comparability & title i compliance annual masbo institute may 12, 2015

Comparability &Title I ComplianceAnnual MASBO InstituteMay 12, 2015

Massachusetts Department of Elementary and Secondary Education

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History of the School Business Official

The leadership role of the school business official has changed during the past two centuries.

Initially, a lay board oversaw the area of school business. That responsibility then moved to selectmen of the town and later to a committee of men.

In the early to mid-1800’s, superintendents were given the responsibility of paying bills and maintaining the buildings.

Then in _____, the role of the school business official was formalized with the establishment of the National Association of School Accounting Officers.


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A. 1953

B. 1910

C. 1938

D. 1925


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The first female Superintendent of public schools the United States was appointed in 1874 in the district of:

A. Davenport, IA

B. Jefferson, WI

C. Dearborn, MI

D. Plainville, KS


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Agenda Title I and comparability Maintenance of effort Internal controls Time and effort reporting Single audits


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5 facts about Title I Title I serves more than 18 million students

nationwide Title I was initiated in 1965 as part of the

War on Poverty Title I serves students Pre-K through 12th

grade Title I is the single largest precollege

federal education program Title I students are found in almost every

school district in the county

Comparability is a test of fairness

Schools receiving federal Title I funds must receive state and local funds comparable to the state and local funds given to non-Title I schools. In other words, Title I schools must be getting their fair share of state and local funds before they receive Title I funds. Title I funds, by law, are therefore supplemental to state and local funds.

Comparability is required by the No Child Left Behind Act of 2001.

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General Rule- §1120A(c) An LEA may receive Title I Part A funds

only if it uses state and local funds to provide services in Title I schools that, taken as a whole, are at least comparable to the services provided in non-Title I schools.

If all are Title I schools, all must be “substantially comparable.”

Meeting comparability

LEAs must conduct calculations every year to demonstrate compliance because Title I, Part A allocations are made annually.

LEAs must keep comparability documentation on file for outside review. 9


How to measure??

Compare Student/Staff Ratios

Average of all non-Title I schools

to

Each Title I school

Exclusions: Federal Funds Private Funds Need not include unpredictable

changes in students enrollment or personnel assignments that occur after the start of a school year

Who is “instructional staff”? Consistent between Title I and non-Title I

EPIMS Codes Used for Comparability: EPIMS 1305 Principal EPIMS 1310 Assistant/Vice Principal EPIMS 2305 Teacher EPIMS 2310 Teacher – support content

instruction EPIMS 2325 Long Term Substitute Teacher EPIMS 2330 Instructional Coach EPIMS 3329 Guidance Counselor

Exemptions Schools with 100 or fewer students

An LEA with only one school for each grade span (Vocational Schools & Charters too)

A school with no comparison school in the same grade span grouping by enrollment size 13


Automated form: detailed school data

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ESE-generated report ESE is using a newly created database to

monitor district compliance with comparability.

ESE will run monitoring reports in February (using current year SIMS and EPIMS data).

Districts in question will be asked to review their staffing data and explain discrepancies or submit hard evidence of student to staff ratios.

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What if a school is not comparable?

LEAs must take immediate action to adjust school resources. Adjustments may involve:

Moving Title I funds out of a school

Replacing them with State or local funds

Making staffing changes in a school16


Maintenance of Effort

MOE: The NCLB Rule

LEA may receive funds only if SEA finds the combined fiscal effort per student or the aggregate expenditures of the LEA from state and local funds from preceding year not less than 90% for second preceding year.

MOE: Preceding fiscal year Need to compare final financial data

ESE Uses End of Year Financial Report (EOYR)

Example: To ensure MOE for FY16 Title I ~ compare FY13 EOYR to FY14 EOYR. (FY15 data would not be available in time)

Expenditures included

EOYR codes used for MOE: 100 Administration 200 Instructional Services 300 Pupil Services 400 Operation & Maintenance of Plant 500 Benefits & Other Fixed Charges

(local & state funds only)

Failure to meet MOE

ESEA: If LEA fails MOE, SEA must reduce amount of allocation in the exact proportion by which LEA fails to maintain effort below 90%.

Reduce all applicable NCLB programs, not just Title I

Determining MOE for FY16 Title I grant funding

Aggregate expenditures

Amount per student

SY 13 $1,000,000 $6,100

SY14 must spend 90% $900,000 $5,490

Actual amount $850,000 $5,200

Shortfall ($50,000) ($290)

Percent shortfall/ reduction FY16 TI grant reduced by 5.3%

-5.6%($50,000/$90,000)

-5.3%**($290/$5,490)

Internal controls

All recipients of federal funds must have controls that:

Ensure federal money is spent correctly Transactions properly recorded and accounted for

Prove federal money is spent correctly Transactions are executed in compliance with laws, regulations, and

provisions of contracts or grants

Safeguard property purchased with federal money Funds, property, and other assets are safeguarded against loss from

unauthorized use or disposition 23


Internal controls

Purchase Orders: should indicate that an item or service was authorized prior to purchase

Information on Invoices: should describe the item or service purchased and its designated purpose

Payment of Invoices: should ensure that expenditures match agreed upon charges with purchase orders and vendor contracts

Vendor Contracts – should document the activity or item being purchased

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Internal controls Equipment records – should indicate up to date

equipment lists, inventory lists with accurate location information and physical inventory at least once every two years

Procedures to Draw Down Funds: should have procedures to draw down funds from ESE within the allowed time periods

Title I Set-Asides: should show the allocation and distribution of funds from Title I set-asides 25


Internal controls

Budget Process – should have financial information that compares actual expenditures to the amounts budgeted (Business Manager tracks)

Grant workbook must align with budget expenditures – submit amendments as needed

Payroll records / FTEs must / time & effort should all reconcile

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Time and effort reporting Districts must maintain auditable "time and effort"

records that show how each Title I employee spent his or her compensated time.

Records are written, after-the fact (not estimated or budgeted).

Time and effort records must be prepared by Title I staff with salary charged directly to: 1. A federal award,2. Multiple federal awards, or 3. To any combination of a federal award and other federal,

state or local fund sources. 27


Time and effort reporting – stipends and other payments

Stipends (and other supplemental contracts) must also be reported.

Record stipends on semi-annual certifications or monthly reports, whichever is utilized for the particular employee.

Alternatively, permitted documentation includes A signed supplemental contract that stipulates Title I work activity; Sign-in attendance logs approved by the supervisor (e.g., pay for

professional development activities, after school activities, etc); and Employee time/pay slips that specify "Title I" and are approved by

the supervisor28


Title I audits

What does the auditor look for?

Deficiencies in internal controls Noncompliance with laws and regulations Questioned costs greater than $10,000

Unallowable costs Undocumented costs Unapproved costs Unreasonable costs

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What is an audit finding?

“Findings” are significant issues noted by the auditor that are disclosed in your audit report, which is a public record.

Your district must prepare a corrective action plan to resolve the issue.

Your district may be asked to repay questioned costs to the grantor agency.

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Statistics on MA single audit findings

FY14 Commonwealth of Massachusetts Common Single Audit findings:

4% Use of funds4% Unallowable costs4% Procurement11% Cash management29% Time and effort50% Reporting/recordkeeping

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Allowable costs To be allowable, a cost must:

Be reasonable for the performance of the award and be allowable in accordance with OMB Circular A-87. http://www.whitehouse.gov/omb/circulars_a087_2004/

All costs must be necessary and reasonable Must be necessary for the performance or administration of the grant Must follow sound business practice Fair market prices Act with prudence under the circumstances Do I really need this? Do I have the capacity to use what I am purchasing? Did I pay a fair rate? Can I prove it? 32


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

Procurement (the acquisition of goods & services)

Written policies and procedures

Common problems: No documentation Invoice predates purchase order Lack of description in contracts/invoices Lack of approval over payment process Inadequate segregation of duties Conflicts of interest

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Inventory controls

LEA Title I Office & Title I school will maintain a current and accurate inventory record of equipment purchased with Title I funds (including purchases for private school services)

Inventory Listing should include equipment that is non-consumable with a life of more than one year

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Travel expenses

As always….

Documentation / pre-approval / purchase order Purpose of travel – where & why? Receipts – auto/airfare/train/taxi/food/hotel Reasonable and necessary

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Tips for T1 Directors & Business Managers Gather and summarize grant information

Clean and organized records to give to auditors Document your policies and procedures

Documentation drives quality and compliance Know where to find the OMB Circular A-133. This supplement

lists 14 areas of compliance that auditors are expected to review when performing an audit

http://www.whitehouse.gov/omb/circulars/a133_compliance_ supplement_2012

Make sure the employees assigned to Title I understand the grant requirements to ensure compliance

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http://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2012

http://www.whitehouse.gov/omb/circulars/a133_compliance_supplement_2012

Contact information

Website: http://www.doe.mass.edu/apa/titlei

Email: [email protected]: 781-338-6230

http://www.doe.mass.edu/apa/titlei/default.html

comparability & title i compliance annual masbo institute may 12, 2015

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