ESEA FINANCIAL ISSUES
September 16, 2014
WVDE Office of Federal Programs
Laura Pauley, CPA
lepauley@k12.wv.us
Helpful Links
– OMB Circular: December 26, 2013 Federal
Register Final Guidance
• http://www.gpo.gov/fdsys/pkg/FR-2013-1226/pdf/2013-30465.pdf
– Education Department General Administrative
Regulations (EDGAR)
• http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.
html
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ESEA Program Updates
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Updates
– New EDGAR finalized December 26, 2014
• To be in line with new Omni Circular
• Draft was due out June 26, 2014
– FY 2015 grants issued prior to December 26, 2014
will still be governed by old regulations
– New monitoring process being implemented
• Omni Circular requires additional monitoring and
oversight of LEAs by SEAs
• Must do some monitoring of every LEA every year in
additional to 5 year schedule
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Updates
• Risk assessments must now be done on all
LEAs prior to providing federal funding
• Certified 5-17 report
• 5-17 report coming out with certified reports (look for this
with enrollment reports in the coming months)
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Carryover
• Title II and Title VI Carryover
– Increased from 15% limit to 40% (for 9/30/14 only
to help offset Title I carryover confusion)
– Need to start analyzing and moving expenses if
necessary before Sept 30th
• Title I limited to 15% (unless allocation <
$50,000)
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Carryover
• How to calculate carryover
– Carryover is verified by WVDE running Project
Financial Reports once counties have closed their
books for September.
– Payroll related encumbrances are not included in
the calculation of carryover.
– If a county has transferred Title II/VI funds into
Title I these funds count towards carryover
amounts
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Carryover
• How to reduce your carryover
– Transfer Title I eligible expenditures from other
funds without carryover limits or with higher
carryover limits into Title I
– Must clean-up carryover over prior to closing
September so that we can verify carryover
amounts
– Obligate funds by Sept 30th
– Practice “First In First Out”
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Obligation
If the obligation is for -
The obligation is made-
(a) Acquisition of real or personal
property
On the date the district makes the binding
written commitment to acquire the
property
(b) Personal services by an employee or
the district
When the services are performed
(c) Personal services by a contractor who
is not an employee of the district
The date the district makes a binding
written commitment to obtain the
services.
(d) Performance of work other than
personal services
On the date the district makes a binding
written commitment to obtain the work.
(e) Public Utility Services
When the district receives the services
(f) Travel
When the travel is taken
(g) Rental of real or personal property
Then the district uses the property
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Liquidation
• Liquidation typically occurs 30 days after end
of the obligation period.
– Make sure funds are requested from WVDE prior
to the ending liquidation date
– WVDE cannot distribute funds after the ending
liquidation date listed on the grant document
• Liquidation dates can vary by grant
– Always double check your grant document
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