Regional Fall ESEA Program
Directors’ Meeting
Morning Agenda
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Welcome & Updates
Fiscal Hot Topics
WV Educator Equity Plan
Open Dialogue on Use of ESEA Resources
Program Data Management (Website,
Percent Needy, Comparability, SMR,
ZoomWVe)
Updates
• Reauthorization
• WVBE Policies
Fiscal Updates
Laura Pauley, CPA
lepauley@k12.wv.us
WVDE Office of Federal Programs
Federal Procurement Standards
Procurement Standards
• Pass-through entities are required to
follow the General Procurement Standards
in Sections 200.318-200.326 for
procurement transactions that include
federal funds.
Procurement Standards
• All non-Federal entities must:
– Have documented procurement procedures
– Maintain oversight to ensure compliance
– Maintain written standards of conduct
covering conflicts of interest (real and or
perceived)
Conflicts of Interest
• A conflict of interest would arise when the
employee, officer or agent, any member of
his or her immediate family, his or her
partner, or an organization which employs
or is about to employ any of those parties,
has a financial or other interest in or
receives a tangible personal benefit from a
firm considered for a contract.
Conflicts of Interest
• LEAs may set standards for situations in
which the financial interest is not
considered substantial or the gift is an
unsolicited item of nominal value.
• Standards of conduct must provide for
disciplinary actions to be applied for
violations of such standards.
Organizational Conflicts of Interest
• When the LEA is unable or appears to be
unable to be impartial in conducting a
procurement action involving a related
organization.
– Written standards must also address
organizational conflicts of interest
– Does not apply when the related organization
is a local or state government
Economy and Efficiency
• Federal procurement must be completed
in a way that fosters economy and
efficiency
– Avoid purchasing unnecessary or duplicative
items
– Consider entering into agreements for shared
goods and services
Responsible Contractors
• Must award contracts only to responsible
contractors who are able to perform
successfully under the terms and
conditions of the contract
• Consider the following:
– Integrity, compliance with public policy
– Record of past performance
– Not suspended or debarred
Recordkeeping
• Procurement records must include the
following:
– Rationale for the method of procurement
– Selection of contract type (ex. fixed price)
– Contractor selection or rejection
– Basis for the contract price
Procurement Methods
• Micro-Purchases (<$3,500)
• Small Purchases (>$3,500 and
<$150,000)
• Competitive Sealed Bids (>$150,000)
• Competitive Proposals
• Noncompetitive Proposals (severely
limited)
Micro Purchases
• The acquisition of supplies and services
under $3,500 (Section 200.320)
– May be awarded without soliciting competitive
quotations if the cost is reasonable.
– To the extent practicable must distribute
equitably among qualified suppliers.
Small Purchases
• Purchases of goods or services >$3,500
but < $150,000 Simplified Acquisition
Threshold
– Must obtain price or rate quotes from an
adequate number of qualified sources
(Section 200.320)
– Simple and informal
Non-competitive Proposals
• Section 200.320 Procurement by
noncompetitive proposals may be used only
when one or more of the following apply:
– The item is available only from a single source
– An emergency will not permit competitive
solicitation
– The awarding agency or pass-through expressly
authorizes noncompetitive proposals
– After solicitation, competition is determined
inadequate
Competition
• Situations that are considered to be
restrictive of competition and a violation of
section 200.319:
– Placing unreasonable requirements on firms in
order for them to qualify to do business
– Requiring unnecessary experience
– Non-competitive pricing practices
– Non-competitive contracts to consultants on
retainer
Competition (Cont.)
– Organizational conflicts of interest
– Specifying only a “brand name” product
instead of allowing “an equal” product to be
offered
Geographical Preference
• Procurements must be conducted in a
manner that prohibits the use of statutorily
or administratively imposed state or local
geographical preferences.
– This does not include state licensing laws
Contract cost and price
• If a procurement exceed the Simplified
Acquisition Threshold ($150,000), the nonFederal entity must perform a cost or price
analysis.
• LEA must make an independent estimate
before receiving any bids or proposals
Suspension and Debarment
• For contracts over $25,000 you must verify
that the vendor is not excluded or disqualified
• This must be done by either:
– Checking System for Award Mgt. (www.sam.gov)
– Collecting a certification from that person, or
– Adding a clause or condition to the transaction
Bidding Exemptions
• State bidding exemptions do not apply for
purchases made with federal funds
– State requirements can only be more
restrictive and not less restrictive
Food & Beverage Purchases
Allowable Cost – Food/Beverage
• Parent Involvement activities only
– Utilizing Title I/III
– Must extend through a mealtime
– Supported with original receipts, event sign-in
sheets and agendas
– Can provide a beverage and light snack
Unallowable Cost – Food/Beverage
• Title I/III cannot be used to pay for
food/beverage for the following
– Open Houses
– Parent Teacher Conferences
– Celebration, recognition or appreciation
events
– PTA/PTO meetings
– Meetings of the general public
Unallowable Cost – Food/Beverage
• Title II and RLIS (Title VI) funds cannot be
used to purchase food and beverage
Travel Costs
• Federal funds may be used to pay for
travel costs including a per diem meal cost
– Must be in accordance with local travel policy
– Amounts paid cannot exceed federal per diem
limits that were in place at the time of the
travel
• $.575 per mile
• Standard meal & incidental of $51/day
Conferences & Meetings
• When planning a conference/meeting to
be paid for with federal funding, food and
beverage may not be included in the
meeting cost
– It is not acceptable for the vendor to embed
these costs, which would be otherwise
unallowable into the cost of the meeting
space
Conferences & Meetings
• Indirect costs may not be used to pay for
food/beverage since it would be easily
considered a direct cost
Conferences & Meetings
• If other non-federal resources are being
used to pay for food/beverage at a
meeting or conference
– Must have a written disclaimer (e.g. note on
the agenda) that Federal grant funds were not
used to pay for the cost of food or beverages
Written Policies and Procedures
NOW REQUIRED
Policies & Procedures
• Now required to have certain written
policies & procedures for the Financial
Management System as it relates to
Federal Awards
Cash Management
• LEA must use existing resources before
requesting a drawdown on their federal
award
• Policy must address the following:
– Program income
– Refunds
– Rebates
– Interest
Allowable Cost
• Written procedures for determining
allowability in accordance with cost
principles 200.400
– From budget process to grant management
Allowable Cost
• All costs must be:
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Necessary, reasonable and allocable
Conform with federal law & grant terms
Consistent with state and local policies
Consistently treated
In accordance with GAAP
Not included as match
Net of applicable credits (§200.406)
Adequately documented
Questions
WV EDUCATOR EQUITY PLAN
HTTP://WVDE.STATE.WV.US/SEARCH.HTML?Q=EDUCATOR+EQUITY+PLAN&X=0&Y=0
Inexperienced Teachers -Figure 6
In your county are your most inexperienced
teachers at your highest poverty schools?
Is this a local or regional concern?
What regional solutions could be leveraged
to assist with the issue?
How might ESEA funding be utilized to
address within your county?
Out-of-Field Teachers -Figure 8
In which programmatic level does the county
have the highest concentration of out-of-field
teachers?
How is the county addressing this concern
with ESEA resources?
Ineffective Teachers -Figure 11
In your county are your most ineffective
teachers at your highest poverty schools?
Is this a local or regional concern?
What regional solutions could be leveraged
to assist with the issue?
How might ESEA funding be utilized to
address within your county?
SUPPORTING SCHOOL REFORM
BY LEVERAGING FEDERAL
FUNDS AND RESOURCES IN A
SCHOOLWIDE PROGRAM
Benefits of a Schoolwide Program
• Serving all students
• Providing services that need not be
supplemental
• Consolidating Federal, State and local
funds
Implementing a Schoolwide
Program
• There are three basic components of a
schoolwide program that are essential to
effective implementation:
- Conducting a comprehensive needs
assessment of the entire school,
- Preparing a schoolwide plan; and
- Annually reviewing the schoolwide plan.
Use of Funds Examples Based on
Needs Assessment
 Increased learning time
 Evidence-based strategies to accelerate the
acquisition of content knowledge for English language
learners
 Equipment, materials and training needed to compile
and analyze data to monitor progress, alert the school
to struggling students and drive decision making
 Devices and software for students to access digital
learning materials and collaborate with peers and
related training for educators
 School climate interventions
Dispelling Myths
Safeguarding the Interests of
Historically Underserved Populations
• A comprehensive schoolwide plan must include strategies for Meeting the educational needs of historically underserved
populations; and
 Addressing students and those at risk of not meeting the
State’s standards who are members of the target population
of any program included in the schoolwide plan.
• A school wide program must provide effective, timely
additional assistance to students who experience difficulty
mastering the State’s academic achievement standards.
Safeguarding the Interests of
Historically Underserved Populations
• An LEA must ensure that each schoolwide program school
receives a basic level of funds or resources from non-Federal
sources to provide services that are required by law for
students with disabilities and English language learners
before using Title I funds in the school.
• An LEA operating a schoolwide program must comply with all
other applicable laws, including: civil rights laws; laws
affecting the education of English language learners; and laws
affecting the education of students with disabilities, such as
the IDEA and Section 504 of the Rehabilitation Act of 1973.
• If a schoolwide program consolidates Federal funds, it must
ensure that it meets the intent and purposes of each Federal
program whose funds it consolidates.
Consolidating Federal, State and
Local Funds
• By consolidating funds in a schoolwide program, a
school can more effectively design and implement
a comprehensive plan to upgrade the entire
educational program in the school as identified
through a comprehensive needs assessment.
• When a school consolidates funds in a schoolwide
program, those funds lose their individual identity
and the school may use the funds to support any
activity of the schoolwide program without regard
to which program contributed the specific funds
used for a particular activity.
Advantages of Consolidating Funds
• Flexibility to allocate all available resources effectively
and efficiently.
• A school is not required to meet most of the statutory
and regulatory requirements of the specific Federal
programs in included in the consolidation, provided it
meets the intent and purposes of those programs.
• A school is not required to maintain separate fiscal
accounting by Federal program that identify the
specific activities supported by each program’s funds.
• Simplified time and effort documentation.
Making a Difference: Using Federal Funds
to Supplement School Reform
• The supplement not supplant requirement does
not apply to a schoolwide program school.
• The presumptions used to determine if supplanting
has occurred do not apply to the use of Title I
funds in a schoolwide program school.
• However, in order for Federal funds to make a
difference in supporting school reform in a
schoolwide program, they must supplement those
funds the school would otherwise receive.
Discussion
Program Data Management
Website Redesign
Percent Needy
Percent Needy
• The West Virginia Percent Needy Report is
the state’s official public reporting of the
percent of economically needy children by
public school and school district which is
used to determine school level Elementary
and Secondary Education Act, Title I, Part A
funding allocations. It is based on certified
data collections made on the first day of
October for each school year.
Percent Needy Prerequisites
• Your district should have already certified
second month student enrollment
• Title I Directors should be granted access
using the Title I Director role
• The menu option for Percent Needy
Report WVR>WVRFP>PERC.NEED
Percent Needy Menu
• Access in WVEIS WOW
• New WVRFP – Office of Federal Programs
• Menu PERC.NEED
Percent Needy
Percent Needy Terms
Term
Definition
Community
"CEP" stands for "Community Eligibility Provision." In CEP schools, all
Eligibility Provision students receive free breakfast and lunch, regardless of their own
(CEP) Status
family's economic status, due to a high proportion of students in the
school being directly certified as eligible for free or reduced price
meals.
Total Enrolled
Students
The total enrollment includes the headcount of all students in the
school, as certified on October 1 of the school year. These are
primarily students in Kindergarten through Grade 12, although prekindergarten students who have Individual Education Plan (IEP) on file
may be included in the enrollment as well. This number is the
denominator in the calculation of "Percent Needy."
Non-CEP: Number This total includes all students who are determined to be eligible for
of Free & Reduced (and who are receiving) free or reduced-price meals (through direct
Price Students
certification, applications, or other methods). This data element is
presented for non-CEP schools only.
Percent Needy Terms Cont.
Term
Definition
CEP: Number of
Identified Student
"Total Students Directly Certified," presented for CEP schools only,
includes the total number of students who are directly certified to be
eligible for free or reduced-price meals (e.g., due to family eligibility for
nutrition assistance programs).
CEP: Application of
USDA Approved
Multiplier
The function of the 1.6 multiplier is to provide an estimate of the
percentage of students eligible for free and reduced-price meals in
participating Community Eligibility schools, groups of schools, or LEAs
that is comparable to the poverty percentage that would be obtained in a
non- Community Eligibility school.
NSBLP County Used to The "Total 'Needy' Students for % Calculation" is the total number of
Calculate Within District students used as the numerator in the percentage calculation. For nonTitle 1 Allocations (must CEP schools, this is the number of students receiving for free or
be <= Enrollment)
reduced-price meals ("F/R Meals Total"). For CEP schools, the total
includes the number of directly certified students ("Total Directly
Certified") multiplied by 1.6; if the result ("Total Directly Certified" * 1.6) is
larger than the total number of students enrolled, then the total
enrollment is used for calculation.
Percent Needy Terms Cont.
Term
Definition
Percent Needy
Used to Rank
Schools for
Within District
Allocations
CEP: Percent of
Identified
Students Used to
Determine Title 1
Rank for Schools
at 100% Needy
The "Percent Needy" represents the percentage of students in
a school who are economically disadvantages. The following
calculation is used: Total "Needy" Students for % Calculation
/ Total Enrolled Students = Percent Needy
A district may have more than one school who has percent
needy equal to 100%. When this occurs this column can be
used to determine the rank of the schools within the district. It
is calculated
Accepting Percent Needy
• After reviewing the data within the percent
needy report you must indicate that you
have reviewed and accept the information
• The button is at the bottom of the report
• Option to print the report is available.
How is Percent Needy Used
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Title I Funding Decisions
Loan Forgiveness
eRate Reporting
Public Reporting in ZoomWV
Percent Needy on ZoomWV
Questions on Percent Needy
Comparability Report
Comparability Report
• ESEA Section 1120A states that a LEA may
receive Title I, Part A funds only if State and local
funds are used in Title I schools to provide
services that, taken as a whole, are at least
comparable to the services provided to non-Title I
schools. If the LEA serves all of the schools in its
district with Title I funds, the LEA must use state
and local funds to provide services that are
substantially comparable in each school.
Comparability Prerequisites
• Your district should have already certified
second month student enrollment,
personnel list, and percent needy
• Title I Directors should be granted access
using the Title I Director role
• The application can be found in the WOW
menus at: WVR>WVRFP>COMP.RPT
Comparability Report
• Access in WVEIS WOW
• New WVRFP – Office of Federal Programs
• Menu COMP.RPT
Comparability Report Step 1
Comparability Report Step 2 Automated
Comparability Report Step 2 Manual
First, select
Manual
Then, click Run
Comparability Report Step 3
• Review your spreadsheet for comparability
• Review your Title 1 schools to ensure all are listed
• Review Student Enrollment, this number should match (October Certification,
also known as Second Month Enrollment)
• Review the list of Staff
Comparability Report Step 4
Comparability Report Step 5
First, select a
file to upload
Then, click open
Comparability Report Step 6
Adjusting for Comparability
• Review personnel in conjunction to job
assignment
• Adjust staffing and resources
Questions on Comparability Report
School Monitoring Report
General Information
• Worked with Office of Education
Performance Audits (OEPA) and School
Improvement (SI) to combine HQDS and
SMR
• Provides one place to submit information
to OEPA and SI
• Self reflection and evidence submitted at
the function level
Combining HQSDC & SMR
• The application will be within WVEIS
WOW
• Anyone submitting self reflection or
uploading evidence will need an account
– If you need an account, please contact your
County Contact or RESA Staff
School Profile
Upload Evidence
Review Evidence
Questions on School Monitoring
Report