IDEA Grants Overview

IDEA Grants Overview Directors Conference August 5, 2015 Egrants Timelines Amendments Carryover CEIS Proportionate Share Audits Excess Cost MOE Questions

FY15 Presented Many Challenges Illinois Districts/Cooperatives Met Each Challenge MOE Eligibility - MOE eligibility page was added to the IDEA grant application. IDEA Excess Cost The initial year for the IDEA excess cost documentation process. Forfeiture Clause Prohibition Districts and cooperatives were notified that special education Articles of Joint Agreement cannot include a provision requiring any member districts withdrawing from the cooperative to forfeit unexpended and unobligated IDEA funds. 100% completion by Illinois districts and cooperatives. Illinois implemented prior to July 1, 2015 regulatory change. 100% completion by Illinois districts and stand-alone charter schools. Several cooperatives requiring revision to their Articles of Joint Agreement promptly contacted ISBE regarding the process and timeline for completion.

FY16 Off to a Good Start MOE worksheets were available early (April 2, 2015) IDEA grant applications were early (May 13, 2015) No significant changes to the grant application process July 1, 2015 revisions to 34 CFR Part 300 - We do not anticipate any needed revisions to Illinois IDEA MOE policies/procedures. Excess cost finding we are cautiously optimistic that documentation will verify that Illinois addressed the requirement prior to receiving the finding.

ISBE Contacts for IDEA Grant Questions

Question IWAS Technical Difficulties, e.g. problems with: Passwords Adding new users Locked pages Adding amendments or subgrants Programmatic IDEA Grant Questions Allowable expenses Grant timelines Excess Cost CEIS IDEA proportionate share On-going audits IDEA Maintenance of Effort (MOE) Fiscal Questions IDEA allocations IDEA proportionate share calculations Expenditure reports Indirect costs Contact Please reference the instructions in the egrant application. If additional assistance is needed, please contact the HELPDESK at 217/558-3600. Special Education Services Grant Coordinators dcamacho@isbe.net tgreco@isbe.net fmalloy@isbe.net 217/782-5589 Special Education Services Pam Jurkoshek 217/782-5589 Funding and Disbursements Division http://www.isbe.net/funding/html/special ed.htm 217/782-5256

Managing the IDEA Grants

US Department of Education IDEA Allocation (Generated by District Population) State Education Agency (ISBE) Special Education Cooperative Stand-alone District Member District Member District Member District

IDEA Funds Moving Between Cooperatives & Member Districts Keep track of the IDEA funds must be able to show the money trail and verify how the funds were spent, this includes IDEA carryover funds Any funds budgeted for payment to districts/cooperatives, must include a clear and detailed explanation Tuition is specific to students, i.e. not salary reimbursement to avoid federal TRS payments

IDEA Funds Moving Between Cooperatives & Member Districts (cont.) Nonpublic proportionate share funds must flow to the districts IDEA funds used for CEIS (voluntary and required) must flow to the districts

IDEA Funds - Follow the Students IDEA funds must be expended on the students/districts that generated the federal funds. IDEA funds expended by a district through an IDEA subgrant. IDEA funds expended by a cooperative on behalf of the member district. Carryover funds are attached to the district that generated the funds. Unexpended and unobligated IDEA funds, including carryover, cannot be forfeited upon withdrawal from a cooperative.

IDEA Funds Moving Between Cooperatives and Member Districts Cooperative (pass-through entity for IDEA funds) Member District Subgrants (IDEA funds allotted to member districts) Funds Expended on Behalf of Member Districts expenditures in the cooperative AFR cooperatives tracks expenditures and carryover by district unexpended funds are district carryover Special Education Expenditures expenditures in the district AFR audit trail for the IDEA funds, including payments made to the cooperative unexpended funds are district carryover (coop. and district track) When a district purchases a service from a cooperative through an IDEA subgrant, the IDEA funds are no longer attached to the district.

Walking the Line IDEA grants are for special education expenses: Expenses must be reasonable and necessary for the provision of special education services. Grantees must be able to verify that IDEA funds expended were for special education costs: Track the money Withstand an audit School districts are required to expend local funds for special education services.

Control What You Can Timelines - ISBE cannot back date or approve after the fact Track IDEA allocations, expenditures, and any carryover Staff training and notifications Have procedures in place to train new staff members Share listserv announcements Amend the grant as needed Keep current Cooperatives and member districts coordinate amendments Use available resources Instruction links in the egrants, FRIS, ISBE website

Prepare for What You Can t Control Allocations can change during the fiscal year State funding can change during the fiscal year Be aware of and verify funding source options for expenditures flexibility without supplanting. Keep current with federal and state regulations. Read the notices from the IDEA grant team and share with staff in the district/cooperative.

Know the Grant Timelines July 1 Earliest start date for the IDEA grants September 30 Timeline for completing MOE May 31 June 30 August 1 Last date to submit an amendment for the regular IDEA grant period End date for the IDEA grants Last date to submit an amendment for any IDEA grant that has an approved extension

Timelines that Impact IDEA Grants Timely and Meaningful Consultations (TMC) Meetings conducted by May 31 TMC documentation submitted to ISBE by June 15 MOE Reduction Eligible districts that seek to take the MOE reduction, must submit the MOE Reduction form to ISBE by September 30. Excess Cost - Due at ISBE by the last working day of January (January 29, 2016 for FY16). CEIS Annual Reporting Due at ISBE by the end of February.

Stay Within the Grant Period Obligating funds - substantially approvable grant (including subgrants) submitted to ISBE Start date for salaries/benefits is tied to the start date of the grant Budget for the current grant period Length of licenses, leases, etc. ESY and summer expenditures (note the timelines) Liquidation period 90 days from the end of the grant

Avoid Common Errors Provide sufficient details in grant applications Double check CEIS and budget details Complete the GEPA and FFATA sections, NA is not an option Only note shipping/handling costs when those costs are billed separately Note per unit cost for equipment Include district threshold for non-capitalized equipment (object 700)

Avoid This Less Common Error Private special education school/facility tuition and travel expenses are NOT allowable costs in the IDEA grants. Information on nonpublic special education programs (14-7.02) is available at http://www.isbe.net/spec-ed/html/nonpublic_se.htm.

Use Equipment Purchases Project/program purchase Possible additional project/program Nonpublic limitations (34 CFR 300.144) Management Requirements INVENTORY TRACKING SYSTEM Disposition More than $5,000 (per unit) use equipment deletion process in IWAS 34 CFR Part 80 (EDGAR) 80.32 Equipment http://www2.ed.gov/policy/fund/reg/edgarreg/edgar.html

Amending the Grant Amendments are required for: significant changes in program scope; or budgeting for more available funds (i.e. carryover); or purchases exceed the ISBE expenditure variance of 20% or $1,000 per budgeted cell, whichever is greater; or adding new expenditure items. *This includes changes in purchases of previously approved equipment. Note changes in the amendment page - Include subgrants with amendments

Carry Over of IDEA Funds Unused IDEA funds carry over to the next fiscal year. Carry over funds must be spent within the one-year carry over period. Carry over funds are attached to the districts that generated the funds. Carry over funds are: Generally loaded in late summer/early fall Noted on the allotment page of the grant Expended first

Better Safe than Sorry Errors with the federal grants can result in repayment of funds or adjustments to budgets. When you encounter a new situation or don t fully understand a grant related issue; email or call your grant coordinator. With grants, it is wiser to ask permission first than to beg forgiveness later.

Audits

Audits A-133 Respond in a timely manner, contact your grant coordinator with any questions District and cooperative communication Follow through on corrective action to avoid a repeat finding Audit findings can impact LEA determinations State ISBE Federal and State Monitoring Generally cyclical Can be in response to red flags Federal - If no notification from ISBE, contact your grant coordinator

A-133 Audits When ISBE receives the A-133 audit findings the districts have already signed agreement to the findings and the plan of action. Any audit finding with questioned costs will be subject to repayment or budget adjustments. Districts can contact their grant coordinators during the audit process. Please provide a detailed explanation, so that we can provide an accurate response.

Sample of Audit Findings Time/effort and certification not completed Inaccurate sub-recipient monitoring resulted in questioned costs for the cooperative and/or district Lack of segregation of duties over cash receipts and cash disbursements Payments to other districts exceeded the budgeted amount Payments to staff: staff member(s) did not meet the qualifications stipends paid lacked review and approval salaries claimed for reimbursement did not agree to total wages in the grant application

A Few More Audit Findings Errors in expenditure claims Claimed too early Claimed in two fiscal years Over-claimed Not filed in a timely manner Did not match the general ledger Unallowable expenses paid from the grant Discrepancies with the general ledger Equipment purchases that exceeded $5,000 were not tracked in an inventory list

Coordinated Early Intervening Services (CEIS)

Coordinated Early Intervening Services (CEIS) Voluntary for most grantees May use up to 15% of funds for CEIS: for professional development, and to provide evaluations, services and supports including scientifically-based literacy instruction. Must document and report to ISBE OSEP: how many students are served, and how many students are later determined eligible under the IDEA.

CEIS (cont.) CEIS is for students who have not been identified as special education eligible. RtI can be included in the grant as a CEIS expense. PBIS and progress monitoring in IDEA grants (e.g. AIMSweb, DIBELS): at-risk population receiving early intervention services budget in CEIS OR special education population only - budget as ordinary IDEA grant expenditures.

CEIS (cont.) IDEA CEIS funds cannot be used to supplant any activity that was previously funded by federal ESEA funds e.g. can use IDEA CEIS funds to supplement/add on to existing activities, but cannot replace previous funding with IDEA CEIS funds. *If a district is eligible for voluntary MOE reduction: any use of CEIS will count toward that total AND the combined dollar amount for the MOE reduction and CEIS will be limited to the smaller amount (usually 15%). Any district opting to take a MOE reduction must complete and submit the IDEA MOE Reduction form to its IDEA grant coordinator by September 30, 2015. 34 CFR 300.205 Appendix D to Part 300

Professional Development

IDEA Funded Professional Development At least 5% of the IDEA flow-through budget must be dedicated to professional development activities. IDEA-focused is the standard for all professional development activities. IDEA funded out-of-state travel for professional development is limited to LEA/cooperative employees.

IDEA Funded Professional Development (cont.) Any equipment provided as part of a conference is the property of the district/cooperative, e.g. pre-loaded ipad Out-of-state travel Requires prior approval, submit the approval request at least one-week in advance of the event All requirements apply, including reasonable and necessary for the purpose of the grant Use the federal funds wisely

Supplement Not Supplant

IDEA funds are to supplement, not replace, local spending on students with disabilities. Excess cost and MOE requirements are two prongs of IDEA supplement not supplant.

Excess Cost of Special Education

34 CFR 300.202 IDEA funds are for the excess costs of providing special education and related services to children with disabilities. IDEA funds must be used to supplement state, local, and other federal funds and not to supplant those funds. The excess cost requirement prevents an LEA from using funds provided under Part B of the IDEA to pay for all of the costs directly attributable to the education of a child with a disability.

Excess Cost Determination Each district must determine its excess cost threshold. Appendix A to Part 300 of the CFR FY15 Initial year for the IDEA excess cost documentation and verification process. FY16 The second year will include steps for IDEA excess cost verification.

FY15 - IDEA Excess Cost It was a new process for all of us. 100% of Illinois districts and stand-alone charter schools completed and submitted the excel worksheets. It was a learning process for districts, cooperatives, and the IDEA grant coordinators. We had some bumps on the road We used those problems as a basis for FY16 revisions We made it through the first year, we will all have a better idea of what to expect for future years.

FY16 - IDEA Excess Cost Revisions to instructions and prompts in the worksheets clearer directions Added a line to Section A for entering IDEA expenditures made by the cooperative on behalf of the district. Cooperative member districts will enter expenditure detail report form data in two places on the excess cost worksheet. Overhaul to Section D: formatted the state/local section to match Sections A and B included lines for districts to note where the expenditures are located in the AFR Added Section H, Excess Cost Check

Section H Excess Cost Check Section H, of the FY16 excess cost worksheet, uses the FY15 AFR expenditure data and the FY15 final, verified child count data to determine the average annual per pupil expenditure. (APPE X students with IEPs = district costs for special education) That amount is then compared to the excess cost threshold from the FY15 excess cost worksheet. (FY15 costs FY15 excess cost threshold) A positive number or a zero means the district met the FY15 excess cost threshold. No other action is needed for FY15, keep monitoring FY16 spending. A negative number means the district did not meet the FY15 excess cost threshold. The negative amount must be resolved to avoid repayment of the federal shortfall.

Excess Cost Check Negative Amount Don t panic Double check for any errors If the amount is still negative, the district should contact the IDEA grant coordinator. The IDEA grant coordinator will work with the district to identify any errors in the FY16 and FY15 excess cost worksheets. As with IDEA MOE, if the negative amount cannot be resolved the district must repay the federal shortfall with local funds.

The worksheet includes a link to the FY15 final, verified child count with each district s student population separate by elementary and secondary. SECTION H - Excess Cost Check Elementary (K-8) Secondary (9-12) Total FY15 # of Students with IEPs (final verified list - www.isbe.net) FY15 Special Education Costs (APPE X students with IEPs) Enter the FY15 IDEA Excess Cost Threshold (line 81 of the FY15 worksheet) $0.00 H FY15 Check (line 77 - line 78 ) $0.00 $0.00 $0.00 The district met the FY15 IDEA excess cost threshold if the final amount is zero or a positive number. A negative amount indicates the district did not meet the FY15 IDEA excess cost threshold. The final amount verifies whether or not the district met the FY15 IDEA excess cost threshold. Any district that did not meet the FY15 excess cost threshold should contact its IDEA grant coordinator. 45

Federal Finding March 19, 2015 Citation: Excess costs are those costs that are in excess of the average annual per-student expenditure in an LEA during the preceding school year for an elementary school or secondary school student, as appropriate, and that are computed using the method described in 34 CFR 300.16. As part of its general supervisory responsibilities under 34 CFR 300.149 and 300.600, the SEA must ensures that LEAs: (1) as part of their application for Part B funds, include an assurance to the SEA that it will comply with the requirements related to excess costs, and (2) are computing excess costs in a manner consistent with Appendix A of the IDEA regulations and using IDEA funds only for the excess cost of providing special education and related services for children with disabilities as required by 34 CFR 300.16 and 300.202.

Status of the Excess Cost Finding The letter of findings acknowledged that given the length of time between OSEP s monitoring and this letter, the State may have changed policies and/or procedures. ISBE provided corrective action documentation (policies/procedures, excess cost worksheets, instructions, webinars, tip sheets, notifications). We are waiting on a response from OSEP.

Excess Cost An Ongoing Process August/September release of the IDEA excess cost worksheets/instructions. This timeframe allows for the revised AFR forms and final, verified fall enrollment and child count data from the previous fiscal year. FY16 will also include the release of an excess cost webinar. October AFRs are due to ISBE, districts will have the data to complete most of the excess cost worksheet. December special education child count is due to ISBE, districts will have the final data needed to complete the IDEA excess cost worksheet. January the IDEA excess cost forms are due to ISBE. When the IDEA excess cost worksheets are complete, the districts will have the excess cost threshold for the current year, i.e. the amount of local (state/local) funds that must be expended on students with disabilities. District should track local spending.

Maintenance of Effort (MOE) 34 CFR 300.203 300.205

MOE in a Nutshell Local (local or state/local) spending on students with disabilities cannot decrease from year-to-year. Regulations specify allowable MOE exceptions: Voluntary departure of staff Termination of obligation to provide an exceptionally expensive program to a student or students with disabilities Termination of costly expenditures for long-term purchases Also, if per capita remains the same, MOE is met. Failure to meet MOE requires repayment of federal funds in the amount of the MOE shortfall.

July 1, 2015-34 CFR 300.203 The MOE regulations were amended July 1, 2015. MOE eligibility and MOE compliance Illinois districts documented MOE eligibility prior to the regulatory revision Detailed four methods for meeting MOE Local only option was available for Illinois districts prior to the regulatory change Clarified that failure to meet MOE does not lower the MOE level (2012 letter to Kathleen Boundy) Did not impact Illinois districts Districts were notified and the letter to K Boundy was posted on the IDEA grant webpage in 2012

MOE - Eligibility and Compliance MOE Eligibility A district is eligible to receive IDEA funds by maintaining local effort. This is based on a comparison of the most recent complete fiscal year (up to 2 years) with the current budgeted amounts. MOE Compliance - Verification that a district maintained local effort based on a comparison of the finalized fiscal records for two years. (MOE worksheets are mailed to districts/cooperatives)

Local Effort When comparing fiscal years, IDEA maintenance of local effort can be achieved through four options: The state and local expenditures are the same or greater than the previously expended state and local expenditures The local expenditures are the same or greater than the previously expended local expenditures. The state and local per capita costs are the same or greater than the previously expended state and local per capita actual costs. The local per capita costs are the same or greater than the previously expended local per capita actual costs. The MOE compliance data provided by ISBE is based on the AFR, which does not separate expenditures by state and local. Any computation of IDEA MOE compliance based on local (no state) expenditures, must be completed at the local level.

Keeping It Timely Don t let a negative MOE delay submitting an otherwise substantially approvable grant. Resolve the MOE issue as soon as possible Work with the ISBE grant team (Pam!!) Avoid holding up approval and/or amendments MOE resolved by September 30 th. Before throwing in the towel, contact the grant team.

Additional Resource Links ISBE www.isbe.net Special Education Services www.isbe.net/spec-ed IDEA Grants http://www.isbe.net/spec-ed/html/idea_part-b.htm Rules - www.isbe.net/rules Part 100 - accounting/budgeting/financial reporting/audits) http://www.isbe.net/rules/archive/pdfs/100ark.pdf Fiscal Procedures Handbook - http://www.isbe.net/funding/pdf/fiscal_procedure_handbk.pdf

Contact Information Special Education Services 217/782-5589 IDEA Grant Coordinators Dawn Camacho dcamacho@isbe.net Tammy Greco tgreco@isbe.net Felicia Malloy fmalloy@isbe.net MOE Consultant Pam Jurkoshek pjurkosh@isbe.net

Questions