Federal IDEA Grant Guidance
Includes:
Federal IDEA Grant Introduction
Federal IDEA Grant Information
Allowable Costs
Final Reports
Maintenance of Fiscal Effort
Permissive Use of Funds/Flexible Funding
Early Intervening Services
Disproportionality and Overidentification
Proportionate Share of Spending for Children Enrolled by their Parents in Private Schools
Program Fiscal Review
Federal Grant IntroductionThe application and guidelines listed pertain to federal grants, Individuals with Disabilities Education Act (IDEA) Flowthrough and Preschool, with emphasis on the importance of:
· Application
· 27-Month Expenditure Period
· Directions on filing Federal Grant Application in Michigan Electronic Grant System Plus (MEGS+)
· Assurance Statements
· Allowable Costs
· Interim Federal Expense Reporting (IFER)
· Maintenance of Fiscal Effort
· Permissive Use of Funds/Flexible Funding
· Proportionate Share of Spending/Private/Parochial/License Home Schoolers
· Program Fiscal Review
This guidance is provided by Oakland Schools to assist in compliance with state and federal laws relating to the above-mentioned federal grants. This will assist in applying for these grants online via the Michigan Electronic Grants System Plus (MEGS+) developed by the Michigan Department of Education, Office of Special Education.
NOTE: How to apply for a Michigan Education Information System (MEIS) account number is available online at: https://cepi.state.mi.us/meis/login.aspx/
If you need any assistance, the following contacts are available at Oakland Schools:
Lydia Purol, Federal Grant Specialist 248.209.2208
Gina Chesnutt, Accounting Manager 248.209.2585
Eligibility - All students that have a valid Multidisciplinary Evaluation Team (MET) report and Individualized Education Program Team (IEPT) report are eligible to be counted on the annual Fall combined count date as a 1.0 Full Time Equivalency that in turn generates the Federal Allocation for Part B funding. The IDEA Flowthrough funds are generated with the 3-21 year old population. The IDEA Preschool funds are generated with the 3-5 year old population. (The 3-5 year olds are counted both for Flowthrough and Preschool funding purposes.)
Distribution of Funds - The Office of Special Education at the State of Michigan is allocated funding via a formula process by the United States Department of Education, Office of Special Education Programs. A majority of the funds, approximately 90%, are disseminated to school districts for programs and services for children and youth with disabilities under Part B. A percentage of the total grant award is used for state level administrative activities and special initiatives to address statewide and federal priorities. These initiatives are referred to as IDEA (2004) Mandated Activities Projects (MAPS). The purpose is to support mandated activities regarding policy, compliance, and federal regulations. The balance is allocated to Intermediate School Districts by their Fall combined count reporting data.
As written in the Intermediate School District Plan for the Delivery of Special Education Programs and Services, Oakland Schools ensures compliance with regulations and assists in meeting the needs of eligible students within Oakland County, by withholding 3.55% of the annual Part B flowthrough allocation. The remaining funds are distributed to districts in accordance with the Part B application and the LEA and PSA Fall headcount prior to the onset of the application.
Notification of Federal Allocation - All eligible LEAs and PSAs are notified by email of their federal grant allocations for both IDEA Flowthrough and Preschool grants annually. The allocations are also available on the MEGSPlus application.
Application Process - The purpose of this section is to clarify issues and concerns that are not part of the grant directions.
1) Grant Application -
The Federal Grant Application for IDEA Flowthrough and Preschool projects will be approved annually. The due date for submission is always July 1 at 11:59 PM. Any budgets received after that date and time would receive the date of submission for beginning expenditures.
Assurances need to be signed and submitted to the Intermediate School District prior to submission of application(s). The ISD collects signatures of local districts and keeps them on file at the ISD if funds are transferred out to local districts. By the ISD clicking the “SUBMIT” button for the grant application, the ISD is confirming that all District Assurances have been received and the ISD is also agreeing to all the listed Assurances.
2) Expenditure Period -
The IDEA Flowthrough and Preschool grant funds have a 27-month expenditure period. This means that the applications filed on July 1 have funds available on a continuous basis for 27 months.
An example of a grant cycle, July 1, 2016 through September 30, 2018, is listed below:
27-Month Cycle: July 1 - September 30
2016-2018 (27 months)
IDEA Flowthrough and Preschool grant sources have 27-month expenditure period for spending funds. However, you are allocated and must apply for new funds annually.
The following outlines the 27-month expenditure procedure:
· It is recommended to expend the entire 27-month allocation within the first 12 months of the grant expenditure period.
· If you choose not to expend the entire amount in the first 12 months of the grant cycle, you are required to report these expenditures from July 1-June 30 for year one and the balance of expenditures in year two, and potentially year 3. The 27-month expenditure period is managed in two 12-month reporting segments and one 3-month reporting segment listed on MEGSPlus as Interim Federal Expenditure Reporting (IFER). After the first 12-month expenditure period, the original budget would be broke down in year one actual expenditures and the balance would be reported under year two. We highly encourage that LEAs make every effort to spend funds within the first 24-months of the expenditure period. Though if not, a year three can be budgeted. This only allows 3 more months of spending.
Application Reminders:
1) Charter Schools -
Charter Schools are Local Educational Agencies (LEAs) and are part of the ISD plan. Therefore, all federal grant information must be shared with the Chief Executive Officer(s) of the Charter Schools and the signature of the Chief Executive Officer(s) must be obtained to indicate agreement with the statement of assurances.
2) Amendments -
An amendment is a report of programmatic or financial change to the grant. Revisions to the grant application should be made if the LEA wants to use funds differently than originally budgeted.
Allowable CostsThe “State Aid & IDEA Part B, Allowable Costs” must be followed in determining costs that can be charged to the grants. A copy of this document is sent to all ISDs, LEAs and PSAs and is available on the MDE website at the following link:
http://www.michigan.gov/documents/mde/StateAid_IDEA_PartB_Section611_Allowable_Costs_519694_7.pdf
Consistent with this criteria, please note the following:
a) Personnel - Funding for staff salaries and contracted services may be charged to the grant provided personnel meet Special Education personnel requirements as stated in 380.6(b) of the School Code. Aides and the ISD central registry position do not require special approval and may be charged to the grant.
Non-mandated Instructional Aides - Report non-mandated Special Education instructional aides by program assignment, not the disability category of the pupil. “LRE Aides” should be used for all individual pupil aides assigned by an IEP to work with a Special Education pupil in regular education. All LRE aides are assigned to a building and are under the direction and supervision of a Special Education “LRE team.” Note: Pool aides continue to be reported on the physical education line.
b) Budget, Salary, and Fringes - If salaries are charged to a federal grant, fringe benefits must also be charged, especially all retirement, Medicare, and social security. The entire fringe benefits are charged when the staff person is funded entirely from the federal grant. Fringe benefits are prorated based on the percent of time staff is funded from the grant.
c) Substitute teacher costs - Costs for substitute teachers are recorded under salaries on the budget line of the teacher for which the substitute works. Charging substitute costs to the grant is not limited to teachers who are funded from the grant. For example, even if the budget does not list charges for the emotionally impaired program, substitute costs may be charged to the line for teachers of the emotionally impaired. Substitute costs for a group of teachers to attend a conference/inservice is charged to salaries under function code 221, Improvement of Instruction.
d) Out-of-State Travel - Extensive use of federal grant funds for out-of-state travel for ISD, LEA and PSA administrative staff, instructional staff, and parents can violate the intent of the federal grants. For example, it may be very beneficial to send one staff member out-of-state for an innovative Inservice or model program visitation to enhance curriculum or program and service delivery. On the other hand, to charge out-of-state travel costs for several administrators, parents and teachers within an ISD to visit the model program begs fiscal and programmatic accountability. Out-of-State travel requires prior MDE OSE approval.
e) Inservice/Conference Travel - Travel is recorded under Improvement of Instruction as Function Code 221, Object code 3220 for instructional staff or as Function Code 283, Object Code 3220 for non-instructional support staff.
f) Instruction Equipment Repair & Maintenance - Repair and Maintenance is limited to instructional equipment only (i.e., hearing aides) used 100% for Special Education. (Report under Object Code 4120.) This does not include repair or replacement costs for copy, fax, or other non-instructional machines.
g) Rental of Special Education instructional equipment; i.e., wheelchairs. (Report under Object Code 4220.) This does not include rental of copy, fax, or other non-instructional machines.
h) Supplies – MDE expects that there will be procedures in place to manage inventory, especially of supplies subject to theft, such as Ipads.
i) Field Trips - Field trips are non-mandated and non-credit events which are considered extra-curricular or co-curricular activities. Example: school district may use funds to transport students to a local civic center to see a dance troupe perform. The admission fees should be recorded in the instruction function object code “4910”. Since this is not a regularly scheduled part of curriculum the cost incurred for transportation may be charged under function code 271 -Pupil Transportation.
j) Indirect Costs - The ISD/Agency is the federal grant recipient. Therefore, the ISD/Agency indirect cost rate is applied to the grant allocation. The ISD/Agency may pass the benefits of the indirect costs to their LEAs and PSAs. However, the LEA and/or PSA indirect costs charged to the grant must be the LEA/PSA assigned restricted rate or a lower rate.
k) Capital Outlay - Capital Outlay refers to non-consumable instructional equipment items costing $5,000 for each item or if you buy as a bundle, or pkg. deal, and it’s over $5,000 then it too would have to be capital outlay for federal grants and require prior approval before purchasing. Furniture and instructional equipment ordinarily available for regular education pupils such as movie projectors and lab tables are not reimbursable. Computers used 100% in Special Education classrooms for instruction is reimbursable.
Standard classroom instructional equipment such as desks, video and DVD players, and movie projectors are not allowable expenditures. Capital construction expenditures that become a permanent part of the building (i.e., cabinets and sinks) are not allowable.
A capital outlay log for equipment valued at $5,000 must be maintained. For each purchase indicate the following:
· A description of the purchase including manufacturer’s model number.
· Identification number, such as the manufacturer’s serial number.
· Identification of the grant under which the recipient acquired the equipment.
· Acquisition date and unit acquisition cost.
· Location, uses, and condition of the equipment.
· All pertinent information of the transfer, replacement, or disposition of the equipment.
Please request Capital Outlay through MEGS+. Once the request has been reviewed by the Office of Special Education, the ISD will notify the school district of approval or denial in MEGS+.
Please Note: All equipment, materials, and supplies including computers must be purchased for instructional purposes only. Computers for special education classroom teachers and auxiliary staff are allowable expenditures for IDEA Flowthrough and Preschool funds.
l) Auditing - Costs for auditing grants can be charged to each federal grant. Audit expenses should be reported under function code 231 (Board of Education) and object 3180. These costs are chargeable to the IDEA grant provided there is a bill showing actual IDEA grant audit costs. Prorated billings are not acceptable.
m) Mediation Fees and Hearing Officer Fees - Costs charged to school districts for mediation and hearing officer fees may be charged to IDEA flowthrough and Preschool funds. Parents must not be charged for these services.
Please contact Lydia Purol 248.209.2208, Oakland Schools, Financial Services, Special Education Fiscal Support Unit, if you need assistance in determining allowable cost expenditures.
Final ReportsThe only final report required by the IDEA grants is the final expenditure report, DS-4044, that states the actual project costs at the end of the 27-month expenditure period and is due 60 days from the end of the project (November 29). The Department Services form DS-4044 is a composite of the actual expenditures for LEAs, PSAs and the ISD. Please note that final budgets for each federal grant project should match the final cost report and single audit reports in your district.
Interim Federal Expenditure Report (IFER) -
If a district chooses not to expend their dollars in the first 12-month period of the grant, they are required to report the expenditures for each expenditure cycle on the Interim Federal Expenditure Report (IFER). The Interim Federal Expenditure Report (IFER) is located in MEGS+. The purpose of the IFER is to report each expenditure period. One represents the first 12-month expenditure cycle a second one represents the second 12-month expenditure cycle, and a third one represents the final 3-month expenditure cycle. The total of the three IFERs should match the budget reported on MEGS and total the districts full allocation amount.
TIPS:
o Budget your full allocation. (This is the only budget for the 27-month expenditure cycle.)
o It is recommended that you spend all funds in the first 12 months of the grant cycle.
o Enter your first 12-month expenditures on the IFER for your district.