Every Student Succeeds Act (ESSA) Fiscal Requirements. Shelly Babler, Assistant Director Kathy Guralski, Assistant Director March 16, 2017

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1 Every Student Succeeds Act (ESSA) Fiscal Requirements Shelly Babler, Assistant Director Kathy Guralski, Assistant Director March 16, 2017

2 ESEA vs NCLB vs ESSA 1965 Elementary and Secondary Education Act (ESEA) Reauthorized several times between 1965 and Reauthorized as No Child Left Behind (NCLB) 2015 Reauthorized as the Every Student Succeeds Act (ESSA)

3 Changes to Certain Fiscal Requirements Title I, Part A within-state allocations Title II, Part A allocations Maintenance of effort requirements Transferability requirements Title I supplement not supplant Equitable service requirements for private school students

4 NCLB: Title I, Part A within-state allocations Total Grant Award by LEA (from USDE) Adjustments: -School Improvement -Administration -Academic Achievement Awards -Hold Harmless Final Allocation

5 ESSA: Title I, Part A Within-State Allocations Total Grant Award by LEA (from USDE) Adjustments: -School Improvement -Administration -Hold Harmless Final Allocation New ESSA Requirement

6 NCLB: Title II, Part A Allocations Total Grant Award (from USDE) DPI Allocates: -Base amount -Additional Funds -20% (based on 5-17 population) -80% (based on 5-17 poverty count)

7 ESSA: Title II, Part A Allocations Total Grant Award (from USDE) DPI Allocates: -20% (based on 5-17 population) -80% (based on 5-17 poverty count)

8 Maintenance of Effort (MOE): Definition & Purpose A year-by-year analysis to ensure LEAs are supporting core education in Title I schools. An LEA may receive its full allocation of ESSA funds if the State determines the LEA has maintained its fiscal effort.

9 MOE: Definition & Purpose LEAs demonstrate MOE by either the combined fiscal effort per student OR the aggregate expenditures (non-federal funds) of the LEA for the preceding fiscal year was not less than 90 percent of combined fiscal effort or aggregate expenditure for the second preceding fiscal year. (No change under ESSA)

10 MOE: Calculations The annual financial report (PI-1505) is used to determine MOE. Amount from preceding year must not be less than 90 percent of the second preceding year. Example: To receive funds available July 2017, DPI will compare school year expenditures to school year expenditures. Slide adapted from Brustein and Manasevit Fall 2012 Forum

11 Annual Report

12 Per Student

13 MOE: Consequences of Failure NCLB The state must reduce amount of allocation in the exact proportion by which LEA fails to maintain effort by falling below 90 percent in the previous year. ESSA The state must reduce amount of allocation in the exact proportion by which LEA fails to maintain effort by falling below 90 percent in the previous year and at least once in the prior five years. Slide adapted from Brustein and Manasevit Fall 2012 Forum

14 ESSA Programs to which MOE Applies Reduction applies to all applicable ESEA/ESSA programs that are still funded by USDE (not just Title I): Title I, Part A Title I, Part D Title II, Part A Title III, Part A Title IV, Part B Title V, Part B, Subpart 2 Title VI, Part A, Subpart 1

15 MOE: Example Analysis for Meeting MOE in Previous Year Aggregate Expenditures Amount per Student Actual Amount $1,000,000 $6,100 90% of Amount $900,000 $5, Actual Amount $950,000 $5,495 Difference $50,000 $5 Percent Reduction in Award for % 0% Maintenance of Effort was met.

16 MOE: Example Analysis for Meeting MOE in Previous Year Aggregate Expenditures Amount per Student Actual Amount $1,000,000 $6,100 90% of Amount $900,000 $5, Actual Amount $850,000 $5,200 Difference (Shortfall) <$50,000> <$290> Percent Shortfall/ Reduction in Award for % -5.3% Under ESEA, the funds will be reduced by 5.3 percent. Under ESSA, the funds will be reduced by 5.3 percent if the LEA also failed MOE in one of the five prior fiscal years.

17 MOE: Example Analysis for Meeting MOE in Previous Year Aggregate Expenditures Amount per Student Actual Amount $1,000,000 $6,100 90% of Amount $900,000 $5, Actual Amount $890,000 $5,495 Difference (Shortfall) <$10,000> $5 Percent Shortfall/ Reduction in Award for % 0% Maintenance of Effort was met.

18 MOE: Waivers NCLB USDE Secretary may waive if: ESSA USDE Secretary may waive if: o there are exceptional or uncontrollable o there are exceptional or uncontrollable circumstances such as natural disaster circumstance such as natural disaster or o OR precipitous decline in financial resources of the LEA. change in organizational structure of the LEA OR o precipitous decline in financial resources of the LEA. Slide adapted from Brustein and Manasevit Fall 2012 Forum

19 MOE: Waivers Non-Regulatory Guidance from USDE issued November 21, 2016: In addition to these two examples listed in the statute, there can be other instances of exceptional or uncontrollable circumstances that might warrant when a waiver request will be considered. Slide adapted from Brustein and Manasevit Fall 2012 Forum

20 MOE: Waivers Waiver Process: 1. DPI will contact LEAs if MOE is not met. 2. LEAs will notify DPI if they want to request a waiver. 3. DPI will request waivers on behalf of all LEAs needing waivers, and 4. DPI will notify LEAs if waivers are granted or not.

21 Transferability LEAs may transfer funds they received by formula under certain programs to better address local needs. NCLB - Limited the amount of funds that could be transferred ESSA - Removed the limits NCLB Section: 6123 ESSA Section: 5103

22 NCLB: Transferability Title II - A Title I - A Note: When NCLB was passed in 2002 there were more Titles funded and therefore more options for transferability. By , transferability was only allowed from Title II to Title I.

23 ESSA: Transferability Title II-A Title IV-A Title I-A Title I-C Title I-D Title II-A Title III-A Title IV-A Title V-B

24 NCLB: Title I Supplement not Supplant (SnS) Title I funds may only be used to supplement the instructional program offered in a school. Title I funds must not supplant, i.e. take the place of, other funds from non-federal sources. NCLB Section: 1120(b)

25 NCLB: Title I SnS for Targeted Assistance Programs Three tests for supplanting: 1. Is the activity or expense required by state or local law or other federal law? 2. Was this activity or expense paid for by local funds in the past? 3. Does the LEA use local funds to provide a service to non-title I students and Title I funds for the same service to Title I students? Answering Yes to any of the three questions implies supplanting. Contact DPI to discuss.

26 NCLB: Title I SnS for Schoolwide Programs Title I Schoolwide Schools do not need to provide services that supplement, and do not supplant the services participating students would otherwise receive if they were not participating in a Title I program. 1. Did the school receive its full share of local funds? 2. Is the proposed budget item addressing an educational need? 3. Is the proposed budget item meeting needs identified in the schoolwide plan? Answering Yes to all three questions implies that the item is allowed. NCLB Section: 1114(a)(2)(A)(ii)

27 ESSA: Title I SnS (1) In General - A State educational agency or LEA shall use Federal funds received under this part only to supplement the funds that would, in the absence of such Federal funds, be made available from State and local sources for the education of students participating in programs assisted under this part, and not to supplant such funds. Difference from NCLB: The term State and local replaced the term Non- Federal and students replaced the term pupils ESSA Section: 1118(b)(1)

28 ESSA: Title I SnS (2) Compliance An LEA shall demonstrate that the methodology used to allocate State and local funds to each school receiving assistance under this part ensures that such school receives all of the State and local funds it would otherwise receive if it were not receiving assistance under this part. ESSA Section: 1118(b)(2)

29 ESSA: Title I SnS (3) Special Rule No LEA shall be required to: A. identify individual costs or services as supplemental or B. provide services through a particular instructional method or in a particular instructional setting to demonstrate compliance. ESSA Section: 1118(b)(3)

30 Fiscal Changes to Private School Equitable Participation under ESSA Title I, Part A, Section 1117 Title I, Part A USDE Non-Regulatory Guidance: Fiscal Changes and Equitable Service Requirements under ESEA, as amended by ESSA, November 21, 2016 Title VIII, Part F, Subpart 1 Title I, Part C Title II, Part A Title III, Part A Title IV, Parts A and B

31 Deriving a Proportional Share for Private School Students Title III, Part A Calculation remains the same. Reminder: Only applies to private schools that elected to participate in Title III Services during consultation.

32 Step 1: Determine the Per Pupil Amount State s Allocation $7,000,000 Total # of Students Administered the ACCESS Test in , Per Pupil Amount $ Hypothetical Data

33 Step 2: Calculate the Proportional Share Public School District Participating Private School A Participating Private School B Number of Students Administered the ACCESS Test in Per Pupil Amount for Allocation 67 $ $10, $ $1, $ $ District Total 77 $11,977.35

34 ESSA: Deriving a Proportional Share for Private School Students Title II, Part A The amount an LEA must reserve to provide equitable services for private school teachers and other educational personnel for Title II, Part A services is based on the LEA s total Title II, Part A allocation, less administrative costs. USDE Non-Regulatory Guidance: Fiscal Changes and Equitable Services Requirements under ESSA, November 21, 2016

35 ESSA Title II, Part A: Deriving a Proportional Share for Private School Students DPI created an Excel calculator to give LEAs an idea of the impact of this new language. It can be found here.

36 ESSA: Deriving a Proportional Share for Private School Students Title I, Part A NCLB: The proportional share must include a share of the reservations for professional development, parent involvement, and districtwide instructional costs. ESSA: The proportional share must be calculated before any allowable expenditures and reservations by the LEA. ESSA Section 1117(a)(4)

37 ESSA: Deriving a Proportional Share for Title I, Part A DPI created an Excel calculator to give LEAs an idea of the impact of this new language. It can be found here.

38 What does this mean for LEAs? Likelihood of more Title I and Title II funds being allocated for services to support private school equitable participation.

39 ESSA: Obligating Funds Funds allocated for educational services and other benefits to eligible private school children, teacher and other educational personnel, and families shall be obligated in the fiscal year for which the funds are received by the LEA. ESSA Section 8501(a)(4)(B) and 1117(a)(4)(B)

40 What does this mean for LEAs? Reinforces the need for timely consultation so services can begin at the start of the school year; LEAs will file separate budgets and claims in WISEgrants; and Impacts carryover.

41 ESSA: Notice of Allocation DPI must provide notice in a timely manner to the appropriate private school officials of the allocation of funds for educational services and other benefits under ESSA that LEAs determined are available for eligible private school children. ESSA Sections 8501(a)(4)(C) and 1117(a)(4)(C)

42 ESSA: Notice of Allocation Timely Manner DPI should ensure that the notice is provided prior to the beginning of the school year. Section N-10, USDE Non-Regulatory Guidance November 21, 2016

43 ESSA: Notice of Allocation How will DPI do this? Data will come from WISEgrants (or paper grant application)

44 What does this mean for LEAs? Submit your grant applications As Soon As Possible. Deadline TBD. DPI will change the deadline to align with private school requirements.

45 ESSA Transition DPI s Website:

46 Thank You! Shelly Babler or (608) Kathy Guralski or (608)