Embed Size (px)
Citation preview
IDEA-B LEA MOE: Lessons Learned
Dina Black, TEA/Division of Federal Fiscal Compliance & Reporting
TCASE - July 2016Division of Federal Fiscal Compliance and
ReportingTexas Education Agency (TEA)
Dina Black, Compliance Unit Manager
2014-2015 IDEA-B LEA MOELessons Learned
} Compliance review timeline and results} Significant PEIMS errors} Change in fiscal years } Common mistakes in using IDEA-B LEA MOE calculation tool
} SHARS Medicaid reimbursements expended in special education
} Open-enrollment charter schools and IDEA-B LEA MOE
Lessons Learned Topics
} Statutory exception documentation} Clarification - “Exceptionally Costly Program” exception
} Subsequent Years Rule
Lessons Learned Topics
Compliance Review Timeline and Results} TTAA preparation letter issued: March 3, 2016} Preliminary reviews issued: April 1, 2016} LEA response deadline: April 8, 2016} TEA evaluation and validation: April 8-28, 2016} Final reviews issued: May 9, 2016} Enforcement issued: May 18, 2016
Status Preliminary Review
Final Review
Compliant 1036 1147Noncompliant 157 46
Compliance Review Timeline and Results
* elevates the LEA’s risk assessment level, which may lead toa referral for subrecipient monitoring
LEA Response to Preliminary # of LEAs
300.204(a) — Voluntary departure 104
300.204(b) — Decrease in enrollment 20
300.204(c) — Exceptionally costly program 25
300.204(d) — Long-term purchase 6
300.204(e) — Assumption of high cost grant 7
300.205 —Adjustment to fiscal effort 21
Significant PEIMS errors* 22
SHARS Reimbursement Report Form error* 8
Significant PEIMS Errors} Refer to IDEA-B LEA MOE Guidance Handbook, pages 7 and 8.
} Significant is defined as “corrections that change the LEA’s compliance status (from noncompliant to compliant or compliant to noncompliant).”
} Any decision to use revised data in the calculation of final IDEA-B MOE compliance will not change the official PEIMS data.
} Elevates LEA risk assessment level, which may lead to a referral for subrecipient monitoring.
Change in Fiscal Years
} No impact to IDEA-B LEA MOE.} Actual financial data reported through the PEIMS collection system must be on a twelve-month basis.
} The independent auditor is required to apply procedures to the district’s processes involving the aggregation and reporting of actual financial data on a twelve-month basis[Financial Accountability System Resource Guide,1.1.12 Change in Fiscal Year].
Common Mistakes in Use of IDEA-B LEA MOE Calculation Tool
Common Mistake Accurate Data SourcePulling incorrectMidyear Data Collection
Select Midyear Data Collection thatreports previous year audited financial data.
For instance:Pull 2016-‐2017 Midyear Data Collection for 2015-‐2016 audited financial data.• PRF1D008 (PEIMS Edit Plus), or• PDM2-‐101-‐002 (TSDS)
Common Mistakes in Use of IDEA-B LEA MOE Calculation Tool
Common Mistake Accurate Data SourceUsing Function 93
Function Codes Not Used in MOE Determination The function codes listed in the following table do not meet the requirements of the IDEA regulations and are not used to aggregate state and/or local expenditures within PIC 23 and PIC 33.
Function Description 35 Food Service 52 Security/Monitoring Service 61 Community Service 71 Debt Service 81 Facilities Acquisition and Construction 91 Contract Services 92 Cst/Sl WADA 93 PMT – SSA 95 PMT – JJAEP 97 PMT – TIF99 Other Intragov Chgs
[IDEA-‐B LEA MOE Guidance Handbook, Page 12 of 17]
Use amount reported on your behalf by the fiscal agent for Fund 437expenditures.
Your fiscal agent should be able to provide your amount from one of these applicable Midyear Data Collection reports:• PRFBD001 (PEIMS Edit Plus), or• PDM2-‐100-‐015 (TSDS)
Common Mistakes in Use of IDEA-B LEA MOE Calculation Tool
Common Mistake Accurate Data SourcePulling incorrect Summary of Finance report
Use first “Near Final” payment cycle report of September.
Using DPE column Use LPE column.SHARS reimbursements expended in special education
Use data certified and submitted to TEA in the SHARS Reimbursement Report form.
Special education student counts
Use total IDEA-‐B student count. LEA pulls applicable Fall Data Collectionreport:• PRF5D010 (PEIMS Edit Plus), or• PDM1-‐121-‐003 (TSDS)
SHARS Medicaid Reimbursements Expended in Special Education} Medicaid funds will not be considered “state or local” funds for purposes of the maintenance of effort [34 CFR 300.154 (g)(2)].
} Each individual LEA reports SHARS reimbursements expended on annual SHARS Reimbursement Report Form.
} Fiscal agents provide member LEAs with amount of SHARS reimbursements expended in Fund 437 expenditures.
} Late submission of SHARS Reimbursement Form elevates LEA risk assessment level.
Open-enrollment Charter schools and IDEA-B LEA MOE} Calculation tool used to impute local expenditures for IDEA-B LEA MOE.
} Imputing local for charter schools may result in false representation of local funds if charter expenditures are solely from state foundation aid (Fund 420) expenditures.
} Charter schools eligible to meet compliance with $0 local expenditures and $0 budgeted for local for eligibility standard.
Statutory Exception Documentation
} Submission requirements (all of the following):1. IDEA-B LEA MOE Exceptions Workbook,2. IDEA-B LEA MOE Certification, signed by the superintendent, and
3. Supporting documentation to justify the amounts reported in the IDEA-B LEA MOE Exceptions Workbook for each of the allowable exceptions.
Statutory Exception Documentation
} Supporting documentation must show account code structure:◦ Fund Code: 199 ◦ Object Code: 61xx, 62xx, 63xx, etc. ◦ Fiscal Year ◦ Program Intent Code: 23/33
Statutory Exception Documentation
} Supporting documentation:◦ Year-to-date account payroll distribution journal with� Letters of resignation or retirement � Human resource personnel action form
◦ General ledger records
◦ Reports generated from general ledger
} All documentation listed above must clearly show account code structure.
Statutory Exception Documentation
} Example of insufficientdocumentation
} TEA not able tovalidate or approvewithout accountcode information
Statutory Exception Documentation
} Example of sufficient documentation} TEA able to validate and approve because account code structure information is included
Clarification – “Exceptionally Costly Program” Exception} Example of LEA claiming $10,740.62 in the Exceptions Workbook for an exceptionally costly program for one student
Clarification – Exceptionally Costly Program Exception
Subsequent Years Rule
} The Subsequent Years Rule prescribes the level of effort an LEA must meet in the year after the LEA fails to maintain effort (34 CFR 300.203(c)).
} The LEA must determine the most recent fiscal year in which the LEA met MOE for the test method used.
Subsequent Years Rule} Example of first page of Final IDEA-B LEA MOE Compliance Review
} At preliminary, LEA’s results matched TEA’s results (note that the LEA was already compliant by passing Test 1)
} TEA approved $33,133.08 of statutory exceptions
Subsequent Years Rule} Example of second page of Final IDEA-B LEA MOE Compliance Review
} Using Subsequent Years Rule, the comparison amounts that will be used for 2015-2016 IDEA-B LEA MOE are indicated for each test method
} Division of Federal Fiscal Compliance and Reporting◦ [email protected]◦ (512) 463-9127
} IDEA-B LEA Maintenance of Effort page of TEA website◦ IDEA-B LEA MOE Guidance Handbook◦ IDEA-B LEA MOE Calculation Tool and Instructions◦ IDEA-B LEA MOE Exceptions Workbook ◦ SHARS and IDEA-B LEA MOE Guidance◦ Statutory authority◦ Compliance review process◦ Federal guidance links
Contact and Resource Information
