WHAT IS APPROPRIATE SPENDING FOR CATEGORICAL PROGRAMS?

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1 WHAT IS APPROPRIATE SPENDING FOR CATEGORICAL PROGRAMS? Tehama County Department of Education Cooperative Ray Dinkel, Director Marv Woodstrup, Consultant Carolyn Steffan, Consultant 1135 Lincoln Street/P.O. Box 689 Red Bluff, Ca Phone Fax

2 TABLE OF CONTENTS Sources Studied... 2 List of Categorical Funding... 3 Appropriate Spending of State Categoricals... 4 State EIA/SCE, Title I Part A, ARRA & Title I Part D... 6 Title I/SCE Related Assurances Title I Part B, Reading First Title II A, Training & Recruiting HQT Larry Champion, County Superintendent of Schools TEHAMA COUNTY DEPARTMENT OF EDUCATION 1135 Lincoln Street/P.O. Box 689 Red Bluff, Ca Phone Fax Title II D, Technology Title III Limited English & Immigrant Title IV, Safe & Drug Free Schools/TUPE REAP (Rural Education) School & Library Improvement, Pupil Retention & Professional Development Block Grants Indirect Costs, Peer Assistance & Review, & AB 1113 School Safety Acronym Guide June

3 SST STAR SWD SWP TANF TAS TESOL U.S.C. WASC Student Study Team State Testing and Reporting System Students With Disabilities School Wide Program Temporary Assistance to Needy Families Targeted Assistance School Teachers of English to Speakers of Other Languages United States Code Western Association of Schools and Colleges This little booklet is used by many inside and out side of Tehama County. The State and Federal government are still clarifying some of the information and regulations as usual. We hope this guide is of help. Please feel free to call us at or if you have any questions. P.S. Remember, this is NOT the final word, nor a legal one, but just a general guide to be of help. The numbered Assurances have been greatly abridged for an easier reading. For greater detail, review the Legal Assurances provided by the State Department of Education with your Consolidated Application. Ray Dinkel, Co-op Director Marv Woodstrup, Consultant Carolyn Steffan, Consultant 24 1

4 SOURCES STUDIED This guide to help school staff and the School Site Council to understand Appropriate Spending was researched from the following: Title I, Part A Policy Guide & Title I website Title I, Part B, Reading First (guide not available) Title I, Part D, Neglected or Delinquent Policy Guide Title II, Part A Teacher and Principal Training website, Title II, Part D, Enhancing Education Through Technology Title III, Language Instruction for LEP and Immigrant Students. Title IV, Part a, Safe and Drug Free Schools Policy Guide Title IV, Part B, 21 st Century Community Learning Centers After School Program. Title V, Part a, Innovative Programs, IS NO LONGER FUNDED. Title VI, Part A, Flexibility and Accountability, Rural Education 5/15/02 M.A. Bidwell Letter No Child Left Behind Act of 2001 Policy Implications for School Districts Update Guide Sheets July 2003 California Department of Education Program Advisory Reports from 1986 to today (no index) mainly in Advisories 87/88-13 and 89/90-15 or SBCP. California Auditor s Guidelines April 2010 The Legal Assurance that each district signs relative to compliance. ARRA CDE 2009 Stimulus Instructions. 2 ESLR Expected Schoolwide Learning Result ETS Educational Testing Service GATE Gifted and Talented Education HOUSSE High, Objective, Uniform State Standard of Evaluation HPHS High Performing High School HQT Highly Qualified Teacher IASA Improving American s Schools Act of 1994 IDEA Individuals with Disabilities Education Act IEP Individualized Education Plan II/USP Immediate Intervention/Underperforming Schools Program LEA Local Education Agency LEP Limited English Proficient NAEP National Assessment of Educational Progress NCES National Center for Educational Statistics NCLB No Child Left Behind Act of 2001 NERCC North Eastern Regional Curriculum Committee NRP National Reading Panel PI Program Improvement PPE Per Pupil Expenditure PSAA Public School Accountability Act 1999 REA Reading Excellence Act RF Reading First RFEP Reclassified Fluent English Proficient RSDSS Regional System of District and School Support RSSIC Regional School Support and Improvement Center S4 Statewide System of School Support SAIT School Assistance Intervention Team SARC School Accountability Report Card SBE State Board of Education SDAIE Specially Designed Academic Instruction in English SEA State Educational Agency SED Socio Economically Disadvantaged SELPA Special Education Local Plan Area SERRF Safe Education and Recreation for Rural Families SES Supplemental Educational Services SIS Student Information System SPED Special Education 23

5 ACRONYM GUIDE LIST OF CATEGORICAL FUNDING ADA Americans with Disabilities Act/Average Daily Attended AMAO Annual Measurable Achievement Objectives API Annual Performance Index APS Academic Program Survey ARISE Advanced Rural Integrated Science Education ASAM Alternative Schools Accountability System AVID Advancement Via Individual Determination AYP Adequate Yearly Progress BTSA Beginning Teacher Support & Assessment CA Corrective Action/California CAHSEE California High School Exit Examination CAPA California Alternate Performance Assessment CCR California Compliance Review (now CPM) CCSESA California county Superintendents Educational Services Association CCTC California Commission on Teacher Credentialing CDE California Department of Education CELDT California English Language Development Test CFR Code of Federal Regulations CISC Curriculum and Instruction Steering Committee CPM Categorical Program Monitoring COE County Office of Education CSG Community Service Grant CSIS California School Information Services CST California Standards Test CTAP California Technology Assistance Project DAIT District Assistance Intervention Team ECE Early Childhood Education EDI Explicit Direct Instruction EETT Enhancing Education Through Technology ELA English/Language Arts ELD English Language Development ELL English Language Learner EPC Essential Program Components ESEA Elementary and Secondary Education Act of CALIFORNIA FUNDING: EIA Economic Impact Aid* SLIP School Library Improvement Block Grant GATE Gifted and Talented Education SPECIAL EDUCATION (services, not dollars) STATE ONE-TIME GRANTS (not currently) TUPE Tobacco Use Prevention Education SDBG Staff Development buy back, AVID, etc. SSBG School Safety Block Grant (not Carl Washington) PRBG Pupil Retention Block Grant (10 th Grade Counseling, Continuation High School, etc.) *Note: all of the above state funding can be used as general funds EXCEPT EIA, for SBCP (School Based Coordinated Plan) need not be used as EIA is the only state categorical. US FEDERAL FUNDING: Title I-A Assisting Educationally Disadvantaged Children (targeted or school-wide)* Title I-D Assisting Delinquent Children Title II Part A Teacher and Principal Training and Recruiting (also used for Class Size Reduction) Title II Part D Technology Title III Language and Instruction for LEP students Title IV Part A Safe and Drug Free Schools Title IV Part B Community Learning Centers Title V Innovative Programs Title VI Part A Flexibility and Accountability (REAP) Title VI Part B Rural Education Grant (REAP) ARRA American Recovery & Reinvestment Act of

6 APPROPRIATE SPENDING OF STATE CATEGORICALS INDIRECT COSTS 1. If it is not in the budget section of your SSC plan, it cannot be spent! Categorical funds must have a plan! 2. The SSC plan and budget are created by the SSC and must be approved by vote of the SSC members. 3. The SSC approved plan must also be approved by the School Board. If the Board does not approve the plan, the SSC has to come back with another SSC approved plan and budget. The Board has to specify desired changes in the SSC plan. A district may take a small portion of the categorical funds for the purpose of implementing the program (i.e. bookkeeping). For California Categoricals (SIP, EIA, SCE, GATE, etc.) the amounts are limited to 3% or less. However, SBCP carryover can use the Restricted Indirect Cost Rate. For Federal Categoricals (Title I, II, III, IV, V and VI) the amount is limited to the Restricted Indirect Cost Rates based on J- 380/580/780 SACS expenditure data. 4. Your SSC can CHANGE the plan and budget at any time and Board approval for the change is required (except for minor changes). The SSC is encouraged to review and monitor their plan several times during the year. 5. You must serve the needs of English Language Learners and Special Education students. 6. Transferability: For , all State Categoricals, with the exception of EIA, are to be transferred to the General fund and then used for any educational purpose. 7. PLANNED EXPENDITURES MUST BE SUPPLEMENTAL to your General Funds. Imagine that the school does not have Categorical Funds and would have used General Funds to pay for something anyway, you CAN T use Categorical Funds. Examples: IF you have always paid for Environmental Camp from General Funds, you can t use SBCP funds to supplant the funds. 4 21

7 PROFESSIONAL DEVELOPMENT BLOCK GRANT This block grant includes: Staff Development buyback days Teaching as a priority AVID These funds for are transferred to general funds. AB 1113 SCHOOL SAFETY These funds for all schools are provided by the State to assist schools in implementing their School Safety Plans. It is recommended that the Schools Safety Plan be attached to the SSC Plan and be known by the School Site Council. PAR PEER ASSISTANCE & REVIEW This program has replaced the State Mentoring Program. Specific details can be found in each districts negotiation agreement, except those who never reached an agreement. The expenditure is only limited by the agreement, the annual evaluation and its written monitoring written record. Expenditure for administration cannot exceed 5% of the PAR funds. PAR committees must meet at least once each year. For , these funds are placed in the General Fund. If you paid for two instructional assistants (salary and benefits) with 60% Categorical, you cannot increase to 75%. However, if the total costs increase for the next year, you can remain at 60% of the costs. 8. All programs and services must be in compliance with the Civil Rights Act of 1964 and the California Fair Employment Practice Act. 9. Every School is to have a Board Approved Plan. Follow the format of the Single School Plan template for developing the PLAN. Attach your School Safety Plan. 10. The PLAN must be revised annually. 11. All funds are subject to what is called comparability. In other words, all students in a district must be provided equivalent curriculum materials and instructional supplies. If one school in the district uses general funds for counseling services, another school cannot use Categorical funds to provide the same services. Any service provided by the general fund in one school, must provide the same services paid by general funds in all schools. 20 5

8 STATE EIA/SCE, TITLE I-A, ARRA & TITLE I-D CAHSEE High School Exit Exam 1. If it isn t in the budget of your SSC Plan, it cannot be spent! Yes, even the ARRA of must be in the School Plan. 2. The SSC Plan process is the same for State funds and Federal funds and should be included in the same plan. Schools should avoid having more than one plan. All actions must be based on research that is shown to be effective. 3. Money MUST be spent on IDENTIFIED Title I students. However, if your school has 40% or more poverty, You can consider all of your students as Title I. When the SSC Plan is approved by your SSC and School Board, and the State Department has informed you by letter, then you have become a School Wide Program (SWP). Help from your RSDSS Director and the Co-op is available. 4. Authorized and Planned activities for spending can be: a. Travel/conferences b. Instructional Equipment c. Instructional Materials d. Book and library resources e. Teachers, counselors, etc., salaries and benefits/leave costs (must be supplemental) f. Instructional assistants salaries and benefits g. Training of staff and parents (can be all staff, not just those paid by Title I-A, Title I-D or SCE) h. Private and school facilities i. Construction, but not permanent buildings* j. Parent involvement materials, videos, training parents k. Evaluation of programs l. Child care during Title I meetings 6 These funds are used to provide assistance to students who are or may not be able to pass the State high School Exit Exam. The exam is a graduation requirement. These funds for are transferred to General Funds. SCHOOL & LIBRARY IMPROVEMENT BLOCK GRANT This State funded block grant combines the funding of the old SIP and Library Grant for each school. This SLIP-BG is urged to be included in the SBCP. For , these funds can and should be transferred to General Funds. PUPIL RETENTION BLOCK GRANT These funds are for enhancing the counseling program at the 10 th grade level, and continuation high school. Staff development Computer-assisted guidance Assessment Counseling Research for students Evening and weekend counseling Career centers (1983 Advisory dated October 20) These funds for are transferred to General Funds. 19

9 TITLE VI RURAL EDUCATION ACHIEVEMENT PLAN REAP PART A IMPROVING ACADEMIC ACHIEVEMENT REAP funds can be transferred under one or more of the Title Federal programs to allow for Small Districts flexibility. A district may combine any or all of the funds from Table A with funds from Table B. m. Co-op administration n. Food & refreshments if necessary for an educational function. o. Facility rental p. Lease/purchase agreements (including interest) q. Custodial services to Title I-A, Title I-D and SCE programs/services * Must be in State Compensatory Education (SCE) Plan and Consolidated Application. Table A Title I-A, Disadvantaged Title II-A, Quality Educators Title II-D, Technology Literacy Table B Title IV, Safe & Drug Free Title VI - REAP 5. Equipment purchased under Title I-A, Title I-D, ARRA or SCE valued less than $5, 000 may be sold, when not needed and the proceeds from sale returned to General Funds or Title I-A funds. To be a Title VI REAP school district or charter school must have less than 600 ADA and all schools must have a Local Code of 7 or 8 under the U.S. Department of Education. The results must show improvement on the AYP within three years. TITLE VI REAP PART B RURAL EDUCATION INITIATIVE These are grants for small rural districts. There are regular REAP grants and low income REAP grants. They have the same flexibility as Part A above. Receipt of these funds are Drawn down electronically at the time of being expended. A district password is required Maintenance and operation costs that support the Title I-A program can be supported b Title I-A, Title I-D, SCE or ARRA funds. (ARRA includes N & D and homeless) 7. Districts can use up to 5% of their Title I-A funds for Coordinated Services between schools and districts. 8. Under NCLB, each school district with more than $500,000 Title I-A entitlement must plan and spend 1% on PARENT INVOLVEMENT actions (i.e. parent training, parent communications, school volunteers, home instruction and parent s rights). 95% of the 1% must be distributed to schools. 9. Examples of using Title I-A purchases in non-title I-A activities: Computers purchased with Title I-A funds are used full time during the school day, but are idle during evening hours and would be beneficial to adult education classes that meet twice a week. The use in the adult education classes would not be extensive and therefore would not 7

10 significantly shorten the life of the equipment. Under these circumstances, the Title I-A computers may be used for the adult education classes. Title I-A computers that are part of a properly designed Title I-A project are being used full time except for one period each school day. The proper amount of computer equipment was purchased for the Title I-A project and the Title I- A project cannot be redesigned effectively to use the computers in every period. Under these circumstances, the Title I-A computers may be used for non-title I-A students. Ten listening centers were purchased with Title I-A Funds and are used regularly but not continuously in the Title I-A project. The Title I-A project cannot be designed effectively to use the centers more frequently. The listening centers are used in an extracurricular foreign language program for a period of time averaging ten percent of less of the time devoted to Title I-A. If the useful life of the centers is not significantly reduced, the centers may be used in this manner. Title IV & TUPE RELATED ASSURANCES The applicant LEA ensures that funds under this subpart will be used to increase the level of State, local, and other non-federal funds that would, in the absence of funds under this subpart, be made available for programs and activities authorized under this subpart, and in no case supplant such State, local and other non-federal funds. As a condition of receiving funds, county offices of education and local school districts shall ensure that they coordinate their efforts toward smoking prevention and cessation with the lead local agency in the community where the local school district is located. The school district must assure that staff, contracts, materials, supplies and equipment funded with TUPE funds supplement but do not supplant existing levels of services. (Revenue and Taxation Code 30125) Title V Innovative is no longer funded The clue seems to be that the Title I-A purchased equipment must be used for Title I-A students at least 80% of the time AND use by non-title I-A students does not wear it out too fast. 10. Schools must maintain fiscal effort. A school district must have General Fund support of at least 90% per student of what it supported two years ago. 11. CARRY OVER of Title I-A funds and ARRA Funds from year to year is limited to 15% of the current allocations IF the allocation is over $50,000. If it is less than $50,000, 8 17

11 The LEA will base its proposed plan under ESEA, Title III Part A, on scientifically based research on teaching LEP children. There are adequate basic and supplemental resources to provide each English Learner with learning opportunities in an appropriate program to provide equal opportunity for academic achievement across the core curriculum, including classes necessary to complete graduation requirements. TEHAMA COUNTY PREVENTION PROGRAM TITLE IV SAFE & DRUG FREE SCHOOLS & COMMUNITIES & TUPE 1. There is no funding for the school year. These funds have been allocated to each district and most districts in the Co-op belong to our Tehama County Prevention Consortium. All requirements and reports will continue to be in effect. 2. The IV Part A is the 21 st Century Schools, which is an after school program. there is no carry over limit. However, the fund from one allocation must be completely spent by the end of twenty-seven (27) months from the time of allocation (July 1 st ). 12. Employee benefits can be paid for funded employees including sick leave and sabbatical leave (Title I-A and I-D). 13. An employee who is Title I-A and also paid from other program support must MAINTAIN RECORDS OF TIME distribution. If the work is the same each week or month, a written statement of the detail must be certified every four months of the year (if SWP-Multifunded, can be certified semi-annually). If the work is not the same, then a time card must be kept to show which program is served and the amount of time spent. Please see the example on the following page. 14. The 85/15 Rule After Indirect Costs are reserved, at least 85% of the funds for School Improvement Programs, Title I, Title V and Economic Impact Aid are spent for direct services to students. Only 15% can be used for administrative costs including Centralized Service charges. 3. Title IV Part B is the Safe & Drug Free Schools program. 4. Tobacco Use Prevention Education, or TUPE, is a state funded program and is limited to grades 4, 5, 6, 7 and 8. These programs have detailed effectiveness measurement components (i.e. violence and drug use, discipline problems, student surveys and parent teacher input). Specific goals are set and an analysis made with the consolidated application. 16 9

12 TEHAMA COUNTY COOPERATIVE FOR CATEGORICAL PROGRAMS TIME UTILIZATION SCHEDULE TITLE III School Name Job Category Funding Sources: % % % % % SBCP TITLE I ELL DISTRICT OTHER FROM TO (Time Period) Time SBCP Title I ELL District Other 8:00-9:00 9:00-10:00 10:00-11:00 11:00-12:00 1:00-2:00 2:00-3:00 Total Minutes If job stays consistently the same, this form needs to be filled out only 3 times per year (twice if SWP) Revenue & Tax Code Title III Part A is for LEP students and Part C for Immigrant students and their families. The goal is high quality teaching and in depth high quality professional development for teachers of LEP students and includes upgraded curriculum and instruction, tutoring, materials and instruction for LEP students and their families. School districts receiving less than $10,000 are to form a consortium with other small districts and create a 2 year plan under (PL ). In Tehama County, districts and the County office have formed a consortium; larger districts will conduct their own plan. Members of the consortium have an MOU with the consortium lead and must request payments as spent. TITLE III - RELATED ASSURANCES The LEA will use ESEA, Title III Part A funds according to the No Child Left Behind Act of (PL , 3102) 14. Transferability: Title II-A, Title II-D, Title IV may transfer up to 50% to any other Federal Title. Title I cannot be transferred out, but can receive funds. Title VI REAP is different (see REAP page 20). ARRA may be used as Title I-A if planned and used. ESEA, Title III Part A funds shall be used so as to supplement the level of Federal, State and Local public funds that, in the absence of such availability, would have been expended for programs for LEP children and immigrant children and young and in no case to supplant such Federal, State and local public funds. [(PL , 3115(g)] The LEA shall provide CDE with an evaluation every two years (PL ). The LEA will develop and submit to the CDE an LEA Plan inclusive of all elements required by the State and ESEA

13 TITLE II D - TECHNOLOGY Title I/SCE RELATED ASSURANCES Title II-D: Enhancing Education through Technology. This is a grant program. Specific requirements of the purchase of hardware, 25% or more for Professional Development, E-Rate, Internet access and policy requirements are provided to the recipients of this grant. A State approved District Technology Plan is required. Title II-D TECHNOLOGY RELATED ASSURANCES Grant recipients must use no less than 25% of grant funds to provide ongoing, sustained, and intensive, high-quality professional development. (PL , 2416) No grant funds made available to local education agencies that not receive services at discount rates under section 254(h)(5) of the Communications Act of 1934 [(47U.S.C. 254(h)(5)], otherwise known as E-Rate, may be used to grant funds to purchase computers used to access the Internet, or to pay for direct costs associated with the accessing of the Internet, unless the school or local educational agency has in place, and is enforcing, a policy of internet safety for minors that includes specified technology protection measures. (PL , 2441) The LEA annually uses the State academic assessments and other indicators described in the state plan to review annually the progress of each school receiving Title I funds to determine whether the school is making adequate yearly progress. If not making progress, a school district can be designated Under Performing and/or Program Improvement. Each requires corrective action in a new SSC Plan. The LEA is maintaining fiscal efforts on behalf of Title I/SCE eligible children to ensure that these funds supplement educated eligible children. ARRA funds can be used to supplement to prevent the layoff of an employee. The LEA has maintained fiscal effort. The combined fiscal effort per student of the aggregate expenditures of the LEA from State and local funds for free public education for the preceding year was not less than 90% of the combined fiscal effort or aggregate expenditures for the second preceding year. Local education agencies receiving grant funds must, during the grant period have at least sixty (60) percent of the teacher at the funded local education agency (LEA) complete both modules of the CTAP2 Technology Assessment Profile (Proficiency Assessment and Technology Use Survey), at to determine their level of technology use. (PL , 2414) 14 11

14 TITLE I PART B, READING FIRST This non-competitive grant requires an application. Eligible districts are to follow the requirements furnished with their award. Tehama County has a very active and extensive program in many schools. No Child Left Behind (NCLB): General Assurances Except as otherwise provided, the LEA will ensure that Title I schools are provided with State and local services that, taken as a whole, are at least comparable to that in schools that are not receiving Title I, Part A funds. If the LEA is providing Title I Part A services to all of its schools, the LEA ensures that State and local funds provided to all of its schools, taken as a whole, are at least comparable in each school. [20 U.S.C (c)(1)(a) and (B), (4), (5); PL , 1120A(c)(1)(A) and (B), (4), (5)] Each LEA receiving Title I/SCE funds is allocating time and resources to coordinate and integrate services with Even Start, Head Start, Reading First, Early Reading First and other preschool programs, as well as other educational services for students who are English Learners (also known as LEP), children with disabilities, homeless, migratory, American Indian, neglected and delinquent students, along with other health and welfare agencies, if appropriate. [20 USC 6301(b)(11), 6311(A)(1), 6312(b)(1)(E); PL , 1112(b)(1)(E)] Implement programs and early intervention for the educationally disadvantaged students based on scientifically based research. Inform eligible school and parents of school-wide programs authority and the ability to consolidate funds from federal, state or local sources. 12 Spend, at minimum, a per child amount of the Federal, State and Local funds, excluding amounts for state compensatory, as was present during the preceding fiscal year. TITLE II-A TRAINING & RECRUITING HIGH QUALITY TEACHERS The Title II Eisenhower Professional Development has been combined with Class Size reduction. 1. Requires a comprehensive and collaborative NEED ASSESSMENT developed by all school staff and parents. This is a critical requirement and does not mean a survey or a WANT list. 2. The results of the NEEDS ASSESSMENT become the basis for the Professional Development in the SSC Plan and must be research based. 3. Professional Development costs include: Conference Fees Travel and accommodation to and from professional development activities. Collaboration time beyond the regular school day for staff to analyze and plan for student improvement. Materials and equipment purchased to train staff for instructing. Recruiting costs of high quality teacher and administrator costs. Salary and benefits for educators time in professional development. Cost of university course work. Cost of substitute employees. 13

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