Three Pieces of the Fiscal Puzzle

Three Pieces of the Fiscal Puzzle 1 IDEA/TITLE I ENTITLEMENTS

General & Special Education Funding Sources Local Tax base Covers the majority of expenditures State Categorical Aids High Cost fund Federal IDEA Entitlement High Cost fund Medicaid 2

General Fund Revenue General Revenue for an LEA with a student population of about 3,260 Local Taxes Equalization/State Categorical Aids Other Revenue All Title Grants 51% 45% 1% 3% 3

Funding source break down for an LEA with a student population of about 3,260 $2,911,841 Special Education Funds Local State IDEA Medicaid $1,124,098 For this LEA, special education costs for a fiscal year totaled $4,636,402 63% 24% 11% 2% $513,459 4 $87,004

FUND 27 5 SPECIAL EDUCATION FUNDING SOURCES

DEFINITION 6 Only the excess costs of providing special education and related services may be attributed to Fund 27. If the cost would exist regardless of a district having students with IEPs, then the cost does not belong in Fund 27. Fund 27 is special education and related services.

IDEA Entitlement Funds Flow-Through (FT) Preschool (PS) Funding Sources 7 Medicaid State Special Education Categorical Aid Special Education High Cost Aid

IDEA Flow-through and Preschool 8

SEA s Award 34 CFR 300.700 & 300.800 State Level Activities 300.704 (b) / 300.804 State Administration 300.700 (a) / 300.800 LEA Entitlement 300.705 / 300.815 High Cost Aid 300.704 (c) Statewide Initiatives RTI Center Mediation Regional Service Network WSPEI 9

10 Entitlement funds under IDEA are awarded on a noncompetitive basis for programs and services to students with disabilities Preschool (PS) Provides funds for special education services to children ages 3 to 5 Flow-through (FT) Provides funds for special education services to children ages 3 to 21 Types of IDEA Entitlement Grants

11 In Wisconsin, the LEA with FAPE responsibility is the only subrecipient of the IDEA entitlement grants Under Wisconsin statute, the following agencies are responsible for FAPE: School districts Independent charter schools (2r) Department of Corrections Department of Health Services Other agencies, such as CESAs and CCDEBs, are not responsible for FAPE and are thus not eligible for IDEA entitlement Eligibility for IDEA Entitlement

Base Payments Each LEA generates a base amount established with child count data reported in the late 1990s Base Payments LEA Entitlement Funds IDEA Increases Since the base amounts were established, the award to Wisconsin has increased, creating new funds IDEA Increases 85% Enrollment Based 15% Poverty Based 85% Enrollment & 15% Poverty Count IDEA funds not obligated for base payments are distributed based on an LEA s total student enrollment and student poverty count numbers 12

13 This is an example of an LEA s allocation calculation for IDEA flow-through funds Base Pay Amount Based on 1999 Child Count 66 Students Total Student Enrollment 85% of the new funds 4,500 Students Title I Poverty Count 15% of the new funds 1,000 Students Total FT Allocation Base + New Money $155,063 $293,756 $51,840 $500,659

IDEA Grant s Availability Each Award Available 27 Months Forward Funding: 3 months (July 1 Sept. 30) Award Period: 12 months (Oct. 1 Sept. 30) Tydings Period: 12 months (Oct. 1 Sept. 30) 14

Unspent FY 2013 Award July 1, 2014 to Sept. 30, 2015 - $500 Expends $500 Unspent FY 2014 Award July 1, 2014 to June 30, 2015 - $100,000 Expends $9,500 FY 2015 Award July 1, 2014 to June 30, 2015 - $100,000 Unspent FY 2013 Award July 1, 2013 to June 30, 2014 - $25,000 Expends $24,500 FY 2014 Award July 1, 2013 to June 30, 2014 - $100,000 FY 2013 Award July 1, 2012 to June 30, 2013 - $100,000 Expends $75,000 15

Carryover Rules (IDEA) 16 Each federal funding source has its own rules on: Funding Availability Carryover IDEA s Rules: Funding is available for 27 months Total amount of allocation is available for the 27 months No limit on the amount that carries over into the next fiscal year

Obligation Period Obligation: A transaction that requires payment. 17 Obligation Period : The same as the 27 months of grant availability. Allowed Grant Charge: Transaction on August 15; Grant began on July 1 Not Allowed Grant Charge: Transaction on June 25; Grant begins on July 1 Transaction on October 15; Grant ended on September 30

LEA Obligation Period 18 Begins July 1 if LEA submits IDEA application in substantially approvable form by July 1

LEA Obligation Period 19 AVAILABILITY OF FUNDS July 1, 2011 September 30, 2013 OBLIGATION PERIOD August 1, 2011 September 30, 2013 Cost A July 15 NOT ALLOWED Cost B August 15 ALLOWED

IDEA Allowable Costs 20 The federal regulation at 34 CFR 300.184 governs the expenditure of IDEA funds. Only the excess costs of providing special education and related services may be charged to the flow-through or preschool entitlement grants. Individual student services must be IEP driven.

Examples of Allowable Costs Special Education Staff (Directors and Assistant Directors, teachers, paraprofessionals) Related services (Physical Therapy, Occupational Therapy, Speech & Language) Assistive Technology equipment Professional Development Student transition services (work experience) Construction Non-Capital and Capital Equipment Software Curriculum 21

Allowed Contracting Costs LEAs may contract with a CESA, CCDEB, or another LEA for any special education services LEAs may contract with a private vendor for services provided directly to the student in: Nursing, Occupational and Physical Therapy Audiology Services and Educational Interpreters Speech / Language Orientation and Mobility Instruction Transition Services for 18 to 21-year-olds. Substitute Teachers and Paraprofessionals 22

Common Unallowed Costs Flat-rate open enrollment tuition amount Medicaid Administration Prorating equipment LEAs may NOT contract with a private vendor for services provided directly to the student in: Psychological Services or Autism Services 23 LEAs may NOT contract with a private vendor for the following positions: Teachers Guidance Counselors Social Workers

Real Time Reimbursement 24 Expenditure is incurred, claim can be submitted immediately after the transaction for reimbursement Technical Assistance Page: http://sped.dpi.wi.gov/sped_lpp-budgets

Medicaid 25

Types of Medicaid Payments Interim SBS Billing (School Based Services) Payment for student-specific expenditures. This reimbursement is based on the billing submitted by the individual providing the direct services. Medicaid Administrative Claiming (MAC) Not student specific, intended to cover administrative overhead. Payment is based on a prior year and sent in a lump sum to the receiving agency. Cost Settlement (SBS) Not student specific, intended to resolve the differences between submitted claims and final eligibility. 26

Medicaid Payment Type Source Code Interim SBS Billing (School Based) Code if transited through a CESA 27R 000 000 780 27R 000 000 581 Medicaid Administrative Claiming (MAC) Code if transited through a CESA 10R 000 000 780 10R 000 000 581 Cost Settlement (SBS) Code if transited through a CESA 10R 000 000 780 10R 000 000 581 27

Medicaid Coding Instructions 28 Beginning with fiscal year 2013-14, all MAC or Cost Settlement payments or recoupments must be booked to fund 10. All interim SBS payments or recoupments (regardless of year) will continue to be booked in fund 27. For additional information and examples, please view http://sped.dpi.wi.gov/files/sped/pdf/medicaid-coding-ta.pdf The information is also available as a recorded webinar http://sped.dpi.wi.gov/files/sped/av/coding-medicaid.wmv

High Cost & State Categorical Aid 29

Special Education Categorical Aid State categorical aid program 30 Eligible Entities: Districts, CESAs, CCDEBs, and 2r charters Reimbursement of prior year expenses Aid is prorated because costs exceed appropriation Approximately 27 cents to the dollar Eligibility generally stricter than IDEA Administered by School Financial Services Team

Categorical Aid Eligible Expenditures Salary and benefits of entities own employees Special education teachers and aides 31 Pupil services (psychologists, social workers, nurses, guidance counselors, OT/PT) Special education portion of all but OT/PT set by Act 221 formula OT/PT eligible only for IEP-required service time Special education supervisors/coordinators Eligibility based on assignment and licensure Special education transportation Separate from regular transportation Cannot claim same student for pupil transportation aid

Categorical Aid Eligible Expenditures Contracted services OT/PT 32 Act 105 services: orientation/mobility training, interpreter, audiology, speech/language therapy, transition Act 255 services: paraprofessionals and substitute teachers http://sped.dpi.wi.gov/files/sped/pdf/act-105-funding.pdf Salary and benefits only Must be from private vendor (not CESA, CCDEB, or another district) Homebound student instruction Includes staff travel

Categorical Aid Non-Eligible Expenditures Salary and benefits Staff without proper license for assignment Professional development/credit reimbursement 33 Non-instructional time (e.g. regular ed teacher in IEP meeting) All other contracted services Open enrollment flat-rate tuition Supplies and equipment Sole exception: special education vehicle purchase, requires approval from DPI

Categorical Aid Reporting 34 PI-1505-SE (annual) and PI-1504-SE (budget) reports Eligible costs coded as project 011 Non-eligible costs coded as project 019 Services purchased from CESA/CCDEB or another district are not eligible because that entity can claim the aid and transit it back to you (source 516) Other project codes for IDEA, CESA/CCDEB grant transits, package programs

High Cost Aid (State & Federal) Student-specific special education service costs for an individual student in a single year must exceed $30,000 35 The amount over $30,000 is eligible for reimbursement on a pro-rated scale Reimbursement is after-the-fact and paid a full year after the costs were incurred Timeline for reimbursement is established in Wisconsin statute

High Cost Aid (State & Federal) 36 Direct special education instruction or related services Services eligible for reimbursement must be documented in the student s IEP Examples include: Autism Educational Services, Educational Interpreters, Extended School Year (ESY), Job Coach, Paraprofessionals, Remodeling, Transition-Employment Skills, Transportation A list of reimbursable costs: http://sped.dpi.wi.gov/files/sped/pdf/highcost-allowables.pdf A list of the base cost special education expenditures: http://sped.dpi.wi.gov/files/sped/pdf/highcost-base-cost.pdf

Categorical Aid Resources SFS Consultant: Daniel Bush daniel.bush@dpi.wi.gov, 608-267-9212 37 Resources (eligible costs, valid license codes, WUFAR examples) http://sfs.dpi.wi.gov/sfs_specedn Reporting http://sfs.dpi.wi.gov/sfs_se_report

IDEA Budget & Claiming Software 38

Version 1.0

Claim Submission Technical Assistance: http://sped.dpi.wi.gov/files/sped/pdf/idea-claim-process.pdf Version 1.0

Version 1.0

Claiming Flexibility 10% Rule (34 CFR 80.30) Acceptable Overage: Approved budget: $6,151 10% rule: the LEA can claim in excess of the approved line items by $615 (10%). Aggregate overage is $414, which is less than $615. Not Acceptable Overage: Version 1.0

Version 1.0

Claim ERROR Messages and What They Mean A new claim cannot be created because the LEA's last approved budget amount ($15,633) is greater than the current amount of funds available ($14,633). A budget amendment is required. There are different times during the year when an LEA may have an approved budget greater than the amount available. This may occur when final indirect rates and carry over amounts are added into the software. A budget amendment must be submitted and approved before the LEA may submit a claim. Unable to create claim. No approved budget for Preschool budget and year 2014 This message appears when the LEA has not submitted a budge type for the claim being chosen. This may be because a budget was created by the LEA but the submission button never selected. Version 1.0

Claim ERROR Messages and What They Mean Unable to create claims for this budget type/year until the amendment submitted on x/xx/xxxx has been reviewed by DPI. This message appears when the LEA has a budget amendment submitted to DPI for review. Because the claim is based on the last approved amount, a submitted budget amendment may be vastly different than the claim amounts the LEA is viewing. As soon as the budget amendment is reviewed and approved, the claim will be updated with the approved budget amounts. Version 1.0

Direct Costs The Cost of Doing Business 54 Federal grants fund specific activities related to meeting the goals of the project Title I teacher in a Title I targeted assistance school Indirect Costs Grant activities generate operational costs such as supervision and payroll, but are not directly related to conducting the grant activities

Recovering Funds for Indirect Costs 55 Indirect Cost Recovery: Acknowledgement by the Federal Government that federally funded programs incur more than just costs directly related to the project Depends on federal grant type Sub-recipient must have an established indirect rate This rate / percentage can be applied against the federal grant to recover funds to offset it s operating costs Outlined in OMB Circular A-87

Establishing an Indirect Rate 56 Two rates determined annually by DPI DPI s Indirect Cost Plan Restricted and Unrestricted rates Based on audited financial data collected from the PI-1505 annual reports Department of Ed Restricted Rates (lower) Used for federal grants that have a supplement not supplant provision (34 CFR 76.563)

IDEA Budget (FT, PS, CEIS) http://dpi.wi.gov/files/wisegrants/pdf/indirect-idea.pdf 57

First Step: Second Step: The 2.659% is the effective indirect rate established in the last approved budget 58

Indirect Cost Recovery Technical Assistance Recorded Webinar: http://sped.dpi.wi.gov/files/wisegrants/av/indirect-cost-recovery.wmv Indirect Budgeting, Claiming and Coding Instructions: http://sped.dpi.wi.gov/files/wisegrants/pdf/indirect-handout.pdf Version 1.0

FUND 10 60 GENERAL INSTRUCTION FUNDING SOURCES

141 Title I-A PROJECTS 61 Federal funds for supplementary education to students who are educationally disadvantaged or at risk of failing to meet the state standards. 365 Title II-A Federal funds for professional development in core academic areas and/or hiring highly qualified teachers for the purpose of closing student achievement gaps 391 Title III-A Federal funds to close achievement gaps for limited English speaking students

PROJECTS 62 341 Coordinated Early Intervening Services Federal IDEA funds to provide academic or behavioral interventions to students without disabilities who have been identified, through a general education screening process, as struggling and at risk for failure. 347 or 341 Title I Schoolwide Set-Aside Federal IDEA funds to support a Title I Schoolwide school s activities per the school s schoolwide plan.

ESEA and Title I, Part A Elementary and Secondary Education Act (ESEA) of 1965. 63 Title I, Part A funds are targeted to high-poverty school districts and provide supplementary education to students who are educationally disadvantaged or at risk of failing to meet the state standards. Title I Contacts: http://titleone.dpi.wi.gov/t1consultant_dir

Distribution of Funds 64 U.S. Department of Education WI Department of Public Instruction Local School District Title I School

Allocation of Funds to LEAs 65 The formula is based on: The state s average per pupil expenditure and The LEA s count of children from low-income families. US Census Bureau Small Area Income and Poverty Estimates (SAIPE) are used to determine poverty.

SAIPE Estimates the number of children ages 5-17 in families in poverty. Will not match Free and Reduced-Price Lunch data or the district s enrollment data. 66

Allocation of Funds to LEAs 67 Basic Targeted Financial Incentive Concentration LEA Poverty Percentage 15% 14.99% 5.00% 4.99% 2% X X X X X X X X X X X X

Reservations Parent Involvement: Required if the allocation is greater than $500,000. 1% must be reserved for parent involvement activities. Other Services: Including, but not limited to centralized services, services to eligible students who do not attend Title I schools (i.e. homeless or migrant students), additional resources for Title I Focus and Priority Schools, etc. Administrative Costs: (Optional) Approved indirect rate + up to 10% of the allocation for direct administrative costs.

Reservations

Title I School Eligibility Based on the number of children ages 5-17 in poverty in an attendance area (school). 70 Includes children who attend private schools both inside and outside of the district and live in a school s attendance area. Enrollment count for all students must be done on the same date.

Title I School Eligibility 71 LEAs may use one of the following measures: Census data; Free and reduced-price lunch data; W2 data; Medicaid data; or a Composite of the above measures. Private schools do not have to use the same measures as the LEAs.

BLUE SCHOOL Public Enrollment 447 Students Private Enrollment 84 Students Total Enrollment 531 Students Low-Income Public 218 Students Low-Income Private 8 Students Low-Income Total 226 Students Low-Income Total 226 Students Total Enrollment 531 Students Percent Low-Income 42.56% Title I Enrollment Calculation 72

RED SCHOOL Public Enrollment 307 Students Private Enrollment 41 Students Total Enrollment 348 Students Low-Income Public 151 Students Low-Income Private 14 Students Low-Income Total 165 Students Low-Income Total 165 Students Total Enrollment 348 Students Percent Low-Income 47.41% Title I Enrollment Calculation 73

GREEN SCHOOL Public Enrollment 180 Students Private Enrollment 7 Students Total Enrollment 187 Students Low-Income Public 76 Students Low-Income Private 2 Students Low-Income Total 78 Students Low-Income Total 78 Students Total Enrollment 187 Students Percent Low-Income 41.71% Title I Enrollment Calculation 74

76 Title I School Eligibility Ranking LEAs serve schools in rank order based on poverty data. LEAs must service all schools with a poverty rate of 75% or higher. An LEA s poverty average Grade Span Grouping Using the LEA s Poverty Average Grade Span Grouping Using the Grade Span s Poverty Average 35% Rule Less than 1,000 Students Exemption Only One School per Grade Span Exemption Options to Rank Schools

Determining Per Pupil Amounts 77 Per pupil amounts are determined for each school The same per pupil amount can be allocated for each eligible school Smaller per pupil amounts may be allocated for lower poverty schools. A school may not receive a smaller per pupil amount than another school that falls below it in rank order.

Determining Per Pupil Amounts Attendance Area (School) Grade Span % Low Income Per Pupil Amount Attendance Area Allocation Red School 165 low income students K-5 47.41% $502 $82,830 Blue School 226 low income students K-5 42.56% $501 $113,226 Green School 78 low income students K-5 41.71% $501 $39,078 78

Targeted & Schoolwide Comparison Targeted Assistance Program Supplemental instructional services 80 Schoolwide Program Comprehensive strategies Specific students who have been identified as failing Not necessarily lowincome students All students Eligible schools must have 40% or more poverty*

Allowable Costs Salary and Fringe Benefits of staff providing Title I services Teachers Paraprofessionals 81 Contracted costs of staff providing Title I services Instructional media and supplies (supplemental) Training / Travel for staff providing Title I services

82 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. Supplement not Supplant 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?

Grant Period & Carryover Policy 83 Fiscal Year: July 1 to June 30 LEA s Allocation Less than $50,000 There is no limit on the amount of funds that can be carried over from yearto-year. LEA s Allocation Greater than $50,000 LEAs may carryover 15% of the total allocation. LEAs must apply for a waiver to carryover more than 15% if the total allocation. This is only allowed once every three years.

Application Process 84 Helps LEAs determine eligible schools and per pupil amounts; Identifies how funds will be utilized; Must reflect the LEA s needs assessment to improve student academic achievement; and Include equitable private school participation (if applicable)

Title I-A Step 1: Title I-A Budget Menu Plan Reservations: Enter Reservations Amounts 85

Title I-A Budget dpi.wi.gov/files/wisegrants/pdf/indirect-title-i.pdf 86