GRANTS AND RELATED REQUIREMENTS
See Federal Grant Policies and Procedures Manual for pursuant to requirements in 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, and Education Department General Administrative Regulations (EDGAR)
According to P.L. 103-382, §1120A (b) and 34 CFR 200.63 the fiscal requirement of supplement, not supplant is to ensure the level of state and local support for programs remain at least constant and cannot be replaced by federal funds. Documentation must be maintained which clearly demonstrates the supplementary nature of federal funds and/or activities as appropriate. The test to determine if you are supplanting is to ask whether the programs supported with Special Revenue Funds would, in the absence of those funds, have been supported with state and local funds. If your answer is yes, this is supplanting and state and local funds may not be diverted to another purpose simply because Special Revenue Funds are available to support those activities. If your answer is no, the funds are being used to supplement the educational program, not supplant state and local funds. The exception to this rule for special revenue was or is the use of Stabilization Funds provided by the federal government through TEA for the recovery of the economy.
Special revenue funds must supplement or augment funds that are required by state law, State Board of Education (SBOE) rule, or activities which have been adopted as policy by a local school board. If Special Revenue Funds are used to enhance or expand a state mandate, SBOE rule, or local policy, the supplementary activities funded by the Special Revenue program must be separately identified and clearly distinguishable from those activities identified as necessary for implementing a state mandate, SBOE rule, or local board policy as outlined in an implementation plan.
Any refund of state, federal or special funds must be deposited to the original fund account. Any refunds should never be deposited in the General Operating Fund.
All encumbrances shall occur on or between the beginning and ending dates of the grant. The grant period begins with receipt of the NOGA from TEA. All goods must be received and services rendered and subsequently liquidated (recorded as an expenditure or accounts payable) within the grant dates (for formula grants, within 30 days after the grant end date). Obligations that are liquidated and recognized as expenditures must meet the allowable costs principles in Office of Management and Budget (OMB) Circular A-87, A-21, or A-122 (as applicable) and in program rules, regulations, and guidelines contained elsewhere. Administrative requirements for grants stipulate you must request cash as close as possible to the time of making disbursements. The cash on hand should not exceed three days' cash needs.
Funds can be released to third party if purchase order, packing list, and invoices are reconciled. An expenditure report can be submitted to TEA through the Expenditure Reporting (ER). Encumbered funds are ineligible for draw down. Monthly expenditure reports shall be filed with TEA. The expenditure report is kept on file with payment receipt from TEA.
Payments through Expenditure Reports (ER) should be deposited into your depository bank within six to seven business days of the request.
The district shall maintain written procedures for determining the allowability of costs in accordance with EDGAR, and the terms and conditions of the Federal award. See Federal Grant Policies and Procedures Manual for further information.
Use the Financial Accounting and Reporting (FAR) Module of the Financial Accountability System Resource Guide to determine appropriate accounting codes. Documentation for all expenditures for each fund source on the eGrants application must be maintained.
Documentation that local funds are used if either travel or transportation expenditures exceed state rates must be maintained.
An application or amendment must be approved by TEA before the initiation of any activities affected by that application or amendment, such as purchase orders issued, funds encumbered or expended, goods received, or services rendered. Applications or amendments received in substantially approvable form for projects funded on a formula or discretionary basis become effective on the date received by TEA (stamp-in date/date of certification by the LEA) or the project begin date, whichever is later.
Funds may be transferred between major objects of expenditures budgeted on Schedule BS6006 -Program Budget Summary and Support, without an amendment if the cumulative total transferred does not exceed 25% of the total current approved budget, funds are already budgeted in the class/object codes involved, and the requested cost items do not require specific approval. Items in class/object codes 6600 always require specific approval.
Budget Amendment will be requested to TEA if:
- Class/object code exceeds 25% of the approved budget
- Increase or decrease in the number of personnel funded in grant
- Addition to the original approved budget
- Increase or decrease to capital expenditures
TRS, Medicare, health insurance, longevity pay, critical needs stipends, and incentive pay will be deducted from grant budgets if payment of fringe benefits is permitted by grant guidelines as a part of payroll expenses. Federally funded grants normally allow for payment of all fringe benefits listed above. State of Texas grants do not normally permit TRS deductions. Fringe benefit expenses should be discussed with the Chief Financial Officer and Executive Director School Support during the grant writing process if the budget includes any payroll expenses.
Title I, Part A -The purpose of Title I is to enable schools to provide opportunities for children served to acquire knowledge and skills contained in the challenging State content standards and to meet the challenging State performance standards developed for all children. This purpose is accomplished by:
- Ensuring high standards for all students
- Providing students with an enriched and accelerated educational program including the use of arts, school wide programs, or the increase of the amount and quality of instructional time so that students served with Title I funds receive at least the classroom instruction that other students receive;
- Promoting school wide reform and ensuring access of children to effective instructional strategies and challenging academic content that include complex thinking and problem solving experiences;
- Providing substantial staff development opportunities to significantly upgrade the quality of instruction;
- Coordinating all Title I services with each other, with other educational services, with health and social service programs funded from other sources;
- Affording parents meaningful opportunities to participate in the education of their children at home and at school;
- Distributing resources, in amounts sufficient to make a difference, to areas and campuses where needs are the greatest;
- Improving accountability by using the State assessment system to measure how well Title I students are achieving the challenging State student performance standards expected of all students; and
- Providing greater decision making authority and flexibility to schools and teachers in exchange for greater responsibility for student performance.
Regulations provide that school wide programs must include a comprehensive needs assessment to determine the performance of its children in relation to the State assessment system and student performance standards, school wide reform strategies, highly qualified professional staff; professional development for teachers and other staff, increased parental involvement, plans for assisting children in the transition to receiving schools, measures to include teachers in the decisions regarding the use of assessments, and effective, timely additional assistance for students who experience difficulty mastering any of the performance standards.
Title I Part A funds are used in a school wide setting when the campus eligibility includes 40% or more of the students enrolled or living in the school's attendance area meets the district's low income criteria. All funds must benefit the children in the current funding year therefore it must be expended before the middle of the spring semester. The use of the funds must be referenced in the campus improvement plan.
Title II, Part A -The purpose of Title II, Part A, is to increase the academic achievement of all students by helping schools and school districts improvement teacher and principal quality and ensure all teachers are highly qualified. Funds are received through a formula basis.
Districts are required to ensure that their strategies and funded activities are grounded in scientifically based research so that students benefit from those researched based teaching practices and methods. Schools and districts are given expanded flexibility to address the need for qualified teachers and principals not only through professional development for existing staff, but through efforts that include attracting qualified individuals into teaching and offering financial incentives and other structural changes to retain them.
The intent and purpose of the Class-size Reduction Program is to reduce the class size using highly qualified teachers to increase achievement for regular and special needs students by providing personal attention and a solid foundation for further learning so that all students learn to read independently. School wide programs that use Class-Size Reduction Program funds must reduce the size of classes, particularly in the early grades, using highly qualified teachers to increase achievement for regular or special needs children. The District again, must use these funds only to supplement, and not supplant state and local funds that, in the absence of the federal funds, would otherwise be spent for activities authorized by Class-Size Reduction.
The Title II funds must benefit the staff in the current funding year with requisitions being submitted in a timely manner. Title II funds may only be used to purchase materials for training purposes and not for classroom implementation. Allowable costs for the Title II, Part A program include recruitment, preparation and professional development, mentoring activities for new teachers, meeting the requirements for becoming highly qualified and expand performance systems that provide differential pay and bonuses for teachers who teach in specific schools and subject areas.
Title III, Part A - LEP -The purpose of Title III, Part A is to improve the education of limited English proficient children by assisting the children to learn English, meet challenging State academic content and meet student academic achievement standards. All activities must use approaches and methodologies based on scientifically based research to teach ELL and immigrant children to develop and implement new language instruction educational programs and academic content instruction programs including programs of early childhood through secondary school; carry out highly focused, innovative, locally designed activities to expand or enhance existing language instruction education program; implement within an individual school, school-wide programs for restructuring, reforming, and upgrading all relevant programs, activities, and operations relating to language instruction educational programs; and implementing, within the entire jurisdiction of the LEA, LEA-wide programs for restructuring, reforming and upgrading all relevant programs, activities, and operating relating to language instruction educational programs and academic content instruction for LEP children.
Title I, Part C, Carl D. Perkins Grant -The purpose of Title I, Part C, is to develop more fully the academic and technical skills of secondary students who elect to enroll in career and technical education (CTE) programs.
The grant has a project start date of July I and an end date of June 30th. The supplement not supplant guideline is effective for this grant.
The following are goals for CTE grant:
- Integrate academics with CTE programs using a coherent sequence of courses
- Link CTE at the secondary and postsecondary levels
- Provide students with strong experience in and understanding of all aspects of an industry
- Develop, improve, or expand the use of technology in CTE programs
- Provide professional development programs to teachers, faculty, administrators, and career guidance and academic counselors who are involved in integrating CTE programs
- Develop and implement evaluations of the CTE programs carried out with funds, including an assessment of how the needs of special populations are being met
- Initiate, improve, expand, and modernize quality CTE programs, including relevant technology
- Provide services and activities that are of sufficient size, scope, and quality to be effective
- Provide activities to prepare special populations for high-skill, high-wage, or high demand occupations that will lead to self-sufficiency
State CTE funds will be distributed to school districts on the basis of the number of contact hours generated by eligible students enrolled in CTE during the entire school year. Courses offered will be funded by the allotment for which they are eligible. The Summary of Finances provided by the Division of State Funding will reflect the State CTE allotment for each LEA.
Special Education Consolidated Grant (IDEA and IDEA-B Preschool) -The purpose of this grant is to provide special education and related services to children with disabilities ages three through twenty-one under the Individuals with Disabilities Act (IDEA). The funds for this grant are based on a child count and projected population and poverty allocation from the United States Department of Education (US DE) as provided by TEA and the Public Education Information Management System (PEIMS) data submitted. Part B of the IDEA authorizes expenditures to help LEA's ensure that children with disabilities, have access to a free, appropriate public education to meet each child's unique needs and prepare him or her for further education, employment, and independent living.
Federal funds for these programs must be used to supplement (increase the level of services) and not supplant (replace) funds from nonfederal sources. Any program activity required by State law, SBOE rules or local board policy may not be paid with these funds. If the LEA maintains (or exceeds) its level of local -or state and local -expenditures for special education and related services from year to year, wither in total or per capita, then the Part B funds are, in fact, supplementing those local -or state and local -expenditures, and the LEA has met its maintenance of effort (MOE) and supplement/not supplant requirements. No requirement currently exists related to supplanting "particular costs" and if an LEA maintains local-or state and local -effort, it will not violate the supplement/not supplant requirements of the IDEA. Cost items that are used by all students should not be funded with Part B funds. Part B funds may be used for the costs of special education and related services, and supplementary aids and services, provided in a regular classroom or other education-related setting to a child with a disability in accordance with the IEP of the child, even if one or more nondisabled children benefit from these services.
In addition to the purpose of IDEA-B Formula funds, the regulations implementing the IDEA-B Preschool funds as a part of this act define the purpose of the act as a means to supplement and increase services beyond the level of State and local funds expended for preschool students ages three through five with disabilities. The priority for these funds is to provide all students with disabilities ages 3-5 with a comprehensive program that meets their individual needs by expanding and extending services already available to these students. The District is responsible for setting aside 25% of its tentative IDEA-B Formula base entitlement or an equivalent amount of state and/or local funds to support costs of residential placement for students in the program. Equipment is defined by 2CFR Part 225 Appendix B as an article of nonexpendable, tangible personal property having a useful life of more than one year and an acquisition cost that equals or exceeds the lesser of $5,000 or the capitalization level established by the LEA for financial statements. Items that are under $5,000 or under the capitalization level established by the LEA should be budgeted under class/object code 6300 supplies and materials.
Up to 15% of IDEA-B Formula and/or Preschool funds for any fiscal year may be used to develop and implement coordinated EIS (Early Intervening Services) for students in Kindergarten through Grade 12 (with a particular emphasis on students in Kindergarten through Grade 3) who are not currently identified as needing special education or related services but who need additional academic and behavioral support to succeed in a general-education environment. (20 U.S.C. l4l3(f), 34 CFR 300.226)
State Compensatory Education - A student at-risk of dropping out of school includes each student who is under twenty-one years of age and who:
- Is in prekindergarten, kindergarten or grade 1,2 or 3 and did not perform satisfactorily on a readiness test or assessment instrument administered during the current school year;
- Is in grade 7, 8, 9, 10, 11, or 12 and did not maintain an average equivalent to 70 on a scale of 100 in two or more subjects in the foundation curriculum during a semester in the preceding or current school year or is not maintaining such an average in two or more subjects in the foundation curriculum in the current semester;
- Was not advanced from one grade level to the next for one or more school years;
- Did not perform satisfactorily on an assessment instrument administered to the student under TEC Subchapter B, Chapter 30, and who has not in the previous or current school year subsequently performed on that instrument on another appropriate instrument at a level equal to at least 110 percent of the level of satisfactory performance on that instrument;
- Is pregnant or is a parent;
- Has been placed in an alternative education program in accordance with TEC 37.006 during the preceding or current school year;
- Has been expelled in accordance with TEC 37.007 during the preceding or current school year;
- Is currently on parole, probation, deferred prosecution, or other conditional release;
- Was previously reported through the Public Education Information Management System (PEIMS) to have dropped out of school;
- Is a student of limited English proficiency, as defined by TEC 29.052;
- Is in the custody or care of the Department of Protective and Regulatory Services or has, during the current school year, been referred to the department by a school official, officer of the juvenile court, or law enforcement official;
- Is homeless, as defined by 42 U.S.C. §11302, and its subsequent amendments; or
- Resided in the preceding school year or resides in the current school year in a residential placement facility in the district; including a detention facility, substance abuse treatment facility, emergency shelter, psychiatric hospital, halfway house, or foster group home.
All purchases/services must be supplemental and directly related to State Comp Ed, and/or improving student achievement in language arts and/or mathematics. All Comp Ed funds must benefit the children in the current funding year. The Texas Education Code requires each school district to have a district and campus improvement plan with the state compensatory education program described in the campus plan if the program is implemented at the campus level or to be described in the district plan if the SCE program is implemented district wide. The district and campus improvement plans are the primary record supporting expenditures attributed to the state compensatory education program.
School districts are required to have local policies and procedures to identify students who are at risk of dropping out of school under the criteria in §29.081, TEC; students who are at risk of dropping out of school under local criteria and document compliance with the 10% cap in §29.081, TEC; how students are entered into the SCE program and how students are exited from the program; the methodologies involving calculation of 110% satisfactory performance on all assessment instruments, in accordance with §29.081, TEC; and the cost of the regular education program in relation to budget allocations per students and/or instructional staff per student ratio.
INDIRECT COST RATES
Indirect costs are part of administrative costs and are those: (a) incurred for a common or joint purpose benefiting more than one cost objective, and (b) not readily assignable to the cost objectives specifically benefited, without effort disproportionate to the results achieved. The term "indirect costs," as used herein, applies to costs of this type originating in the grantee department, as well as those incurred by other departments in supplying goods, services, and facilities. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect costs within a governmental unit department or in other agencies providing services to a governmental unit department. Indirect cost pools should be distributed to benefited cost objectives on bases that will produce an equitable result in consideration of relative benefits derived.
Indirect cost rates are established for each school district to determine the amount of indirect cost revenue that can be recorded in the General Fund. As discussed above, indirect cost revenues recognized in the General Fund are intended to defray the cost of providing certain services to grant programs. Examples of these costs are accounting, auditing and payroll processing. All of these business function costs are incurred by the school district as a whole. An attempt to maintain separate time and effort accounting for each specific grant would be prohibitive. By calculating and using an indirect cost rate, indirect cost revenues can be transferred from the grant to the general fund to compensate the school district for district-wide expenditures used to facilitate the grant. It is not necessary to track the use of indirect cost revenues once they are transferred to the General Fund. Once earned, the revenues may be used for any education-related expenditure, including administrative costs and fixed costs incurred in administrating the grant.
TIME AND EFFORT
Documentation for Grant-Funded Personnel
For employees who work:
- 100 percent in administrating programs that are part of consolidated administrative funds;
- under a single grant program; or
- under a single cost objective, including Title I, Part A school wide programs funded from eligible multiple funding sources. Cost objective means a function, organizational subdivision, contract, grant, or other activity for which cost data is needed and for which costs are incurred.
Recordkeeping Requirements for These Employees
- These employees are not required to maintain time and effort records.
- However, each employee must certify in writing, at least semi-annually, that he/she worked solely on the program(s) for the period covered by the certification.
- The certification must be signed by the employee or by the supervisor having first-hand knowledge of the work performed and should reference the employee's signed and dated job description maintained in their personnel file.
- Charges to the grant must be supported by these semi-annual certifications.
- This is a requirement under the revised OMB Circular A-87 Cost Principles effective July 1, 1995.
Job Description Requirements for These Employees
- Each employee must maintain on file a signed and dated job description which clearly shows that the employee is assigned 100 percent to the program or single cost objective.
- The job description must be updated annually or when a function or activity is added to or deleted from an existing job description, must clearly identify the function and activities performed by the employee for the applicable fund source(s) or cost objective, and must be maintained in the employee's personnel file.
- TIME AND EFFORT:
- who do not work 100 percent in administrating programs that are part of LEA‟s consolidated administrative funds;
- who work under multiple grant programs; or
- who work under multiple cost objectives.
Recordkeeping Requirements for These Employees
- These employees are required to maintain time and effort records or to account for their time under a substitute system.
- Employees must prepare time and effort reports, at least monthly, to coincide with pay periods.
- Such reports must reflect an after-the-fact distribution of 100 percent of the actual time spent on each activity and must be signed by the employee.
- Charges to payroll must be adjusted at least quarterly to coincide with preparation and submittal of the quarterly expenditure report.
- Employees who work partially on administering programs that are part of the LEA‟s consolidated administrative funds and partially from other funds must maintain time and effort or account for their time under a substitute system.
- Employees who are paid partially on administering programs that are part of the LEA‟s consolidated administrative funds and partially from program funds must maintain time and effort or account for their time under a substitute system.
Employees who work a portion of their time in a Title I school wide project and a portion of their time in another activity must maintain time and effort or account for their time under a substitute system.
- SUBSTITUTE SYSTEMS
In Lieu of Time and Effort Reports:
Job Description – General Requirement
- A current job description for each employee which delineates the program(s) or - cost objectives under which the employee works should be available for documentation to support charges to federal programs.
- For teachers and instructional aides, daily class schedules should provide adequate documentation. However, teachers and instructional aides must maintain on file a signed and dated job description, agreement or equivalent documentation identifying the function(s) and activities performed for fund sources before or after their normal work day.
- Job descriptions must be updated annually or when a function or activity is added to or deleted from an existing job description, must clearly identify the function and activities performed by the employee for the applicable fund source(s) or cost objective, and must be maintained in the employee's personnel file.
FRAUD AND FINANCIAL IMPROPRIETY
Lubbock ISD prohibits fraud and financial impropriety in the actions of its trustees, employees, vendors, contractors, consultants, volunteers and others seeking or maintain a business relationship with the district. All violations of federal criminal law involving fraud, bribery or gratuity violations that potentially affect the federal award must be disclosed, in a timely manner and in writing to the federal awarding agency or pass-through entity.
See Waste, Fraud and Abuse procedure for further information.