1
SPECIAL EDUCATION
FINANCE
FY 2015-16
Revised October 27, 2015
2
REVIEW APSCN/COGNOS REPORTS
Prior to August 31, review all SPED AFRs in COGNOS to
ensure
• that appropriate special education function and
object codes have been used,
• that Function/Object expenditures do not exceed the
10% variance
• that State/Local Maintenance of Effort has been met.
Prior to September 30, review all SPED budgets in COGNOS
to ensure
• that appropriate special education function, object
and program codes have been used,
• that State/Local Maintenance of Effort has been
budgeted,
• that 100% of Title VI-B funds available have been
budgeted and
• that Medicaid and ARMAC projected and carryover
funds have been budgeted.
3
Budgets due in APSCN before October 1
All budgets listed below will reflect the use of SPED
program codes and must be budgeted in the APSCN
system before the October 1 deadline.
• State/Local
• VIB section 611 (School Age)
• VIB, section 619, Federal Preschool (if applicable)
• State Preschool (if applicable)
• Medicaid
• ARMAC
4
Accessing Reports via COGNOS
A detailed guide, which describes how to access Special Education Budget
and AFR Reports, can be found on the ADE Special Ed website. It is
important to read the descriptors at the bottom of each COGNOS Report
in order to know what fund and program codes are included in the report
pull.
https://arksped.k12.ar.us/FundingAndFinance/Workshops.html
5
Important Due Date
Special Education Budget Submissions
School-Age, section 611
Preschool, section 619
Due October 1, 2015
• Complete Budget Signature Sheets
1. Statement of Intent
2. Assurances & Agreements
3. ED 80-0013—Certification of Lobbying
https://arksped.k12.ar.us/FundingAndFinance/FinanceForms.html
• FY 2015-16 Special Education Budget Checklist (in MYSPED
Resource)
• FY 2014-15 Special Education Annual Financial Report Checklist
(in MYSPED Resource)
• CEIS Application (if applicable)
6
Budget and Annual Financial Reports
• FY 2015-16 Budget
Data will be pulled
from Cycle 1
Submission to
APSCN—Due
September 30, 2015.
• FY 2014-15 Annual
Financial Report Data
will be pulled from
Cycle 9 Submission to
APSCN—Due August
31, 2015.
• AFR Reports are
expenditures
7
CODING
• Commissioner’s Memo FIN-15-100 announces change in
coding
• An updated list of commonly used SPED codes and Non-
allowable SPED codes is posted on the web
https://arksped.k12.ar.us/FundingAndFinance/Workshops.html
• Please refer to the Arkansas Financial Accounting
Handbook as a reference for codes (available in APSCN).
8
Special Education forms Due Oct 1
Forms below are required for each Special Education Program Budget
State/Local, VIB, Medicaid and ARMAC
https://arksped.k12.ar.us/FundingAndFinance/FinanceForms.html
AFR forms for 2014/15:
Budget forms for 2015/16:
These forms should match the
COGNOS AFR Report amounts
These forms should match the
COGNOS Budget Report amounts
• Request to Purchase form for
• Report of Equipment /
Equipment, Technology or
Bus
• Request to Purchase form for
Construction, Renovation or
Repair
• All Requests must be in the
budget before submitting.
• All Requests Forms must be
preapproved before
purchase.
Technology Purchased or
Bus Purchased form
• Report of Construction,
Renovation or Repair form
9
MAIL ORIGINAL
DOCUMENTS
Special Education Unit
Attn: Grants & Data
1401 West Capitol, Suite 450
Little Rock, AR 72201
OFFICE: 501-682-4223
FAX: 501-682-4313
10
Payment Suspension
• All Budget Applications should be submitted by the due date of
October 1, 2015.
• After October 31, Title VI-B payments could be suspended for
districts that have submitted budgets with inaccuracies, or have not
submitted all required budget items.
• Suspended payments will be resumed for these districts when all
inaccuracies have been corrected or when all required information
is provided and the district’s budget application is approved.
11
EXCESS COST
Part B
12
Federal Definition of Excess Cost
• §300.16
Excess costs means those costs that are in excess of the
average annual per-student expenditure in an LEA during
the preceding school year for an elementary school or
secondary school student.
• §300.202
The excess cost requirement prevents an LEA from using
funds provided under Part B to pay for all of the costs
directly attributable to the education of a child with a
disability.
13
Excess Cost Intent
• At both the elementary and secondary school levels
(computed separately), the excess cost requirement
stipulates the district must spend (in state and local funds)
at least as much (average amount per pupil) on special ed
students, as the district is spending on all students
(average amount per pupil).
14
Excess Cost Intent
• In summary, a district must document that it is spending at
least as much (in state and local funding) on disabled
students, as the district spends on non-disabled students.
• By meeting both the MOE and EC requirements… a
district is in compliance with the non-supplanting
provisions of federal law and regulation.
15
Excess Cost Calculation
Four components to the Excess Cost Calculation:
Compute total expenditures
2. Subtract certain expenditures
3. Compute average annual per pupil amount
4. Determine minimum amount of funds to spend for
Students With Disabilities
1.
16
Excess Cost v. MOE
Excess Cost:
• Spending on Special
Education students
compared to nonSpecial Education
students
• By grade range
• Expenditures
compared in same
year
MOE:
• Spending only on
Special Education
students
• At district level
• Expenditures
compared to prior year
17
EXCESS COST
Excess Cost Calculation should be calculated
by the district and kept onsite. Districts are
not required to submit Excess Cost calculation
in the October 1 submission but should be
aware of the impact this requirement has on
the use of Part B funds in conjunction with the
use of State or Local funds.
• Links to more information concerning Excess
Cost are posted on the web
•
https://arksped.k12.ar.us/FundingAndFinance/Workshops.html
18
MOE
MAINTENANCE OF EFFORT
19
Legal Expenses
Legal expenses, including attorney fees and other related
hearing expenses, may not be included when calculating a
district’s Maintenance of Effort (MOE). As stated in the
relevant federal regulation, 34 C.F.R. § 300.203, an LEA
complies with the MOE requirement, “if the LEA budgets,
for the education of children with disabilities, at least the
same total or per capita amount……. as the LEA spent for
that purpose….. for the most recent prior year for which
information is available.” (emphasis added) The education
of children with disabilities includes special education and
related services as defined in federal regulations, 34 C.F.R.
§§ 300.34 and 300.39. Neither legal fees nor attorney fees
are included in either definition and therefore, may not be
included in a district’s calculation of MOE.
20
State and Local Test
• For the 2015-16 year, districts will continue to meet MOE with State and
Local funds, test #1. COGNOS Budget and Annual Financial Reports
(AFR) give the MOE status in the upper left of the report. Use the AFR
(expenditure) report for current status.
21
IDEA Fiscal Requirements
Individuals with Disabilities Education
Act (IDEA) Fiscal Requirements:
• Maintenance of Effort (MOE)
• Excess Costs
• Private School Proportionate Set Aside
• Coordinated Early Intervening Services
(CEIS)
22
IDEA Fiscal Requirements
• Districts should consider their MOE status (Eligibility and
Compliance), Excess Cost requirement, Private School
Proportionate Set Aside amount and Coordinated Early
Intervening Services possible set aside when developing
annual budgets.
• All four of these additional fiscal requirements impact a
district’s use of its Part B funds.
23
MOE Requirement
IDEA Maintenance of Effort
The Individuals with Disabilities Education Act (IDEA),
§300.203, requires the Arkansas Department of Education
to determine that a school division complies with the
maintenance of effort requirement to spend at least the
same total amount of either local or local plus state dollars
or per capita amount of either local or local plus state
dollars for the education of children with disabilities that the
school division spent from the same source for that
purpose in the previous year.
24
MOE Eligibilty Standard
The first MOE requirements for districts
to meet is the Eligibility/Budget Standard
• Eligibility Standard: a district must budget, for the
education of children with disabilities, at least the
same total or per capita amount of local or local plus
state dollars as the district spent for that purpose
from the same source for the most recent prior year
available
• Districts provide the documentation that demonstrates a
plan to budget the required amount in their Local
Application for Part B funds.
25
MOE Compliance Standard
The second MOE requirement for districts to meet is
the Compliance/Expenditure Standard.
• Compliance Standard: a district must expend at least the
same total or per capita amount of local or local plus state
dollars for a current school year on the delivery of special
education and related services, as were spent the
previous year (comparison year).
• ADE will determine whether a district has met its MOE
Compliance requirement by reviewing final district
expenditures reported in the Cycle 9 data collection.
26
COMPARISON YEAR:
ELIGIBILITY STANDARD:
The comparison year is "the most recent fiscal year for
which information is available”, regardless of which
method the LEA uses.
COMPLIANCE STANDARD:
The comparison year is “the preceding fiscal year”,
regardless of which method the LEA uses.
27
Using Allowable Exceptions for
Eligibility Standard
To the extent the information is available;
• The (exceptions) the LEA took in the intervening year, or years
between the most recent fiscal year for which information is
available, and the fiscal year for which the LEA is budgeting;
and
• The (exceptions) the LEA reasonably expects to take in the
fiscal year for which the LEA is budgeting
28
The 4 Tests of MOE
Section §300.203 of the IDEA Regulations specifies the
four MOE tests districts can use to meet the Eligibility
and Compliance Standards status:
Local expenditures only
2. Local and State combined expenditures
3. Local per pupil expenditure
4. Local and State per pupil expenditure
1.
29
New Clarification on Passing
MOE Tests
• The level of effort a district must meet in the fiscal year
after it fails to maintain effort is the level of effort that
would have been required in the absence of that failure,
not the LEA’s reduced level of expenditures
• Districts must figure all 4 “tests” for MOE compliance and
keep track of these amounts (AFR) for reference in each
subsequent year (see Compliance example).
• Districts must meet at least one MOE test.
30
: 4 TESTS MOE form
• Complete and mail the NEW “4 Tests” form for MOE to
Grants & Data by October 15.
https://arksped.k12.ar.us/FundingAndFinance/FinanceForms.html
31
Impact of Method of the Subsequent
Years Rule
• To determine required level of effort, the
district must look back to the most recent
fiscal year in which LEA maintained effort.
• and must look back to the most recent
fiscal year in which the LEA met MOE
using the same method.
32
Impact of Method of the Subsequent
Years Rule
• For example,
• LEA wants to use State and local funds
(total) to meet the compliance standard in
FY 2016-2017.
• LEA failed to meet MOE in FY 2015-2016
using that method.
• LEA met MOE in FY 2014-2015 using that
method.
• LEA must use FY 2014-2015 as the
comparison year.
33
Eligibility/Budget Example
Fiscal Year
Local Only
State + Local
Local per Capita
State + Local per
capita
Child Count
2011 – 2012
$400
*
$1,100
*
$40
*
$110
*
10
2012 – 2013
$450
*
$1,300
*
$45
*
$130
*
10
2013 – 2014
$550
*
$1,200
**
$55
*
$120
**
10
2014 – 2015
$500
**
$1,300
*
$50
**
$130
*
10
2015 – 2016
Required Amount
to Budget for 2016
– 2017
$550
• Met MOE
** Failed MOE
$1,300
$55
$130
34
Compliance Example/AFR
Fiscal Year
Local Only
State + Local
10
$10,500
2012
$10,400
**
$21,600
*
$1,040
**
$2,160
*
10
2013
$10,650
*
$21,500
**
$1,065
*
$2,150
**
10
2014
$10,800
*
$22,200
*
$ 1,080
*
$2,220
*
10
2015
$ 8,900
**
$22,000
**
$ 890
**
$2,200
**
10
*Met MOE
**Failed MOE
$10,800
$1,050
Child
Count
State + Local per
capita
2011
Required MOE
2015-2016
$21,000
Local per Capita
$22,200
$2,100
$1,080
$2,220
35
Exceptions to IDEA MOE
§300.204a
A school division may reduce the level of
expenditures below the previous year’s spending if
the reduction is attributable to the voluntary
departure, by retirement or otherwise, or departure
for just cause, of special education or related
service personnel.
• Excludes positions eliminated through RIF
• Includes positions eliminated through attrition from State/Local
funds
• Includes savings between high salary of departing teaching and
low salary of new teacher (only from State/Local funds)
36
Exceptions to IDEA MOE
§300.204b
A school division may reduce the level of expenditures
below the previous year’s spending if the reduction is
attributable to a decrease in the enrollment of children
with disabilities.
(The 2 most current years of Child Count loss is the only allowable
exception for decrease of enrollment on the AFR Checklist form.)
37
Exceptions to IDEA MOE
§300.204c
A school division may reduce the level of expenditures
below the previous year’s spending if the reduction is
attributable to the termination of the obligation of the
agency to provide a program of special education to a
particular child with a disability that is an exceptionally
costly program, as determined by the state’s education
agency.
38
Exceptions to IDEA MOE
§300.204d
A school division may reduce the level of expenditures
below the previous year’s spending if the reduction is
attributable to the termination of costly expenditures for
long-term purchases.
39
Adjustment to MOE
In accordance with section §300.205 of the IDEA
regulations, in any fiscal year that a district’s sub-grant
allocation exceeds the amount that the LEA received in the
previous fiscal year, that district may reduce the level of
local, or state and local, expenditures otherwise required by
the district’s MOE requirements in IDEA, section 613(a)(2)
by up to 50 percent of the increase in the district’s subgrant allocation.
40
Adjustment to MOE
• The district must spend the ‘freed-up’ local (or state and
local) funds on activities that are authorized under the
Elementary and Secondary Education Act (ESEA) of
1965.
• This provision cannot be used by any district that has
been identified as having significant disproportionality and
is required to reserve 15 percent of their federal Part B
award for Coordinated Early Intervening Services (CEIS).
• However, if a district voluntarily chooses to set aside up
to, but not to exceed, 15 percent of its federal Part B grant
award, the amount the district chooses to set aside is
reduced by the amount taken for the allowable exception
under this provision.
41
Consequences of MOE Failure
If school division doesn’t meet its MOE requirement:
• ADE pays back the US Department of Education using
non-federal funds
• ADE may require the district to pay back
• The threshold for the next MOE calculation will revert
back to the last year that the district did meet MOE.
42
MAINTENANCE OF EFFORT
(REVIEW COGNOS REPORTS)
1) Review the COGNOS State & Local Annual
Financial Reports before the Cycle 9
submission to APSCN to determine whether
MOE has been met for the 2014-2015 year.
2) Review the COGNOS State/Local Budget
Reports before the Cycle 1 submission for
purposes of MOE for the 2015-2016 year.
43
Maintenance of Effort
If a district’s COGNOS Budget Report shows the MOE status is
in the negative, the district must list allowable exemptions in
the Budget Checklist on MySPED or increase the State/Local
budget.
44
MOE Exemptions
• Exemptions for 2014-
15 should be listed on
the AFR Checklist form.
• Exemptions for 2015-
16 should be listed on
the Budget Checklist
form.
45
MAIL ORIGINAL
DOCUMENTS
Special Education Unit
Attn: Grants & Data
1401 West Capitol, Suite 450
Little Rock, AR 72201
OFFICE: 501-682-4223
FAX: 501-682-4313
46
COORDINATED EARLY
INTERVENTION SERVICES
CEIS
http://www2.ed.gov/policy/speced/guid/idea/ceis_pg3.html
47
Required Coordinated Early Intervening
Services (CEIS)
• As permitted by section § 300.226 of the IDEA
regulations, a school district may use 15 percent (or up to
15 percent) of their Part B award to provide certain
services to students who ARE NOT identified under the
IDEA as students with disabilities.
• A school district identified as having significant
disproportionality is required to set aside 15 percent of its
Part B award for CEIS.
48
REQUIRED CEIS
Based on the provisions of individuals with Disabilities Education Act
(IDEA) of 2004 a district that has been identified with significant
disproportionality is:
• Required to budget and use 15% of the IDEA FY 2015-16 allocation for the
provision of Coordinated Early intervening Services (CEIS) for at risk children in
the district, particularly those in groups that were significantly over-represented
in the special education population.
• Required to complete a review of policy, procedures, and practices.
• Prohibited from reducing its Maintenance of Effort (MOE) under 34 CFR 300.205.
49
Voluntary Coordinated Early Intervening
Services (CEIS)
• A school district may choose to voluntarily set aside up to
15 percent of their Part B award for Coordinated Early
Intervening Services (CEIS).
• Districts that voluntarily set aside up to 15 percent of its
Part B award will have to be aware of the implications with
Section § 300.205 and a possible adjustment to its MOE
status.
50
Coordinated Early Intervening Services
(CEIS)
Each LEA that develops and maintains
coordinated, early intervening services must
annually report to the SEA on:
• The number of children served under this section who received
early intervening services; and
• The number of children served under this section that received
early intervening services and subsequently receive special
education and related services under Part B of the Act during the
preceding two year period.
51
CEIS Data in APSCN
The CEIS data are a component of the special education module
in the Arkansas Public School Computer Network (APSCN).
This data dictionary at the link below explains the APSCN
data fields and codes that are required for federal reporting.
Not all situations are covered in the Guide. If after consulting this
data dictionary you still have questions about data entry and
coding, please contact the Arkansas IDEA Data & Research
Office at 501-683-7219.
https://arksped.k12.ar.us/DataAndResearch/DataDictionaries.html
52
CEIS Data Dictionary
https://arksped.k12.ar.us/DataAndResearch/DataDictionaries.html
53
Caution: Possible CEIS Supplant Issues
Cautions should be taken before coding a program as CEIS.
Consider using the guiding questions below and involve
district administration to avoid supplant issues.
• Is the CEIS program required by law ?
• If the CEIS program is not a new program, how was it
funded in the past?
• Do all students participate in this program (or all 6th
graders, or all 2nd graders…) ? If all students receive this
service, how is this a CEIS program?
54
CEIS Application FormA form for Required and
Voluntary CEIS
Program Application is
posted on the web and
should be submitted
before the October 1
deadline.
https://arksped.k12.ar.us/FundingAnd
Finance/FinanceForms.html
In the future, the CEIS Application will
be submitted in June to allow districts
to budget accordingly.
55
CEIS Program Description
• Research based
• What is the research base for the program?
• Program Description:
• Does the program description address at-risk students in the district, particularly those
groups that were significantly over-represented in the special education population?
• How many students are being served?
• What amount of time do these students spend in the program daily/weekly?
• What materials are used?
• If funds are being used for purposes other than direct student services, please provide an
explanation.
• Program Evaluation
• What tool is being used to measure progress?
56
Coordinated Early Intervening Services
Coding
Required CEIS—Districts found to have significant disproportionality
based on race or ethnicity are required to use 15% of its IDEA funds (Total
Title VI-B, § 611 School Age and Title VI-B, § 619 Preschool funds) for CEIS
Activities.
• Required CEIS funds must be coded to program 269.
• Required CEIS funds that are not spent during the current year must be
carried over to the next year.
• Required CEIS carryover funds must be coded to program 267.
Voluntary CEIS—Title VI-B funds used for CEIS activities cannot exceed
15% of your Total Title VI-B, § 611 (School Age) and Title VI-B, § 619
(Preschool) funds for voluntary CEIS activities.
• Voluntary CEIS funds must be coded to program 265.
• Voluntary CEIS carryover funds must be coded to program 264.
• Voluntary CEIS funds must be coded to function 1297 (instruction,) or function 2213 (staff
development).
57
Coordinated Early Intervening Services (CEIS)
Important Budget Codes for Required CEIS:
Example:
Fund
Function
Subject
Program
Code
Location
Object Code
6702-
1297
-XXX
-269 (REQUIRED)
-XX
-6XXXX
6702-
1297
-XXX
-267 (CARRYOVER)
-XX
-6XXXX
FUNCTION CODE 1297 used for Direct CEIS Instruction
FUNCTION CODE 2213 used for all Professional Development
FUNCTION CODE 1297 or Program codes 264, 265,
267, or 269 should not be budgeted or expended from
State/Local, Medicaid, or ARMAC funds.
58
Coordinated Early Intervening Services (CEIS)
VOLUNTARY CEIS:
An LEA may voluntarily use up to the maximum amount (15% of 611 and 619 funds)
The LEA may reallocate any unspent voluntary CEIS funds during the time that the funds are
available for obligation.
Fund/Source 6702 and Program code 265 must be used for current year voluntary CEIS funds
while program code 264 must be used for carryover funds for voluntary CEIS.
Fund
Function
Subject
Program
Code
Location
Object Code
6702-
1297
-XXX
-265 (CURRENT YR)
-XX
-6XXXX
6702-
1297
-XXX
-264
-XX
-6XXXX
(VOLUNTARY CARRYOVER)
FUNCTION CODE 1297 used for Direct CEIS Instruction
FUNCTION CODE 2213 used for all Professional Development, including CEIS
FUNCTION CODE 1297 or Program codes 264, 265,
267, or 269 should not be budgeted or expended from
State/Local, Medicaid, or ARMAC funds.
59
PRIVATE SCHOOL PROPORTIONATE
SHARE
PSPS
Link to PSPS Chart https://arksped.k12.ar.us/FundingAndFinance/SchoolAge.html
60
Private School Proportionate
Set Aside
• Under section § 300.132 of the IDEA regulations, districts
are required to complete a formula to identify the amount
they must set aside of their Part B award to be used to
provide special education and related services, through a
Services Plan, to children whose parents have placed
their child in a private school but who still want their child
to receive some special education.
61
Private School Proportionate Share (PSPS)
Districts are required to spend a proportionate
amount of IDEA Part B funds to provide services
to parentally-placed private school or home
schooled children with disabilities.
Private School Proportionate Share information
is pulled from Cycle 4 reports.
• Required PSPS funds must be coded to
program 268.
• Required PSPS funds that are not spent
during the current year must be carried
over to the next year.
• Required PSPS carryover funds must be
coded to program 266.
62
Private School Proportionate Share (PSPS)
Title VI-B Regular Funds—Fund/Source 6702 and Program Code 268 must be
used for current year Private School Proportionate Share funds and Program
Code 266 must be used for carry over funds for Private School Proportionate
Share.
Fund
Function
Subject
Program
Code
Location
Object Code
6702-
2158
-XXX
-268 (Current Year)
-XX
-6XXXX
6702-
2158
-XXX
-266 (Carryover)
-XX
-6XXXX
Only function codes 1218, 1228, 2158, and 2168 should be
used for Private School Proportionate Share funds.
63
Private School Proportionate
Set Aside
Number of eligible children with disabilities in the District (December 1,
2014 Child Count)
Number of parentally placed or home school eligible children with
disabilities in private schools or home school located in the district and
number identified as needing services but services not being provided.
Use Dec. 1, 2014 Child Count and Private School Survey Questions 4 & 5.
Total Title VI Part B allocation to the District (current year only)
Average allocation per eligible child (#3 divided by #1)
Amount to be expended for parentally placed children and home school
children with disabilities (PSPS) (#4 multiplied by #2)
148
2
246,269.34
1,663.98
3,327.96
64
PSPS Set-Aside
• The PSPS Chart
posted on the web is
based on the
Preliminary Allocation
amount for VIB in
Commissioner’s Memo
FIN-16-011.
https://arksped.k12.ar.us/FundingAnd
Finance/SchoolAge.html
• It is not necessary to
include a set aside for
the 2014-15 Additional
Reserve.
65
PRIVATE SCHOOL SURVEY
The Private School Survey is required for all districts. The
survey is necessary to ensure that all private school or home
school students that have been identified as needing special
education and/or related services are included in the
calculation of Private School Proportionate Share.
Private school AND/OR home school students that were
1) being served or
2) identified as needing special education and/or related
services
as of December 1, 2015, should be included in this survey.
66
PRIVATE SCHOOL SURVEY
The Private School Survey will open Dec. 1, 2015 and must be
completed online by
December 18, 2015.
The completed survey should be printed after submission and mailed to:
Special Education Private School Survey
Grants & Data Management
Arkansas Department of Education
1401 W. Capitol, Suite 450
Little Rock, AR 72201
67
TITLE VIB
IDEA PART B
68
Title VI, Part B for disabled students only
34 C.F.R. §300.202 Use of amounts. (a) General. Amounts provided to
the LEA under Part B of the Act—
• (1) Must be expended in accordance with the applicable provisions of
this part;
• (2) Must be used only to pay the excess costs of providing special
education and related services to children with disabilities, consistent
with paragraph (b) of this section; and
• (3) Must be used to supplement State, local, and other Federal funds
and not to supplant those funds.
69
Title VI-B Permanent Formula
[34CFR 300.705]
•Base Allocation – 1999 Base Year
•Population – Prior year October 1
enrollment plus private school enrollment
(85% after state set-aside and base
allocation)
•Poverty – F/R lunch eligibility of all
school age students (15% after state setaside and base allocation)
(Refer to Commissioner’s Memo FIN-16-024 for
allocation disbursement procedures.)
70
ADE Finance
• ADE Finance announces federal awards
through Commissioner’s Memos. The
award/budget amount is a set amount
and should not be increased/decreased by
the district.
• Throughout the year, ADE Finance will
continue to announce updates to awards.
Districts should be mindful in checking
Commissioner’s Memos.
• When Final Allocations are announced,
• Preliminary Award amounts are
announced in August of 2015. PSPS and
CEIS percentages will use these amounts.
• Districts should also consider the Cash on
Hand, Additional Reserves awarded and
Carryover funds from previous years
when arriving at Total Funds Available for
budgeting the October 1 submission.
districts should amend the budgets
accordingly before the announced
amendment deadline.
Commissioner’s Memos
Preliminary Allocations
• FIN-16-011 VIB, Section 611 School Age
• FIN-16-009 VIB, section 619 Federal Preschool
• FIN-16-010 State Preschool
http://www.arkansased.gov/
72
PREAPPROVED REQUESTS TO PURCHASE
Grants and Data must preapprove purchases for
Equipment , Technology, Buses and/or
Construction/Renovation for amounts $1000 or over. .
Before approval of a purchase can be granted, the
item(s) on the Request Form must be included in the
budget under object code 67000 for Equipment,
Technology and Buses. Object code 64000 should be
budgeted for Construction/Renovation requests.
73
TITLE VI-B FUNDS AVAILABLE = BUDGET AMOUNT
(+) COH (Cash-on-Hand) from FY 2014-15*
*See APSCN Board Report at the end of the Fiscal Year (2014-15) to determine the COH
(will be $0 for most districts)
(+) Carryover funds from previous year
(+) ANY ADDITIONAL RESERVE announced in Commissioner’s Memos
(+) FY 2015-16 PRELIMINARY ALLOCATION
in Commissioner’s Memo
= TOTAL FUNDS AVAILABLE (amount to budget for FY 2015-16)
TOTAL FUNDS AVAILABLE MUST BE BUDGETED before
a budget can be approved.
74
IDEA Title VI-B grants have a 27-month window of time to
obligate funds and three additional months to liquidate
funds.
For 14/15 additional reserve distribution allocations, please note the following:
• Obligation deadline: September 30,2016
• Liquidation deadline: December 30, 2016
• Title VI, Part B Section 611: Source Code 6702, Revenue Code 45613
For 2015-16 allocations, please note the following:
• Obligation deadline: September 30, 2017
• Liquidation deadline: December 30, 2017
• Title VI, Part B, Section 611: Source Code 6702,Revenue Code 45613
75
HOW TO CODE VI-B REVENUE FOR JUNE
2015 EXPENDITURES
Accrued revenue that districts are required to use for Title VIB federal funds since ADE has gone to the “REIMBURSEMENT”
method for sending federal funds for this program.
If the district had a negative balance of $100,000 for Title VI-B
funds (F/S 6702) on the board report on June 30 (end of
Period 12 or 13 of FY 2015), the correct entry would be:
• Debit 6702 – 01410 (Intergovernmental Receivables)
$100,000
• Credit 6702 – 45613 (Title VI-B Revenue)
$100,000
*Note: This amount of revenue CANNOT cause the Yearto-Date (YTD) revenue for the district to exceed the total
funds available. If this occurs, expenditures MUST be
moved from F/S 6702 to other sources.
76
HOW TO CODE VI-B REVENUE FOR
JUNE 2016 EXPENDITURES
On or after July 1, 2016 (during Period 1 of FY 2016),
the correct entry is:
•
•
Debit 6702 – 45613 (Title VI-B Revenue) $100,000
Credit 6702 – 01410 (Intergovernmental Receivables) $100,000
Then when the money is received, it is receipted as
normal revenue with a CR to revenue and a DR to cash.
This is the preferred method by ADE and Audit.
•
•
Debit 6702 – 01010 (CASH) $100,000
Credit 6702 – 45613 (Title VI-B Revenue) $100,000
77
VIB REMINDER
• When the VIB final
allocation is
announced through
Commissioner’s
Memo, Districts must
amend the budget
total, based on the
final allocation before
the amendment
deadline.
78
Time Certification
Time certification forms are required for
all Federal employees:
• Full-time federal employees
require certification forms to be
completed two times per year.
• Employees who work in more than
one federal program or work part
time in a federal program and part
in state, local or other programs
require time certification forms to
be completed each month the
employee works.
79
KEY CHANGES
Post award and sub-award changes
80
Key Changes in Post-Award Activities
Notable Key Changes:
• Greater emphasis on internal controls to ensure
compliance and fiscal responsibility;
• Enhanced oversight requirements of subrecipients,
which includes risk assessment to develop an
appropriate monitoring plan and tools;
• Enhanced oversight of contracts; and
• Greater focus on performance expectations and
results
81
Key Changes in Post-Award Activities
Longstanding grantee flexibilities known as the “Expanded
Authorities” are still there, just moved to 2 CFR 200.308:
• Pre-award costs allowable up to 90 days before award
• Extension one time, up to 12 months
• “Carry forward” of unobligated balances
• Budget transfers
82
Key Changes for Pass-Through Entities
 Under 2 CFR 200.331, pass-through entities are required to:
• Provide sub-award information to their sub-recipients, including the
indirect cost rate for the Federal award
• Perform a risk assessment for the purpose of sub-recipient monitoring
• Verify that every sub-recipient is audited (as required by the Single Audit
Act)
83
Key Changes: Risk-Based Monitoring
 Increased responsibilities for pass-through entities:
• 2 CFR 200.331 (b) Pass-through entities must evaluate each sub-
recipient’s risk of noncompliance with Federal statutes,
regulations, and the terms and conditions of the sub-award for
the purpose of determining the appropriate monitoring actions.
• Risk Assessment does not have to be completed before sub-
awards are made, but recipients can decide to make
assessments before making the sub-awards.
84
Key Changes: Risk-Based Monitoring (cont.)
 Considerations for pass-through entities in evaluating sub-recipient risk:
• History of Maintenance of Effort issues or failure to meet MOE
• Evidence of financial instability
• New Director and/or business manager
• History of late submission of required data or financial information (Part B
•
•
•
•
application, Annual Report)
History of audit findings
Inaccurate or unverifiable reporting of actual expenditures and carryover on
previous year budgets
Issues related to timely obligation and liquidation of funds
Relevant Federal monitoring
85
Key Changes: Risk-Based Monitoring (cont.)
 Increased responsibilities for pass-through entities:
• Under 2 CFR 200.331 (d) Pass-through entity monitoring must include:
• Review of financial and performance reports;
• Issuance of management decisions for audit findings on sub-recipients;
and
• Follow-up activities ensuring sub-recipients take timely, appropriate
action to cure deficiencies
86
Key Changes: Risk-Based Monitoring(cont.)
 Under 2 CFR 200.331 (e) the pass-through entity must assess risk
to determine monitoring approach. Monitoring and follow up may
include:
• Providing training and technical assistance,
• Performing an on-site review of entity’s program operations, and
• Arranging for agreed-upon-procedures for audit services
87
Required Risk-Assessment
• In November, SPED Finance will post a Risk Assessment Survey on
the Survey Tab on the SPED web page to be completed before
December 18, 2015 .
https://arksped.k12.ar.us/index.html
• The Risk Assessment will provide baseline data for the monitoring
process.
• Questions on the Risk Assessment reflect the Fiscal Monitoring
Protocol.
88
PRESCHOOL SERVICES
EARLY CHILDHOOD
89
Special Education Preschool Services
IDEA (Individuals with Disabilities Education
Act) requires school districts to provide all
eligible children with disabilities with a free
appropriate public education, from ages 3 to 21
years.
Districts have the option of providing special
education services to eligible preschool children
themselves, working with another district(s), or
working with an educational service cooperative
(ESC) to provide the required services.
The Early Childhood Provider Survey, due in
March, establishes the flow of funds to the
appropriate providers of service for ADE Finance.
Accurate entries in the survey are important.
90
Special Education Preschool Services
Preschool funds from State Preschool Grant
Funds and Title VI-B Section 619 federal grant
funds are sent to districts providing their own
preschool services and to Educational
Cooperatives for providing services to
participating districts. ESCs also invoice districts
for costs not covered by the funding mentioned
above.
91
ADE Finance
• ADE Finance announces Federal
Preschool and State Preschool awards
through Commissioner’s Memos.
• Preliminary Award amounts are
announced in the summer of 2015.
• Districts and Co-ops should also consider
the Cash on Hand, Additional Reserves
awarded and Carryover funds from
previous years when arriving at Total
Funds Available for budgeting the Oct. 1
submission
• Throughout the year, ADE Finance will
continue to announce updates to awards.
Districts and Co-ops should be mindful in
checking Commissioner’s Memos.
• When Final Allocations are announced,
Districts and Co-ops should amend the
budgets accordingly.
92
Title VIB, Section 619 PRESCHOOL
(+) COH (Cash-on-Hand) from FY 2014-15*
*See APSCN Board Report at the end of the Fiscal Year (2014-15) to determine the COH
(will be $0 for most districts, but Cooperatives will likely have COH)
(+) Carryover funds from previous year
(+) ANY ADDITIONAL RESERVE announced in Commissioner's Memos
(+) FY 2015-16 PRELIMINARY ALLOCATION announced in Commissioner’s Memos
= TOTAL FUNDS AVAILABLE (amount to budget for FY 2015-16)
Starting in year 2015-16, Federal Preschool will change to the reimbursement system with
ADE Finance. The current COH will be deplenished first before ADE Finance will reimburse
from current funds.
93
STATE PRESCHOOL
(+) COH (Cash-on-Hand) from FY 2014-15*
*See APSCN Board Report at the end of the Fiscal Year (2014-15) to determine the COH
(will be $0 for most districts, but Cooperatives will likely have COH)
(+) Carryover funds from previous year
(+) FY 2015-16 PRELIMINARY ALLOCATION announced in Commissioner’s Memos
= TOTAL FUNDS AVAILABLE (amount to budget for FY 2015-16)
TOTAL FUNDS AVAILABLE MUST BE BUDGETED
94
Charges to Districts for Preschool Services
The amount each district will be invoiced by most co-ops will be $610 per child
for their children served by the co-op on December 1, 2015 (some ESCs charge a
different amount than $610 per child). Children served in Head Start, ABC, day
care programs, etc. are included in the preschool child count; therefore, the
districts will no longer be charged an additional amount for children served in
Head Start centers.
School districts receive no Title VI-B (Section 611), funds for their preschool
children that receive services through ESCs, but Title VI-B (Section 611) funds can
be used by districts to provide special education preschool services.
The account code that should be used if Title VI-B funds are used
to pay the ESC is:
6702
1290
698
200
00
65910
ESCs will provide a list of each districts’ children that
received preschool services and are included in the invoice if
requested to do so.
PREAPPROVED REQUESTS TO PURCHASE
Grants and Data must preapprove purchases for
Equipment , Technology, Buses and/or
Construction/Renovation for amounts $1000 or over. .
Before approval of a purchase can be granted, the
item(s) on the Request Form must be included in the
budget under object code 67000 for Equipment,
Technology and Buses. Object code 64000 should be
budgeted for Construction/Renovation requests.
96
Federal and State Preschool REMINDER
• Preschool Final
Allocations are
announced through
Commissioner’s Memo.
Districts must amend
the budget totals,
before the announced
amendment deadline.
Please be mindful to
check Commissioner’s
Memos.
97
Preschool Survey due March 4, 2016
• All Districts must complete the Early Childhood Survey in
MySPED before the March 4, 2016 deadline.
• The Early Childhood Survey is necessary for participating
in Educational Cooperative Preschool Provider Services, for
providing district preschool services or for announcing a
change in Preschool service provider.
• The Early Childhood Provider Survey establishes the flow
of funds to the appropriate providers of service for ADE
Finance. Accurate entries in the survey are important.
98
MEDICAID
www.armits.org
99
Medicaid & ARMAC
Budgets are required for Medicaid and ARMAC
(Arkansas Medicaid Administrative Claiming).
• Budget any Cash-on Hand and Projected Funds for
Medicaid and ARMAC
• Funds can be carried over into subsequent years.
Medicaid and ARMAC funds can be used for special
education or non-special education activities:
• Special Education activities should be coded to
program code 200-260.
• Non-Special Education activities should not
be coded to program codes 200-269.
100
Medicaid Match
Districts’ Medicaid Match must be paid from
State/Local funds.
The account code for payment of a district’s Medicaid Match
should be:
2000
2990
000
200
00
Medicaid/ARMAC Questions?
1.866.280.8300
501.375 MITS (6487)
501.375.6488 (fax)
65900
101
AMENDMENTS
Established dates
102
Amendments will now be deadlines
State/Local, VIB, Medicaid, ARMAC
After the October 1 submission and approval, amendments
will become budget pulls on established dates. Grants and
Data will pull COGNOS budget reports on these dates.
• These established dates will be COGNOS budget pulls for all
districts. Districts should update total funds available and
any changes to the budget prior to the announced deadline.
No amendment form is required. 10% Variance still
applies.
• Grants and Data will send corrective information after the
amendment deadline for districts to correct before the next
deadline or year end, which ever is applicable.
• Announcements and reminders will be posted on
MySPED.
•
103
Amendments will now be deadlines
State/Local, VIB, Medicaid, ARMAC
• Districts will continue to use the Request for Purchase of
Equipment form, if there is a change in object code 67000
from the October 1 approved budget.
• Districts will continue to use the Request for Bus Purchase
form, if this was not a part of the approved budget.
• Districts will continue to utilize the Request for
Construction/Renovation form if this was not a part of the
approved budget.
104
10% Variance
BEGINNING WITH THE 2015-16 SCHOOL YEAR
(as of July 1, 2015)
10% variance in special education funding will follow the
same procedure as other federal programs. Refer to
Commissioner’s Memo LS-16-023.
EDGAR 80.30© allows budget changes up to 10% of the total approved budget
without ADE approval.
• The 10% Variance in federal fund expenditures refers to when actual
expenditures exceed budgeted expenditures.
• It is not considered a ‘variance’ when actual expenditures are less than
budgeted expenditures.
• Districts may make budget changes of up to 10% of the total budget amount
without ADE approval.
105
10% Variance of Function code
Commissioner’s Memo LS-16-023
• Compare each Function Total Actual Expenditures to
Budgeted Expenditures.
• LINE ITEM Actual expenditure Variance cannot exceed 10% of Total Budget
• Total budget is $300,000. 10% variance would be $30,000.
• Look at each line item to determine if the line item is out of compliance
• EX: Function 1220, Resource services total line item is $40,000. If the final
expenditure is $44,000, it is in compliance because the final expenditure was only
$4000 more which is less than 10% of the total budget.
• If the function line expenditure is greater than the budget by 10%, it is out of
compliance.
Function 2292, supervisor total line item is $125,000. The final expenditures
are $167,000. The variance in the budget of $125,000 to the actual $167,000 is
$42,000 which is out of compliance because the function line expenditure is more
than the allowed $30,000 . (10% of the total budget)
• EX :
106
10% Variance of Object Code
Commissioner’s Memo LS-16-023
• If an object column total actual expenditure is greater than
the budgeted expenditure, then determine if the column is
out of compliance.
• Check the OBJECT Column Totals:
• 61000, Salaries: Variance cannot be greater than 10% of Total Budget
• Total budget is $300,000. 10% variance would be $30,000.
• Variance for the Total Object column for Salaries cannot be more than 10% of the total budget
($30,000)
• 62000, Variance cannot be greater than 10% Total budget, etc.
• Summary: Function Row Totals and Object Column Totals cannot be
greater than 10% of the Total Budget
107
LEA SUPERVISOR
FUNDING
2240
108
LEA Special Education Supervisor
Funding
• Supervisor funds must be coded to Fund/Source 2240
and Revenue 32310.
• LEA Supervisor funds can be used for Salary and
Benefits of special education supervisors (or purchase of
the services of special education supervisors.)
• Expenditures from current year or carryover funds should
be coded F/S 1240 or F/S 2240.
• State/Local, Title VI-B or Medicaid funds can be used to
support LEA Special Education Supervisor Salaries &
Benefits.
109
EXTENDED SCHOOL
YEAR
ESY
Link to ESY Guide https://arksped.k12.ar.us/FundingAndFinance/ExtendedSchoolYear.html
110
Extended School Year (ESY) Services
Two payments will be made:
• Part I for services from end of school
year through June 30, 2015:
reimbursed in August.
• Superintendent’s Certification due
July 17, 2015
• Part II for services after July 1, 2015:
reimbursed in September or October.
• Superintendent’s Certification due
September 11, 2015
111
Extended School Year (ESY) Services
Part I ESY services through June 30, 2015:
• Funding will be $74 per day for each child
served.
• Superintendent’s Certification forms are due
July 17th for the actual number of days ESY
services were provided through June 30th.
• Part I ESY reimbursements will be made in
August or September.
• Anticipated revenue for ESY services
through June 30 must be recoded as accrued
revenue.
• ESY expenditures that exceed the revenue
that will be received plus carryover must be
coded to some other fund.
• ESY revenue must be coded to Fund/Source
2244 and revenue 32314.
112
Extended School Year (ESY) Services
The correct entry that ESCs/Districts may be required to use to
record accrued revenue for Extended School Year services (F/S
2244) provided in June is shown below:
If the ESC/District had provided ESY services that would have
generated $10,000 for ESY revenue in June ($74 per day times the
number of days served by June 30 for all students served), during
period 12 or 13 of FY 15, the correct entry would be:
Debit 2244-01410 (Intergovernmental Receivable)
Credit 2244-32314 (ESY Revenue) $10,000*
$10,000
On or after July 1, 2015 (or after the start of period 1 of FY ‘16),
the correct entry is:
Debit 2244-32314 (ESY Revenue)
Credit 2244-01410 (Intergovernmental Receivable)
$10,000
$10,000
113
Extended School Year (ESY) Services, cont.
When funds are received, they should be
recorded as a normal deposit with a CR to
revenue and a DR to cash.
Debit 2244-01010 (CASH)
$10,000
Credit 2244-32314 (ESY Revenue)
$10,000
*Note: This amount of revenue CANNOT
exceed the amount of ESY revenue that will
be received.
If a negative fund balance exists for F/S 2244
after anticipated revenue has been accrued,
expenditures must be moved to another
funding source.
114
Extended School Year (ESY) Services
Part II ESY services after July 1, 2015:
• Funding will be $74 per day for each child
served.
• Superintendent’s Certification forms are
due September 11th for the actual number
of days ESY services were provided after
July 1, 2015.
• Part II ESY reimbursements will be made
in September or October.
• ESY revenue must be coded to
Fund/Source 2244 and revenue 32314.
• ESY expenditures that exceed the revenue
that will be received plus carryover must
be coded to some other fund.
115
2015-16 Reporting Deadlines
Please refer to the SPED Reporting Deadlines posted on the
web for ESY and Residential 2015-16 deadlines.
https://arksped.k12.ar.us/FundingAndFinance/Workshops.html
116
RESIDENTIAL
REIMBURSEMENT
Link to Residential Guides
https://arksped.k12.ar.us/FundingAndFinance/ResidentialPlacement.html
117
Residential Reimbursement
In-State Reimbursement
School districts with approved residential
facilities are eligible for reimbursement of
education costs for disabled and non-disabled
students.
Out-of-State Reimbursement
The school district where the student is a
resident is eligible for reimbursement of
education costs for disabled students only who
are provided services at approved Out-of-State
residential treatment facilities.
118
Residential Reimbursement
In-State Reimbursement
Approved residential facilities will be able to log into the RPR
system to enter student information, including dates served.
School district personnel are required to review data entered
by in-state residential facilities.
Superintendent’s Certification forms are due at the end of each
quarter.
Timely website submission required.
$60 per day reimbursement rate.
Due to the number of days that services are provided by
residential facilities, the per day amount might be adjusted
for the fourth quarter of FY 2015-16.
119
Residential Reimbursement
Out-of-State Reimbursement
School district personnel are required to log into the
RPR system to enter student information, including
days served, for disabled students placed at approved
out-of-state residential facilities each quarter.
Superintendent’s Certification forms are due at the end
of each quarter..
Timely website submission required.
$60 per day reimbursement rate.
Due to the number of days that services are provided
by
residential facilities, the per day amount might be
adjusted for the fourth quarter of FY 2015-16.
120
Coding for Residential Funding - Disabled
Students
Residential Funding—Disabled Students
FY 2015-16 Funding — $60 Per Day
Revenue must be coded as Fund/Source 2255
Revenue Code 32340.
Expenditures for Residential Funding — Disabled
students
Must be coded as Fund/Source 2255 and
Program Code 200. These expenditures should
equal but not exceed residential finding for
disabled students that is received from the state.
The function code for residential expenditures
for disabled students is 1270.
121
Coding for Residential Funding Non-Disabled
Students
Residential Funding—Non-Disabled Students
FY 2015-16 Funding—$60 Per Day
Revenue must be coded as Fund/Source 2250
Revenue Code 32330.
Expenditures for Residential Funding—Nondisabled students
Must be coded as Fund/Source 2250 and
Program Code 000. These expenditures should
equal but not exceed residential funding for nondisabled students that is received from the state.
The function code for residential expenditures
for non-disabled students is 1197.
122
COMING SOON
A worksheet for Excess Cost, a Fiscal Accountability
Manual and a Fiscal Monitoring Procedure Protocol are in
process. Continue to check the website for postings.
https://arksped.k12.ar.us/FundingAndFinance/Workshops.html
123
SPED Finance Staff
Christina.Foley@arkansas.gov
Mikki.Eubank@arkansas.gov
Jamila.Ford@arkansas.gov
Camile.Wyllia@arkansas.gov “Pepper”
Questions?
Special Education Unit
Attn: Grants & Data
1401 West Capitol, Suite 450
Little Rock, AR 72201
OFFICE: 501-682-4223
FAX: 501-682-4313
•
•
•
•
•
•
124
Area Assignments
Mikki.Eubank@arkansas.gov 501-682-4293
LEA # 0101-3001, LRSD, NLR, ESY, JDC, Residential
Jamila.Ford@arkansas.gov 501-682-4295
LEA# 3002-5604
Camile.Wyllia@arkansas.gov “Pepper” 501-683-3449
LEA# 5605-7510, PCSSD, Charter districts, Preschool