Maintenance of Effort 2012 ‐ Instructions for Completing Compliance and Eligibility Screens
Maintenance of effort requires a district to spend the same amount of state and local funds combined, either per pupil or in total, or local only funds either per pupil or in total, from one year to the next for the education of students with disabilities. In certain circumstances described in the Individuals with Disabilities Education Act (IDEA) regulations, the Office of Special Programs may give the LEA approval to reduce the level of expenditure required. To determine whether a district has complied with this rule, expenditures for the two consecutive years for which complete data are available are pulled into the MOE Compliance screens in the Five Year Online Strategic Plan – Special Education Component. These screens are found under Compliances – LEA Special Education – MOE 2012 – State/ Local and Local Funds At the top of the screens, two links appear. Requirements links to the IDEA requirements for four calculations to determine maintenance of effort and the allowable exceptions. Only one of the four tests for MOE must be met to be in compliance. If the test meets compliance, it displays in green; noncompliance displays in red. If all tests show noncompliance, an acceptable reason for reduction must be documented and submitted to the OSP for approval to achieve compliance. Please e‐mail Dr. Sandra McQuain, smcquain@access.k12.wv.us if assistance is needed in locating information regarding prior years’ approved reductions in MOE. Resource links to a table with the Medicaid amounts and reduction in maintenance of effort based on 50% of the increase in federal funds, collected by the Office of Special Programs (OSP). State/Local Calculation Screen: 1: This line includes total expenditures for students with disabilities (2xxxx, excluding program/function 21271) in funds 11, 12, 2x, 3x, 4x, 5x, 61 and 71, Projects 00yxx ‐ 29yxx and 9xyxx,
and excluding projects 04yxx ,
2. If expenditures for OPEB were not recorded to Program/Function 2xxxx but should have been, the LEA adds that total in this space. (If expenditures were recorded, they show in the above amount) 3. Total Expenditures for Medicaid (Project 00y83) ‐ If expenditures for students with disabilities (2xxxx, excluding 21271) have been coded to 00y83, they will show on this line. Beginning in FY 2011, recording Medicaid to 00y83 is required for all LEAs. 4. If Medicaid expenditures for students with disabilities were not recorded in project 00y83, enter the total expended for Medicaid in the space. Refer to the Resource table. 5. Reduction in maintenance of effort approved for FY10 by the Office of Special Programs is entered in this box by the LEA. It does not reduce the expenditures credited to FY09, however, it is subtracted from the FY09 level to determine the level that was required for FY10 after the reduction. Two types of reductions are allowed under IDEA: 1) The OSP may have approved a reduction equal to up to 50% of the increase in federal IDEA, Part B funds received in FY10 compared to FY09. To use this reduction, the LEA included the amount to be reduced and a budget for use of the “freed up” state and local funds to be spent during FY10 for a 1 OSP June 2011 Maintenance of Effort 2012 ‐ Instructions for Completing Compliance and Eligibility Screens
purpose allowable under ESEA. The expenditures were recorded under project 00087. Please enter the amount expended and recorded under this code to non‐special education expenditures. In this situation, expenditures coded to special education (program/function 2xxxx) are not part of the reduction. This amount may be found in the Resource table. 2) The Office of Special Programs may have approved a reduction when the FY10 budget was submitted based on another allowable reason, for example, reduction in child count, receipt of high cost fund reimbursement, or voluntary retirement of special education personnel. If so, the reason and amount may be found on the MOE page in a prior year’s plans. Prior years’ plans in pdf may be accessed within the Five Year Online Strategic Plan site under Printing/ Submission ‐ Special Education. Local only calculation screen: Review the local funds calculation screen. The LEA cannot make entries in this screen. Compliance shows in green; noncompliance shows in red. If Medicaid adjustments were required in the State/local screen, those expenditures also must be subtracted in this screen. The OSP will manually perform this calculation, when it is required for the LEA to demonstrate MOE, using Medicaid adjustments reported by the LEA. Eligibility screen: The LEA must enter the total amount of state and local funds budgeted for students with disabilities (2xxxx, excluding 21271) for FY2012 on the first line. The OSP is not pulling this information. On line 2, the LEA enters the additional amount of OPEB that will be recorded as expenditure for students with disabilities at the end of FY2012 but does not show in the FY2012 budget submitted to WVDE. The total displays on the third line. This is the amount the LEA, i.e., the Superintendent of Schools, assures will be spent for students with disabilities in FY2012, and, furthermore, assures this amount will meet maintenance of effort requirements. If this amount is less than the amount expended in FY10, provided FY10 was in compliance, then the LEA must document allowable exceptions for reducing this amount. To receive approval of the special education plan, the reasons and applicable documentation must be submitted to the OSP and be approved. Please note the FY2010 expenditure level is used to estimate the required amount for FY2012, however, the FY2012 budget actually must meet or exceed the FY2011 expenditure level by one of the four allowable tests of MOE. When the actual FY2011 expenditure data are available (November 2011), the FY2011 and FY2010 comparisons to determine compliance will be performed, and the required expenditure level will be compared to the FY2012 budget to determine whether it will meet MOE. The LEA Superintendent assures adjustments will be made if necessary to meet MOE for FY2012. Final eligibility to receive IDEA funds is not established until the actual FY2011 expenditures are analyzed. 2 OSP June 2011