The summer sun brings with it a sense of peace and calm that we all need after such a challenging year. Enjoy this season and take some time out to soak up the sun and focus on your own wellness.
In this issue of the newsletter, we review time and effort language, as well as some Grant Management Application and Planning (GMAP) changes and schoolwide flexibility options due to COVID that will help you prepare to build your FY22 application.
ESSA Schoolwide Flexibility and Flexibility for Within District Allocations Due to COVID-19
Section 1114(a)(1)(B) of the Every Student Succeeds Act (ESSA) offers flexibility for the operation of schoolwide programs in schools that don’t meet the poverty threshold required in Section 1114(a)(1)(A). This threshold is typically set at 40%. However, flexibility is offered as follows:
“(B) EXCEPTION. – A school that serves an eligible school attendance area in which less than 40 percent of the children are from low-income families, or a school for which less than 40 percent of the children enrolled in the school are from such families, may operate a schoolwide program under this section if the school receives a waiver from the State educational agency to do so, after taking into account how a schoolwide program will best serve the needs of the students in the school served under this part in improving academic achievement and other factors.”
With approval, the school would have to meet all requirements under ESSA Section 1114.
To request this flexibility, a district must apply on behalf of a school. The request must:
- Describe that the district requests the flexibility;
- Address how the schoolwide program will best serve the needs of students in the school in improving academic achievement and other factors;
- Be written on the district’s letterhead; and
- Include the signature of the superintendent or his or her designee.
Please note, districts that have been approved for this flexibility in the past do not need to request it again and may continue to operate schoolwide programs in those approved schools as long as they remain eligible for services as outlined in ESSA Section 1113. Those districts must maintain documentation of the original approval.
Email David Millanti with flexibility requests and questions or mail to David Millanti, Assistant Director; Division of School and Program Improvement; 300 Sower Blvd., 5th Floor; Frankfort, KY 40601.
Additionally, districts may benefit from flexibility offered for using data to determine within district allocations. This U.S. Department of Education fact sheet explains the flexibility for using data from the 2019-2020 school year for the purposes of ranking and serving schools and discusses how to use data for determining equitable services. For more information, email David Millanti.
Time and Effort
Time and effort reporting must be maintained for all employees who are paid fully or partly from Title I funds (or any federal funding source). This applies to staff at the district and school level paid completely or partially from Title I funds. These records are often referred to as “time and effort” records. Time and effort records must reflect an after-the-fact distribution of the actual activity of the employee.
Written policies and procedures are essential to implementing an effective time reporting system. Districts must develop written procedures as part of their system of internal controls [2 CFR 200.430(i)]. The Cost Allocation Guide for State and Local Governments, U.S. Department of Education (2019) provides an outline of the sections that should be included in the district’s instructions, which includes the following:
- The completion of time and attendance reporting;
- The approval cycle that is required;
- The processing of personnel charges to federal awards; and
- The internal review process that will be established to ensure effective internal control over the federal award.
Refer to the May Title I Webinar and the June Title I Webinar for more information on time and effort. Look for Title I Handbook updates to be released on this topic later in the summer.
Coordinator's Year at a Glance - Summer Months
- Meet with district financial staff to reconcile fiscal issues, including time and effort reconciliation, prior to the end-of-year closeout.
- Determine roles and responsibilities of appropriate local education agency representatives to determine comparability requirements. Refer to the comparability guide and comparability report training video to prepare for this activity in the fall.
- Gather data on private school services and evaluate programs for the upcoming year.
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