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Fiscal Requirements and Guidance

This handbook provides general guidance from OSPI on how local educational agencies (LEAs) may spend Title I, Part A funds under the Every Student Succeeds Act (ESSA).

The purpose of this document is to empower school and LEA leaders, grant administrators, educators, and other stakeholders to maximize the use of federal and state funds by providing information on how different federal and state funds may be used independently or together to meet specific, identified student and staff needs.

This bulletin sets forth the fiscal year 2018–19 grant payment processes, expenditure reporting, budget revision policy, and information about carryover funds and indirect costs for federal and state grant programs issued through the iGrants system.

This section includes the Title I, Part A Fiscal Handbook, Unlocking Federal and State Program Funds to Support Student Success document, and OSPI Bulletin 082-18 Grants Management.

An LEA must annually rank all of its school attendance areas according to their percent of poverty.

Priority A: Without regard to grade spans, rank school attendance areas with low-income percentage greater than 75 percent from highest to lowest. Note: The district may choose to lower this the threshold to 50 percent for high schools.
Priority B: With remaining funds, the district may rank remaining eligible school attendance areas from highest to lowest either by grade span or by district average. Please read through the law and non-regulatory guidance on this page to gain a full understanding of the requirements of this section.

Other important ranking and allocation rules:

  • Ranking and allocating rules do not apply to LEAs with a total enrollment of less than 1,000.
  • LEAs may designate buildings with 35 percent low-income children as eligible.
  • If a building with less than 35 percent low-income is served, ALL buildings must be served according to the 125 percent rule.

Additional information and resources:


Community Eligibility Provision (CEP)

If your district has approved CEP schools, please ensure you gain an understanding about how this affects your ranking and allocation for Title I, Part A purposes.

Additional information and resources:

This section includes ranking and allocating rules, Non-Regulatory Guidance, feeder pattern guidance, and community eligibility provision (CEP) information.

Required Set-Asides

Parent and Family Engagement (PFE)

This set-aside is required for LEAs with an allocation over $500,000. Calculate your PFE set-aside by taking one percent of your total allocation. Of that one percent, no less than 90 percent must go to Title I, Part A buildings. The remaining 10 percent (or less) may remain at the district level.

Additional information and resources:

Homelessness and Title I, Part A

This set-aside is required of all LEAs, even if no students are currently identified as homeless. Each LEA is required to complete the Homeless Student Needs Assessment to determine the Title I, Part A set-aside amount for homeless children and youth.

Additional information and resources:

Neglected Students

This set-aside is required for all LEAs with students in local neglected institutions. An LEA is required to reserve funds necessary to provide services to children in local institutions for neglected children, and/or community day programs for neglected children.

Additional information and resources:

Delinquent Students

This set-aside is required if the LEA has students in a local institution or community day program for delinquent children, e.g., facilities for detention, juvenile corrections, adult corrections, or community day programs.

Additional information and resources:

Private Schools

This set-aside is required for all LEAs with at least one private school in the district participating in Title I, Part A or there are district students eligible for Title I, Part A services who attend out-of-district private schools. LEAs with participating private schools are required to set aside a proportional share of funds "off the top" of their Title I, Part A allocation. 

Additional information and resources:


Optional Set-Asides

Early Learning

Use this set-aside for district-wide early learning activities. Whether in the entire LEA or just a portion of the LEA, there are a number of early learning activities that can be funded with Title I, Part A funds.

Additional information and resources:

Foster Care

Use this set-aside to support foster care students, who are categorically eligible for Title I, Part A.

Additional information and resources:

Additional Optional Set-Asides

  • Administration of Public School Programs
  • Instructional Programs (Summer School/Extended Day Programs)
  • Professional Development (LEA initiative for Title I, Part A buildings only)
  • Incentives and rewards to attract and retain qualified teachers, and/or salary differentials for Title I, Part A building staff

Unspent Set-Asides

This section includes information on required, optional, and unspent set-asides.

Supplement Not Supplant (SNS)

In general terms, Title I, Part A funds should be in addition to (supplement) and not replace (supplant) state and local funds.


Maintenance of Effort

LEAs must ensure that state and/or local funding spent on programs is consistent between years. The amount of Federal funding received for a program should not lead to a decline in the amount of state and/or local funding for the same program.

Additional information and resources:


Comparability

As a condition of receiving Title I, Part A, LEAs must ensure that state and local funds are used to provide services that, taken as a whole, are comparable between Title I, Part A and non-Title I, Part A schools. LEAs use October enrollment data to conduct the annual comparability analysis. LEAs need to make appropriate adjustments to staffing in Title I, Part A and non-Title I, Part A schools if the analysis demonstrates an issue with comparability.

Note about exclusions: Preschool staffing and students must be excluded from comparability analysis. The LEA may choose to exclude state-funded LAP, state-funded special education, and state-funded LEP/bilingual educational staff.

    This section includes information on supplement not supplant, maintenance of effort, and comparability.

    Allocations

    Title I, Part A allocations for each school year can be accessed through Form Package (FP) 201. The preliminary allocations are released approximately April-May.


    Allowability

    Title I costs must be allowable under the Title I program. At a minimum this means:

    • Costs still must only benefit eligible students, i.e., all students in a schoolwide program and identified students in a targeted assistance program.
    • Costs must be permissible under Title I and ESSA generally (note that ESSA clarified the wide uses of funds that can be permissible under the Title I program).
      • Context matters. For example, a school operating a schoolwide program should be able to demonstrate that a Title I cost is consistent with the school’s needs assessment and schoolwide plan.
    • Costs must be necessary, reasonable, and allocable.

    When considering whether the Title I, Part A funds may be used at the LEA or building level, business managers and Title I, Part A directors and staff should ask themselves the following set of questions to determine if an expenditure is allowable:

    • How is the expenditure reasonable, necessary and allocable to carry out the intent and purpose of the Title I, Part A program?
    • What need does the expenditure address? How does it connect to relevant Title I, Part A schoolwide plan or targeted assistance plan? 
    • How will the expenditure be evaluated to measure a positive impact on student achievement?

    LEAs are encouraged to:

    • Carefully consider the needs of students, educators, and other relevant stakeholders.
    • Determine which activities are most likely to effectively address those needs.
    • Prioritize those activities when deciding what costs to support with ESSA funds (unless those activities are being paid for by other funding sources).

    Additional information and resources:


    Transferability

    Title V Section 5103 of the Every Student Succeeds Act (ESSA) permits a local educational agency (LEA) to transfer up to 100 percent of Title II, Part A and Title IV, Part A formula funds into other allowable federal Title programs. A few general rules apply to the transfers of funds:
    • LEAs may only transfer funds from Title II, Part A and Title IV, Part A.
    • The percentage of funds an LEA may transfer from allowable Title programs is not limited; it can be all or a portion of the available funds.
    • Consultation with private schools is required under ESSA Section 8501, if such a transfer affects students or educational personnel from private schools.
    • LEAs must consult with local Tribal governments if 50 percent or more of the schools/districts students are Native American/Alaska Native or the district receives $40,000 or more from a Title VI, Part A, Subpart 1 grant.
    • LEAs must notify OSPI 30 days prior to the transfer of funds through the submission of FP 821 in iGrants. 
    • Once funds are transferred, they take on the identity of the Title program into which they were transferred and must be spent under rules applicable to that Title program.

    Additional information and resources:


    Carryover

    School Districts with $50,000 or Higher Allocation

    There is a maximum 15 percent carryover of Title I, Part A funds from one year to the next (not including carryover from the prior year) for school districts with an allocation of $50,000 or more. Carryover in excess of 15 percent is permitted not more than once every three years; this process requires a waiver via Form Package 200.

    • Carryover funds that have a specific purpose required by law such as the one percent set-aside for parental and family engagement must still be spent on the original purpose.

    School Districts with Less than $50,000 Allocation

    For school districts with an allocation of less than $50,000, there is no restriction to the maximum amount of available carryover funds.


    Reallocations

    The funds available for reallocation vary each year. The amount is determined by (1) allocations not accepted by LEAs via form package 201, and (2) carryoverincluding excess carryovernot claimed by LEAs in FP 200. These funds are reallocated to LEAs in March via FP 355. Typically, LEAs are chosen for reallocation based on their reduced allocation, with preference going to LEAs with the highest percentage of reduction. An LEA's poverty rate and carryover amount may also impact being selected for reallocated funds.

    Reallocation awards are treated as an increase to the current year's Title I, Part A allocation; therefore, please note:

    • These funds are not required to be obligated by August 31 of the current year, however;
    • They are included in the award amount that is subject to the 15 percent carryover limitation.
    • If funding is allocated to buildings, ranking and allocating guidelines must be followed.

    Combining Funds

    Schoolwide programs are intended to provide flexibility for serving students in eligible school buildings by combining certain federal, state, and local revenues to more effectively address the needs of all academically struggling students.

    LEAs may only operate schoolwide programs in Title I, Part A buildings that have been identified in the district Title I, Part A iGrants application. Schools in which at least 40 percent of the students are from low-income families may combine Title I, Part A with certain other federal, state, and local funds in order to improve academic performance of all students, particularly the lowest achieving students.

    Additional information and resources:

    This section includes information on allocations, allowability, transferability, carryover, reallocations, and combining funds.

    Time and Effort

    All employees charged to federal grants must document the time they spend working on the grant's objectives to demonstrate that the amounts charged to federal programs are true and accurate.

    Additional information and resources:

    • Time and Effort FAQ
    • B048-17 Addendum Bulletin
    • Attachment 1: Semi-Annual Certification - Single Cost Objective
    • Attachment 2: Monthly PAR - Multiple Cost Objectives/Reconciliation to Payroll Records
    • Attachment 3: Monthly PAR with Multiple Cost Objectives for Employee with Fixed-Schedule (if not using the "Fixed Schedule" system)
    • Attachment 4: Employee Certification and Schedule - Employee with Fixed Schedule (if using the "Fixed Schedule" system)

    ESSA Law

    Education Department General Administrative Regulations (EDGAR)

    Records Retention

    Records from a federal grant must be retained for five years, plus the current year, for a total of six years. If a district has a pending audit, the records must be retained until the audit is settled.

    Additional information and resources:

    • The Secretary of State (SOS) guide on how to scan/image record retention requirements for compliance with state law
    • SOS calendar of trainings

    This section includes information on time and effort, laws, Non-Regulatory Guidance, EDGAR, and records retention.

    Title I, Part A Schools in Washington State

    Washington State Poverty Data (FRPL and CENSUS)


    This section includes information on Title I, Part A schools as well as poverty data.
    Tags: 
    Fairness in education