Updated ODE Title IA Guidance May 15, 2009
1. What are the Title IA ARRA allocations and the preliminary Title IA regular allocations?
The information in the following table gives the District allocations for Title IA ARRA funds and the Preliminary Title IA regular funds. Please use this information for planning purposes only. Actual allocations will be posted through the CIP Budget Narrative. See question 2 for timelines. See attachment link at bottom of the page or go to the following link:
Table
2. How and when will LEAs access the money?
Districts will fill out Title IA ARRA pages in the 2009-10 CIP Budget Narrative which will open in Mid-May 2009. After the Title IA ARRA pages are approved, ODE will release 50% of the ARRA funds to be accessed through EGMS. The other 50% of the ARRA funds will become available during October 2009. In the CIP Budget Narrative, the District will describe how they will spend 100% of their Title IA ARRA funds. District should not plan on dividing the ARRA funds into two years of spending (Districts should not plan on carryover). See question 4 for information on carryover and waivers.
Absent a waiver, 85% of both ARRA and 2009-10 Title IA funds must be obligated by each LEA by September 30, 2010, and the remaining funds must be obligated by September 30, 2011.
The regular Title IA funds will be distributed through the CIP Budget Narrative process which will be open in August 2009. 09-10 CIP Budget Narratives for regular NCLB funds will be due September 15, 2009.
3. When is an obligation made?
According to EDGAR Sec 75.707
The following table shows when a grantee makes obligations for various kinds of property and services.
If the obligation is for--
|
The obligation is made-- |
| (a) Acquisition of real or personal property |
On the date the grantee makes a binding written commitment to acquire the property. |
| (b) Personal services by an employee of the grantee |
When the services are performed. |
| (c) Personnal services by a contractor who is not an employee of the grantee. |
On the date on which the
grantee makes a binding written commitment to obtain the services. |
| d) Performance of work other than personal services. |
On the date on which the grantee makes a binding written commitment to obtain the work. |
| e) Public utility services |
When the grantee receives
the services. |
| f) Travel............................ |
When the travel is taken. |
| g) Rental of real or personal property |
When the grantee uses the property. |
| h) A preagreement cost that was properly approved by the Secretary under the cost principles identified in 34 CFR 74.171 or 80.22. |
|
4. May a district carryover Title IA ARRA funds that remain unobligated after September 30, 2010?
Yes, a district can carryover any unobligated Title IA ARRA funds to the subsequent fiscal year (ending September 2011). All funds will need to be obligated by September 30, 2011 and claimed through EGMS by November 15, 2011. The district should not plan for carryover. ODE can waiver the carryover limitation if the request is reasonable and necessary or a supplemental appropriation becomes available. Title IA ARRA funds are a supplemental appropriation under Title IA. Districts will apply for carryover of 2009-10 Title IA ARRA funds in the 2010-11 CIP Budget Narrative process. ODE will review the carryover request and will grant waivers that are reasonable and necessary.
5. How should a district plan for Title IA ARRA and Title IA regular funds?
When planning for Title IA, the district needs to look at the whole Title IA allocation, which includes both Title IA ARRA and regular Title IA. The set-asides are calculated off the combined allocations of Title IA ARRA and regular Title IA. When planning on targeting schools, the district will need to think of the whole allocation and rank and serve the schools according to normal Title IA rules. It will work best if districts allocate Title IA ARRA and Title IA regular funds to all the schools being served. Remember the targeting page will require districts to allocate to all schools over 75% poverty and target according to rank order. Remember that Title IA ARRA and Title IA regular funds will be described on two different CIP Budget Narrative pages.
6. What are some recommended uses for Title IA recovery funds?
- Using reading or mathematics coaches to provide professional development to teachers in Title I schools;
- Creating a modified school schedule to allow for collaboration and professional development among the instructional staff;
- Establish or expand fiscally sustainable extended learning opportunities for Title I-schools, including activities provided before school, after school, during the summer, or over an extended school year;
- Continue to focus on K-3 literacy in schoolwide programs;
- Expand the number of schools funded under Title I with particular focus on middle schools and high schools (These schools will need to be TAS);
7. What needs to happen if funding a new school?
If funding a new Title IA school, the school will begin as a Targeted Assistance School (TAS). The district will need to ensure that a compliant TAS plan will be written and in place when the school begins spending any Title IA funds in the school. For information on how to write a compliant TAS Plan and a TAS Plan Template see ODE website at the following link: http://www.ode.state.or.us/search/page/?id=1939
8. If our district is under the Title IIA Accountability 2141(c) can we use the Title IA ARRA funds to fund additional paraprofessionals?
No, if your district is under the 2141(c) Accountability in Title IIA you may not pay for any additional paraprofessionals with the Title IA ARRA funds or your regular Title IA funds. If your district has Title IA paraprofessionals who were only working part time, funding can be used to increase those paraprofessional’s hours.
9. Do districts need to provide equitable services for private school students with Title IA ARRA funds?
Yes, the district must consult with private schools concerning the Title IA ARRA funds and provide the equitable services that the private school and the district agree upon.
10. Must a district reserve Title IA ARRA funds for homeless children who do not attend Title IA schools?
Yes, the district must reserve funds to ensure that services are comparable to those provided to students participating in Title IA schools for students who do not attend Title IA schools. The services may include providing educationally related support services to children in shelters and other locations where children may live. The district will need to set-aside money from both Title IA ARRA and Title IA. If the district needs more information on calculating set-asides for homeless students see following link:
11. Must a school receiving Title IA ARRA funds meet the comparability requirements?
Yes. For more information on comparability go to the following document:
LINK
12. Are the State Fiscal Stabilization Funds (SFSF) included in the districts determination of comparability.
No. To meet comparability requirements, the district must use State and local funds in each Title IA school to provide services that are at least as comparable to the services it provides to non-Title IA schools. Because SFSF funds are Federal funds, they are not included in comparability. The district needs to be aware of which staff they are funding with SFSF funds to ensure that the comparability requirements are met.
13. Must a district maintain fiscal effort to receive Title IA funds including ARRA funds?
Yes. ODE calculates Maintenance of Effort for districts. For 09-10 school year, ODE will be using expenditures from 06-07 school year and 07-08 school year. If the district’s first decrease in expenditures occurred in 08-09 school year, then MOE will not be affected in 09-10 school year. However, absent a waiver, it could affect the district’s ability to maintain effort for 10-11 school year. The USDE may waive the MOE requirement, if the USDE determines that a waiver would be equitable due to precipitous and unforeseen decline in financial resources of the State.
14. Do the supplement not supplant requirements of Title IA apply to Title IA ARRA funds?
Yes. Generally, a district may not use Title IA funds for activities that it would have conducted in absence of Title IA funds. Several situations give rise to a presumption of supplanting: 1) the activity is required by local, state or other federal law; 2) the district conducted the activity in the prior year with non-federal funds; or 3) the district uses non-Federal funds to provide the same activity for non-Title IA students or in non-Title IA schools that it provides with Title IA funds for Title IA students in Title IA schools.
15. What qualities would a district look for when selecting an instructional coach?
When selecting a staff member to become an instructional coach, these are the qualities of a good instructional coach:
1) Strong interpersonal skills;
2) Exemplary teaching practice;
3) Leadership capacity;
4) Credibility among teachers and administrators;
5) Predisposition as a learner; and
6) Desired experience and knowledge of: professional teaching standards, coaching or other collaborative models and working with diverse populations.
16 What guidance is ODE waiting to receive from USDE?
• Specific reporting and accountability requirements
• Waivers on district set-asides including school improvement (SES and Choice) and district improvement
Title I, Part A Recovery Funds for Grants to Local Educational Agencies
