Special Education – Solving the Mystery Together 08/17/07 Lori Ames, School Finance Consultant.

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Special Education Special Education Solving the Solving the Mystery Together Mystery Together 08/17/07 08/17/07 Lori Ames, School Finance Lori Ames, School Finance Consultant Consultant

Transcript of Special Education – Solving the Mystery Together 08/17/07 Lori Ames, School Finance Consultant.

Special Education – Special Education – Solving the Mystery Solving the Mystery

TogetherTogether

Special Education – Special Education – Solving the Mystery Solving the Mystery

TogetherTogether

08/17/0708/17/07

Lori Ames, School Finance ConsultantLori Ames, School Finance Consultant

Agenda• Special Education Funding Sources

• Special Education Expense Coding

• State Special Education Categorical Aid

• Adjustments to Aidable Expenses

• Special Education Fiscal Reporting

Special Education Funding Sources

• State Special Education Categorical Aid

• High Cost Categorical Aid

• Federal Special Education Aid

• Medicaid

• State Equalization Aid

• Local Property Tax

State Spec Ed Categorical Aid

• Aidable costs may include, but are not limited to:– Salary/Fringe Benefits for:

• Most Special Education Teachers and Assistants• Speech/Physical/Occupational Therapists• School Psychologists, Social Workers, Guidance

Counselors, and Nurses• Special Education Administrative Staff• Special Transportation

High Cost Categorical Aid

• School districts are eligible for aid if the district incurred, in the previous school year, more than $30,000 of non-administrative costs for providing special education and related services to a child, and those costs are not eligible for reimbursement under the state special education categorical aid program, the federal Individuals with Disabilities Education Act, or the federal Medicaid program

http://www.dpi.wi.gov/sfs/highcost.html

Federal Special Education Aid/Grants

• The Individuals with Disabilities Education Act (IDEA) originally authorized funding of 40% of average per-pupil expenditures to support special education services for children with disabilities. Most of the funding is distributed to local school districts in the form of flow-through aids or other discretionary grants.

http://www.dpi.wi.gov/sped/fedgrant.html

Medicaid

• A fairly small source of revenue for school districts is insurance reimbursement provided through the combined federal/state Medicaid program.

http://dpi.wi.gov/sfs/doc/medicaid.doc

State Equalization Aid

• Equalization is a state “cost sharing formula” which reduces local district reliance on local property taxes.

• The state shares in most costs incurred by Wisconsin school districts that are not reimbursed by other revenue sources. Eligible costs include special education and related services.

http://www.dpi.wi.gov/sfs/equalaid.html

Local Property Tax

• Special Education and related services not reimbursed through one of the programs mentioned above are funded by local property taxes.

• The extent to which local property taxes are used to fund special education costs in a particular district varies greatly and depends largely on the amount of state equalization aids received by the district.

Spec Ed Expense Coding

• All special education expenses, regardless of funding source must be accounted for in fund 27

• The function number and the project number are the most critical elements of the total account code

Special Education Expense Coding

• Function Number– Identifies the special education program

• 152000 – Early Childhood

• 158000 – Cross Categorical

• 156600 – Speech & Language

• 159200 – Substitutes

Spec Ed Expense Coding

• The Business Office and the Special Education Department will need to work closely together to ensure that staff members are being charged to the appropriate program or function.

• Appropriate staff licensure is important when assigning staff to various functions

http://www.dpi.wi.gov/sfs/doc/valid_code_se.doc

Project Coding

• The key to identifying the correct project code is ……

……understanding that the project code identifies how the expense is to be ultimately funded.

Project Number – 011

• Use this project on all original object 100 – 900 expenditures when:

– the LEA is using only local dollars to fund the expenditure (no grant money reimbursement)

– the expenditure is directly state special education categorically aidable

Project 011-Aidable Expense Example

• The school district incurs salary & benefit expenses for an appropriately licensed Early Childhood teacher, funded w/ local dollars.

Fund Object Function Project

27 100/200 152000 011

Project Number - 019• Use this project on all original object

100-900 expenditures when:

– the LEA is using only local dollars to fund the expenditure (no grant money reimbursement)

– the expenditure is NOT directly state special education categorically aidable

Project 019-Non-Aidable Expense Example

• The school district purchases supplies for an early childhood program w/local dollars.

Fund Object Function Project

27 410 152000 019

Project Number - 340• Use this appropriate IDEA grant project

code of “341-349” on all original object 100-900 expenditures when:– This expenditure is charged directly to an

IDEA (flow-through, entitlement, etc..) grant.

– The LEA name on the grant is the same as this LEA.

Project 340 Grant Expense Example

• The LEA purchases supplies for an early childhood program that is reimbursed by grant dollars direct to this LEA.

Fund Object Function Project27 410 152000 340

Project Number - 599

• Use this project code on all original object 100-900 expenditures when:

– This expenditure is charged directly to a grant such as AODA, Drug Free, etc….

– The LEA name on the grant is the same as this LEA.

Project 599 Grant Expense Example

• The LEA purchases supplies for an early childhood program that is reimbursed by non-IDEA grant dollars direct to this LEA.

Fund Object Function Project27 410 152000 599

Project Number – 315/317• Use these projects, 315 (State) or 317

(Federal) on all original object 100-900 expenditures when:

– The expenditure is then charged to a state/federal grant of another LEA

– The LEA name on the state/federal grant is another school district (NOT this LEA)

Project 315/317Grant Expense Example

• The LEA purchases supplies for an early childhood program that is reimbursed by another school district using federal grant dollars

Fund Object Function Project27 410 152000 317

Project Number – 515/517

• Use these projects, 515 (State) or 517 (Federal) on all original object 100-900 expenditures when:

– The expenditure is then charged to a state/federal grant.

– The LEA name on the state/federal grant is a “CESA” or a “CCDEB”, NOT this LEA

Project 515/517Grant Expense Example

• The LEA purchases supplies for an early childhood program that is reimbursed by a CESA or CCDEB using federal grant dollars

Fund Object Function Project27 410 152000 517

Project Number - 091

• Use this project on all original object 100-900 expenditures when:

– The LEA is using only local dollars to fund the expenditure (no grant money reimbursement)

– The expenditure is directly reimbursed by a payment from CESA (using CESA local dollars – no grant money)

Project 091 CESA Package Program Example

• The host district of a CESA package program purchases supplies for an early childhood program that is reimbursed w/local dollars by CESA.

Fund Object Function Project27 410 152000 091

Project Number – 092

• Use this project on all original object 100-900 expenditures when:

– The LEA is using only local dollars to fund the expenditure (no grant money reimbursement)

– The expenditure is directly reimbursed by a payment from a CCDEB (using CCDEB local dollars – no grant money)

Project 092 CCDEB Package Program Example

• The host district of a CCDEB package program purchases supplies for an early childhood program that is reimbursed w/local dollars by a CCDEB.Fund Object Function Project

27 410 152000 092

Why is Coding Important?

• DPI uses the account codes to determine aidable expenses and ultimately calculate your district’s state special education categorical aid

How Do I Know If An Expense is Aidable?

• Refer to the “Special Education Categorical Aid Claim Directions” document for definitions of aidable expenses.

http://dpi.wi.gov/sfs/xls/se_claim_directions.xls

Special Education Categorical Aid

• Entities eligible to receive state special education categorical aid:– School Districts

– CESAs

– CCDEBs

– 2R Charter Schools

Special Education Categorical Aid

• Based on the information reported in the special education annual report, the district’s special education categorical aid is calculated

• the aid is paid based on prior year aidable expenditures (aid paid in 2007-08 is based on expenditures from 2006-07)

Special Education Categorical Aid• Categorical aid may be received either

directly or indirectly:

– Direct: Your district receives aid directly from DPI as a result of an expense coded to an 011 project

– Indirect: Your district reimburses another entity with local funds for expenses that the other entity coded to an 011 project. The other entity transits your share of the aid to our district.

Special Education Categorical Aid

• Due to the high amount of eligible expenses, the amount of aid paid is prorated to approximately 29%.

• Aid is paid in multiple payments (Nov 15%, Dec 15%, Jan 15%, Feb 15%, March 15%, and June 25%)

Special Education Fiscal Reporting

• Districts are required to submit both a special education budget and annual report that is currently separate from the full SAFR budget and annual report

• The special education budget/annual program is located on either a staff member’s individual hard drive or on a network drive within the district.

Spec Ed Fiscal Reporting

• District data is entered in the resident program.

• Since the report is not web-based, the district must create a text file containing the data. (part of the program)

• The text file is emailed to:[email protected]

Adjustments to Aid Eligible Expenses

• No Valid License – staff members are not appropriately licensed for the program.

• Additional Questioned Cost -

• Inappropriate allocation of salaries/benefits - social workers, psychologists, nursing, and guidance

No Valid License

• PI 1202

– Report filed by district with DPI in fall

– List by staff, FTE, and teaching position

– No updates during the year

No Valid License

• “No Valid License” listing on June 30th

– Identifies staff not properly licensed for the teaching assignment listed on the PI 1202

– Auditor required to report to DPI salaries, benefits, and account structure (even in funds other than 27) for all individuals on “no valid license” listing.

No Valid License

• “No Valid License” listing on June 30th

– Available in reporting portal

No Valid License

• “No Valid License” listing on June 30th

– When teaching position of an individual was incorrectly reported on PI-1202

• Obtain, for auditor, a written representation from the Special Education Director or other appropriate person stating that the reported assignment (PI-1202) was incorrect. Include previously reported teaching assignment and correct teaching assignment for individual.

No Valid License

• “No Valid License” listing on June 30th

– DPI special education licensing follows up on the licensing status

• May result in phone call to district

– Aid is withheld until DPI special education licensing approves the individual

Additional Questioned Cost

• “Valid License” listing on June 30th

– Available in Reporting Portal

• Auditor performs a payroll test and determines if salary and related benefits are properly reported for staff on the list

Additional Questioned Cost

• Any individual not reported in proper account coding for their teaching assignment (per PI-1202 and valid license list) is:

– Reviewed by Auditor for correct teaching assignment (through inquiry)

• If teaching assignment is in agreement with license – salaries and benefits are moved to appropriate WUFAR accounts (no filing with DPI)

• If teaching assignment is not in agreement with license – salaries and benefits are reported to DPI as questioned cost

Additional Questioned Cost

• DPI special education licensing follows up on the licensing status

– May result in phone call to District

• Aid is withheld until DPI special education licensing approves the individuals

Allocation of Salaries and Benefits to Fund 27

• Salaries and benefits of professionals working in both the regular education and special education areas must be allocated between fund 10 and fund 27 based on time and costs

– School Social Worker– School Psychologist– School Nurses (Registered Nurses, licensed by WI

Department of Regulation and Licensing)– School Counselors

Allocation of Salaries and Benefits to Fund 27

• January 12, 2006 Letter– http://www.dpi.wi.gov/sfs/ltrjan12_06.html– Types of activities that would be eligible for

special education aid– Methodologies in determining time and cost

• Must be done for each individual staff member claimed

• Documentation must be maintained• Must be rational and defensible method of

allocation

Allocation of Salaries and Benefits to fund 27

Special Education

General Ledger Claim FormSocial Worker Function 212000 Function 212000

Project 011

Psychologist Function 215000 Function 215000

Project 011

Nurse Function 214000 Function 299999

Project 019

Guidance Counselor

Function 213000 Function 299999

Project 019

Allocation of Salaries and Benefits to Fund 27

• Identify these costs in the cover e-mail with the upload file attachments as follows:– For (LEA Name), the “011-state aidable” guidance

counselor and school nurse salary/fringe costs reported in function 299 999 under project “019” on the PI 1505SE are:

• School Guidance Counselor– Object 100 – Salary: (Amount)

– Object 200 – Fringes: (Amount)

• School Nurse– Object 100 – Salary: (Amount)

– Object 200 – Fringes: (Amount)

Allocation of Salaries and Benefits to Fund 27

• Included in Auditor payroll test will be individuals from the categories of psychologist, social worker, guidance counselor, and nurse

• Supply auditor with instructions to staff on how to determine what time is aidable

• Provide auditor with documentation of methodology used

Allocation of Salaries and Benefits to fund 27

• Auditor reports to DPI as questioned cost the salaries and benefits of individual in question

• DPI special education licensing follows up on the licensing status

– May result in phone call to District

• Aid is withheld until DPI special education licensing approves the individual

Spec Ed Fiscal Report

• Common Errors in the Special Education Annual Report:

– Spec Ed Annual = SAFR Annual Report– Grant payments and expenses between

entities do not equal.– Deductible receipts are not identified

Spec Ed Annual = SAFR Annual

Spec Ed SAFR

218200.100 21,000 21,000

218200.200 4,200 4,200

218200.300 3,000 2,500

218200.400 800 800

218200.500 1,000 1,000

Total 30,000 29,500

Function total out of balance

Spec Ed Annual = SAFR Annual

Spec Ed SAFR

218200.100 21,000 21,000

218200.200 4,200 4,200

218200.300 3,000 3,800

218200.400 800 0

218200.500 1,000 1,000

Total 30,000 30,000

Object Total out of Balance

Grant Payments Between Entities• Example Assumptions:

– 3rd party grant scenario

– District A incurs the original expense to be reimbursed

– District B is the grant holder

– Federal flow-thru grant

Grant Payments Between Entities

DPI

District A – Incurs Original Vendor Expense - Project 317

VENDOR

District B – Reimburses District A using Federal Flow-Thru Funds –

Project 340

District B files DPI Grant Claim & Receives Reimbursement – Source

730

District A – Receipts Reimbursement-Source 317

Grant Payments Between Entities• On the special education report:

– District A enters nothing but the expense in the appropriate account number, project 317

– District B answers “yes” to paying another LEA for services from a grant, identifies District A, and the amount paid

District A Project 317 =

District A Source 317 = District B Object 340

Grant Payments Between Entities• Example Assumptions:

– 3rd party grant scenario

– District A incurs the original expense to be reimbursed

– CESA is the grant holder

– Federal flow-thru grant

Grant Payments Between Entities

DPI

CESA

District A – Incurs Original Vendor Expense - Project 517

VENDOR

CESA – Reimburses District A using Federal Flow-Thru Funds –

Project 340

CESA files DPI Grant Claim & Receives Reimbursement – Source

730

District A – Receipts Reimbursement-Source 517

Grant Payments Between Entities• On the special education report:

– District A enters nothing but the expense in the appropriate account number, project 517

– CESA answers “yes” to paying another LEA for services from a grant, identifies District A, and the amount paid

District A Project 517 =

District A Source 517 = CESA Object 340

27.000.211.152000.011 27.000.386.436000.019

27.000.110.152000.011

27.000.550.218100.517

27.000.410.221300.599

27.000.310.221300.340

27.000.410.156600.317

27.000.212.152000.011

27.000.220.152000.01127.000.310.156600.515

Special Education ReportSpecial Education Report

But what happens if another entity reimburses your district for an

expense coded to 011 using grant funds?

Not Aidable Aidable

Deductible Receipt• What is a deductible receipt?

– A deductible receipt is created when an entity incurs an aidable expense (coded to project 011) that is ultimately reimbursed by another entity with grant funds.

Deductible Receipt• Why does DPI care about deductible

receipts?

– DPI should not pay special education categorical aid on an aidable expense (coded to project 011) that has been reimbursed with state or federal grant funds.

Deductible Receipt Example

• District A provides Early Childhood services to multiple districts. District B’s share of the program include salary ($400), benefits ($200), and materials ($100). District B reimburses District A using federal grant money.

• District A Expense: 27E.xxx.110.152000.011 $400• District A Expense: 27E.xxx.2xx.152000.011 $200• District A Expense: 27E.xxx.410.152000.019 $100• District A Revenue: 27R.317 $700

Deductible Receipt Example

• On the Special Education Report:– District A:

• Answers “yes” to “did your district receive deductible receipts”

• Identifies District “B” and the amount of the deductible receipt $600

• Enters $600 in 27D152000 000 011

– District B:• Answers “yes” to paying another LEA for

services from a grant, identifies District “A”, and the amount paid ($700)

Deductible Receipt-Open Enrollment

• District A serves the student and bills District B.

– District B pays with local funds only

• Flat Rate – no deductible receipt

• Additional Cost – no deductible receipt

Deductible Receipt-Open Enrollment

• District A serves the student and bills District B.

– District B pays with grant funds

• Flat Rate – no deductible receipt

• Additional Cost – deductible receipt for the portion of the additional cost originally charged by District A to an 011 project number.

Spec Ed Reporting Changes Ahead!

• The finance team is currently in the design phase of creating a new special education fiscal report.

• The goal is to integrate the fund 27 detail with the full SAFR Budget/Annual Report beginning with the 2008-09 Budget Report.

Resources

• WUFAR (full document & expense matrix) http://www.dpi.wi.gov/sfs/wufar.html

• Special Education Transaction Coding

http://www.dpi.wi.gov/sfs/doc/sped.doc

• Special Education Claim Directions

http://www.dpi.wi.gov/sfs/xls/se_claim_directions.xls

Resources

• Valid Teacher Licenses & Reporting Codes

http://www.dpi.wi.gov/sfs/pdf/valid_code_se.pdf

• “Special Education” Pupil Transportation

http://dpi.wi.gov/sfs/xls/setrpl00.xls

• Special Education Media-Site Presentations

http://media2.wi.gov/DPI/Catalog/Front.aspx?cid=2352cf23-e130-4a9c-b83f-8f8e90b15f41

Resources

• Open Enrollment

http://www.dpi.wi.gov/sfs/doc/open_enrollment_wufar.doc

• Function 430000http://www.dpi.wi.gov/sfs/doc/funct_430.doc

• Coop Agreement – 66.0301

http://www.dpi.wi.gov/sfs/coop_agree.html

Resources

• Fiscal Agent Requirementshttp://www.dpi.wi.gov/sfs/doc/fisagnt.doc

• Fiscal Agent Agreement Account Codinghttp://www.dpi.wi.gov/sfs/xls/fisagagree.xls

• Fiscal Agent-Example of Level 3 Documentationhttp://www.dpi.wi.gov/sfs/doc/fisagnt_example.doc

Contacts

• Lori Ames [email protected]

• Kathy Guralski [email protected]

• Janette Gosdeck [email protected]