Choosing a Consolidation Option for Schoolwide Programs

 

Local educational agencies (school districts and charter schools) that would like their campuses to take advantage of the flexibility offered by a Title I, Part A schoolwide program must choose the best way to consolidate funds. The chart below can help you and your local educational agency (LEA) decide which of the three possible consolidation options would be most beneficial for your campus.

Campuses can consolidate their Title I, Part A grant funds, or their Title I, Part A funds and other funds, into a single budget “pool.” Funds in the pool belong to the schoolwide program budget instead of many individual budgets, and the campus can use the pool to pay for any activity that improves the entire educational program of the campus. This consolidation eases some of the usual fiscal and programmatic requirements that apply to federal grant funds.

The options are as follows:

  1. Full consolidation. This option involves pooling some or all of your campus’s federal funds with state and local funds, and provides the most flexibility in terms of operating schoolwide programs.
  2. Federal consolidation. This option involves pooling some or all of your campus’s federal funds, but does not involve state or local funds.
  3. Title I, Part A. This option does not pool any funds, but allows your campus to use its Title I, Part A allocation on a schoolwide basis.

Local educational agencies can choose different options and include different fund sources for each campus.

Please note that you must account for all expenditures for any federal funds that are not consolidated.

Consolidation Options

 Applicable Requirements

Option 1
Full Consolidation

Option 2
Federal Consolidation

Option 3
Title I, Part A Only

General fiscal activities

Most flexibility

Some flexibility

Least flexibility

Local control

Most flexibility

Some flexibility

Least flexibility

Ability to try innovative programs

Most flexibility

Some flexibility

Least flexibility

Before implementation

Eligible funds

All federal education funds (formula and discretionary) that come from programs administered by the U.S. Department of Education are eligible. These funds must be used to carry out activities in a public elementary or secondary school. The U.S. Department of Education does not administer Head Start and National School Lunch programs so their funds cannot be consolidated in a schoolwide program.

IDEA, Indian Education, and Migrant Education grants are eligible but have additional requirements. Specific information about these requirements is given below this chart.

Only Title I, Part A funds are eligible.

Identification of funds

Your campus improvement plan (CIP) must identify the specific programs being consolidated and the dollar amount each program contributes to the consolidated schoolwide budget.

Your CIP must demonstrate that your schoolwide program contains sufficient resources and activities to reasonably address the intents and purposes of each of the consolidated federal programs, particularly as they relate to your campus's lowest-performing students.

Your CIP must include the dollar amount of all Title I, Part A funds in the schoolwide budget.

Your CIP must specify each activity you will provide using Title I, Part A funds.

Implementation

How you must use the funds

For consolidated formula funds, you must address the intents and purposes of the programs and the needs of the intended beneficiaries of the programs. You do not need to meet most of the individual statutory and regulatory requirements of each program for funds that are consolidated.

For consolidated discretionary funds, you must carry out all of the activities described in the discretionary program grant application.

You must use Title I, Part A funds to address the specific educational needs of the campus that were identified in your needs assessment and listed in your CIP.

Activities and services are allowable as long as they meet the intents and purposes of the Title I, Part A program.

Specific allowable costs

The schoolwide budget may support any service or activity of your schoolwide program that was identified in your comprehensive needs assessment and included in your CIP, and that is allowed by state and federal law.

The schoolwide budget may only support a service or activity that supports the educational or instructional needs of the campus that were identified in your comprehensive needs assessment and included in your CIP.

Costs must meet any additional requirements given in Office of Management and Budget (OMB) Circular A-87.

Allowability of basic operational expenses (such as maintenance, repairs, and landscaping)

Fund sources lose their programmatic identity and it is impossible to know which specific funds paid for specific activities. Therefore, you may use schoolwide budgets for basic operational expenses. However, to comply with the supplement not supplant requirement, your campus must receive its full allocation of state and local funds, which must be sufficient to provide for these expenses.

Consolidated funds can only pay for educational or instructional expenses, so you may not use schoolwide budgets for basic operational expenses.

Basic operational expenses are also not allowable under OMB Circular A-87.

Accounting

You do not need to track consolidated federal funds to activities that are allowable under individual programs.

Because Title I, Part A funds are not consolidated with other federal, state, and local funds, you must account for and track the Title I, Part A funds separately, identifying the activities supported by the funds.

Records that must be maintained

Your campus does not need to maintain separate fiscal accounting records, by federal program, to demonstrate that an activity in your CIP may be supported by consolidated federal funds.

If you consolidate only federal funds, including Title I, Part A funds, you must keep records that demonstrate that you use federal funds, including Title I, Part A funds, to support activities that address the specific educational needs of your campus identified by your comprehensive needs assessment and included in your CIP.

If you consolidate only Title I, Part A funds, you must keep records that demonstrate that you use the Title I, Part A funds to support activities that address the specific educational needs of your campus identified by your comprehensive needs assessment and included in your CIP.

Advantages

Time and effort documentation

Employees paid entirely from the schoolwide pool are not required to maintain signed semi-annual certifications or any other form of time and effort records.

Employees paid partially from a federal fund that is not consolidated must maintain time and effort records in accordance with OMB Circular A-87 or a substitute time and effort system approved by TEA.

Employees paid entirely from the schoolwide pool must maintain signed semi-annual certifications. However, if the campus consolidates funds from programs covered by Ed-Flex, the semi-annual certification required is waived.

Employees paid partially from a federal fund that is not consolidated (or from a federal program not covered by Ed-Flex) must maintain time and effort records in accordance with  OMB Circular A-87 or a substitute time and effort system approved by TEA.

Budget amendments to the NCLB Consolidated Application

Amendments are not required if you use the class-object code 8911, Operating Transfer Out. However, for funds not budgeted under class-object code 8911, amendments may be required.

Amendments are required because funds are budgeted by program fund source and class-object code.

Supplement not supplant

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

In other words, the campus does not need to demonstrate that any particular service is supplemental to state or locally funded services.

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

In other words, the campus does not need to demonstrate that any particular federally funded service is supplemental to state or locally funded services.

Federal funds must supplement the state and local resources the campus would receive in the absence of Title I, Part A.

In other words, the campus does not need to demonstrate that any particular Title I, Part A–funded service is supplemental to state or locally funded services.

 

Additional Requirements for Certain Federal Programs

The following are additional requirements that your campus must meet if you consolidate funds from certain programs:

  • Individuals with Disabilities Education Act, Part B (IDEA-B). A schoolwide campus may consolidate IDEA-B funds, but the amount of funds consolidated may not exceed the amount of IDEA-B funds received by the campus’s LEA for that fiscal year divided by the number of children with disabilities in the LEA’s jurisdiction multiplied by the number of children with disabilities participating in the schoolwide program. In addition, LEAs must consider consolidated IDEA-B funds as federal IDEA-B funds for the required calculations that ensure compliance with the excess costs and maintenance of effort provisions of IDEA-B. 
    A campus may also consolidate funds it receives for students with disabilities under Section 8003(d) of the Elementary and Secondary Education Act (ESEA). A campus that consolidates section 8003(d) funds or IDEA-B funds may use those funds for any activities included in its schoolwide program campus improvement plan, but the campus and LEA must comply with all other requirements of IDEA-B to the same extent that they would if they did not consolidate funds. For example, LEAs must ensure that each schoolwide campus provides services to children with disabilities in accordance with a properly developed individualized education program and provides all the rights and services guaranteed to children with disabilities under IDEA.
  • Indian Education. A schoolwide campus may consolidate Indian Education funds received under Subpart 1 of Part A of Title VII of ESEA only if the parent committee established by the campus’s local educational agency to help develop the Indian education program approves the inclusion of those funds.
  • Migrant Education. Before consolidating Title I, Part C Migrant Education funds, a schoolwide campus must, in consultation with parents of migrant children or organizations representing those parents, or both, document that it has met TEA's 11 migrant student performance criteria. The campus must have written approval from Migrant Education program staff at TEA.

Additional Guidance from TEA

Additional guidance about Title I, Part A schoolwide programs is available at the following web pages:

Schoolwide Programs
This is the home page for Title I, Part A schoolwide programs, and provides general information about choosing to implement a schoolwide program, eligibility, and basic requirements.

General Information about Schoolwide Programs
This page describes the general purpose, goals, and fundamental principles of Title I, Part A schoolwide programs.

Schoolwide Programs: Comprehensive Needs Assessment
This page provides detailed information about the required comprehensive needs assessment, including recommended steps to follow.

Schoolwide Programs: Campus Improvement Plan
This page provides detailed information about the required campus improvement plan, including the required accounting and program components.

Schoolwide Programs: Annual Evaluation Plan
This page provides detailed information about the required annual evaluation plan, including recommended steps to follow.

Fiscal Issues Related to Operating a Schoolwide Program
This page describes various fiscal issues related to operating a schoolwide program, including adequate documentation, appropriate accounting structures, and specific fiscal requirements such as set-asides, supplement not supplant, and time and effort.

Additional Guidance from USDE

TEA's web pages summarize the information and requirements given by the U.S. Department of Education. The source documents are available at the links below:

Section 1114 of the Elementary and Secondary Education Act (ESEA)

Designing Schoolwide Programs, Non-Regulatory Guidance, March 2006 (Word, 452 KB, outside source)

Title I Fiscal Issues, Non-Regulatory Guidance, February, 2008 (Word, 995 KB, outside source)

Federal Register, July 2, 2004 (Volume 69, Number 127)

Office of Management and Budget (OMB) Circular A-87

Contact Information

For more information about Title I, Part A schoolwide programs, please contact Anita Villarreal in the Division of Federal and State Education Policy at nclb@tea.state.tx.us.

For more information about the TEA federal flexibility initiative, please contact Thomas Howe in the Office for Grants and Federal Fiscal Compliance at thomas.howe@tea.state.tx.us.

Page last modified on 8/22/2014 09:24:59 AM.