Council of Chief State School Officers
 This webinar will be recorded and posted, along with the
Toolkit, to the CCSSO website following today’s
presentations
 All participants have been muted, but you are invited to
submit questions using the chat feature on your screen
 If you experience technical difficulties during this
presentation, please call the WebEx helpline:
(866) 569-3239
Maximizing Federal Funds Toolkit
 Peter Zamora (peter.zamora@ccsso.org)
Director of Federal Relations
CCSSO
 Federal Education Group
 Melissa Junge, Esq.
 Sheara Krvaric, Esq.
 Kathleen Airhart
Deputy Commissioner
Tennessee Department of Education
 David Blowman
Deputy Secretary
Delaware Department of Education
Introduction to Toolkit
 Why this toolkit?
 Many states are not doing things they want to do because of
concerns about the impact on federal funds/federal compliance
requirements
 For example, many states want to:
• Organize around policy priorities as opposed to funding source
• Spend federal formula grants in ways that support state policy goals
• Monitor not only for compliance but for program performance
 How does this toolkit help?
 Provides an overview of common misperceptions about federal
programs that create implementation barriers
 Provides a roadmap for addressing those misperceptions
3
Changing the Status Quo is Hard
 Complicated federal rules lead to compliance myths
and other challenges
 State power levers with regard to federal funds are
“hidden” within complex regulatory language
 Past practice is powerful
4
Complicated Rules Impact Delivery
 Compliance myths: belief things are not permitted by federal law
even when they are
• Driver/example: confusion over supplement not supplant
– BUT . . .rule is more flexible than typically perceived/differs by program
 Silo approach: initiatives administered on a federal funding stream basis
rather than comprehensively
• Driver/example: time and effort requirements
– BUT . . . federal law offers some flexibility with regard to time and effort
 Significant resources (time and money) devoted to administrative
requirements: numerous federal compliance requirements take up significant
staff time/money (at federal, state, district, and school level)
• Driver/example: duplicative planning, reporting, monitoring requirements
– BUT . . . federal law permits certain planning to be consolidated
5
Toolkit Approach
 Sets up the problem and the challenge
 Recommends steps states can take to begin the work
 Identifies three broad areas where states can begin to
rethink federal program implementation:
1. State use of funds policies
2. Planning and reporting requirements
3. Monitoring and oversight
 Suggests strategies and activities in each of these
areas
6
First Area: State Use of Funds Policies
 Example of Opportunity: Supplement Not Supplant (SNS)
 Traditionally examined through the lens of three
presumptions:
1.
2.
3.
Is the activity required by state or local law?
Was the activity previously supported with state/local funds?
Do state/local funds support the same activity for other students?
 Yet, there are different SNS rules for different programs



Title I schoolwide programs – different test
IDEA, Part B – effectively no SNS just MOE
Title II – no third presumption
7
Supplement not Supplant Example
(cont.)
 State guidance may fail to highlight the different
approaches to supplement not supplant, leading schools
and districts (and their auditors) to apply more restrictive
rules
 Opportunity: issuing guidance that clarifies the law and the
available flexibilities
8
Second Area: Planning Requirements
 Example: Consolidated Application/Plans
 Federal law permits states to consolidate or combine
applications/plans in certain circumstances
 Challenge is to maintain ability to trace back to federal
compliance requirements and expectations
 Opportunity: taking an inventory of plans, then consolidating or
combining plans in a way that reduces burden, increases focus,
and reduces paperwork so that LEAs and schools can spend
more time on instructional and student support activities
9
Third Area: Monitoring and Oversight
 Example: Monitoring Process
 Opportunity: reducing burden and increasing meaningfulness of
monitoring and oversight work by embedding oversight
throughout the grants process and taking a differentiated
approach based on risk (including performance measures,
spending data, etc.)
10
Rethinking Federal Processes at an SEA:
Consolidated Planning and Monitoring
Dr. Kathleen Airhart, Deputy Commissioner
November 16, 2013
CCSSO Richmond, VA
Increasing Rigor and Improving Outcomes for ALL Students
Curriculum
and
Instruction
Career and
Technical
Education
Teachers and Leaders
College &
Career
Readiness
Consolidated
Planning & Monitoring
Special
Populations
CORE
support
12
Office of Consolidated Planning & Monitoring
Goal: To provide support to LEAs by aligning funding sources
through a consolidated planning and monitoring process to
incorporate a focus on outcomes for all students
Better support districts to:
 Target ambitious goals around growth and gap closure
 Increase focus of spending plans on academic support
 Analyze and utilize all of available financial resources
 Streamline all aspects of monitoring and compliance
 Provide a clear connect between spending and student learning
ePlan: Tennessee’s Planning and Monitoring tool
Phased implementation Plan
Planning Component: One electronic spending plan document
providing information to include all revenues and directly linked to
district accountability.
Monitoring Component: Joint tiered monitoring combining ESEA
and IDEA requirements and targeting those districts with the most
significant challenges.
Challenges to Implementation






Reorganizing the SEA
Supporting LEAs to plan comprehensively
Shifting to results based-monitoring focus
Targeting ESEA/IDEA compliance differentials
Changing paradigms and breaking down barriers
Providing consistency in messaging!
Kathleen.Airhart@tn.gov
16
Delaware’s Move Toward
Greater Flexibility with Stronger
Accountability
November 2013
17
Federal Funds: A Brief History
 Compliance focus as a result of federal monitoring findings
 Scope of Consolidated Application content increased
dramatically
 Reduced focus on intent of “Consolidating” to reduce
redundancy and increase coordination among programs
 Limited flexibility given to Schoolwide Schools due to
misunderstanding of supplanting rules
 Untimely and sometimes inaccurate final allocations and
significant delays in loading of funds
 Limited timeline for availability of funds
 One size fits all monitoring approach
18
School Year 13-14 Process Changes
 Centralized coordination and support for program managers
to increase consistency of grant reviews
 Enhanced grant technical assistance to include clarity from
program managers on grant expectations
 After providing technical assistance to LEAs provided full
flexibility on use of funds for schoolwide schools
 Automated Title I allocations to reduce delays and eliminate
errors
 Shortened timeframe for initial grant reviews by DOE
 Streamlined process of loading grant funds
 Gave LEAs full period of availability of funds
 Incorporated monitoring of quality for Title I, IDEA and ELLs
into ESEA Flex routines
 Moved majority of compliance monitoring to desk audits
19
14-15 School Year and Beyond
 Enhanced technical assistance on strategic planning, with
particular focus on conducting a quality needs assessment
 Stronger expectations on alignment of LEA/school defined
needs, and needs discovered through data review during
ESEA Flex monitoring routines, to the use of federal funds.
 Change focus of some consolidated application questions to
hone in on quality rather than compliance
 Allow maximum flexibility for LEAs that are making progress
 Limiting allowable uses of funds for some LEAs that have not
made progress with past uses of funds or where no alignment
to needs exists (Ex. Title II and class size reduction)
 Greater coordination among program managers where there
is overlap exists in grant questions (i.e. equitable
services),Technical assistance, and fiscal monitoring
 Automating allocations for all other federal programs to further
20
reduce turnaround time for final allocations
Questions?
 Please enter questions or comments in the chat box on
your screen
 This webinar and the toolkit will be posted to
www.ccsso.org
 States interested in learning more about the Federal
Funds Working Group should contact CCSSO:
 Peter Zamora (peter.zamora@ccsso.org)
 Margaret Millar (margaret.millar@ccsso.org)