ARRA ESEA Update May 2009

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ARRA ESEA Update May 2009 Powered By Docstoc
					             American Recovery and
               Reinvestment Act
                ARRA ESEA Title I Update
                      May 5, 2009
            Nebraska Department of Education

4/25/2009                                      1
 ARRA Update General Information
• Title I and IDEA Allocations are on the NDE
  homepage (ARRA)
      – IDEA application open on May 1
      – ESEA Title I application open on May 5
• School Lunch Equipment applications are due
  May 15
• Governor and Legislature determining State Fiscal
  Stabilization Funds
            • Anticipate application for these funds will be through the
              grants management system (GMS)

4/25/2009                                                                  2
                  Latest Guidance
• Guidance from the Federal Government
  continues to be developed
      – Uses of funds and reporting requirements
• and
      – Official sites for all ARRA information and
      – Guidance
• NDE homepage has links to all of the above at:
4/25/2009                                             3
                    A-133 Audits
• Any district receiving $500,000 or more in
  federal funds must have an A-133 single audit
      – This includes federal funds from any program
        (IDEA, NCLB, School Lunch, ARRA, REAP, etc.)
      – Anticipating more districts will need A-133 audits
        with the additional ARRA funds
• A-133 audits review both financial and
  program compliance

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                 ARRA and A-133
• Federal Government Accounting Office (GAO)
      – Revising the single audit (A-133) process to
        ensure ARRA activities receive special emphasis
        and audit scrutiny

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            District Budget Authority
• ARRA funds become available when
  applications are approved
• NOTE: If ARRA funds are spent within the
  2008-09 budget year, the district’s budget
  (spending authority) may need to be amended
• NEW – some expenditures are allowable from
  February 17th (date ARRA was signed)
      – Contact the NDE program staff for assistance

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   ARRA ESEA Consolidated Application
• Allocations
      – The ARRA ESEA Allocations Page will open with
        funds only for the Title I program
            • ARRA Title II, Part D (Enhancing Education Through
              Technology) funds will be added before July
            • USDE has not yet determined whether the flexibility
              options (REAP-FLEX and Section 6123) in NCLB apply to
              ARRA funds
      – Districts will need to amend ARRA ESEA when Title
        II, Part D funds are available
4/25/2009                                                             7
            ARRA Title I Allocations
• Posted on the NDE homepage (ARRA)
      – Needed to be calculated as part of the overall Title
        I allocation
      – Preliminary figures for NCLB Title I funds that will
        be allocated later and used in the NCLB
        Consolidated Application
• District must have a poverty level of 5% to be
  eligible for ARRA Title I funds

4/25/2009                                                  8
                     ARRA Title I
• USDE considers the ARRA Title I and NCLB Title
  I (regular) funds to be for “one project” in the
  2009-10 school year
      – The carryover provision allows the use of funds
        allocated now to be used until September 30,
        2011 (ARRA is a one-time grant)
• ARRA and NCLB funds have separate account
  numbers and must be tracked separately

4/25/2009                                                 9
      Implications and Complications
• One project with two sources of funds
      – Different timelines:
            • ARRA ESEA Title I must be approved before NCLB
              Consolidated Application can be completed due to
      – Same rules apply so 15% carryover limitation
        affects the “one project”
      – Nonpublic Participation Forms
            • This year already included ARRA and NCLB funds

4/25/2009                                                        10
   ARRA ESEA Consolidated Application
• Opens May 5 and is due June 20
• Abbreviated “consolidated” application
      – Goals and Needs
            • Applies only to Title I until amending in Title II, Part D
            • Only two tabs:
                – School Reform
                – Nonpublic Participation
      – Only 1 application now
            • ESEA Title I

4/25/2009                                                                  11
                   School Reform
• Provides information on possible reporting
  requirements (no final guidance yet)
• Asks for general description of the uses of
  ARRA funds to support:
      – District’s Title I program
      – School Reform areas (see next slide)
• May need to be more specific when reporting
  requirements are known

4/25/2009                                       12
 Four Areas of the Reform Agenda
• Teacher effectiveness and ensuring that all schools
  have highly qualified teachers
• Higher standards and rigorous assessments that will
  improve both teaching and learning
• Intensive support, effective interventions, and
  improved achievement in schools that need it the
• Better information to educators and the public, to
  address the individual needs of students and
  improve teacher performance
            Nonpublic Participation
• For districts with nonpublic schools or having
  resident low-income students attending
  nonpublic schools
• All the NCLB rules apply
      – Equitable participation of nonpublic students and
        staff for Title I and Title II, Part D
      – Title I’s Targeting pages will figure allocations for
        nonpublic students and the percentage of any
        district set-asides
4/25/2009                                                       14
            ARRA ESEA Title I Application
• Same pages as the NCLB Consolidated
• Responses must address only the use of ARRA
• Amendments to ARRA ESEA Title I allowed but
  no changes will be permitted to the Targeting

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                    Program Information
• ARRA ESEA Program Information
      – Questions similar to NCLB Title I
            •   Activities to be funded with ARRA
            •   Preschool Information
            •   Summer services
            •   Nonpublic services
            •   Teacher effectiveness (professional development)
            •   Services for Neglected and homeless
            •   School Improvement

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                  Title I Targeting
• Only one set of data can be used for ARRA and
  NCLB Title I targeting
      – Data for public and nonpublic poverty by school
        attendance area
      – Any single date between January 1, 2009 and June
        1, 2009
• The ARRA ESEA and NCLB Consolidated
  Applications will use the same Targeting data

4/25/2009                                              17
                  Targeting Data
• When the ARRA ESEA Application is
  submitted, the Targeting pages will be locked
      – Locked pages can be changed (Returned for
        Changes) but will be Locked (not amendable) once
        the original ARRA ESEA application is approved
• Districts must identify the buildings to be
  served in the 2009-10 school year with “all”
  Title I funds, not just the ARRA funds

4/25/2009                                              18
            New Schoolwide Projects
• An accelerated timeline for new schoolwide
  projects has been announced
• Using the 2009-10 Targeting data, a building
  with 40% poverty is eligible* to become a
  schoolwide (*see next slide)
• Districts anticipating a building becoming a
  schoolwide should mark it as schoolwide in
  the ARRA ESEA Targeting Step 4

4/25/2009                                        19
            Other Criteria for Eligibility
• Schoolwide Eligibility:
      – 40% poverty (public only or public and nonpublic)
      – Building must have an active school improvement
      – There must be an improvement plan that can be
        adapted to meet NCLB Title I requirements
      – At least 80% of the teachers must support moving to a
        schoolwide (this must be documented)
      – For schools that submitted the Schoolwide Intent
        form by May 1, the schoolwide plan must be
        submitted by June 1 (in time for a peer review)
4/25/2009                                                   20
        Connecting the Targeting Data
• The Targeting data from the ARRA ESEA Title I
  Application, upon approval, will be copied into
  the NCLB Consolidated Application, when it is
• The NCLB Application will have new tabs that
      – ESEA and NCLB Title I allocations combined for set
        asides and building allocations
      – Display the amounts under ARRA and ESEA

4/25/2009                                                21
                Combined ARRA and ESEA
• Targeting Step 4 combines ARRA and ESEA
  funds in the NCLB Consolidated Application
      – Used for allocations among the buildings
      – Amounts for nonpublic
      – District set-asides that are required
            •   Neglected funds
            •   Parent Involvement
            •   School Improvement (if necessary)
            •   Homeless
      – Set-asides that are not required
4/25/2009                                           22
                ARRA Budget Pages
• Allowable activities remain the same as the NCLB
  Title I
• Administrative Costs – a 5% limit on ARRA funds
  used for Title I administration costs
• Indirect costs will use the 2008-09 approved
  indirect cost rate since these funds can be spent
  during the 2008-09 budget year
      – Indirect costs may be over “recovered” due to the
        increased funds and may need to be adjusted in
        future years

4/25/2009                                                   23
                     ESEA Title I
• Staff – include only ARRA funded (see next
      – No scheduled payments for staff funded with
        ARRA funds
• Equipment – include only ARRA funded

4/25/2009                                             24
               Funding Staff with ARRA
• Supplement, not supplant applies to ARRA funds
            • Entire guidance from U. S. Department of Education on
              Supplement, not supplant is provided at the end of this
• There are instances, in Targeted Assistance
  Programs, where the district funded portion of
  Title I staff can be ARRA funded from Feb. 17th on
  (see next slide)
• Any staff funded with both ARRA and NCLB funds
  must use time and effort records

4/25/2009                                                               25
        Criteria for use of ARRA Funds
• ARRA funds can be used to cover the district
  funded portion of salary and benefit without
  supplanting only IF
      – The Title I program is fully operational as Title I (all
        students served are eligible, parent compacts for all,
      – The original 2008-09 district Title I allocation was
        insufficient to fully fund the teacher
      – The 2008-09 Title I budget contains only salary and
        benefits (no supplies, equipment, etc.)
• These criteria indicate the district’s decision was
  made at the time of budgeting for 2008-09
4/25/2009                                                          26
   Title I Staff and Flexibility Options
• If a district used one of the flexibility options
  (REAP-FLEX or Section 6123) in their 2008-09
  NCLB Consolidated Application to move funds to
  Title I in order to fully fund a Title I teacher, the
  district cannot use ARRA funds now to cover
  those costs
      – The flexibility options cannot be changed at this time
        of the year since payments would have been made
      – The position was fully funded in the 2008-09
        application although from multiple sources

4/25/2009                                                        27
               Payments for ARRA
• ARRA payments are through the GMS
      – Like the NCLB payments
      – Reimbursement Requests when funds have been
        spent with supporting documentation
      – Will need the names of all staff paid with ARRA
        funds in the supporting documentation
      – No scheduled payments for salaries and staff
        funded with ARRA funds

4/25/2009                                                 28
• Assurances
      – All NCLB program assurances are still included as
        they may be needed if the flexibility options do
        apply to ARRA Title II, Part D when it is added
• NEW assurance – “The district will file 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.”
4/25/2009                                                   29
                    Financial Reporting
• Awaiting guidance on what will be required
  for the ARRA quarterly reports
      – The amount of ARRA funds spent is included in
        the information we’ve received and we do not
        know if this will mean quarterly reimbursement
            • Attempting to create a district quarterly report for all
              ARRA grants rather than separate program reports
• Close-out of ARRA ESEA is September 30, 2010
  and carryover is allowed

4/25/2009                                                                30
• The Title I carryover limitation of 15% applies
  to the “one project” of ARRA and NCLB Title I
      – Still working on a way to connect the close-out of
        ARRA and NCLB applications to simplify this
• Also waiting on final guidance about waivers
  for districts to exceed the 15% carryover
4/25/2009                                                    31
    Supplement, Not Supplant (SNS)
USDE Guidance:
  A determination of supplanting necessitates determining
  what activities a district would conduct with non-Federal
  funds if it had no Title I, Part A funds. Generally, a district
  may not use Title I, Part A funds for activities that it would
  have conducted in the absence of Title I, Part A funds.
  Several situations give rise to a presumption of supplanting:
  (1) the activity is required by local, State, or other Federal
  law; (2) the district conducted the activity in the prior year
  with non-Federal funds; (3) the district uses non-Federal
  funds to provide the same activity for non-Title I students
  or in non-Title I schools that it provides with Title I Part A
  funds for Title I students in Title I schools.

4/25/2009                                                       32
       SNS USDE Guidance Continued
    Thus, the use of Title I, Part A ARRA funds for an
    activity that a district provided in the prior year
    with non-Federal funds generally gives rise to a
    presumption that the district would have
    continued to use non-Federal funds to conduct
    the activity this year in the absence of Title I, Part
    a ARRA funds and, therefore, the use of Title I,
    Part A funds for that activity would constitute
    supplanting. The district may overcome this
    presumption, however, under the following

4/25/2009                                                33
       SNS USDE Guidance Continued
• The district can demonstrate that there was a
  reduction in the amount of non-Federal funds
  available to the district to pay for the activity
  previously supported by non-Federal funds or
  the district can demonstrate that its
  educational priorities with respect to its use of
  non-Federal funds have changed.

4/25/2009                                         34
       SNS USDE Guidance Continued
• The district makes the decision to eliminate the activity
  without taking into consideration the availability of Title I,
  Part A funds, as documented by fiscal and programmatic
  records confirming that, in the absence of Title I, Part A
  funds, the district would have eliminated the activity.
  These records, for example, might document the reduction
  in non-Federal funds or explain what priorities changed to
  warrant a shift of non-Federal funds away from those
  priorities and the districts reasons for choosing to eliminate
  non-Federal support for the priorities. Please note that
  such documentation must be contemporaneous with the
  district’s decision-making process; it is very difficult to
  rebut a presumption of supplanting after the fact.

4/25/2009                                                      35
       SNS USDE Guidance Continued
• The activity now paid with Title I, Part A funds is
  allowable under Title I, Part A and consistent with all
  Title I fiscal and programmatic requirements. This
  means, for instance, that a teacher formerly paid from
  non-Federal funds must be (1) engaged in activities
  that are allowable under Title I, Part A; (2) meeting the
  academic needs of Title I students identified through a
  schoolwide programs school’s comprehensive needs
  assessment or providing supplemental services in a
  targeted assistance school; and (3) conducting
  activities consistent with the district’s application
  approved by the State.

4/25/2009                                                 36
       SNS USDE Guidance Continued
• Using Title I, Part A funds for the activity also
  meets the general standards established in Office
  of Management and Budget (OMB) Circular A-87
  Cost Principles for State, Local, and Indian Tribal
  Governments (OMB A-87). OMB Circular A-87
  requires that the use of funds for a specific
  purpose be necessary and reasonable for the
  proper and efficient performance and
  administration of the program and be authorized
  and not prohibited under State and local laws or

4/25/2009                                           37

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