th
55
IASBO
Annual
Conference
NCLB Funds: What a Business Manager
Needs to Know
May 18, 2006
Robert Wolfe, CPA
Division Administrator
External Assurance Division
Illinois State Board of Education
Ethelene Crawford
Division Supervisor
External Assurance Division
Illinois State Board of Education
1
How We Monitor
Web-Based Self-Monitoring Review:
•
•
•
•
IWAS - https://sec1.isbe.net/iwas/asp/login.asp?js=true
Checklist - http://www.isbe.net/ea/htm/checklist.htm
Proof Indicators http://www.isbe.net/ea/htm/proof_indicators.htm
Sample Monitoring Instrument http://www.isbe.net/ea/htm/Sample%20Monitoring%20Instr
ument.htm
On-Site Visits:
•
•
•
•
Announcement Letter – mailed 45 days in advance followed-up
with call to arrange a mutually acceptable time and date
Exit Conference
Report generated within 90 days of Exit Conference
District allowed 30 days to respond
2
Title I, Part A
Three Fiscal Requirements
To ensure that funds made available under Title I, Part A are
used to provide services that are in addition to the regular
services normally provided by a Local Educational Agency
(LEA) for participating children, three fiscal requirements
related to the expenditure of regular state and local funds must
be met by the LEA. The LEA must –
1.
2.
3.
Maintain fiscal effort with state and local funds,
Provide services in its Title I schools with state and local funds
that are at least comparable to services provided in its non-Title I
school; and,
Use Part A funds to supplement, not supplant regular non-federal
funds.
3
Maintenance of Fiscal Effort (MOE)
The combined fiscal efforts per student of the aggregate
expenditures of the LEA for the preceding fiscal year was
not less than 90 percent of the combined fiscal effort or
aggregate expenditures for the second preceding fiscal
year.
Waiver of MOE
1.
2.
Exceptional or uncontrollable circumstances such as a
natural disaster; or
A precipitous decline in the financial resources of the
LEA.
4
Comparability
A LEA may receive Title I, Part A funds only if it uses State
and local funds to provide services in Title I schools that,
taken as a whole, are at least comparable to the services
provided in schools that are not receiving Title I funds.
Criteria for Meeting Comparability
District-wide salary schedule;
Policy to ensure equivalence among schools in teachers, administrators,
and other staff; and
Policy to ensure equivalence among schools in the provision of
curriculum materials and instructional supplies.
Comparability measured by:
Student/instructional staff ratios
Student/instructional staff salary ratios
Instructions
http://www.isbe.net/ea/htm/fy06_title_I_comparability_instructions.rtf
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Supplement-Not-Supplant
Targeted Assistance Schools:


Title I funds must be used only to supplement, and in no
case supplant, the level of funds that would, in the absence
of Title I, be available from non-federal sources for Title I
students.
LEA is not required to provide Title I services using a
particular instructional method.
6
Supplement-Not-Supplant
Schoolwide Program Schools:
 Are not required to provide supplemental service
to targeted children
 Must use Title I funds only to supplement the
amount of funds that would, in the absence of
Title I funds, otherwise be made available for that
school (including funds needed to provide
services required by law for disabled children and
LEP children)
 Demonstrate that local funds are allocated based
upon the same amount per pupil in same
programs as non-project schools.
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Presumption of Supplanting
(These are rebuttable)
Schoolwide Program Schools:
 An LEA has used Title I funds to provide services that the
LEA was required to make available under federal, State, or
local law.
 An LEA used Title I funds to provide services that the
LEA provided with non-federal funds in the prior year(s).
 An LEA has used Title I funds to provide services for
participating children that the LEA provided with nonfederal funds for non-participating children.
8
Non Public School Participation
Does the LEA comply with the requirements for
private school participation?
a.
b.
c.
LEA has consulted with appropriate private school
officials as required.
Equitable participation of children and/or teachers in
private schools is provided
Funds are being used to benefit the student and/or
teachers and not to benefit the private school.
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Non Public School Participation
Does the LEA comply with the requirements for
private school participation?
d.
Funds are allocated proportionately for services to public
and participating nonprofit private school children.
District-Wide Instructional Programs
Parental Involvement Reservation
Professional Development Reservation
e.
f.
The LEA exercises continuing administrative control over
funds and property that benefit students enrolled in private
schools.
Determine if each nonpublic school within the public
school district participating met the requirement of the use
of equipment and materials for secular, neutral, and non
ideological purposes.
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District:
Worksheet*
Title I Equitable Services
1.Districtwide Instructional Program(s) Reservation (does not apply to preschool programs)
In participating public school attendance areas:
# of Private School Children
from low-income families
Total # of Children
from low income families
÷
= Proportion of Reservation
Proportion of Reservation x $ Reservation = for Equitable Services
2.Parental Involvement Reservation
In participating public school attendance areas:
# of Private School Children
from low-income families
Total # of Children
from low income families
÷
= Proportion of Reservation
Proportion of Reservation x $ Reservation = for Equitable Services
3. Professional Development Reservation
In participating public school attendance areas:
# of Private School Children
Total # of Children
from low-income families
from low income families
÷
= Proportion of Reservation
Proportion of Reservation x $ Reservation = for Equitable Services
* This is not an official Department of Education document. It is provided only as an example.
11
34 CFR 74-34 (f) (1)
Inventory records must have the following components:
• Description of the equipment
• Manufacturer’s serial number, model number, or other
identification number
• Revenue source for the equipment
• Acquisition date
• Location and condition
• Unit acquisition cost
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Non-Allowable Expenditures
Title I
Targeted Assistance Program:
 Any expenditure that does not directly benefit the students
identified for as Title I students
 Any expenditure for items that the LEA is required to
provide by State or Local policy
13
Non-Allowable Expenditures
Title I – Low Income
Administrative:
 Any expenditure that would supplant State and Local
funds
 5% per capita
14
Non-Allowable Expenditures
Title II, Part A
 Classroom size reduction salary if the teacher is not highly
qualified
 Professional development activities that:
1. Are not based upon needs assessments or
professional development plan
2. Activities that are not sustained intensive – or have a
positive impact on student achievement
3. Activities not based on scientifically-based research
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Non-Allowable Expenditures
Title II, Part A
4. The term “Core Academic” Subjects include:
• English
• Reading or Language Arts
• Mathematics
• Science
• Foreign Languages
• Civic and Government
• Economics
• Arts
• History
• Geography
Public Law 107-10 [§ 9101 (11)].
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Non-Allowable Expenditures
Title II, Part A
5. Activity not based on effective instructional strategies,
methods and skills
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Non-Allowable Expenditures
Title IV






Incentives
Non-instructional supplies
School assemblies unrelated to Title IV program goals
Materials or activities that promote responsible use of
drugs
Health education textbooks or other materials,
equipment, or services not directly related to violence
or drug abuse education/prevention
Expenditures in excess of 40% for security purposes
18
OMB Circular A-87
Cost Principles for Stare, Local and Indian Tribal Governments
Attachment B
14. Entertainment - Costs of entertainment, including amusement, diversion, and social
activities and any costs directly associated with such costs (such as tickets to shows or sports
events, meals, lodging, rentals, transportation, and gratuities) are unallowable.
27. Meetings and conferences - Costs of meetings and conferences, the primary purpose of which
is the dissemination of technical information, are allowable. This includes costs of meals,
transportation, rental of facilities, speakers' fees, and other items incidental to such meetings
or conferences. But see Attachment B, section 14, Entertainment costs.
43. Travel costs - Lodging and subsistence. Costs incurred by employees and officers for travel,
including costs of lodging, other subsistence, and incidental expenses, shall be considered
reasonable and allowable only to the extent such costs do not exceed charges normally
allowed by the governmental unit in its regular operations as the result of the governmental
unit’s written travel policy. In the absence of an acceptable, written governmental unit policy
regarding travel costs, the rates and amounts established under subchapter I of Chapter 57,
Title 5, United States Code (“Travel and Subsistence Expenses; Mileage Allowances”), or by
the Administrator of General Services, or by the President (or his or her designee) pursuant
to any provisions of such subchapter shall apply to travel under Federal awards (48 CFR
31.205-46(a)).
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Stevens Amendment
Does the LEA comply with the Stevens
Amendment?
a.
Press releases, bid solicitations and other documents
funded in whole or in part with Federal money clearly
state the percentage and dollar amount of
programs/activities financed with federal funds: *the
percentage of the total program cost, *the dollar
amount for the program and * the percent and dollar
amount of the total cost financed by non-governmental
sources.
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