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California Department of Education Educational Data Management Division 2017–18 CONSOLIDATED APPLICATION PROGRAM WINTER GUIDANCE January 15, 2018

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Page 1: ConApp Guid - 2017 Winter (CA Dept of Education) · Web view2018/01/15 · In addition, Title I, Part A funds must be reserved for serving eligible low-income students who are attending

California Department of EducationEducational Data Management Division

2017–18 CONSOLIDATED APPLICATIONPROGRAM WINTER GUIDANCE

January 15, 2018

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Table of ContentsIntroduction.........................................................................................................................12017–18 Title III, Part A Immigrant Expenditure Report.....................................................22017–18 Title III, Part A English Learner Expenditure Report............................................42017–18 Federal Transferability.........................................................................................72017–18 Title I, Part A Reservations..................................................................................82017–18 Title I, Part A School Allocations........................................................................112017–18 Title I, Part D Local Educational Agency Allocation...........................................162017–18 Title II, Part A Local Educational Agency Allocation...........................................192017–18 Consolidation of Administrative Funds...............................................................202017–18 Title IV, Part A Student Support and Academic Enrichment..............................22

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IntroductionThis document reflects guidance for programs included in the 2017–18 Consolidated Application (ConApp). It is intended primarily for local educational agency staff who are involved in the completion of the ConApp using the Consolidated Application and Reporting System (CARS), but may also be helpful to anyone who is reviewing the ConApp.

The CARS is a Web-based system used to apply for funding, collect and report ConApp data, and track categorical program expenditures and activities.

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2017–18 Title III, Part A Immigrant Expenditure Report ExpendituresRefer to the Every Student Succeeds Act (ESSA), Section 3115 (e)(1) as a guide to determine authorized expenditures for the relevant Title III Immigrant Program Subgrant:

ESSA, Section 3115:

(e) Activities by agencies experiencing substantial increases in immigrant children and youth —

(1) In General - An eligible entity receiving funds under section 3114(d)(1) shall use the funds to pay for activities that provide enhanced instructional opportunities for immigrant children and youth, which may include —

(A) family literacy, parent and family outreach, and training activities designed to assist parents and families to become active participants in the education of their children;

(B) recruitment of, and support for personnel, including teachers and paraprofessionals who have been specifically trained, or are being trained, to provide services to immigrant children and youth;

(C) provision of tutorials, mentoring, and academic or career counseling for immigrant children and youth;

(D) identification, development and acquisition of curricular materials, educational software, and technologies to be used in the program carried out with awarded funds;

(E) basic instructional services that are directly attributable to the presence of immigrant children and youth in the local educational agency (LEA) involved, including the payment of costs of providing additional classroom supplies, costs of transportation, or such other costs as are directly attributable to such additional basic instructional services;

(F) other instructional services that are designed to assist immigrant children and youth to achieve in elementary schools and secondary schools in the United States, such as programs of introduction to the educational system and civics education; and

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(G) activities, coordinated with community-based organizations, institutions of higher education, private sector entities, or other entities with expertise in working with immigrants, to assist parents and families of immigrant children and youth by offering comprehensive community services.

Direct Administrative CostsRecommended direct administration expenses for a fiscal year may not exceed 2 percent of such funds for the cost of administering this subpart.

Indirect CostsIndirect Costs amount should not exceed the estimated portion of the entitlement amount that is not reserved for direct administrative costs, multiplied by the LEA's approved indirect cost rate (ICR) as published on the California Department of Education (CDE) ICR Web page at http://www.cde.ca.gov/Suppfg/ac/ic/.

Supplement, Not SupplantFederal funds made available under this subpart shall be used so as to supplement the level of federal, state, and local public funds that, in the absence of such availability, would have been expended for programs for English learners and immigrant children and youth and in no case to supplant such federal, state, and local public funds.

LEA PlanLEAs that participate in the Title III Immigrant program funding are required to update their LEA Plans annually (ESSA, Title III, Part A, Section 3116). The annual LEA Plan update includes a proposed budget for the subgrant year.

Please visit the CDE Title III Frequently Asked Questions Web page at http://www.cde.ca.gov/sp/el/t3/title3faq.asp.

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2017–18 Title III, Part A English Learner Expenditure ReportExpendituresRefer to the Every Student Succeeds Act (ESSA), Section 3115 (c)(1)(2)(3) and (d) as a guide, to determine authorized expenditures:

(c) Required Subgrantee Activities - An eligible entity receiving funds under section 3114(a) shall use the funds —

(1) to increase the English language proficiency of English learners by providing effective language instruction educational programs that meet the needs of English learners and demonstrate success in increasing —

(A) English language proficiency; and

(B) student academic achievement;

(2) to provide effective professional development to classroom teachers (including teachers in classroom settings that are not the settings of language instruction educational programs), principals and other school leaders, administrators, and other school or community-based organizational personnel, that is —

(A) designed to improve the instruction and assessment of English learners;

(B) designed to enhance the ability of such teachers, principals, and other school leaders to understand and implement curricula, assessment practices and measures, and instructional strategies for English learners;

(C) effective in increasing children's English language proficiency or substantially increasing the subject matter knowledge, teaching knowledge, and teaching skills of such teachers; and

(D) of sufficient intensity and duration (which shall not include activities such as one-day or short-term workshops and conferences) to have a positive and lasting impact on the teachers' performance in the classroom, except that this subparagraph shall not apply to an activity that is one component of a long-term, comprehensive professional development plan established by a teacher and the teacher's supervisor based on an assessment of the needs of the teacher, the supervisor, the students of the teacher, and any local educational agency (LEA) employing the teacher, as appropriate.

(3) to provide and implement other effective activities and strategies that enhance or supplement language instruction educational programs for English learners, which —

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(A) shall include parent, family, and community engagement activities; and

(B) may include strategies that serve to coordinate and align related programs.

(d) Authorized Subgrantee Activities - Subject to subsection (c), an eligible entity receiving funds under section 3114(a) may use the funds to achieve one of the purposes described in subsection (a) by undertaking one or more of the following activities:

(1) Upgrading program objectives and effective instructional strategies.

(2) Improving the instructional program for English learners by identifying, acquiring, and upgrading curricula, instructional materials, educational software, and assessment procedures.

(3) Providing to English learners —

(A) tutorials and academic or career and technical education; and

(B) intensified instruction, which may include materials in a language that the student can understand, interpreters, and translators.

(4) Developing and implementing effective preschool, elementary school or secondary school language instruction educational programs that are coordinated with other relevant programs and services.

(5) Improving the English language proficiency and academic achievement of English learners.

(6) Providing community participation programs, family literacy services, and parent and family outreach and training activities to English learners and their families —

(A) to improve the English language skills of English learners; and

(B) to assist parents and families in helping their children to improve their academic achievement and becoming active participants in the education of their children.

(7) Improving the instruction of English learners, which may include English learners with a disability by providing for —

(A) the acquisition or development of educational technology or instructional materials;

(B) access to, and participation in, electronic networks for materials, training, and communication; and

(C) incorporation of the resources described in subparagraphs (A) and (B) into curricula and programs, such as those funded under this subpart.

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(8) Offering early college high school or dual or concurrent enrollment programs or courses designed to help English learners achieve success in postsecondary education.

(9) Carrying out other activities that are consistent with the purposes of this section.

Direct Administrative CostsRecommended direct administration expenses for a fiscal year may not exceed 2 percent of such funds for the cost of administering this subpart.

Supplement, Not SupplantFederal funds made available under this subpart shall be used so as to supplement the level of federal, state, and local public funds that, in the absence of such availability, would have been expended for programs for English learners (EL) and immigrant children and youth and in no case to supplant such federal, state, and local public funds.

LEA PlanLEAs that participate in the Title III EL program funding, either as a direct funded LEA or as part of a consortium, are required to update their LEA Plans annually (ESSA, Title III, Part A, Section 3116). The annual LEA Plan update must include a proposed budget allocating the funds to the activities planned for the subgrant year.

Please visit the California Department of Education Title III Frequently Asked Questions Web page at http://www.cde.ca.gov/sp/el/t3/title3faq.asp.

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2017–18 Federal TransferabilityTitle V Section 5103 of the Every Student Succeeds Act (ESSA) allows a local educational agency (LEA) to transfer up to 100 percent of Title II, Part A and Title IV, Part A program funds to other allowable programs. The allowable programs are:

Title I, Part A;

Title I, Part C;

Title I, Part D;

Title II, Part A

Title III, Part A English Learner;

Title III, Part A Immigrant;

Title IV, Part A; and

Title V, Part B.

An LEA may not transfer funds allocated under Title I or Title III.

Consultation with private schools is required under ESSA Section 8501, if such a transfer affects students or educational personnel from private schools.

For more information on federal transferability rules, see ESSA, Title V, Section 5103 Transferability of Funds on the U.S. Department of Education Web page at https://www2.ed.gov/documents/essa-act-of-1965.pdf.

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2017–18 Title I, Part A ReservationsSection 1 – Title I, Part A Required ReservationsLocal educational agencies (LEAs) are required to reserve Title I, Part A funds, before allocating to schools, to provide comparable services that are necessary to assist students in meeting State challenging academic standards (Every Student Succeeds Act [ESSA] Section 1113[c][3][A]). The required reservations for the 2017–18 school year are described below.

Parent and Family Engagement ReservationUnder the ESSA Section 1116(a)(3), an LEA with an allocation in excess of $500,000 must reserve at least 1 percent of the LEA’s Title I, Part A allocation for parent and family engagement activities specified in ESSA Section 1116.

School Parent and Family Engagement Amount:

At a minimum, 90 percent of the one percent reserved must be distributed to schools for parent and family engagement activities.

LEA Parent and Family Engagement Amount:

If an LEA receives $500,000 or less in Title I, Part A funds, the LEA is not required to reserve any specific amount of Title I, Part A funds for parent and family engagement activities. The LEA and its Title I schools, however, must still implement the provisions for parent and family engagement under ESSA Section 1116.

For more information, please see the California Department of Education (CDE) Title I, Part A Parent and Family Engagement Web page at https://www.cde.ca.gov/sp/sw/t1/parentfamilyinvolve.asp.

Homeless Services ReservationLEAs must reserve Title I, Part A funds to provide comparable services to homeless children to ensure that homeless children receive a high-quality education and meet the challenging State academic standards (ESSA sections 1112[b] and 1113[c][3][C]).

LEAs determine the amount to be reserved that is necessary and reasonable to provide comparable services to homeless children and youths, including providing educationally related support services to children in shelters and other locations where children may live (ESSA Section 1113[c][3][A][i]).

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To determine the amount of Title I, Part A funds to be reserved, LEAs shall base their decision on the total Title I, Part A allocation received by the LEA and prior to any allowable expenditure or transfers by the LEA.

For information about allowable activities for homeless children, see the CDE Resources for Homeless Children and Youths Web page at http://www.cde.ca.gov/sp/hs/cy/.

Neglected and/or Delinquent Reservation

LEAs shall reserve Title I, Part A funds as are necessary to provide comparable services to ensure that neglected and/or delinquent children receive a high-quality education and meet the challenging State academic standards (ESSA Section 1112[b]). LEAs shall use the reserved funds to serve children in local institutions for neglected children, and if appropriate, children in local institutions for delinquent children, and neglected or delinquent students in community day programs (ESSA Section 1113[c][3][A][ii]-[iii]).

Such reservation shall be determined based on the total allocation received by the LEA and prior to any allowable expenditures or transfers by the LEA. The amount to be reserved to support these students is determined by the LEA as appropriate and reasonable (ESSA Section 1113[c][3][B]-[C]).

For more information, please see the CDE Title I, Part A Neglected Reservation Web page at https://www.cde.ca.gov/sp/sw/t1/title1ptaneglected.asp.

Public School Choice TransportationLEAs, beginning in the 2017–18 school year, are no longer required to offer the public school choice (Choice) program under the No Child Left Behind Act (NCLB) of 2001. However, they must allow students who previously transferred to another public school which was not identified for Program Improvement (PI) under the NCLB Choice program to remain in that school until they complete the highest grade offered in that school.

LEAs that have students who previously transferred to a non-PI school under the NCLB Choice program must set aside a reasonable amount of funds to pay for transportation (but not exceeding an amount equal to 15 percent of the LEA’s current year’s Title I, Part A allocation).

For more information, about Title I, Part A School Choice, please see the CDE ESSA Update #8 Web page at http://www.cde.ca.gov/re/es/letter17jul17.asp and the CDE Title I, Part A School Choice Web page at https://www.cde.ca.gov/ta/ac/ti/schoolchoice.asp.

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Section II – Title I, Part A Authorized ReservationsLEAs are authorized to reserve Title I, Part A funds to implement districtwide Title I initiatives. These initiatives are designed to improve the achievement of Title I students and are managed at the central level rather than at the school level with the purpose to benefit all, or a group, of Title I schools in the district. For an LEA with both Title I and non-Title I schools, these initiatives are not truly districtwide. In general, an LEA cannot use Title I, Part A funds to benefit students in non-Title I schools except such students who are homeless, neglected/delinquent and they may be attending non-Title I schools in the LEA. See Section I - Title I, Part A Required Reservations of this guidance for additional information. In addition, Title I, Part A funds must be reserved for serving eligible low-income students who are attending non-profit private schools which have service agreements with the LEA. For more information see the CDE Title I Services for Students in Private Schools Web page at https://www.cde.ca.gov/sp/sw/t1/privateschoolsvs.asp.

Though under ESSA there is no specific cap on the amount of funds an LEA can reserve for district-managed districtwide initiatives, the bulk of Title I funds generally should be allocated to schools because Title I, Part A is designed to be a school-based program. In California Education Code Section 63001, LEAs are required to use 85 percent of Title I, Part A funds for direct student services at school sites. However, reserving some Title I, Part A funds at the LEA level for districtwide activities may be reasonable if these activities are LEA-level responsibilities specified in ESSA Section 1112. If the percentage reserved for LEA authorized activities is too high, the CDE will review for reasonableness and potentially compliance.

For additional information regarding the general criteria to approve activities or expenditures, please see the CDE Title I, Part A Authorized Use of Funds Web page at https://www.cde.ca.gov/sp/sw/t1/authuseoffunds.asp.

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2017–18 Title I, Part A School AllocationsTo allocate Title I, Part A funds to schools, local educational agencies (LEAs) must follow the rules specified in the Every Student Succeeds Act (ESSA) Section 1113.

For an LEA with an enrollment of less than 1,000 students, the ranking and serving requirements based on poverty percentages are not applicable (ESSA Section 1113[a][6]). However, the LEA’s decision to allocate Title I, Part A funds to schools must be based on an assessment of the needs of the students in the schools. An LEA cannot use this special provision arbitrarily to skip a school if its students have a demonstrated need that is as great as or greater than another school.

The rules governing school allocations are as follows:

Ranking and Serving SchoolsAn LEA shall allocate funds received under Tile I, Part A to eligible school attendance area or eligible schools in rank order on the basis of the total number of children from low-incomes families in each area or school (ESSA Section 1113[c][1]). The term “eligible school attendance area” means a school attendance area in which the percentage of children from low-income families is at least as high as the percent of children from low-income families served by the LEA as a whole (ESSA Section 1113[a][2][B]).

If funds allocated are insufficient to serve all eligible attendance areas or schools, an LEA shall:

Annually rank, without regard to grade spans, the LEA’s eligible school attendance areas in which the percentage of children from low-income families exceed 75 from highest to lowest according to the percentage of children from low-income families (ESSA Section 1113[a][3][A][i]) and serve such eligible school attendance areas in rank order (ESSA Section 1113[a][3][A]).

LEAs may lower the threshold to 50 percent for high schools (ESSA Section 1113[a][3][B]). In other words, if a high school has a low-income poverty percentage equal to or greater than 50 percent, the high school may be funded the same way as those schools that have low-income percentages exceeding 75 percent.

If funds remain after serving all eligible school attendance areas or schools exceeding 75 low-income percentage and, at the LEA’s discretion, high schools with a low-income percentage at 50 or beyond, the LEA shall:

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Rank remaining eligible school attendance areas from highest to lowest either by grade span or for the entire LEA according to the percentage of children from low-income families (ESSA Section 1113[a][4][A]).

Serve such eligible school attendance areas in rank order either within each grade-span grouping (under development) or within the LEA as a whole (ESSA Section 1113[a][4][B]).

LEA Discretion Regarding Serving SchoolsLEA discretions are usually exercised by using exception reasons. Therefore, the following information should be read in conjunction with the brief explanations for each exception reason in the last section of this guidance:

Serving Schools Below Districtwide Low-Income Average But At or Above 35 Percent Low-Income – LEAs may choose to continue serving schools that are below the districtwide average low-income percentage but are at or above 35 percent low-income percentage as long as schools with higher low-income percentages have been served first. If an LEA chooses to do so, the LEA must use Exception Reason “a” - Meets 35 percent Low Income Requirement.

Fund a School that Does Not Serve an Eligible School Attendance Area – Some types of schools enroll students districtwide such as charter schools, magnet schools, or alternative schools. These schools must be ranked and funded the same way as other schools in the LEA. In other words, LEAs can only use low-income percentage as a measure to fund schools. The LEA cannot use anything else, such as types of schools or instructional models of schools (ESSA section 1113[b][1][B]).

For locally funded charter schools that are part of an LEA, depending on their charter contracts with their LEAs, the charter schools may be able to make the decision to participate or not participate in Title I programs. Exception Reasons “g” – Local Funded Charter Opted Out and “h” – Local Funded Charter Opt in, are used for the LEA to indicate whether or not their charter schools are participating.

Serving an Ineligible School – LEAs have the discretion to continue funding a school that is no longer eligible but was eligible and served in the preceding year. LEAs may only serve an ineligible school for one additional fiscal year (ESSA Section 1113[b][1][C]). If an LEA chooses to do so, the LEA must use Exception Reason “e” – Grandfather Provision.

Skipping Eligible Schools – LEAs may elect not to serve an eligible school attendance area or an eligible school that has a higher percentage of children

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from low-income families if:

The school meets the comparability requirements of ESSA Section 1118(c);

The school is receiving supplemental funds from other state or local sources that are spent according to the requirements of ESSA Section 1114 or 1115; and

The funds expended from such other sources equal or exceed the amount that would be provided from Title I, Part A (ESSA Section 1113[b][1][D][i]-[iii]).

In California, the only “other sources” of funds that are eligible to be used for this purpose are Economic Impact Aid/State Compensatory Education (EIA/SCE) funds. In other words, LEAs with no EIA/SCE carryover funds may not skip a required or an eligible school to fund a school that has a lower low-income percentage. For more information, see Exception Reason “k” – Funded with EIA/SCE in the Available Exception Reasons section below.

Serving Schools with Low-Income Percentages Below 35 – If an LEA has a districtwide average low-income percentage below 35, the LEA may only serve schools at or above the districtwide low-income average. In addition, the per-pupil amount of funds allocated to each school attendance area or school shall be at least 125 percent of the per-pupil amount of funds the LEA received for that year under the poverty criteria described by the LEA in the LEA Plan, submitted under ESSA Section 1112 (ESSA Section 1113[c][2][A]).

The LEA must calculate the 125 percent allocation per low-income child before the LEA reserves any funds. The calculation of per low-income child amount is the total LEA Title I Part A allocation divided by the total number of low-income children in the LEA. The LEA then multiplies this per low-income student amount by 125 percent.

Serving Middle and High Schools Using Feeder Patterns – As middle and high school students are less likely to participate in free and reduced-price lunch programs than are elementary school students, LEAs may use comparable data collected through alternative means such as a survey or use the “feeder pattern” concept. This allows the LEA to project the number of low-income children in a middle or high school based on the average low-income rate of the elementary school attendance areas that feed into that school (ESSA Section 1113[a][5][B][ii]). If an LEA chooses this option, the LEA must use Exception Reason “f” – Feeder Pattern.

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Carryover FundsAn LEA shall obligate funds during the 27 months extending from July 1 of the fiscal year (FY) for which the funds were appropriated through September 30 of the second succeeding FY (General Education Provisions Act Section 421[b]). This maximum period includes a 15-month period of initial availability in addition to a 12-month period for carryover.

LEAs may carry over up to 15 percent of the current year’s allocation (not including funds received through any reallocation under this subpart) for one additional FY (ESSA Section 1127[a]). LEAs may apply for CDE to waive the 15 percent carryover limit and such requests are approved once every three years (ESSA Section 1127[b]).

The 15 percent limitation for carryover shall not apply to any LEA that receives less than $50,000 under this subpart for any fiscal year (ESSA Section 1127[c]).

Parent and Family EngagementEach LEA that receives more than $500,000 in Title I, Part A funds, shall reserve at least 1 percent of its allocation to assist schools to carry out the parental and family involvement activities (ESSA Section 1116[a][3][A]). Not less than 90 percent of the funds reserved shall be distributed to schools served with priority given to high-need schools (ESSA Section 1116[a][3][C]).

For allocating Title I, Part A funds for parent and family engagement to charter schools, see ESSA sections 1113 and 1116.

Available Exception ReasonsException Reasons are used to indicate reasons for funding or not funding certain schools with Title I, Part A funds. Brief explanations about exception reasons are in the following:

a - Meets 35% Low-Income Requirement: The LEA may elect to provide funding to schools with a low-income percentage below the district or grade span average but at or above the minimum 35 percent requirement as long as schools with higher percentages are funded first (ESSA Section 1113[b][1][A]).

d - Desegregation Waiver on File: The school or district is operating a state or court ordered desegregation program that allows the district to serve eligible schools with a low-income percentage equal to or greater than 25 percent (ESSA Section 1113[a][7]).

e - Grandfather Provision: By using Exception Reason “e,” the LEA designates a school that is not eligible under current ranking but was served in the preceding

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fiscal year. Exception Reason “e” can only be used once in the subsequent year after the school was served with Title I funds (ESSA Section 1113[b][1][C]).

f - Feeder Pattern: LEAs are allowed to use an estimated percentage of low-income children in a middle school or high school based on the average low-income percentages of the feeder schools to deem a school eligible for funding in Title I, Part A funding (ESSA Section 1113[a][5][B][ii]).

g - Local Funded Charter Opted Out: The CDE created Exception Reason “g” to be used when a locally funded charter decides to opt out of Title I, Part A funding. If a charter school opts out of Title I, Part A funds, the LEA is able to skip the charter school and fund the next ranked school (ESSA Section 1113[b][1][B]). LEAs using Exception Reason “g” may want to keep backup documents for verification of compliance.

h - Local Funded Charter Opt In: Locally funded charters may elect to participate in Title I, Part A programs. If a locally funded charter school decides to opt in for Title I, Part A funding, the LEA is able to fund the school in rank order by using Exception Reason “h” (ESSA Section 1113[b][1][B]).

k - Funded with EIA/SCE: LEAs have the discretion to not serve an eligible school attendance area or eligible school that has a higher percentage of children from low-income families if the funds expended from such other sources equal or exceed the amount that would be provided (ESSA Section 1113[b][1][D]). In California, the only “other sources” of eligible funds are EIA/SCE funds.

Beginning in the 2017–18 school year, Exception Reason “c” is no longer available as the only eligible funds for skipping schools for Title I funds are EIA/SCE funds which are no longer apportioned. Unless an LEA has EIA/SCE carryover funds, the LEA will not be able to skip any eligible schools or indicate the change.

ResourcesText of the Elementary and Secondary Education Act, as amended by the ESSA, can be found at https://legcounsel.house.gov/Comps/Elementary%20And%20Secondary%20Education%20Act%20Of%201965.pdf.

Additional non-regulatory guidance can be found in the U.S. Department of Education Web document located at http://www2.ed.gov/programs/titleiparta/wdag.doc.

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2017–18 Title I, Part D Local Educational Agency Allocation Frequently Asked Questions Regarding Title I, Part D Allocations

1. What is a centralized service?

A centralized service is an activity funded by a school allocation but administered by the local educational agency (LEA) central office. The activity would be included in the 15 percent if it is an administrative cost or would be part of the 85 percent if it is a direct service to students.

Examples of centralized services include:

English language proficiency testing of students at a central location;

Professional development activities for multiple schools; or

Shared costs of staff members (e.g., nurses, instructional aides, or teachers) who provide services to multiple schools.

Centralized services must be itemized as proposed expenditures in the Single Plan for Student Achievement and approved by the Schoolsite Council and local school board.

2. What are the maximum administrative costs that can be charged to Title I, Part D?

Districts have a set amount of funds for indirect costs, which are a type of administrative cost. Administrative costs, including those funded through centralized services, school level administrative costs, and indirect costs may not exceed 15 percent. Expenditures for personnel engaged in district administrative or planning activities can be included in the administrative costs charged to Title I, Part D. Also included are expenditures for salaries and benefits for:

District administrative personnel;

District program personnel, either certificated or classified;

Itinerant staff based at the district, except for the time engaged in directly instructing students, providing professional development activities directly related to the purposes of the Title I program, or traveling to or from school sites for the delivery of instruction or staff development; or

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School program administrators, to the extent they do not provide direct instruction or conduct professional development activities to meet the specific student needs consistent with Title I purposes.

3. What is the definition of a direct service to students?

Direct services are those that are delivered at the school site where the student is the direct recipient or beneficiary of the services. Expenditures for personnel are justified as direct service and for inclusion in the 85 percent if the personnel are providing direct, hands-on instruction to students or the services being provided are so integral to the instructional program that to not provide the services would affect the quality of the instruction itself and the academic success of students.

For example, an LEA may include in the 85 percent, the salaries and benefits of such certificated personnel as specialist or resource teachers, school nurses, school librarians, school counselors, classified instructional aides, and school program administrators, to the extent that they provide direct instruction or conduct professional development to meet specific Title I student needs.

Similarly, allowable expenditures for operating expenses and equipment, when the purposes meet the specific needs of eligible Title I students, might include:

Acquisition, installation, relocation, maintenance, and repair of instructional equipment (e.g., computer hardware);

Contract services, including consultant services to work with eligible students and to work with teachers who have special needs to upgrade their instructional skills for the direct benefit of students;

Student services for Title I students in private schools;

Program evaluation at school sites;

Student evaluation, including testing and data processing;

School library materials for use by students;

Schoolsite Councils;

Supplementary instructional materials and supplies, including computer software; or

Staff development activities to meet specific student academic needs.

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4. When does an LEA identify the funds that are to be set aside for indirect costs?

Indirect costs are calculated before district reservations and before funds are allocated to schools. Since the calculation is just an estimate, the actual indirect costs are subtracted at the end of the school year based on how much funding was expended. For example, an LEA allowed a 3 percent indirect cost rate out of the total Title I annual allocation would budget for it on the Title I, Part A LEA Allocation page of the Consolidated Application; however, the LEA would only charge indirect costs equal to 3 percent of its eligible expenditures at the end of the school year.

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2017–18 Title II, Part A Local Educational Agency AllocationTitle II, Part A funds are allocated based on the following formula:

(a) 20 percent based on the relative number of individuals age 5 through 17, and

(b) 80 percent based on the relative numbers of individuals age 5 through 17 from families with incomes below the poverty line, residing in the area the local educational agency serves based on U.S. Census or state alternative poverty data.

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2017–18 Consolidation of Administrative Funds A local educational agency (LEA) that consolidates administrative funds for any fiscal year (FY) shall not use any other funds under the programs included in the consolidation for administration for that FY (Every Student Succeeds Act [ESSA] Section 8203). Indirect costs are a part of costs of administration; thus, indirect costs pertaining to programs included in the consolidation may only be paid out of the funds available for the administrative cost pool. For example, if a program must budget and expend at least 85 percent on direct services to students, then the total allowable for administration (e.g., program administration plus indirect costs) cannot exceed 15 percent.

Programs that may be included in the consolidation of administrative funds are:

Standardized Account Code Structure (SACS) Resource Codes

Programs

3010 Title I, Part A (Basic)

3060 Title I, Part C (Migrant Education)

3025 Title I, Part D (Delinquent)

4035 Title II, Part A (Supporting Effective Instruction)

4201 Title III (Immigrant Students)

4203 Title III (English Learner Students)

4124 Title IV, Part B (21st Century Community Learning Centers)

The consolidated funds may be used for the administration of the programs included in the consolidation and for uses, at the school district and school levels, designed to enhance the effective and coordinated use of funds under those programs, including such activities as:

The coordination of the ESSA programs with other federal and non-federal programs;

The establishment and operation of peer-review mechanisms under ESSA;

The administration of Title VII of ESSA (General Provisions);

The dissemination of information regarding model programs and practices;20

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Technical assistance under any ESSA program;

State-level activities designed to carry out Title VII; and/or

Training personnel engaged in audit and other monitoring activities.

An LEA that consolidates administrative funds may treat the consolidated administrative cost pool as a single cost objective; therefore, it is not required to keep separate records, by individual programs, to account for costs relating to the administration of the programs included in the consolidation. Use SACS Resource Code 3155 to account for consolidated administrative funds.

Expenditures of the consolidated funds (Resource Code 3155) will be distributed (charged) to the contributing programs and will be reported as expenditures of those programs; the distribution will not necessarily be in the same proportion as the amounts contributed (or that could have been contributed) by the programs to the pool, as long as the amount distributed to a program is within the allowable percentage or maximum amount for administration for that program and the grant amount is not exceeded after the distribution. The distribution may be done at any time during the year; any undistributed expenditures at the end of the year will be distributed to the participating programs so that Resource Code 3155 has net zero expenditures at the end of the year.

For further accounting information please refer to the California Department of Education California School Accounting Manual, Procedure 780, Consolidation of Administrative Funds at http://www.cde.ca.gov/fg/ac/sa/documents/csam2016complete.pdf.

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2017–18 Title IV, Part A Student Support and Academic EnrichmentThis program provides funding to improve students’ academic achievement by increasing school district capacity to:

Provide all students with access to a well-rounded education;

Improve school conditions for student learning; and

Improve the use of technology in order to improve the academic achievement and digital literacy of all students.

Program OverviewThe California Department of Education (CDE) believes that the following school improvement programs are key components of both Title IV, Part A and student academic success in California:

School-based mental health services and counseling; Programs to promote safe and supportive school climates to reduce the use of

exclusionary discipline; Programs that promote supportive school discipline; Programs supporting dropout prevention; A healthy, active lifestyle (nutritional and physical education); Alcohol, tobacco, and other drug education; Systems and practices to prevent bullying/cyberbullying and harassment; Trauma-informed practices; Relationship-building skills to reduce violence and abuse; and Establishing community partnerships.

Strategies

The Student Support and Academic Enrichment (SSAE) Program authorizes significant funds to address the expectations listed above by means of a formulaic allocation of Title IV, Part A funds to California’s Title I schools; a transfer of the Title IV, Part A funding allocated for state activities to Title II; and a percentage of the available funding allocated to the CDE for the purposes of the associated state operations to monitor activities and effective implementation of the SSAE Programs as permitted by the Every Student Succeeds Act (ESSA). 

FundingCalifornia anticipates receiving $44 million in Title IV, Part A funds. The state’s allotment is based on its portion of the Title I appropriation. Similarly, local educational agencies

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(LEA) receive funding under Title I based on their portion of the state’s Title I appropriation. Of the state’s Title IV, Part A allotment, no less than 95 percent must be allocated to LEAs, not more than 1 percent may be used to administer the program, and the remaining 4 percent may be used by the state for activities described in ESSA Section 4104(b).

ReferencesU.S. Department of Education, Non-Regulatory Guidance Student Support and Academic Enrichment Grants - https://www2.ed.gov/policy/elsec/leg/essa/essassaegrantguid10212016.pdf

Fact Sheet: ESSA Title IV, Part A - https://www.iste.org/docs/advocacy-resources/title-iv-fact-sheet-for-essa_final.pdf

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