001This presentation will discuss the requirement related to the title one part A campus allocations which has been selected for review as part of the program monitoring validation process being conducted by the federal program compliance division at the Texas Education Agency. This presentation is intended solely to provide general information and guidance to Texas LEAs, ESC's, nonprofit subgrantees, and participating private schools receiving equitable services. The content of this presentation reflects the Texas Education AY's current understanding of statute and applicable federal guidance. The content of this presentation is subject to change as a result of future guidance or other updates provided by federal agencies with regulatory oversight of these programs. This presentation does not constitute legal advice and entities are therefore advised to seek legal counsel regarding the information and guidance provided in this presentation before acting upon
002the education provided. The Texas Education Agency does not permit thirdparty recording or the use of artificial intelligence summary services during its grants related trainings. Attendees of TEA's grant related trainings may not use AI services, language models, applications, interfaces, or assistance to attend, review, or record the trainings. TEA further prohibits any person or entity from using the information included in its grants related trainings to train AI technologies. Any attendees of TEA's grant related trainings who violate this prohibition may be removed from the trainings and may be barred from attending future grants related trainings. Documenting overall compliance for a program requirement may require several forms of documentation to be maintained locally and available upon request by TEA and/or an auditor. To ensure overall compliance with program requirements, LEAs should refer to the program guide and/or other program
003related resources that reference the multiple forms of documentation required to be maintained locally. The documentation requested for submission during the validation process may not include all forms of documentation that are required to be maintained locally. The agenda for today's presentation will include a discussion of the specific program requirement, acceptable documentation for the validation, past validation issues, a discussion of examples, and the resources that are available. In general, LEAs are required to allocate Title One Part A funds to eligible campuses in rank order on the basis of the number of low-income children in each attendance area or school. An LEA that serves a campus with a low-income percentage below 35% must apply the 125% special allocation rule to all of the Title One Part A schools it serves. ELEAs with fewer than 1,000 students and LEAs
004consisting of a single campus were excluded from the selection pool for this validation because they are exempt from the rank and serve requirement that is tested through this validation item. For item 1.1, the selected LEAs must submit evidence showing the amounts of their Title One Part A campus allocations and how those amounts were determined. Acceptable documentation would include a spreadsheet showing the campus name, campus number, enrollment, number of low-income students, lowincome percentage per pupil amount, and the amount of the Title One Part A campus allocation for all Title One Part A campuses served for the school year being validated. Please note that the campus status, enrollment, and lowincome percentages should match the SC5000 for the school year being validated. Please also note that Title One Part A parent and family engagement funds that are allocated
005to campuses as part of the LEA's PF reservation requirement should be tracked separately and should not be included as part of the regular Title One Part A campus allocations. Issues that may result in an improvement needed status for this item include the following. Auditable documentation requested was not submitted. Campus allocations were not based on the number of lowincome students. The rank and serve rules were not followed. If required, the 125% special allocation rule was not applied correctly or the documentation submitted does not align with the SC5000 for the applicable school year. For item 1.2, LEAs must submit evidence connecting the Title One Part A campus allocation calculations to the campus budgets. Acceptable documentation could include summary pages from the general ledger showing the amount of Title One Part A funds allocated to each campus. Issues
006related to this item that may result in an improvement needed status include the following. The auditable documentation requested was not submitted. Campus names or campus numbers and their corresponding title one part A budget totals are not evident. Budgeted amounts are not related to the campus allocation calculations that were submitted or the documentation submitted was not for the school year requested. Okay. I'd like to take a couple of minutes now and address some of the issues that have come up in past validations of uh the title one campus allocation requirement. First, among the issues that we've identified are that calculations are sometimes based on campus enrollment instead of on the number of low-income students. The statute requires that the campus allocation be based on the number of low-income students. So if the LEA has used campus
007enrollment to calculate the campus allocation, that is going to be a finding. The second issue that we found is that there are sometimes rounding issues that get built into the spreadsheet when the LEA uses formulas to calculate uh the allocation amounts. uh sometimes uh rounding issues can get somehow buried inside the formulas and so leas may be having rounding issues created uh that they don't actually uh realize are happening and we'll discuss ways to um find that out and to avoid it. There are also um on occasion um a mismatch with the campus listing in the SC SC5000. Um the SC5000 in the consolidated federal grant application is the official record of which campuses are considered title one campuses. So, in order to create the campus allocation list, the LEA needs to be sure that
008they are listing the campuses as they are in their most recent SC5000 schedule. Another issue can be um is that the math doesn't quite work. Um so, your math teacher's advice about always checking your work is really important here. Um, as we'll see in our example, um, sometimes it can look right on the spreadsheet, but when you actually do the math, it's somehow not quite right. So, um, it always pays to double check your math. Sometimes we find that the LEA is grouping the campuses by grades span above 75% poverty and that is something that is not allowed in statute. Um the statute requires that campuses that are above 75% poverty be served in rank order. So the camp the the LEA does not have the flexibility to group by grades span for campuses that
009are above 75% poverty. Campuses that are 75% poverty and below can be grouped by grades span. And lastly, some uh something that can create issues for um eleas is if they are serving a campus that is below 35% poverty, um the LEA is required to apply the 125% special allocation rule. And sometimes this is not done correctly. So um the LEA is required to calculate what 125% of the uh campus allocation uh per pupil amount would be. uh taking the total uh number of low-income students in the LEA including any uh particip including any low-income students at private nonprofit schools um and divide that by the total number of students in the LEA plus the total number of students at the private schools and that is going to give a per pupil amount which is
010then multiplied by 125% which gives a minimum per pupil amount that the LEA is supposed to apply to all of its Title One campuses, not just the Title One campuses that are below 35% poverty. So that rule kicks in if the LEA is serving any campus that is below 35% poverty. Okay, so now let's take a look at u an example spreadsheet. Um on the surface, this particular spreadsheet looks like it's pretty good. It's got its campuses ranked from highest to lowest based on the number of low-income students. Uh the percentage of low-income students. Um it has a per pupil amount that's listed that on the surface looks pretty good because it's giving the same per pupil amount to all of these campuses that are above 75%. Then it gives another per pupil amount to
011campuses that are below 75%. And and that's fine. That's an allowable thing. Um but what happens if when we um do the math um if we take the number of low-income students at this first campus on elementary A which is uh 535 students and we multiply that by the 63425 that they claim as the per pupil amount we get an amount that is $339,323.75 which is not the amount that is listed here on the spreadsheet. So, this is what I'm I'm talking about when I say sometimes the math isn't mathing correctly. Um, if you take the number of low-income students and you multiply it by the per pupil amount, you should get the amount for the campus allocation. Um, so here it may be that there is a rounding issue somehow buried in the calculation.
012Um, I couldn't tell because uh it was a a a PDF file that came to me. So I could explore what the actual uh formula was but that's my suspicion is that there is a a a a rounding issue in here somewhere. Um so if we look at what happens if we took the amount that they said they were giving to the campuses which is the $339,063 and we divide that by the number of lowincome students. we should get the per pupil amount that they list. And as you see here, we don't get that. We get $633.76 and a decimal point out six places. So there there's obviously a problem here with the spreadsheet. Either it is not listing the campus allocation amounts correctly or it is not listing the per pupil amounts correctly. One
013or the other. Um so this particular LEA if they had checked their math could have seen that there was a discrepancy somewhere um and would have been able to um adjust their their campus allocations. Um one other thing that we notice on this spreadsheet is down here where they are skipping three campuses. Now in this particular case, this LEA has chosen to stop serving its campuses at the 80.78% mark to skip three campuses that are above 75% poverty and start serving again at 75.74% and serve uh then after 75% they are choosing to serve the intermediate group and the elementary group down to 58.80%. And that's fine as far as it goes. Um, but what this LEA should also do on its spreadsheet is to calculate the amount in supplemental state or local funds that
014it's going to be giving the skipped campuses. One of the reasons or one of the the requirements for skipping a campus is that the skipped campus has to be comparability of services requirements and that the LEA is going to give the skipped campus an amount that is equal to the amount that it would have gotten from title one part A funds. So what it could do here is to calculate what it would have gotten in title one part A funds and to indicate then that they're providing that amount from supplemental state or local sources such as state compensatory education. So they could take the 146 students that are listed here for um school in multiply that by the whatever the actual per pupil amount is. We'll we'll call it $634.25 25 cents since that's what's
015supposed to be showing here on the spreadsheet. Um, and they could come up with the amount of uh money that they would be giving this campus from state and local sources. So, that would be a way that they could improve the spreadsheet and show that they were giving their skipped campuses the amount in supplemental state or local funds that they were entitled to because they were not getting the those funds from Title One Part A. So again, some suggestions to consider when you're allocating Title One Part A funds to campuses. Please be sure that the campus list and the number of uh low-income students uh the number of low-income percentages match the most recent SC5000 for the LEA. Um, it's important that all of the campuses be listed and it's important that the low-inccome percentages
016match because the statute requires that the LEA make campus eligibility determinations and campus allocation determinations based on the same data set. So, whatever the percentage was or whatever the number of low-income students was um that created the the eligibility for that campus for title one part A services, those numbers need to be used to to determine the amount of the Title One Part A funds that the campuses receive. The other thing is to be sure that the labeling on the spreadsheet is clear um that these are the Title One Part A campus allocations. It's fine for there to be other funds represented on the spreadsheet. For example, um if the LEA is is also putting on the spreadsheet um what amount the campuses are getting from the um parent and family engagement reservation of funds,
017they can put them there. Um but those amounts are extra. They're they're over and above the amount that the LEA is getting for Title One Part A. Um and like we also mentioned uh on the previous slide, if there is a skipped campus that's getting supplemental state and local funds such as from state compensatory education um to function in lie of the title one part A funds. Um those funds can be represented on the spreadsheet but they should be labeled as state compensatory education funds so that uh they are not confused with the title one part A allocation. And the LEA really wants to avoid the rounding issues. Um, in in in truth, uh, the LEA really shouldn't be dealing in sense at all. They should be using whole numbers both for the number of
018low-income students because at least in Texas, we don't have any partial students. Um, the students are should be the number of students should be u a total whole number. Um, and the per pupil amount should be I mean the LEA really should make that a whole number. Um, when uh decimals get used for the per pupil amount, what that looks like is that the LEA has sort of backgineered uh or reverse engineered the the per pupil amount based on actual expenditures. And that's kind of backwards because this is supposed to be something that's happening at the beginning of the school year when allocations are made, when budgets are created. And so the LEA doesn't necessarily know what the final expenditure amounts are supposed to be for the campuses. So they should be dealing in whole
019numbers. Um that just takes the the whole rounding issue um out of the equation, so to speak. um because if you don't have uh decimals going into the calculation, you're not going to get decimals coming out of the calculation. So, um if you if the LEA has um a certain amount of money, you say they got, you know, an odd $49 or whatever that they have left over or that uh uh didn't come out uh even. um what they can do with that money is to take that $49 or whatever their amount is and put it in the allocation for the highest poverty campus. And in that way, um they would not run a foul of the campus allocation rules because that campus that's the highest poverty would be getting a higher peral amount than
020the other campuses and that is always an acceptable thing. Um or if they don't want to do that, they could take the $49 and they could add it to the amount that was being reserved at the LEA level. Um so that way they could get their their their budget to come out uh they could they could allocate all of their funds um but they wouldn't end up with rounding issues uh for their campuses. Next, we will review the resources and support that are available to assist LEAs in completing the program monitoring validation process. In the category of overall process resources, ELEAs can access the PMV process handbook, instructions, training video, and training slides for tips on submitting documentation and a video on how to navigate the Smart Sheet work app system. These, as well as
021other programspecific resources, are available on the ESSA program monitoring validations web page. For each requirement included in the validations, there is a guidance document that describes the acceptable documentation as well as training slides in a training video that discuss previous findings. These resources are available to eleas to review prior to submitting documentation for selected PMV requirements. Please take advantage of these documents to ensure that the district is informed of the overall process for program monitoring validations and all program specific resources. Complimentary technical assistance and training are available from each regional education service center. ESC contacts for each regional center are located towards the bottom of the TEA Title One Part A web page. Questions related to the program monitoring validations for the Title One Part A program may be directed to Vivian Smurl at essport
022tea.ex.gov.