tom torlakson state superintendent of public instruction 11 title iii lep/immigrant technical...

TOM TORLAKSONState Superintendent of Public Instruction


11

Title III LEP/Immigrant Technical Assistance: Required Annual Update of the

Local Educational Agency Plan and Budget

Veronica Aguila, Director English Learner Support Division

Lilia G. Sánchez Geoffrey Ndirangu Education Programs Consultants

Language Policy and Leadership OfficeCalifornia Department of Education



Presentation Goals

Participants will Be informed about the requirement and process for annually updating and submitting the LEA Plan Goal 2 (LEAP Goal 2) including the projected budget for the entire subgrant entitlement

Be provided with a template of LEAP Goal 2 that includes the projected budget for the entire subgrant entitlement and a template for just the budget update for multiyear LEAP Goal 2

Be provided samples of Title III allowable and unallowable activities and supplement, not supplant requirements 2



LEAP Goal 2 Annual Update Requirement

Per ESEA, Title III, Part A, section 3114: for a fiscal year, eligible LEAs must have a plan in accordance with ESEA, Title III, Part A, Section 3116 to receive Title III Funding (LEP & Immigrant)

3



Annual LEAP Goal 2 Update

LEAs who participate in the Title III, LEP or Title III, Immigrant programs are required to update their LEAP Goal 2 annually (ESEA, Title III, Part A, Section 3114)

The annual LEAP Goal 2 update must include a projected budget for the entire entitlement for the subgrant year

4



Annual LEAP Goal 2 Update(Cont.)

As part of the CARS “Certification of Assurances” Web page, the CDE requires LEAs to provide a direct link (URL) to their posted updated LEAP Goal 2 that includes the projected budget for the entire entitlement for the subgrant year

CDE staff will confirm that the updated plans including projected budgets are posted at the URL provided before releasing any funds to an LEA in 201516

5



Certification of Assurances

6



7

Year 3 or 4+ In CAIS

Step 1: Update LEAP Goal 2 with budget

Step 2: Post a PDF of both on local Web site Step 3: Provide the direct URL in CARS Certification of Assurances page

Note: Budget must account for all Title III supplementary activities expenditures

Year 0, 1 or 4+ Not in CAIS

Step 1: Update LEAP Goal 2 with budget

Step 2: Post a PDF of both on local Web site

Step 3: Provide the direct URL in CARS certification of assurances page


Year 2 or Year 4 In CAIS

Step 1: Use current “Accepted” Year 2 or Year 4 Improvement Plan plus updated LEAP Goal 2 with Budget

Step 2: Post a PDF of both on local Web site

Step 3: Provide the direct URL in CARS certification of assurances page


When applying for Title III Limited English Proficient/Immigrant funding for any fiscal year, eligible LEA must have an approved plan and budget under Title III Section 3116.Funds must be used to supplement other Federal, State and local public funds that would have been expended absent such funds.Provide in CARS Certification of Assurances page a direct URL to the updated LEA Plan Goal 2 and budget by June 30. Provide a separate budget if template does not have a budget column. In 2015-16 and thereafter, the LEAP Goal 2 and budget should be updated by June 30 in order to receive the first apportionment in August. Funds will be release to LEAs after confirming that the current plan and budget are posted at a designated Web address with a valid URL.LEAs may use the Year 2 or Year 4 current improvements plans or updated versions, for the required annual update. However , plan activities must be current and total LEAP Goal 2 updated budget for the entire entitlement for the subgrant year must be provided.

Title III Limited English Proficient/Title III ImmigrantAnnual Plan with Budget Update

Funding Process



LEAP Goal 2 Update

An LEA may use the LEAP Goal 2 template with budget columns for the required annual updates (See attached sample)

Please note, if an LEA uses the LEAP Goal 2 template without budget columns, the Title III projected budget for the entire entitlement for the subgrant year must be attached

8



9

Sample - LEAP Goal 2 with budget columns



LEAP Goal 2 Update

The CDE has developed a “Budget Update Sample Template” to use as an addendum to the multi-year LEAP Goal 2

(see attached sample )

10



11



LEAP Goal 2 Update This budget template is not designed to be

used in lieu of a full LEAP Goal 2 revision, but as an update to Goal 2 (Title III) of the LEAP Plan

It addresses only the proposed fiscal element; the expenditures for the activities of the applicable subgrant

It does not satisfy or replace the required Title III Year 2 or Year 4 Improvement Plan

Activities identified in the LEAP annually projected budget must demonstrate that the funding is used to supplement the level of other federal, state, and local public funds 12



LEAP Goal 2:Year 2 and Year 4

Improvement Plans

• If the entire projected budget for the subgrant year will be used to implement the improvement plan, the LEA may use the Year 2 or Year 4 Improvement Plan (LEAP Goal 2) to satisfy the annual update requirement

13



LEAP Goal 2:Year 2 and Year 4

Improvement Plans

• If only a portion of the entitlement for the subgrant year will be used to implement the Year 2 or Year 4 Improvement Plan (LEAP Goal 2), the LEA may use this plan plus the Budget Update Template to completely allocate the entire entitlement and satisfy the annual LEAP Goal 2 update requirement

14



LEAP Goal 2 Update

The LEA must

provide an update of the goals and activities where such have changed

must identify the required and allowable activities to be implemented with the proposed Title III funds

The LEAP Goal 2 must identify all items to be purchased in support of the activity in the projected budget for the entire entitlement of the subgrant year

This would include personnel, materials, programs and services consistent with the required and allowable activities of ESEA, Title III, Part A, Section 3115 and

are supplemental to other state, federal, and local funds15



LEAP Goal 2 Update

The LEAP Goal 2 must identify the projected budgeted amounts for each activity identified to sufficiently implement the action to meet the LEA goals

16



LEAP Goal 2 UpdateDeveloping a Supplemental Title III Program

Do all of the items in the LEAP Goal 2 and projected budget narrative meet the following criteria?

Are the activities and expenditures allowable? Are the activities and expenditures allocable?Are the activities and expenditures reasonable, sufficient, and necessary to carry out subgrant functions? Should the activities and expenditures be included in the 2% limit because they are administrative costs?

17



LEAP Goal 2 Update

Federal Criteria for Title III Activities Costs must be …Reasonable

A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the costAllocable

A cost is allocable to a cost objective if the goods or services involved are chargeable or assignable to the cost objective in accordance with the relative benefits receivedAllowable

A cost is allowable if it is necessary and reasonable for proper and efficient performance of the award and allocable to the award (OMB Uniform Guidance)

18



LEAP Goal 2 UpdateExamples of Unallowable Costs

Alcoholic beverages Donations and contributions Entertainment costs tickets to shows or sports events, meals, lodging

rentals, transportation, gratuities

MAY be Allowable Reasonable lunch for participants in a professional development activity, if there is no other opportunity to eat, and the activity is all dayReasonable snacks for students for Title III-funded summer or after school programs, and transportation for these programs, if needed and not provided by the district Tickets and transportation for educational trips, if part of high- quality language instruction educational program Reasonable refreshments for parent outreach activities

19



LEAP Goal 2 UpdateSupplement, Not Supplant Requirement

Questions to Ask When Considering Whether Title III Funds Can be used Without Violating the Supplement, Not Supplant Requirement

1.What is the general fund base instructional program/service provided to all students?

2.What does the LEA do to meet Lau requirements?

(Take appropriate action to overcome language barriers that impede equal participation in instructional programs)

3.What services is the LEA required to provide by other federal, state, and local laws or regulations?

4.Was the program/service previously provided with state, local or other federal funds?

20



LEAP Goal 2 Update

Supplement, Not Supplant Requirement

Questions to Ask When Considering Whether Title III Funds Can be used Without Violating the Supplement, Not Supplant Requirement

Based on the answers to the previous questions, would the proposed funds be used to provide an instructional program/service that is in addition to or supplemental to an instructional program service that would otherwise be provided to EL students (or be required to be provided by other laws/regulations) in the absence of a Title III grant?

21



LEAP Goal 2 UpdateAllowable or Not?

Sample Personnel Activities Portion of the salary of an assistant principal:

No, as the LEA is obligated to provide school leadership to run a school, and this individual would be required to work with all students, including EL students, in the absence of a Title III grant. All Administration would be in the 2 percent

Additional resource teacher who provides teachers support with integrating English Language Development into their lessons:

Yes, if the LEA is able to demonstrate how this position is supplemental and would not be provided absent Title III funds

22




Sample Personnel Activities Regular classroom teacher who delivers a child’s only language arts or ELD instruction: No. The LEA is obligated to provide a core language instruction educational program to the student

Stipend to teacher to assess newly enrolled students for English language proficiency:

No, as the LEA is obligated to assess the English language proficiency of students identified under the Home Language Survey for placement and identification purposes

23



LEAP Goal 2 Update

Allowable or Not?

Sample Professional Development Activities Stipend for a consultant to deliver ongoing PD on EL strategies beyond those of standards implementation: Yes, if training is above and beyond other training required under State law, and provided by LEA to teachers of ELs for the purposes and conditions of Section 3115 Payment of stipends for teachers to pay for substitutes so teachers may attend PD session described above: Yes, if training is consistent with the goals and conditions of Title III. Keep note that use of Title III funds for costs associated with training to administer the California English Language Development Test would be considered supplanting and not allowable

24




Materials (Sample)Textbooks that serve as a child’s main mathematics or language arts textbook: No. The LEA is responsible to provide this as part of the core educational program for all studentsSupplementary textbooks or reference guides that supplement the LEA-provided textbook and are for specific EL instructional purposes: Yes, if the LEA can demonstrate that they are supplemental to the EL Program and consistent with the purposes of Title IIIOffice supplies for the EL student intake center:No. Title III funds should only be used to support purchase of Title III-specific supplies for instruction, not supplies for the intake center

25




Activities (Sample) ELD curriculum development: Yes, if the LEA can demonstrate that this curriculum development is above and beyond what is the adopted ELD Program After school and/or summer programs: Yes, if the LEA can demonstrate that these programs are above and beyond what is provided for by the school, LEA, and State. Take note that students must have access to all programs for which they qualifyParents ESL classes: Yes, if the LEA can demonstrate that these programs are consistent with the purposes of Title III as outlined in Section 3115

26




Assessments (Sample) Title I and Title III funds may not be used to administer the California English Language Development Test (CELDT) for progress because:

Title I does not specifically authorize this expenditure, which is necessary because the requirement applied to all EL students (not just Title I students)

Use of Title III funds for this purpose would violate the supplement, not supplant requirement since the CELDT is a requirement under Title I

Neither Title I nor Title III funds may be used to develop or administer CELDT for identification and placement purposes except that Title III funds may be used for identification and placement assessments for private school students (if the use of such funds would not supplant other Federal, State or local funds that may be used for such purposes)

27



Funding Eligibility

CDE staff will confirm that the updated LEAP Goal 2 including the proposed budgets for the entire entitlement for the subgrant year are posted at the URL provided before releasing any funds to LEA in 201516

28



Funding Eligibility

CDE must verify that plans contain:

Required activities Allowable activities Reasonable and necessary activities

CDE will also verify that:

No additional administrative costs are interwoven into the activities

The entire entitlement for the subgrant year has been allocated

All subgrant activities are of supplemental nature

29



Release of Funds

In 2015–16 and each year thereafter, in order to receive the first apportionment in August

the LEAP Goal 2 including the projected budget for the entire entitlement for the subgrant year should be updated with all necessary content by June 30

The CDE will release Title III funds for the subgrant year to LEAs after confirming that:

there is an updated LEAP Goal 2 including the projected budget for the entire entitlement for the subgrant year

the LEA has provided a valid and direct Web link on CARS 30



2015−16 Funding Eligibility

LEAs that do not have a LEAP Goal 2 including a projected budget for the entire entitlement for the subgrant year are not eligible to receive Title III funds

Funding may be delayed to LEAs who do not provide approvable plan updates and/or links on CARS by June 30, 2015

31



323232

Supporting Documents

Supporting documents are posted at:

Title IIII Accountability Requirements 2014 http://www.cde.ca.gov/sp/el/t3/t3amaotargets14.asp

Title III http://www.cde.ca.gov/sp/el/t3/

CARS Web page http://www.cde.ca.gov/fg/aa/co/ca14rfa.asp

Office of Managements and Budget (OMB) Uniform Guidance at:http://www.ecfr.gov/cgibin/textidx?SID=ed90f54836feb6a994f657188eb05e33&node=2:1.1.2.2.1&rgn=div5#se2.1.200_134



333333

2014–15 Allocation Amounts

Funding amounts (Entitlements), including Maintenance Of Effort (MOE) reductions are posted at:

LEP: The CDEs Funding Results Title III-LEP Student Subgrant Program Web page at http://www.cde.ca.gov/fg/fo/r14/lep14result.asp

Immigrant: The CDEs Funding Results Title III Immigrant Education Subgrant Program Web page at http://www.cde.ca.gov/fg/fo/r14/imm14result.asp



343434

Title III Fiscal and Program Technical Assistance Contacts

LEP & Immigrant

Fiscal Questions: Patty Stevens, Associate Governmental Program Analyst, 916-323-5838 or [email protected]

Program Questions: Geoffrey Ndirangu, Education Programs Consultant, 916-323-5831 or [email protected]

Cash Management Allocations, Apportionments and Cash Management

Cash Management Data Collection System Questions: Karen Almquist, Educational Fiscal Services Consultant, 916-327-4406 or [email protected]



35

Lilia G Sánchez Education Programs Consultant

Language Policy and Leadership [email protected]

916-319-0265

Title III Accountability Requirements and Technical

Assistance Contact