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Frequently Asked Questions About IDEA Grant Funding (including IDEA Recovery Funds)
Top 10 FAQ | Application Procedures | Use of IDEA Recovery Funds | Use of Funds for CEIS | Parentally Placed Private School Students | MOE | Use of Freed Up Funds | Reporting and Accountability | Claims A. Application Procedures
B. Use of IDEA Recovery Funds
C. Use of Funds for Coordinated Early Intervening Services (CEIS)
D. Parentally Placed Private School Students
E. Maintenance of Effort (MOE)
F. Use of Funds Freed Up Through the 50% Rule
G. Reporting and Accountability
H. IDEA Claims
A. Application ProceduresA1. What are the procedures for receiving IDEA Recovery funds? Although utilizing the same budget software system, the IDEA Recovery application and reporting process is separate from the regular IDEA flow-through and preschool entitlement process. Each LEA submits the assurances required for all IDEA grants, IDEA Recovery flow-through and preschool applications, including budgets, claims, and reports. No cooperative applications are accepted. A2. How does an LEA submit an application for Recovery funds? LEA budgets, claims, and required reports may be submitted through the Special Education Portal at https://www2.dpi.state.wi.us/seportal. The assurances required for all IDEA grants may be downloaded from http://dpi.wi.gov/sped/lpp-assurances.html. A list of helpful links for IDEA budgets is found at http://dpi.wi.gov/sped/pdf/lpp-helpful_links_for_budget_software.pdf. A3. What amount of IDEA Recovery funds will each LEA receive? Wisconsin will receive $218,027,899 in flow-through and preschool IDEA Recovery funds. The DPI has calculated LEA IDEA-Part B allocations in accordance with the IDEA regulations, including both IDEA Recovery funds and the IDEA flow-through and preschool entitlement funds. The fiscal year 2009-2010 flow-through allocation spreadsheet may be accessed at http://dpi.wi.gov/sped/xls/fy10flow.xls and the preschool allocation spreadsheet at http://dpi.wi.gov/sped/xls/presch10.xls. A4. May an LEA refuse IDEA Recovery funds? An LEA may refuse to accept IDEA-Part B funds, including IDEA Recovery funds. An LEA considering refusing IDEA Recovery funds should review the Office of Special Education Programs ARRA guidance at http://www.ed.gov/policy/gen/leg/recovery/guidance/idea-b.doc. [A-4, pp. 8-9]. LEAs considering refusing funds should consider the potential uses of the funds and the impact of refusing the funds on the LEA and the community it serves. If an LEA decides to refuse IDEA Recovery funds, the district administrator must send a written refusal to the State Director of Special Education, Stephanie Petska. The DPI will review the LEA’s decision. LEAs are reminded they must make available to parents of children with disabilities and to the general public all documents relating to the eligibility of the LEA for IDEA funds. [34 CFR §300.212] A5. Must all IDEA budgets, regular IDEA entitlement and IDEA Recovery budgets, be submitted before an LEA may use IDEA Recovery funds? No. An LEA may claim funds only after the required IDEA assurances for the IDEA grants and IDEA Recovery budgets have been submitted and approved. The IDEA assurances may be accessed at http://dpi.wi.gov/sped/lpp-assurances.html. All budgets, both regular IDEA entitlement and IDEA Recovery, and IDEA assurances are due by July 1, 2009. A6. May an LEA budget just part of its IDEA Recovery allocation if it has not yet decided how to use the entire allocation? Yes. At the outset, an LEA may budget all of the Recovery funds or may budget part of the funds. After the Recovery budget is approved, the LEA may amend it. Recovery budgets must be submitted by July 1, 2009. Claims can only be paid on the amounts in existing approved budgets. A7. How soon after a budget is submitted will it be reviewed? In most cases, a budget will be reviewed and approved, or disapproved and unlocked for amendment, within two weeks of submission. A8. Will LEAs be able to apply an indirect cost rate for IDEA Recovery budgets? Yes. The rate currently determined for an LEA may be applied to the IDEA Recovery grants. A9. How are indirect cost rates determined? Indirect costs are costs incurred to benefit more than one program or objective not readily assignable to the programs. The indirect cost rate is negotiated between an LEA and DPI’s Division for Finance and Management. The IDEA Recovery budget software allows an LEA to enter in an approved indirect cost rate up to its negotiated amount. If the LEA does not have an approved indirect cost rate, the LEA cannot claim indirect costs. Additional information on indirect costs is available at http://dpi.wi.gov/sfs/indirect.html. A10. I don’t remember my password for the Special Education Portal. What should I do? Authorized users may contact Linda Peterson at (608) 267-2063 or linda.peterson@dpi.wi.gov. She will reset the user’s password. B. Use of IDEA Recovery FundsB1. What are the timeframes for use of IDEA Recovery funds? The funding cycle for the IDEA Recovery funds is February 17, 2009, (the date ARRA was signed) through September 30, 2011. The IDEA Recovery budgets will not be “re-set” on July 1, 2010. After initial submission, IDEA Recovery budgets will be in “amendment mode” until September 30, 2011. LEAs will have until then to obligate the IDEA Recovery funds. There will be no carry-over after this date. Recovery funds not obligated by this date will be returned to the U.S. Department of Education. B2. What does it mean to obligate funds? An obligation is a transaction that requires payment. An LEA must be able to relate ALL costs to a specific transaction that occurred during the period of grant availability. The chart below demonstrates when an obligation has occurred:
A grantee must liquidate all obligations incurred under an IDEA grant award by September 30th after the fiscal year has ended. For example, if an LEA has a written signed agreement with a vendor on June 25 of the fiscal year, the vendor services must be received and the payment made to the vendor on or before September 30th. An LEA may not use IDEA funds to pay in advance for services that cover multiple years. For example, an LEA cannot sign a lease agreement for a vehicle and pay three years of payments up front using a single fiscal year’s IDEA funds. B3. How should the IDEA Recovery funds be used? These funds should be spent in ways likely to improve results for students, produce long-term gains in LEA capacity and effectiveness, accelerate reform, and foster continuous improvement. LEAs are cautioned to invest one-time IDEA Recovery funds thoughtfully to minimize what the federal government is calling the “funding cliff.” The funds should be invested in ways that do not result in unsustainable continuing commitments after the funding expires. Suggested strategies for using IDEA Recovery funds in conjunction with other funding sources to accomplish ARRA’s goals may be found at http://dpi.wi.gov/recovery/pdf/uses-strategies2009-05-05.pdf. B4. What are allowable costs for IDEA Recovery funds? IDEA Recovery funds are subject to the same restrictions as regular IDEA funds. They must only be used for the excess costs of providing special education. For a particular cost to be allowed, it also must be necessary and reasonable for proper and efficient performance and administration of the grant. Funds must be used in accordance with the guidelines for IDEA allowable costs and Wisconsin’s state statutes. A table of allowable IDEA flow-through and preschool costs is available at http://dpi.wi.gov/sped/pdf/IDEA-dos-and-donts.pdf. A table of allowable CEIS costs is available at http://dpi.wi.gov/sped/pdf/eis-allowables-FY10.pdf. B5. How can you determine if a cost is an excess cost of providing special education services? When determining whether a cost is an excess cost, ask the following guiding questions. In the absence of special education needs, would this cost exist? Is this cost also generated by students without disabilities? If it is a child specific service, is the service documented in the student’s IEP? B6. Will the provisions for the permissive and the required use of flow-through funds for coordinated early intervention services (CEIS) apply to IDEA Recovery funds? Yes. IDEA Recovery funds are subject to the same restrictions as regular IDEA funds. Because all the IDEA Recovery funding is considered 2009-2010 funding, for that year the calculation of the 15% for CEIS is based on the combined regular IDEA entitlement and IDEA Recovery allocations. Current information on allowable costs for CEIS may be found at http://dpi.wi.gov/sped/pdf/eis-allowables-FY10.pdf. B7. May regular IDEA entitlement funds and IDEA Recovery funds be used to retain staff slated for layoff? Yes. Both regular IDEA entitlement and IDEA Recovery funds may be used to retain special education staff slated for layoff or contract reduction. Moving special education staff from local funds to regular IDEA entitlement or IDEA Recovery funds would not violate the supplement not supplant requirement as long as a district meets its requirement for IDEA maintenance of effort for the fiscal year. B8. Can IDEA Recovery funds be used to purchase or lease equipment? Yes. However, an LEA must receive approval from the DPI before acquiring equipment. The equipment must improve the LEA’s program for children with disabilities. “Equipment” is an article of nonexpendable, tangible personal property having a useful life of more than one year and a cost of $5,000 or more. However, some LEAs have established lower capitalization levels for equipment. If an LEA has established a level less than $5,000 for capital equipment, then prior approval will be needed for such equipment. Detailed budget descriptions for equipment must include the equipment type and the number of units for the cost identified with that line item. For additional information on requesting approval for equipment through IDEA budgets, view http://dpi.wi.gov/sped/pdf/cap-equip-rules.pdf. When the equipment is no longer needed to meet the needs of a child with a disability, it must be managed or disposed of in accordance with 34 CFR §80.32, Education Department General Administrative Regulations http://edocket.access.gpo.gov/cfr_2004/julqtr/pdf/34cfr80.32.pdf. B9. Can IDEA funds, including Recovery funds, be used to purchase a bus? Yes. However, an LEA is required to receive prior approval from the DPI for the acquisition of a bus. A bus acquired with IDEA funds must be used only to transport special education students whose IEPs require transportation. A detailed description is required in the grant budget. For additional information on requesting approval for vehicles through IDEA budgets, view http://dpi.wi.gov/sped/pdf/cap-equip-rules.pdf. B10. Can IDEA funds be used for construction or alteration of facilities? Yes. However, LEAs will need to obtain prior approval from the DPI. An application is posted on the DPI website [http://dpi.wi.gov/sped/idearecovery.html]. The project must improve the LEA’s program for children with disabilities. The proposal must be consistent with the least restrictive requirement requirements at 34 CFR §§300.114-300.117. Any construction or alteration of facilities must comply with Appendix A to part 36 of title 28, Code of Federal Regulations, the “Americans with Disabilities Accessibility Guidelines for Buildings and Facilities” or Appendix A of subpart 101-19.6, of title 41, Code of Federal Regulations the “Uniform Federal Accessibility Standards.” (34 CFR §300.718) LEAs also must comply with requirements in 34 CFR Part 76 regarding construction, including the requirements in 34 CFR §§75.600-75.617 incorporated by reference in 34 CFR §76.600 [http://www.ed.gov/policy/fund/reg/edgarReg/edgar.pdf]. B11. Are there special requirements for the use of Recovery funds for construction? Yes. In addition to the requirements for the use of IDEA funds, if an LEA uses Recovery funds for construction, it must comply with specific requirements relating to the use of American iron, steel and manufactured goods used in the project (ARRA §1605), as well as the wage rate provisions (ARRA §1606). Also, ARRA §1604 prohibits the use of any ARRA funds, including IDEA Recovery funds, for any casino, or other gambling establishment, aquarium, zoo, golf course, or swimming pool. B12. Can IDEA funds, including Recovery funds, be used for alterations to a classroom that will house an integrated 4K/EC program? Remodeling costs are allowed only to provide students with disabilities access to the classroom and must be an excess cost of special education. Costs must be necessary and reasonable. LEAs must have prior approval from DPI to use IDEA funds for remodeling for accessibility. B13. Can IDEA Recovery funds be used to pay for substitute teachers for regular education teachers? Substitute teachers are allowed costs when regular education teachers are released to engage in activities related to the provision of free appropriate public education to children with disabilities. For example, substitutes hired to release regular education teachers for inservice training related to children with disabilities, to attend IEP team meetings, and for planning time with special education teachers to meet the needs of children with disabilities are allowed costs. B14. Can IDEA Recovery funds be used for classroom technology like SMART boards? IDEA Recovery funds must only be used for the excess costs of providing special education. Acquisition of SMART board technology is not an excess cost of providing special education if the LEA has decided to equip classrooms in a school and simply charges the IDEA grant a prorated amount based upon the number of children with disabilities in the school. The equipment is an excess cost of special education when related to the needs of a child with a disability in accordance with the IEP of the child. It may be provided in a regular education class or other education-related setting, even if one or more nondisabled children benefit. When the equipment is no longer needed to meet the IEP needs of a child with a disability, it must be managed or disposed of in accordance with 34 CFR §80.32, Education Department General Administrative Regulations, http://edocket.access.gpo.gov/cfr_2004/julqtr/pdf/34cfr80.32.pdf. For additional information on requesting equipment through IDEA budgets, view http://dpi.wi.gov/sped/pdf/cap-equip-rules.pdf. B15. Why is account 436000 the only function available for purchased instructional services in the Purchase Services section (300 objects)? According to the Wisconsin Uniform Financial Accounting Requirements, function 436000 must be used for purchased instructional services. All school financial reports submitted to DPI must follow this accounting structure. For further information on WUFAR functions: http://dpi.wi.gov/sfs/wufar.html. A worksheet specifically on function 436 000 can be downloaded from http://dpi.wi.gov/sfs/doc/funct_430.doc. C. Use of Funds for Coordinated Early Intervening Services (CEIS)C1. May IDEA Recovery funds be used for coordinated early intervening services (CEIS)? Yes. IDEA provisions relating to the permissive use of funds for coordinated early intervening services apply to Recovery funds. Coordinated early intervening services are intended for students who have not been identified as students with disabilities under IDEA but who are determined to need additional academic and behavioral supports to succeed in general education. LEAs may use up to 15 percent of their Part B funds for any fiscal year to develop and implement coordinated early intervening services (CEIS). A list of allowable costs is found at http://dpi.wi.gov/sped/pdf/eis-allowables-FY10.pdf. C2. May Recovery funds be used for interventions and progress monitoring in a system of CEIS? Yes. Recovery funds set aside for CEIS may be used to fund evidence-based academic and behavioral interventions, progress monitoring, and training if they are for students identified as at-risk for failure. CEIS funds may not be used to support the implementation of core (universal) activities designed to provide high quality instruction to all students in a grade, school, or LEA. See question C1 for more information on CEIS. C3. May Recovery funds be used to fund Positive Behavioral Intervention and Supports (PBIS)? Yes. Recovery funds may be used to fund PBIS in accordance with allowable costs under coordinated early intervening services (CEIS). See question C1 for more information on CEIS. C4. How may RtI activities, including an RtI coordinator, be funded? RtI activities, including an RtI coordinator, may be funded with IDEA funds or with funds freed up by moving local special education costs to the IDEA grant. RtI activities benefiting all children, not just children with disabilities, must be funded through the coordinated early intervening services (CEIS) budget, because the services are for students who have not been identified as students with disabilities under IDEA. Coordinated early intervening services are intended for students determined to need additional academic and behavioral supports to succeed in general education. If the LEA reduces required maintenance of effort (MOE) through the 50% rule, the funds freed up by moving local special education costs to the IDEA grant may be used to support RtI activities for all students without the restrictions imposed by IDEA under CEIS. C5. May Recovery funds be used for all components of an RtI system, including universal screeners or other costs associated with core programming? Neither IDEA entitlement nor IDEA CEIS funds, including Recovery funds, may be used to purchase universal screeners or costs associated with core programming. However, if an LEA reduces maintenance of effort through the 50% rule, the freed-up local funds may be used for any component of an RtI system. C6. If an LEA does not plan on submitting a CEIS budget until later in the summer, but before the November 1 deadline, where should the LEA budget the amount that might be used for CEIS? An LEA should not budget for the proposed CEIS amount in the flow-through budget under a “placeholder” budget line. LEAs are not required to budget the entire allocation amount before submitting IDEA budgets. The LEA may leave the amount it plans to spend on CEIS out of the flow-through budget and include the amount later in the CEIS budget. For example, if the LEA has a flow-through allocation of $100,000 and the plan is to budget $10,000 for CEIS later in the summer, the LEA should budget $90,000 or less for flow-through. The LEA will be able to submit the flow-through budget without having to budget the entire allocation of $100,000. D. Parentally Placed Private School StudentsD1. Will the provisions for equitable service set-aside calculations be affected by the Recovery funding? Annually, an LEA must set aside a proportionate amount of IDEA funds for services for parentally placed private school students with disabilities. Because all of the IDEA Recovery funding is considered 2009-2010 funding, the amount of IDEA funds that must be set aside for services for parentally placed private school students in fiscal year 2009-2010 must be based on the combined regular IDEA allocation and IDEA Recovery allocation. Further information on calculating the equitable service set-aside, is available at http://dpi.wi.gov/sped/pdf/lpp-pppc_calc_ta.pdf. D2. Are expenditures of local funds included when determining whether an LEA expended the required amount on equitable services? No. Expenditures of local funds are not included when determining whether the LEA expended the required amount on equitable services. Only IDEA funds are counted. D3. Must LEAs consult with private schools and parents on the use of IDEA Recovery funds to provide equitable services? Yes. The required consultations with private school officials and representatives of parents of private school children with disabilities must include the IDEA Recovery funds. For more information, view http://dpi.wi.gov/sped/pdf/private-school-consultation.pdf. D4. Where do LEAs budget for equitable services set-aside for parentally placed private school students? There is no specific location/section in the IDEA budget to identify parentally placed private school student expenditures. Districts may track these costs by identifying them in the detailed description budget fields. At the local level, districts must be able to demonstrate the amount of IDEA funds expended on services for parentally placed private school students, because the equitable services set-aside will be one focus area of the LEA fiscal monitoring process. E. Maintenance of Effort (MOE)E1. Will the current rules for MOE apply to IDEA Recovery funds? The IDEA requirements for MOE apply to IDEA Recovery funds, including all provisions permitting reduction in required MOE. For a full discussion of the MOE requirements go to http://dpi.wi.gov/sped/pdf/moe_ta.pdf. E2. Will expending IDEA Recovery funds increase an LEA’s required MOE for subsequent years? No. The MOE requirement is based on the amount of state and local funds expended by an LEA on special education. The required MOE will not increase until the LEA increases the level of special education expenditures, using state or local funds, on its own. E3. What are the provisions permitting reduction of required MOE? An LEA may reduce its required MOE if the reduction in expenditures is attributable to:
When reducing its required local effort, an LEA must continue to provide a free appropriate public education to each child with a disability, including special education and related services based upon the child’s unique needs, as reflected in the IEP. E4. What is the 50% rule? This provision permits an eligible LEA that receives an increase in its IDEA flow-through allocation from one fiscal year to the next to reduce its MOE obligation by an amount equal to up to half of the increased amount (50% rule). The locally funded special education costs may be moved to the IDEA grant, freeing up local dollars. E5. Does the 50% rule apply whether the increase occurred because of an increase in the regular IDEA allocation or because of the IDEA Recovery funds? Yes. This exception applies whenever there is an increase in IDEA flow-through funds from one fiscal year to the next, whether because of an increase in the regular allocation or Recovery funds. E6. Doesn’t the “supplement not supplant” requirement prevent the use of IDEA Recovery funds for costs that were supported with local dollars during the previous year? An LEA may use IDEA Recovery funds for a special education cost funded in the previous year with local funds without violating the supplement not supplant requirement, as long as the LEA maintains its total local effort consistent with the MOE requirement. E7. Does reducing required MOE using the 50% rule mean an LEA is reducing special education services? No. When an LEA reduces MOE using the 50% rule, it shifts special education expenditures from local and state funds to either regular IDEA or IDEA Recovery funds, freeing up local and state funds for other uses. The LEA must still provide a free appropriate public education (FAPE) to each child with a disability, including the provision of all services required by the child's IEP in the least restrictive environment. E8. How does reducing required MOE by shifting special education costs from local funds to IDEA impact the LEA's state special education categorical aid? State special education categorical aid is paid as a percentage of eligible costs, currently 28%. This aid is paid in the next year. Eligible costs include salaries and fringe benefits for special education teachers, special education paraprofessionals, speech and language pathologists, physical therapists, occupational therapists, special education administrators, school psychologists, school social workers, school counselors and school nurses, as well as special transportation expenses. Costs paid with IDEA are not eligible for state special education categorical aid. Therefore, if an LEA shifts eligible costs from local funds to IDEA, the amount of eligible costs decreases, and the LEA's state special education categorical aid will decrease. E9. Which LEAs may reduce MOE with the 50% rule? All LEAs may use the 50% rule, except those given IDEA determinations by the DPI of “needs assistance,” “needs intervention,” or “needs substantial intervention” or designated as having "significant disproportionality.” While some LEAs have been designated as having disproportionate representation, only LEAs currently designated as having “significant disproportionality,” i.e., required to use 15% of their entitlement for coordinated early intervening services, are not eligible to use the 50% rule. Also, if the DPI has taken responsibility for providing a FAPE to children with disabilities in an LEA because the LEA is unable to establish and maintain programs of FAPE, or the DPI has taken action against the LEA under IDEA section 616, the LEA is not eligible to use the 50% rule to reduce required MOE. E10. Where can I find the MOE reduction permitted for my LEA? The maximum reduction of MOE permitted for each LEA using the 50% rule is listed in the last column of the table found at http://dpi.wi.gov/sped/xls/fy10flow.xls. While the 50% rule permits LEAs to reduce state and local special education expenditures, the LEA must still ensure it provides a free appropriate public education (FAPE) to each child with a disability, including the provision of all services required by the child’s IEP in the least restrictive environment. E11. Where do LEAs report a reduction in required MOE? LEAs that wish to take advantage of this opportunity must reflect this reduction in the PI-1504 SE budget report submitted for fiscal year 2009-2010. The reduction in required MOE must also be reflected in the 2009-2010 PI-1505 SE annual report submitted during fiscal year 2010-2011. The LEA’s IDEA entitlement or IDEA recovery budgets would include the special education costs that have been shifted from local dollars to the federal grant. E12. Will the 50% rule apply to Recovery funds in 2010-2011? Because all of the IDEA Recovery funds are considered 2009-2010 funds, the opportunity to reduce MOE related to the 50% rule and IDEA Recovery funds is available only for 2009-2010. E13. What effect will using the 50% rule and other provisions for reducing required MOE have on MOE for future years? If an LEA uses the flexibility available through the 50% rule or other provisions to reduce its MOE obligation, the LEA will be able to maintain the new reduced MOE amount in subsequent years, until the LEA increases the level of special education expenditures, using state or local funds, on its own. E14. What impact will the end of Recovery funding have on 2011-2012 LEAs budgets? Recovery funds must all be expended by September 30, 2011. When the funding is no longer available, LEAs must continue to ensure all children with disabilities have available to them free appropriate public education (FAPE), including all of the services in their IEPs. Services may only be reduced based upon the needs of students, as determined by IEP teams. After all Recovery funds are expended, LEAs may fund allowable special education activities with regular IDEA funds, including any funds carried over from the previous year. LEAs may expend local funds and receive state special education categorical aid. Note that an increase in state and local expenditures will increase required MOE in the next and subsequent fiscal years. E15. Will a reduction in the amount required for MOE affect an LEA’s IDEA allocation in subsequent years? No. A reduction in the amount required for MOE will not affect the LEA’s IDEA allocation in subsequent years. E16. What effect does the voluntary expenditure of funds for CEIS have on reducing required MOE using the 50% rule? When an LEA’s maximum MOE reduction is less than the amount that may be set aside for CEIS, the maximum MOE reduction is reduced by the amount expended for CEIS. For example, if an LEA has a $100,000 increase in its allocation and expends no funds on CEIS, it may reduce its MOE by up to $50,000. (100,000 x .50 = 50,000) However, if this LEA expends $40,000 on CEIS, it must subtract this amount from the permitted reduction in MOE. Therefore, the LEA may only reduce its required MOE by $10,000 (100,000 x .50 = 50,000 – 40,000 = 10,000). However, during the 2009-2010 school year for almost all LEAs, the maximum MOE reduction permitted is greater than the amount that may be set aside for CEIS. In this instance, the MOE reduction is capped at the maximum amount that may be set aside for CEIS minus the amount expended on CEIS [34 CFR §300.226 (a)]. Expending IDEA funds on CEIS automatically reduces the LEA’s maximum MOE reduction to the same amount as the maximum that may be set aside for CEIS (15% of the Part B allocation). For example, if an LEA has an $800,000 increase in IDEA funds to a total of $1,700,000, it may reduce MOE by $400,000 if it expends no funds on CEIS. If it expends $10,000 on CEIS, the maximum MOE reduction permitted is $245,000. (1,700,000 x 15% = 255,000-10,000 = 245,000) A calculator to determine the effect of using funds for CEIS on MOE reduction is available at www.dpi.wi.gov/sped/xls/moe_calculator.xls. Detailed information on the maintenance of effort requirement can be accessed at http://dpi.wi.gov/sped/idearecovery.html#moe. E17. Is there an advantage to reducing MOE and not using IDEA funds for CEIS? Freed-up local funds may be used for the type of activities conducted through a RtI system without the restrictions imposed on IDEA funds used for CEIS. The funds may also be used for other activities unrelated to RtI. E18. When reducing local MOE, may LEAs use more than one of the options available for MOE reduction? Yes. LEAs may use all of the applicable options to reduce required MOE. These include:
For example, if an LEA has an increase of $200,000 in its IDEA flow-through allocation and a high-cost child with special education expenses of $20,000 moves out of the LEA’s jurisdiction, the LEA may reduce its MOE by up to $100,000 through the 50% rule and an additional $20,000. This LEA’s maximum MOE reduction is $120,000. While funds freed up under the 50% rule must be expended on activities that could be supported with ESEA funds, this provision does not apply to funds freed up under the other exceptions. In the example above, the LEA must use up to $100,000 on activities that could be supported with ESEA funds. The use of the $20,000 freed up because a high-cost child moved out of the LEA’s jurisdiction does not have to be expended. E.19. If an LEA (with significant disproportionality) fails to use the required 15% of IDEA funds for CEIS in 2008-2009 and expends these funds in 2009-2010, does the expenditure affect the LEA’s calculation of its required MOE for 2009-2010? No. While in 2009-2010 the LEA must expend the additional amount it failed to expend on CEIS in 2008-2009, the expenditure of these funds does not enter into the LEA’s calculation of its required MOE for 2009-2010. F. Use of Funds Freed Up Through the 50% RuleF1. Must local funds freed up using the 50% rule be expended or may the amount be cut from the LEA’s budget? The amount of funds equal to the reduction in MOE cannot simply be cut from the LEA’s budget, reducing the LEA’s expenditures. The LEA must expend an amount of local funds equal to the reduction in required MOE. This requirement applies only to funds freed up using the 50% rule and does not apply to funds freed up using other MOE exceptions. F2. For what purposes can funds freed up with the 50% rule be used? The IDEA regulations state the freed-up funds must be used to carry out activities that could be supported under the Elementary and Secondary Education Act (ESEA), regardless of whether the LEA is using funds under the ESEA for those activities. According to the Office of Special Education Programs (OSEP), U.S. Department of Education, this includes any activities allowed under Title I, Impact Aid, and other ESEA programs. During a technical assistance webinar, OSEP indicated it is not aware of any specific activities that may not be funded. Their advice is based on the latitude LEAs have in expending ESEA Impact Aid. According to information from the Office of Elementary and Secondary Education, U.S. Department of Education, Impact Aid is ...considered general aid to the recipient school districts; these districts may use the funds in whatever manner they choose in accordance with their local and State requirements. Most recipients use these funds for current expenditures, but recipients may use the funds for other purposes such as capital expenditures.... School districts use Impact Aid for a wide variety of expenses, including the salaries of teachers and teacher aides; purchasing textbooks, computers, and other equipment; after-school programs and remedial tutoring; advanced placement classes; and special enrichment programs. [“About Impact Aid”, http://www.ed.gov//print/about/offices/list/oese/impactaid/whatisia.html ] Based on guidance from U.S. Department of Education, we believe funds freed up using the 50% rule may be used in any manner LEAs choose, consistent with their local policies and state requirements. LEAs should be prepared to demonstrate how and when freed-up funds were used. F3. Does an LEA have to be eligible for Title or Impact Aid in order to use the freed-up local funds on these activities? No. The LEA does not have to be eligible for Title programs or Impact Aid in order to use the freed-up local funds on activities that are allowed under these programs. F4. May local funds freed up under the 50% rule be used to retain staff slated for layoff or contract reduction? LEAs that move locally-funded special education costs to federal dollars under the 50% rule may use freed-up local funds to retain non-special education staff slated for layoff or contract reduction. F5. Must the LEA already be using ESEA funds to support the activity that freed-up local funds will support? No. The LEA does not have to be currently using ESEA funds for the activity that will be funded with freed-up local funds. F6. May freed-up funds be used for expenses previously paid by ESEA funds? Yes. Freed-up funds may be expended for any activity that can be supported with ESEA funds. F7. Must LEAs expend funds freed up in 2009-2010 through the 50% rule in the same year? Yes. Local funds freed up in 2009-2010 using the 50% rule must be expended in fiscal year 2009-2010. LEAs will not be able to reduce MOE in 2008-2009 or 2010-2011 based on the increase in the IDEA award for fiscal year 2009-2010. F8. If an LEA reduces MOE through the 50% rule, can the LEA move the previously locally funded special education costs to the regular entitlement grant or must the costs be moved to the Recovery funds? This would be the choice of the LEA. Locally-funded special education costs can be moved to either regular IDEA funds or Recovery funds, or the costs can be split between these funding sources. F9. Are freed-up funds budgeted in Fund 27? Fund 27 is for special education expenditures. We expect freed-up funds will not be used for special education expenses; therefore, they will not be budgeted in Fund 27. F10. May freed-up funds be used to support special education costs? An LEA could use freed-up funds on special education; however, this, in turn, would not reduce an LEA’s MOE. The MOE is based on an LEA’s aggregated local special education costs budgeted to Fund 27. A district could reduce its MOE by 50% of the increase in flow-through funding for FY 2009-2010, move the local special education costs to the IDEA grant, spend the freed-up funds on Fund 10, and keep the reduced level of MOE for future years. If the LEA spends the freed-up funds on special education, the MOE for FY 2010-2011 will be based on the total local special education expenditures for FY 2009-2010. G. Reporting and AccountabilityG1. What will be the reporting requirements? One of the principles for ARRA is to ensure transparency, reporting, and accountability. To support the most effective uses of ARRA funds and accurately measure and track results, recipients must publicly report on how funds are used. ARRA Recovery funds are subject to additional and more rigorous reporting requirements than normally apply to grant recipients. DPI is awaiting further guidance from the U.S. Department of Education on reporting requirements. G2. Are there codes to use when coding IDEA Recovery expenses? Yes. The codes below have been established for IDEA Recovery funds. CFDA # - Flow-through Recovery: 84.391a G3. When will reporting start? The DPI must report to the U.S. Department of Education by October 10, 2009. The period covered by the first report is February 17 to October 1, 2009. G4. Will LEAs have to keep track of the number of jobs created with the stimulus money? Quarterly, LEAs will be required to report both jobs created and positions retained. The DPI is required to make such information publicly available by posting the information on the DPI website. G5. Will LEAs have to demonstrate improved academic results for children with disabilities? We expect to receive more information regarding specific ARRA reporting requirements from the U.S. Department of Education. We will disseminate the information when received. H. IDEA ClaimsH1. How are claims submitted for IDEA entitlement and IDEA recovery funding? Beginning in fiscal year 2009-2010, all IDEA-related claims (for both regular entitlement and Recovery funds) must be submitted using the IDEA web-based claim process. The web-based claim system uses the PI-1086 program fiscal report form, but the claim is integrated into the IDEA budget software contained within the Special Education Application Web Portal. The Special Education Application Web Portal is located at https://www2.dpi.state.wi.us/seportal/ Only claims submitted through the web-based system will be accepted. Claims for fiscal year 2009-2010 submitted via e-mail or fax will not be accepted. H2. I am a district bookkeeper, how do I get access to the web-based IDEA claim form? Individuals who submit claims on behalf of the LEA must have a user name and password assigned to them to access the web-based software. District users are set up by the Director of Special Education. If you have not already been set up as a district user, contact your Director of Special Education as soon as possible to have this step completed. The steps for setting up a district user can be found in the “Instructions for Submitting IDEA Entitlement & Recovery Fund Claims” located at http://dpi.wi.gov/sped/pdf/idea-claim-process.pdf. If your LEA currently does not have a Special Education Director, contact Nancy Furhman at nancy.fuhrman@dpi.wi.gov to be set up as a district user to access the IDEA budgets. H3. Are there set due dates for claim submissions? Yes, although the due dates are different for regular entitlement funds and Recovery funds.
H4. Why are the IDEA Recovery claims due prior to the end of the calendar quarter? The Department of Public Instruction (DPI) received information on what data must be collected to meet the requirements of section 1512 of the American Recovery and Reinvestment Act. This data includes ARRA funds DPI disbursed to LEAs. This data must be submitted to White House Office of Management and Budget (OMB) by the Wisconsin Department of Administration (DOA) through the federal data reporting system. The DPI must provide the data to the DOA in time to meet OMB's deadline. LEAs must submit claims for expenditures made against the IDEA Recovery flow-through or preschool funds timely, so that the claims can be paid and these expenditures can be reported to the DOA. H5. What if an LEA has not expended any IDEA Recovery funds since the end of the last reprting period? Does the LEA submit a claim? By the end of each IDEA Recovery reporting period (July 31 and November 30, 2009; February 26 and May 31, 2010), each LEA must log into the IDEA budget and claim web-based application and answer a “yes-no” question whether it has any unclaimed expenditures against IDEA Recovery funds. If the LEA responds with “no,” then the DPI will not expect to receive a new claim from the LEA for IDEA Recovery funds. If the LEA responds with “yes,” then the LEA must submit a claim by the due date with all expenditures through the end of the reporting period. H6. For the IDEA Recovery funds claim, should an LEA include projected expenditures through the end of the calendar quarter)? No. This claim is for expenditures made during the period of February 17, 2009 through July 31, 2009. If expenditures were not made by July 31, 2009, they should not be on the August 21, 2009, claim. H7. Should the Recovery claims include amounts obligated through the end of the reporting period? No. This claim is for expenditures made through the end of the reporting period. If expenditures were not made by the end of the period, they should not be on the claim. H8. Is an LEA restricted to submitting claims only on the quarterly dates required? No. Districts may submit claims for both IDEA Recovery and IDEA entitlement funds more frequently than the claim due dates listed in question H3. H9. If an LEA made expenditures against the IDEA recovery funds, but does not submit a complete claim timely, what are the consequences? Timely, complete, and effective reporting under Section 1512 of the American Recovery and Reinvestment Act is a term and condition of receiving Recovery Act funding (Memorandum M-09-21). Material omissions and significant reporting errors can result in termination of Federal funding and/or initiation of suspension and debarment proceedings of either the recipient or sub-recipient, or both. Further, in some cases, intentional reporting of false information can result in civil and/or criminal penalties. H10. How long can an LEA expect to wait until claims are paid after they are submitted? The waiting period for claim payment may take up to 40 days. H11. Are “Total Funds Received to Date” in the claim form referring to the amount received as of the reporting end date or the date the claim is submitted? The district should report on funds received as of the date the claim is submitted. H12. Are claims submitted for IDEA recovery expenditures between February 17, 2009 and June 30, 2009 allocated to fiscal year 2008-2009? Yes, expenditures made between February 17, 2009 and June 30, 2009 should be allocated as 2008-2009 expenditures. These should be set up as receivables for the 2008-09 fiscal year. H13. Do LEAs still have to mail a claim hard copy with the District Administrator’s signature on it with the new web-based system? The District Administrator’s signature is required on the final claim. Partial claims throughout the year are submitted through the web-based system and do not require a signature. When final claims are submitted through the web-based system, the district will select the choice “Final Claim” and a message will appear stating that in addition to submitting the claim online, a hard copy of the final claim must be printed, signed by the district administrator, and submitted to DPI prior to any final claim being paid. This signed final claim can be scanned and sent by e-mail, postal mail or fax to DPI.
Last updated on 11/19/2009 1:35:12 PM |
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State Superintendent of Public Instruction Tony Evers
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