Maintenance of Effort (MOE) for Individuals with Disabilities Education Act (IDEA) Part B

Size: px

Start display at page:

Download "Maintenance of Effort (MOE) for Individuals with Disabilities Education Act (IDEA) Part B"

Shon Tyler
5 years ago
Views:

1 Maintenance of Effort (MOE) for Individuals with Disabilities Education Act (IDEA) Part B Texas Education Agency Division of Financial Audits Grant Audits Section

Copyright and Terms of Service Copyright Texas Education Agency, 2010.

2 Copyright and Terms of Service Copyright Texas Education Agency, The materials are copyrighted and trademarked as the property of the Texas Education Agency and may not be reproduced without the express written permission of the Texas Education Agency, except under the following conditions: 1. Texas public school districts, charter schools, and Education Service Centers may reproduce and use copies of the Materials and Related Materials for the districts and schools educational use without obtaining permission from the Texas Education Agency; 2. Residents of the state of Texas may reproduce and use copies of the Materials and Related Materials for individual personal use only without obtaining written permission of the Texas Education Agency;

3 Copyright and Terms of Service 3. Any portion reproduced must be reproduced in its entirety and remain unedited, unaltered and unchanged in any way; and 4. No monetary charge can be made for the reproduced materials or any document containing them; however, a reasonable charge to cover only the cost of reproduction and distribution may be charged. Private entities or persons located in Texas that are not Texas public school districts or Texas charter schools or any entity, whether public or private, educational or non-educational, located outside the state of Texas MUST obtain written approval from the Texas Education Agency and will be required to enter into a license agreement that may involve the payment of a licensing fee or a royalty fee. Contact TEA Copyrights with any questions you may have at copyrights@tea.state.tx.us.

4 On the Agenda Maintenance of Effort Legal Requirement Information Required Data used to determine compliance Determination Noncompliance Data Quality Adjustment to Fiscal Effort Exceptions

5 About the Presenter Yolanda Walker Audit Manager Division of Financial Audits Texas Education Agency (512) (512) facsimile

6 Legal Requirement PL , Section 613(a)(2)(A)(iii) Amounts provided to the local educational agency under this part shall be expended in accordance with the applicable provisions of this part and shall not be used, except as provided in subparagraphs (B) and (C), to reduce the level of expenditures for the education of children with disabilities made by the local educational agency from local funds below the level of those expenditures for the preceding fiscal year.

7 Information Required 34 CFR (b) Information The LEA must have on file with the SEA information to demonstrate that the requirements of paragraph (a) of this section are met.

8 What types of information? Actual audited financial data PEIMS Midyear Submission

9 The Data Where does the data come from? YOU!» Business Manager» PEIMS Coordinator» Special Education Director

10 The Data What is your role? Business Manager» Ensure funds are properly accounted for Payroll Non-Payroll» Ensure that expenditures are properly coded Proper use of Program Intent Codes PIC 99 The Myth vs. The Reality

11 The Data What is your role? PEIMS Coordinator» Ensure that PEIMS data is accurate Go beyond PEIMS edits Run Edit Plus reports and compare to internal reports Query data to identify unexpected variances» Understand data allocation methodology The Allocation Process for EDIT+ Reports

12 The Data What is your role? Special Education Director» Ensure that PEIMS data accurately represents your program Visit with business manager and PEIMS coordinator Review and approve budget (this is your program) Review and approve expenditures» Ensure compliance with state and federal program and fiscal requirements If properly implemented, the program will determine expenditures, not the other way around

13 Determination Auditors will use PEIMS Midyear Submission» Record 032 (allocated)» Record 033 (allocated) School districts only

14 Determination Step 1: collect allocated data Record 032 data» Districts fund code 199» Charters net asset code 199 and 420» All object, organization and fiscal year codes» Program intent code 23» Function codes 11, 12, 13, 21, 23, 31, 32, 33, 34, 36, 41, 51, 53» For fiscal years 2010 and 2011 only Include fund/net asset code 266

15 Determination Step 1: collect allocated data Record 033 data» Only applies to districts» Fund code 437» For fiscal years 2010 and 2011 only Include fund code 366

16 Determination Step 2: Compare the total expenditures of the preceding fiscal year to the second preceding fiscal year If expenditures increased or stayed the same, the LEA is compliant Otherwise, go to step 3

17 Determination Step 3: Count number of students enrolled in special education Step 4: Calculate expenditures per pupil Divide total expenditures for each year by applicable child count Step 5: Compare expenditures per pupil If expenditures increased or stayed the same, the LEA is compliant Otherwise, the LEA is noncompliant

18 Noncompliance If both total expenditures and expenditures per pupil decline, the LEA is noncompliant

19 Noncompliance Preliminary Letter of Findings No response or response does not result in an adjustment How to respond to the Preliminary Letter of Findings ( Concur with auditors findings Form A Erroneous PEIMS data submitted by the LEA/SSA Form H Adjustment to fiscal effort Form B Exceptions Forms C through G Note: Form A should be provided in all instances

20 Data Quality If you determine that your PEIMS data was erroneous, you will need to provide the following: Form H: Submission of Inaccurate PEIMS Data A statement signed by the superintendent and CFO representing that the midyear submission for either the succeeding or base year contained erroneous financial data that materially affected the auditors maintenance of effort analysis

21 Data Quality A schedule containing» Name and functional title of the individual(s) that prepared the schedule» Fields containing the following data elements for each individual amount erroneously reported to the PEIMS General ledger account code classification Erroneous amount Correct amount

22 Data Quality A statement certifying that the amounts disclosed on the schedule are accurate and all known errors were fully disclosed A statement representing that the amounts disclosed on the schedule are fully supported by the financial accounting records, including its general ledger and source documentation

23 Data Quality A statement signed by the independent auditor that conducted the audit for the school year in question» Consistent with GAAS, the independent auditor s statement should disclose consideration of the potential effect of the PEIMS data upon the opinion issued for the affected school year

24 Adjustment to Fiscal Effort PL , Section 613(a)(2)(C)(i) for any fiscal year for which the allocation received by a local educational agency under section 611(f) exceeds the amount the local educational agency received for the previous fiscal year, the local educational agency may reduce the level of expenditures otherwise required by subparagraph (A)(iii) by not more than 50 percent of the amount of such excess.

25 Adjustment to Fiscal Effort To be eligible LEAs must Meet the state targets for all five of the SPP compliance indicators (9, 10, 11, 12, and 13) and Have a determination level of Meets Requirements and Are not identified as having significant disproportionality. Will need to provide Form B: Assertion of Eligibility for Adjustment to Local Fiscal Effort and supporting documentation Will need to demonstrate Eligibility Actual amount of adjustment The amount of the adjustment expended on NCLB activities

26 Adjustment to Fiscal Effort PL , Section 613(a)(2)(C)(ii) If a local educational agency exercises the authority under clause (i), the agency shall use an amount of local funds equal to the reduction in expenditures under clause (i) to carry out activities authorized under the Elementary and Secondary Education Act of 1965.

27 Activities Parental Involvement Activities Drop out Prevention Programs for At- Risk Children and Youth Family Literacy Services Activities to Promote Family Support for Higher Education Mentor Programs

28 Exceptions PL , Section 613(a)(2)(B) A local educational agency may reduce the level of expenditures where such reduction is attributable to» The voluntary departure, by retirement or otherwise, or departure for just cause, of special education personnel RIF does not qualify

29 Exceptions Only applies to special education staff Voluntary departure Retirement Resignation Departure for just cause Lawful termination Will need to provide Form C Assertion of Exception 1 Departure of Special Education Personnel Supporting Documentation Source payroll record (e.g., personnel action form, payroll authorization form) indicating the reason (s) why the employee departed Payroll journal Schedule that agrees the payroll costs Employee s SBEC record (i.e. certification) Employee s sign and date job description

30 Exceptions» A decrease in the enrollment of children with disabilities Identify number of students that left the LEA Compare state special education allotment for each year Identify local funds used to support special education in each year Will need to provide Form D: Assertion of Exception 2 Decrease in the Enrollment of Children with Disabilities

31 Exceptions» The termination of the obligation of the agency, consistent with this part, to provide a program of special education to a particular child with a disability that is an exceptionally costly program, as determined by the State educational agency, because the child Has left the jurisdiction of the agency Has reached the age at which the obligation of the agency to provide a free appropriate public education to the child has terminated or No longer needs such program of special education Will need to provide Form E: Assertion of Exception 3 Termination of Exceptionally Costly Program and supporting documentation

32 Exceptions» The termination of costly expenditures for long-term purchases, such as the acquisition of equipment or the construction of school facilities Will only consider capital outlays Costly is defined by LEAs capitalization policy Will need to provide Form F: Assertion of Exception 4 Termination of Costly Expenditures for Long Term Purchases and supporting documentation

33 Exceptions 34 CFR (e) The assumption of cost by the high cost fund» Must have received a high cost grant» Will need to provide detailed general ledger and supporting documentation» Costs may only include those approved by TEA Will need to provide» Form G: Assertion of Exception 5 Assumption of Cost by High Cost Fund

IDEA-B LEA MAINTENANCE OF EFFORT (MOE) GUIDANCE HANDBOOK FOR FISCAL YEAR 2014 AND BEYOND

IDEA-B LEA MAINTENANCE OF EFFORT (MOE) GUIDANCE HANDBOOK FOR FISCAL YEAR 2014 AND BEYOND Texas Education Agency Version 1.0 (09/2013) Contents Introduction... 1 Relationship of Maintenance of Effort (MOE)