001Hello, welcome to TEA's Federal Fiscal Compliance and Reporting Division's presentation on the ESSA fiscal requirements for title one part A comparability of services. This presentation will specifically review the reporting and documenting of instructional staff FTE data. This presentation is based on the viewer being familiar with the comparability requirement and having viewed the title one part A comparability of services general overview presentation. So let's begin. This is the standard TEA disclaimer. It explains that this presentation is intended solely to provide general information and guidance to school systems. It reflects TEA's current understanding of the applicable federal guidance and it does not constitute legal advice. This is TEA's AI disclaimer. It states that TEA does not permit recording or use of AI summary services during this training. The consequence of this action would mean being removed from
002future training opportunities. Okay, based on last year's validation review of the CCF, TEA has identified common issues which are occurring among school systems. We believe additional clarification is needed. The CCF data being submitted appears accurate in regard to items such as grade span groups, high low enrollment splits, etc. But the issues identified are not occurring within how the school systems are conducting the comparability testing. The issues are occurring within the data the school systems are using in the comparability calculations. The fiscal requirements for the comparability requirement are federal law because the consequence of non-compliance with the comparability requirement is the return of all title one part A funds for the fiscal year. TEA collects the comparability data during the fiscal year under review. This allows for any non-compliant campuses to be brought into compliance with
003the requirement. School systems are required to test for compliance using current year budget data. The term expenditure is used, but because the requirement is tested during the current year, you must report budget data instead of expenditures. Because it is required to test for compliance using current year budget data, the school system should not be reporting any previous year data or any current year total expenditures to date when they're reporting the state and local expenditures. So, for example, for school year 2526, you'd report the 2526 enrollments and the state and local budgeted amounts and FTEES, etc. Nonfederally funded instructional staff FTEES. Six common issues that we've seen when reporting non-federally funded instructional staff FTEES per pupil. Uh, not excluding FTEES paid with federal funds. Not excluding FTEES paid with supplemental state and local dollars. Not excluding
004FTEES paid with supplemental state and local dollars consistently on a consistent basis. reporting staff counts instead of FTEES, not including all FTEES that are considered instructional staff FTEES, and not having auditable documentation to support the reported non-federally funded instructional staff FTEES. No FTEES or portions of FTEES paid with federal funds can be included in non-federally funded instructional staff FTEES. So in the comparability instructions appendix 2 titled codes used in comparability calculations, you'll find a list of all role IDs that should normally be included in the calculation. This list is applicable to the non-federally funded instructional staff FTEEs that are reported. The comparability instructions can be found on TEA's Title 1 Part A comparability of services web page. Public Law 115-64 section 1118 fiscal requirements the exclusion of funds states that a school system may exclude
005supplemental state and local dollars. This statement applies to FTEES paid with supplemental state and local dollars. It is not a requirement to exclude the FTEEs paid with supplemental dollars. However, excluding FTEEs pegged with supplemental dollars creates a more accurate picture of the school systems campuses, making it easier to come into compliance with the testing requirement. Certain services are meant for specific students, so FTEEs paid with supplemental state and local expenditures can vary from campus to campus based on the student population. Excluding FTEEs paid with supplemental dollars can be critical when coming into compliance with the testing requirement if the number of FTEEs paid with supplemental dollars varies greatly from campus to campus. If a school system chooses to exclude nonfederally funded instructional staff FTEES paid with supplemental state and local dollars, it must do so
006consistently across the school system and across grade spans. Appendix two of the title one part A comparability of services handbook provides further information on supplemental state and local fund expenditures that may be excluded from comparability testing. Thus, a school system may exclude FTEEs paid with supplemental state and local funds for the following special programs. language instruction educational programs such as bilingual education for emergent bilingual students. Excess state and local costs of providing services to children with disabilities as determined at the local level. State or local supplemental programs in any school attendance area or school meeting the intent and purposes of title one part A. Exclude FTEES paid with supplemental state and local dollars consistently. If a school system excludes FTEEs paid with supplemental state and local dollars from one campus total of non-federally funded instructional
007staff FTEES, it must exclude the same FTEES from all campuses non-federally funded instructional staff FTEES. All campuses, all grades span groups. There is no flexibility with this requirement. FTE is an acronym for full-time equivalent. A full-time equivalent count is not the same as a staff count. You can have 10 staff members, which may equate equate to five FTEEs. If each is halfime only, school systems are required to report non-federally funded instructional staff FTEES, not federally funded instructional staff counts. There is no flexibility with this requirement for FTEES funded through both federal funds and state and local funds or supplemental state and local funds and non-supplemental state and local funds. The portion of the FTE considered non-supplemental state and local should be calculated and reported. Per the public education information management system data standards, the PE's
008data standards, the full-time equivalency of nonfederally instructional staff members is calculated as illustrated in the examples on the following slides. If a staff member is employed for at least 187 days, which is considered to be full-time by the Texas Education Code, the FTE is calculated by determining the percent of the day spent teaching classes paid with state and local funds and then dividing the number by 100 days and teaches two classes paid with title one part A funds and four classes paid with state and local funds in a sixth period day. The four classes paid with state and local funds make up 67% of the day and 67 divided by 100 is 67. The nonfederal FTV FTE for this teacher is 67. Example two. If a staff member is employed for less than 187 days,
009the FTE is calculated by determining the percent of the day spent teaching classes paid with state and local funds, dividing the number by 100, multiplying the result by the number of days employed, then dividing the number by 187. Percent of day divided by 100 times days employed divided by 187. In this example, a teacher is employed for 175 days and teaches two classes paid with title one part A funds and four regular classes in a six period day. The four classes paid with state and local funds make up 67% of the day and 67 divided by 100 is 67. This result multiplied by 175 is 117.25. 25 which divided by 187 is 63. The nonfederal FTE for this teacher is 63. Per USDE non-regulatory guidance on title one fiscal issues. If a school system chooses
010to measure compliance by comparing student staff ratios or student staff salary ratios, the school system should consistently include the same categories of staff members in the ratios for both title one and non-title one schools. Instructional staff may include teachers and other personnel assigned to schools who provide direct instructional services such as music, art, and physical education teachers, guidance counselors, speech therapists, and librarians, as well as other personnel who provide services with support instruction such as school social workers and psychologists. Instructional staff refers to numerous categories of personnel and does not mean teachers only. All non-federal positions which provide direct instructional services and or services that support instruction should be included unless paid with supplemental state and local dollars, then it's excluded. Refer to appendex 2 of the comparability instructions for a list of role IDs
011considered instructional staff. Staff coded as instruction, instructional leadership, or instructional support should be included as instructional. The role IDs listed in appendix 2 of the comparability instructions are normally considered instructional staff because those roles normally either provide direct instructional services or provide services which support instruction. When in question, the school system should review the position's job description to make the determination as to whether the position is considered instructional staff for comparability purposes. Because comparability is a federal requirement, the information reported must be supported by auditable documentation. Official records are the only records considered auditable documentation. FTE documentation can vary from one school system to another. The school system has discretion as to the documentation to use. However, the documentation must be considered official documentation and supported through official records. Auditable documentation includes reports from the
012school systems accounting system indicating the FTEES by fund, function, and or codes. These reports can be in PDF format. Any other official documentation which reflects approval by the board of trustees and or the superintendent. An Excel spreadsheet with the employee names and FTEES is not considered auditable documentation. A data export from the school systems accounting system into Excel with the appropriate notations is considered auditable documentation. All exported data will have notations indicating the scope of the data and the system from which it originated. These are notations a staff member would make. They are part of the export of the data. It is recommended you use official financial system records for the state and local FTEES being reported. You obtain the necessary FTE reports for all campuses by fund function and object codes from your financial
013accounting system. You'll exclude any FTEES or portion of FTEES paid with federal funds. Exclude any FTEES or portion of FTEES paid with supplemental state and local dollars. And if FTEES or portions of FTEEs paid with supple supplemental state and local dollars are excluded, you will detail which FTEES paid with supplemental dollars have been excluded. Have documentation of the excluded amounts. Arrive at the reduced FTE total to be reported. Provide the math used to arrive at the reported FTE totals. For example, if 10 FTEEs were deducted for being funded with supplemental state and local dollars, show your math on your documentation and detail how the new total was achieved. All adjustments made to the original FTE totals must be itemized. The original FTE totals, the same totals as indicated on the original FTE report. Any adjustments
014noted and the final FTE totals reported must be transparent in the support documentation. You want to keep all documents which support the non-federally funded instructional staff FTEES being reported as per the school systems record retention schedule. TEA does request this documentation on a random basis. This concludes our presentation. Should you have any questions about this information, please email us. One of our team members will be happy to assist.