Safety Net 2013-14
Presentation for ESDs
Disclaimer
Information provided today is meant to supplement and not
supplant reading bulletins and accompanying documents;
guidance from the U.S. Department of Education; Chapter 392172A WAC; Part 300 of the federal regulations; and, the
Individuals with Disabilities Education Act.
This presentation and/or materials:
 Should be viewed and applied by users according to their
specific needs,
 Should be used as guidance, and
 Is not intended as legal advice.
2
Safety Net Program

Enacted by the Legislature and funded annually in the
Appropriations Acts;

Established as a law in Title 28A Revised Code of
Washington (28A.150.392);
Codified in administrative rules and regulation in WAC
392-140-600—685; and
Announced in the annual Safety Net Bulletin-B062-13.


3
Safety Net Awards

Safety net is a combination of state and federal funding
available as awards to districts with demonstrated
capacity for special education funding beyond the amount
provided through the special education funding formulas.

Safety net is awarded by the state special education
oversight committee subject to conditions and
limitations.
4
Two Types of Safety Net Awards
Community Impact-for districts that convincingly
demonstrate capacity for funding to meet the
extraordinary costs associated with communities that
draw a larger number of families with children in need of
special education services.


State special education funded (Revenue 4121).
High Need Individual-for districts that convincingly
demonstrate capacity for funding to meet the special
education and related services costs of an eligible high
need student with a properly formulated IEP.


5
High need awards may be a combination of state (Revenue
4121) and federal (Revenue 6124) funding.
2012-13 Applications & Awards

Six (6) districts applied for and were awarded
Community Impact (CI) funding in 2012-13.

108 school districts and one Educational Service
Agency submitted 2,121 high need individual
applications on behalf of special education students
in Washington State.
6
Safety Net Awards
3,500
3,197
3,000
2,936
2,604
Total Award Amounts
2,500
2,270
2,136
2,000
1,854
2,016
2,121
1,759
1,865
1,477
1,500
1,036
1,000
500
Applications Submitted
Applications Awarded
Percent of Applications
Awarded
7 *ARRA influenced
07-08
2,936
2,270
08-09
3,197
2,604
09-10*
1,477
1,036
10-11*
2,136
1,854
11-12
2,016
1,759
12-13
2,121
1,865
77%
81%
70%
79%
87%
88%
Funded High Need Awards

88% of the high need applications were awarded
funding‒1,865 individual applications.

Awards totaled $29,569,521.

The average award was $15,855.
8
Safety Net Web Site
http://www.k12.wa.us/SpecialEd/FinanceGrants/SafetyNet.aspx
9
Deadlines & Meeting Dates
10
Deadline for
Receipt of
Application at
OSPI
Type of
Application
Oversight
Committee
Meeting Date
Meeting
Location
February 14,
2014
Community
Impact
March 20–21,
2014
SPSCC, Lacey
(Hawk’s Prairie)
March 28, 2014
High Need
Individuals
June 18–19, 2014
SPSCC, Lacey
(Hawk’s Prairie)
March 28, 2014
Community
Impact
(Resubmittals
Only)
June 18–19, 2014
SPSCC, Lacey
(Hawk’s Prairie)
To Apply

First, read the Safety Net Bulletin;

Then, complete Worksheet A to determine if the district
demonstrates capacity for funding.

Worksheet A is pre-populated with 2013–14 F-195 data
and 2012–13 F-196 data.
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If Worksheet A
Demonstrates Capacity for Funding

The district may apply for a Community Impact award, or

High Need Individual award, or

both, Community Impact and High Need Individual
awards, but

not for an individual student on both Community Impact
and High Need Individual applications. (No double
dipping.)
12
Community Impact
A unique factor causing a disproportional number of families
with need for special education services
13
2013-14 Community Impact Changes

Districts may submit their Community Impact application
via email to Maryellen.parrish@k12.wa.us.

Applications are due Friday, February 14, 2014 by 5 pm.

Email submissions are limited to Community Impact!
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Application Steps:
1.
Identify the unique factor(s).
2.
Present the student enrollment data, including SSID
numbers, attributed to the factor(s). Compare district
data with surrounding districts or districts of similar
size or statewide data where applicable.
3.
Quantify the fiscal impact upon the district’s special
education program.
4.
Summarize the application and describe steps taken to
address the impact of the factor(s).
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Community Impact Applications
Include:

Certification Form;

Worksheet A;

Year to date expenditure report showing budget and
actual expenditures, totaled at activity/object level thru
the most recent completed month (January 2014);

Special Education Enrollment Exception reports for 201314 Note: October—February;

Community Impact Application.
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Certification Form
Please indicate if a representative of the district will be
attending the Safety Net meeting. Action will be taken on
the district’s application on the morning of the second day
of the State Oversight Committee meeting for those
districts.
( ) __________________________ will attend the
State Oversight Committee meeting.
( ) The district will not attend the State Oversight
Committee meeting.
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Worksheet C
Fiscal demonstration of individual high need costs
18
2013-14 Changes to
High Need Application Process

The high need individual application threshold is $25,395.

The IEP Review Form has been updated. Use this review
form for any IEP written after September 2013.

Complete the IEP Review Form before preparing
Worksheet C to confirm that the IEP is a properly
formulated, compliant IEP.

The IEP Review Form is used for self-review only, please
do not submit it with the application.
19
Reminder of 2012-13 Changes

Applicants are required to submit all IEPs in effect for the
2013-14 school year to validate and quantify the provision
of reimbursable direct special education services for the
period of the funding requested.

To make quantification of costs easier, Worksheet C
includes a coversheet that helps districts separate current
and prior IEP costs.

Submit all Special Education Enrollment Exception
reports for the school year. Note: October—March.
20
442 Correction Process
 All IEPs identified as non-compliant by either the SOC or
Program Review during 2012-13 must go through the 442
correction, verification, and validation process before submission
for safety net funding in 2013-14.
21
Screen Shot of Worksheet C Coversheet
Step 1:
Complete the Worksheet C
Summary
Enter IEP information for each student in cells shaded
green.
NOTE: Many of the fields on this worksheet have drop down or predefined lists.
Step 2:
Current IEP
Enter the number of days the resident student is served with the Current IEP in 2013–14 school year.
85
Note: Sum of the Current IEP number of days and the Prior IEP number of days should equal the number of
days in the school year, unless there is a lapse in service between IEPs.
For the student's Current IEP, enter:
Staff Cost information
Includes information regarding the Special Education teacher and the Classified staff serving
this student.
Other Staff Cost information
Includes information regarding the in-district related service providers (SLP, OT, PT, VI etc.)
serving this student.
Personal Service Contractor information
Includes information regarding the contracted related service providers (SLP, OT, PT, VI etc.)
serving this student.
22
Step 3: Prior IEP
Enter the number of days the resident student is served with the Prior IEP in the
2013–14 school year.
90
Note: Sum of the Current IEP number of days and the Prior IEP number of days should equal the
number of days in the school year, unless there is a lapse in service between IEPs.
For the student's Prior IEP, enter:
Staff Cost information
Includes information regarding the Special Education teacher and the Classified staff
serving this student.
Other Staff Cost information
Includes information regarding the in-district related service providers (SLP, OT, PT,
VI etc.) serving this student.
Personal Service Contractor
information
Includes information regarding the contracted related service providers (SLP, OT, PT,
VI etc.) serving this student.
23
Step 4: ESY
Enter the number of days per week the resident student is served in ESY in the
2013–14 school year.
Enter the number of weeks the resident student is served in ESY in the 2013–14
school year.
3
4
For the student's ESY costs, enter:
Staff Cost information
Includes information regarding the Special Education teacher and the Classified staff
serving this student.
Other Staff Cost information
Includes information regarding the in-district related service providers (SLP, OT, PT, VI
etc.) serving this student.
Personal Service Contractor
information
Includes information regarding the contracted related service providers (SLP, OT, PT,
VI etc.) serving this student.
24
Fiscal Corrections on High Need
Applications in 2012-13

Base salary for certificated special education staff.

Caseload for certificated special education staff.

Calculation for Extended School Year costs.
25
26
27
Reasons for Fiscal Adjustments
Worksheet A did not demonstrate funding
capacity
Application funded in Community Impact
award
28
2
2
Service provider was not quantified
11
442 verification and validation process either
not completed or completed late in school year
31
Mathematical errors on Worksheet C
12
Incomplete IEP
15
ESY costs were included but student did not
qualify for ESY
5
Reasons for Fiscal Adjustments
Costs were calculated for full year even though
student had exited the district
3
IEP had lapsed
1
Contract costs were corrected
7
Costs were recalculated based on change in level
of services
12
Costs of non-special education programs
employees were deducted
5
Teacher salary and/or caseload corrected
8
29
More about the 442
 If an application is submitted for an IEP that was on
the 2012–13 iGrants Form Package 442, the costs
associated with the application will be pro-rated from
the date of the 442 correction.
 Example: An IEP was found non-compliant in 2012–
13 and the district did not correct the noncompliance associated with the IEP until September
30, 2013, the costs associated with the application
would be adjusted to reflect the September 30, 2013
correction date.
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Tips

Know the number of school days in the school year for
your district!

Be sure that LRE is calculated correctly.

Include the names of the special education students
served on contracts submitted with high need
individual applications .

Tie contract billings to attendance when possible.

Submit the complete IEP.

Be careful when photocopying two-sided documents.
31
Reasons for Fiscal Adjustments

Frequency, duration and location of ESY services not
specified in the IEP. Example:
32
Reasons for Fiscal Adjustments

Cost of services were based on an incorrect number of
school days.
33
Adjustments for Differing Hourly Rates

The district paid a lower hourly rate than stated on
contract for services.
Example: The district entered into a contract for nursing
services. The contract was based on a registered nurse’s
rate of pay but the company actually supplied a licensed
practical nurse.
34
Programmatic reasons why
applications weren’t funded
IEP lacked present levels of performance and/or effect of
disability in Gen Ed—300.320(a)(1) & WAC 392-172A03090(1)(a)
IEP lacked Measurable Annual Goals—300.320(a)(2) &
WAC 392-172A-03090(1)(b)
IEP lacked an explanation of extent to which student will
participate with nondisabled peers—300.320(a)(5) &
WAC 392-172A-03090(1)(e)
IEP lacked state assessment decision and/or alternate
assessment goals and objectives—300.320(a)(6) & WAC
392-172A-03090(1)(f)
35
24
37
2
10
Programmatic reasons why
applications weren’t funded
IEP did not specify frequency, location, and duration of
services and modifications—300.320(a)(4) & WAC 392172A-03090(1)(d)
IEP lacked a properly formulated transition plan—
300.320(b)(1,2) & WAC 392-172A-03090(1)(j)
IEP lacked required personnel at IEP meeting and/or
written permission excusing staff—300.321 & WAC 392172A-03095
Aversive intervention plan lacked required
components—WAC 392-172A-03135
36
8
27
7
57
Programmatically
1.
Lack of measurable annual goals continues to be the
number one reason why individual requests are not
funded;
2.
Transition;
3.
IEP was either missing Aversive Intervention Plan
referenced in IEP or Aversive Intervention Plan lacked
required components.
37
For Each High Need
Application, submit:
Three copies of the following, assembled in this order:

Worksheet C (including Staff Costs, Other Staff Costs and Personal
Service Contractor Cost Worksheets, if applicable).

Medicaid Reimbursement Calculator, if applicable.

Transportation Cost Calculator, if applicable.

Student’s redacted IEP(s) in effect for the 2013-14 school year. If more
than one IEP is necessary, submit only one set with the prior IEP.

Aversive Intervention, Behavior Intervention and/or Health Care Plans, if
applicable.

Purchase Order, contract and Invoice for any expenditure claimed.
Staple the student applications in the left hand corner, then group each stapled
application together in order of SSID number (lowest to highest), with a
rubber-band around each set.
38
A Complete Application for
High Need Awards Includes:
One set of each of the following items in the financial
package:





39
Certification Form;
Worksheet A;
Year-to-date expenditure report showing budget and actual
expenditures and totaled at activity/object level thru the
most recent completed month (February2014);
Special Education Enrollment Exception reports for 2013-14
Note: October—March
and
High Need Individual application packet
After the Applications are
Reviewed in June

The district will receive a conditional award letter.

The district will be asked to submit the following
information by July 31, 2014 or after July payroll is posted:

Detailed expenditure reports for Programs 21, 22, 24, 26, and
29 showing budgeted and actual year-to-date expenditures
sorted by program and totaled at activity/object level, and

A roster indicating ESY participation of students for whom
the district requested ESY reimbursement, and

A roster of any high need applicants that exited the district
during the period for which the district requested
reimbursement.
40
Additionally…

Form SPI 1679 is due no later than June 30, 2014.

Districts must submit SPI Form 1679 Potential
Medicaid Eligible Student Worksheet prior to fiscal
award determinations in August as a condition of
determining potential award. (See Memorandum 05913M)
41
Potential Medicaid Eligible Students
Section 1. Medicaid Eligible Students:
400
Number of students on eligibility report provided by district's billing consultant company.
Section 2. Non-billable Medicaid Eligible Students - Unduplicated
Number of students considered non-billable because:
a. The student(s) is/are in initial evaluation process.
b. The student(s) is/are no longer enrolled in this district.
8
6
c. The student(s) have exited Special Education.
d. The student(s) receive Specially Designed Instruction (SDI) in academic
areas only, and is/are not scheduled to be re-evaluated during this school
year.
e. The student(s) receive(s) services delivered by a non-billable provider.
f. The student's parent/guardian did not sign the 'Consent to Bill for SchoolBased Medicaid Reimbursement' form.
14
125
199
14
g. The student(s) receive(s) services covered by third-party insurance.
0
Total Non-billable Medicaid Eligible Students:
366
Sec. 3. Potential Billable Medicaid Eligible Students
34
Potential Medicaid Eligible Students
Number of Students Billed
=
% of students
billed
In this example, the district is billing for 100% of eligible students: 34 / 34 = 100%
42
Determination of Final Award in August

State funded awards will be included in the district’s
August apportionment.

To receive federal funded awards in August, districts must
submit the iGrants budget (form package 269) and draw
down funds by August 19, 2014.

Even if the district does not draw down federal funds in
August, the district must create their budget in iGrants by
August 30, 2014 to obligate the funds.
43
Request for Review & Reconsideration

Rules regarding request for review and reconsideration
have been in place since 1996.

The criteria for a request can be found in WAC 392-140656.

The request is time sensitive.
44
Audit & Recovery

All safety net applicants are subject to audit by the
Office of the State Auditor at the request of the State
Oversight Committee.

All safety net funding awards are subject to adjustment
and recovery.

Recovery could include situations where the student has
left the district or had a change in services or capacity
for funding was reduced based on F-196 data.
45
Survey says…
[√] Publish Bulletin and threshold sooner.
[√] Start training sooner.
[√] Provide data on errors from prior years.
[√] Provide online submission for some portion of the
applications.
[√] Provide bulleted lists of what is needed in an
application.
46
For more information…




http://www.k12.wa.us/SpecialEd/FinanceGrants/SafetyNet.aspx
http://www.k12.wa.us/SpecialEd/FinanceGrants/Medicaid.aspx
http://apps.leg.wa.gov/WAC/default.aspx?cite=392-140600
Maryellen.parrish@k12.wa.us
47
Conditions & Limitations
Applying to Worksheet A
1.
Differences in costs attributable to district philosophy,
service delivery choice, or accounting practices are not
a legitimate basis for safety net awards;
2.
All available revenues from the state special education
funding formula and all available federal revenues for
special education eligible students—Impact Aid,
Medicaid, Individuals with Disabilities Education Act,
special needs projects, and program income are
considered when evaluating capacity for funding;
48
Conditions & Limitations
3.
The maximum allowable indirect cost for calculating
safety net eligibility cannot exceed the federal indirect
cost rate for the district plus one percent;
4.
The costs of supplemental contracts are not included
for purposes of determining safety net awards;
5.
And, all information presented is true, accurate, and
complete.
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Additionally,

The district certifies that:




federal Medicaid has been billed for all services provided by
licensed billers to Medicaid eligible students;
the district has no unresolved audit issues related to special
education;
and the district’s special education services are operated in a
reasonably efficient manner.
And acknowledges that, safety net funding is:



50
not an entitlement,
subject to adjustment and recovery, and
may not be available in future years, and must be expended in
Program 21 or 24.
Legislative Language

“Beginning with the 2010-11 school year award cycle, the
office of the superintendent of public instruction shall
make award determinations for state safety net funding in
August of each school year. Determinations on school
district eligibility for state safety net awards shall be based
on analysis of actual expenditure data for the current
school year.”
51