Finding the Pot of Gold: An Elusive Quest

New Director’s Academy WCASS Spring Conference

May 6, 2015

Show Me the Money

Who are we?• Greg Nyen, Stevens Point Area School District

• John Peterson, Hamilton School District

• Kurt Eley, Waunakee Community School District

Overview of Presentation: Funding Sources

• Maintenance of Effort (MOE)

• Categorical Aid

• IDEA Grants

• Coordinated Early Intervening Services (CEIS)

• Transfer of Service

• High Cost Special Education Aid

• Contracted Services

• District Budget

Maintenance of Effort

Definition of MOE Requirement that certain level of state and local funding is maintained from year to year.

Different rules depending on the federal program

Analysis of program expenditures not funded with grants

IDEA MOE Regulations SEA – Prohibits a state from reducing state financial support for special education below the amount of that support for the preceding fiscal year. (34 CFR 300.163)

LEA – IDEA requires that LEAs must budget and expend the same amount of local funding for special education as it expended in the previous fiscal year. (34 CFR 300.203)

Local MOE Tests Eligibility Test

◦ Local special education budget amounts compared to prior year’s actual expenditures.

◦ Determines whether LEA is “eligible” to receive the IDEA entitlement grants

Compliance Test◦ Local special education actual expenditures two-year expenditures◦ Determines if LEA is in final compliance with MOE requirement

Fiscal Data LEAs submit all Fund 27 (special education) planned expenses including local funded and grant funded expenses.

Usually done by the district’s business office

Use PI 1504 – Special Education Budget Report – Due December 1 of current fiscal year

Data is used in the LEA’s MOE calculation to determine IDEA grant eligibility

Fiscal Data LEAs submit all Fund 27 (special education) expenses including local funded and grant funded expenses.

Usually done by the district’s business office

Use PI 1505 – Special Education Annual Report – Due September 30 for previous fiscal year

Data is used to determine LEA’s state special education categorical aid and IDEA MOE compliance

Child Count Data Use Individual Student Enrollment System (ISES)

October 1 Child Count

Looks at and LEA’s financial responsibility for the student

Used to determine a “per capita” expenditure amount for purposed of MOE

Four Ways to Pass MOE An LEA only needs to pass ONE of the following comparison tests:

1. Local and state expenditures (Project Codes 011 and 019)

2. Local only (Fund 10 and 27)

3. The per student per capita amount of Local and State expenditures. (Project Codes 011 and 019)

4. The per student capita amount of Local only (Fund 10 and 27)

Departure of Special Education Staff

The voluntary departure by retirement or otherwise or departure for just cause of special education or related services personnel. (34 CFR 300.204 (a))

The difference between salaries and fringe of staff employed between two years.

Allowed exceptions: Retirements, Transfers, Resignations and Terminations for just cause

Not Allowed exceptions: Lay-offs, Position Eliminations – (Contract Non-renewals)

Decrease in Students with Disabilities Enrollment

A decrease in enrollment of students with disabilities (34 CFR 300.204 (b))

Per student capita amount must not be lower between comparison years.

Reflected in Tests #3 and #4

Year Special Ed. Enrollment

MOE Per Pupil Cost

2010 45 $100,000 $2,222

2011 40 $95,000 $2,375

2011 40 $75,000 $1875

Costly Student Leaves LEA

Exceptionally costly student leaves the district◦ Graduates◦ Ages out◦ No longer needs special education

Open enrolled student who leaves does not meet this exception

Determined by state to be cost greater than open enrollment transfer rate - FY 11 $6,498

Example:◦ PT cost $3,5000◦ Transportation cost $4,000◦ Prior to next school year student moves to another district

Termination of Costly Expenditures

The termination of costly expenditures for long-term purchases, such as the acquisition of a vehicle special education transportation (34 CFR 300.204 (d))

Equipment must have minimum cost of $5,000 to qualify.

Vehicles, equipment or remodeling charged to IDEA grant do not qualify.

Categorical Aid• Included staff

• Which expenditures are aided?

• Amount of expenditure eligible for aid• Special education teachers and paraprofessionals 100%

• Directors 100%

• Nurses 29%

• Social Workers 59%

• Psychologists 84%

• Counselors 10%

IDEA Grants• Be aware of allowable expenditures

• Maximize Special Education Categorical Aid

• Consider utilizing 15% CEIS Allotment

• Budget for initiatives

• Reserve funds for the unexpected

IDEA funds may be used to benefit students not currently identified as needing special education or related services

Students need additional academic or behavioral support to succeed in general education environment

No more than 15%

Voluntary

Required if district found disproportionate

Funds supplement not supplant

CEIS

34 CFR 300.226

Kindergarten through 12 grade – Emphasis on K-3

For professional development to deliver scientifically based academic and behavioral interventions

Providing educational and behavioral evaluations, services, and supports

Includes scientifically based literacy instruction

CEIS Voluntary Use

Number of students who received early intervening services

Number of students who received CEIS and who received special education and related services at later time that year

Report through ISES, the students who received interventions in the same year the funds are claimed

CEIS Reporting Requirements

34 CFR 300.646

Race and ethnicity

Based on:◦ Identification of children with a disability◦ Placement in a particular educational setting◦ incidence, duration, and type of disciplinary actions, including suspensions and

expulsions

CEIS and Disproportionality

Review and, if appropriate revise policies, procedures, and practices used in the identification or placement

Must use 15% of IDEA funds for efforts related to correcting disproportionality

LEA must publically report on revisions of policy, procedures and practices

So You Are Disproportionate

Transfer of Service•Student moving into district

•New expenditures required

•Special education and English Language Learners

•Within WI transfers require previous district response

•Out of state transfers do not require response

•Don’t forget B-3 students

High Cost Special Education Program

WI Statute 115.881 – Created in 2005

Administrative Rule – PI 30

Student-specific special education service costs for an individual student in a single year must exceed $30,000.

◦ Amount over $30,000 is eligible for reimbursement on a pro-rated scale.

Reimbursement is after the fact – paid a full year after the costs were incurred.

Claims for the 2011-12 school year are due January 31, 2013.

Reimbursement if 90% of cost over threshold or pro-rated if total claims exceed budget amount

Eligible Costs Direct special education instruction or related services

◦ Services eligible for reimbursement must be documented in the student’s IEP◦ Examples: Educational Interpreters, Extended School Year (ESY), Job Coaching,

Paraprofessionals, Transition-Employment Skills, Transportation

Transportation◦ Must be in the student’s IEP◦ Examples: Vehicle insurance, Mileage, Driver Costs, Transportation aide costs◦ If these same costs are also incurred by students who do not meet the

definition of high cost, then the costs are ineligible for reimbursement

Contracted Services•Comparison shopping

•Way to save money

•Reference checks

•Contract in compliance with Omni circular

•Contract reviewed by district’s attorney

Medicaid

Medicaid Administrative Claiming (MAC) Allowable activities:

◦ Medicaid outreach and related training◦ Facilitating Medicaid eligibility application◦ Health-related referral and monitoring of health service

delivery◦ Medical service program planning, policy development

and interagency coordination◦ Arranging Medicaid-related transportation and provision

of Medicaid-related translation

School Based Services Direct Medical Services covered:

◦ Physical Therapy◦ Occupational Therapy◦ Speech Therapy◦ Nursing Services◦ Attendant Care Services◦ Psychological Services◦ Counseling Services◦ Social Work Services

MAC Staff Pool List Administrators, Principals, Assistant Principals

Special Education Teachers

Program Coordinators

Program Aides

Directors and Assistant Directors of Special Education

Interpreters

Note: Person can only be on one Staff Pool list

SBS 1 Staff Pool List Attendant Care Nursing Service Provider/Personal Care

Delegated Nursing Service Provider

Licensed Counselor

Licensed Social Worker/School Social Worker

LPN

Registered Nurse

Note: Person can only be on one Staff Pool list

SBS 2 Staff Pool List Audiologist/Audiologist Assistant/Aide/Intern

Occupational Therapist/Assistant

Physical Therapist/Assistant

Psychologist/Assistant/Aide/Intern

Speech and Language Pathologist

/Assistant/Aide/Intern

Note: Person can only be on one Staff Pool list

Attendant Care Services

Attendant cares services are a range of human assistance provided to students with a disability or chronic condition. The assistance enables them to accomplish tasks in the educational setting that they would normally do for themselves if they did not have a disability or chronic condition.

Examples of Attendant Care ServicesProviding assistance to a child with a disability in the following areas: Eating, including food purchasing and preparation Routine personal hygiene (hand washing, brushing teeth, combing hair, grooming and showering) Dressing Toileting Transferring Routine care of personal assistive devices (eyeglasses, wheelchair, communication boards) Supervision and cuing of activities

Services Not Covered under Attendant Care Bus aides during transportation are not covered

Skilled services that may be performed only by a health professional

Services that are educational in nature. A class all students attend that provides instruction in “Life Skills”.

Math, reading instruction

Topics from the Field

Thank you for all you do!