Examples ofAccountingProcedures an LEA with SchoolsOperatingSchoolwide Programs can Useto Account forConsolidatedFunds

EXAMPLE 1:

In this example,an SEAcreates,through its electronicconsolidated fundingapplicationsystem,aprocessthat allows anLEAto list the program funds eachschoolplans toconsolidate in its schoolwideprogram.This enables theLEA to createaconsolidated schoolwide pool, with its own accountingcode,forall of theschoolsoperating a schoolwideprogram. The program fundsdistributed to a schooloperatingaschoolwide programthat are includedin the consolidation losetheiridentityandmaybeused foranyactivityconsistent with the school’sschoolwideplan.

As illustrated in Chart A below,anLEA determines foreach of its TitleIschools operatingaschoolwideprogram howmuch eachprogram included in its schoolwideprogramcontributes to theconsolidatedschoolwidepool.As each of its schoolwide schoolsspends moneyforactivities to supportits schoolwideplan, the LEA draws downfunds and charges them to eachprogram contributingto theconsolidatedschoolwidepool based on the proportionateshares shown. Forexample,because TitleI,Part A contributed 8 percent of the funds to the consolidatedschoolwide pool, theLEAwould knowthat8 percentof theexpenditures madefrom the consolidatedschoolwide pool forall its schoolwideschoolsshould be attributed to TitleI, PartA. NotethatanyFederal funds not included in the consolidatedschoolwide pool must be accountedforseparately.

ChartA

ProgramsContributingFundstotheConsolidatedSchoolwidePool
SchoolBuilding / FederalFunds / StateandLocalFunds / TotalforEachBuilding
TitleI -ADisadvantaged / TitleII-AImprovingTeacherQuality / TitleIV-ASafeandDrugFreeSchools / IDEA-B
A / $182,535 / $25,000 / $10,685 / $94,462 / $2,048,115 / $2,360,797
B / 115,455 / 25,000 / 20,071 / 27,709 / 1,380,884 / 1,569,119
C / 181,780 / 25,000 / 23,686 / 69,272 / 1,940,161 / 2,239,899
D / 141,900 / 110,437 / 22,351 / 93,202 / 1,999,902 / 2,367,792
E / 229,460 / 110,437 / 27,546 / 61,715 / 1,936,291 / 2,365,449
F / 169,860 / 110,437 / 23,796 / 54,158 / 1,525,307 / 1,883,558
TotalFundsLEADistributestoIndividualSchools / 1,020,990 / 406,311 / 128,135 / 400,518 / 10,830,660 / 12,786,614
PercentofTotal / 8% / 3% / 1% / 3% / 85% / 100%

Thefirstlineofthetablereads:SchoolAcontributes$182,535inTitleI-Afunds,$25,000inTitleII-Afunds,$10,685inTitleIV-Afunds,$94,462inIDEA-Bfunds,and$2,048,115inStateandlocalfundstotheconsolidatedschoolwidepoolwithintheLEA.

Althoughprograms consolidated in a schoolwidesettinglose their identityandLEAs arenot required totrackexpendituresbyspecific program, Stateaccounting guidelinesgenerallyrequirethat anLEA be

able to identifyexpenditures fortheentireconsolidated schoolwide pool byfunctionalcategories likesalaries,travel, and supplies, etc. 1 However,anLEAwould not be required to track how much itspends on salaries, for example,back to a specificprogramincluded in theconsolidated schoolwidepool.

1 AnLEAwouldaccountforindirect costs for allFederal programs on adistrict basis in accordancewith §§75.560 through 75.563 of EDGAR before allocating Federalfunds to individual schools forconsolidation,whereapplicable, in a schoolwide pool.

EXAMPLE 2:

This examplelooks at a singleschool. Here anLEAestablishes aconsolidated schoolwide pool fromwhich a schoolwide buildingusesall oraportionof theFederal, State, andlocal funds it receives tosupport its schoolwideactivities consistent with itsschoolwideplan.Although the program fundsincluded in theconsolidated schoolwide pool losetheiridentityandmaybe used foranyactivityconsistent with the school’sschoolwideplan, theLEA,foraccountingpurposes, still attributesexpenditures of thosefunds back to a specific programregardless of what services those funds support.AnLEAmayuse anyreasonable method to demonstratethat the funds in aschoolwideprogram havebeenexpended. Two options are illustrated below:

Option 1– Distributionof ExpendituresBased on Revenues

A buildinghas aschoolwide program with a totalof $1,000,000 in revenues from the programs shownin Chart A below:

ChartA

SourceofFunds / Revenues / PercentofTotal / Expenditures
Total / $1,000,000 / 100.0% / $950,000
StateandLocalFunds(includedinschoolwideprogram) / 520,000 / 52.0% / 494,000
FederalPrograms(includedinschoolwideprogram)
TitleI,PartA / 240,000 / 24.0% / 228,000
TitleII,PartA--ImprovingTeacherQuality / 40,000 / 4.0% / 38,000
IDEAPartB(SpecialEducation)* / 50,000 / 5.0% / 47,500
TitleV,PartA / 70,000 / 7.0% / 66,500
CarlD.PerkinsCareerandTechnicalEducationAct / 80,000 / 8.0% / 76,000

Thefirsttwolinesofthetableread:Ofthe$1,000,000includedintheconsolidatedschoolwidepoolfortheschoolbuilding,$520,000(52percent)isfromStateandlocalsourcesand$240,000(24percent)isfromTitleI,PartA.Thus,52percent($494,000)oftheexpendituresareattributedtoStateandlocalsourcesand24percent($228,000)toTitleI,Part A.

* See response in E-10 concerninghowaschoolwide programmayconsolidate fundsreceived underPart BofIDEA.

In this option, theLEA allocatesall buildingschoolwide programexpendituresbased on theproportionof program revenuescominginto the buildingand budgeted forschoolwide activities.Expendituresareallowablewithoutregardto whethertheysupportthe programthatgenerated the funds so longas theyareincurred to support the schoolwideprogramplan.

Like thefirst example, althoughprogramsconsolidated in a schoolwide settinglose their identityandLEAsarenotrequired totrackexpendituresbyspecific program, Stateaccounting guidelinesgenerallyrequirethatanLEA beable to identifyexpenditures forthe entireschoolwide consolidated pool byfunctional categories such assalaries, travel, and supplies, etc.2 However, anLEAwould not berequired to track how much it spent on salaries, for example,back to a specific programincluded in theconsolidatedschoolwidepool.

Option 2– SequenceCharging of SchoolwideExpenditures

Another option is foranLEA tocharge 100 percent of allemployee and non-employeeschoolwideexpenditures in a school buildingfirst to State andlocalsourcesand then toTitleI,Part Aand otherFederalprograms until these funds arespent in their entiretyor until themaximum carryoveramount isall that remainsunexpended. Thechart belowuses the figuresfrom Option 1 to illustrate how sequencechargingmight work.

SourceofFunds / Revenues / TotalExpenditures($950,000)ChargedtoFederal,State,andLocalPrograms / AmountRemaining
TotalIncludedinSchoolwideConsolidatedPool / $1,000,000
StateandLocalSources / 520,000 / - / $520,000
TitleI,PartA / 240,000 / - / 240,000
TitleII,PartA--ImprovingTeacherQuality / 40,000 / - / 40,000
IDEAPartB(SpecialEducation)* / 50,000 / - / 50,000
TitleV,PartA / 70,000 / - / 70,000
CarlD.PerkinsCareerandTechnicalEducationAct / 80,000 / - / 30,000 / 50,000

Thistablereads:Ofthe$950,000expendedfromtheconsolidatedschoolwidepoolfortheschoolbuilding,thefirst

$520,000inexpensesischargedtoStateandlocalsources;thenext$240,000ischargedtoTitleI,PartA;andthenext

$40,000ischargedtoTitleII,PartA.$50,000remainavailableforexpenditureinthefollowingyear fromthe CarlD.PerkinsCareerandTechnicalEducationActprogram.

* See response in E-10 concerninghowaschoolwide programmayconsolidate fundsreceived underPart BofIDEA.

AnLEAmayattribute employeeand non-employee expendituresto particularfund sources withoutregard to whethertheyactuallysupport the fund sourceso longas theexpendituresincurred support theschoolwideprogramplan. Like theother examples, althoughprograms consolidated in a schoolwide

2 AnLEAwouldaccountforindirect costs for allFederal programs on adistrict basis in accordancewith §§75.560 through 75.563 of EDGAR before allocating Federalfunds to individual schools forconsolidation,whereapplicable, in a schoolwide pool.

settinglose their identityandanLEA is not required to trackexpendituresbyspecific program, Stateaccountingprocedures generallyrequire that anLEAbe able to identifyexpenditures fortheentireconsolidatedschoolwidepool byfunctionalcategories such as salaries, travel, and supplies,etc.

However,anLEAwould not be required to trackhow much it spent on salaries,forexample,backto aspecific program included in the consolidated schoolwide pool.

Source: [United State Department of Education Non-Regulatory Guidance: Title I Fiscal Issues, February 2008]