1 Read, wRite, and Report A pplications R ules and Regs R eporting Requirements and A uditors.

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Read, wRite, and ReportRead, wRite, and ReportRead, wRite, and ReportRead, wRite, and ReportAApplicationspplications

RRules and Regsules and Regs

RReporting Requirements eporting Requirements andand

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ReadRead

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Available Information

• www.isbe.net• http://www.isbe.net/spec-ed/html/i

dea_part-b.htm• http://

www.isbe.net/arra/pdf/arra_reporting_inst.pdf

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Helpful Internet SitesHelpful Internet SitesARRA Recovery Site :ARRA Recovery Site :http://www.recovery.gov/http://www.recovery.gov/

ARRA Department of Education GuidanceARRA Department of Education Guidancehttp://www.ed.gov/policy/gen/leg/recovery/index.htmlhttp://www.ed.gov/policy/gen/leg/recovery/index.html

ARRA-IDEA Part B Department of Education GuidanceARRA-IDEA Part B Department of Education Guidance http://www.ed.gov/policy/gen/leg/recovery/guidance/idea-http://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.pdfb.pdf

State or Federal Project and Payment Information:State or Federal Project and Payment Information:http://206.166.105.128/FRISInquiry/http://206.166.105.128/FRISInquiry/

IDEA 2004IDEA 2004 http://idea.ed.gov/explore/homehttp://idea.ed.gov/explore/home

USDE – Office of Special EducationUSDE – Office of Special Educationhttp://www.ed.gov/about/offices/list/osers/osep/index.htmlhttp://www.ed.gov/about/offices/list/osers/osep/index.html

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wRitewRite

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Important Terms

• Excess Cost

• Supplant

• Maintenance of Effort (MOE)

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Excess Cost• The LEA must maintain its local and

state fiscal effort (spending) for the education of children with disabilities before federal funds are used.

• This prevents LEAs from using federal funds to pay for all costs of special education

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Supplantsup plant (transitive verb)

1. oust somebody

2. replace

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If the LEA maintains (or exceeds) its level of local, or state and local, expenditures for special education and related services

from year to year, either in total or per capita, then the Part B

funds are, in fact, supplementing those local, or state and local, expenditures and the LEA has

met its MOE and supplement/not supplant requirements.

New Guidance on Supplanting

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Maintenance of Effort

Spending the same or greater amount of money (as was spent the previous year) from local funds to support special education.

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What is MOE?The Federal Standard is:“An LEA…must ensure that the amount of local funds it budgets for the education of children with disabilities in that year is at least the same…as the amount it spent for that purpose in the most recent fiscal year for which information is available…”

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Exceptions to MOE• Through normal attrition, qualified lower-

salaried staff replace higher-salaried staff

• Decrease in enrollment of children with disabilities

• Termination of obligation to a particular child that is exceptionally costly

• Termination of costly expenditures

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Use of IDEA Funds

Federal and state funds may be used for such expenditures as are reasonably necessary for providing appropriate programs and meeting the requirements of the law.

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Allowable Expenditures

• Staff salaries/benefits• Supplies/materials• Equipment• Other items necessary to sp.

ed. program

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Costs not permitted

• Private school tuition• Matching funds for grants• Debt reduction• Attorney’s fees for representation• Other expenditures not directly

related to the grant activities

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Out of State Travel

• Requires pre-approval

• Complete form and fax or mail to grant coordinator(Page 29 in “Blue Book”)

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Early Intervening Services (EIS)

• May use up to 15% of funds for EIS• Use of funds is specific

(page 16 in “Blue Book”)• Documentation will be needed

Who is targeted?What happens?

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Proportionate Share

• Funds are to serve students with disabilities in non-public schools. Figure is calculated at ISBE and published at http://www.isbe.net/funding/html/specialed.htm

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Grant Management

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There are rules . . .

Federal & State regulations

EDGAR & A133

(Pages 6-7 in “Blue Book”)

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Putting things in place

• Record keeping and office procedures are important

• Pages 30-32 in “Blue Book”

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FRIS Inquiry

• Financial Reimbursement Information System

• You can find budgets, payments, expenditure reports and more

• Find it at www.isbe.net

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Expenditure Reports

• Due quarterly

• Sent electronically

• Contact Sharon Conrathat 217/782-5256

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Frozen Funds!!!!

• Excess cash on hand• Late expenditure reports• Non-compliance with

regulations

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eGrant Application

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How to submit a grant:In IWAS:• Click “system listing”• Select grant • Click Yes• Give your grant a title• Click “create new project”• Move through all tabs to complete

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A Few Tips . . .

• To start grant, click Yes

• Save early save often

• No save button – may be locked

• Hold down Ctrl for checklist

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Important Details• Remember to list staff names

• Describe types of benefits

• Itemize supplies / materials

• Equipment is $500+ per unit

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Cooperative Grants

• The Cooperative is the AA

• The AA must allocate funds to member districts (green zero)

• The AA is responsible for all funds

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Things we’ve learned from reviewing audit findings!

Some findings are worse than others. Some findings have questioned costs. Findings affect LEA determination. Findings always require an action plan. Many people do not read the “Accounting

Procedures” section in the instructions.

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Uses of ARRA Funds

• Must be consistent with the current IDEA Part B statutory and regulatory requirements.

• Funds should be used for short-term investments that have potential for long-term benefits

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Possible ARRA IDEA uses:

• Assistive technology and training.• Intensive district-wide professional

development for special education.• Develop and expand the capacity to

collect and use data.• Expand placement options for

preschoolers.• Hire transition coordinators.

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ARRA IDEA Funding

All ARRA IDEA funds allocated to cooperatives and districts will be available until September 30, 2011.

ARRA IDEA funds cannot be obligated after that date.

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ReportReport General Reporting

RequirementsNote: Presentation is based on preliminary

information regarding reporting known as of 9/14/09 and is subject to change.

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Tracking ARRA Funds

• The State (SEA) is required to report ARRA funds separately

• SEA must maintain accurate documentation of all expenditures

• SEA must ensure data quality and proper expenditure of ARRA funds

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Questions Reports Must Answer:

• Who is receiving ARRA funds?• How much are they receiving?• What projects or activities are being

funded?• What is the completion status of the

projects?• What impact on job creation and

retention?

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When Are Reports Due?

• ARRA requires that the state’s report on the use of ARRA funding is due no later than the 10th day after the end of each calendar quarter.

• Due to the short timeline, LEAs will need to transmit ARRA data before the day that the state’s report is due.

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Federal Oversight Authority

• OMB, Recovery Board, Office of Inspector GeneralEstablish data quality expectationsEstablish data and technical standardsCoordinate any centralized reviews of

data• Findings by a Federal agency can result in

termination of Federal funding

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Cautions• No waivers will be granted regarding

required reporting• Reporting elements cannot be combined

with other Federal reporting requirements• Prime recipient (state) must avoid double

counting• Non-compliance with reporting

requirements is considered a violation of the award agreement and reports may be used to assess compliance with award agreements

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Who Reports?

• Prime recipients (States) have the primary responsibility for reporting all data.

• Sub-recipients (Districts) must report to the state.

• Reports are expected to meet the requirements of recent legislation regarding reporting.

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Prime Recipient

• Owns recipient data• Initiates appropriate data collection and

reporting procedures• Implements internal control measures to

ensure accurate and complete information• Performs data quality reviews and makes

appropriate and timely corrections

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Sub-recipients

• Own sub-recipient data• Initiates appropriate data collection and

reporting procedures• Implements internal control measures

to ensure accurate and complete information

• Reviews information and makes appropriate and timely corrections

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VendorsIf a sub-recipient (i.e. district or cooperative) awards ARRA funds greater than $25,000 to a vendor for services needed to carry out the project or program, the sub-recipient must report the identity of the vendor by reporting the DUNS number, if available, or otherwise the name and zip code of the vendor’s headquarters.

A vendor is defined as a dealer, distributor, merchant, or other seller providing goods or services that are required for the conduct of the program.A vendor: (1) Provides the goods and services within normal business operations; (2) Provides similar goods or services to many different purchasers; (3) Operates in a competitive environment; (4) Provides goods or services that are ancillary to the operation of the Federal program; and(5) Is not subject to compliance requirements of the Federal program.

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Required Data Elements

• Sub-recipient DUNS

• Sub-recipient type

• Amount received• Amount awarded

• Sub-award date• Sub-award period• Place of

performance• Area of benefit• Officer names and

compensation

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ARRA Reporting Variables

• All districts and cooperatives must have a Nine Digit Dun and Bradstreet (DUNS) number assigned http://fedgov.dnb.com/webform

• Central Contracting Registration (CCR) – you must have a DUNS number to register at CCR. More information available at http://www.ccr.gov

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Expenditure Reports

• Transfer of funds by a cooperative to a member district’s subgrant does not constitute an expenditure.

• Cooperatives must ensure member districts have expended funds that were subgranted and report the aggregated expenditures on their quarterly and final expenditure reports.

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ARRA Reporting Variables

All expenditure and other ARRA data must be reported CUMULATIVELY or year-to-date from the point that each LEA began expending ARRA funds through the end of each quarterly reporting period.

Each subsequent quarterly report will also be cumulative. In other words, the report due January 2010, will include the data reported through September 2009 and be updated to include data that accumulated through December 2009. ISBE will aggregate all ARRA expenditures across fiscal years for each LEA.

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Jobs Created and RetainedA job created is a new position created and filled; a job retained is an existing position that would not have been continued were it not for ARRA funding.

FTE – Full Time Equivalency

Enter the FTE for each position. This is calculated as total hours worked divided by the number of hours in a full-time schedule. The figure should be reflected to two decimal places.

The number reported should represent a reasonable average of FTE’s created and retained for the quarter. Such an estimate would ideally be done by taking FTE’s for each pay period in the quarter and averaging them. It could also be done at a single point in time, as long as care is taken that the single point is representative of the quarter for the position.

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Reporting on Jobs Creation

• Required to report an estimate of jobs directly created or retained

• Number of jobs expressed as FTEs• Report includes a job title or labor

category• Report only on “direct” jobs• Report on all jobs attributable to an

award

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Federal Funding Accountability and Transparency Act (FFATA)Not later than January 1, 2008, the Office of Management and Budget shall, in accordance with this section, section 204 of the E-Government Act of 2002 (Public Law 107-347; 44 U.S.C. 3501 note), and the Office of Federal Procurement Policy Act (41 U.S.C. 403 et seq.), ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each --

(A) the name of the entity receiving the award; (B) the amount of the award; (C) information on the award including transaction type,

funding agency, the North American Industry Classification System code or Catalog of Federal Domestic Assistance number (where applicable), program source, and an award title descriptive of the purpose of each funding action;

(D) the location of the entity receiving the award and the primary location of performance under the award, including the city, State, congressional district, and country;

(E) a unique identifier of the entity receiving the award and of the parent entity of the recipient, should the entity be owned by another entity; and

(F) any other relevant information specified by the Office of Management and Budget.

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Reporting MOEReporting MOEReporting MOEReporting MOE

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Reporting Requirement

Districts that choose to supplant must track these funds separately so that it can be substantiated that the supplanted funds were used for other ESEA programs.

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If the LEA maintains (or exceeds) its level of local, or state and local, expenditures for special education and related services from year to year, either in total or per capita, then the Part B funds are, in fact, supplementing those local, or state and local, expenditures and the LEA has met its MOE and supplement/not supplant requirements.

New Guidance on Supplanting

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The 50% Rule“An LEA may treat as local funds up to 50% of the amount of funds it is eligible to receive…from that appropriation that exceeds the amount from funds appropriated for the previous fiscal year that the LEA was eligible to receive…to carry out activities that could be supported with funds under the ESEA regardless of whether the LEA is using funds under the ESEA for those activities.”

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For ExampleFY 09 IDEA Allocation = $1,000,000

FY 10 IDEA Allocation = $1,000,000FY 10 ARRA IDEA Allocation = $1,000,000

Total FY 10 = $2,000,000

Difference between FY 09 and FY 10 is $1,000,000.

The 50% rule allows the district to use 50% of this amount or $500,000 to supplant local expenses.

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Maintenance of Effort and the 50% Rule

The District’s MOE is $3,000,000 in FY 09The District’s MOE is $3,000,000 in FY 10

Since the 50 % rule allows the District to use $500,000 to supplant local expenses, the district can subtract this amount from MOE and report the new total, $2,500,000, as the FY 10 MOE.

$2,500,000

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MOE Questions• Total IDEA Flow Through and IDEA

Preschool Allocations to LEAs?• What was the LEAs Determination

status?• Reduction of state and local funds taken

in dollars?

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Early Intervening Early Intervening ServicesServices

(EIS) Reporting(EIS) Reporting

Early Intervening Early Intervening ServicesServices

(EIS) Reporting(EIS) Reporting

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EIS questions• Was the LEA required to use 15% for EIS due to

disproportionality?

• What was the amount the LEA was required to spend?

• Did an LEA voluntarily use up to 15% for EIS?

• What Amount was voluntarily reserved for EIS?

• Total number of children receiving CEIS under IDEA in FY 10?

• Total number of children who received EIS under IDEA anytime in the past two school years (FY09 and FY10)?

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Contact Information• IDEA Grant Coordinators – Bonnie

Douglas and Penny Kelly at 217-782-5589– [email protected] and [email protected]

• Funding and Disbursements Consultants – Kim Lewis or Sharon Conrath at 217-782-5256– [email protected] and [email protected]