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Frequently Asked Questions - Title I Schoolwide Programs
Specific to Abbott Districts

IASA Project Period September 1, 2000 to August 31, 2001
(as of February 19, 2001)

General

Q1. What is a Title I schoolwide program?

A. The Improving America's Schools Act (IASA), Title I, Part A defines a Title I schoolwide program as a program in a Title I-eligible school in which Title I, Part A and other federal education program funds and resources are used to upgrade the entire educational program of the school. The program purpose is to increase the academic achievement for all students in the school by allowing schools to integrate their programs, strategies and resources.

Q2. How is a Title I schoolwide program different from a Title I targeted assistance program?

A. A Title I targeted assistance program uses Title I, Part A funds only for the provision of supplementary educational services to eligible children who are failing, or at risk of failing, to meet state standards. In a Title I schoolwide program, a school is not required to provide supplemental services to identified children but to upgrade the entire educational program in the school.

Q3. What advantages are there in operating a Title I schoolwide program?

A. Title I schoolwide programs have more flexibility in determining how to spend their Title I, Part A funds as follows:

1) Schoolwide programs do not have to identify specific children as eligible for services.

2) Schoolwide programs do not have to show that federal funds used within the school are paying for additional services that would not otherwise be provided.

3) Schoolwide programs do not have to separately track federal dollars.

4) Schoolwide programs may combine Title I, Part A funds with other federal funds in support of the schoolwide program.

5) Schoolwide programs focus on increasing achievement levels for all children served in the school.

6) Schoolwide programs do not have to conform to most of the statutory or regulatory requirements of each separate federal program as long as the intent and purposes of those programs are met.

Q4. Where can additional information be found about schoolwide programs?

A. The United States Department of Education website provides written guidance, program ideas and audit information. Valuable documents are listed below and can be found at www.ed.gov

Title I Schoolwide Program Eligibility

Q5. What are the eligibility requirements for becoming a Title I schoolwide program?

A. The school must be eligible for the Title I program, receive Title I, Part A funds, at least 50 percent of the children enrolled in the school or residing in the school attendance area must be from low-income families, comply with a year of planning and meet the eight essential program components. Title I eligibility and the 50 percent poverty level is determined using the Title I Eligibility of Public Schools form located in the IASA Subgrant Application (See Question 26). To promote effective, long-term planning, a school can maintain its schoolwide program eligibility even if it drops below the 50 percent poverty threshold. However, the school must still meet Title I eligibility and receive Title I funds.

Q6. What if a specific school wants to operate a Title I schoolwide program but does not meet the poverty requirements?

A. The LEA, on behalf of the school, must apply directly to the federal government for a waiver of the poverty requirements. Refer to the 2000-2001 IASA Consolidated Application Guidelines on the New Jersey Department of Education (NJDOE) website at www.state.nj.us/education Select Grants and then Select Waivers of Federal Program Requirements to obtain the process and the timelines. The NJDOE is planning to submit a waiver on behalf of all Abbott districts, but until approval is received, LEAs must comply with the requirement or seek individual waiver approvals.

Q7. If a school is eligible for Title I funds, meets the 50 percent poverty requirement and the LEA "jumps" the school, is the school eligible to operate a schoolwide program?

A. Only eligible Title I schools receiving Title I funds may operate schoolwide projects. (See Question 5)

Q8. Can midyear second and third cohort schools implement a Title I schoolwide program?

A. Midyear second cohort and third cohort whole school reform schools may implement a Title I schoolwide program after meeting the Title I schoolwide program requirements (See Question 5), submitting a Title I Schoolwide Program Plan and obtaining approval from the NJDOE. Such approval permits the school to blend its federal funds only and use these funds to serve the entire school population. The blending of state and local funds is not permitted for midyear second and third cohort schools until the 2001-2002 school year which is the first year of implementing their approved whole school reform plan and blended school-based budget.

Meeting Federal Requirements

Q9. Which federal education program funds may be combined to support a schoolwide program?

A. Although the Improving America's Schools Act of 1994, Public Law 103-382, allows all of the listed programs to combine funds to support a schoolwide program, New Jersey only permits the following programs to be blended in school-based budgets:

  • Title I, Part A of ESEA: Helping Disadvantaged Children Meet High Standards, Improving Basic Programs Operated by Local Education Agencies
  • Title II of ESEA: Eisenhower Professional Development
  • Title IV of ESEA: Safe and Drug-Free Schools and Communities
  • Title VI of ESEA: Innovative Education Program Strategies
  • Title IX of ESEA: Indian Education
  • Individuals with Disabilities Education Act (IDEA)
  • Class Size Reduction

In New Jersey, funds from the following federal programs are distributed through contract agreements with LEAs to provide services districtwide and, in some cases, beyond the confines of the LEA. In such cases, the LEA maintains line item budgets and expenditure reporting. Where funds are transferred to a school operating a schoolwide program to implement the grant program or portion of the grant program, the NJDOE is investigating possible accommodations to support the blending of the following revenue sources:

  • Title I, Part B of ESEA: Even Start Family Literacy
  • Title I, Part C of ESEA: Education of Migratory Children
  • Title I, Part D of ESEA: Neglected, Delinquent or At-Risk Youth
  • Title III, Part A, Subpart 2 of ESEA: Technology for Education
  • Title V, Part A of ESEA: Magnet Schools
  • Title VII of ESEA: Bilingual Education
  • Title VII of the Stewart B. McKinney Homeless Assistance Act: Education for Homeless Children and Youth
  • Title VIII of ESEA: Impact Aid
  • Goals 2000: Educate America Act
  • Perkins Vocational Education Act
  • School-to-Work Opportunities Act
  • Comprehensive School Reform Demonstration Program

Q10. How is the NJDOE ensuring that the LEA and schools that are operating schoolwide programs are meeting the intent of the federal programs for which the school receives funding?

A. The intent of schoolwide programs is to raise student academic performance. To that end, the Office of Specialized Populations reviews Title I evaluation data to assure that all students are meeting state standards and that schools are progressing to close achievement gaps.

Q11. From what federal requirements is a schoolwide program not exempt?

A. A Title I school operating a schoolwide program school must comply with the following requirements applicable to individual federal programs:

  • Health and Safety- 20 U.S.C. 1221e-3,3474 and 6511(a)
  • Civil Rights-Title VI of the Civil Rights Act of 1964 (P.L. 88-352)
  • Gender Equity-Title IX of the Education Amendments of 1972 (20 U.S.C. 1681-1683)
  • Supplement, not Supplant-IASA 1120A(b)
  • Maintenance of Effort-IASA 14501
  • Comparability of Services-IASA 1120A
  • Distribution of Funds to SEAs and LEAs-IASA 1122 & 1124
  • Parents’ and Students’ Involvement-IASA 1118
  • Private School Children Participation-IASA 1120

In addition, if a Title I schoolwide program school is combining Migrant Education Program funds, it must first consult with parents of migratory children or organizations representing those parents in order to address the identified needs of migratory children that will permit them to participate effectively in school.

Q12. For schools that are operating Title I schoolwide programs, must they comply with the comparability requirement?

A. Yes. The comparability requirement is one of the areas that is not exempt from compliance when operating a Title I schoolwide program as per Title I law (1120A (c)). The FY 2001 IASA Guidelines, in Section VIII pages 48 to 50, has specific information on how to demonstrate compliance with this requirement.

Q13. How does the LEA/school provide Title I, II, IV and VI services to private school students?

A. The LEA is responsible for providing services to eligible private school students. The amount of funds for private school students is calculated using the Title I Eligibility of Public Schools form in the IASA application. For Titles II, IV and VI, private school funds are identified on the LEA allocation notices. The LEA is required to consult with each eligible private school to develop a plan to service the private school students. The LEA's IASA Program Plan must include the objectives, activities and evaluation plan for each of the private schools. The LEA is responsible to ensure that the appropriate services are provided based upon the approved IASA application.

Q14. In a Title I schoolwide program, can funds be used to support general teachers or do funds have to support a Title I teacher?

A. Federal funds are not tracked to individual accounts, specific staff or services. Schools may use federal funds to upgrade the entire school, as long as the same amount or more of state and local funds are included in the budget from the prior year. Therefore, there is no distinction among staff supported by federal, state, or local funds.

Q15. If the LEA/school has operated an extended (before and after school) program using Title I funds and this activity is not a component of the whole school reform model, can this program be continued and funded within a blended budget?

A. Yes. While they are not necessarily components of whole school reform, often schools can demonstrate the need for before and after school programs, as well as summer school programs.

Q16. If a Title I schoolwide program school combines funds from other federal education programs, does the school have to demonstrate that it is complying with the specific program requirements of the individual federal programs?

A. A schoolwide program school is required to meet the intent and purposes of the federal programs from which funds are combined to ensure that the needs of the intended beneficiaries of those programs are addressed. When federal program funds are combined to support a schoolwide program and upgrade the entire educational program in the school, these funds lose their fiscal identity. Expenditure reporting by program can no longer be used as documentation that the individual program activities were completed. The school must be able to demonstrate that its schoolwide program contains sufficient activities to reasonably address the needs of the intended beneficiaries and thus meet the intent and purposes of each program. The school does not need to document that it used funds from a particular federal program to meet the specific intent and purposes of that program. Accountability for compliance for all Titles is based on student performance on the state assessments.

Title I
If a schoolwide program school receives Title I program funds, the school must provide opportunities for all children to acquire the knowledge and skills necessary to meet the state's challenging Core Curriculum Content Standards. The goal is to help all children meet these high standards.

Title II-Eisenhower
If a schoolwide program school receives Title II program funds, its plan must include sustained and intensive high-quality professional development programs for school staff (primarily teachers) in the core academic subjects (primarily in mathematics and science) that are aligned with the state’s Core Curriculum Content Standards. Those programs must reflect recent research on teaching and learning and must incorporate methods and practices to meet the educational needs of diverse student populations.

Title IV- Safe and Drug-Free Schools and Communities Act
If a schoolwide program school receives Title IV funds, the school must have a comprehensive drug and violence prevention program designed for all students and employees. The program must be designed to create a disciplined environment conducive to learning, preventing violence and promoting school safety, and preventing the use, possession, and distribution of tobacco, alcohol, and illegal drugs by students.

Title VI-Innovative Programs and Strategies
If a schoolwide program school receives Title VI funds, activities must support one of the following purposes:

  • assisting local educational reform efforts which are consistent with and supportive of statewide reform efforts under the Goals 2000: Educate America Act;

  • supporting state and local efforts to accomplish the National Education Goals;

  • providing funding to enable LEAs to implement promising educational reform programs;

  • providing a continuing source of innovation and educational improvement, including support for library services and instructional and media materials; or

  • meeting the special educational needs of at-risk and high-cost students.

Class-Size Reduction
Schools operating schoolwide programs must strive to reduce the size of their classes, particularly in the early grades, using fully qualified teachers to increase student achievement. The intent of the Class-Size Reduction program is to recruit, hire and train "new" certified teachers and to ensure that teaching staff is fully qualified. Professional development services for teachers are activities supported by this program.

Individuals with Disabilities Education Act (IDEA)
Schools operating schoolwide programs must comply with all of the IDEA requirements. Programs and related services must be provided in accordance with each student's Individual Education Program.

Q17. If a Title I school operating a schoolwide program is not required to identify particular children eligible to receive Title I services, how can the school determine whether it is meeting the needs of the intended beneficiaries of the Title I program?

A. A Title I schoolwide program school is not required to focus federal education funds on particular children, as all children are eligible to participate in all aspects of a Title I schoolwide program. However, the school must know which children have special needs such as: children with disabilities, migrant children, children with limited English proficiency, or children at risk of failing to meet state academic and performance standards. By definition, a schoolwide program is designed to improve the achievement of all the students in the entire school. Therefore, state assessment results must show overall student performance in meeting the state standards. In addition, results of the state assessments of all students in the school must be disaggregated to determine their performance levels. Schools are required to address the achievement gap of those students not meeting mandated state performance standards.

Q18. What restrictions are there on the use of IDEA funds in a Title I schoolwide school?

A. All children in the particular school where the approved schoolwide program is operating must be participating. This includes students attending self-contained classes. If not all students are participating, then no portion of IDEA funds may be used for the schoolwide program.

Q19. How much of the IDEA funds can be used in a schoolwide program?

A. Notwithstanding section 613(a)(2)(A) or any other provision of IDEA-Part B, an LEA may use funds received under Part B for any fiscal year to carry out a schoolwide program under 1114 of the Elementary and Secondary Education Act of 1965, except that the amount so used in any such program shall not exceed - (i) the number of children with disabilities participating in the schoolwide program; multiplied by (ii) (I) the amount received by the LEA under Part B for that fiscal year; divided by (II) the number of children with disabilities in the jurisdiction of that agency.

Both the basic (ages 3-21) and preschool (ages 3-5) applications may obligate funds for schoolwide programs with the same restrictions.

Q20. If a Title I schoolwide school receives Class-Size Reduction Program funds, blends its funds but does not use any of the funds to hire a teacher, is the school in compliance with meeting the intent of the program?

A. The school is in compliance with the Class-Size Reduction Program providing the intent of this program is fulfilled. See Question # 14 for the specific intent and purposes of the Class-Size Reduction Program.

Q21. How is the cash analysis requirement calculated in LEAs whose funds are allocated to schools that are blending budgets?

A. The Federal Cash Analysis Report is completed for each federal entitlement grant in excess of $50,000. Box 1 in this report is the amount of cash received under the particular entitlement program through March 31. The cash disbursed amount reported in Box 2 is the amount of expenditures including encumbrances allocated to the particular federal entitlement on March 31 utilizing the percentage of resources allocation calculation discussed in The Abbott Addendum to The Audit Program for Reporting Whole School Reform Activities in First Cohort Schools 1999 – 2000. This calculation is the same as the year-end calculation, including encumbrances. Box 3 is the difference between Box 1 and Box 2.

Q22. How can the LEA determine the amount of federal expenditures to include in the maintenance of effort calculation, if federal funds are combined in a schoolwide program and lose their fiscal identity?

A. The LEA must complete the Blended Resource Fund 15 Statement of Blended Expenditures Allocated by Resource Type for each whole school reform school in their LEA. This statement is a calculation of the allocation of the school’s total school-based expenditures to the various funding sources. Once the individual school statements are prepared, a districtwide summary is prepared to total the expenditures allocated to the various programs in each school. The expenditure amounts used in the Maintenance of Effort calculations are obtained from this districtwide statement. The expenditure allocation is explained in detail and a sample school district calculation, as well as sample statements, are included in the Abbott Addendum to The Audit Program for Reporting Whole School Reform Activities in First Cohort Schools 1999 – 2000. The expenditure allocation calculations are required to be included in the Comprehensive Annual Financial Report (CAFR) of the Abbott districts.

Q23. Does the LEA or the schoolwide school demonstrate that it supplements, not supplants, state and local funds?

A. Supplement, not supplant requires the school to use Title I funds and other federal education program funds included in the schoolwide program only to supplement the total amount of funds that would, in the absence of the federal funds, be made available from non-federal sources for that school, including funds needed to provide services that are required by law for children with disabilities and children with limited English proficiency. In general, it is the LEA's responsibility, not the school's, to ensure that a schoolwide program school receives all the state and local funds it would have received had it not been a Title I schoolwide program school. The LEA must be able to demonstrate that it distributed state and local funds fairly and equitably to all its schools, including schoolwide program schools, without regard to the school's receipt of federal resources. A schoolwide school is not expected to keep records of the services paid using federal funds nor is it required to demonstrate that any particular service supplements the services regularly provided in that school.

Meeting IASA/Class-Size Reduction Grant Application Requirements

Q24. If an Abbott school with an approved whole school reform plan is receiving Title I funds, meets the 50 percent poverty criterion and wants approval to operate a schoolwide program, does the school still have to meet the Title I requirements of (1) a year of planning and (2) submission of a separate schoolwide program plan?

A. For first and second cohort Abbott schools, the New Jersey Department of Education (NJDOE) considers the required school-level planning that took place to select a whole school reform model and develop its Whole School Reform Implementation Plan as sufficient to meet the Title I schoolwide requirement of a year of planning. Additionally, the approved Whole School Reform Implementation Plan is accepted in place of a separate Title I schoolwide program plan. Abbott midyear second cohort and third cohort schools must comply with the Title I schoolwide program requirements.

Q25. What documents must be submitted with the IASA and Class-Size Reduction applications to fulfill the program plan requirements?

A. For cohort one and two schools implementing whole school reform and designated as Title I schoolwide programs, the approved Whole School Reform Implementation Plan for these schools is accepted as their Title I Schoolwide Plan. For these schools, their approved Whole School Reform Implementation Plan is also used as their IASA Program Plan and Class-Size Reduction Program Plan. The NJDOE will obtain the approved Whole School Reform Implementation Plans directly from the Office of Program Review and Improvement.

For cohort midyear two and three whole school reform schools, the IASA and Class-Size Reduction Applications require the completion of a program plan that includes the goals, objectives, activities and evaluation plans for these schools. Separate Title I Schoolwide Plans are also required if these schools are applying for approval to implement Title I schoolwide programs.

All LEAs must submit IASA and Class-Size Reduction Program Plans that include objectives, activities and evaluation plans for programs to be implemented at the district level, in private schools, in neglected and delinquent facilities, in ineligible Title I schools and in Title I targeted assistance schools.

Q26. The 7th National Education Goal states that "all schools will be free of drugs, violence and the unauthorized presence of firearms and alcohol, and will offer a disciplined environment that is conducive to learning." What is a realistic objective for schools?

A. The NJDOE provides four goals in the IASA application under which LEAs develop and organize measurable objectives for each Title. LEAs should base their objectives for Title IV on an analysis of the current use, and consequences of such use, of alcohol, tobacco, and other drugs; and/or documented research-based risk factors related to substance abuse and the violence, safety and discipline problems among students; and/or the documented research-based risk factors antecedent to these problems. Each LEA should develop an action plan to effect a significant, but achievable, reduction in the priority student behaviors of concern or the improvement of conditions which place students at risk for documented problems.

Q27. On the IASA application, Title I Eligibility of Public Schools form, are the total resident students for each attendance area used to calculate the school's allocation?

A. Yes. The total number of resident students (including public and private) for each attendance area is used to calculate the school's Title I eligibility and allocation. If a school is ineligible for Title I based on the LEA poverty rate, there is a provision in the IASA law that allows for LEA discretion to use only the low- income students enrolled in the school, excluding the private school students, to determine the school's Title I eligibility. See the IASA Guidelines for more specific information in completing this form.

Q28. On the IASA application, Title I Eligibility of Public Schools form, is the per- pupil amount determined using the allocation amount or the program amount (net after set-asides)?

A. The LEA allocation amount is used to determine the per-pupil amount.

Q29. Title I requires a 1 percent set aside for parental involvement for grantees receiving over $500,000. Is this still required in a district with first and second cohort whole school reform schools with schoolwide status?

A. Parent involvement is inherent in whole school reform. If whole school reform schools have an approved Whole School Reform Implementation Plan, these activities must take place. This meets the intent of the one percent set-aside for parental involvement and a set-aside for these schools is not required.

As an alternative, the LEA may choose to set aside the one percent for parental involvement on a district level. The LEA would then provide the services and identify, track and report the funds.

Q30. Does an amount need to be set aside for professional development on the IASA application-Title I Eligibility of Public Schools form?

A. No. Professional development is an important component of both Title I and Title I schoolwide programs. A comprehensive professional development program is also inherent in whole school reform. For cohort one and two whole school reform schools that blend funds, a specific amount for professional development does not need to be identified. Professional development activities for these schools must be included in the approved Whole School Reform Implementation Plan. For midyear two and three cohort schools, funds for professional development must be identified. In either case, the LEA/school must ensure that the professional development programs at all its schools are comprehensive, on-going, and sustained. The funds for professional development do not need to be identified on the Title I eligibility form.

Q31. The LEA has allocated set-aside funds for indirect costs and/or administrative costs for Title I and for the other Titles. Is this permissible in an LEA that is implementing whole school reform? How does the LEA budget these costs?

A. LEAs may use funds for indirect costs for all Titles regardless of schools implementing schoolwide programs. Administrative costs may be also used for districtwide activities and should not be combined into schoolwide budgets. The Title I Eligibility of Public Schools page in the IASA application has a section for the set-aside costs for indirect and administrative costs. For the LEA to use an indirect cost rate, it must be applied for by the LEA and approved by NJDOE. For IASA, the total amount of indirect and administrative costs is restricted to a maximum of 5 percent by Title. For the Class-Size Reduction Program, the total of indirect and administrative costs is restricted to a maximum of 3 percent.

Q32. How does an LEA develop its budget in the IASA consolidated application for one or more schools that are designated as Title I schoolwide programs?

A. For first and second cohort whole school reform schools that have approved Title I schoolwide programs: The LEA must identify the IASA resources budgeted for each school by Title. On the IASA Budget Detail, for each school using GAAP code 520-930, list each school in the description column and list the amount budgeted from each Title. On the Budget Statement, enter under GAAP code 520-930, the total budgeted for schools operating schoolwide programs from each Title.

For mid-year second and third cohort whole school reform schools that have approved Title I schoolwide programs: The LEA must identify the IASA resources budgeted for each school by Title. On the IASA Budget Detail, for each school use GAAP code 520-932, list each school in the description column and list the amount budgeted from each Title. On the Budget Statement, enter under GAAP code 520-932, the total budgeted for schools operating schoolwide programs from each Title.

For schools that are not approved as Title I schoolwide programs: These schools are not permitted to blend their federal funds. The LEA must use individual GAAP codes.

Q33. How does the LEA allocate the IASA (Titles II, IV & VI) and Class-Size Reduction funds to the schools?

A. For IASA (Titles II, IV and VI) and Class-Size Reduction programs, the amount of funds allocated to the individual schools is based on the needs of the schools. This is determined collaboratively by district-level and school-level staff. For Title IV, the allocation of funds must be used to either reduce the problem(s) or improve the conditions that contribute to those problems identified in the Objective Analysis.

Q34. Can an LEA keep IASA funds at the district level to pay for districtwide programs?

A. The LEA’s IASA Advisory Committee develops and approves the IASA Subgrant Application that is submitted to the NJDOE for approval. During the application development, the amount of funds needed for districtwide programs is determined and budgeted.

For Title II, LEAs must allocate a minimum of 80 percent of these funds for professional development activities for teachers, and, where appropriate, other staff and parents of individual schools. This school-level portion of funding does not need to be distributed equally or proportionally to all schools. However, it should be distributed or utilized in accordance with the needs assessment for professional development, which was developed with the input of teachers representing all schools and all grade levels. The remaining 20 percent may be used for district-level professional development activities or may also be used for school-level activities.

For Titles I, IV, VI and Class-Size Reduction, the LEA may chose to maintain some funds at the LEA level to be used for districtwide activities. This decision needs to be mutually agreed upon by the LEA’s IASA Advisory Committee.

Blended School-Based Budgeting/Auditing

Q35. If there are first and second cohort whole school reform schools in the LEA not eligible for Title I funds, can the schools still blend their budgets?

A. Title I eligibility is a prerequisite of schoolwide program eligibility. Without an approved schoolwide program, a school is not permitted to blend federal funds with state and local finds. These ineligible schools may only blend state and local funds. LEAs/schools may submit a waiver request to the USDOE. The NJDOE is planning to submit a federal waiver requesting permission for any ineligible Abbott schools to be able to blend their federal funds. Until approval is received, LEAs must comply with the requirement or seek individual waiver approvals.

Q36. Can all Abbott schools combine their federal resources and their other state and local resources in a school-based budget?

A. Only first and second cohort whole school reform schools may combine federal, state and local funds in a blended budget. These schools must also be approved as Title I schoolwide programs in the IASA Consolidated Subgrant Application to be granted under federal regulation the flexibility to combine certain federal funds. Midyear two and three cohort schools with approved Title I schoolwide programs may combine federal funds but may not combine state and local funds until July 1, 2001.

It is the Abbott v. Burke decision and N.J.A.C. 6:19A-4.4(a)4 that permits the Abbott districts to blend state and local resources, along with federal resources as allowed by law, in their school based budgets. N.J.A.C. 6:19A-4.4(a)4 states, "The principal shall prepare a school-based budget as follows: . . . except where prohibited by Federal law, all local, State and Federal funds shall be considered general funds available for WSR activities, notwithstanding any restrictions that would otherwise apply."

Q37. What is Fund 15 and how does the LEA use this fund?

A. Fund 15 was developed to budget and account for school-level expenditures for schools implementing an approved whole school reform plan. Fund 15 is considered a subfund of the general fund. Revenues are recorded in Fund 15 as operating transfers from the general and special revenue funds. The school-based budget must specifically identify federal, state and local programs that are to be combined and the resources to be used to support the whole school reform program.

Q38. Are all Abbott schools implementing approved whole school reform plans required to blend their funds and develop school-based budgets?

A. School-based budgeting and the blending of funds are fundamental elements in implementing whole school reform. The blending of funds requirement is specified in the proposed Abbott code. First and second cohort whole school reform schools must blend their federal, state and local funds if the school has been designated a Title I schoolwide program. Midyear second cohort and third cohort schools must develop a school-based budget and begin to blend funds as of July 1, 2001.

Q39. In the whole school reform budgets, professional development stipends are categorized under "teacher salaries" in the Chart of Accounts. Is a more appropriate category "223" (developer costs)?

A. No. Fees to the contractor for professional development are appropriately categorized using 223. Stipends paid to staff attending professional development activities would be charged to the appropriate salary account according to the Chart of Accounts.

Q40. For LEAs with schools implementing a Title I schoolwide program and blending its funds, what are the fiscal audit requirements?

A. The CAFR reporting requirements for school-based reporting for LEAs implementing whole school reform and a Title I schoolwide program are detailed in the Abbott Addendum to The Audit Program for Reporting Whole School Reform Activities. This document was distributed to all Abbott districts with first cohort schools. Additional copies of this document may be obtained from the NJDOE Publications Office.

Q41. What recordkeeping requirements apply to an LEA with respect to federal education funds that are blended in a school-based budget?

A. An LEA must be able to show the amount of funds from each federal education program allocated, on an annual basis, to schools operating a Title I schoolwide program. An LEA or a Title I schoolwide program school is not required to assign specific costs to federal funds combined in the schoolwide program or to a particular federal program. Schoolwide programs are not required to track federal funds separately at the individual school level.

IASA/Class-Size Reduction Grant Accounting & Reporting

Q42. In a Title I schoolwide school, is an LEA required to track split funding of personnel and must time sheets be maintained?

A No. Separate accounting requirements do not apply to Title I schoolwide program schools. If the school has been designated a Title I schoolwide program, there is no longer a requirement to track personnel by funding source. Federal funds are used for all students within a schoolwide program school.

Q43. How does the LEA account for the TPAF/FICA amounts charged to the federal grants when completing the state reimbursement forms?

A. Contracted teacher salaries need to be determined from the payroll system on a school-by-school basis. Once these amounts are determined, the contracted salaries are allocated to Title I and to the other federal programs based on the resource percentages calculated on the Blended Resource Fund 15 Statement of Expenditures Allocated by Resource Type. A detailed discussion of this process, as well as sample calculations for a sample school district, are included in the Abbott Addendum to The Audit Program for Reporting Whole School Reform Activities.

Q44. How does the LEA/school calculate funds expended in a schoolwide program for IASA/CSR grant reporting purposes?

A. On June 30, each individual school operating a schoolwide program allocates the total expenditures incurred during the year to the various state, federal and local funding sources, which were blended in its school-based budget (Fund 15) and reports the amount of unexpended school-based budget funds by funding source to the LEA. This allocation is explained in detail and a sample school district calculation, as well as sample statements, are included in the Abbott Addendum to The Audit Program for Reporting Whole School Reform Activities in First Cohort Schools 1999 – 2000.

Once this allocation is performed, the deferred revenue can be calculated. Deferred revenue is calculated as the total revenue received for a particular funding source minus the total expenditures allocated to that funding source. The LEA places the funds in a deferred revenue account on June 30 and reallocates the federal funds back to the schools on July 1 in the amounts that were originally deferred. The LEA blends the June 30 deferred revenue with the other resources on July 1 and continues to process purchase orders in the school-based budget from July 1 through August 31(the end of the federal grant project period).

Since the State Fiscal Year is July 1-June 30 and the IASA/CSR grant project period is September 1-August 31, another allocation of expenditures, similar to the one performed at June 30, is required to calculate the individual program expenditures from July 1 through August 31. When these calculations are performed on August 31, expenditures should be allocated to the deferred revenue and the current year funding as one lump sum. When the unexpended balance is calculated for each funding source, the total allocated expenditures for that funding source (deferred resources calculated on June 30 plus the current year allocation) should be subtracted from the total cash received from that funding source (deferred plus current year cash receipts). If the expenditure allocation for that funding source is equal to or exceeds the deferred amount, the school should assume that the deferred funds were used first. The school should then report that the total funding source allocation for the grant project period was completely expended. Each school reports the amount of unexpended federal funds to the LEA. The LEA completes an IASA Final Report identifying the amount of expended and unexpended federal funds by Title as of August 31. If the unexpended balance is greater than the deferred amount, the difference represents the carry-over amount. The LEA has an opportunity to apply to carry-over any of these unexpended funds in accordance with the IASA Consolidated Application or CSR Guidelines. The same process is used by each school operating a schoolwide program without a school-based budget to allocate expenditures to various federal funding sources in Fund 20.

In the second year, the schools will need to be careful to perform the allocations in two pieces to ensure that only expenditures relating to the grant period of September through August are included in each program’s reported expenditures. This is not an issue in the first year because prior-year deferred revenues and carry-over funds were not blended into the school-based budgets in the first year.

Q45. How are federal IASA/CSR carry-over funds tracked for whole school reform schools with school-based budgets if all the funds are in a blended budget (first and second cohort schools)?

A. The LEA is responsible for submitting a carry-over application that accurately reflects the amount of funds available to carry over as of the end of the grant project period (August 31). Once the LEA determines the amount of funds to be carried over, the LEA has several options as described in the IASA Consolidated Application or CSR Guidelines. The LEA must select an option and complete the carry-over application accordingly. Once the carry-over application is approved, the LEA must expend the carry-over funds in accordance with the approved carry-over application or request an amendment in accordance with the IASA Consolidated Application or CSR Guidelines.

If the carry over is allocated back to the school and blended, the school will have to perform the expenditure calculations discussed in detail in the Abbott Addendum to The Audit Program for Reporting Whole School Reform Activities in First Cohort Schools 1999 – 2000. When these calculations are performed, expenditures should be allocated to the carry-over and the current year funding as one lump sum. When the current year deferred revenue is calculated, the total allocated expenditures for that funding source (carry-over plus current year allocation) should be subtracted from the total cash received from that funding source (carry-over plus current year cash receipts). If the expenditure allocation for that funding source exceeds the carry-over amount, the school should assume that the carry-over funds were used first.

If the LEA retains the funds at the district level, the LEA must track expenditures by program.

Q46. At the end of the federal project period, may LEAs move unneeded federal funds from school to school?

Yes. IASA and Class-Size Reduction funds may be returned to the LEA's central office and redistributed to schools based upon a mutual decision by the LEA and the schools. Title I funds may be redistributed to the schools in accordance with IASA Section 1113. These unneeded funds may also be maintained at the LEA to support district-level activities.

Q47. In a Title I schoolwide school using a blended budget, if equipment is purchased, is the federal tracking of equipment still required?

A. No. Title I schoolwide schools are not required to track purchases, including equipment, with funds in a blended budget. The school is accountable to ensure the use of funds is for schoolwide purposes.

Q48. Is it allowable to transfer funds from a Title I school to a non-Title I school?

A. No. Title I funds are to support Title I activities. A school must be eligible for Title I funding to receive such funds.