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 state and local expenditurebased salary data. The presentation is based on the viewer being familiar with the comparability requirement and having viewed the title one part a comparability of services 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. State and local base salary data. Six common issues that we found school systems making when reporting state and local base salaries are not excluding salaries paid with federal funds. Not
002excluding salaries paid with supplemental state and local dollars or not excluding salaries paid with supplemental state and local local dollars consistently across all campuses and great span groups and not excluding staff salary differentials for years of employment. We only want to see the base salary. Common issues we found when school systems are reporting the state and local base salaries are uh not including all staff considered instructional staff and not having auditable documentation to support the state and local base salaries that are being reported on the CCF. A successful tip for reporting state and local base salaries is to exclude federal funds. No salaries or portion of salaries paid with federal funds can be included in the state and local expenditures. In the comparability instructions appendix 2 codes using comparability calculations, you will find a list
003of all state and local fund codes that are required to be included in the calculation. The list is applicable to the state and local base salaries 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 D exclusion of funds states that a school system may exclude supplemental state and local dollars. This statement applies to salaries paid with supplemental state and local dollars. It is not a requirement to exclude the supplemental state and local dollars. However, excluding salaries paid with supplemental dollars creates a more accurate picture of the campuses, making it easier to come into compliance with the testing requirement. Certain services are meant for specific students. Thus, salaries paid with supplemental state and local expenditures can vary from
004campus to campus based on student populations. Excluding the salaries paid with supplemental dollars can be critical when coming into compliance with the testing requirement if the number of salaries paid with supplemental dollars varies greatly from campus to campus. If a school system chooses to exclude state and local based salaries paid with supplemental state and local dollars, it must do it consistently across the school system. Appendix 2 of the Title One Part A comparability of services handbook provides further information on the supplemental state and local fund expenditures that may be excluded from comparability testing. A school system may exclude salaries paid with supplemental state and local funds for the following school program special programs. Language instruction educational programs such as bilingual education for emergent bilingual students. Excess state and local costs of providing services to students
005with disabilities as determined by the school system. state or local supplemental programs in any school attendance area or school which meets the intent and purposes of title one part A. The next tip for a successful submission is to exclude supplemental state and local dollars consistently. If a school system excludes supplemental state and local dollars from one campus's total state and local expenditures, it must exclude the same supplemental dollars from all campuses total state and local expenditures, all campuses, all grades span groups. And there is no flexibility with this requirement. ESSA section 1118 C2B for the purpose of comparability in the determination of expenditures per pupil from state and local funds or instructional salaries per pupil from state and local funds. Staff salary differentials for years of employment shall not be included in such determinations. School
006systems are required to exclude staff salary differentials for years of employment when reporting state and local base salaries. For example, a teacher with 15 years is hired for a position and paid $115. The position paid $100 initially, then $1 for each year of employment. Many districts call this steps. The school system would only report $100. No salary increases for years of employment can be included. This is specified in the law and there is no flexibility with this requirement. State and local base salaries must exclude benefits, stipens, and merit increases. Non-regulatory guidance on title one fiscal issues. It states, "If you choose to measure compliance by comparing student and 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
007non-title one schools. Instructional staff may include teachers and other personnel assigned to schools who provide instructional services such as music, art, PE, guidance counselors, speech therapists, and librarians and other personnel who provide services which support instruction such as school social workers and psychologists. So instructional staff refers to numerous categories of personnel. It does not mean teachers only. All non-federal positions which provide direct instructional services and or services that support instruction should be included unless they're paid with supplemental state and local dollars. State supplemental state and local dollars are excluded. You'll want to refer to appendix two of the comparability instructions for a list of role IDs that are considered 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
008instructions are normally considered instructional staff because these 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 budget records are the only records considered auditable documentation. For example, a computer accounting system records such as uh payroll journals reflecting the budgeted amounts are considered official records and are auditable documents. Auditable documentation includes reports from your school systems accounting system indicating the reported budget salary amounts by fund function and or codes. A PDF of this report is acceptable. Auditable documentation also includes any other official budget document which reflects approval by
009the board of trustees and/or superintendent. An Excel spreadsheet with the employees name and salary amounts 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 must have not indicating the scope of the data and the system from which it originated. These are not notations a staff member would make. They are a part of the export of the data. Recommended to use official accounting system records for state and local salaries being reported. Obtain the necessary salary and budget reports for all campuses by fund function and object codes from your financial accounting system. Exclude any state and local base salaries paid with supplemental state and local dollars. Exclude any and all benefits, stipens, and merit increases that are included in
010the salary amounts. It is likely that excluding merit increases will need to be done manually. This particular test requirement makes it more difficult to readily obtain the needed information and thus has the most margin for error. If salaries paid with supplemental, state, and local dollars are excluded, detail which salaries paid with supplemental dollars have been excluded and have documentation of the excluded amounts. Arrive at a reduced budget total to be reported. Provide the math used to arrive at the reported totals. For example, if a $100 was deducted for 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 salary amounts must be itemized. The original salary amounts, the same amounts as indicated on the original salary report. Any adjusted month
011any adjustments noted and the final amount reported must be made transparent in the support documentation. Keep all documents which support the state and local base salaries being reported as per the school systems records retention schedule. TEA does request this documentation on a annual random basis. This concludes our presentation. Should you have questions about this information, please email us. Our team members will be happy to assist you. Thank you.