Title I Fiscal Responsibilities Presented by: New Jersey Department of Education Office of Title I Program Planning and Accountability Are You Fiscally.

Title I Fiscal Title I Fiscal ResponsibilitiesResponsibilities

Presented by:Presented by:

New Jersey Department of New Jersey Department of Education Education

Office of Title I Program Planning Office of Title I Program Planning and Accountabilityand Accountability

Are You Fiscally Compliant?

What is Needed to be in What is Needed to be in Compliance with Title I & Compliance with Title I &

Where to Find ItWhere to Find It• Title I LawsTitle I Laws

– No Child Left BehindNo Child Left Behind• www.ed.gov/legislation/ESEA02/index.htmlwww.ed.gov/legislation/ESEA02/index.html

• OMB Circular A-87, Attachment BOMB Circular A-87, Attachment B– www.whitehouse.gov/omb/circulars/a087/www.whitehouse.gov/omb/circulars/a087/

a087_2004.pdfa087_2004.pdf

• EDGAR EDGAR – http://www.ed.gov/policy/fund/reg/edgarReg/http://www.ed.gov/policy/fund/reg/edgarReg/

edgar.htmledgar.html• Compliance Supplement (A-133) Compliance Supplement (A-133)

– http://www.whitehouse.gov/omb/circulhttp://www.whitehouse.gov/omb/circulars/a133_compliance/05/cs5updates.htars/a133_compliance/05/cs5updates.htmlml

Board MinutesBoard Minutes

Resolutions to:Resolutions to:

Apply for Funds (copy of budget Apply for Funds (copy of budget statement)statement)

Accept the FundsAccept the Funds

What should be in my Board minutes?

Board Minutes (continued)Board Minutes (continued)

Appointment of TeachersAppointment of Teachers NameName SalarySalary SchoolSchool Funding Percentage for Each ProgramFunding Percentage for Each Program

Appointment of Secretaries, Aides, Appointment of Secretaries, Aides, Program Directors, etc.Program Directors, etc.

NameName SalarySalary Work LocationWork Location Funding Percentage for Each ProgramFunding Percentage for Each Program

What should be in my Board minutes?

Final Expenditure ReportsFinal Expenditure Reports• Must be consistent with budget (amendments Must be consistent with budget (amendments

filed through County Office)filed through County Office)• Must file separate final expense report for Must file separate final expense report for

Carryover monies spent in current yearCarryover monies spent in current year• CANNOT:CANNOT:

– Move more than 10% of Move more than 10% of total fundstotal funds or $50,000, or $50,000, whichever is less, without State approval (filed whichever is less, without State approval (filed through County Office)through County Office)

– Add a budget category without State approval (filed Add a budget category without State approval (filed through County Office)through County Office)

– Carryover more than 15% of Carryover more than 15% of total amounttotal amount received received more than once every three years without State more than once every three years without State approvalapproval

Carryover of FundsCarryover of Funds(Set Asides)(Set Asides)

Some Carryover Funds are Restricted Some Carryover Funds are Restricted to the Original Intent and Purpose of to the Original Intent and Purpose of the Fundingthe Funding

**** Accounting Tracking Required ******** Accounting Tracking Required ****

• Parental Involvement Parental Involvement – If these funds carried over, then can only be spent for If these funds carried over, then can only be spent for

original intent and purpose or must be refund to SEAoriginal intent and purpose or must be refund to SEA• Professional Development (SINI and DINI)Professional Development (SINI and DINI)

– If these funds carried over, then can only be spent for If these funds carried over, then can only be spent for original intent and purpose or must be refund to SEAoriginal intent and purpose or must be refund to SEA

Select Expenditures and Select Expenditures and Support NeededSupport Needed

• Fully-funded SalariesFully-funded Salaries

– Periodic certification signed at least Periodic certification signed at least semi-annuallysemi-annually

– Signed by employee and supervisorSigned by employee and supervisor

Select Expenditures and Select Expenditures and Support NeededSupport Needed

• Split-funded SalariesSplit-funded Salaries

– Personnel activity reportsPersonnel activity reports– Signed by employee and supervisorSigned by employee and supervisor– Must be an after-the-fact distribution Must be an after-the-fact distribution

of actual activityof actual activity– Prepared at least monthly and must Prepared at least monthly and must

coincide with pay periodscoincide with pay periods

Use of ParaprofessionalsUse of Paraprofessionals

Effective January 8, 2002 all newly appointed Effective January 8, 2002 all newly appointed paraprofessionals must:paraprofessionals must:

Have at least an Associates Degree or Have at least an Associates Degree or Have two years of college orHave two years of college or Pass a State administrated exam on Pass a State administrated exam on

readiness readiness – Note: All existing paraprofessionals must Note: All existing paraprofessionals must

obtain the degree within four years (start of obtain the degree within four years (start of 2006-2007 school year)2006-2007 school year)

– In a Schoolwide Program all paraprofessionals In a Schoolwide Program all paraprofessionals (not just Title I funded) must meet the above (not just Title I funded) must meet the above standards.standards.

Use of Third Party Providers Use of Third Party Providers for Non-Public Servicesfor Non-Public Services

USDOE has recently been reviewing USDOE has recently been reviewing the services to non-public the services to non-public students and has cited at least students and has cited at least two states on the way they give two states on the way they give guidance on Non-Public Services guidance on Non-Public Services by Third Party Providersby Third Party Providers

Use of Third Party Providers Use of Third Party Providers for Non-Public Servicesfor Non-Public Services

Third Party Provider Contracts:Third Party Provider Contracts: - When bid, the specifications should have the - When bid, the specifications should have the

Stephens Amendment wordingStephens Amendment wording - Vendor Complaint Policy- Vendor Complaint Policy - Details on who provides parental involvement - Details on who provides parental involvement

activitiesactivities - Renting/Ownership of Supplies, Trailers, etc.- Renting/Ownership of Supplies, Trailers, etc. - Breakout of Invoices to Include:- Breakout of Invoices to Include: - Instructional Salaries and Benefits- Instructional Salaries and Benefits - Instructional Supplies- Instructional Supplies - Rental of books, supplies, trailers- Rental of books, supplies, trailers - Administrative Charges/Profit- Administrative Charges/Profit

Use of Third Party Providers Use of Third Party Providers for Non-Public Servicesfor Non-Public Services

Remember that the Administrative Costs of Remember that the Administrative Costs of Third Party Providers counts against the Third Party Providers counts against the Districts Five Percent (5%) Total Districts Five Percent (5%) Total Administrative CostsAdministrative Costs

Who pays the Administrative Costs? Off the Who pays the Administrative Costs? Off the top allocation of the District of Other Title I top allocation of the District of Other Title I Funds (USDOE Non-Regulatory Guidance) Funds (USDOE Non-Regulatory Guidance)

Select Expenditures and Select Expenditures and Support NeededSupport Needed

• General PurchasesGeneral Purchases

– Must have purchase ordersMust have purchase orders– Must have account number on P.O.Must have account number on P.O.– Should indicate Title I purchasesShould indicate Title I purchases– Signed by Business AdministratorSigned by Business Administrator– If split P.O., Title I should be easily If split P.O., Title I should be easily

identifiableidentifiable

Select Expenditures and Select Expenditures and Support NeededSupport Needed

• EquipmentEquipment

– Maintain master inventory listingMaintain master inventory listing•Date, Serial Number, Model, Cost, LocationDate, Serial Number, Model, Cost, Location

– Each school should maintain subsidiary Each school should maintain subsidiary listinglisting

– All equipment should be labeled with “Title All equipment should be labeled with “Title I” or equivalent tracking systemI” or equivalent tracking system

– Need to keep records for FIVE years past Need to keep records for FIVE years past disposition (date needs to be on master list)disposition (date needs to be on master list)

Select Expenditures and Select Expenditures and Support NeededSupport Needed

• Employee BenefitsEmployee Benefits

– TPAF/FICA reimbursement applies only to TPAF/FICA reimbursement applies only to teachers’ contracted salaries, supervisors and teachers’ contracted salaries, supervisors and program directorsprogram directors

– TPAF/FICA reimbursement report does not TPAF/FICA reimbursement report does not apply to aides, secretaries or clerical, stipends, apply to aides, secretaries or clerical, stipends, substitute teachers or summer teacherssubstitute teachers or summer teachers

– All other benefits based on actual cost, not All other benefits based on actual cost, not budgeted percentagesbudgeted percentages

Select Expenditures and Select Expenditures and Support NeededSupport Needed

• Employee Benefits – TPAF/FICA Employee Benefits – TPAF/FICA Reimbursement ReportReimbursement Report

Salaries Title 1 Other Federal Total Rate Total

Contractual Salaries

352,808.00 -

352,808.00 -

352,808.00 6.68% 23,567.57

Amounts subject to SS

352,808.00 -

352,808.00 7.65% 26,989.81 Amounts only subject - 1.45% - To Medicare

352,808.00 $ 50,557.39

Policy StatementsPolicy Statements

Should have District Policies on:Should have District Policies on:

• Maintenance of EffortMaintenance of Effort

• Comparability Comparability

• Supplement vs. SupplantSupplement vs. Supplant

Policy StatementsPolicy Statements

Maintenance of EffortMaintenance of Effort

Current Expenditures (Not Including Capital Outlay)Current Expenditures (Not Including Capital Outlay)Less: Community ServicesLess: Community ServicesDivided by: Average Daily AttendanceDivided by: Average Daily Attendance

Compare to prior year (current year/prior year) and Compare to prior year (current year/prior year) and must be at least 90%must be at least 90%

*** Must Be Done Annually ***

Policy StatementsPolicy Statements

Maintenance of Effort ExampleMaintenance of Effort ExampleFISCAL CURRENT COMMUNITY CURRENT DAILY PERYEAR EXPENDITURES SERVICE EXPENDITURES ATTENDANCE PUPIL

(A) - (B)= C (C) / (D)= E

1999 $3,367,661.00 $0.00 $3,367,661.00 453.0 7,434.13$

2000 $4,700,145.00 $0.00 $4,700,145.00 465.0 10,107.84$

Calculation: 10,107.84$ 7,434.13$ 135.97%

2000 1999 (must be > 90 %)( E ) ( E )

Policy StatementsPolicy Statements

ComparabilityComparability

• Compare Like-Kind Schools (Title 1 to Compare Like-Kind Schools (Title 1 to Non-Title 1) orNon-Title 1) or

• Compare Like-Kind Title 1 Schools to Compare Like-Kind Title 1 Schools to each other oreach other or

• Compare Like-Kind Grade Span Compare Like-Kind Grade Span Groupings (Elementary, Middle or Groupings (Elementary, Middle or High)High)

Policy StatementsPolicy Statements

ComparabilityComparability

The average number of students per The average number of students per instructional staff for Title I schools instructional staff for Title I schools does not exceed 110 percent of the does not exceed 110 percent of the average of schools not participating in average of schools not participating in Title I programs; Title I programs;

oror

Policy StatementsPolicy Statements

ComparabilityComparability

The average instructional staff salary The average instructional staff salary expenditure per student for Title I expenditure per student for Title I schools is at least 90 percent of the schools is at least 90 percent of the average of schools not participating in average of schools not participating in Title I programs.Title I programs.

Policy StatementsPolicy Statements

Components Needed for ComparabilityComponents Needed for Comparability• Short FormShort Form

– Instructional staff only Full Time Staff Equivalent (FTE)Instructional staff only Full Time Staff Equivalent (FTE)– Pupils enrolledPupils enrolled– Different sheets depending on if ALL schools are funded or if Different sheets depending on if ALL schools are funded or if

some are funded and some are notsome are funded and some are not

• Long Form (if required)Long Form (if required)– District-wide salary scaleDistrict-wide salary scale– All employees at first range of scaleAll employees at first range of scale

** Required to document compliance once every year **** Required to document compliance once every year **

Supplement Not Supplant Supplement Not Supplant

• Funds must be “supplemental” to Funds must be “supplemental” to local spendinglocal spending

• Supplemental Defined: Supplemental Defined:

““In the absence of federal funds, In the absence of federal funds, would funds have been spent (prior would funds have been spent (prior year funding is one distinguishing year funding is one distinguishing factor)”factor)”

Supplement Not Supplant Supplement Not Supplant

• If all students/classroom get items, If all students/classroom get items, district can’t pay for Title I part out of Title district can’t pay for Title I part out of Title I funds I funds

• Items purchased should not be used by Items purchased should not be used by non-Title I studentsnon-Title I students

• Presentations/Trips should not benefit Presentations/Trips should not benefit non-Title I studentsnon-Title I students

• Special rules apply to approved and Special rules apply to approved and implemented “Schoolwide Programs”implemented “Schoolwide Programs”

Schoolwide Programs Schoolwide Programs

• MUST have approved plan that MUST have approved plan that addresses all schoolwide issuesaddresses all schoolwide issues

• Time sheets are required Time sheets are required

Schoolwide Programs Schoolwide Programs

• Approval on a school by school basisApproval on a school by school basis

• Key questions to be addressed: Key questions to be addressed: – Do the activities budgeted support the Do the activities budgeted support the

intent of the law? [Federal Register: July intent of the law? [Federal Register: July 2, 2004 (Volume 69, Number 127)]2, 2004 (Volume 69, Number 127)]

– Are supplemental services provided to Are supplemental services provided to the students enrolled in the school?the students enrolled in the school?

Frequently Asked Questions Frequently Asked Questions

• Time Sheets and SalariesTime Sheets and Salaries•Multiple Federal Grants – If someone works Multiple Federal Grants – If someone works

on multiple federal grants, must their salary on multiple federal grants, must their salary be allocated to all the grants since it is one be allocated to all the grants since it is one large federal pot of money – yes, since each large federal pot of money – yes, since each is a separately funded programis a separately funded program

Frequently Asked Questions Frequently Asked Questions

• Title I Set-AsidesTitle I Set-Asides•Choice/SES – If no Choice than all SES, If no Choice/SES – If no Choice than all SES, If no

SES, then all Choice, If both minimum 5% for SES, then all Choice, If both minimum 5% for each and 10% district option. each and 10% district option.

– May use state or local money to meet this May use state or local money to meet this obligation – just be able to verifyobligation – just be able to verify

- Must track per pupil expenditures by - Must track per pupil expenditures by studentstudent

Frequently Asked Questions Frequently Asked Questions

• Title I Set-AsidesTitle I Set-Asides•Teacher and Paraprofessional Qualifications Teacher and Paraprofessional Qualifications

– Must set aside not less than 5% unless – Must set aside not less than 5% unless lesser amount is needed and can be lesser amount is needed and can be documented that it is not needed. documented that it is not needed.

– All teachers in Title I schools can benefit, not just All teachers in Title I schools can benefit, not just Title I. Title I.

– May not use in Non-Title I schools.May not use in Non-Title I schools.– North Dakota Policy LetterNorth Dakota Policy Letter

Frequently Asked Questions Frequently Asked Questions

• Title I Set-AsidesTitle I Set-Asides•Parental Involvement – Must show that at least Parental Involvement – Must show that at least

1% was spent on grants over $500,0001% was spent on grants over $500,000. .

– Be able to document all parental Be able to document all parental involvement activities with associated costsinvolvement activities with associated costs

– Remember that 95% must be at the school Remember that 95% must be at the school level and five percent can be at the district level and five percent can be at the district levellevel

– Remember Carryover Restriction and Remember Carryover Restriction and Tracking of FundsTracking of Funds

Frequently Asked Questions Frequently Asked Questions

• Title I Set-AsidesTitle I Set-Asides•Professional Development – Must set-aside Professional Development – Must set-aside

10% if school is identified as in need of 10% if school is identified as in need of improvement.improvement.

- Remember Carryover Restriction and Tracking of Remember Carryover Restriction and Tracking of FundsFunds

• If Parental Involvement or Professional If Parental Involvement or Professional Development reserved, then proportional Development reserved, then proportional amount for nonpublic (Regulations 200.65(a))amount for nonpublic (Regulations 200.65(a))

CAPA Visits CAPA Visits and and

Title I Addendum Title I Addendum • In conjunction with the Title I CAPA Visits In conjunction with the Title I CAPA Visits

(year 3 and year 4 schools), a Title I (year 3 and year 4 schools), a Title I addendum will be doneaddendum will be done

• Helping our districts do the right thingHelping our districts do the right thing– Program ContentProgram Content– Fiscal ContentFiscal Content

• No monetary findings, but actions the No monetary findings, but actions the district needs to take to prevent any district needs to take to prevent any problems in the future and on-site problems in the future and on-site assistanceassistance

Common Audit Findings Common Audit Findings

• Personnel not listed in board minutes Personnel not listed in board minutes (with Title I percentage) for current year (with Title I percentage) for current year and carryoverand carryover

• Lack of time sheets (or signature of Lack of time sheets (or signature of employees/supervisors)employees/supervisors)

• TPAF/FICA not being properly calculatedTPAF/FICA not being properly calculated

• Not performing Maintenance of EffortNot performing Maintenance of Effort

• Not performing ComparabilityNot performing Comparability

Common Audit Findings Common Audit Findings

• Lack of inventory records on a Lack of inventory records on a perpetual basisperpetual basis

• Equipment not being labeledEquipment not being labeled• Improper payroll distribution (not pro-Improper payroll distribution (not pro-

rated)rated)• Purchase orders not indicating Title 1 Purchase orders not indicating Title 1

(and adjusting entries to reclass (and adjusting entries to reclass amounts)amounts)

• Final expense reports not matching Final expense reports not matching budgetsbudgets

Common Audit Findings Common Audit Findings

• Final expense reports not matching Final expense reports not matching budgets for individual line items (adding a budgets for individual line items (adding a line without State approval)line without State approval)

• Policies not being updated for current lawPolicies not being updated for current law

• Supplanting on purchases of non-salaried Supplanting on purchases of non-salaried itemsitems

• Not spending at the schools approved in Not spending at the schools approved in the applicationthe application

Common Audit Findings Common Audit Findings

• Encumbering Funds prior to the start Encumbering Funds prior to the start of the grantof the grant

• Not liquidating within 90 (ninety) Not liquidating within 90 (ninety) days of the end of the grantdays of the end of the grant

ConclusionConclusion

Remember: Remember:

“ “ If you take the money, you are responsible If you take the money, you are responsible for knowing the rules and regulations for knowing the rules and regulations concerning the grant.”concerning the grant.”

If you need further help contact:If you need further help contact:– Anthony Hearn at (609) 633-2492 or Anthony Hearn at (609) 633-2492 or

[email protected]@doe.state.nj.us