Where Has All the Money Gone?
Administrators’ Management Meeting
September 17-19, 2008
TOPICS
• IDEA Funding and Use of Funds
• Coordinated Early Intervening
Services
• Proportionate Share for PPPSS
Status of IDEA Entitlement Awards
• 99% eligible applicants met 7/1/08
deadline
19 districts completed electronic
submissions by June 1
• 68% of applicants awarded projects
by August 1
9 awards in June
39 awards in July
Review of Applications
Most applicants adequately addressed
all required components of application
with minimal edits
Budget
Assurances
Narratives (Required and Voluntary)
Permissive Use of Funds
• Benefit to Nondisabled Students
• Administrative Case Management
• Coordinated Early Intervening Services
(CEIS)
Benefit to Nondisabled Students
• “Voluntary” provision
• Permits flexibility when 100% IDEA-
funded service or aide provided for SWD
• Incidental benefit derived by nondisabled
students from service or aid for SWD
• Training for teachers/staff NOT a service
or aid for SWD
• 55 districts/agencies chose this option
Administrative Case
Management
• “Voluntary” provision
• Purchase of technology (computer
hardware and software)
• Purposes restricted to
recordkeeping,
data collection, and
related case management activities
• 34 districts/agencies chose this option
Fiscal and Program Accountability
• Project records (3 year retention)
• Fiscal project reports
• Audit reports
• Program reports
Keep records that show
How funds were used
Total cost of the project
Share of costs provided by other
sources
Financial records documenting
compliance
Program records documenting
performance
All records needed to satisfy audit
Most Common Audit Findings
• Inadequate Support of Salaries and Wages
Personnel Activity Reports (PARS) for Multi-funded
Semi-Annual Certifications for 100% IDEA-funded
• Omission of Required Contractual
Language/Forms (i.e., suspension/debarment
language)
• Inadequate Procurement Policies/Procedures
OR Noncompliance With Policies/Procedures
Obligation of Funds
If obligation is for-- Obligation is made--
Acquisition of Date of binding written
Property commitment
Personal Services of When services
Employee performed
Personal Services of When services
Employee performed
Personal Services by Date of binding written
Contractor commitment
Travel When travel is taken
Coordinated Early
Intervening Services
CEIS (Voluntary)
• Use no more than 15% of Part B
• Develop and implement activities
supporting “coordinated early intervening
services” for nondisabled students
needing academic and/or behavioral
support
• 22 districts chose this option
CEIS (Voluntary)
Who is eligible?
• Nondisabled students in grades K-12
(no preschool)
Need additional academic and
behavioral support
May include students who received
special education, but no longer receive
special education
CEIS (Voluntary)
How are children identified?
• Performance on reading and math
assessments
• Disciplinary referrals
• Suspensions and expulsions
CEIS (Voluntary)
Caveats for school-wide interventions!
• Must document CEIS funds used ONLY
for students in need of support
• Other funds must be used for school-wide
interventions for special education
students and students NOT in need of
supplemental support
CEIS (Required)
Significant disproportionality by
race/ethnicity
• identification of children with disabilities (11
districts),
• placement of these children in educational
settings (1 district), and
• disciplinary actions, including suspensions
and expulsions (0 districts)
CEIS (Required)
• Calculations for 2008-09 grant
• Risk Ratios calculated – see handout
• Identification and Placement calculations
based on October 2007 Survey 2 data
• Discipline calculations based on 2006-07
Survey 5 data
• Cut point of 3.5 applied to all categories
CEIS (Required)
• Calculations for 2009-2010
• Hope to use same calculations
• New guidance from OSEP may impact
calculations
CEIS (Required)
• Must use maximum amount (15%) of
Part B funds for CEIS during the
period of availability, regardless of
whether disproportionality resolved
• 15% calculated using sum of Part B (611)
& Preschool (619)
CEIS (Required)
• All CEIS expended from Part B (611)
funds
• Funds used for CEIS must be those
appropriated for the FY following the date
significant disproportionality determined or
from the prior FY
• Serve children in the LEA, but NOT
exclusively, those who were significantly
over-identified
CEIS (Required)
• Districts must
review policies, practices, and
procedures with respect to identification,
placement, and disciplinary actions
taken; and
report publicly any revisions to those
policies, practices, and procedures
CEIS (Required)
• CEIS NOT limited to ONLY students
in those groups significantly over-
identified
Fiscal Considerations (CEIS
Required)
Must use maximum amount of 15%------
calculate using both Part B and Preschool
Part B Flow-through = $ 297,809
+
Preschool Flow-through = $ 30,202
.15 X $ 328,011 =
Set-Aside for CEIS = $ 49,202
Fiscal Considerations (CEIS
Required)
• May not reduce the amount LEA uses for
this calculation by any other amount
required by IDEA.
Example: if flow-through is $1,098,422,
this same amount is used to calculate
CEIS and proportionate share.
Fiscal Considerations (CEIS
Required
• Set-aside funds (15%) must be used
during the period of availability
• Funds must be used for CEIS, even if
significant disproportionality resolved
during the time funds available
Fiscal Considerations (Voluntary
and Required CEIS)
CEIS affects compliance with
“Maintenance of Effort” (MOE)
requirement
• Amount of funds expended for CEIS shall
count toward the maximum amount that MOE
may be reduced
Fiscal Considerations (Voluntary
and Required CEIS)
CEIS affects compliance with
“Maintenance of Effort” (MOE)
requirement
• If LEA uses additional local funds for special
education in place of the Part B funds for
CEIS, this higher level of expenditures
becomes the new MOE base for the
subsequent year
• See examples in Appendix D of Part B
regulations
Reporting Considerations
(Voluntary and Required CEIS)
Districts must report
• # children who received CEIS
• # children received CEIS and received
special education and related services
during the preceding two-year period
Reporting Considerations
(Voluntary and Required CEIS)
• A code (I) has been added to indicate
students receiving Early Intervening
Services funded by IDEA, Part B dollars.
• States are required to track by student
those nondisabled children who received
these services and whether or not they
ultimately were found eligible for special
education and related services.
• Reported on Federal/State Indicator Status
format in Survey 5.
Proportionate Share for
Parentally Placed Private
School Students
Private School Consultation
• How are eligible students enrolled in non-
profit private schools identified?
• How are private school representatives and
parents of children with disabilities informed
of the process?
• The amount of proportionate share
determined and how funds will be used.
Private School Consultation
• How are decisions made with regard to
services offered in the consultative
agreement? (types of services, including
direct service, and any alternate service
delivery)
• How is this information (consultative
agreement) shared with private schools and
parents?
Private School Consultation
• How are affirmations obtained from
representatives of private schools?
Remember—
You must have documentation on file that a
“timely and meaningful consultation
occurred”
and
is signed off by private school officials or by
a representative of private schools.
Eligible Private School Students
• Students enrolled in nonprofit private
schools
• Students who are determined to be
students with a disability
– Initial evaluation and re-evaluation
Eligible Private School Students
Current Data FY 08 Data
• Part B = 8,901 (36% • Part B = 13,871
reduction)
• Preschool = 361 (53% • Preschool = 770
reduction)
Source: FY 09 App’n Source: FY 08 App’n
Proportionate Share
Expenditures
Districts must
track expenditures by FY (first and
second “roll” year)
maintain records of expenditures
determine if roll satisfied
Important to Note--
• Proportionate share funds expended must
meet the special education and related
services needs of eligible students with
disabilities
• IDEA funds are NOT used for
Needs of a private school
Repairs, remodeling, or construction of
private schools
General needs of students enrolled in
the private school
Also…property, equipment, and
supplies purchased under this
provision must be
Administered and under control of
district
Used ONLY for Part B purposes
Removed from the private school when
no longer needed and/or to avoid
unauthorized use
Where have the dollars gone?
Set-aside Proportionate Share Funds
Part B = $11.9 million
Preschool = $176,576
Set-aside Coordinated Early Intervening
Services
Part B = $22.1 million
Thank you
Karen Denbroeder
Exceptional Education and
Student Services
850.245.0475
Karen.Denbroeder@fldoe.org