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South Dakota Department of Education – Grants Management

Rob Huffman – Administrator

Mark Gageby – Special Education Fiscal

Kim Fischer – Fiscal Monitoring

Paul Schreiner – Title I Part A Fiscal

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The American Recovery and Reinvestment Act (ARRA) The American Recovery and

Reinvestment Act (ARRA)Title I Part A IDEA Part B Sections 611 & 619

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Title I Part A ARRA

ARRA State Allocation $34,650,000

Job Funded 183 during Quarter ending March 31, 2010

Funds Dispersed to LEAs Thru April 2010 $10,710,000 About 31%

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IDEA Part B 611 ARRA

ARRA Allocation $31,630,863

Job Funded 292 during Quarter ending March 31, 2010

Funds Dispersed to LEAs Thru April 2010 $10,325,000 About 33%

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IDEA Part B 619 Preschool ARRA

ARRA Allocation $1,520,277

Job Funded 23 during Quarter ending March 31, 2010

Funds Dispersed to LEAs Thru April 2010 $581,000 About 38%

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ARRA Quarterly Reports

Due at the end of each quarter through September 30, 2011

Next one due for Quarter Ending June 30, 2010

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ARRA Quarterly Reporting ARRA Quarterly Reporting RequirementsRequirements New guidance issued December 18, 2009

shifting focus from “Jobs Created, Jobs Retained” to “Jobs Funded.”

Recipients no longer required to make a subjective judgment on whether jobs were created or retained as a result of the Recovery Act.

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ARRA Quarterly Reporting ARRA Quarterly Reporting RequirementsRequirements Recovery Act Jobs Funded ~ Methodology

for Determining Number of Jobs Funded

Definite Term – Employees contracted for a definite term such as a school year

Hourly employees and hours outside of a contracted time

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ARRA Quarterly Reporting ARRA Quarterly Reporting RequirementsRequirements Vendor Payments of $25,000 or more

An individual payment to a vendor in a reporting quarter not cumulative payments over the life of the project.Vendors are defined as entities or individuals from which the sub-recipient procures goods or services needed to carry out the project of a program.

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Program requirements of ARRA funds The same program provisions that

currently apply to regular program funds apply to the ARRA funds.

Two separate funding sources for same program

Either regular or ARRA funding source can pay for program activities.

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Reporting ARRA Fund Use

Track separately from regular program fundsNew CFDA Numbers for each program

Maintain accurate documentation of all ARRA expenditures.

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Planning & Budgeting

Fiscal staff need to work with program coordinators in preparing and revising budgets to ensure program requirements are met between the combined amounts in the two separate budgets.

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Strategies for ARRA Option 1

Obligate all a program’s ARRA funds before June 30, 2010 Advantage - Don’t have to budget or track in FY 2011

ARRA Funds must be tracked separately and cannot be commingled with regular funds

Use in place of regular funds in FY 2010 and carryover regular funds

Regular 2010 carryover funds may be commingled with the FY 2011 regular allocation.

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Option 1 Continued

May need to amend FY 2010 ARRA program budgets in eGrant

May not be feasible at this point, if the district has a large ARRA balance remaining.

Need to avoid supplanting & MOE issues.

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Remember - Supplement Not Supplant and IDEA MOE Provisions

Do not replace state and local funds with ARRA funds just to avoid ARRA carryover balance.

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Strategies for ARRA Option 2

Ensure all ARRA carryover funds are expended for program activities in FY 2011 Pick activities easy to track that equal or exceed

ARRA fund balance. Look for ways to spend ARRA funds before regular

FY 2011 funds. Remember ARRA funds will expire & cannot

carryover into FY 2012 Make sure program balance at the end of the grant

period is made up of regular funds only.

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Closing Out FY 2010

Districts need to file a Project Completion Report on FY 2010 ARRA programs.FY 2010 Grant Period for obligations ends on

June 30, 2010.Must submit claims to liquidate any

outstanding FY 2010 ARRA obligations by September 10, 2010.

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SY 2010-11 Budgeting

For budgeting purposes on the SY 2010-11 grant applications

Districts may provide the DOE with projected carryover balances for 2010 ARRA and/or regular carryover.

Otherwise, wait until PCR are processed to budget

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Projected Carryover Form

Will be emailed to district business officials.Amounts provided by district will be loaded

into eGrant for budgeting purposesUp to districts to provide reliable amounts.The Budgets will need to be adjusted to actual

amounts once the final amount is determined.

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Projected Carryover Form

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Submit by Business Official

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SY 2010-11 ARRA Budgets

Separate ARRA budgets will be included in the Title I and the IDEA Sections 611 & 619 Program Applications.

Budgets will be on eGrantNew for IDEA Part B programs

Paper application with budgets on eGrant IDEA will be now be reimbursement basisSubmit claims on eGrant

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Carryover Limits

Title I Part A Need a waiver from State to exceed15% carryover

limit Based on Combined Regular and ARRA Allocations

less than $50,000 are exempt from this limit

IDEA Part B No Carryover limit - may carryover all FY 2010 funds

into FY 2011

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Title I 15% Carryover Waiver

District must demonstrate a reasonable basis to prudently spend funds over two years.

Spending plan must be reasonable, necessary & allocable to the Title I program

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IDEA Part B Maintenance of Effort (MOE)

LEA application standard: With certain exceptions, an LEA budgets for the

education of children with disabilities, at least the same total or per capita amount of either: local funds only; or State and local funds

as it spent from those same sources in the most recent prior year for which the information is available

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LEA (MOE) requirement

IDEA Part B funds must not be used by an LEA to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds below the level of those expenditures for the preceding year

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LEA MOE (cont)

Don’t include as state or local funds any federal funds for which the SEA or an LEA is required to account to the federal government

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LEA MOE (cont)Audit standard:

Compliance with the MOE requirement, after a fiscal year has ended, is based on the actual local or state and local expenditures for special education and related services in the audited year and the prior year

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LEA MOE: Common Problem

The LEA does not fully spend the amount of local, or state and local, funds it was required to budget in its application at the beginning of the year to demonstrate to the State that the LEA would meet the MOE requirements.

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Optional Flexibility Authority-50% Rule For any fiscal year that an LEA’s allocation

exceeds the amount of its prior year’s allocation, the LEA may reduce its expenditure of local funds by not more than 50% of the increase in federal funds

The LEA must use an amount of local funds equal to the reduction for activities that could be supported with funds under the ESEA

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Optional Flexibility Authority-50% Rule (cont) The LEA must spend the freed up local funding by June

30, 2010 or it will not make MOE in SY 2009-10.

Funds do not carryover into next fiscal year.

This will reduce the MOE for next year-FY 2011

This flexibility must be taken in the fiscal year the excess IDEA allocation became available.

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Optional Flexibility Authority-50% Rule (cont) LEA’s are required to track the funds and

provide DOE with a detailed expenditure report.

Business Managers can export the information out of their financial software and provide a spreadsheet in either a PDF or Excel format.

Expenditure reports are due with your Project Completion Report (PCR).

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ARRA Funds-IDEA Part B 611 & 619-FY 2010 LEA’s must close out their FY 2010 ARRA

IDEA Part B 611 & 619 grants.

Fiscal Year ends June 30, 2010

Project Completion Reports must be completed by September 10, 2010.

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Amendments

Revised Flowthrough Funds form can be used for amendments to Regular IDEA Part B funds, Coordinated Early Intervening Services (CEIS) and Optional Flexibility Authority (50% Rule).

Website for form: http://doe.sd.gov/oess/specialed/flowthrough.asp.

ARRA funds amendments should be done on eGrants system.

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HB 1021

Equipment purchases which are not assistive technology tied to an IEP can now be purchased with federal funds.

Must be approved by DOE.

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Questions

?605 773-3248