School-wide Consolidation

2015 ESEA Directors Institute

August 26, 2015

Consolidated Planning & Monitoring

Renee PalakovicDirector of Planning

Renee.Palakovic@tn.gov

Session Objectives

Session Objectives

• Review of:– Purpose of Title I school-wide programs– Flexibility provided through Title I school-wide programs

• School-wide consolidation of funds– Options for consolidation– Federal funds eligible for consolidation

• Single pool of funds– Identifying programs & contributions– Determining IDEA maximum contribution– Reimbursement requests

• Meeting intents and purposes of programs consolidated• Statutory and regulatory requirement changes• Keys to success for consolidation of funds• 2015-16 school-wide consolidation pilot program

Title I School-wide Programs

Purpose of Title I School-wide Programs• Enabling schools with high numbers of at-risk children

to integrate services provided to children from federal, state and local resources– Title I schools with 40% or more poverty– ALL students can benefit from funding– Upgrade the entire educational program– School-wide plan based on comprehensive needs assessment

Flexibility Through School-wide Programs• No identification of students required• Supplement/supplant determined at the school level

rather than the expenditure level• Allows for systematic changes that help to coordinate

services for students• Title I funds are spent on educational services

identified and addressed in school-wide plan• Other school level funds are used to support the

school-wide plan, but retain their unique identity

Consolidation of Funds

School-wide Consolidation of Funds

• Consolidation of funds is an OPTION, not a requirement

• School MUST be operating a Title I school-wide program

• Funds are placed into a single pool to increases flexibility

• Funds included in consolidation lose their identity • Funds must be used to meet the intents and purposes

of grant programs included in the consolidation• Some federal statutory and regulatory requirements

can be eased at the school level

Consolidation Options

• Consolidate only school level federal funds– Funds lose their identity– Must meet the intent and purpose of programs included – Funds can be used to address the educational needs

identified in the school-wide plan

• Consolidate school level state, local and federal funds– Funds lose their identity– Must meet the intent and purpose of programs included– No distinction between federal and non-federal funds– Funds can be used to address any needs identified in the

school-wide plan (may be non-educational)

Federal Funds Eligible for Consolidation• Any federal funds administered by the United States

Department of Education (ED) that can be used to support students in public schools– Formula funds such as

• Title I, Part A• Title II, Part A• Title III• IDEA, Part B• Perkins

– Discretionary (competitive) funds• Must still complete activities within the funding application

• Head Start and National School Lunch CANNOT be included because they are not administered by USDOE

Single Pool of Funds

• A school or LEA determines the programs to be included in the consolidation

• The school-wide plan identifies the programs and amounts to be consolidated

• Funds are combined into a single pool of funds• Funds from the pool are used to support the activities

outlined in the school-wide plan• Expenditures are not “tracked” back to specific

programs within the pool

Single Pool of Funds

School Building Title I Part A Title II Part A IDEA Part B State/Local Funds Building Total

School A$182,535 $25,000 $94,462 $2,048,115 $2,350,112

School B$115,455 $25,000 $27,709 $1,380,884 $1,549,048

School C$181,780 $25,000 $69,272 $1,940,161 $2,216,213

Total Funds Distributed to Individual Schools

$479,770 $75,000 $191,443 $5,369,160 $6,115,373

Single Pool of Funds

• If IDEA, Part B funds are being consolidated– The maximum amount of funds consolidated must be

calculated based on the number of students with disabilities in the school

– School must comply with all other requirements of IDEA, Part B to the same extent as it would if funds were not included in the consolidation

IDEA Allocation

# of SWDs in LEA

# of SWDs in School

LEA Per Pupil

Maximum School Amount for Consolidation

$500,000 500 50 $1,000 $50,000 (50 X $1,000)

Single Pool of Funds

• Reimbursement requests must be submitted for each federal program included in the consolidation

• Amounts requested from each program are based on – Total expenditure from the pool– Percentage of contribution to the pool

• Total building expenditure: $350,000

School Building Title I Part A

Title II Part A

IDEA Part B

State/Local Funds

Building Total

School A $182,535 $25,000 $94,462 $2,048,115 $2,350,112

Percent of Total Contribution 8% 1% 4% 87% 100%

Percent of Expenditures to be Reimbursed

$28,0008%

$3,5001%

$14,0004%

$304,50087%

$350,000100%

Intent and Purpose

• Federal law authorizes recipients operating school-wide programs to consolidate spending from federal, state and local funds to support the implementation of the school-wide program as long as the school demonstrates that the intent and purpose of the program are met.

• For example:– Title II, Part A: the intent and purpose of this program is to

increase student achievement through strategies such as:• Improving teacher and principal quality• Increasing the number of highly qualified teachers, principals

and assistant principals in schools • Holding LEAs and schools accountable for improvements in

student academic achievement

Intent and Purpose

• A school-wide program would meet the intent and purpose of Title II, Part A if:– The school-wide plan contains activities and strategies that

promote increased student achievement, such as• On-going and sustained professional development for teachers

and administrators• Strategies to recruit and retain highly effective, highly-qualified

teachers• Teacher mentoring programs• Induction programs for new teachers

Intent and Purpose

• Title I, Part A (school-wide program)– Programs and services designed to meet the educational

needs of all students in a school, particularly those who are not meeting state standards.

• Title III, Part A– Programs to help ensure that children with limited English

proficiency become proficient in English, develop high academic attainment in English, and meet the same challenging state academic content and achievement standards in core academic subjects that all other children are expected to meet.

– Increase the capacity of schools to establish, implement and sustain high-quality language instruction programs, and English language development programs that assist schools in effectively teaching students with limited English proficiency.

Intent and Purpose

• IDEA, Part B– To ensure that all children with disabilities have available to

them a free appropriate public education designed to meet their individual needs.

• Perkins – Programs and services to more fully develop the academic

and career and technical skills of secondary education students and postsecondary education students who elect to enroll in career and technical education programs.

Statutory and Regulatory Requirements• Several federal statutory and regulatory requirements

are eased through school-wide consolidation at the school level– Supplement/supplant

• Building level testing, rather than expenditure level

– Time and effort• Pool of funds is a single cost objective

– Procurement & equipment inventory• If consolidating state, local and federal

– Can use state and local procurement rules– Federal equipment tracking rules do not apply

– Fiscal accounting of expenditures• Not tracked back to individual grant programs• Tracked only as part of the school-wide pool of funds

Statutory and Regulatory Requirement• Several federal statutory and regulatory requirements

remain, but are handled differently– Maintenance of effort

• Expenditures calculated based on percentage of funds contributed to the pool

– Comparability• Percentage of federally paid staff based on percentage of funds

contributed to the pool

– Carryover limits• Calculated based on LEA total award• Carryover amounts based on total expenditures and percentage

of funds contributed to the pool

Keys to Success

Funding

• Clear funding formula to determine state and local funds allocated to schools

• School level allocation of federal funds– Limited set asides at the LEA level

• Decision making authority at the school for – Staffing– Interventions– Materials & supplies– Professional development

School-wide Plan

• Comprehensive needs assessment done annually– All relevant data included (academic, discipline, attendance,

parent/community engagement, teacher evaluation, etc.)– In depth data analysis– Root cause analysis– Prioritization of goals to be met in one academic year– Targeted strategies to meet goals– Action steps that are:

• Aligned to goals and strategies• Measurable

• Intentional opportunities for plan review and revision throughout the school year

Recordkeeping

• Accurate and adequate documentation of programs and funds included in the school-wide pool

• Budget and accounting codes necessary to separate costs from all other expenditures

• Support to show meeting intents and purposes of grants included in the consolidation

• Policies and procedures for accurately determining:– IDEA school maximums (if included in the pool)– Maintenance of Effort– Comparability– Federal fund reimbursement requests

School-wide Pilot

School-wide Pilot

• 2015-16 Planning Year– Partner with LEAs statewide (ideally one per CORE region)

interested in school-wide consolidation– Create a taskforce of representatives from:

• Partner LEAs• TDOE

– CPM– Fiscal– IDEA– Special Populations– CCTE– 21st Century– Local Audits

• Others as necessary

School-wide Pilot

• 2015-16 Planning Year– Quarterly meetings of task force– Collaboratively develop policies and procedures for

implementation of school-wide consolidation in Tennessee– Pilot policies and procedures in partner LEAs in 2016-17– Adjust policies and procedures in 2016-17 as necessary

based on pilot feedback– Develop and release final policies and procedures, FAQs,

templates, etc. for school-wide consolidation– Make option of school-wide consolidation available to all LEAs

in 2017-18

School-wide Pilot

• If interested in participating in the school-wide pilot:

– Submit the following information to Renee.Palakovic@tn.gov by September 30

• LEA Name• Contact person for school-wide pilot• Contact person phone and email• Number of Title I school-wide schools interested in participating

QuestionsFeedback

TASL Credit Keyword

Questions?

Feedback Survey

• At the end of each day, please help us by providing feedback.

• Today, please use the survey link below.

– https://www.surveymonkey.com/r/2015-ESEA-Aug-26

TASL Credit

• In order to receive 14 TASL credits for the 2015 ESEA Directors Institute, the participant must attend two full days, August 26 – 27.– Partial credit cannot be earned.– Use the form provided at the back of the agenda to collect

keywords throughout the conference. – After the conference, go online to https://

www.surveymonkey.com/r/2015-ESEA-TASL and enter your information.

• You will not receive credit if you do not complete the online form by September 4, 2015.

FRAUD, WASTE or ABUSE

Citizens and agencies are encouraged to report fraud, waste or abuse in State and Local government.

NOTICE: This agency is a recipient of taxpayer funding. If you observe an agency director or employee engaging in any

activity which you consider to be illegal, improper or wasteful, please call the state Comptroller’s toll-free Hotline:

1-800-232-5454

Notifications can also be submitted electronically at:

http://www.comptroller.tn.gov/hotline