Federal Program Director’s Webinar - ESC-20 · • PNP Complaints and Procedures – ESSA PNP Complaints and Procedures – ESSA PNP Complaint Form (PDF) ... • All districts must

Federal Program Director’s Webinar2017-2018 12/14/2017

Agenda• EDGAR and Procurement

• LOGIC

• Grant News

– ESSA Consolidated Compliance Report

– TEA Guides: Recommended Uses of Funds

– Private Non-Profit

– Transitioning to a SW campus

• Resources

– Bridging the Gap

– A Guide to Statutory Professional Development/Training for Texas Public School Employees

• TEA updates

– TEAL/TEASE transition

– IDC

– Methodology for supplement not supplant Title IA

– Equity Plan

– SHARS

– Trainings

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Education Department General Administrative Regulations

A collection of general administrative requirements applicable to Federal education grants

Includes Uniform Guidance (2 CFR Part 200), which is applicable to all Federal grants

Includes other OMB Circulars specific to Federal education grants

Grant management system requirements for:

Financial Management

Procurement

Inventory Management

Education Department General Administrative Regulations

EDGAR Includes:

34 CFR Part 81 The General Education Provisions Act (GEPA)

Implements Part E of the General Education Provisions Act (GEPA)

Governs the enforcement of legal requirements under applicable programs administered by the Department of Education

Education Department General Administrative Regulations

Includes requirements for:

Allowability of Funds

Audit Requirements

Internal Controls

Documentation

Records Retention

Indirect Cost Rates

Participation of Students Enrolled in Private Schools (general rules; IDEA-B has program-specific rules)

Obligation and Liquidation of Funds

Education Department General Administrative Regulations

Procurement Definition

The act of obtaining or buying goods and services. The process includes preparation and processing of a demand as well as the end receipt and approval of payment. It often involves

(1) purchase planning,(2) standards determination,(3) specifications development,(4) supplier research and selection,(5) value analysis,(6) financing,(7) price negotiation,(8) making the purchase,(9) supply contract administration,(10) inventory control and stores, and(11) disposals and other related functions.

The process of procurement is often part of a company's strategy because the ability to purchase certain materials will determine if operations will continue.

http://www.businessdictionary.com/definition/procurement.html

Procurement

Procurement

News Bulletin covers several options for an LEA in procuring services from an ESC (1A-2B)

1. Use of Interlocal Agreements (1A-1B)

2. TEA authorizing ESC services as noncompetitive (2A-2B)

Option 2B

Each ESC may request TEA to provide a broad, general authorization that any service from that ESC be authorized as a noncompetitive procurement for LEAs. If your ESC submits this request to TEA then Options 1A and 2A are not needed

Cory GreenTEA’s Associate Commissioner of the Department of Contracts, Grants and Financial Administration

January 26Session ID 49031

Cory GreenTEA’s Associate Commissioner of the Department of Contracts, Grants and Financial Administration

January 26Session ID 49031

To attend via webinar (ZOOM), do NOT register in Connect20; ONLY register via the following link:

https://esc-20.zoom.us/meeting/register/538e07a594300373cde7dc3c8da9331e

EDGAR FAQs

New EDGAR Frequently Asked Questions (FAQ)• TEA has developed the following preliminary guidance

document applicable to all federally funded grant programs administered by the agency. Except where a question specifies a particular type of subgrantee, such as an education service center (ESC), all responses are intended for TEA subgrantees, primarily independent school districts (ISDs), charter schools, and ESCs.

• This FAQ will be updated as further information becomes available.

New EDGAR FAQ (Version 7, 06/01/2017)

EDGAR FAQs

7.1 Which procurement thresholds determine the strictest rules to follow, EDGAR or FASRG?

Response: The response varies depending on the subgrantee’sentity type: ESC, LEA or Charter.

Federal Fiscal Monitoring Updates

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LOGIC

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Https://www.esc20.net/page/sup_lg.LOGIC

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Grant News

ESSA

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ESSA

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ort 1. Did the LEA meet the identified one year performance measure (SMART Goals) …

2. If the LEA did not meet the one year performance measure, insert one or more related, other indicators of progress toward meeting each SMART goal that was not met.

3. Did the LEA continue the performance measure in the 2018-2019 ESSA Consolidated Application?

4. Did the LEA change ESSA-funded programs or activities in the 2018-2019 ESSA Consolidated Application based on progress toward meeting SMART goals?

5. Describe how the LEA reviewed and/or modified programs and activities to ensure the LEA will meet or make progress toward SMART goals in 2018-2019.

6. Did the LEA spend at least 90% of funds budgeted on Schedule PS3001 on activities aligned to this priority? IF the LEA answered no, explain how and why the budgeted amount differed from actual expenditures.

7. Did the LEA implement a recommended use of ESSA funds for Strategic Priority … whether tied to a SMART goal or not? If yes, identify the federal funding program in the ESSA consolidated application that supported the recommended initiative.

ESSA

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1. Did the LEA implement a recommended use of ESSA funds for Strategic Priority … whether tied to a SMART goal or not? If yes, identify the federal funding program in the ESSA consolidated application that supported the recommended initiative.

Private Non-Profit

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Private Non-ProfitRandom Validation Timeline Draft

• January TEA notifications to LEAs

• February Deadline for submission of documents

• March TEA notification of results

• April ESC uploads technical assistance

Private Non-ProfitLEA Self-Assessment of Private Nonprofit Equitable Services

Private Non-ProfitLEA Self-Assessment of Private Nonprofit Equitable Services

Private Non-Profit

Ensure

• All communication is documented

• All inventory is accounted for

• Share with PNPs within your district [email protected]

• PNP Complaints and Procedures– ESSA PNP Complaints and Procedures

– ESSA PNP Complaint Form (PDF)

• Refer to the ESSA PNP Equitable Services FAQ (Version 1, 08/23/2017) for answers to common questions regarding the provision of equitable services.

Transitioning to a SW Campus

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Transitioning to a SW Campus

Developing the Schoolwide Plan

• To be schoolwide, a campus must complete a year of planning.

• An ESC assists and verifies that the year of planning took place.

• One-year planning is required, unless it is determined that less time is needed to develop and implement the schoolwide program.

SW Campus

Resources

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TEA

TEA is in the process of migrating to a new secure environment, TEA Login (TEAL), which replaces our older system, TEASE. Eventually, all TEA

applications will use TEAL.

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GFFC Users …

• No more rate extensions beyond 17-18

• All districts must submit a proposal for 18-19

• Will need three years of fiscal data for a one-year IDC

• PEIMS data will be brought in to complete 90% of what a district needs

TAA: 2018–2019 Process for Requesting Indirect Cost Rates (Independent School Districts Only)

TEA IDC page: https://tea.texas.gov/index2.aspx?id=3842&menu_id=645

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Indirect Cost Rate

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Ind

irect

Cost

Rate

TAA: 2018–2019 Process for Requesting Indirect Cost Rates (Independent School Districts Only)

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Indirect Cost Rate

Supplement not Supplant – All Federal Programs

Presumptions of Supplanting

1. Providing Services Required Under State or Local Law

2. Providing Same Services as Those Provided in Prior School Year with State or Local Funds

3. Providing the Same Services in Federal and Non-Federal Programs

Supplement not Supplant Flexibility– Title IASection 1118 (b) (b) FEDERAL FUNDS TO SUPPLEMENT, NOT SUPPLANT, NONFEDERALFUNDS.—

• (1) IN GENERAL.—A State educational agency or local educational agency shall use Federal funds received under this part only to supplement the funds that would, in the absence of such Federal funds, be made available from State and local sources for the education of students participating in programs assisted under this part, and not to supplant such funds.

• (2) COMPLIANCE.—To demonstrate compliance with paragraph (1), a local educational agency shall demonstrate that the methodology used to allocate State and local funds to each school receiving assistance under this part ensures that such school receives all of the State and local funds it would otherwise receive if it were not receiving assistance under this part.

• (3) SPECIAL RULE.—No local educational agency shall be required to— (A) identify that an individual cost or service supported under this part is supplemental; or (B) provide services under this part through a particular instructional method or in a particular instructional setting in order to demonstrate such agency’s compliance with paragraph (1).

• (5) TIMELINE.—A local educational agency— (A) shall meet the compliance requirement under paragraph (2) not later than 2 years after the date of enactment of the Every Student Succeeds Act;

Districts with SW and TA campuses must have written methodology

Supplemental Funds Test Methodology

To pass the supplemental funds test, the LEA must apply the same method to all of its campuses, and maintain documentation of its method and all related calculations.

• Methodology is written process

• Spreadsheet documents methodology was used

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Supplemental Funds Test Methodology

• Charter schools will need to consider any monies they code as “local” toward this methodology.

• School board approval, as always, is dependent on your local policy.

• While this test sounds like comparability, the difference is comparability is specific to certain expenditures and is not inclusive of all state and local funds as the SNS methodology is.

• This does not apply to districts/charters with only one campus.

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Supplemental Funds Test Methodology

USDE Provides Additional Time to Comply with New Title I, Part A SNS Requirement under ESSA

In a prior news bulletin issued on November 30, 2017, TEA reminded LEAs of the deadline set by USDE of December 10, 2017, to develop a supplement, not supplant methodology that complies with the requirement under ESSA.

In order to ensure a smooth transition to the new law, USDE today provided additional time to meet the supplement, not supplant compliance requirement. LEAs do not need to have their methodology in place by

December 10, 2017. However, the LEA must have a methodology in place for use in the 2018-2019 school year.

Please note that ESSA still requires that, even if the new methodology is not yet in place, TEA and LEAs utilize all Title I, Part A funds only to supplement the funds that would, in the absence of such Title I, Part A funds, be made available from State and local sources for the education of students participating in programs assisted

under Title I, Part A, and not to supplant, such State and local funds.

Methodology Submission to TEA Not Required

Once you have developed a new supplement, not supplant methodology, you will keep this documentation locally. You will not be required to submit your methodology to TEA.

TEA Training on Supplement, Not Supplant Methodology

TEA will be providing training in the spring 2018 on how to develop the new supplement, not supplant methodology. More details about the training will be released in January 2018.

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SHARSSchool Health and Related Services• Medicaid reimbursable services provided by the schools. • Services provided must be documented in the student's IEP• Student must be Medicaid eligible. • Texas Health and Human Services Commission (HHSC) and TEA have an MOU in place for

SHARs services. • This year, TEA is conducting both desk reviews and on-site audits of SHARS. • Reviews will include folder audits, interviews with key stakeholders, classroom observations,

and a parent summary. • TEA audit summary will then be provided to HHSC for the development of their compliance

report. • Individuals who prepare the cost report are required to complete training every odd year,

thus since this is 2017 training must be completed to enter data in the system. • A link to training information and the training schedule https://rad.hhs.texas.gov/acute-care/school-health-and-related-services/shars-training

SHARS listserv: https://www.esc20.net/page/esc.listserv

Equity Plan Updates

What we know

• TEA has reviewed submissions and will be contacting districts/charters whose plans were incomplete or need more information

• Remember your benchmarks: 6 months, 6-12 mo, 12-24 mo, 2-5 years

• Six-month checkpoint falls May 2018

• Unsure about “amendment” process for equity plans (or PR1500)

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Common Audit findings

– Not having policies/procedures (don’t have or don’t follow)

– Noncompetitive procurement (one of the four allowances - not supporting with documentation - using sole source letter only - by itself not justification) or sole source from prior years

– Obligating funds prior to start of grant period (signing contracts without exclusion clause that it depends on grant)

– Unable to verify payment for services rendered

– Unable to verify agreed upon rate paid (no documentation)

– High rate of contracts as sole sources

– Not providing documentation to show procurement was bid correctly

– Micro purchase - amount exceeds $3500;

– Small purchase - not getting sufficient number of quotes/no documentation for quotes they cited LEA for getting 2 quotes, but were cited since their local policy said they needed 3 quotes

Trainings• National Title I Conference

February 8-11, 2018 Philadelphia, PA

• ACET April 10-12, 2018 Austin

• Learning for A Change Summit• Feb. 5-6, 2018 Austin

– Day 1 Parent Involvement– Day 2 School Support

• Learning Roundtable January 31, 2018 Austin