Maintenance of Effort (MOE)
Illinois State Board of Education
Individuals With Disabilities Education Act (IDEA)
Maintenance of Effort (MOE) Pam Jurkoshek May 5, 2016 65th ILLINOIS ASBO CONFERENCE AND EXHIBITIONS May 4 – MAY 6, 2016 @IllinoisASBO #iasboAC16
Illinois ASBO Ethics Statement • The Moderator will help ensure the Illinois ASBO Code of Ethics is adhered to throughout the presentation and ensuing audience discussion. • Moderators are given the authority to ask any attendee to leave if they become combative with presenters • This presentation is to be informative and not to promote specific products, services, companies, etc. • If a vendor is a presenter and uses the presentation as a platform to “sell” their product or services, the Moderator has the authority to stop the presentation if the presenter refuses to modify their content. • Any vendor presenter who violates these regulations may be excluded from presenting at future presentations. • We ask the audience to join with us in respecting these guidelines.
65th ILLINOIS ASBO CONFERENCE AND EXHIBITIONS May 4 – MAY 6, 2016 @IllinoisASBO #iasboAC16
Compliance Requirement Funds provided to a local education agency (LEA) under Part B must not be used to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds below the level of those expenditures for the preceding fiscal year. (34 CFR §300.203) FY17 MOE Compliance Spent in current year ≥ expended last fiscal year (2014-2015 ≥ 2013-2014)
Methods for Meeting MOE LEAS can meet MOE by one of the following methods: □ Net Combination of State and Local Costs □ Per Capita Combination of State and Local Costs □ Net Local Costs Only □ Per Capita Local Costs Only
Local Funds – Net and Per Capita The MOE compliance data provided by ISBE is based on the AFR, which does not separate expenditures by state and local. Any computation of IDEA MOE compliance based on local (no state) expenditures, must be completed at the local level.
“Local Only” MOE ISBE preprinted MOE District Worksheets are prepared using information verified in the AFR which includes State and Local Funds both in total expenditures and per capita spending. A district that does not meet MOE using the State and Local Funds methods may meet MOE using the Local Only Funds methods. The district must submit the Maintenance of Effort by Local Expenditures form along with verification from the district’s auditor that the separated Local expenditures and State expenditures are accurate and together total the expenditure amount reported in the AFR.
AFR REFERENCE SHEET
Annual Financial Report (AFR) Lines Used to Determine Maintenance of Effort (MOE) FuncBon Number and DescripBon
Annual Financial Report Lines
SPECIAL EDUCATION EXPENDITURES 1000 2110 2120 2130 2140
Instruc*on (Special Educa*on Programs) A@endance & Social Work Services Guidance Services Health Services Psychological Services
2150 Speech Pathology & Audiology Services 2210 Improvement of Instruc*on Services 2220 Educa*onal Media Services 2230 2310 2320 2330 2410 2510 2520 2540 2550 2570 2600
40, 230 44, 234 45, 235
Assessment & Tes*ng Services Board of Educa*on Services Execu*ve Administra*on Services Service Area Administra*on Services Office of Principal Services Direc*on of Business Support Services Fiscal Services Opera*on and Maintenance of Plant Services Special Educa*on Pupil Transporta*on Internal Services Support Services -‐ Central
46, 236 49, 239 50, 240 51, 241 55, 253 59, 122, 257 60, 258 61, 124, 260, 338 Pupil Transporta*on & Claim Reimbursement Report 64, 263 72, 271
4000 Payments for Special Educa*on Program
FEDERAL FUNDS REVENUE 4600 IDEA Preschool Flow-‐Through 4620 IDEA Flow-‐Through
districts use only highlighted func*ons coopera*ves use any expenditure func*on as verified by afr
8, 9, 22, 23, 211, 212 36, 226 37, 227 38, 228 39, 229
79, 86, 94, 133, 183, 276, 300
218 220
RCDT Code
District
Maintenance of Effort by Local Expenditures / Per Capita
July 1, 2013 -‐ June 30, 2014
July 1, 2014 -‐ June 30, 2015
1 Total Special Educa*on Students December 1 2 1000 Instruc*on (Special Educa*on)
State
Local
Federal
Total*
State
Local
Federal
Total*
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
3 2140 Psychological Services 4 2150 Speech Pathology/Audiology 5 2330 Special Area Administra*on 6 2550 Special Educa*on Transporta*on 7 4000 Payments for Special Educa*on 8
9
Other (specify func*on) Total Special Educa*on Expenditures
Federal Revenue (IDEA)
Net Expenditures (Total less Revenue)
Per Capita
-‐ -‐ -‐ -‐
-‐ -‐ -‐ -‐
-‐
-‐
State *Per AFR / PTCR
Comparison
Local
Total
“Other” Expenditures The MOE District Worksheet (line 8) allows for a district to add expenditures approved in the IDEA Part B grant but were not included in the preprinted worksheet expenditures. Examples include OT/PT (2130 Health Services), Social Work Services (2110 Attendance and Social Work Services)
The district must submit the MOE District Worksheet (OTHER) attachment along with a copy of the IDEA Part B Flow-Through budget page and copies of vendor detail reports reflecting payment date and amount.
MOE DISTRICT WORKSHEET (OTHER) aWachment District: A@ach a copy of the IDEA Part B Flow-‐Through budget page and copies of vendor detail reflec*ng payment date and amount. As approved in the IDEA Part B Flow-‐Through budget FY_____ Func*on Obj. Code Expenditure Descrip*on $ Budgeted Date Purchased $ Expended
TOTAL EXPENDITURES $ -‐
Allowable MOE Exceptions □ Voluntary Departure of Special Education or Related Services Personnel Personnel leave due to retirement, resignation, or for just cause (School Board action) – does not include contract non-renewal, reassignment or staff lay-off due to RIF. □ Termination of a Costly Obligation for a Specific Child Student leaves the district, ages out, or no longer needs the program due to an IEP change. □ Termination of a Costly Long-Term Purchase Acquisition of equipment or the construction of school facilities.
Allowable MOE Exceptions (cont.) □ Decrease in Enrollment of Children with Disabilities Must demonstrate per capita spending ≥ previous year
Excep*ons to Maintenance of Effort Federal IDEA Regula*ons 34 CFR §§ 300.204 & 300.205 District Name Region-‐County-‐District-‐Type (RCDT) Name of Person Comple*ng Report Telephone Number Maintenance of Effort Shorkall from Worksheet $ -‐ 2014 -‐ 2015 The level of expenditures may be reduced below the level of the preceding fiscal year only if the reduc*on is a@ributable to any of the following. If the total of allowable excep*ons equals or exceeds the MOE shorkall, fiscal effort has been maintained. $ -‐ The voluntary departure, by re*rement, resigna*on, or for just cause, of special educa*on or related services personnel.
(Does not include contract non-‐renewal, reassignment or staff lay-‐off due to RIF.) employee name
posi*on
reason for leaving
salary & benefits
replacement name
salary & benefits
subtotals
$ -‐
subtotals $ -‐
total $ -‐ $ -‐ The termina*on of the obliga*on to provide an excep*onally costly special educa*on program to a child with a disability. (leaves the district, ages out, graduates, or no longer needs the program due to an IEP change.) (Specify ini*als of student, reason(s) expenditures are no longer needed, previous year placement, and the cost of the tui*on, transporta*on, aide or other.) student reason services not needed previous placement tui*on transport aide other total
total The termina*on of costly expenditures for long-‐term purchases, such as the acquisi*on of equipment or the construc*on of school facili*es (purchased previous year with unit cost of at least $1,000). descrip*on of expenditure date purchased
$ -‐
Total Allowable Excep*ons to Maintenance of Effort
$ -‐
$ -‐
unit cost
$ -‐
total ISBE Use Only
MOE Eligibility - 1 A district is eligible to receive IDEA funds by maintaining local effort. This is based on a comparison of the most recent complete fiscal year (up to 2 years) with the current budgeted amounts. The Illinois IDEA grant applications must identify the MOE eligibility status for each district. That is based on the most recent complete/finalized fiscal year. E.g. in FY16 districts used the FY14 fiscal records.
MOE Eligibility - 2 MOE eligibility has the same four options, or tests, for meeting the requirement: □ Net Combination of State and Local Funds □ Per Capita Combination of State and Local Funds □ Net Local Funds Only □ Per Capita Local Funds Only
FY16 IDEA Grant ApplicaBon FY14 local per capita and net expenditures How the district anBcipates/budgets FY16 local spending to meet the FY14 amounts.
IDEA MOE Reduction - 1 The 34 CFR 300.205 allows districts with an increase in federal Individuals with Disabilities Education Act (IDEA) funds to reduce maintenance of effort (MOE) by up to 50% of the amount of the IDEA increase, providing the freedup local funds are used for Elementary and Secondary Education Act (ESEA) activities. This is a voluntary option for districts that have an increase in IDEA allocations AND meet all MOE reduction criteria.
IDEA MOE Reduction - 2 A district with an increase in IDEA funds may take an IDEA MOE reduction, up to 50% of the increase (flowthrough only, not preschool). • LEA “Meets Requirements” determination is required. • LEA must be able to provide a free and appropriate public education (FAPE) to students with disabilities(no action against the LEA by ISBE) • If the district is also using IDEA funds for coordinated early intervening services (CEIS), the combination of IDEA MOE reduction and IDEA funds used for CEIS purposes is limited to the smaller of the two amounts.
IDEA MOE Reduction - 3 • Any “freed up” local funds must be used on Elementary & Secondary Education Act (ESEA) activities and the district must identify and document those activities. • Districts that elect to take a MOE reduction must submit a completed IDEA MOE Reduction form to the Special Education Services Division by September 30. • All MOE reduction records are subject to audit by the Illinois State Board of Education (ISBE).
QuesBons
Pam Jurkoshek Available at ISBE March – September 217-‐782-‐5589
[email protected]
IDEA MOE worksheets are available on the IDEA grant webpage at hWp://www.isbe.net/spec-‐ed/html/idea_part-‐ b.htm.
Individuals With Disabilities Education Act (IDEA)
Maintenance of Effort (MOE) Pam Jurkoshek May 5, 2016 65th ILLINOIS ASBO CONFERENCE AND EXHIBITIONS May 4 – MAY 6, 2016 @IllinoisASBO #iasboAC16
Illinois ASBO Ethics Statement • The Moderator will help ensure the Illinois ASBO Code of Ethics is adhered to throughout the presentation and ensuing audience discussion. • Moderators are given the authority to ask any attendee to leave if they become combative with presenters • This presentation is to be informative and not to promote specific products, services, companies, etc. • If a vendor is a presenter and uses the presentation as a platform to “sell” their product or services, the Moderator has the authority to stop the presentation if the presenter refuses to modify their content. • Any vendor presenter who violates these regulations may be excluded from presenting at future presentations. • We ask the audience to join with us in respecting these guidelines.
65th ILLINOIS ASBO CONFERENCE AND EXHIBITIONS May 4 – MAY 6, 2016 @IllinoisASBO #iasboAC16
Compliance Requirement Funds provided to a local education agency (LEA) under Part B must not be used to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds below the level of those expenditures for the preceding fiscal year. (34 CFR §300.203) FY17 MOE Compliance Spent in current year ≥ expended last fiscal year (2014-2015 ≥ 2013-2014)
Methods for Meeting MOE LEAS can meet MOE by one of the following methods: □ Net Combination of State and Local Costs □ Per Capita Combination of State and Local Costs □ Net Local Costs Only □ Per Capita Local Costs Only
Local Funds – Net and Per Capita The MOE compliance data provided by ISBE is based on the AFR, which does not separate expenditures by state and local. Any computation of IDEA MOE compliance based on local (no state) expenditures, must be completed at the local level.
“Local Only” MOE ISBE preprinted MOE District Worksheets are prepared using information verified in the AFR which includes State and Local Funds both in total expenditures and per capita spending. A district that does not meet MOE using the State and Local Funds methods may meet MOE using the Local Only Funds methods. The district must submit the Maintenance of Effort by Local Expenditures form along with verification from the district’s auditor that the separated Local expenditures and State expenditures are accurate and together total the expenditure amount reported in the AFR.
AFR REFERENCE SHEET
Annual Financial Report (AFR) Lines Used to Determine Maintenance of Effort (MOE) FuncBon Number and DescripBon
Annual Financial Report Lines
SPECIAL EDUCATION EXPENDITURES 1000 2110 2120 2130 2140
Instruc*on (Special Educa*on Programs) A@endance & Social Work Services Guidance Services Health Services Psychological Services
2150 Speech Pathology & Audiology Services 2210 Improvement of Instruc*on Services 2220 Educa*onal Media Services 2230 2310 2320 2330 2410 2510 2520 2540 2550 2570 2600
40, 230 44, 234 45, 235
Assessment & Tes*ng Services Board of Educa*on Services Execu*ve Administra*on Services Service Area Administra*on Services Office of Principal Services Direc*on of Business Support Services Fiscal Services Opera*on and Maintenance of Plant Services Special Educa*on Pupil Transporta*on Internal Services Support Services -‐ Central
46, 236 49, 239 50, 240 51, 241 55, 253 59, 122, 257 60, 258 61, 124, 260, 338 Pupil Transporta*on & Claim Reimbursement Report 64, 263 72, 271
4000 Payments for Special Educa*on Program
FEDERAL FUNDS REVENUE 4600 IDEA Preschool Flow-‐Through 4620 IDEA Flow-‐Through
districts use only highlighted func*ons coopera*ves use any expenditure func*on as verified by afr
8, 9, 22, 23, 211, 212 36, 226 37, 227 38, 228 39, 229
79, 86, 94, 133, 183, 276, 300
218 220
RCDT Code
District
Maintenance of Effort by Local Expenditures / Per Capita
July 1, 2013 -‐ June 30, 2014
July 1, 2014 -‐ June 30, 2015
1 Total Special Educa*on Students December 1 2 1000 Instruc*on (Special Educa*on)
State
Local
Federal
Total*
State
Local
Federal
Total*
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
-‐
3 2140 Psychological Services 4 2150 Speech Pathology/Audiology 5 2330 Special Area Administra*on 6 2550 Special Educa*on Transporta*on 7 4000 Payments for Special Educa*on 8
9
Other (specify func*on) Total Special Educa*on Expenditures
Federal Revenue (IDEA)
Net Expenditures (Total less Revenue)
Per Capita
-‐ -‐ -‐ -‐
-‐ -‐ -‐ -‐
-‐
-‐
State *Per AFR / PTCR
Comparison
Local
Total
“Other” Expenditures The MOE District Worksheet (line 8) allows for a district to add expenditures approved in the IDEA Part B grant but were not included in the preprinted worksheet expenditures. Examples include OT/PT (2130 Health Services), Social Work Services (2110 Attendance and Social Work Services)
The district must submit the MOE District Worksheet (OTHER) attachment along with a copy of the IDEA Part B Flow-Through budget page and copies of vendor detail reports reflecting payment date and amount.
MOE DISTRICT WORKSHEET (OTHER) aWachment District: A@ach a copy of the IDEA Part B Flow-‐Through budget page and copies of vendor detail reflec*ng payment date and amount. As approved in the IDEA Part B Flow-‐Through budget FY_____ Func*on Obj. Code Expenditure Descrip*on $ Budgeted Date Purchased $ Expended
TOTAL EXPENDITURES $ -‐
Allowable MOE Exceptions □ Voluntary Departure of Special Education or Related Services Personnel Personnel leave due to retirement, resignation, or for just cause (School Board action) – does not include contract non-renewal, reassignment or staff lay-off due to RIF. □ Termination of a Costly Obligation for a Specific Child Student leaves the district, ages out, or no longer needs the program due to an IEP change. □ Termination of a Costly Long-Term Purchase Acquisition of equipment or the construction of school facilities.
Allowable MOE Exceptions (cont.) □ Decrease in Enrollment of Children with Disabilities Must demonstrate per capita spending ≥ previous year
Excep*ons to Maintenance of Effort Federal IDEA Regula*ons 34 CFR §§ 300.204 & 300.205 District Name Region-‐County-‐District-‐Type (RCDT) Name of Person Comple*ng Report Telephone Number Maintenance of Effort Shorkall from Worksheet $ -‐ 2014 -‐ 2015 The level of expenditures may be reduced below the level of the preceding fiscal year only if the reduc*on is a@ributable to any of the following. If the total of allowable excep*ons equals or exceeds the MOE shorkall, fiscal effort has been maintained. $ -‐ The voluntary departure, by re*rement, resigna*on, or for just cause, of special educa*on or related services personnel.
(Does not include contract non-‐renewal, reassignment or staff lay-‐off due to RIF.) employee name
posi*on
reason for leaving
salary & benefits
replacement name
salary & benefits
subtotals
$ -‐
subtotals $ -‐
total $ -‐ $ -‐ The termina*on of the obliga*on to provide an excep*onally costly special educa*on program to a child with a disability. (leaves the district, ages out, graduates, or no longer needs the program due to an IEP change.) (Specify ini*als of student, reason(s) expenditures are no longer needed, previous year placement, and the cost of the tui*on, transporta*on, aide or other.) student reason services not needed previous placement tui*on transport aide other total
total The termina*on of costly expenditures for long-‐term purchases, such as the acquisi*on of equipment or the construc*on of school facili*es (purchased previous year with unit cost of at least $1,000). descrip*on of expenditure date purchased
$ -‐
Total Allowable Excep*ons to Maintenance of Effort
$ -‐
$ -‐
unit cost
$ -‐
total ISBE Use Only
MOE Eligibility - 1 A district is eligible to receive IDEA funds by maintaining local effort. This is based on a comparison of the most recent complete fiscal year (up to 2 years) with the current budgeted amounts. The Illinois IDEA grant applications must identify the MOE eligibility status for each district. That is based on the most recent complete/finalized fiscal year. E.g. in FY16 districts used the FY14 fiscal records.
MOE Eligibility - 2 MOE eligibility has the same four options, or tests, for meeting the requirement: □ Net Combination of State and Local Funds □ Per Capita Combination of State and Local Funds □ Net Local Funds Only □ Per Capita Local Funds Only
FY16 IDEA Grant ApplicaBon FY14 local per capita and net expenditures How the district anBcipates/budgets FY16 local spending to meet the FY14 amounts.
IDEA MOE Reduction - 1 The 34 CFR 300.205 allows districts with an increase in federal Individuals with Disabilities Education Act (IDEA) funds to reduce maintenance of effort (MOE) by up to 50% of the amount of the IDEA increase, providing the freedup local funds are used for Elementary and Secondary Education Act (ESEA) activities. This is a voluntary option for districts that have an increase in IDEA allocations AND meet all MOE reduction criteria.
IDEA MOE Reduction - 2 A district with an increase in IDEA funds may take an IDEA MOE reduction, up to 50% of the increase (flowthrough only, not preschool). • LEA “Meets Requirements” determination is required. • LEA must be able to provide a free and appropriate public education (FAPE) to students with disabilities(no action against the LEA by ISBE) • If the district is also using IDEA funds for coordinated early intervening services (CEIS), the combination of IDEA MOE reduction and IDEA funds used for CEIS purposes is limited to the smaller of the two amounts.
IDEA MOE Reduction - 3 • Any “freed up” local funds must be used on Elementary & Secondary Education Act (ESEA) activities and the district must identify and document those activities. • Districts that elect to take a MOE reduction must submit a completed IDEA MOE Reduction form to the Special Education Services Division by September 30. • All MOE reduction records are subject to audit by the Illinois State Board of Education (ISBE).
QuesBons
Pam Jurkoshek Available at ISBE March – September 217-‐782-‐5589
[email protected]
IDEA MOE worksheets are available on the IDEA grant webpage at hWp://www.isbe.net/spec-‐ed/html/idea_part-‐ b.htm.
