2012 Title I, Part A/LAP Spring Workshop

Office of Superintendent of Public Instruction

Allowable Costs

OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments Codified in 2 CFR Section 225

2

Purpose

• Provides principles and standards for determining costs for federal awards• Grants

• Cost reimbursement contracts

• Other agreements with state and local governments and federally recognized Indian tribal governments

3

Attachment A

• Definitions

• Basic Guidelines• Factors affecting allowability

• Reasonable costs

• Allocable costs

• Applicable credits

• Classification of Costs

• Direct and Indirect Costs

4

Basic Guidelines—Allowability of Costs

• To be allowable a cost must-

• Be necessary and reasonable for proper and efficient performance and administration of federal awards

• Be allocable to federal awards

• Be authorized and not prohibited

• Conform to any limitations in the circular

• Be consistent and applied consistently (capital assets, direct vs. indirect cost, etc.)

• Allowable if-

• Follows generally accepted accounting principles

• Not be used to meet cost sharing or matching of another federal award

• Is net of all applicable credits

• Is adequately documented

5

Basic Guidelines—Reasonable Costs

• Prudent Person Test• Ordinary and necessary for operation or performance of

federal award

• Follows sound business practices; arms length bargaining; follows laws/regulations federal terms

• Market price for comparable goods and services

• Administered with prudence

• No significant deviations; consistent with non-federal

6

Basic Guidelines—Allocable Costs

• Benefits the program

• Indirect costs

7

Specific Items of Cost

Attachment B 8

Accounting

• Allowable• Cost to establish and maintain accounting and other

information system

9

Advertising

• Allowable• Recruitment of personnel

• Procurement of goods and services

• Disposal of surplus materials (unless reimbursed at standard rate)

• For specific purposes necessary to requirements of federal award

10

Public Relations

• Allowable

• Specifically required by federal award (only as direct cost)

• Communicate specific activities or accomplishments from performance of federal award to public or press (direct cost)

• Necessary to liaison with news media-limited to keeping public informed on federal notices, contracts, grant awards, financial matters

• Unallowable

• All other advertising and public relations

• Costs of conventions, meetings or other events

• Costs of displays, demonstrations, exhibits

• Costs of meeting rooms, hospitality suites, etc.

• Salaries and wages of employees engaged in setting up and displaying exhibits, making demonstrations, providing briefs

• Promotional items (models, gifts, souvenirs)

• Costs of advertising and PR designed to solely promote governmental unit

11

Advisory Councils

• Allowable • As direct cost if authorized by federal awarding agency

• As indirect cost where allocable to federal awards

12

Alcoholic Beverages

• Unallowable!!!

13

Audit Services

• Allowable

• If performed in accordance with Single Audit Act (and OMB Circular A-133)

• Percentage of costs charged to federal awards for single audit may not exceed percentage derived by dividing federal funds expended by total funds expended by recipient during fiscal year• Exceed only if appropriate documentation of higher costs

• Other audit costs must be preapproved or part of indirect cost allocation plan or rate

14

Electronic Data Processing

• Allowable• But see Equipment

15

Bad Debts

• Unallowable• Unless specifically provided for in federal program award

regulations

16

Bonding Costs

• Allowable• Costs of bonding employees and officials if in accordance

with sound business practice

17

Budgeting

• Allowable• Costs for development, preparation, presentation and

execution of the budget

18

Communications

• Allowable• Costs of • telephone

• mail

• messenger, etc.

19

Compensation for Personal Services

• Allowable • Comply with time and effort requirements and

documentation

• Are reasonable for services rendered and conform to established policy of district consistently applied to both federal and non-federal employees

• Hired in accordance with district rules and meets merit system or other federal requirements

20

Contingencies

• Unallowable• Contributions to contingency reserve for events which

cannot be predicted

• Allowable• Self-insurance reserve

• Pension plan reserves

• Post retirement health and other benefits computed with acceptable actuarial cost method

21

Contributions and Donations

• Unallowable• All contributions and donations, including cash, property,

and services by governmental units to others, regardless of recipient

22

Defense and Prosecution of Criminal and Civil Proceedings and Claims

Unallowable

Costs incurred in defense of any civil or criminal fraudCosts incurred by a contractor in connection with any

criminal, civil or administrative proceedings commenced by the United States or a state

Legal expenses for prosecution of claims against the federal government

Allowable

Legal expenses required to administer federal program

23

Depreciation and Use Allowances

• Allowable• Use one or the other, not both for asset class

• Follow district policy and GAAP

• Unallowable• Land

• Buildings or equipment purchased or donated by federal government or used as part of match

See Circular for additional guidance

24

Disbursing Service

• Allowable• Cost of disbursing funds

25

Employee Morale, Health and Welfare Costs

• Allowable• Costs of health, first-aid clinics and/or infirmaries,

recreational facilities, employee counseling services, employee information publications, related expenses consistent with district policy

• Income from any of these activities will be offset against expenses

26

Entertainment

• Unallowable• Costs of entertainment, including amusement, diversion and

social activities and any costs directly associated with such costs• Examples: tickets to shows or sports events, meals, lodging,

rentals, transportation, gratuities

27

Equipment and Capital Expenditures

• Allowable• Through depreciation or use allowances, OR

• Charged directly

• Includes equipment, replacement equipment, other capital assets and improvements which materially increase the value or useful life of equipment• Federal agencies may waive or delegate approval

28

Equipment and Capital Expenditures

• Equipment with acquisition cost of less then $5000 are considered supplies • allowable as direct costs

• Change in capitalization level• May continue to follow use or depreciation or amortize

amount to be written off over period negotiated with cognizant agency (OSPI)

• Trade in for replacement equipment may be used to offset cost of new

29

Fines and Penalties

• Unallowable • Unless incurred as a result of compliance with specific

provisions of federal award or written instructions by awarding agency authorizing (rare)

30

Fundraising and Investment Management Costs

UnallowableCosts of organized fund raising, including financial

campaigns, solicitation of gifts and bequests, and similar expenses incurred to raise capital or obtain contributions

Costs of investment counsel and staff to enhance income from investments

AllowableCosts associated with pension, self-insurance or

other funds which include federal participation

31

Gains and Losses on Disposition of Depreciable Capital Assets

• Allowable in year they occur as credits or charges

• Limited to difference between amount realized on property and the undepreciated basis

• Unallowable

• Amount depreciated, amortized, or use allowance

• When property given in exchange as part of the price of similar item

• Losses from failure to maintain insurance

• Substantial relocation of federal awards from a facility where federal participation to another facility prior to expiration of useful life requires federal approval

• Does not usually apply to United States Department of Education (ED) grants

32

General Government Expenses

• Unallowable• Salaries and expenses of chief executives (superintendent's

office, principal’s office)

• Salaries and expenses of school boards whether incurred for purposes of legislation or executive direction

• Cost of prosecutorial activities unless authorized by program regulations (rare)

33

Idle Facilities and Idle Capacity

• Unallowable unless• Necessary to meet fluctuations in workload

• Were necessary when acquired (limit one year)

• Does not usually apply to ED grants

34

Insurance and Indemnification

AllowableCosts of insurance required, approved or

maintained pursuant to the federal awardCosts of other insurance (allocable to program)

Follow district policy and sound business practiceCosts due to losses not covered due to nominal deductible

insurance coverage if follow sound management practiceMinor losses not covered by insurance which occur in

ordinary course of operations

35

Insurance and Indemnification

AllowableContributions to reserve for self-insurance

programs (including workers compensation, unemployment compensation, and severance pay) subject to:Type of coverage, extent of coverage and rates would have

been allowed had insurance been purchased to cover the risksEarnings and investment income on reserves creditedContributions to reserves based on sound actuarial principles

and updated at district bienniallyOther (see section 25)

36

Insurance and Indemnification

• Allowable (conditions)• Actual claims paid to or on behalf of former or current

employees must be allowable in the year of payment• Consistent policy followed

• Allocated as general administrative expense to all activities of district

• Insurance refunds must be credit against costs

• Only to extent provided in federal award

37

Insurance and Indemnification

UnallowableCosts of insurance or contributions to a reserve

covering risk of loss of or damage to federal government property unless agency has specifically required or approved

Actual losses which could have been covered by permissible insurance

Cost of commercial insurance that protects against costs of contractor for contractor’s defects in materials or workmanship

38

Interest

• Unallowable

• Costs incurred for interest on borrowed capital or the use of district’s own funds

• Allowable

• Financing costs of allowable costs of building acquisition, construction, reconstruction or remodeling if• Financing from bona fide third party external to district• Assets used in support of federal awards• Earnings on debt service reserve and interest offset

39

Lobbying

• Unallowable!!!

40

Maintenance, Operations and Repairs

• Allowable, if• Not prohibited by law

• Keeps property in efficient operating condition

• Does not add to value or prolong life of property

• Are not included in rental or charges for space

• Costs which add to permanent value or prolong life should be treated as capital expenditures

41

Materials and Supplies

• Allowable• Charge actual price after deducting discounts, rebates and

allowances

• Stockroom withdrawals at cost

• Incoming transportation charges are part of materials and supplies costs

42

Memberships, Subscriptions and Professional Activities

AllowableDistricts memberships in business, technical, and

professional organizationsDistrict’s subscriptions to business, technical and

professional periodicalsMeetings and conferences where primary purpose is

dissemination of technical information (includes meals, transportation, rental of meeting facilities and incidental costs)

Membership in civic and community social organizations with approval of federal agency

43

Memberships, Subscriptions and Professional Activities

• Unallowable• Membership in organizations substantially engaged in

lobbying

44

Motor Pools

• Allowable• Costs of service organization which provides automobiles to

district at a mileage or fixed rates and/or provides vehicle maintenance, inspection, and repair services

45

Pre-Award Costs

• Unallowable, unless• Necessary to comply with the proposed delivery schedule or

period of performance

• Only to extent they would have been allowable if incurred after award date

• Only with written approval of awarding agency

46

Professional Service Costs

Allowable

Professional and consultant services, including retainer fees, by persons or organizations that are members of a particular profession or possess a special skill, ifReasonable Not contingent upon recovery of costs from the federal government

Unallowable

Defense and prosecution of criminal and civil proceedings and claims

47

Proposal Costs

• Allowable• Costs to prepare proposals for potential federal awards• Treat as indirect costs unless prior approval of federal

awarding agency

48

Publication and Printing Costs

• Allowable• Must be reasonable and allocable

49

Rearrangements and Alterations

• Allowable• Ordinary and normal rearrangement and alteration of

facilities

• Special arrangements and alterations specified in the federal award or with prior approval

50

Reconversion Costs

• Allowable• Restoration or rehabilitation of district’s facilities to

approximately same condition immediately prior to federal awards, less costs related to normal wear and tear

51

Rental Costs

• Allowable• Must be reasonable

• Sale and lease back arrangements limited to what it would have cost if district owned the property

• Less than arm’s length transactions limited to amount if district had title to property

• Rental costs under leases must be treated as capital leases under GAAP (follow FASB Stmt 13)

• See interest section

52

Taxes

• Allowable• If legally required

• Gasoline taxes, motor vehicle fees other taxes which are user fees for benefits to federal program

• Unallowable• Self-assessed taxes and/or policies that disproportionately

affect federal programs

• If deemed inappropriate by federal agency

53

Training

• Allowable• Reasonable for professional development of employees

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Travel Costs

• Allowable• Transportation, lodging, subsistence, and related items for

employees on official business

• May be charged based on actual cost, per diem or combination in accordance with district policy

• Travel costs for general government employees are allowable when specifically related to federal awards

• All charges must be reasonable and not exceed normally allowed costs

55

Travel Costs

• Unallowable• Costs in excess of normal costs permitted by district policy

(use federal guidance if no district policy)

• Commercial airfare must be coach rate or equivalent

• Non-commercial air travel is generally not allowable

56

Underrecovery of Costs under Federal Agreements

• Unallowable• Excess costs over federal contribution of one award are not

permitted to be charged to other awards

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Time and Effort Reporting

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Where is the Requirement?

• Time and effort reporting is required under the Federal Office of Management and Budget’s Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments

• Attachment B, Selected Items of Cost, Item 11, Compensation for personnel services

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When is Time and Effort Required?

• Time and effort reporting is required when any part of an individual’s salary is charged to a federal program

• Charge may be “direct” or “indirect”

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What type of reporting is needed?

• Single cost objective →Semi annual certification

• Multiple cost objectives →Monthly time reports or Personnel Activity Reports (PARs)

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What is a cost objective?

Work activities allowable under the terms and conditions of one or more

funding sources

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What are some examples of a single cost objective?

• 100% charged to a single federal program activity

• Federal Special Education and State Special Education

• Schoolwide program

• Multiple activities in a single federal program

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What are some examples of multiple cost objectives?

• Salary charged to more than one set aside activity in a single federal program (e.g., parent involvement, professional development)

• Salary charged partially to federal program and partially to state and/or local sources

• Salary charged partially to sources combined into a schoolwide program and partially to those not included

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What is a semi annual certification?

• Statement individual(s) worked solely on activities related to single cost objective

• Completed at least every six months

• Signed by employee or supervisor with first-hand knowledge of work performed

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What is a monthly time report?(PAR)

• Must account for total contracted compensated hours

• Must be prepared at least monthly

• Must be signed by employee

• May also be signed by supervisor

• Must reflect actual work performed (not budget)

• Must agree with supporting documentation (e.g., calendar)

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When are adjustments to actual made?

• If payroll is initially based on budgeted or estimated time, payroll and time and effort reports must be reconciled at district quarterly

• If the difference is 10% or more Payroll records must be adjusted to match actual time worked Following quarter’s payroll estimates must be adjusted

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What time and effort is reported?

• Report time actually worked in a specific activity not time budgeted for that activity

• Budgets are reconciled to actual at least quarterly.

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Who should sign the reports?

• Monthly reports (PARs) must be signed by the employee

• Semi annual certifications may be signed by either employee or supervisor having first-hand knowledge of work performed

• For internal control purposes, districts may require both the employee and supervisor to sign

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What type of supporting documentation is needed?

• Documentation is VERY important.

• Examples include, but are not limited to:• Class schedules

• Number of students

• Number of minutes

• Remember • DOCUMENT! DOCUMENT! DOCUMENT!

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Supplemental Contracts, Stipends, Extra Hours

• Primary contract and additional contracts may be considered separately

• Based upon whether or not charged to federal program• Time and effort may be required for primary contract but

not supplemental (or vice versa)

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Administrators

• Superintendent, assistant superintendent, principal, assistant principal usually not allowable charge to federal program• Generally presumed to be a supplant issue

• Requires good documentation to rebut supplant presumption

• Other administrators (e.g., federal program directors) may be charged to federal program(s) based on time and effort• Supporting documentation must be maintained

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Schoolwide Programs

• Schoolwide plan must specify programs to be included (not all programs may be included)

• A schoolwide program is a single cost objective• If employee works 100% on programs combined → Semi

annual certification

• If employee works partially on programs combined and partly on those not combined, → Monthly time report (PAR)

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Schoolwide Program

Title I, Part A Schoolwide ProgramTitle I, Part A (Disadvantaged)Title II, Part A (Professional Development)BEA (Basic Education)Local Funding, Levy, District, etc.Title III, (Immigrant)

Most ED Programs

Cannot IncludeTransitional Bilingual

State Special EducationState Highly CapableIOther State Programs which are

limited only to certain students (not available to allstudents in the building)

RestrictedMigrant

Indian EducationFederal Special EducationLAP

Carl Perkins

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What is a substitute system?

• An alternative method for determining and reporting time and effort based on statistical sampling of work performed

• Must be approved by OSPI prior to use• Jennifer Carrougher (Jennifer.Carrougher@k12.wa.us) is

responsible for approval (as well as any revisions)

• Should be periodically reviewed to determine if still appropriate

• Any revision of a previously approved substitute system must be submitted to OPSI for approval prior to use

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For Additional Information

• OSPI Bulletin 051-11 (Time and Effort Reporting)• Examples• Sample forms

• OSPI Bulletin 050-11 (Combining Funds in Schoolwide Programs)

OMB Circular A-87, Cost Principles for State, Local, and Tribal Governments (2 CFR Section 225)

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COMBINING FUNDS IN SCHOOLWIDE PROGRAMSSchoolwide-Systematic Reform Based Model

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• The schoolwide program model is a comprehensive reform strategy designed to upgrade the entire reading and mathematics program for the Title I, Part A building

• The primary goal of the schoolwide program is to ensure that all students, particularly those who are low-achieving, demonstrate proficient and advanced levels in the state academic achievement standards.

• To create schoolwide reform, the primary focus of the schoolwide program is to design and implement a well defined “schoolwide-system model”, of tiered/leveled additional interventions

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Step 1

• Readiness to Benefit: Schoolwide-Systematic Reform Based Model• Clarify the vision of reform/A clear focus

• Discuss with staff shared vision

• Analyze ten-components of schoolwide plan

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• Develop a comprehensive needs assessment for the entire building:• Modify schoolwide needs based on annual evaluation and

review of program

• Determine where the building is now and where it wants to be when its vision is realized

• Collect, sort, analyze data • Reading, mathematics, language arts, and science

• Set priorities and concerns

• Identify strengths and weaknesses

80Step 2

Step 3

• Build Schoolwide comprehensive component plan to identify reform strategies:

• Create a tiered/leveled model of additional intervention

• Determine and identify proven researched-based strategies, designed to facilitate reform and improvement

• Accept a collective responsibility for reaching and teaching all students

• Tie all components to needs assessment (including which programs to be combined in the schoolwide program)

• Set measurable goals-define action plan for reform

• Includes list of programs combined, amount combined and how their intent and purpose of each combined program are met in the schoolwide plan and program (this will be used to determine appropriate time and effort

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Step 4

• Implement the plan• Ongoing review of action plans

• Review effectiveness of systematic-intervention model

• Keep documentation of implementation

• Modify and make adjustments, as needed, during the year

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Consolidating Funds

• Schoolwide programs may combine federal, state and local funds of programs consolidated

• Schools operating schoolwide programs are not required to maintain separate accounting records for combined programs if• Combined programs are identified in the plan

• School maintains records documenting intents and purposes of programs combined are met

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Purpose/Benefit of Consolidation

• To help schoolwide school effectively design and implement a comprehensive plan to upgrade the entire educational program in the school based on needs identified in the needs assessment

• When combining BEA funds, instructional staff become schoolwide staff• Instructional staff are part of an additional tiered-model of

interventions

• Use of all available resources to meet needs

• Flexibility in use of resources• Not required to account separately for funds used in program

• Not required to meet most statutory and regulatory requirements of specific program included in consolidation

84

Consolidation of Funds

• Treat funds as a single “pool” of funds• Lose individual identity

• Use funds to support any activity of the schoolwide program

• But, must meet intent and purpose of each program

85

Supplement not Supplant

• Met in schoolwide program by documenting each school operating a schoolwide program receives all the state and local funds it would otherwise receive to operate its educational program in the absence of Title I, Part A or other federal education funds • This includes funds required for Special Education and ELL

students

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Use correct order

1. Determine which funds will be combined

2. Address intents and purposes in the plan

3. Meet and document intents and purposes

4. Determine how to charge

87

Fiscal flexibility

• Examples of ways to charge consolidated funds• Charge proportionately based on revenue

• Charge sequentially

• Charge based on activity (not use flexibility)

88

Federal No Child Left Behind (NCLB) Waiver

and Washington StateWhat does this mean for Washington State SES?

89

1. College- and Career-Ready Expectations for All Students

2. State-Developed Differentiated Recognition, Accountability, and Support

3. Supporting Effective Instruction and Leadership

4. Reducing Duplication and Unnecessary Burden

Principles For Improving Student Achievement and Increasing the Quality of Instruction

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1. The requirements in the Elementary and Secondary Education Act (ESEA) Section 1111(b)(2)(E)-(H) that prescribe how a State Education Agency (SEA) must establish annual measurable objectives (AMOs) for determining adequate yearly progress (AYP) to ensure that all students meet or exceed the state’s proficient level of academic achievement on the state’s assessments in reading/language arts and mathematics no later than the end of the 2013–2014 school year

The SEA requests this waiver to develop new ambitious but achievable AMOs in reading/language arts and mathematics in order to provide meaningful goals that are used to guide support and improvement efforts for the state, districts, schools, and student subgroups

91

ESEA Flexibility Request-Waiver 1

2. The requirements in the ESEA Section 1116(b) for a district to identify for improvement, corrective action, or restructuring, as appropriate, a Title I, Part A school that fails, for two consecutive years or more, to make AYP, and for a school so identified and its district to take certain improvement actions

The SEA requests this waiver so that a district and its Title I, Part A schools need not comply with these requirements

ESEA Flexibility Request-Waiver 2 92

3. The requirements in ESEA Section 1116(c) for an SEA to identify for improvement or corrective action, as appropriate, a district that, for two consecutive years or more, fails to make AYP, and for a district so identified and its SEA to take certain improvement actions

The SEA requests this waiver so that it need not comply with these requirements with respect to its districts

ESEA Flexibility Request-Waiver 3 9

3

4. The requirements in ESEA sections 6213(b) and 6224(e) that limit participation in, and use of funds under the Small, Rural School Achievement (SRSA) and Rural and Low-Income School (RLIS) programs based on whether a district has made AYP and is complying with the requirements in ESEA Section 1116

The SEA requests this waiver so that a district that receives SRSA or RLIS funds may use those funds for any authorized purpose regardless of whether the district makes AYP

ESEA Flexibility Request-Waiver 4 94

Implementation of School Improvement Requirements

• Flexibility from requirement for school districts to identify or take improvement actions for schools identified for improvement, corrective action, or restructuring

• Eliminates Public School Choice (PSC) as a mandate• Eliminates Supplemental Educational Services (SES) as a

mandate• Eliminates the 20 percent district Title I, Part A set aside to fund

PSC and SES• Eliminates the 10 percent set aside for professional development

for schools

Flexibility to Improve Student Achievement and Increase the Quality of Instruction 95

• Priority schools: Identify lowest-performing schools and implement interventions aligned with the turnaround principles

• Focus schools: Identify and implement interventions in schools with the largest achievement gaps or low graduation rates among subgroups

Priority and Focus Schools 96

• What is a Priority school?• At least the lowest five percent of Title I, Part A schools based on “all

students” performance on state assessments • Title I, Part A- participating and Title I, Part A- eligible high schools

with < 60 percent graduation rate

• We propose to use the Washington Achievement Index to identify lowest performing schools (rather than just reading and math)

• Districts with priority schools ensure the schools implement turnaround principles using a set-aside of up to 20 percent of district Title I, Part A funds

Priority Schools 97

• What is a focus school?At least 10 percent of Title I, Part A schools with the lowest subgroup achievement and biggest gaps among subgroups; may also include non-Title I, Part A schools (middle or high performing, non low income schools with large achievement gaps)

• Proposing: update the Washington Accountability Index to include each subgroup separately

• Districts with focus schools must implement a plan to improve the performance of subgroups who are furthest behind using a set-aside of up to 20 percent of district Title I, Part A funds

Focus Schools 98

5. The requirement in ESEA Section 1114(a)(1) that a school have a poverty percentage of 40 percent or more in order to operate a schoolwide program

The SEA requests this waiver so that a district may implement interventions consistent with the turnaround principles or interventions that are based on the needs of the students in the school and designed to enhance the entire educational program in a school in any of its priority and focus schools that meet the definitions of “priority schools” and “focus schools,” respectively, set forth in the document titled ESEA Flexibility, as appropriate, even if those schools do not have a poverty percentage of 40 percent or more

ESEA Flexibility Request-Waiver 5 99

6. The requirement in ESEA Section 1003(a) for an SEA to distribute funds reserved under that section only to districts with schools identified for improvement, corrective action, or restructuring

The SEA requests this waiver so that it may allocate Section 1003(a) funds to its districts in order to serve any of the state’s priority and focus schools that meet the definitions of “priority schools” and “focus schools,” respectively, set forth in the document titled ESEA Flexibility

ESEA Flexibility Request-Waiver 6 100

ESEA Flexibility Request-Waiver 7

7. The provision in ESEA Section 1117(c)(2)(A) that authorizes an SEA to reserve Title I, Part A funds to reward a Title I, Part A school that (1) significantly closed the achievement gap between

subgroups in the school; or (2) has exceeded AYP for two or more consecutive years

The SEA requests this waiver so that it may use funds reserved under ESEA Section 1117(c)(2)(A) for any of the state’s reward schools that meet the definition of “reward schools” set forth in the document titled ESEA Flexibility.

101

8. The requirements in ESEA Section 2141(a), (b), and (c) for a district and SEA to comply with certain requirements for improvement plans regarding highly qualified teachers

The SEA requests this waiver to allow the SEA and its districts to focus on developing and implementing more meaningful evaluation and support systems

ESEA Flexibility Request-Waiver 8 10

2

9. The limitations in ESEA Section 6123 that limit the amount of funds an SEA or district may transfer from certain ESEA programs to other ESEA programs

The SEA requests this waiver so that it and its districts may transfer up to 100 percent of the funds it receives under the authorized programs among those programs and into Title I, Part A

ESEA Flexibility Request-Waiver 9 103

10. The requirements in ESEA Section 1003(g)(4) and the definition of a Tier I school in Section I.A.3 of the School Improvement Grants (SIG) final requirements

The SEA requests this waiver so that it may award SIG funds to a district to implement one of the four SIG models in any of the state’s priority schools that meet the definition of “priority schools” set forth in the

document titled ESEA Flexibility

NOTE: Waiver number 11 was NOT requested

ESEA Flexibility Request-Waiver 10 104

12. The requirements in ESEA Sections 1116(a)(1)(A)-(B) and 1116(c)(1)(A) that require districts and SEAs to make determinations of AYP for schools and districts, respectively.

The SEA requests this waiver because continuing to determine whether a district and its schools make AYP is inconsistent with the SEA’s state-developed differentiated recognition, accountability, and support system included in its ESEA flexibility request

The SEA and its districts must report on their report cards performance against the AMOs for all subgroups identified in ESEA Section 1111(b)(2)(C)(v), and use performance against the AMOs to support continuous improvement in Title I, Part A schools that are not reward schools, priority schools, or focus schools

Optional Flexibilities-Waiver 12 10

5

13. The requirements in ESEA Section 1113(a)(3)-(4) and (c)(1) that require a district to serve eligible schools under Title I, Part A in rank order of poverty and to allocate Title I, Part A funds based on that rank ordering

The SEA requests this waiver in order to permit its districts to serve a Title I, Part A-eligible high school with a graduation rate below 60 percent that the SEA has identified as a priority school even if that school does not rank sufficiently high to be served

Optional Flexibilities-Waiver 13 106

Waiver Resources

• Summary of ESEA Flexibility Request http://www.k12.wa.us/ESEA/pubdocs/ESEAFlexibility.pdf

• Flexibility Request FAQs http://www.k12.wa.us/ESEA/pubdocs/ESEAFlexibility.pdf

107

Resource Links• OMB Circular A-87—Allowable Costs (Codified as 2 CFR 225)

• http://www.whitehouse.gov/omb/circulars_a087_2004/

• OMB Circular A-102— Grants and Cooperative Agreements with State and Local Governments

• http://www.whitehouse.gov/omb/circulars_a102/

• OMB Circular A-133—Audit Requirements and the related Compliance Supplement

• http://www.whitehouse.gov/omb/rewrite/circulars/a133/a133.html/

• 34 CFR 80—Administrative Requirements

• http://www.access.gpo.gov/nara/cfr/waisidx_04/34cfr80_04.html

• 34 CFR 76—Requirements for grants passed to districts through the state agency, OSPI

• http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title34/34cfr76_main_02.tpl

108

Director, Gayle Pauley: gayle.pauley@k12.wa.us

Program Supervisors• Petrea Stoddard: petrea.stoddard@k12.wa.us • Mary Jo Johnson: maryjo.johnson@k12.wa.us • Reginald Reid: reginald.reid@k12.wa.us • Jamilyn Penn: jamilyn.penn@k12.wa.us • John Pope: john.pope@k12.wa.us • Larry Fazzari: larry.fazzari@k12.wa.us • Bill Paulson: bill.paulson@k12.wa.us

Administrative Support• Julie Chace: julie.chace@k12.wa.us • Tony May: tony.may@k12.wa.us

OSPI Title I, Part A/LAP Contacts

109