Special Education Aid Eligibility for Certain Professional Staff

Date: January 12, 2006

To: School District, CESA, CCDEB, (2r) Charter School Administrators

From: David Carlson, Director
School Financial Services Team

Re: Special Education Aid Eligibility for Certain Professional Staff

Please route this information to district staff that complete the PI 1505 SAFR Annual Report, the PI 1505 SE (Special Education) report, and the PI 1202 Staffing report. District directors of special education and pupil services and school business managers will be especially interested in the following information.

The purpose of this letter is to clarify the cost eligibility of certain professional staff for reimbursement by state special education categorical aid. This letter supplements the information provided in a letter to districts date June, 2004. That letter is located on the department’s website at dpi.wi.gov/sped/doc/cat-aid-mem.doc.

Wisconsin State Statute 115.88 has recently been amended to include the additional following staff whose costs are eligible for reimbursement: school nurses (Registered Nurses (RNs), licensed by the Wisconsin Department of Regulation and Licensing not Licensed Practical Nurses (LPNs)) and for school counselors (license 54) for aid paid in 2006-2007.

Since many of these professionals, similar to school social workers and school psychologists, work in both the regular education and special education areas of operations, districts have asked for guidance in the allocation of their time and costs between regular education, fund 10 and special education, fund 27 for pupil services staff. Districts should consider the following information as applicable to school psychologists and school social workers as well as school nurses and school guidance counselors.

It is the intent of the statute that salary and fringe costs can be allocated to special education only for those staff that actually fulfill responsibilities associated with the district’s special education program. Please refer to the list of activities in the special education program below. Further, only the portion of the professional staff’s time and costs when fulfilling these responsibilities may be claimed for special education aid. Districts may use any of the following methodologies in determining time and costs; however, the determination must be done for each individual staff member the district wishes to claim. Districts may elect to use a different methodology for each staff member. Which ever methodology is used, the district must maintain documentation for audit purposes which reflects a rational and defensible method of allocation of costs. Allocating staff time and costs to special education based upon incident rates within the general school population is not an acceptable methodology.

Methodology #1: Use of employee position description. The employee and school district administration review the responsibilities or tasks identified on the employee’s position description. Each task or responsibility is evaluated on two criteria: percent of total time this task or responsibility reflects of the total tasks or responsibilities; and the percent of time this task meets the criteria of working with special education students or staff. This analysis would be repeated for all major tasks or responsibilities. The result will be a totaled special education related percentage that would then be multiplied by the total salary and fringe costs of the pupil services professional. The special education cost would be reported on PI 1505 SE. Note that it is understood that the 2005-2006 PI 1202 Staffing report has already been filed.

Methodology #2: Survey task analysis. Randomly select four weeks during the employee contract year and cause the employee to log the time spent on special education and regular education related activities. Omit weeks that do not normally reflect the work week of the staff person. Convert hours to percent of work week. One model is the time studies that are required for Medicaid reimbursement; these may be used for this purpose also. At the end of the year average the percents for special education. Apply the percent to salary and fringe cost and complete PI 1505 SE report at the end of the year.

Methodology #3: Require the employee to keep a daily log throughout the school year that identifies the time of activities as special education related. Convert to a percent and apply as referenced above.

Districts are required to maintain a copy of their analyses signed by both the professional and by school administration. This document is to be available for auditor review and for review by department staff. Note again that the district may use a different methodology for each individual staff member. Aid will not be paid without evidence of the required documentation.

Districts have also asked for guidelines on the type of activities of pupil services staff that would be eligible for special education aid. Below is a list that is intended to provide general guidance.

• IEP evaluations, program planning, and IEP meetings for eligible staff;
• Implementation of IEPs, including related services specified in the IEP;
• IEP team coordination (case management) responsibilities including the facilitation of transition for children in Birth to Three programs who qualify for early childhood special education programs;
• Supplementary aids and services, support for school personnel and parent training pursuant to an IEP; and
• Consultation with teachers and other staff regarding students with disabilities and IEP issues.

To report these staffing costs districts are directed to do the following:

Districts should continue to use function 212000 for social workers and 215000 for psychologists on both the PI 1505 SAFR Annual Report and PI 1505 SE Annual Report.

Beginning in 2005-2006, record in fund 27 on the 2005-2006 PI 1505 SAFR Annual Report the salaries and fringes (objects 100, 200) for time spent with the special education program paid directly to licensed (1) school guidance counselors in function 213000 and (2) school nurses in function 214000.

On the current version 4 PI 1505 SE, special education report, record the school guidance counselor and school nurse salary/fringes (objects 100/200) in the summary function 299 999 under Project “019” and identify these costs in the cover e-mail with the BH and AH upload file attachments as follows:

For (LEA Name), the “011-state aidable” guidance counselor and school nurse salary/fringe costs reported in function 299 999 under Project “019” on the PI 1505 SE are:

1. School Guidance Counselor
   1. Object 100 – Salary: (Amount)
   2. Object 200 – Fringes: (Amount)
2. School Nurse
   1. Object 100 – Salary: (Amount)
   2. Object 200 – Fringes: (Amount)

Contact one of the following individuals should you have questions about the types of activities allocable to special education.

Stephanie Petska	(608) 266-1781	stephanie.petska@dpi.wi.gov
Doug White	(608) 266-5198	douglas.white@dpi.wi.gov

Contact one of the following school finance consultants should you have questions about special education aid eligibility.

Brad Adams	(608) 267-3752	bradley.adams@dpi.wi.gov
Lori Ames	(608) 266-3464	lori.ames@dpi.wi.gov
Karen Kucharz	(608) 267-9707	karen.kucharz@dpi.wi.gov
Beverly Kraus	(608) 266-1089	beverly.kraus@dpi.wi.gov

dgd

January 27, 2006 Addenda: After this letter was mailed on January 12, the department received requests for clarification. The following is the department’s response to those requests. Note that this letter was not resent with the addenda but districts were informed via listserves of the changes and the letter was reposted to department websites.

Clarification #1 – Counselor costs with license #54, #964 and #966 are eligible for special education aid.

Clarification #2 - In order for pupil services staff costs to be eligible for special education aid, the staff must be employed not contracted by a school board, CESA, CCDEB, or (2r) charter school. (s. 115.88 Wis. Stats.).

Clarification #3 – Because of federal aid eligibility requirements, districts may not use methodology #1 for those employees whose salary or benefits are reimbursed by a Federal program or grant.

August 6, 2007
Clarification - Districts are required to update each employee's methodology and cost allocation yearly.

For questions about this information, contact dpifin@dpi.wi.gov (608) 267-9114

Last updated on 2/25/2008 12:03:51 PM