Schoolwide Funding Consolidation PanelPanelists:

Nancy Konitzer, Arizona Department of Education, Rebecca Vogler, Cincinnati Public Schools and

Jose Figueroa, Baboquivari Unified School District

Moderated By: Tiffany R. Winters, Esq. and Leigh Manasevit, Esq.

Brustein & Manasevit, PLLCwww.bruman.com Spring Forum 2015

Three Types of SW Schools

1. SW with no consolidation2. SW that consolidates only federal funds3. SW that consolidate federal, state, and local

funds• Sometimes referred to as “SW3”

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All Schoolwide Programs: Basic Requirements

• Consolidate programs to upgrade the entire educational program of the school

• Ensure all children meet standards, particularly those most at risk

• Requirements:– 40% poverty– Schoolwide plan

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• All formula (non-competitive) BUT some caveats -• Includes IDEA - up to cap (but not exempt from programmatic

requirements)• Migrant; Indian Ed restrictions re consultation

• All discretionary (competitive)• Still must comply with application

• ED only (no School Lunch, Head Start)

• Important: Must Identify in SW PLAN: the programs that are “consolidated” and the amounts consolidated from each!

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What federal program funds can be consolidated?

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For Formula Grants

Meet “Intents and Purposes”• A school that consolidates federal funds is not required to

meet most of the statutory and regulatory requirements of the specific federal programs applicable at the school level. – Not required to ID particular children or provide

supplemental services

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For Discretionary Grants

• Must still carry out all activities described in application• But do not need to account separate for specific expenditures

of the discretionary grant funds

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What does it mean to consolidate funds?

• Treat funds like a “single pool of funds”• Lose individual program identity• School has one flexible pool of funds

– LEA does not literally need to combine funds in a single account or pool with its own accounting code

– “Pool” is used conceptually

• “Use to support any activity of the schoolwide program without regard to which program contributed the specific funds used for a particular activity”

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Can the State prevent consolidation?

• NO. Each SEA must “encourage schools to consolidate funds from Federal, State, and local sources in their schoolwide programs”, and

• “Each State plan shall contain assurance that - the SEA will modify or eliminate State fiscal and accounting barriers so that schools can easily consolidate funds from other Federal, State, and local sources for schoolwide programs”

• ESEA 1111(c)(9) and (10)

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TYPES OF SW PROGRAMS AND

LEVELS OF CONSOLIDATION

1. No Consolidation2. Consolidate only federal funds3. Consolidate federal, state and local funds

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Standard Title I Schoolwide School- No Consolidation

• All students are eligible Title I Students• Title I funds must be spent on the “educational needs”

of school– Identified in needs assessment– Articulated in SW Plan

• Must account for and track the Title I funds separately, identifying the activities the Part A funds support

• EDGAR and allowability rules apply

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Schoolwide School With Federal Funds Only Consolidation

• All students are eligible Title I Students• Title I funds must be spent on the “educational needs”

of school (same as standard Title I school)

• Single Federal consolidated pool

• “From an accounting perspective, the funds from the contributing Federal programs lose their individual identity when they become part of a consolidated schoolwide pool and would be accounted for as part of that pool rather than by the individual programs that contribute to the consolidated schoolwide pool.”

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Schoolwide School With Consolidation of Federal, State and Local Funds

• “When Title I, Part A funds are consolidated with State and local funds . . . they lose their identity.”

• No distinction between federal and non-federal

• EDGAR does not apply

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THE MECHANICS OF CONSOLIDATION

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The Mechanics of Consolidation

EXAMPLE 1: Across all SW schools in LEA•Consolidated schoolwide pool with its own accounting code

•The expenditures attributed to that code are charged on a proportional basis– If Title I contributed 8%, then 8% of SWP expenses

charged to Title I

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The Mechanics of Consolidation (cont.)

EXAMPLE 2: Single school model•No single accounting code for SWP •For accounting purposes, LEA attributes expenditures back to specific program REGARDLESS of what services those funds support•Two options for distributing expenditures:

– proportion of revenues or sequence charging

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Recordkeeping in SWP

• School operating SWP that consolidates funds is not required to maintain separate fiscal accounting records, by Federal program, that ID the specific activities supported by each program’s funds.– May have to track to functional categories like salaries, travel, supplies,

etc. BUT– The LEA would not be required to track how much it spends on

activities (for example, salaries) back to a specific program included in the consolidated SW pool.

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Reporting with SW Consolidation

Proportional Basis (or “any other reasonable method”)

•Use for identifying:– Carryover– Amount unused non-federal funding– MOE– Comparability– Reporting expenditures back to State or USDE– State Per Pupil Expenditure (SPPE)

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Supplement Not Supplant in all SW Schools

• ESEA 1114(a)(2)(B): Title I must supplement the amount of funds that would, in the absence of Title I, be made available from non-federal sources– The actual service need not be supplemental

• School must receive all the state and local funds it would otherwise need to operate in the absence of Federal funds– Includes routine operating expenses such as building maintenance and

repairs, landscaping and custodial services

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Time and Effort Required with Consolidation?If LEA/school consolidates . . . Then must keep . . .

Federal, state, and local funds No time and effort records

Federal only Time and effort required

Nothing (only Title I funds SWP) Time and effort required

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PANELISTS

Nancy Konitzer, Arizona Department of Ed; Rebecca Vogler, Cincinnati Public Schools; and

Jose Figueroa, Baboquivari Unified School District

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Schoolwide Legal Resources

• Statute: ESEA Section 1114• Regulations: 34 CFR 200.25-200.29• Non-Regulatory Guidance

– Designing Schoolwide Programs Guidance: March 2006 www.ed.gov/policy/elsec/guid/ designingswpguid.doc

– “Title I Fiscal Issues,” February 2008 (replacing May 2006) http://www2.ed.gov/programs/titleiparta/fiscalguid.pdf• Consolidating funds in schoolwide programs, MOE, SNS, Comparability,

Grantbacks, Carryover

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QUESTIONS?Brustein & Manasevit, PLLC

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