Supplement versus Supplant: A case study of the effect of ...
Supplement or Supplant Was it in place last year? Was it affected by cuts in unrestricted funding?...
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Transcript of Supplement or Supplant Was it in place last year? Was it affected by cuts in unrestricted funding?...
Supplement or Supplant
Was it in place last year?
Was it affected by cuts in unrestricted funding?
Is it part of the district’s core program?
Is it aligned to a SPSA/LEAP goal?
Is it included within the approved SPSA and or LEAP?
Likely to be supplanting or disallowed
Proceed with caution
Likely to be supplemental Meets the major requirements-
check the program funding rules to ensure this is an allowable use
No
No
No
NoNo Yes Yes
Yes
Yes
Yes
Allocation Plans- What Programs Need Them?
Is it a program included in the current Tier III flexibility
provisions? e.g., GATE or SIP
Is it a federally funded program? e.g., Title l, or
Migrant?
Is it Title l funding?
Is it restricted state funding ?
Is it EIA?
An Allocation Plan is required for EIA . Thought needs to be given to the appropriate split
between SCE and LEP
An Allocation Plan is required for Title l funds (other federal
funds do not require Allocation Plans)
CautionAllocation
Plans need to align to LEAP
and SPSA
Caution districts are required to
demonstrate adequate and appropriate
support for ELs
No
No
No
No
No Yes
Yes
Yes
Yes
Yes
An Allocation Plan is not required
85/15 Rule-What is a Direct Service?
Was the service in place last year?
Was the service affected by unrestricted funding reductions?
Are the services based at a school site? e.g., extended learning time?
Are students the direct recipients of the services? e.g., hands on
instruction?
Do the services contribute to the quality of the program ? e.g., professional development or
academic coaches
Are services aligned to the SPSA
Likely to be counted toward the 15% limit for indirect and
administrative costs
Likely to be counted toward the 85% requirement of direct
services to students
Proceed with
Caution!!
Do the services contribute to administrative functions? e.g., evaluating ,or supervising ?
No
No
No
No
No
Yes
Yes Yes
Yes
Yes
Yes
Yes
No
Centralized Services Compliant or Not?
Is it a type of service that lends itself to be organized centrally? e.g. ,
summer school or academic coaches
Is the service considered a direct services/support to students? e.g., academic intervention counseling
Is it an administrative service? e.g., clerical support for the program
Have the sites been involved in the process of selecting the
support/services?
Has the “centralized” service been approved by the site council?
Likely not a good fit as a centralized service
No
No
No
Yes
No
Yes
Yes
Yes
Yes
Possibly eligible as a centralized service if there is “room” in the districtwide15%
administrative cost limit
Compliance with regulations necessitates site council
involvement in the selection and subsequent approval of
centralized servicesLikely to be in compliance and eligible to be classified as a
centralized service
Proceed with
Caution!
Caution ensure
documentation of involvement and approval
Caution ensure
service is an allowed
use
Library Services; Are They a Supplemental Service?
Were the library services in place last year?
Do the library services support student
achievement? i.e., offer instruction on specialized
curriculum?
Do the sites have discretion to run library services? e.g. some sites have services
others don’t
Are library services part of the defined “core” services i.e., supported on a district-
wide basis from general funds?
Were they affected by unrestricted funding
reductions?
Likely to be supplanting or disallowed if library services are supported with restricted
funds
Likely to be considered a “place” and not a
supplemental service
Likely a supplemental service that can be
supported with restricted funds
Caution ensure library
services align to the
SPSA
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Proceed with
caution if using
restricted funds
Counselors; Core or Supplemental?
Were counseling services in place last year?
Were counseling services affected by general fund
reductions?
Are counseling services provided for specific
populations? e.g. at risk or low performing students
Do sites have discretion in planning counseling services/support?
Are counseling services considered part of the core program? e.g. counselors supported by general funds
Likely to be supplanting or disallowed if counseling
services are supported with restricted funds
Likely services are supplemental and can be supported with restricted
funding. Consider using Title l , EIA, ASES or Migrant funds
Caution ensure
counseling services
align to the SPSA
No
No
No
NoYes
Yes
Yes
Yes
Yes
Are the learning opportunities offered district-wide? i.e., to all
students?
Is the curriculum offered for core subjects or credit recovery?
Is the curriculum for a targeted population? i.e., ELs or Migrant?
Is the program offered at a SIG School?
Is the school Title l SWP or EIA/SCE
Is the schools Title l targeted population or EIA/LEP?
Likely general funds are needed to support the extended learning
opportunity
Likely Title l EIA/SCE funds can support the opportunity
Likely SIG funds can be used
Likely general funds are needed to support the extended learning
opportunity
Likely Title l or EIA/LEP can support targeted students
Extended Learning Opportunities Funding Options
Yes
Yes
Yes
Yes
Yes
No
No
No
No
NoYes
Caution! ensure
program is aligned to SPSA & LEAP
Caution supplanting
issue if program is
supported with general funds at other sites
Cautionensure grant
proposal matches the program that
is offered
No
Paper, or pencils
Instructional Supplies—Supplemental or Core?
Were the supplies purchased with general funds last year?
Are the supplies basic or core supplies?
Are the supplies only used by a specific population?
Are the supplies aligned to goals in the SPSA/LEAP
Are the supplies included in the SPSA and SPSA budget?
Likely to be considered core supplies. Use general funds to
support the purchase
If supplies are aligned to the SPSA revise the SPSA budget
Likely can be considered supplemental instructional
supplies
At risk students
Cautionhave Site Council approve
budget revision before
purchase
Cautioncheck program funding rules to ensure supplies are an allowed
use
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Were the supplies affected by cuts in the unrestricted general
fund?
NoYes
Technology Equipment Supplemental or Core
Is the equipment in place now?
Does the equipment require infrastructure or capital
improvements before installing?
Is the equipment part of a technology retrofit? i.e., bringing
all sites up to a specific standard?
Is this a routine equipment upgrade or periodic
replacement?
Does the equipment enhance core curriculum?
Likely to be core and included in a Facility Master Plan or
Technology Replacement Plan
Likely supplanting use general funds or possibly e-rate funds
to support purchase
Possibly supplemental. Check specific program funding rules
to ensure allow ability
Proceed with CAUTION
if using restricted funding!!CAUTION
If it doesn’t enhance
curriculum delivery don’t
purchaseNo
No
Yes
Yes
Yes
Yes
No
No
Yes
CAUTIONinfrastructure costs are generally not allowable with federal funds
Technology Equipment StandardsIs technology equipment
replaced or upgraded per an established schedule?
Are technology purchases centrally managed?
Can sites or departments make their own technology equipment
selections?
Are there technology equipment “packages” based on user type?
e.g., student or staff
Is there a review process for technology purchases? i.e.,
annual review of user satisfaction of equipment or
software effectiveness?
Consider establishing technology equipment
standards that include user levels for students and staff
Congratulations!! Sounds like you have technology equipment
standards under control.
No
No
No
Likely an annual review process for technology
equipment and software would increase satisfaction and
effectiveness
Yes
YesYes
Yes
No
Yes
Are there dedicated funding sources for equipment
replacement?
Establish a dedicated funding source for equipment
replacement
No
Yes
Technology Software Core or Supplemental?
Are there established core software standards?
Is the software used on a grade span basis districtwide? i.e., K-12, K-8 or 9-
12
Is the software utilized for extended learning?
Is the software used at a SIG school?
Is the software used at a SWP Title l or EIA/SCE school?
Refer to standards to determine core versus supplemental software
Likely a core expense; use general funds or possibly
Prop 39 Lottery funds
Likely would be supplanting; proceed with caution if using
restricted funds
Likely supplemental ; Title l and EIA/SCE are possible funding sources. Ensure software is referenced in SPSA plan and budget
Likely supplemental and might be considered a SIG expense. Check to ensure the software is included in
the SIG plan
Is the software aligned to SPSA/LEAP goals? No
No
No
No
No
No
Yes
Yes
Yes
Yes
Yes
Yes
Caution! if software is
used at targeted Title l or EIA/LEP sites ensure use
is for targeted students only
Professional Development Options to Consider
Do the LEAP and SPSA outline current professional development plans?
Are staff members willing to participate in after school or
summer opportunities?
Is there time embedded in the collective bargaining
agreements for professional development?
Is professional development included as a component of the
“core” program?
Likely supplemental; restricted funding could be
used to support staff compensation, materials,
contracts or travel/conference
Likely supplanting or disallowed if using restricted
funds to support P.D.
*Best Practice* Reach out to staff
with alternative options. e.g. buying
prep periods or online/webinar
training
*Best Practice* Update plans to include relevant,
quality P.D. opportunities
No
No
No
No
Yes
Yes
Yes
Yes
Proceed with caution if
using restricted funds for
salary
Possible funding sources: Title l, Title ll or EIA
Food and Refreshments; Best Practices?
Does your agency have a policy that supports
food/refreshment purchases?
Is food used as an enticement to encourage adult attendance
at meetings?
Is food used as a student reward? i.e. pizza party for
increased test scores
Has past practice allowed food and refreshment purchases
anyway? Are requests for food and refreshment reviewed prior to
purchase?
*Best Practice* Establish a Board
Policy that represents the agency’s culture
and climate and Wellness Policy
*Best Practice* Requests should be reviewed to ensure
purchases made restricted funds align
with SPSA/LEAP goals
*Best Practice* Provide healthy
reward alternatives e.g. sports activities
Congratulations! Best Practices Appear to be in
place
No
No
No
No
Yes
Yes
Yes
Yes
Yes
*Best Practice* Encourage a
culture of adult improvement and
involvementNo