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1Developed by the Office of Title I
2
I. To provide an overview of Title I requirements that must be implemented in schools and districts.
II. To enable the program director to implement Title I policies at the school and district level.
III. To provide technical assistance and support to the Title I program director(others) responsible for Title I program design and implementation.
Goals and Objectives
3
1. Overview of Elementary and Secondary Education Act 2. Intents and Purpose of Title I 3. Eligibility4. Comprehensive Needs Assessment5. Program Requirements 6. Supplement vs. Supplant7. Serving Nonpublic School Students8. Professional Development9. Paraprofessionals10. Family and Community Enagagement11. ESEA Flexibility
Agenda
The Early Years – In the Classroom
Signing of the Elementary and Secondary Education Act (ESEA) of 1965
http://www.youtube.com/watch?v=QQzCV1UdPLc
Title I, Part A: Intent and Purpose
Public Law 107-110 Section 1111-1127 : Improving the Academic Achievement of the Disadvantaged
Improving Basic Programs Operated by Local Education Agencies (LEA) provides supplemental funding to state and LEAs for resources to help schools with high concentrations of students from low-income families provide a high quality education that will enable all children to meet the state’s student performance standards.
6
Title I - A Brief History
1965 - Elementary and Secondary Education Act1981 - Educational Consolidation and Improvement Act
(Chapter 1)1988 - Reauthorized – focus on accountability1994 - Improving America’s Schools Act (Title I) 2001 - No Child Left Behind2008 - New Rules – CFR 2002010 - Secretary’s Blueprint for Reform2011- ESEA Flexibility Waivers2014- Renewal of ESEA Flexibility Waivers
Scope of Title I-Nationwide
2011-2012 School Year*
Federal allocation of over $14 billiono Title I represents the largest federal elementary and secondary
education program
Over 66,000 schools
Over 23 million students served
*US Department of Ed-Data Express (http://eddataexpress.ed.gov/index.cfm
8
Scope of Title I in New Jersey
2011-2012 School Year
Allocation of $302,805,798388, 681 students served (over 7,000 nonpublic)Supplemented instructional programs in English Language
Arts, Mathematics, Science, Social Studies and CTEProvided support services: guidance, medical, dental, eye
care (Title I Schoolwide and Homeless)
9
DETERMINING TITLE I ELIGIBILITY
10
Eligibility Eligible School Attendance Area (§1113)
The proportion of economically disadvantaged students in a school determines the amount of funds that may go to a school.
Any student enrolled in an eligible school may receive Title I services if they are low achieving.
All Title I funds must be distributed and accounted for.
Low-income nonpublic school students in served school attendance areas must receive an equitable share.
11
Eligibility
1. Select poverty criteria: Free/reduced lunch, TANF, Medicaid, Composite, Feeder Method
2. Rank Schools: Based on the percentage (not number) of children from low-income families.
3. Serve Schools75% rulePoverty rate at/above district poverty rateGrade-span grouping
Poverty rate below 35% Per pupil expenditure calculated at 125% or 1.25 times the district per pupil
amount
Poverty rate ≥ 35%
12
COMPREHENSIVE NEEDS
ASSESSMENT
13
Comprehensive Needs Assessment
Includes the input of all stakeholder groupso Teachers, administrators, families, community members, students
(if appropriate) and technical assistance providers
Ongoing process that is summarized in the district’s Consolidated Application
Foundation for the use of Title I funds
Expenditures not supported by comprehensive needs assessment are not “necessary and reasonable.”
14
Purpose: Enable schools to identify their strengths and weaknesses, so they can specify priority problems and plan activities to help improve student achievement and meet state academic standards. The following can be used: State assessments
District commercial tests and other data
Teacher tests and observations
Surveys and stakeholder input
15
Data-Driven Decision Making
The problems selected by the district require an adequate description that identifies the following:
The target population The causes of the problem The identification of the data source The analysis of the data, areas to be measured The measurement tool The specific school targets
16
Priority Problems
TITLE I PROGRAM DESIGN
17
Targeted Assistance and Schoolwide Programs
Title I supports schools in implementing either a school-wide program or a targeted assistance program. These programs must use effective methods and instructional strategies that are grounded in scientifically based research.
18
Targeted Assistance SchoolwidePoverty Threshold 40%
Targeted Assistance Programs (TAS)
Title I funds are used only for services for eligible children who are failing or at risk of failing to meet state standards.
Eight required program components
Must identify student eligibility for services.
19
Targeted Assistance Programs (TAS)
20
Establish entrance and exit criteria based on multiple, objective, and uniform criteria such as:
● Assessment results, teacher recommendations, and parent recommendations
● Children who have the greatest academic need receive Title I services
● Districts may need to prioritize the student selection to provide a meaningful program
Targeted Assistance Programs (TAS)
21
Eight Essential Components (§1115) 1. Assist students in reaching state standards2. Are based on effective means for improving student achievement3. Ensure appropriate planning4. Use instructional strategies effectively by minimizing pull-out and offering
in-class support or extended day and summer programs5. Coordinate with and support regular education programs such as pupil
services (counseling, mentoring) and transition programs6. Offer instruction by highly qualified staff7. Provide professional development8. Use strategies to increase parental involvement
Targeted Assistance Programs (TAS)
Instructional and Programmatic Strategies
● In- class support● Extended year programs● Summer programs● Transition programs● Coaches● Test prep classes● Specified professional development
22
Schoolwide Programs
23
34 CFR 200.25
“[t]he purpose of a schoolwide program is to improve
academic achievement throughout a school so that all
students, particularly the lowest-achieving students,
demonstrate proficiency related to the State's academic
standards . . .”
Schoolwide Programs (SW)
24
Criteria (§1114)
● Title I funds are used to upgrade the educational program of the entire school to meet the state’s academic standards.
● 40 percent or more of the students enrolled in the school, or residing in the school attendance areas, must be from low-income families.
● A comprehensive needs assessment must be conducted.
● The district must meet with stakeholder group when developing the schoolwide plan
Ten (10) Components of a Schoolwide Program
COMPREHENSIVE NEEDS ASSESSMENT
INCREASE PARENTAL INVOLVEMENT
SCHOOLWIDE REFORM STRATEGIESTRANSITION OF PRESCHOOL
CHILDREN
HIGHLY QUALIFIED TEACHERSTEACHER DECISIONS REGARDING
ASSESSMENT
PROFESSIONAL DEVELOPMENTASSISTANCE TO
AT-RISK STUDENTS
RECRUITMENT AND RETENTION OF
HIGHLY QUALIFIED TEACHERSCOORDINATION & INTEGRATION OF
SERVICES & PROGRAMS25
Title I Schoolwide Plan
Reflects 10 components of a schoolwide programs
Annual requirement
Submitted with district’s Consolidated Application
26
Title I Schoolwide Plan
The schoolwide plan must include the following three elements:
1. A description of how the school will implement the mandatory schoolwide program components described below;
2. A description of how the school will use resources from Title I and other resources to implement those components; and
3. A list of federal, state, and local programs that will be consolidated in the schoolwide program.
27
Stakeholder EngagementESEA §1114(b)(2)(B)(ii)
The schoolwide plan should be developed with the involvement of parents and other members;
Provide all students in the school the opportunity to meet the state’s proficient and advanced levels of student academic achievement;
Use effective methods and instructional strategies that are grounded in scientifically based research; and
Strengthen the core academic program in the school. 28
Evaluation34 CFR § 200.26 (c)
A school operating a schoolwide program must—
Annually evaluate the implementation of, and results achieved by, the schoolwide program, using data from the State's annual assessments and other indicators of academic achievement;
Determine whether the schoolwide program has been effective in increasing the achievement of students in meeting the State's academic standards, particularly for those students who had been furthest from achieving the standards; and
Revise the plan, as necessary, based on the results of the evaluation, to ensure continuous improvement of students in the schoolwide program.
29
Needs AssessmentESEA §1114(b)(1)(A)
Schools must perform a comprehensive needs assessment of the entire school.
The assessment must be based upon information that includes the achievement of children in relation to the State academic content standards and the State student academic achievement standards.
30
Reform StrategiesESEA§1114(b)(I)(B)
Provide all students in the school the opportunity to meet the state’s proficient and advanced levels of student academic achievement
Use effective methods and instructional strategies that are grounded in scientifically based research
Strengthen the core academic program in the school31
Reform Strategies
ESEA§1114(b)(I)(B) Increase the amount and quality of learning time (i.e.,
extended school year , before and after school programs, and summer programs)
Provide an enriched and accelerated curriculum Meet the educational needs of historically underserved
populations Include strategies to address the needs of ALL children in
the school (particularly, the needs of low-achieving students)
32
Family and Community Engagement ESEA§1114(b)(1)(F)
Schoolwide plans must contain strategies to involve families and the community in assisting children to do well in school
Families and communities must be involved in the planning, implementation, and evaluation of the schoolwide program
33
SUPPLEMENT NOT
SUPPLANT
Supplement Not Supplant
Schoolwide Programs
Schoolwide Programs: Programs and services do not have to be supplemental; Title I funds used to support the program must be supplemental. ● District cannot reduce schools’ state/local funding based on an
increased Title I allocation. ● The amount of state/local funding to schools must be sufficient to
support the school’s basic educational program. ● Documentation that schools have enough state/local funds to fully
operate without federal funds.● District must be able isolate the state/local funds needed for schools
in current year and prior years.
Supplement Not Supplant
Targeted Assistant Programs and District-Level ExpendituresPresumption of supplanting
The district has used the Title I funds to provide services that the district was required to make available under federal, state or local law.
The district used Title I funds to provide services it provided with non-federal funds in the prior year(s).
The district has used Title I funds to provide services for participating children that it provided with non-federal funds for non-participating children.
Supplement Not Supplant
Targeted Assistance Program Scenarios
District has 3 elementary schools. School A and B are Title I-funded schools with a Targeted Assistance Program. School C is not a Title I school. The district wants to pay the salaries of its basic skills teachers in School A and B with Title I funds and will pay the salaries of its basic skills teachers in School C with local funds. Is this allowable?
NO! This is supplanting.37
Supplement Not Supplant
Targeted Assistance Program Scenarios
A district with a Targeted Assistance Program has an afterschool program for its Title I students. With Title I funds, it wants to pay the salary of the Title I teacher, instructional materials for the students in this afterschool program, and iPads for the students to use as part of the program. Are all of these things allowable?
YES! All of these costs are supplemental and used for Title I teachers/students only.
38
Supplement Not Supplant
Targeted Assistance Program Scenarios
The school would like to send all of its Math teachers to a Math Recovery professional development program that provides a powerful mathematics intervention framework that gives teachers the unique techniques and assessment tools they need to help elementary children achieve lifetime results. Is this allowable?
NO! In a Targeted Assistance program, Title I funds for professional development may benefit Title I staff only.
39
Supplement Not Supplant
Targeted Assistance Program Scenarios
The school wants to contract with reading expert to provide onsite professional development on techniques and assessment tools to help low-achieving students achieve lifetime results. The school would like every teacher to participate in the professional development. Is this allowable?
YES! The district may pay for a consultant/expert to come to school district to provide professional development that primarily benefits Title I staff. The other teachers may attend as "incidental benefit."
40
Supplement Not Supplant
Targeted Assistance Program Scenarios
A Title I school with a Targeted Assistance Program would like to put in three SmartBoards in English language arts classes where the majority of students (about 70%) are Title I. Is this allowed?
NO! Title I instructional equipment may benefit Title I students only.
41
Supplement Not Supplant
Targeted Assistance Program Scenarios
A Title I school with a Targeted Assistance Program would like to use Title I funds to hire a data analyst, a Math Coach and a Literacy Coach. Is this allowed?
Possibly, but not advisable! The services of these staff would have to be limited to Title I students only. This is a high bar to meet in a targeted assistance program, so it is advisable for the district to use it state/local funds for these positions.
42
SERVING ELIGIBLE
NONPUBLIC STUDENTS
43
Equitable Service Provision ESEA §1120
Requires districts receiving Title I, Part A funds to provide services to:
Eligible nonpublic students
Teachers of eligible nonpublic school students
Families of eligible nonpublic school students
44
Equitable ServicesWhy?
Census poverty data includes low-income families with nonpublic school children
Census poverty data used to determine districts’ Title I allocations
Child Benefit Theory: Funds benefit child ONLY
45
Child Benefit Theory34 CFR § 200.66
Title I services benefits the “individual” child, NOT the entire school.
Services are provided by the district, not the nonpublic school
Child Benefit Theory complies with the Constitutional Prohibition against Federal funding- No funds are to EVER go to the nonpublic school!
46
Equitable Service Provision ESEA §1120
Step 1: Locating Nonpublic Students
Step 2: Counting Nonpublic Studentso Enrollment data, Income data
Step 3: Generating Nonpublic Allocation
47
Equitable Service Provision ESEA §1120
Step 1: Locating Resident Nonpublic Students
Resident nonpublic schools
Bordering nonpublic schools
Transportation Documents (Busing routes, Aid-in-Lieu)
48
Equitable Service Provision ESEA §1120
Step 2: Counting Resident Nonpublic Students
Enrollment data: match resident nonpublic students to their public school attendance area
Low-income data: Contact schools enrolling resident nonpublic students
• Various methods: survey, extrapolation, proportionality, equated m49
Equitable Service Provision ESEA §1120
Step 3: Generating Nonpublic Allocations
Who: Nonpublic students who 1) live in the attendance area of a Title I public school and 2) come from low-income families
How: District enters enrollment and low-income numbers into its annual Title I, Part A application
How much: The same per-pupil amount as public schools students residing in the Title I attendance area
50
Participation of Students Enrolled in Private Schools (ESEA § 1120 )
● An eligible private school student resides in the participating attendance area of the school district and is selected on the same basis as targeted assistance students.
● The district in consultation with non-public school official(s) MUST establish clearly defined entrance and exit criteria to meet the needs of eligible nonpublic school children using multiple, educationally related, objective criteria (i.e. Achievement tests, teacher referral/recommendations based upon objective, and educationally related criteria; and grades)
51
Allocating Funds
District reserves off the top –
If a district reserves funds for instructional related activities for public school students at the district level, the district must also provide from these funds equitable services to eligible nonpublic school children.
Amount of funds must be proportional to the number of nonpublic school children from low-income families residing in public school attendance areas.
52
Allocating Funds
Not eligible for equitable services o N&D/ Homeless
Eligible for equitable services o Parental Involvement
o Professional Development
o Districtwide Instructional Programs
53
Consultation
Consultation between the public school and private schools, during the design and development of the programs:
● Must be timely and meaningful.● Must take place on an annual basis, and be documented by the
district: sign in sheets, agenda, written affirmation. ● Must continue throughout the year, to ensure the needs of private
school students are being met.● Shall occur before the school district makes any decision that affects
the opportunities of eligible private school children, teachers, and other educational personnel to participate.
Delivery of Services
● Under control and supervision of the public school.
● The public school maintains control of all materials, supplies, equipment, and property acquired with Title I funds for the benefit of eligible private school students.
● Services for private school children must begin at the same time as services for public school children.
Delivery of Services
Key word is services. No public funds are
distributed to private schools, only services and
materials..
Delivery of Services Examples
● Instructional services outside the regular classroom.● Extended learning time (before/after school and in the
summer).● Family literacy programs.● Counseling programs.● Early childhood.● Home tutoring.● Computer-assisted instruction.
Delivery of Services
Materials and supplies purchased with Title I funds
may ONLY be used by the “identified” Title I students
in the Title I program.
Must be supplemental and may not replace or
supplant services that would, in the absence of Title
I, be provided by nonpublic school to participating
nonpublic school children.58
Evaluation
The district in conjunction with nonpublic officials
MUST define ‘annual progress’ for nonpublic school
Title I participants. If annual progress is not met, the
district in conjunction with nonpublic officials must
modify the Title I program.
59
PROFESSIONAL DEVELOPMENT
60
Professional Development
Must be sustained, high-quality, classroom-focused training in core content areas and strategies that work
Use of Title I funds for PD will vary depending upon Title I program
Title I teachers, principals, paraprofessionals, and other staff may participate.
61
Allowable Uses
Strategies tied to the state’s academic standards, state student performance standards and consistent with the district’s needs assessment
Activities involving parents in the education of their children
Activities addressing the needs of teachers in Title I schools and students most “academically” at-risk
Activities incorporating teaching strategies in the CCSS/CCCS areas for meeting the needs of “academically” at-risk students
62
PARAPROFESSIONALS
63
Requirements
Instructional paraprofessionals in targeted assistance and schoolwide programs MUST meet one of the following criteria:
● Have an Associate’s Degree or higher
● Completed two years of college coursework
● Passed a rigorous test showing the ability to assist with the teaching of reading, writing, and mathematics
64
Duties
1. Provide one-on-one tutoring when a student is not being instructed by a teacher.
2. Assist with classroom management.
3. Provide instructional assistance in a computer lab.
4. Conduct parental involvement activities.
5. Provide support in a library/media center.
6. Act as a translator.
7. Provide instructional support under the direct supervision of a teacher.
65
FAMILY AND COMMUNITY ENGAGEMENT
66
Why Family and Community Engagement?
It is required by law.
It helps raise student achievement.
67
Family and Community Engagement
Parent involvement is one form of family and community
engagement
The Title I statute defines the term “parental involvement” as the
participation of parents in regular, two-way, and meaningful
communication involving student academic learning and other
school activities.
68
Family and Community Engagement
Applies to all Title I districts & schools.
Comprehensive and based upon families’ needs.
Benefit the greatest number Title I families who have
children being served in Title I programs.
One-percent reserve of Title I allocations over $500,000.
69
Family and Community EngagementDistrict Set-Asides
Districts receiving $500,000 or more in Title I, Part A funds must set aside, at minimum, 1% for family & community engagement purposes, including promotion of family literacy and developing parenting skills. 95% of the district set-sides must be allocated to Title I buildings for building-level family and community engagement activities.
Districts < $500,000 must also provide family and community engagement opportunities at the district and building levels.
Parents’ Right-to-Know (§1111)
At the beginning of the school year Title I district must notify parents of their right to request the following information regarding their child’s teachers:
Whether the teacher has met state qualifications and licensing criteria. Whether the teacher is under emergency or provisional status.
Whether the teacher has a baccalaureate degree, certification in the discipline field and other pertinent education.
Whether the child is provided services by paraprofessionals, and, if so, their qualifications.
Schools must notify parent when their child has been taught for four consecutive weeks by a teacher not highly qualified.
71
Language Instruction Education Program (§1111)
72
Not later than 30 days after the beginning of the school year, the district is required to inform the parent (s) of a limited English proficient child identified for participation in a language instruction educational program of the following:
●The reasons for the identification of their child as limited English proficient and in need of placement in a language instruction educational program.
●The child’s level of English proficiency, how such level was assessed, and the status of the child’s academic achievement.
The Written Parental Involvement Policy (§1118)
Describes how the district will:● Involve parents in developing the district’s plan for school review and improvement
● Provide coordination, assistance and support to assist in planning and implementing effective parental involvement activities to improve student performance
● Build schools’ and parents’ capacity for strong parental involvement
● Coordinate and integrate parental involvement strategies with other programs (e.g., Head Start, Reading First etc.)
● Conduct an annual evaluation of the content and effectiveness of the parental involvement policy
● Involve parents in the activities of schools served under Title I
73
The Written Parental Involvement Policy (§1118)
School Policy Requirements
Each school must develop, jointly with parents of children participating in Title I services, a written school parental involvement policy that describes how the school will carry out the parental involvement requirements in §1118(c)-(f), including the development of a parent compact
74
The School-Parent Compact: Shared Responsibility for High Student Achievement (§1118 )
Each school must develop a school-parent compact jointly with parents, student and teachers of students receiving Title I services that outlines:
How parents, the entire school staff, and students will share the responsibility for improved student academic achievement.
How the school and parents will build and develop a partnership to help children achieve the state’s high standards.
75
Annual Parent Meeting§1118(c)(1)(2)
All Title I funded schools invite parents to attend a meeting to inform parents of Title I program
Meeting must be documented (invitational flyer/letter, agenda, sign-in-sheets, and minutes)
76
Title I Parental InvolvementNotification Requirements for Districts
77
http://www.state.nj.us/education/title1/program/parent/resources/Requirements.pdf
* Includes sample templates
ESEA FLEXIBILITY
78
10 Areas Subject to Waiver
1. District improvement requirements2. School improvement requirements3. 100% Proficiency by 2013-2014 4. Rural districts5. Schoolwide Programs6. Rewards schools7. Supports for schools in need of improvement8. Highly-qualified teacher plans9. Transferability10. Use of School Improvement Grant (SIG) funds
79
Waiver Implementation 2012-2014
● Schools no longer identified as schools in need of improvement.
● Identify priority schools (lowest 5% of Title I participating and/or eligible schools)
● Identify focus schools (10% of Title I schools that contribute to the achievement gap)
80
Waiver Implementation 2012-2014
Progress Targets: The NJDOE will calculate Progress Targets for schools and districts based on the goal of closing the achievement gap by half within six years.
The Progress Targets are set in annual equal increments toward a goal of reducing by half the percentage of students in the “all students” group and in each subgroup who are not proficient within six years.
81
Progress Targets
● The ‘all students’ group has a proficiency rate of 40%, so there is a 60% point gap between 100% proficiency and the current rate.
(100 – 40 = 60)
Divide the gap in half to determine the target for the sixth year – a gain of 30 percentage points.
( 60 / 2 = 30)
Divide the 30-percentage point gain into six equal increments to set annual targets.(30/6 = 5)
The school in begins with 40% proficiency rate, and obtain proficiency rates of 45%, 50%, 55%, 60%, 65%, and finally 70% in each of the following years of the six-year period.
82
Waiver Implementation 2012-2014
● Requirement for the NJDOE’s district and school report cards to identify a school in need of improvement and a district in need of improvement.
● Under the waiver, the Report Card will not identify schools as a School in Need of Improvement based solely on narrow AYP achievement targets.
83
Waiver Implementation 2012-2014
● Requirement for a school to have a poverty rate of 40% or higher to operate a Title I schoolwide program.
● The waiver allows districts to apply to operate a Title I schoolwide program in a Priority or Focus School with a poverty rate below 40%.
84
Waiver Implementation 2012-2014
● The requirement for districts reporting less than 100% of their teachers as meeting the definition of “Highly Qualified” to develop and implement an improvement plan.
● The waiver provides increased focus on the development of more meaningful evaluation systems for teachers.
85
Web Site Resources
NJ Department of Education http://www.nj.gov/njded/title1/http://www.nj.gov/njded/grants/nclb/http://www.state.nj.us/education/grants/nclb/waiver/
Title I Parental Involvement Notification: http://www.state.nj.us/education/title1/program/parent/resources/Requirements.pdf
US Department of Education Guidancehttp://www.ed.gov/print/programs/title1parta/legislation.htmlhttp://www.ed.gov/esea/flexibility
NCLB Consolidated Subgrant Reference Manual http://www.nj.gov/njded/grants/entitlement/nclb/nclbrefman.pd
President’s Blueprint for Reform
http://www2.ed.gov/policy/elsec/leg/blueprint/publicationtoc.html
86
● Targeted Assistance
● Schoolwide Programs
● Parental Involvement
● Paraprofessionals
● Private School Children
Web site: http://www.nj.gov/njded/title1/leg/
87
US Department of Education Non-Regulatory Guidance
What Happens When Federal $$$ Are Misspent??????
89
US Dept of Education- Office of Inspector General
90
Accountability. Efficiency. Effectiveness. Oversight
OIG Fraud News
According to court documents, on June 20, 2007, BROOKS-SIMMS pled guilty to conspiracy to commit federal program fraud. She admitted she secretly conspired with a local businessman, to approve the purchase of an educational software program for the Orleans Parish School System. Jefferson received over $900,000 of Orleans Parish School Board money as his sales commission for selling the software program to the school board. In exchange for her assistance in promoting and approving the software program, BROOKS-SIMMS received approximately $140,000 as a bribe/reward from the Jefferson. Both BROOKS-SIMMS and the Jefferson funneled these payoffs through several bank accounts to disguise their illegality. On August 21, 2009, Jefferson was convicted by a federal jury after a two week trial and has been sentenced to serve ten (10) years in federal prison.
OIG Fraud News
THOMPSON was employed at Langston Hughes Academy Charter School as the
Business and Human Resources Manager/Financial Manager beginning approximately
July 1, 2008 until approximately November 6, 2009. THOMPSON admitted that in her
position at Langston Hughes Academy Charter School, she would make cash
withdrawals while acting in her capacity as Business and Human Resources
Manager/Financial Manager and then manipulated the school’s record in order to
conceal the thefts. The amount of loss to Langston Hughes Academy Charter School is
approximately $660,000.
OIG Fraud News
PHILADELPHIA—Rosemary DiLacqua, 51, of Philadelphia, was sentenced today to a year
and a day in prison for honest services mail fraud committed while she was board president
for the Philadelphia Academy Charter School (“PACS”), announced United States Attorney
Michael L. Levy. DiLacqua accepted a total of approximately $34,000 in payments from
codefendant Kevin O’Shea, the former CEO of PACS, and another former school official that
she did not disclose on her mandatory statement of financial interest form or to the other
board members. After receiving these undisclosed payments, DiLacqua approved a series of
salary increases for O’Shea and also a 20-year consulting contract for the other former school
official that would have paid him in excess of $100,000 annually for no more than 90 days of
consulting each year. When O’Shea left PACS the following Spring (May 2008), he was
earning in excess of $200,000 in salary from PACS.
OIG Fraud News
FORMER CEO OF CHARTER SCHOOL SENTENCED TO 37 MONTHS ON FRAUD, THEFT AND TAX CHARGES
In July 2009, O'Shea entered a guilty plea admitting that he stole between $400,000 and $1 million from PACS by: (1) using approximately $710,000 in PACS' funds to purchase a building in the name of his purported non-profit business; (2) demanding kickbacks from PACS vendors; (3) submitting for reimbursement at least $40,000 in fraudulent invoices for personal meals, entertainment, home improvements, and gas and telephone bills; (4) having approximately $50,000 worth of home repairs improperly billed to PACS; (5) collecting approximately $34,000 in rent from entities using PACS facilities; and (6) hiring a computer firm in an attempt to destroy computer evidence to obstruct this investigation. O'Shea also admitted to filing a false tax return for 2006.
Board MinutesWhat should be in my Board minutes?
Resolutions to:
Apply for Funds (copy of budget statement)
Board Minutes
What should be in my Board minutes?EDGAR Part 80, Section 20
● Appointment of Teacherso Nameo Salaryo Schoolo Funding Percentage for Each Program
● Appointment of Secretaries, Aides, Program Directors, etc.o Nameo Salaryo Work Locationo Funding Percentage for Each Program
Final Expenditure Reports
● Must be consistent with budget (amendments filed through County Office) – EWEG Monitors
● CANNOT:o Move more than 10% of total funds, whichever is less, without
State approval (filed through County Office)o Add a budget category without State approval (filed through
County Office)o Carryover more than 15% of total amount received more than
once every three years without State approval (Must have good reason) – NJDOE has a Waiver in Place
Carryover of Funds(Set Asides)
Some Carryover Funds are Restricted to the Original Intent and Purpose of the Funding
**** Accounting Tracking Required ****
Parental Involvement o If these funds carried over, then can only be spent for original
intent and purpose or must be refund to SEA
Select Expenditures and Support NeededFully-funded Salaries
Periodic certification signed at least semi-annually
Signed by employee and supervisor
** New Model – October 2012
http://www.state.nj.us/education/title1/tech/schoolwide022213/ - Click on “Sample Time and Activity Reports”
Select Expenditures and Support Needed
Split-funded Salaries Personnel activity reports
Signed by employee and supervisor
Must be an after-the-fact distribution of actual activity
Prepared at least monthly and must coincide with pay periods
Select Expenditures and Support Needed
General Purchases
Must have purchase orders Must have account number on P.O. Should indicate Title I purchases Signed by Business Administrator If split P.O., Title I should be easily identifiable
REMEMBER – Money spent in Individual Schools should EQUAL amount in Step 4 of Eligibility
Select Expenditures and Support Needed
Equipment Maintain master inventory listing (Date, Serial Number, Model,
Cost, Location) Each school should maintain subsidiary listing All equipment should be labeled with “Title I” or equivalent
tracking system Need to keep records for FIVE years past disposition (date
needs to be on master list) Even if not equipment for GRANT purposes, if district has a
lower threshold, then tracking of equipment is required If less expensive to inventory than to replace, it should be
inventoried
Select Expenditures and Support Needed
Employee Benefits
TPAF/FICA reimbursement applies only to teachers’ contracted salaries, supervisors and program directors
TPAF/FICA reimbursement report does not apply to aides, secretaries or clerical, stipends, substitute teachers or summer teachers
All other benefits based on actual cost, not budgeted percentages
Select Expenditures and Support Needed
Employee Benefits – TPAF/FICA Reimbursement Report
Salaries Title 1 Other Federal Total Rate Total
Contractual Salaries
352,808.00 -
352,808.00 -
352,808.00 6.68% 23,567.57
Amounts subject to SS
352,808.00 -
352,808.00 7.65% 26,989.81 Amounts only subject - 1.45% - To Medicare
352,808.00 $ 50,557.39
Selected Items of Cost
Special rules for specific expenses Still subject to basic guidelines Examples:
o Alcohol: Never allowableo Salaries and Wages: Allowable if time
distributiono Meetings and conferences: Allowable
if dissemination of technical information
Selected Items of Cost – Student Incentives
• The US Dept. of Education(ED) has indicated that an LEA may use Title I funds to provide “non-monetary” rewards of “nominal” value (e.g., Plaque, gift certificate, or book, etc.) in an effort recognize Title I students for good performance.
• Title I funds may NOT be used to pay students a stipend or provide some other type of award as an incentive for student participation in a Title I program
Selected Items of Cost – Parent Incentives
• To encourage parents of Title I students to participate in school activities in the evening, an LEA may use Title I funds to provide light refreshments.
• Note, ESEA § 1118(e)(8) authorizes LEAs to use Title I funds for “parent-related” activities that are reasonable and necessary for expenses associated with parental involvement activities, including child care and transportation to enable parents to attend “school-related” meetings and training sessions
Helpful Questions to Ask When Analyzing Costs
Is the proposed cost consistent with federal cost principles? OMB A-87, Attachment B
Is the proposed cost allowable under the relevant program? (Title I, IDEA, etc)
Is the proposed cost consistent with an approved program plan and budget? (EWEG)
Is the proposed cost consistent with program specific fiscal rules? (Supplement not Supplant)
Is the proposed cost consistent with EDGAR?
Documentation required for both school-level and district-level expenditures
Documentation must explain: 1. How is the expenditure reasonable and necessary to carry
out the intent and purpose of the program?
2. What need, as identified in the comprehensive needs
assessment, does the expenditure address? 3. How would the program, activity, or strategy be funded if the
Title I, Part A funds are not available?
Expending Funds
109
Documentation must explain:
If for a schoolwide campus, how will the expenditure upgrade the entire educational program on the campus?
How is the expenditure supplemental to other nonfederal programs?
How will the expenditure be evaluated to measure a positive impact on student achievement?
Expending Funds
110
Allowable Costs
All Costs must be:
Necessary
Reasonable
Allocable
Legal under state and local law
Nonpublic Expenditures
Same Fiscal Rules Applyo Only your districts studentso Students that need extra services
NO longer just supplies/computer – SERVICES ARE REQUIRED
Carryovero Funds not Spent in Prior Year (Discretion)o Automatic flow of district carryover in EWEG
Nonpublic Expenditures
Third Party Provider Contracts
When bid, the specifications should have the Stephens Amendment wording
Vendor Complaint Policy Details on who provides parental involvement activities Renting/Ownership of Supplies, Trailers, etc. Breakout of Invoices to Include:
o Instructional Salaries and Benefitso Instructional Supplieso Rental of books, supplies, trailerso Administrative Charges/Profit
Nonpublic Expenditures
Third Party Provide Contracts
● Administrative Costs of Third Party Providers counts against the District’s Five Percent (5%) Total Administrative Costs
Who pays the Administrative Costs? Off the top allocation of the District of Other Title I Funds (USDOE Non Regulatory Guidance)
Fiscal Policy
District Policies on:
● Maintenance of Effort
● Comparability
● Supplement vs. Supplant
Fiscal Policy
Maintenance of Effort
Current Expenditures (Not Including Capital Outlay)o Less: Community Serviceso Divided by: Average Daily Enrollment
Compare to prior year (current year/prior year) and must be at least 90%
*** Must Be Done Annually ***
Fiscal Policy
Maintenance of Effort Example
Line Description Aggregate ExpensesAverage Daily
EnrollmentAmount Per
Student
1 Amount from 2004-2005 $ 5,098,944 377.50 13,507.14
2 Amount LEA had to Spend in 2005-2006 (90% of Line 1) $ 4,589,050 377.50 12,156.42
3 Actual Amount Spent in 2005-2006 $ 5,095,897 398.00 12,803.76
4 Amount District Failed to Maintain
5 Percent of Reduction in 2006-2007
EXCESS $ 506,847 $ 647.34
Fiscal Policy
Comparability
Compare Like-Kind Grade Span Groupings (Elementary, Middle or High – Only 3 Groupings)
Monitoring Coming Soon – Verify staffing
Schoolwide Programs
● MUST have approved plan that addresses all schoolwide issues
● Time sheets are required (except in a blended resource fund, e.g., Fund 15 for former Abbott districts)
Frequently Asked Questions
Time Sheets and Salaries
Q: Multiple Federal Grants – If someone works on multiple federal grants, must their salary be allocated to all the grants since it is one large federal pot of money?
A: Yes, since each is a separately funded program.
Fiscal News from Washington
New Haven Audit Report from Office of Inspector General
Supplanting in a Schoolwide Programhttp://www.ed.gov/about/offices/list/oig/auditreports/a02f0005.pdf
Fiscal News from Washington
William Floyd Audit Report from Office of Inspector General
Unsupported Expenses Unsupported Adjusting Journal Entries Supplanting of Textbooks Weak Internal Controls
http://www.ed.gov/about/offices/list/oig/auditreports/a02f0030.pdf
Fiscal News from Washington
City of Detroit and Parent Involvement Fund2005
Disallowed Charges for Entertainment, Promotional Items and Public Relations
Need to be necessary, reasonable, allocable and documented
Disallowed items include advertising for an event and live musical entertainment at parent volunteer functionhttp://www.ed.gov/about/offices/list/oig/auditreports/a05f0018.pdf
Fiscal News from Washington
City of Detroit -Revisit in 2008
● Over $131 Million in 2005 and $126 Million in 2006 ● No Time Sheets – Almost $50 Million● Teaching non-Title I students – even though most of Detroit is schoolwide some
schools are not (no plan submitted) and OIG looked to these schools and found staff being funded that were teaching non-Title I identified students. Detroit argued they could have been schoolwide if they did a plan and the OIG rejected this argument
● Over $21 M for adjusting entries for employees that were charged to other programs and then charged to Title I
● Gift cards they could not show got to students ● $150,000 for martial arts training
Fiscal News from Washington
OIG Audit-St. Louis
Lost 125 Computers
Serving Ineligible Schoolso http://www.ed.gov/about/offices/list/oig/areports.html
Fiscal News from Washington
OIG Audit
Kiryas Joel Union Free School District
Supplanted funds by charging rent to lease building for public school
Couldn’t Support Salaries for After School Programhttp://www.ed.gov/about/offices/list/oig/areports.html
Fiscal News from Washington
Philadelphia
Findings totaling $138,376,068Unsupported salaries (some direct and some through
adjusting entries)School police paid from Title I FundsSupplanting (moving company, etc)No backup for school choice charges of $1.3MWeak internal controls
Fiscal News from Washington
Maryland – Title I ARRA Funds Findings totaling $540,013$8,736 in gifts to staff$4,352 in Dinner Cruises in Baltimore HarborLack of Receipts for Expenses$200,323 in Unsupported Title I and IDEA Salaries$3,922 for tablets with no controls over them or
applications that are downloaded (Items against policy – 22%)
Fiscal News from Washington
• Former Charles County Public Schools Title I Coordinator Sentenced (Maryland).
• The former Title I coordinator was sentenced to serve 27 months in prison and 36 months of supervised release. She was also ordered to pay more than $115,300 in restitution for theft. The former official used Title I grant funds to purchase technology items for herself, family, and friends, including computers, video games consoles, portable media players, tablet computers, and televisions.
Fiscal News from WashingtonSandra Campbell, 57 a former Detroit Public Schools contract accountant and school board candidate, and her daughter, Domonique Campbell, 38, a Detroit Public Schools teacher, were convicted today by a federal jury in Detroit on charges of program fraud conspiracy, money laundering conspiracy, and tax charges following a five-week jury trial, United States Attorney Barbara L. McQuade announced today. The jury returned its verdict after only one-and-a-half hours of deliberations.
McQuade was joined in the announcement by FBI Special Agent in Charge Robert D. Foley, III and Special Agent in Charge, Erick Martinez, Internal Revenue Service, Criminal Investigation.
The evidence presented at trial established that between 2004 and 2008, Sandra Campbell and Domonique Campbell obtained in excess of $530,000 from the Detroit Public Schools through a fraudulent scheme in which orders were placed with the Campbells’ sham company for books and educational materials never provided to the schools. Sandra Campbell and Domonique Campbell conspired to launder the fraud proceeds and to defraud the Internal Revenue Service and failed to report the money they fraudulently obtained from the Detroit Public Schools as income on their tax returns.
United States Attorney Barbara L. McQuade said, “Anyone who considers stealing from our school children should take note that we are scrutinizing records and conduct, and will prosecute wrongdoers.”
Common Audit Findings
Lack of time sheets (or signature of employees/supervisors)
Improper payroll distribution (not pro-rated)
Purchase orders not indicating Title I (and adjusting entries to reclassify amounts)
Common Audit Findings
Policies not being updated for current law
Supplanting on purchases of non-salaried items
Not spending at the schools approved in the application
Not liquidating within timelines (now less than prior year)
Conclusion
Remember: “If you take the money, you are responsible for
knowing the rules and regulations concerning the grant.”
If you need further help contact Anthony Hearn o(609) [email protected]