001Okay, it's 10:55, so welcome back from your break. Um, we'll get on with the um remaining of the training, which is dealing with the uh the fun part, the the handing the money out, right? Um, that's always more fun than the the rules part. Unfortunately, there are also rules related to handing out the money. Um, however, right now, this is probably how you're feeling in terms of the amount of information that you've uh been dealt. Um, so I sympathize. Uh, but one of the reasons why we uh record these trainings and put them out available for you is so that you can come back and look at them again if you need to um after you've had time to digest uh what I already told you about the the campus eligibility and campus selection pieces.
002Okay. So I'm going to talk about uh the allocation of funds. There are two pieces of this. Uh we are drawing the the data that we are providing to you. Um from the uh US Department of Education guidance on the within LEA allocations. Um there is a link to this on um our website. We've provided it here in these slides. Um so if you want to go um look at the guidance document uh to see where we are drawing our information from uh that is certainly available to you. So, as Haime mentioned earlier, Title One Part A is essentially a campus-based program. ELEAs that receive Title One Part A funds must operate either a schoolwide program or a targeted assistance program at one or more of its campuses. Uh, the LEA can't simply operate Title
003One Part A from the district level. The LEA must make allocations to campuses, at least one campus, based on the number of low-income students at the campus. So, there are a lot of factors that determine the amount of funds that are available to be allocated to a campus. Um, the LEA has its title one part a total allocation. Um it comes from uh the entitlement that's generated. Uh usually at the beginning of the the grant year, the LEA is basing its application on a planning amount. Uh a planning amount for the the the regular entitlement for title one part A. Um the LEA has the option of transferring in funds from title 2 part A or title 4 part A under the funding transferability program. Uh, so those two fund sources, if the LEA uses
004the funding transferability program, would count as part of the LEA's total title one part A allocation. Um, those funds would be included in u calculating the percentages. For example, if uh we're determining whether the LEA uh meets the threshold for the required 1% for parent and family engagement activities, uh we would be looking at the LEA's entitlement from title one part A plus any transfers in from title 2 or title 4 through funding transferability. um funds that are uh whose purpose is transferred under the REAp program, the rural education flex um achievement program would not be included in that uh calculation. So it's just the LEA's entitlement plus what funds are transferred from title 2 and title 4 through funding transferability. And you see that on the PS3101 schedule. uh for uh title one part
005a you see in part one a uh the first part uh which is reap uh is only there for information uh in part 1B uh this is the title one part a funds that are available for the LEA to use either through uh its uh LEA reservations or through its allocations to campuses that includes the current year allocation funds from title one part A plus any funds transferred in under title 2 or title four. So the amount on line 4 part 1B is what's used to calculate uh the percentages on the LEA reservation schedule on the PS3101. So when we figure out how much funds are available to be allocated to the campuses, the LEA has to consider what reservations it's going to make. Um there are two categories of reservations for the LEA. Uh
006there are LEA there there are reservations that are required under statute which means that the LEA has to make those reservations if those situations apply. Um and then the LEA also has a category of authorized reservations which are reservations that may be made if the LEA chooses. And we're going to go over each of these. So on the PS3101 on part C, the LEA uh is required to put uh the amount of funds uh that it is uh reserving for uh these various activities and under the column reserved funds for the current year entitlement. So, if the LEA is choosing to use the uh uh the parent family engagement uh reservation, uh they would uh they would use uh line one here. Now, one of the things that um we want to point out is
007that uh there's a little bit of a mismatch this year uh between the consolidated application for federal funding and the uh consolidated compliance report. uh there's a crosswalk for the uh um compliance report uh that the LEA will be able to use for that. So let's talk specifically about the reservation of funds. The required reservations come from uh section 1113, section 1117, section 1116 um in the statute. So as as we said, we we have uh required reservations and authorized reservations. So, the required reservations, um, the first one is, uh, the private nonprofit school equitable services amounts. Um, the parent and family engagement, uh, 1% if the LEA's got, uh, greater than $500,000 entitlement. Um, all LEAs are required to reserve funds for the homeless children and youth. And LEAs may also reserve funds for
008children uh, in local facilities for the neglected. So we'll take these in turn. So the uh amount of funds that are required to be reserved for participation of children enrolled in the eligible uh uh private schools. Um we should sorry let me back that up. Um the private school reservation for equitable services is not applicable to charter schools. It's only applicable applicable to school districts that have private nonprofit schools participating in title one part A. Um there is a proportional share that is calculated uh based on uh information provided in the PS3099 the private nonprofit school schedule. So when the LEA completes its application, one of the schedules it completes first is the um the PS3099 for the private nonprofit school equitable services. Um if the LEAs are required to um reserve funds for private
009schools, uh that amount uh that's calculated from the PS3099 uh will be put uh the LEA will enter that on uh the line for private schools on the PS3101. If you have questions about how the equitable services amount are calculated um or in general um questions about uh equitable services for private schools, um we would like you to contact Lindy Trig. Her contact information is here um and she will be able to assist you with uh questions related to private school equitable services. The second area is uh for parent and family engagement. So if an LEA has a title one part A allocation of more than $500,000 that's either as a direct uh title one entitlement or the title one entitlement plus whatever has been added through funding transferability. Um, if that exceeds $500,000, then
010the LEA is required to reserve at least 1% of that amount for PFE activities. And out of that 1% amount, the LEA is required to distribute at least 90% to its title one part A schools with priority given to high needs schools. So, the LEA can retain no more than 10% of that 1% for LEA level PF activities. The LEA can reserve more than the 1% requirement if the LEA wants to retain more than that 10%. It's optional for LEAs that have a Title One allocation of $5,000 or less to reserve funds at the LEA level for PF activities. So for the parent and family engagement requirement um parents must have input into how those funds are used. Uh so they must be involved in the decisions for u how how funds are reserved and
011how those reserved funds are allotted for parent and family engagement activities. uh the 90% that's distributed to campuses uh those should be for activities that are jointly agreed upon by the school and the parent and family members of the children receiving services in that school. So there's a lot of um input um coordination that needs to happen um at the campus level to determine how those 90% funds that are distributed to campuses are used. The remaining 10% that is uh kept at the LEA level for PF activities. Those PF activities must be jointly agreed on by the LEA and parent and family members of children across the LEA from those title one part A uh schools. Um and those that feedback needs to be taken into consideration uh when determining how that 10% uh of
012the PF activities that 10% of the 1% how that's supposed to be spent. So the statute also provides that the funds that are reserved to carry out PF activities must include at least one of the following. So there must be either some type of PF related professional development at the district level. There must be some type of parent and family outreach at the district level or there must be u PF best practices um information dissemination, collaboration with community- based organizations or some other activity that's consistent with the LEA's PF policy. So at least one of these things must occur with the PF funds that are reserved at the district level. So as with all of the title one uh part A u use of funds uh there are general uh steps that the LEA must
013look at in order to ensure that the funds are used appropriately. Uh, for example, um, funds that are reserved at the district level must only be used to benefit Title One Part A served campuses. So, if the district has campuses that are not title one part A campuses, those campuses cannot benefit from the title 1A reserved funds. U, the district would have to ensure that those reserved funds are only being used for title one part A served campuses. The exception to that would be for services to homeless ch homeless children and youth. Uh so homeless children and youth can receive title one part a services at any campus regardless of their title one part a status. Um the LEA if they're serving those homeless students at non-title one part A campuses should be sure that
014they're serving them from the district level. The district never wants to have title one part a funds actually allocated to uh a title one or a non-title one campus. So you don't want to be using a non-title one or code uh for uh services to homeless students. You want to be using the district code to provide those services at non-title one campuses. Um the other exception would be for services to students who are at local facilities for the neglected. um those students would not necessarily have to be um attending a title one campus to receive services out of title one. The LEA could be providing those services um to those students um at the local facility for the neglected. would not have to be at a campus. Um to provide uh or in in in
015determining whether uh a particular activity can be done with uh title one funds at the district level, the LEA would need to be sure that they had a valid uh supplement not supplant methodology for allocating its state and local funds to its campuses or they'd need to have a statement a valid statement of exemption. Um so the theory on that is title one has extra flexibility concerning the supplement not supplant um provision. Um they have the flexibility of documenting their compliance with supplement non-supplant by having the methodology for allocating state and local funds to its campuses. Therefore any title one funds that are distributed on addition to those state and local funds would be considered to be supplemental. That's only for title one part A and for title one school improvement. However, all the other
016programs um would have to follow the traditional presumptions of supplanting. Um the LEA would also need to ensure that the activities and resources uh that they were uh using would have been identified in the current year's comprehensive needs assessment. Um and that they would be uh addressed in the district improvement plan. uh that plan would need to address how the activity was would be uh evaluated and how that plan uh that plan would need to address how those needs of students um who are most at risk of not meeting the state standards are being met. Uh the funds would have to be reasonable, necessary to carry out the intent and purpose of the title one part A program. They would have to be allocable under the grant and generally allowable under title one part A.
017Um the LEA would have to um ensure that they were meeting all of the the Edgar requirements. Uh that would be the education department general administrative regulations. Um uh those tend to be the the time and effort requirements. That's uh one thing that's part of the Ed Edgar requirements. Um uh requirements related to travel. Um those all fall under the Edgar uh regulations. Um and the ELEA would also have to ensure that its district policies and procedures are being followed because if the LEA is being more restrictive than the federal uh law then uh those more restrictive policies would come into play. Uh the third required uh reservation deals with homeless children and youth. There is a guidance document uh related to uh the services that can be provided to homeless children and youth. Uh
018we've taken uh the information from this document. Uh there's a wide variety of services that are available uh to help homeless students uh meet the state standards um and provide services that are uh include those that would be provided in title one schools but that are also maybe in addition to that might not ordinarily be provided to other title one students. The two basic uh principles governing the use of the title one part A funds to homeless students are that the the service has to be reasonable and necessary. Um and it must be a last resort uh so that those the title one funds um are made available for those services if the LEA has u been unable to obtain those services from other sources either public or private. Um so we have a a
019a list of things that uh can be provided with that. So um one of the questions we frequently get is in an LEA with non-title one in title one schools are homeless students uh who attend not non-title one schools eligible receive services and yes they are. uh the LEA is required to reserve sufficient funds to provide services to homeless students um who attend non-title one schools uh so that those services would be comparable to those who uh that they would receive if they were in a title one school. Um the services can be educationally related uh but they can also um in include um other services that might not ordinarily be provided to students. And how should the LEA determine how many how much funds uh to reserve uh for the comparable services? uh the
020the funds uh the LEA must determine that amount based on a needs assessment. So it uh the LEA can't just pull the number out of a hat. It can't just be the $100 that the LEA has to put to be able to get the application to submit. It has to be based on uh need. It has to be based on um an assessment of what homeless students would need from the LEA if the LEA were to u suddenly have homeless students. Um we frequently get told, you know, well, we don't have any homeless students in our district. Uh well, you're a house fire away from having a homeless student in your district. And so one of the things that the LEA should do as part of this needs assessment is to consider if we suddenly
021had two, three or four homeless students in our district, what would we need to be able to provide to them immediately? Because if you if you have students who become homeless in that kind of a circumstance, you don't want to have to take the time to do a needs assessment in order to determine what their needs are. You need to figure out what you would be providing. you need to figure out what kinds of services are available from other sources um and how title one part A would be used uh to uh supplement that. Um, we've created uh a revised spreadsheet uh a document that the eleas can use uh to to guide their needs assessment, something that they can maintain as documentation to show what they considered uh what other fund sources they looked
022at uh how they determined what their homeless reservation would be. And that that is available through uh the link that is here. Um, we neglected to put the link on the slides that you currently have, but we can replace that document and uh you'll be able to to have that. Um, Haime, if you are still on and you want to put the link to that worksheet in the chat so that they can have immediate access to it, that would be great. Thank you. So, the statute doesn't prescribe a specific amount. However, they do uh specify that it is supposed to be based on a needs assessment. Uh and that basically is also um uh what we've uh just discussed with the the uh use of funds document. Um the last category for the uh required
023reservations is for children who are in local institutions for neglected or delinquent or sorry local institutions for the neglected. Um if there is a neglected facility located within the boundaries of the LEA um the LEA would probably have completed uh the SC9000 which is a special data collection u every November uh which collects information uh that affects uh funding for the following year based on the number of students who were residing in the FAC. facility during the month of October. Um that part of the LEA's reservation or of the the LEA's entitlement is called the neglected share. Um if the LEA is to retain that neglected share, they must provide services to students who reside within uh that particular facility that generated those funds. So, uh, if the LEA has an institution for neglected children
024within its boundaries, the LEA is required to reserve Title One Part A funds to provide comparable services to the students who are in the neglected institution. So, there's a couple of ways this can happen. This can either be done through a reservation, which is like what we're talking about right now on the U on the PS 3101. uh the LEA could reserve the funds uh to provide services to the students u in the neglected facility. Um or if the LEA uh for example if the LEA has a is operating a campus at the facility which sometimes happens um the LEA could be providing those services as part of a campus allocation. And so just because the LEA has a neglected facility doesn't necessarily mean that it's going to be provided it's going to be providing
025services through the reservation but they would have to provide services either through a reservation or through the uh allocation to the campus. So that would be done on the PS3102 and the general use of funds for the reserved uh for the LEA reservations would also apply. So those are the four areas of the required LEA reservations. We're going to touch on uh the ones that are now authorized which the LEA may may choose to do. So the LEA may choose to uh provide services to students who are residing in local facilities for delinquent children. Uh they may reserve funds for uh the title for administration of the title one part A programs. Uh there would be a section for the administration of the title one program in general which would include then the programs for
026students at facilities for neglected or delinquent. And there would be also a reservation line for the title one uh for the administration of the title one programs for uh equitable services to private school students. There are also other authorized activities uh that the LEA can reserve funds for including um early childhood education uh to support schools uh that are in school improvement. Uh there can be other coordinated services that the LEA could provide services for such as summer school uh professional development. So if the LEA is operating a summer school for its title one programs, it could reserve funds uh for that purpose. If the LEA is providing professional development to all of its ele title one elementary teachers, the LEA could provide could reserve funds for that particular activity. It would just have to
027be something that the LEA was providing on a district level for its title one's campuses. Okay. So allowable uses of title one part a funds for uh the district reservations include uh services that it's going to be providing in general to its schoolwide program campuses, its targeted assistance campuses, um its homeless children and youth. So if if the LEA is providing uh services to these campuses that would be uh considered an allowable uh reservation. Unallowable use of funds for the reservation would be to include skipped campuses. If skipped if a campus is skipped, it is not a title one campus and it is not eligible to res to benefit from the LEA reservations that are made for title one part A. um if a campus is not served, it's not eligible for uh to benefit
028from the LEA reservation of funds. And if the title one campus or if a campus is not title one eligible at all, obviously it's not eligible to participate uh in the activities that are being conducted with the LEA reservations. So to participate in the LEA reservations, a campus has to either be schoolwide targeted or it has to the the the uh homeless students would be receiving services directly from the district. So let's walk through an example of what um LEA reservations might look like. So, if we had a total Title One Part A allocation of $5 million, that would be made up possibly from a $4 million Title One Part A entitlement. Uh we're transferring in $750,000 from Title 2 Part A and $250,000 from Title 4 Part A. So, we have a total of
029$500,000 to operate our Title One Part A program for the district as a whole. So in this particular example uh we're going to walk through each of the each of these steps talk about the particular activity what basis it is what the amount is and then how much the allocation is after the reservations. So our first required reservation was for title one private school equitable services. So we had 10% of the children from low-income families who reside in the LEA's title one school uh attendance area attend private schools. So this was going to be used to generate the proportionate share. So our activity is for the equitable services and administration of equitable services. So the basis for that would be the $5 million times the 10% equitable share calculation. that comes up to uh $500,000
030which it would include the $5,000 that reflects the proportional share of the uh PF reservation that's going to be used for private schools. So that would leave u that would account for uh $500,000 out of the title one uh entitlement. So that would leave $4,500,000 remaining after this particular reservation. So now we're going to look at parent and family engagement. So for parent and family engagement activities, we've got uh we have uh an entitlement that exceeds $500,000. So it has the LEA has to reserve at least 1%. It can reserve more, but it has to reserve at least 1% of the LEA's total title one allocation. We've already taken care of the amount for the private school u portion. So, uh we would be looking at uh $45,000 based on the 1% because we've already
031dealt with the uh 5,000 for the families for low-income students. So after that, we would then have uh $4,455,000. So then we have the homeless reservation. So based on need, we've decided to reserve u $525,000 uh for the children in local uh neglected facilities. uh we base that on a needs assessment. We reserve $325,000. So then after these two steps, we have 3,65,000. Other authorized reservations for preschool programs, we've decided to reserve uh the $200,000. for administration of title one programs, we've reserved $45,000. So now we're ready to allocate funds to campuses. So after having figured out what required and authorized reservation of funds that we were going to to make, now we're going to allocate funds to campuses. So we have a total of $3 million that we're going to allocate to our Title
032One Part A campuses in this example. And this is just an overview of the uh steps we just walked through. Now, one of the things that um we need to note is that because Title One is a C is essentially a campus-based program. If the LEO reservation exceeds 30% of the LEA's entitlement, that's sort of leaning toward being less of a campus-based uh program. So, if the LEA reserves uh more than 30% of its entitlement, the the agency may contact you for a justification for that particular uh to for that particular fact. Um, it's not that the LEA couldn't justify such a program, but we want to we we the the LEA uh needs to be prepared to uh give a reason for why more of the funds weren't being directed to the campus-based programs.
033So, we've dealt with all of these other issues and now we're going to talk about allocating funds to campuses. Um, hi May, am I stopping here? Uh, no, we can continue. Okay. Because I want to be sure that I get through all of it and we only have like half an hour left. Okay. So, Haime walked you through determining poverty counts and ranking and identifying eligible campuses. And so, now we're going to do the fun part about handing out money. So when the LEA is allocating funds to eligible eligible campuses, we need to think in terms of the amount per lowincome student that an LEA will use to allocate the funds. So the LEA has a lot of flexibility, generally speaking, in determining what that amount per lowincome student is. uh when we get to
034the 125% rule, there's a formula about how it has to be calculated. But outside of that, if the LEA is not using the 125% special allocation rule, the LEA has lots of flexibility to come up with what this number is. So, whatever number the LEA chooses for its per pupil amount, they're going to multiply that amount times the number of low-income students at the campus to come up with the campus allocation. Now, I want to stress that it doesn't matter whether the campus is going to be a schoolwide campus or a targeted assistance campus. The LEA would get the or the campus would get the same campus allocation because the amount per low-income student, whatever the LEA determines, is being multiplied by the number of lowincome students. It's not being multiplied by the number of
035students served. So, a schoolwide campus doesn't get to multiply that number by its entire enrollment because it's a schoolwide. they get to multiply it by the number of low-income students. If that same campus was going to operate a targeted assistance campus, it would multiply the per pupil amount by the number of low-income students, not by the number of students who was going to be served at the targeted assistance campus. So, it's important for the LEA to understand that. So, in in this little example that we have here, if the LEA is going to choose $1,500 as its low income as its amount per low-income student, uh, this particular campus has got 250 total students. $195 of them are low income. The LEA is going to multiply the the $1,500 times the $195 lowincome students to
036get $292,500 for the campus's title one part A allocation. So amount per low-income student times the number of low-income students gives you the campus allocation. And the LEA gets to select generally speaking the amount per low-income student. So when the LEA is figuring out how to do the campus allocations, they can either do it on a district-wide basis, so do it the same way for all campuses, or the LEA can choose to group campuses below or 75% and below by gradspan. Or if the campus is if the district is serving any campus that is below 35%, then the 125% rule will kick in. We'll talk about that later. So I want to talk first about just the LEAwide basis. So we're we're determining uh campus allocations based on the district as a whole. Okay. So
037here is my district. I have a campus at 78%, a campus at 70, a campus at 65, and a campus at 38%. I can choose as a district to have either the same amount at all of my campuses, the same amount per low-income student, or I can do a graded uh scale version. So, my campus at 78% I'm going to give $1,500 per low-income student. My campus at 70% I'm going to give $1,100 per low-income student. At 65% and below, I'm going to give $800 per student. So you see this trend as the campuses go down in rank order of poverty the district is giving them a lower amount per low-income student. Okay. So that's a a a trend that we need to understand. They can either have the same or they can you know
038go go down according to poverty percentage. Um, but you can't give generally speaking a higher per pupil amount to a lower poverty score. So let's look at weird animations. Okay, so I have a a chart here where I have the public school, the grades served, the enrollment, the uh free and reduced price lunch, uh, low-income students, uh, the poverty percentages. Okay. So, the LEA would want to develop and maintain a spreadsheet similar to this um when figuring out what its uh campus allocations are. So, this particular example, we've got it rankordered based on the num based on the poverty percentage. So, it's highest to lowest based on poverty. The LEA's lowinccome percentage is calculated by dividing the uh students who are eligible for free and reduced price lunch by or whatever poverty measure the district
039is using. So the low-income students for the district divided by the total enrollment of the district. That's going to give you the LEA's low income percentage. Okay. So in this particular example, the LEA is going to serve the campuses between 76% all the way down to 36.2%. So it's going all the way down to the district percentage. You can see here that there would be two campuses that are technically eligible for services because they're above 35%, but the district has chosen to stop at a particular point. That's the district's prerogative. They do not have to keep going until they run out of eligible campuses. The district, if they're serving in rank order from highest to lowest, they can come down this list until they feel like they can't maybe operate a a decent program uh
040for the amount of money that's left. We're going to stop. This is as far down the list as we're going to go. The district has has the the the option to stop where it needs to go on the list. So these two campuses, they're eligible, but they're not going to be served. So they would be marked on their SC5000 as not served. These campuses that are ineligible would also be marked on the SC5000 as not served. So there wouldn't be any distinction between these eligible, but not served, but ineligible campuses. They'll be treated the same way on the SC5000. So, these are the campuses that are uh being allocated funds. And here we have the 15 thou $1,500 per low-income child is going to the campuses above 75%. If you multiply $456 times,500, you'll get
041$684,000. uh the campus between uh or the campuses that are are below uh generally speaking, they're getting $1,100 per low-income student. The one that's at 487.1 is getting just a little bit more. Oops, let me back up. Just getting just a little bit more. That's okay. It doesn't have to be the same amount. Just it can't get it can't get more than the campus at 76. we can't give the campus at 46.3 more than we gave the campus at 41 47.1. So you'll see that that the the per pupil amounts also descend in rank order. Okay. Now I want to talk a little bit about grouping campuses by grades span. So we have um the elementary group, we have a middle school group, we have a high school group. Generally speaking, those are the grades
042spans that that fall within it. Um, the LEA can use different ones. Um, but we're trying to be simple here. Um, it could include uh preK through 1st and 2 through 4th. Middle school could be fifth and sixth and 7th through 8th. Could be a high school at 9th grade center and 10 through 12. U the LEA can create more grade spans uh for eligibility and allocation purposes. You could put the F preK through one in a separate one. Um, but we're trying to to keep it relatively simple. So, for this in this example, if you're grouping by grades span, you need to consider that campuses that are above 75% poverty are like a separate group. Okay? So, they're like a grade span, if you will, all by themselves because they're above 75% poverty. You
043could have middle schools, elementary schools, high schools in this group. They're grouped in this group because they're above 75% poverty. they get a particular uh low income per pupil amount per low-inccome student amount. Um campuses that are below are 75% poverty and below are what can be grouped by grades span. So my elementary school campuses that are 75% poverty and below can get a particular per pupil amount. My middle school students or middle school campuses can get a particular per pupil amount. My high school campuses can get a particular per pupil amount as long as the grades span groups don't get more per pupil than the campus group that's above 75% poverty. I also have the flexibility grouping by grades span like this to choose not to serve a particular grade span. So, I could
044say as a district, I'm going to serve above 75% poverty. I'm going to serve my middle or my elementary campuses. I'm going to serve my high school campuses, but I'm not going to serve my middle school campuses. The district has that option. So within a grade span, so say I had my campus above 75% poverty, I'm serving at $1,500 $1,500 per low-inccome student. my middle school grades span. If I decide to serve that middle school grades span, I can differentiate between the campuses within that grad span. I can either give them all the same amount, I can give them a lower amount for the lower poverty schools as long as I don't give a lower poverty campus a higher per pupil amount within that grade span. So, in this particular example, um, we have the
045above 75% poverty, getting $1,500 per low-income student. We have our elementary campuses starting out at 1,000 per low-inccome student, coming down to 800, coming down to 750. I have my high school campuses starting out at 1,200 and coming down to uh $1,000 per low-inccome student. Now, if you've been paying attention, you're going to tell me right away, "Wait a minute. I've got a 72% campus, 72% poverty campus that's getting 1,200 and a 75% campus that's getting a thousand. Didn't you just tell me that I couldn't give a lower I couldn't give a higher amount per student to a lower poverty campus?" Yes, I did. But once we group by gradespan, we're looking within this grade span. So, if I'm looking at elementary school campuses, I'm paying attention to what the the per pupil amount is
046within the elementary group. I don't get to peek over and see what the high schools are doing. Okay? So, I don't have to go across grades span to ensure that the 75% isn't getting less than the 72%. So, it's within the grades span group that that particular determination is made. The exception to that is the 75% above 75% poverty. That one has to be that one can't get less than it than any of the others. It has to get more than or equal to everybody else. Okay. Um another example in a different format here. Um, so here I have my above 75% poverty group, uh, getting $1,500 per child. In my elementary group, I'm choosing to serve the top four campuses. I'm electing not to serve the four campuses that come after that, even though
047they would be eligible. Um, when you group by grades span, you're comparing it to the gradespan percentage, not the district percentage. So this 34.3 campus could be eligible because it's above the 32.8 or the grades span group, but the district is within its um within its allowable options to serve just the top four campuses in this gradespan group and not serve the others. That's the district's choice. Uh, in this particular one, I have my high school group, which is the only campus in the group. So, it's eligible. Uh, I'm choosing to serve it. Uh, I've chosen in this particular case not to serve the middle schools even though we have a campus that's at 40% and it would be eligible. But if if the district decides not to serve its middle schools, that is an
048option that is available. Here's another example. I have my grade, my above 75% poverty school is served. I am choosing to serve Oops, one too many clicks. I am choosing to serve these other campuses um in rank order within each grade span. So that's consistent with the rules that we have just discussed. Okay. Now we're going to throw the wrinkle of the 125% rule in here. So 125% rule kicks in in situations where the district is choosing to serve a campus that is below 35% poverty. So in a case where the district percentage is 30%. The district has the option to serve down to 30%. So if it serves this campus that's at 31, it's going to trigger the 125% rule because the campus is serving the district is serving a campus that's below 35%
049poverty. So we mentioned earlier that when that happens, statute dictates how the per pupil amount is calculated. So the district once the 125% rule kicks in, the district doesn't have a choice about well it doesn't have a choice about the minimum amount that it can give to campuses. So let's talk about what that's going to look like. Why is it called the 125% rule? It's called the 125% rule because once it's triggered by serving a campus that's below 35%, every campus that the district serves with Title One Part A funds has to get at least 125% of the LEA's per pupil amount as calculated according to the statutory formula. So how we do that? statute says that to calculate the 125% you take the LEA's total title one part A allocation before any reservations were
050made so that amount of money and you divide it by the number of public school and private school lowincome children that gives you a per pupil amount which you then multiply by 1.25. So what does this look like? If we have an example where the total Title One allocation before any reservations were made was $2,500,000. The total public and private school children from low-income families is $1,243. Based on the statutory calculation, you'd take the $2,500,000, you'd multiply it by or sorry, you divide it by $1,243 and you would get $2,1121. You take the $2,11, sorry, 26. You'd take the that amount of money and you'd multiply it by 1.25 25 and you would get $25148. Now, what's weird about the 125% rule is that if you come up with cents, don't drop them. Do not
051round down. You round up regardless of what the rounding rules are about less than five, whatever. If you have cents for the 125% rule calculation, you have to go up, not down. So, the district would want to use uh $2,515 as its per pupil amount. So, it would take the $2515 and it would because you want it to be at least this amount of money. Okay? So, you that's why you don't drop the cents because if you drop the cents, it wouldn't be at least that amount. It would be less than that amount. So, I'm going to give this amount per low-income student to all of my Title One campuses, not just the one that triggered the low income, the 125% rule. So, here's what this would look like. you would take the the low-income
052students multiplied by the the 2515 and that would give you the allocation for each of the campuses that is being served by this district. Now, the last district on the list, yes, it has a different amount of money and it is less than the at least or the minimum amount that got calculated, but the statute provides that for the last served campus, the LEA can give a lesser amount if it feels that it can still operate a title one a a a decent title one part a program at that campus. So rather than not serve the campus at all, the district is choosing to give this campus, this lasts served campus, a lesser per pupil amount, but that's allowable under the statute. Okay. And there is also a related exception um that states that if
053the amount of the supplemental state or local funds the campus receives is less than uh what it would receive under title one part a. So if if the amount in state in state or local funds is less than what it would receive under title one part a sorry allows the LEA to reduce the amount of title one part A funds to the campus by the amount of supplemental funds that it spends on programs to meet the purpose of title one part a. So that in a nutshell are the rules for allocating funds to campuses. I want to talk a little bit about um some of the the the the uh campus selection reviews that we do and also um I hope I have time to go through an example spreadsheet to show you um some
054of the things that we find when we were reviewing uh the allocations during the uh validation process. So the SC5000 reviews that we do um we uh started doing them because uh grants administration streamlined the negotiation process. Uh so it limited the amount of uh things that were checked on the application before it was approved before it was no good. Um so the SC5000 is actually no longer reviewed during the negotiation process because that slowed it down considerably. we were we we wanted the ELEAS to be able to get their NOAs and get their programs started. Um so the S the review of the SE5000 shifted to the postawward uh time frame. Um we do feel like that we have to do some kind of check on the SC5000 just to be sure that the
055LEA doesn't get itself in trouble by allocating title one funds to a campus that's not eligible to be a title one campus. So um we feel that we need to do our due diligence to to ensure that um eleas aren't going down the wrong path uh with that. So we look at uh uh basic title one eligibility whether the campus is eligible for title one funds. We look and see that uh the schoolwide campuses the campuses that are marked as schoolwide are actually eligible uh to be schoolwide campuses. um that the LEA is generally following uh the rank and serve requirements that so that they're not uh serving campuses out of order when they're not supposed to um at least not without skipping them officially. Um and then we also look at uh the supplement
056on not supplant uh statement of exemption to be sure that the LEA is eligible for the statement of exemption that it's uh claiming. um we look at those between uh September or during the month of September, usually by the end of the month, we um export the data to look at. We crunch uh numbers and run queries against it uh to to see uh uh where the outliers are where where uh uh problems seem to pop up. And we will be notifying eleas of uh any deficiencies that we find um by the end of November so that the LEA can uh uh complete the correction process. We ask them to submit a draft amendment through the work app. Uh we review the draft amendment. Um, and then once we've agreed that if the LEA fixes
057it that particular way, then we tell the LEA, "Yeah, go ahead and submit the the the amendment in egrants and it can be processed." So, we try to get the SC5000 reviews done um and wrapped up uh by the end of January. I want to touch briefly on uh the uh issues that we found during the random during the uh validation process. Um, one of the mistakes that we sometimes find is that uh the calculations of the campus uh allocations uh are based on the campus enrollment instead of the number of low-income students. So, you want to be sure that you're using the number of low-income students, not the campus enrollment. The only time that would be the same is if you had 100% low-income students. Um, we find that there are frequently rounding issues
058that are built into the spreadsheets. Uh, that can cause some problems. I've got an example here I'm going to show you in just a minute. Um there can be a mismatch between the SC5000 and the uh spreadsheet that's submitted that the LEA uses uh to calculate the campus allocations. Whatever data is on the spreadsheet, that's the data that the LEA needs to use to calculate uh the campus allocations. So if uh the enrollments need to match uh the LEA needs to use the number of low-income students that it used to generate the uh poverty percentage that it reported on the SC5000. So we need to be dealing with the same data set. Um some of the issues uh that we find are directly related to ignoring your math teachers advice about checking your work. You
059always want to check your spreadsheet. Um Excel is your friend except when it's not. Um, sometimes formulas don't do what you think they're doing. Um, we found sometimes that eleas were grouping uh by grades spend above 75% poverty and that's not allowed under court uh according to statute. Campuses that are above 75% poverty are supposed to be served in rank order. So the the LEA doesn't have the option to group by grades span above 75% poverty. Um, sometimes the 125% rule is not applied correctly. Um, and if I had you in person, we would be doing this as like a table activity or whatever. But, uh, since I don't, I'm going to call up, uh, assuming I can find it. Ah, my mouse disappeared. There it is. Great. So, um, forgive my blur here. Can
060you see that? Hi, May. Am I sharing that correctly? Yes. Okay. So, here is a sample spreadsheet. You could just increase the size a little bit. Oh, picky picky. Yeah, I can do that maybe. It's trying. Okay, that's as big as I think I can make it. All right, so there's a lot of good things about the spreadsheet and I want to point those out, but then I also want to point out the things that are not so good on the spreadsheet. So the the spreadsheet shows the total allocation. It shows the amount that's coming in being transferred under funding transferability from title 4 part A. That's great. So we've got a total amount of money. Um we walk through the various uh uh district reservations. That's fine. We've got a total amount of money
061minus the district reservations minus the indirect costs min and so we come up with an amount of money that's going to be allocated to campuses. All that's great. Um the LEA has decided that it's going to use uh the $63425 for a per pupil amount above 75% and it's got a different per pupil amount for below 75%. On paper that's fine. Um, however, I want to caution you that you really don't want to use cents as in C ns. You don't want to use uh cents in your calculations. You want your per pupil amount to be a whole number. You want your number of lowincome students to be a whole number. There's no such thing as a partial child. So, so you've got uh whole numbers that you're dealing with. If you're dealing in whole
062numbers, you're going to avoid some of the rounding issues that are here. So, on paper, this looks good because it looks like you're getting through uh $734.25 cents per low-income child for all these campuses that are above 75%. But if you start multiplying, I've got a calculator. If you start multiplying, we'll start at the top here. 535 students times 63425 doesn't give me the same amount as what's listed here on this particular spreadsheet. Okay, that's a problem because the LEA is not giving the campus the amount of money that is actually supposed to be being generated here. So, let me do one more. So if we do 314 and we multiply it by 634 and 25 that doesn't give me the same amount as here 400 no 377 * 63425 Oops. That's what I get
063for trying to go too fast. 377 * 63425 doesn't give me the same amount as what I've got over here in this column. Why this is an issue is if we turn this around the other direction and we say I've got $339,000 and six and okay and $63. If I divide that by the number of low-income students 535, that should give me the per pupil amount. But as you can see, it doesn't give me the per pupil amount that is listed. This becomes a problem. So if if you just jot down beside, okay, $633.76. All right, that's what I'm giving my highest ranked campus per low income kid. If I do 199,165 divided by 314, I'm giving $334.31 and change to the lower the the next lower campus. I'm giving more per pupil to the
064lower poverty school. And that's gotten hidden in this particular format of the spreadsheet. Now, I couldn't tell whether the formula if it's a problem with the formula or problem with the rounding, but I can almost guarantee you that it's a problem with the rounding. Probably because they think that by taking the formatting for this down to 25 cents that it only is doing a two decimals, but the decimal continues and it keeps hiding in the formulas and it throws everything off. So, you can end up like this district having campuses that are lower poverty that are getting a higher per pupil amount which is in direct violation of the way it's supposed to work in statute. Okay, so I know that was too fast. We'll close that. Where did it go? Okay. So, the LEA
065needs to consider all of these things while they're doing their uh spreadsheet. So, you need to be sure that the campus list on the SC5000 matches the most recent FC 5000. Uh you need to be sure that the labeling is clear. Uh, other things besides title one campus allocations could be on the spreadsheet, but you need to be sure that it's labeled correctly because your auditor needs to be able to know which funds you're talking about. Um, to avoid the rounding issues, please use the whole numbers. Um, you can take, as we saw in some of the earlier examples, you can you can take uh the difference out of either the highest one if it's too much. You can give them extra. if it's not enough, you can take it off the one that's at
066the bottom. Um, so there's ways of dealing with that um that that don't require having rounding issues. And please check your math because if if if x times y doesn't if you if you can't back it out and get the same number that you started with, it's a problem. Okay. Um I think we're out of time. U I have a list of resources that are also available. There are links to these um through the rest of the the presentation. Um your education service centers are great resources for you. Um as you're trying to work through these um also if you if you have a particular question about eligibility or allocations, you are welcome to um email us at ESA support. Um we're happy to set up a call and talk about your particular situation because
067I know that that in doing this um some of the things we talked about may not apply to you. some things that uh do apply to you, we may need to talk about it in a little bit more depth, um we're happy to do that. Uh just give us a call or an email and we'll we'll we'll set something up with that. So um that's all the time that we have. If you would please take the opportunity to give us some feedback on this presentation, um we would uh uh greatly appreciate that. We do take uh your input uh into account as we try to u design new and improved presentations to help you. So if you can let us know what worked for you, what didn't work for you, what you need instead or
068in addition to um we would really appreciate that. Hi mate, did you have anything else? That is it. Thank you for joining us.