districts must offer equitable services to
    private school students and teachers from ARRA
  • The District must control funds and show the
    equitable amounts or services were provided

  • IDEA Maintenance of Effort (MOE) Requirement

IDEA Supplement not Supplant
  • If the LEA meets its MOE requirements, it is
    considered to have met the supplement, not
    supplant requirement.
  • Individual activities are not looked at.

LEA MOE requirement
  • With certain exceptions, Part B funds must not be
    used by an LEA to reduce the level of
    expenditures for the education of children with
    disabilities made by the LEA from local funds
    below the level of those expenditures for the
    preceding year

LEA MOE (cont)
  • LEA application standard
  • With certain exceptions, an LEA budgets for
    the education of children with disabilities, at
    least the same total or per capita amount of
  • local funds only or
  • State and local funds
  • as it spent from those same sources in the
    most recent prior year for which the information
    is available

LEA MOE (cont)
  • Audit standard
  • Compliance with the MOE requirement, after a
    fiscal year has ended, is based on the actual
    local or state and local expenditures for special
    education and related services in the audited
    year and the prior year

LEA MOE (cont)
  • Dont include as state or local funds any federal
    funds for which the SEA or an LEA is required to
    account to the federal government

LEA MOE Example 1
  • In fiscal year (FY) 2009, the LEA spent a total
    of 100,000 local funds and 900,000 state and
    local funds on the education of children with
  • For FY 2010, the LEA must spend at least 100,000
    of local funds OR 900,000 of combined state and
    local funds for the education of children with

LEA MOE Example 1(cont)
  • If the LEA spent 97,000 of local funds and
    905,000 of state and local funds on the
    education of children with disabilities, it would
    meet its MOE level
  • If the LEAs calculation of 905,000 of state and
    local funds, included 64,000 of ESEA Title 1
    funds that it used for services to children with
    disabilities, it would not have met its MOE level

LEA MOE Example 2
  • In FY 2009, Harrison LEA spent a total of
    100,000 local funds and 900,000 state and local
    funds on the education of children with
  • In FY 2009, Harrison LEA had 150 children with
  • 100,000/150 667
  • 900,000/150 6,000

LEA MOE Example 2 (cont)
  • FY 2010 the number of children with disabilities
    drops to 130
  • For FY 2010, Harrison LEA must spend at least the
    following amounts on the education of children
    with disabilities
  • 667 per child local funds (86,710) OR
  • 6000 per child state and local funds (780,000)

LEA MOEExample 2 (cont)
  • If in FY 2010 Harrison LEA spent 80,000 in local
    funds and 800,000 in state and local funds on
    the education of children with disabilities, it
    would meet it MOE level based on a per capita

LEA MOE Exceptions
  • An LEA may reduce the level of its expenditures
    below the comparison year if the reduction is the
    result of
  • Voluntary departure, or departure for just
    cause, of special education or related
    services personnel
  • Decrease in enrollment of children with

LEA MOE Exceptions (cont)
  • Termination of an exceptionally costly obligation
    of the agency to a particular child with a
    disability because the child
  • Has left the jurisdiction of the LEA
  • Has reached the age at which the obligation to
    provide a free appropriate public education
    (FAPE) to the child is terminated, or
  • No longer needs special education

LEA MOE Exceptions (cont)
  • Termination of costly expenditures for long-term
    purchases, such as acquisition of equipment or
    construction of school facilities

LEA MOE Common Problem
  • The LEA does not fully spend the amount of local,
    or state and local, funds it was required to
    budget in its application at the beginning of the
    year to demonstrate to the State that the LEA
    would meet the MOE requirements.

Possible Optional MOE Flexibility 50 rule
  • Available under the IDEA, but,
  • Currently not allowed by State law.
  • State plans to a introduce bill in the
    legislature in January 2010 to revise State law.
  • Emergency provision to implement upon the
    governors signature.

LEA MOE Optional Adjustment 50 Rule
  • For any fiscal year that an LEAs allocation
    exceeds the amount of its prior years
    allocation, the LEA may reduce its expenditure of
    local, or state and local funds by not more than
    50 of the increase in federal funds
  • The LEA must use an amount of local funds equal
    to the reduction for activities that could be
    supported with funds under the ESEA

Optional MOE 50 Rule Continued
  • The LEA must use the freed up local or State
    funds to carry out activities that could be
    supported with ESEA funds.
  • The LEA must track and report to the SEA on the
    use of the freed up funds.
  • Must use during current fiscal year
  • Does not carryover into next fiscal year.
  • This will reduce the MOE for next year.

Optional MOE 50 Rule Continued
  • The LEA must spend the freed up local funding by
    June 30, 2010 or it will not make MOE in SY
  • This flexibility must be taken in the fiscal year
    the excess IDEA allocation became available.

LEA MOE 50 Rule Exceptions
  • The LEA is prohibited from reducing the level of
    expenditures for that fiscal year if an SEA
    determines that
  • an LEA is unable to establish and maintain FAPE
  • the SEA has identified the LEA for state
    enforcement through local determinations.

LEA MOE Adjustment Example
  • In year 1, Taft LEAs allocation is 900,000.
  • For year 2, Tafts allocation is 1,100,000
  • Increase 200,000
  • Maximum Amount of MOE reduction 100,000 for
    use in ESEA activities

Early Intervening Services (EIS)
  • An LEA may use up to 15 of its annual
    allocation, less any amount by which it has
    reduced its MOE level, to develop and implement
    coordinated, EIS for children in K -12 who are
    not currently identified as needing special
    education but who need additional academic and
    behavioral support to succeed in a general
    education environment

EIS the 50 Rule on MOE Adjustments
  • The amount of funds expended by an LEA for early
    intervening services counts toward the maximum
    amount of expenditures by which the LEA may
    reduce local effort

EIS the 50 Rule on MOE Adjustments - Continued
  • LEAs use of Part B funds for early intervening
    services zeros out the ability for the LEA to
    take an MOE reduction.
  • Basically the LEAs early intervening service
    amount equals or exceeds the amount of the 50
    MOE reduction

EIS/MOE Example 1
  • Prior Years Allocation -- 900,000
  • Current Years
  • Allocation -- 1,000,000
  • Increase 100,000
  • Maximum MOE
  • Reduction -- 50,000
  • Maximum for EIS -- 150,000

EIS/MOE Example 2
  • Prior Years Allocation 1,000,000
  • Current Years
  • Allocation 2,000,000
  • Increase 1,000,000
  • Maximum MOE Reduction 500,000
  • Maximum for EIS 300,000

EIS/MOE Example 2 Continued
  • If MOE Reduction is 500,000
  • Then max EIS is 0
  • If the EIS is 300,000
  • Then MOE reduction max is 200,000

EIS/MOE Example 3
  • Prior Years Allocation 1,000,000
  • Current Years
  • Allocation 1,000,000
  • Increase 0
  • Maximum MOE Reduction 0
  • Maximum for EIS 150,000

Planning Budgeting
  • Fiscal staff need to work with program
    coordinators in preparing budgets.
  • Ensure Fiscal Requirements are met
  • Ensure required program set asides are included
    in budgets.
  • Ensure equitable share budgeted for private

Planning Budgeting (continued)
  • Ensure costs are appropriately categorized
  • Guard against exceeding amount available or under
    utilizing the full amount
  • Ensure costs are allowable

Follow Approved Budgets
  • Districts expenditure should follow the approved
  • Just budgeting required set asides doesnt
    fulfill responsibility
  • Actual expenditures will be looked at to ensure

Determining Allowable Costs for Federal Programs
  • Analyze costs to determine if they are allowable
  • Develop a formal process to ensure costs are

Allowable Costs Questions
  • Consistent with federal cost principles?
  • Allowable under the grant program?
  • Consistent with the approved application?
  • Consistent with program specific fiscal rules?
  • Consistent with the needs of the program

Basic A-87 Guidelines
  • All Costs Must Be
  • Necessary
  • Reasonable
  • Allocable
  • Authorized or not prohibited under state and
    local law

Reasonable Costs
  • A-87 Definition - A cost is reasonable if it does
    not exceed that which would be incurred by a
    prudent person under the circumstances prevailing
    at the time the decision is made to incur the

Questions - Reasonable
  • Is the expense targeted to a legitimate program
  • Do we have the capacity to use what we are
  • Can we prove that we paid a fair rate?
  • Would I be comfortable defending this purchase?

  • Must be necessary for the performance or
    administration of the grant
  • Questioning necessary
  • Do we really need this?
  • Do we already have existing resources sufficient
    for this purpose?

  • Can only charge in proportion to the value
    received by the program
  • Example The district purchases a computer to
    use 50 in the Title I program and 50 in a state
    program can only charge half the cost to Title

Questions - Allocable
  • Can I prove the program benefited?
  • Can I prove other programs are not the primarily
  • Ensure only authorized use
  • Incidental benefit is okay

Other Basic Guidelines
  • Legal under state and local law
  • If not legal under state law, cannot pay with
    federal funds
  • Conform with federal law grant terms

Adequate Documentation
  • Lack of Documentation is 1 Audit Finding
  • Document the following
  • Amount of funds under grant
  • How the funds are used
  • Total cost of the project
  • Share of costs provided by other sources

Adequate Documentation
  • Records that show compliance
  • Records that show performance
  • Other records to facilitate an effective audit
  • Keep at least 3 years after the final project
    completion report is submitted
  • Longer if unresolved audit issues

Program Implementation
  • Monitor Expenditures to Budget
  • Ensure Set-aside activities are completed
  • Submit Timely reimbursement requests
  • Submit Timely budget revisions or amendments

  • Submit Project Completion Report
  • Due within 90 days after grant period
  • Ensure all required set asides were met.
  • Maintain Program Records

Federal Cost Principles
  • OMB Circular A-87 Cost Principles for State,
    Local Indian Tribal Governments
  • Applies to School Districts
  • Available at OMB website
  • http//
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