Title I Compliance Training - the School District of Palm Beach County

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Title I Technical
Assistance Training
Federal and State Programs
Welcome
Introductions
Materials and Handouts
Title I Contacts (orange folder)
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Department of Federal and State Programs Contact List
Title I Allowable Expenses
Title I Food Purchase Pre-Approval/Checklist
Title I Field Trip Audit Compliance Checklist
Title I Travel Audit Compliance Checklist
FY14 Title I Tutorial Guidelines
FY14 Audit Checklist by Folder
FY14 Audit Checklist by Month
FY14 Title I Job Codes
Title I Faculty Presentation Verification
Title I Contact Handbook
Sample Title I Charter School Reimbursement Packet
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Materials and Handouts
CFO/Payroll/Treasurer Contacts (blue folder)
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Department of Federal and State Programs Contact List
Title I Allowable Expenses
Title I Food Purchase Pre-Approval/Checklist
Title I Field Trip Audit Compliance Checklist
Title I Travel Audit Compliance Checklist
Title I Tutorial Guidelines
FY14 Title I Job Codes
FY14 Title I Typical Functions and Accounts
Goal and Benefits of Title I
To help ensure that all children have the
opportunity to obtain a high-quality education
and reach proficiency on challenging state
academic standards and assessments
To provide additional funding to supplement
the existing curriculum, parent involvement
initiatives, and provide staff development to
ensure highly effective staff
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Title I Eligibility/Schoolwide Plan
• Based on number of students who qualify for free or reduced
priced meals, ages 5-17
• Percentages posted on School Food Services website
http://www.palmbeachschools.org/sfs/reports/Title1.pdf
• “Date Certain” (FY15 - December 20, 2013)
• Academic Leadership Team sets Title I % cutoff
• Schools ranked by percentage, FY14 eligibility set at 59.5%
• All Palm Beach County Title I schools are schoolwide programs
• Serve all students in the school, but require special focus on
lowest achieving students
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Responsibilities of Title I Schools
• Adhere to Federal and State Requirements
• Document Federal and State Compliances
• Manage Title I budget in accordance with SIP/SWP
• Expend non-salary funds by December 20, 2013 to
ensure maximum benefits
• Close the Achievement Gap
Recommendations
Create a Title I school team consisting of key personnel
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Support Services
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Host Title I Chats – first Wednesday of the month
Visit schools monthly – Sept, Oct, Nov, Jan, Feb, Mar, May
Provide budget information and compliance updates
Provide updates to area directors
Meet with key school personnel in small groups with similar
concerns, as needed
• Monitor SIP/SWP to ensure alignment with Title I budget(s)
• Approve budgets, budget transfers, and requisitions
• Visit school activities for compliance (e.g. Annual Meeting,
tutorial, Kindergarten Round-up, etc.)
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FY14 Budgets
Step 1 – School submits Title I Planning Tool in Spring
for approval
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FY14 Budgets
Step 2 – Budget is uploaded into PeopleSoft in June
FY14 Budgets
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Step 3 – School documents expenditures in SIP/SWP
Step 4 – Once the plan is approved by Title I, all changes must
be approved by SAC and revised in SIP template
Recommendation
Print approved SIP Final Budget to review when submitting
budget transfers and requisitions
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Title I Funds
• Title I (Part A Basic) – all schools
 Fund 4201 closes June 30, 2014
• School Improvement Grant (SIG a) – DA schools
 Fund 4215 closes October 2013
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Minimum Requirements
a.k.a. Set Asides
• All Title I schools must expend their Parent Involvement
allocation in Function 6152
• All schools must utilize a portion (10%) of their Title I
allocation(s) on professional development activities
that address the needs of students who are not
demonstrating mastery
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FY14 Title I Unacceptable Expenditures
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Secretary, office assistant, attendance clerk
School police officer, security guard, school police aide
Clinic aide, school nurse, clinic supplies
Custodian, custodial supplies
Cafeteria worker, cafeteria supplies
Administrative personnel and costs (i.e. grade books, office
computers, and toner)
ESE and ELL coordinators, ESE forms and tests
Behavioral Intervention Assistant (BIA)
Incentives, rewards, certificates, door prizes, raffle items, etc.
Marketing items such as brochures, banners, and flags
Memberships for professional organizations
Field trips for entertainment
Food items (unless purchased for parent trainings)
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New Procedure for FY14
Food Purchases for Title I
Family Involvement Trainings
• Pre-approval is required five SCHOOL DAYS prior to
incurring expenses for parent training when cost
exceeds $100.00
• Submit Title I Food Purchase Pre-Approval/Checklist
to your Title I specialist
• Additional documentation will be required
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Common Errors
 Food purchased for activities that were not
parent trainings
 Food purchase did not support number of
parents in attendance
 Missing evaluations
 Missing Title I Food Checklist with packet
 Trainings did not address the needs of
schools’ diverse population
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Title I Food Purchase
Pre-Approval/Checklist
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Criteria for Food Purchases for Title I
Family Involvement Trainings
• Training must be tied to curriculum such as
enhancing literacy or math and teaching
parents strategies they can use to assist their
children at home
• Not part of the School Advisory Council, PTA,
PLC, or other committee meetings
• Reasonable in cost
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Criteria for Food Purchases for Title I
Family Involvement Trainings
• Expenditures must be identified in the school’s
Parent Involvement Plan (PIP) and the
SIP/SWP as a means of encouraging or
expanding family involvement
• Absolutely no food expenditures will be allowed
for faculty or student events
• Contact your Title I specialist for clarification
before incurring expenses
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Travel
• Conferences/workshops
must be documented in
your SIP/SWP
• Out-of-County travel must
be approved by area
superintendent
(account 533600)
• Out-of-State travel must be
approved by CAO
(account 533620)
• No charges should be
incurred prior to Title I
approval
Field Trips
• Must relate to the needs outlined
in the SIP/SWP
• Must have a direct tie to the core
content areas of reading, writing,
mathematics, or science
• May not be used as incentives or
rewards
• Costs should be reasonable
• Resort or vacation areas (water
parks, amusement parks, etc.) are
not allowable
• Title I funds cannot cover
expenses for parents or
chaperones
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Property and Equipment
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• All unit items costing $350.00 through $999.99 must be labeled as
Title I and added to the school’s Title I Inventory List
• A running list of these items must be maintained throughout the
year (template on website) including mobile devices such as iPads,
Nooks, and Kindles (Items MUST be labeled Title I)
• All items costing $1,000.00 or more must be labeled with a white or
red Property Records Tag
• The location of the items should be indicated on the Title I Inventory
List and updated if items have been relocated and available for
specialists during visit
• Labeling of items verified during site visit
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Highly Qualified Staff
• All teachers of core content areas are to be highly
qualified in the area for which they are hired
• All paraprofessionals providing instructional
support must be highly qualified (i.e. those who
assist with classroom management, provide
instructional assistance in a computer lab or media
center, or provide instructional support services)
• Staff who are NOT highly qualified cannot work in a
tutorial program, with the exception of the lead
tutor
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Tutorial Guidelines
• Teacher rate is usually $20.44 an hour
• Non-instructional staff earn their regular hourly rate
• ONLY highly qualified teachers will be placed in
tutoring positions
• Teachers may ONLY be paid for 15 minutes of
planning time for every hour of tutoring
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Tutorial Guidelines
• One-on-one tutoring is not allowed
• An average of 5 students should be in a tutoring session
• If no students are in attendance, tutors may be paid up to 15
minutes wait time
• Tutors MAY NOT be paid for the entire scheduled tutorial
session without students present
• Tutorial documentation should be ordered by teacher
sign-in/out, student attendance, and lesson plans
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Tutorial Tools
• Individual Time Sheet
• Individual Time Sheet with Make-up Hours
• Student Attendance Sign-in
• School Sign-In Time Sheet
• Title I Tutorial Monitoring Checklist
• Track Hours for Tutorial Program
• Title I Tutorial Budget Planner (Due October and January)
Family Involvement
Fall Requirements
• Email to all Title I principals and contacts will be sent
mid-August
• Supporting documentation available on website
 Distribution of LEA/District Parent
Involvement Plan (PIP) Summary
 Parent Involvement Plan (PIP)
 School-Parent Compact
 Title I Annual Meeting
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Parent Trainings
• Hold at least three parent trainings a year
• Trainings are to cover core content areas:
reading, math, writing, and science
• Document with invitations, agendas, sign-in
sheets, and parent evaluations of trainings
• Resources in handbook and on website
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Staff Training
• Required to hold at least one staff training
before January
• Trainings to cover strategies for teachers to
improve relationships with parents
• Document with agenda, sign-in sheets, and
follow-up
• Resources on website
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Schoolwide Plan (SIP/SWP)
The School Improvement Plan serves as the
Schoolwide Plan that:
 Shows evidence of the Ten Components
 Documents how Title I funds will be used to meet
the needs of the lowest performing students
 Documents professional development for all staff
 Provides a needs assessment justifying strategies
to be implemented
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Components
Required of all Title I schools
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Changes to the Title I Budget
Title I will not approve reimbursement requests
associated with item(s), program(s), and/or
personnel that are not outlined in the SIP/SWP
(Sec 200.27 Development of a Schoolwide Program
Plan)
Steps to change budget:
• Plan ahead
• Seek approval from SAC and revise SIP/SWP
• Email your specialist when revisions have
been completed
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Rationale for Audit Compliance
• Mandated by law
• Creating a Schoolwide Plan with strategies that will
increase student achievement with an emphasis on the
lowest performing students
• Detailing the use of Title I funds in the Schoolwide Plan
so a monitor/auditor can track how federal funds are
used to increase student achievement
• Being able to successfully complete a monitor/auditor’s
interview by explaining compliance
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Example of State Compliance
Compliance Item KIA-6: The Local Educational Agency (LEA) shall
ensure that each participating school, in conjunction with the
parents of participating students, has jointly developed a schoolparent compact that: describes the school's responsibility to provide
high quality curriculum and instruction in a supportive and effective
learning environment; addresses the importance of ongoing
communication between teachers and parents; and describes the
ways in which each parent will be responsible for supporting their
child's learning.
Section 1118(d), P.L.107-110
School Level Review Question(s)
• Who was involved in the development of the compacts?
• When and how were these compacts developed and/or revised?
• How are the compacts used?
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Areas of Compliance
Organization of Documentation
Audit Assurance
Fiduciary
Family and
Community
Involvement
Highly
Qualified
Instructional
Support
Accountability
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Instructional Support
Highly Qualified (Y1)
• Lists of core content teachers not highly qualified
• List of instructional paraprofessionals with HQ
designation
• Memo regarding parent notification letter of 4-week
NHQ teacher
• Copy of letter for every teacher/sub not highly
qualified notifying parents of teacher/sub's status
(all languages)
• Paraprofessional schedules with names of
supervising teachers
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Instructional Support
Tutorial Services (Y2)
• All teacher sign-in sheets with hours, student
attendance sheets, and lesson plans
(Assemble tutorial documentation into packets per
pay period as follows: teacher sign-in sheets,
student attendance, and lesson plans)
• Tutorial Budget Planner (October and January)
Instructional Support
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On-Site PD (Y3)
• Collegial planning agenda, sign-in sheets, and
minutes and/or Focus Calendars
• Full day PD agendas, sign-ins, and notes
• All academic coaches’ schedules/documentation
of services
• Consultant Contracts
Off-Site PD (Y4)
• Conference agendas/programs, registrations, TDEs,
travel expenses, follow-up and Title I checklists
• District academic training/workshop TDEs, agendas
and follow-up regardless of funding (monthly samples)
Instructional Support
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Technical Assistance (Y5)
• Title I Faculty Presentation Verification
• Site Visit Logs
• Title I meeting agendas and Title I Chats with notes
• Title I Contact Handbook
Instructional Programs (Y6)
• List of students enrolled in special programs
(i.e. SAI, Migrant, ELL, Intensive Reading/Math, etc.)
• Field trip checklist and supporting documentation
• Parent training documentation for children transitioning
to kindergarten including agendas, flyers, brochures,
readiness handouts, and sign-in sheets
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Fiduciary
Allocation (G1)
• Copy of Title I budgets
• List of students eligible for FRPL
• Copy of SIP/SWP Final Budget
• Documentation of 6402 expenditures equaling 10%
or more of the school’s allocation
Property and Equipment (G2)
• Destiny inventory print-out of mobile devices
• Property Control Record
• List of all items purchased with Title I funds costing
over $350.00 and mobile devices such as Nooks and
Kindles (Items MUST be labeled Title I)
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Accountability
School Improvement (R1)
• All SAC agendas, sign-in sheets, and minutes
• Documentation of the development of the SIP/SWP,
including input from teachers, parents and community
(agendas, sign-in sheets, minutes)
• Written parent and community notification of the
availability and location of the SIP/SWP
• School Improvement Plan
• Title I SIP/SWP review of Ten Components
• SIP/SWP Mid-Year Review
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Accountability
Assessment (R2)
• Learning Team Meeting agendas, sign-in sheets and
minutes (minimum of 3 samples from various grade
levels and/or content areas for Sept, Nov, Jan, Mar)*
• RtI/SAI/other meeting agendas, sign-in sheets, and
minutes (samples for October and February) *
• SPAR, SPAR bulletin, parent notification letter and
verification of distribution of parent letter
• Student assessment samples
• Parent notification of FCAT scores
*NOTE: must address data, needs, students at risk of
reading failure and differentiated instructional strategies
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Family and Community Involvement
Parents’ Right to Know (B1)
• Parents’ Right to Know letters (all languages) and
memo regarding professional qualifications of teachers
• Annual Meeting documentation
• Documentation of parent input in the development of
School-Parent Compact (i.e. SAC minutes)
• School-Parent Compact (all languages)
• Copies of signed School-Parent Compacts (samples)
• Copies of parent-teacher conferences in which
School-Parent Compact was discussed
(3 - 5 samples, elementary only)
• Evidence of providing parents with requested
information regarding staff qualifications
Response Log
Schools must establish a procedure to track parent requests
regarding the professional qualifications of staff (teachers and
paraprofessionals). For example:
 Principal’s secretary may keep a notebook of teacher certificates
 Parent requesting information may make an appointment with
administration to look up the certification online
 School may require written request
Regardless of procedure, a log of requests/responses must be kept
and filed at the end of the school year in the monitoring/audit files.
Sample template is available on the Federal and State Programs’
website.
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Family and Community Involvement
Communication with Parents (B2)
• Evidence of parent communication such as
newsletters, student handbook, student
agenda, Edline, phone call-outs, etc. (include
all languages)
• Copies of academic parent-teacher
conferences (3 - 5 samples) in which student
data was discussed
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Family and Community Involvement
Parent Involvement Plan (PIP) (B3)
• Evidence of review of FY13 Title I Survey results
• LEA PIP Summary, memo/email and verification of
distribution
• Documentation of parent input of PIP (i.e. SAC minutes)
• Parent Involvement Plan Summary (all languages)
• Distribution of Parent Involvement Plan Summary
(all languages)
• Parent Involvement Staff PD documentation
• FY14 Title I survey results (LEA and school)
• Completed FY14 Title I surveys
• Volunteers (names and number of hours)
• Business Partners (agreements, letters, etc.)
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Family and Community Involvement
Parent Training Food Expenses (B4)
• Parent training agendas, sign-in sheets, evaluations,
and handouts that support student achievement in
Reading, Math, Writing, and Science
(i.e. FCAT/Curriculum Night, Literacy Night, Science
Fair, etc.)
• Parent training agendas, sign-in sheets, evaluations,
and handouts that build parent capacity (i.e. Parent
University, Roots and Wings, College Fair, AVID)
• Receipts for food expenditures with the Title I Food
Purchase Pre-Approval/Checklists
(Parent Trainings ONLY)
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Parent Trainings
To Support Student Achievement
or Build Parent Capacity?
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Role of Title I Contact and Team
• Serve as school contact for compliance
• Maintain Title I monitoring/audit files and submit the
Monthly Electronic Audit Assurance Checklist
• Monitor FY14 Title I Budgets in order to
expend non-salary funds by December 20, 2013
• Monitor Position Status Reports and SIP/SWP
• Coordinate participation at Title I meetings and
monitor family involvement activities
• Print your name and initial each monitoring/audit
folder, verifying that required documentation is filed
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Title I Audit
Checklist by
Folder Color
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Monthly Electronic Audit Assurance Checklist
Available on Website (due monthly)
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Procedures for Reimbursements
Title I funds may be used only for student achievement,
staff development, and to build parental capacity. These
funds must supplement the regular school program.
• How does this expenditure affect student achievement?
• How does this expenditure affect staff development?
• How does this expenditure increase parental capacity or
involvement?
• Is this something that would be purchased if the school was not
Title I?
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Timeline for Financial Requests
A quarterly submission of receipts is required. Any
expenses, including salary, submitted outside of the
quarter timeline may not be reimbursed.
• October 11, 2013 (Expenses from July – September)
• January 10, 2014 (Expenses from October – December)
• April 11, 2014 (Expenses from January – March)
• June 12, 2014 (Expenses from April – June)
The last day to submit reimbursement for June
salary expenses is tentatively July 8, 2014.
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Procedures for Reimbursements
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An approved Title I Budget Planning Tool completed in
Spring
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An approved School Improvement Plan/Schoolwide Plan
must be on file that documents expenses
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Submit a completed Title I Checklist for Quarterly
Reimbursements signed by principal
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Checklist for
Quarterly
Reimbursement
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Common Errors
(Title I Checklist for Quarterly Reimbursement)
 Missing Title I Checklist for Quarterly Reimbursement in
the packet
 Missing check or X marks in the appropriate boxes
 Missing principal’s signature
 Not dated
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Procedures for Reimbursements
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Submit Original Grant Reimbursement Request
Letter
• Charter school’s letterhead
• Address on the letter must match the address on file with the
District
• Separate letters and packets are needed for multiple funding
sources
• Signed in blue ink by a board member
• Copies are not acceptable
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Grant
Reimbursement
Request Letter
Common Errors
(Grant Reimbursement Request Letter)
 The letter is not original; no blue ink signature from a
board member
 The total amount of reimbursement in the letter does
not match with the total amount in the Summary Totals
spreadsheet
 The address on the letterhead does not match with the
address on file with the District
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Procedures for Reimbursements
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Submit completed Charter School Summary Reimbursement
Spreadsheet
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Submit documentation of expenditures by non-salary/salary
and by function
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Documentation of Expenditures
Non-salary expenses
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Copies of cancelled check(s) or bank statement(s)
Copies of credit card statement(s), if applicable
Evidence that credit card has been paid (cancelled check)
Itemized receipts/paid invoices
5150 Classroom expenses (classroom libraries, software, etc.)
6152 Family Involvement expenses (training materials, postage, etc.)
6402 Professional Development expenses (PD books, training supplies, etc.)
Title I does not reimburse taxes except for out-of-state travel.
Common Errors
(Non-salary expenses)
 Non-salary items are not documented in the SIP/SWP
 Non-salary items are not for classroom, PD and parent
involvement’s use
 Missing cancelled checks
 Missing evidence that credit card was paid
 Taxes included
 No checklist for travel and food reimbursement request
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Documentation of Expenditures
Salary expenses
• Detailed payroll reports
• Federal Grants Charter School Staff Directory
• Tutorial documentation, if applicable
5150 Classroom expenses (tutoring, teacher salary, etc.)
6152 Family Involvement expenses (parent liaison salary, PRT, etc.)
6402 Professional Development expenses (stipends, trainers, subs, etc.)
Charter School Staff Directory must be included with each packet.
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Stipends vs. Part-time In-system (PRT)
• Stipends are used to pay teachers to attend a workshop
or training. The only function for stipends is 6402. The
rate is usually $20.44 for teachers.
• PRT is used to pay tutors (5150), trainers (6402), temp
parent liaisons (6152), etc.
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Common Errors
(Salary expenses)
 Staff funded by Title I is not documented in the SIP/SWP
 Missing payroll report and/or conflicting amounts
 Missing FY14 Federal Grants Charter School Staff
Directory
 No tutorial documentation (teacher sign–in/out, student
sign-in and teacher lesson plan)
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Documentation of Expenditures
Consultant expenses
• Board approved consultant contract
• Copies of invoices
• Copies of cancelled check(s) or bank statement(s)
• Documentation of services – agenda, sign-in sheets, etc.
• 6402 Professional Development non-salary expenses
It is recommended that consultant contracts be all inclusive.
If not, follow the District travel reimbursement procedures.
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Common Errors
(Consultant expenses)
 Consultant is not documented in the SIP/SWP
 Missing signatures and date in consultant contract
 Missing invoices and cancelled checks
 Missing documentation of services such as agenda,
sign-in sheet, and evaluation, if appropriate
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Documentation of Expenditures
Travel expenses
• Completed Title I Travel Audit Compliance Checklist
• PBSD 0096 summarizing all expenditures for travel
• Per diem is allowed for meals based upon school Charter and may not
exceed Federal guidelines
• No meal receipts are required
• Mileage is reimbursed based upon school Charter and may not exceed
Federal guidelines
• Copy of the conference registration form and receipt
• Receipt for air travel and baggage fees
• Receipt for hotel showing a zero balance
• Parking or toll receipts, if applicable
• Agenda/program of the activities
Title I does not reimburse taxes except for out-of-state travel.
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Common Errors
(Travel expenses)
 Travel and conferences are not documented in the SIP/SWP
 Missing or incomplete Title I Travel Audit Compliance Checklist
 Missing PBSD 0096 summarizing all expenditures for travel
 Missing receipt for hotel showing a zero balance
 Missing agenda/program of the activities
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Documentation of Expenditures
Food expenses
• Allowed for parent trainings only
• Title I Food Purchase Pre-Approval/Checklist
• Agenda
• Sign-in sheets
• Itemized receipts
• Parent evaluation of training
• Cancelled check(s) or bank statement(s)
Title I does not reimburse for gratuity.
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Title I Food Purchase
Pre-Approval/ Checklist
Common Errors
(Food expenses)
 Training and food expenses are not documented in the
SIP/SWP
 Missing FY13 Title I Food Purchase Checklist
 Excessive amount of food purchase
 Missing agenda, parent sign-in sheets, and evaluation of
training
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Procedures for Reimbursements
Order packet as follows:
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2.
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4.
Title I Checklist for Quarterly Reimbursement
Original Grant Reimbursement Request Letter
Final SIP budget
Charter School Summary Reimbursement Spreadsheets
(Summary Totals)
5. Non-salary documentation for 5150, 6152, 6402
6. Federal Grants Charter School Staff Directory
7. Salary documentation for 5150, 6152, 6402
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District Reimbursement Procedures
• Grant Reimbursement Request Packet is date stamped when received
• Documentation reviewed and verified by Title I specialist
• Title I budget manager reviews packet and forwards to director for final
approval/signature
• If corrections are required, the Title I specialist contacts school
• If no corrections are needed, the reimbursement will be processed for
payment
Expect payment within 10 business days upon final approval of
reimbursement packet.
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Complete handbook
available on website
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Title I Chats
• First Wednesday of the month, starting in
September
• Agenda and times will be emailed
• First chat will discuss SIP/SWP and Fall
Requirements
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First Task
• Present to staff the
responsibilities of Title I
schools
• Presentation available
on website
• Complete verification
attaching agenda and
sign-in sheets for filing
in yellow 5
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Conclusion
• Questions
• Evaluation
• Pick-up monitoring/audit box
• Thank you for your attention
The Department of Federal and State Programs
wishes you a successful school year!
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