title i program directors training 1 developed by the office of title i

1Developed by the Office of Title I

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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

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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.

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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

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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)

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DETERMINING TITLE I ELIGIBILITY

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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.

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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%

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COMPREHENSIVE NEEDS

ASSESSMENT

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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.”

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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

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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

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Priority Problems

TITLE I PROGRAM DESIGN

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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.

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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.

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Targeted Assistance Programs (TAS)

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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)

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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

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Schoolwide Programs

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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)

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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

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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.

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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.

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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.

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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)

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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

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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.

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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.

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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."

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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.

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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.

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SERVING ELIGIBLE

NONPUBLIC STUDENTS

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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

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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

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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!

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Equitable Service Provision ESEA §1120

Step 1: Locating Nonpublic Students

Step 2: Counting Nonpublic Studentso Enrollment data, Income data

Step 3: Generating Nonpublic Allocation

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Equitable Service Provision ESEA §1120

Step 1: Locating Resident Nonpublic Students

Resident nonpublic schools

Bordering nonpublic schools

Transportation Documents (Busing routes, Aid-in-Lieu)

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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

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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)

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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.

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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

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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.

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PROFESSIONAL DEVELOPMENT

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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.

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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

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PARAPROFESSIONALS

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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

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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.

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FAMILY AND COMMUNITY ENGAGEMENT

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Why Family and Community Engagement?

It is required by law.

It helps raise student achievement.

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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.

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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.

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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.

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Language Instruction Education Program (§1111)

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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

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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

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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.

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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)

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Title I Parental InvolvementNotification Requirements for Districts

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http://www.state.nj.us/education/title1/program/parent/resources/Requirements.pdf

* Includes sample templates

ESEA FLEXIBILITY

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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

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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)

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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.

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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.

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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.

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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%.

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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.

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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

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● Targeted Assistance

● Schoolwide Programs

● Parental Involvement

● Paraprofessionals

● Private School Children

Web site: http://www.nj.gov/njded/title1/leg/

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US Department of Education Non-Regulatory Guidance

What Happens When Federal $$$ Are Misspent??????

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US Dept of Education- Office of Inspector General

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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

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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

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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) 633-2492oanthony.hearn@doe.state.nj.us

When in Doubt, Reach Out!!

609-943-4283titleone@doe.state.nj.us

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