ESEA FINANCIAL ISSUESESEA FINANCIAL ISSUES

September 16, 2014

WVDE Office of Federal ProgramsLaura Pauley, CPA

lepauley@k12.wv.us

Helpful LinksHelpful Links– OMB Circular: December 26, 2013 Federal

Register Final Guidance • http://www.gpo.gov/fdsys/pkg/FR-2013-12-26/pdf/201

3-30465.pdf

– Education Department General Administrative Regulations (EDGAR)• http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.

html

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ESEA Program Updates

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Updates

– New EDGAR finalized December 26, 2014• To be in line with new Omni Circular• Draft was due out June 26, 2014

– FY 2015 grants issued prior to December 26, 2014 will still be governed by old regulations

– New monitoring process being implemented• Omni Circular requires additional monitoring and

oversight of LEAs by SEAs• Must do some monitoring of every LEA every year in

additional to 5 year schedule4

Updates

• Risk assessments must now be done on all LEAs prior to providing federal funding

• Certified 5-17 report • 5-17 report coming out with certified reports (look for this

with enrollment reports in the coming months)

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Carryover

• Title II and Title VI Carryover– Increased from 15% limit to 40% (for 9/30/14 only

to help offset Title I carryover confusion)– Need to start analyzing and moving expenses if

necessary before Sept 30th

• Title I limited to 15% (unless allocation < $50,000)

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Carryover

• How to calculate carryover– Carryover is verified by WVDE running Project

Financial Reports once counties have closed their books for September.

– Payroll related encumbrances are not included in the calculation of carryover.

– If a county has transferred Title II/VI funds into Title I these funds count towards carryover amounts

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Carryover

• How to reduce your carryover– Transfer Title I eligible expenditures from other

funds without carryover limits or with higher carryover limits into Title I

– Must clean-up carryover over prior to closing September so that we can verify carryover amounts

– Obligate funds by Sept 30th

– Practice “First In First Out”

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ObligationIf the obligation is for - The obligation is made-

(a) Acquisition of real or personal property

On the date the district makes the binding written commitment to acquire the property

(b) Personal services by an employee or the district

When the services are performed

(c) Personal services by a contractor who is not an employee of the district

The date the district makes a binding written commitment to obtain the services.

(d) Performance of work other than personal services

On the date the district makes a binding written commitment to obtain the work.

(e) Public Utility Services When the district receives the services

(f) Travel When the travel is taken

(g) Rental of real or personal property Then the district uses the property

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Liquidation

• Liquidation typically occurs 30 days after end of the obligation period.– Make sure funds are requested from WVDE prior

to the ending liquidation date– WVDE cannot distribute funds after the ending

liquidation date listed on the grant document

• Liquidation dates can vary by grant – Always double check your grant document

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