state & federal grant procedures handb oo k - Fitzgerald ...

6000: Finance – FPS – State & Federal Grant Procedures Handbook

Fitzgerald Public Schools

STATE & FEDERAL GRANT

PROCEDURES H A N D B OO K

Updated November 24, 2014


Fitzgerald Public Schools – State and Federal Grant Procedures Handbook SECTION 1: 31A At Risk Program (Pages 3 – 10)

SECTION 2: Title I, Part A Program Oversight Process & School Improvement

Planning/Implementation/Evaluation/Reporting & Parent Notification

Requirements (Pages 10 – 24)

SECTION 3: Title I, Part A Allowable Use of Funds & Student Eligibility (Pages 24 –

32)

SECTION 4: Title II, Part A Program (Pages 32 – 41)

SECTION 5: Title III LEP & Immigrant Programs (Pages 41 – 48)

SECTION 6: Time and Effort Approval & Report (Pages 48 – 55)

SECTION 7: Equipment Management & Monitoring (Pages 55 – 62)

APPENDICES

Appendix A: K-2 Eligibility Worksheet

Appendix B: 4-12 Eligibility Worksheet

Appendix C: Birth-Age 5 Eligibility (MDE did not release new form in August 2014)

Appendix D: Sample 31A Staff Funded Activity Log

Appendix E: End of Trimester 31A Funded Staff Member Report

Appendix F: Sample of PAR

Appendix G: Sample of Semi-Annual Certification

Appendix H: 2014-15 Office of Field Services District Monthly Activity Organizer

Appendix I: Samples of Supplemental Program Description

Appendix J: Parent Notification Letter Samples


SECTION 1: 31A PROGRAM

The purpose of 31a At Risk funds is to ensure that Fitzgerald students are proficient in

reading by the end of grade 3 and that high school graduates are career and college

ready.

The allocation formula is based on the foundation allowance and the previous year’s fall

membership and number of students eligible for free meals (11.5 percent of foundation

allowance X free eligibility count). Allocations are prorated based on a per pupil

amount to stay within the State appropriation.

August 2014 Note: The supplement, not supplant provision of Section 31a has been

deleted to give school staff increased flexibility to achieve reading proficiency at 3rd

grade and college and career readiness in 11th

grade.

Beginning in 2014-2015, districts, public school academies, or Education

Achievement Authority (EAA) not demonstrating to the satisfaction of MDE that

at least 50% of at-risk students are reading at grade level by the end of grade three

as measured by the state assessment or demonstrate to the satisfaction of the

department improvement over 3 consecutive years in the percentage of at-risk

pupils that are career-college-ready as measured by the student’s score on each of

the individual subject areas on the college entrance examination portion of the

Michigan merit examination shall ensure all of the following:

Determine the proportion of total at risk pupils that represent the number of

students in grade 3 that are not reading at grade level by the end of grade 3 and

shall expend that same portion multiplied by 1/2 of its total at-risk funds under

this section on tutoring and other methods of improving grade 3 reading levels.

Determine the proportion of total at risk pupils that represent the number of

students in grade 11 that are not college and career ready as measured by the

student’s score on each of the individual subject areas on the college entrance

examination portion of the Michigan merit examination shall expend that same

portion multiplied by 1/2 of its total at-risk funds under this section on tutoring

and other activities to improve scores on the college entrance examination portion


of the Michigan merit examination.

31A IDENTIFIED STUDENTS (SAME IDENTIFICATION PROCESS

USED FOR SCHOOLWIDE TITLE I ELIGIBLE STUDENTS)

As used in this section, “at-risk pupil” means a student for whom the district has

documentation that the student meets any of the following criteria:

Is a victim of child abuse or neglect.

Is a pregnant teenager or teenage parent.

Has a family history of school failure, incarceration, or substance abuse.

For students for whom the results of the Michigan merit examination have been

received, is a student who does not meet the other criteria, but who did not

achieve proficiency on the reading, writing, mathematics, science, or social

studies components of the most recent Michigan merit examination for which

results for the student have been received.

For students in grades K-3, is a student who is at risk of not meeting the district’s

core academic curricular objectives in English language arts or mathematics.

The pupil is enrolled in a priority or priority-successor school, as defined in

the elementary and secondary education act of 2001 flexibility waiver

approved by the United States department of education.

The student did not achieve a score of at least proficient on 2 or more state-

administered assessments for English language arts, mathematics, science, or

social studies.

For high school students in grades not assessed by the state, the student did not

receive a satisfactory score on 2 or more end-of-course examinations that are

aligned with state standards in English language arts, mathematics, science, or

social studies. For middle school students in grades not assessed by the state, the

student did not receive a satisfactory score on 2 or more end-of-semester or end-

of-trimester examinations that are aligned with state standards in science or social

studies. For students in the elementary grades in grades and subjects not assessed

by the state, the pupil did not receive a satisfactory score or did not have a

satisfactory outcome on 2 or more interim assessments in English language arts,

mathematics, science, or social studies.

In the absence of state or local assessment data, the student meets at least 2 of the

following criteria, as documented in a form and manner approved by the

Michigan Department of Education:


The student is eligible for free breakfast, lunch, or milk.

The student is absent more than 10% of enrolled days or 10 school days during

the school year.

The student is homeless.

The student is a migrant.

The student is an English language learner.

The student is an immigrant who has immigrated within the immediately

preceding 3 years.

The student did not complete high school in 4 years and is still continuing in

school as identified in the Michigan cohort graduation and dropout report.

The district updates the 31a Identified/Title I Eligible Student list twice a year

– after universal screeners and curriculum-based/local assessments are

administered in the fall and again in the spring after state assessment scores

are available to districts, in addition to mid-year/spring universal screeners,

and curriculum-based/local assessments area administered. Schools begin

servicing students in the beginning of the year using the spring list. The

attached identification worksheets must be completed and returned to the

Fitzgerald Curriculum Office no later than November 30th of each school year

in order for the Curriculum Officer to update student identification/eligibility

in the district’s data management system, Data Director.

ALLOWABLE USES OF 31A FUNDS

31A Instructional Programs

Fitzgerald Public School may use the 31a funds only to provide instructional programs

and direct non-instructional services including but not limited to:

The instruction provided by 31a funds may be conducted before, or after regular

school hours or by adding extra days to the school year/calendar.

Fitzgerald may use up to 100% of the funds it receives under this section to

implement school-wide reform in schools with 40% or more of their students

identified as at-risk students by providing supplemental instructional or non-

instructional services consistent with the school improvement plan.

Instructional staff

Instructional materials, software, or equipment to implement instruction


Job-embedded, ongoing, research-based and need-based professional learning to

improve the quality and fidelity of instruction

Development, enhancement and implementation of curriculum, formative or

interim assessments and evidence-based instruction to improve student learning

Mentoring, coaching, and collaboration among instructional staff to improve

student learning

Programs and activities to engage students and parents more actively in

instruction and improve learning outcomes

Implementation of high-quality preschool, credit recovery, extended day or year

and similar programs that will accelerate student learning

August 2014 Note: The supplement, not supplant provision of Section 31a has been

deleted to give school staff increased flexibility to achieve reading proficiency at 3rd

grade and college and career readiness in 11th

grade.

Any instructional program that is provided should be aligned with the school’s

continuous improvement process and directly benefit student education and learning.

Instructional programs or interventions should be based on the Student Eligibility

Worksheets and a Comprehensive Needs Assessment (CNA) leading to a District

Improvement Plan (DIP), School Improvement Plan (SIP) or School Reform Plan

(SRP). If the objectives of such Plans are not met, the districts/Public School

Academies (PSAs) or schools are to modify these Plans reflect program, interventions

or strategies designed to meet the need. Districts/PSAs may use the Michigan

Department of Education (MDE) Evaluation Tool for annual evaluation.

Schools/districts should focus on achieving the objectives, strategies and activities

included in the DIP, SIP or SRP.

Districts planning to implement the School-wide reform option should provide

supplemental instructional or non-instructional services consistent with the DIP, SIP or

SRP.

Teachers and Instructional Paraprofessionals funded under Section 31a can only

provide services to eligible at-risk students unless the school meets the eligibility

criteria and chooses to implement a School-wide program as defined in Section 10.


The MDE encourages school staff to use the locally-developed CNA and school and

district improvement plans to select and implement research-based instructional

programs and activities that will address the unique academic needs of students. School

staff will be held accountable for these outcomes.

Direct Non-Instructional 31A Services

Medical, Mental Health and Counseling Services

Fitzgerald Public Schools may provide medical, counseling, and/or mental health

programs/services to support a comprehensive program that is based on the needs

identified using the Student Eligibility Worksheets and focused on the overall goal of

improving student academic achievement.

Hearing and Vision Screening

Legislation provides a state level set aside supporting 50% of hearing and vision

screening conducted by local public health departments. MDE encourages schools to

refer students with potential needs for these services to your local public health

department.

Security

Fitzgerald Public Schools, a school district of the first class under the revised school

code, with at least 50% of the pupils in membership that met the income eligibility

criteria for free breakfast, lunch, or milk in the immediately preceding state fiscal year

may use no more than 20% of the funds it receives under this section for school

security. Carry-over funds may not be used unless it can be documented that they were

not used in previous years.

School Breakfast Programs

Fitzgerald Public Schools operates a school breakfast program under Section 1272a of

the year revised school code, MCL 380.1272a, and may use from the funds received

under this section an amount, not to exceed $10.00 per student for whom the district

receives funds under this section, necessary to operate the school breakfast program.

Anti-bullying and crisis intervention programs are non-instructional 31a allowable

services.


The direct non-instructional services provided by Section 31a funds may be conducted

before, after regular school hours or by adding extra days to the school year/calendar.

Funds under this Section may include the following types of services:

Medical, counseling or behavioral intervention programs/services can include

counselors, nurses, social workers or staff with specialized training in

behavioral intervention strategies

Community Medical Referrals

Dental Care

Substance Abuse Counseling

Sexually Transmitted Disease (STD) Education

Mental Health Services

Prenatal Care

Immunizations

Obesity

Individuals authorized to administer services include:

Licensed Physician

Licensed Practical Nurse (LPN)

Licensed Registered Nurse (RN)

Licensed Physicians Assistant (PA) working under the supervision of a

Physician during all hours of clinic operation

Certified Health Educator

Registered Dietician

Licensed or School Psychologist

Licensed Dentist or Dental Hygienist

Licensed Social Worker or School Social Worker

Activities and services to improve the culture and climate of the school, to address

safety and security, to provide anti-bullying or crisis intervention programs, etc. where

there is a clearly-defined need may be supported with Section 31a funds.

Unallowable Use of 31A Funds


Administrative Costs

SECTION 31a FUNDS MAY NOT BE USED TO PAY ANY ADMINISTRATIVE

COSTS. This prohibition includes, but is not limited to personnel time spent managing

the program, audit costs, evaluation activities and indirect costs. Section 31a does not

allow any administrative costs including indirect costs.

Program records must be made available for audit and any disallowances must be

returned to State.

The MDE encourages school staff to focus Section 31a resources on the school

improvement goals and objectives to ensure achieving 3rd

grade proficiency in reading

and career and college readiness for at-risk students by implementing and evaluating the

DIP, SIP or SRP with fidelity. Districts and schools are still accountable toward

improving academic achievement of all eligible 31a at-risk students placed in grades K-

12.

Unobligated funds have a limit of a one-year carryover period. If the funds are not

expended and reported in the July 15 annual report, the funds are returned to the State's

School Aid budget.

The Section 31a Program Report is due in MEGS+ by July 15 of each fiscal year.

MDE may withhold payment of Section 31a funds in the event that the required

program report is not submitted on a timely basis.

MDE has some limitations on what constitutes the program report. The report must not

exceed 10 pages and address the uses of the funds. The report shall include and report

covering the amount of funds allocated to Section 31a

Fitzgerald Public Schools will report:

A brief description of the program conducted or services performed.

The actual grade levels served.

The total number of at-risk students receiving each program or service.

The actual amount of Section 31a funds spent on each program or service.


Section 31a describes the accountability requirements for using the funds which place

the primary emphasis on proficiency in third grade reading and eleventh grade college

and career readiness in subjects measured by the MEAP or Michigan Merit

Examination.

NOTE: Specific accountability measures aligned with [Sec. 31a(14) will be

determined by MDE and disseminated to districts/PSAs at a later date.

SECTION 2: TITLE I Part A PROGRAM OVERSIGHT PROCESS & SCHOOL

IMPROVEMENT PLANNING / IMPLEMENTION /

EVALUATION / REPORTING REQUIREMENTS

Superintendent identifies district personnel to provide program oversight and protocols

(Curriculum/Title I Director, Director of Business, supported by building-level

principals).

Fitzgerald Public Schools receives an annual estimated Title I allocation from the

Michigan Department of Education each spring posted on the MDE website.

Upon receiving the estimated allocation amount for Title I Part A, the Title I Director

shares the allocation amounts at the District Improvement Team Meeting or before each

year.

Consultation for Private Schools (PS) schools occurs annually each spring through

invitation to determine if PNP wishes to plan and/or participate in the Title I, Part A

programs. PNPs are communicated with throughout the school year via face to face,

phone calls, emails, and/or written letters. Documentation of this consultation is kept

on file with the Title I Director.

Consultation and collaboration between the Title I Director and the Homeless Liaison

occur to determine whether or not Title I, Part A funds are needed for reservation.

The District Improvement Team then discusses the funding amounts, and it is

determined which buildings will be Title I Part A buildings for the following year based

on:

1. The funding amount increasing or decreasing


2. The poverty level of each building; buildings with 75% poverty will be Title I

schools as required

3. The needs identified in the comprehensive needs assessment

4. The availability of other grant funds to support the non-Title I schools

5. The type of Title I Part A each school will be: School-wide or Targeted

Assistance

Once it is determined which building(s) will be Title I buildings, the Title I Director

completes the Title I School Selection (TISS) pages in MEGS Plus. District Set-Asides

are included in the TISS.

Next, the Title I Director shares the school allocations, which are determined using the

formula recommended by MDE.

1. District level set-asides are taken off the top of the district allocation, as required.

2. School level budgets are then generated by taking the remainder of the allocation

and dividing by the total number of district free and reduced meals from the

October 31 count of the prior year and multiplied by 125% to get the per pupil

allocation.

3. The building with the highest poverty of Free and Reduced students is served

first. That number is multiplied by the per pupil allocation to determine the Title

I funding allocated to the building. The process continues until the funds are

balanced at -0-.

4. The district level team, along with the building teams, may decide to focus the

funds more or less at one level than others based upon need, philosophies, and

other grant funds available to serve at-risk children.

The district will have a limit of 10% of the Title I grant for administration. Common

administration cost Function Codes are: 226, 283, 231-single audit, 261 building

operational services, 281 central office program evaluation, and indirect cost.

Once the school allocations are determined, the school level stakeholders design their

plan. The Title I Director then takes the school improvement plans for review to ensure

appropriate strategies and activities align with the comprehensive needs assessment.

Next, the director will ensure strategies and activities are allowable in accordance with

program legislation. Finally, the district stakeholders ensure the school plans align with

the District Improvement Plan.


Once the District Improvement Plan is complete, the Title I Director inputs all requests

into MEGS Plus in the Consolidated Application. The Resource Profile and the budget

detail items in MEGS Plus are aligned. Once the Consolidated Application is submitted,

stakeholders await approval or modifications from the MDE Field Service Consultant.

Once approval of the Consolidated Application is given, the schools monitor the

implementation of their plans through the continuous school improvement process.

Collaboration between the Business Office, Program Director and/or Building

Administrators occurs quarterly to monitor progress of plan implementation and

expenditures to ensure there are no deviations in the Title I, Part A budget.

Once Final Allocations are given, the planning starts again. At District Improvement

Team meetings, the new allocations are shared and representatives take the information

back to their school staffs for input. The Title I Director is able to make amendments

based on the school level input to the original Consolidated Application in MEGS Plus.

Upon approval from MDE, the implementation of expenditures begins.

The Fitzgerald Public Schools’ Supplemental Program Descriptions are due to the

Curriculum Office no later than November 30th

to increase internal controls.

Supplemental program job descriptions are also due to the Curriculum Office no

later than November 30th

.

The Title I Part A programs are evaluated for effectiveness on an annual basis by using

the district determined or MDE Program Evaluation Tool at the school level. Results

are used to determine if programs will be continued, adjusted, or eliminated.

The Title I Part A staff will keep records of student identification worksheets, caseloads

with entrance and exit dates, parent contacts, inventory lists, communications with staff,

and program evaluation documentation. These records are turned into the Curriculum

/Title I Director at the end of each year for audit.

The Curriculum/Title I Director will send notifications to grant funded staff at the

beginning of the school year, or whenever there is a change in staffing or grant funding,

explaining funding sources for salary/benefit percentages and requirements for program


reporting. The Curriculum Office sends a memo to all district administrators with grant

funded staff names, funding sources, and percentages, including what documentation

will be required for monitoring and reporting purposes. The memo and communication

to administration is updated as changes are made to staff and/or funding sources. Staff

will be required to complete a personnel activity report (PAR - % of daily time/activity)

so that 100% of the time is in alignment with grant and other funding sources or a Semi-

Annual Certification (twice a year). The building administrator with knowledge of time

and activity will authorize PARs, Semi-Annual Certifications (in December and June

for staff with same funding source and objectives), and activity reports. Staff will

submit their documentation to the business office for monitoring and auditing purposes.

Staff will be notified of the staff member in the business office to who the

documentation should be sent. PARS and activity reports are submitted monthly by pay

periods. Semi-Annual Reports and activity logs are submitted in December and in June,

unless staff is paid with grant funds for a summer program, then the summer staff

submit their documentation to the business office after the program with proper

supervisor authorization.

Periodic review of grant expenditures and budget reports are completed by the

Curriculum/Title I Director to ensure compliance. The Curriculum/Title I Director, in

collaboration with the Business Office Director/designee, completes the Final

Expenditure Report each year as required by MDE (In MEGS Plus).

ESSENTIAL COMPONENTS OF SCHOOLWIDE TITLE I PROGRAMS

The schoolwide program comprehensive plan is a crucial element for reforming the

instructional program in the school. There must be broad-based involvement in

developing the plan that includes the community to be served and the individuals who

will carry out the plan, including teachers, principals, other school staff and, if

appropriate, pupil services personnel, parents of students in the school, and secondary

students if the plan relates to a secondary school. The plan, where appropriate, must be

developed in coordination with other important programs within the school.

The plan should be reviewed and updated regularly to reflect the needs of all children in

the school.

There are three core elements of a schoolwide program[34 CFR 200.26].

1. A school operating a schoolwide program will conduct a comprehensive needs


assessment that identifies the school’s strengths and challenges in key areas that

affect student achievement.

2. The school will develop a comprehensive schoolwide plan that describes how it

will achieve the goals it has identified as a result of its needs assessment. The

schoolwide plan must--

Identify reform strategies, aligned with the needs assessment, that are

research-based and provide opportunities for all children to meet the

State’s proficient or advanced levels of academic achievement;

Provide instruction by highly qualified teachers;

Offer high-quality, ongoing professional development;

Create strategies to attract highly qualified teachers;

Create strategies to increase parental involvement;

Develop plans to assist preschool students through the transition from early

childhood programs to local elementary school programs;

Identify measures to include teachers in decisions regarding the use of

academic assessments;

Conduct activities to ensure that students who experience difficulty

attaining proficiency receive effective, timely, additional assistance; and

Coordinate and integrate Federal, State and local services and programs.

Additionally, the school plan must document that it has met the intent and purposes of

each program whose funds are consolidated if it chooses to consolidate funds from Title

I, Part A, and other Federal education program funds and resources without maintaining

separate fiscal accounting records by program, or meeting most statutory requirements

of those programs [Section 1114(b)(1) of Title I of ESEA].

3. The school will evaluate annually the outcomes and the plan’s implementation to

determine whether the academic achievement of all students, and particularly of

low-achieving students, improved, whether the goals and objectives contained in

the plan were achieved, and if the plan is still appropriate as written.

ANNUAL EVALUATION

The district will require that each school evaluate annually the outcomes and the school

improvement plan’s implementation to determine whether:


the academic achievement of all students, and particularly of the low-achieving

students, improved;

the goals and objectives contained in the plan were achieved; and

if the plan is still appropriate as written.

Annually, building staff along with parents, community member and students, if

appropriate, will describe how the results of annual evaluation of the effectiveness of

the schoolwide plan will be used to make revisions to the plan to ensure continuous

improvement of students in the schoolwide program. The district will also evaluate

district-level programs/strategies/initiatives funded with district Title I, Part A and

district Title II, Part A set-aside funds. The MDE Evaluation tool in the Advanc-ed

ASSIST website will be used as part of the school improvement evaluation process.

Title I, Part A--SECTION 1118 PARENT INVOLVEMENT

Parent Involvement Policy for Schools and Districts

The district and every school using Title I funds will develop jointly with parents of

children participating in Title I programs a written parent involvement policy. Parents

must agree to the policy, and the district will distribute the policy to parents and the

community. Schools or the district may amend current parent involvement policies that

involve all parents to meet the following new requirements.

District Parent Involvement Policy

The parent involvement policy must detail ways the district will:

Involve parents in developing district and school improvement plans.

Offer technical assistance and coordination to help schools plan parent

involvement activities to improve student and school academic performance.

Build school and parent capacities for strong parent involvement.

Coordinate and integrate parent involvement strategies with other programs,

such as Head Start, Reading First, Early Reading First, Even Start, Parents as

Teachers, Home Instruction Program for Preschool Youngsters, and limited

English proficiency programs.

Annually evaluate with parents the effectiveness of the policy in academically

improving district schools. The evaluation must include identification of barriers

to parent involvement, especially barriers to parents who are economically


disadvantaged, disabled, have limited English proficiency, have limited literacy,

or belong to a racial or ethnic minority. The district will revise the policy if

necessary.

The district will establish a parent advisory council to provide advice on parent

involvement programs. They also may work with community-based organizations and

businesses to develop parent involvement activities.

The district will use at least one percent of its Title I, Part A funds for parent

involvement activities. Parents of children served by Title I should help decide how

funds are spent.

Title I includes parent in the development and revision of the parent involvement plan;

in implementing and evaluating the program offering services, requires the development

and review of a parent school compact outlining each stakeholder’s responsibilities and

helps students achieve.

School Obligations Each school using Title I funds will write a parent involvement policy jointly developed

with, agreed to, and distributed to Title I parents. The policy must be made available to

the community and updated periodically.

The school will:

Conduct an annual meeting for Title I parents to inform them about the policy,

their rights under Title I, and how they can be involved in the planning, review,

and improvement of Title I programs in the school, including development of this

policy.

Provide parents with timely information about Title I school programs, school

curriculum, assessments used by the school to measure student achievement, and

proficiency levels students are expected to meet.

Respond quickly to parent requests for opportunities to meet regularly and

participate in decisions about the education of their children.

If parents are dissatisfied with the school’s Title I program plans, include parent

comments in the report to the school district.

Required Components – Annual Parent Meeting Each year, Title I programs are required to host a meeting for parents to explain what

the Title I program is and how parents can become involved in the Title I program.

(This is different from the Annual Review Meeting, which is also required.)

The following issues must be addressed at the Annual Parent Meeting:


Explain their school’s participation in Title I (whether they are schoolwide or

targeted).

Explain the Title I requirements (schoolwide or targeted, whichever is

applicable).

Explain what participation in Title I programming means, including:

1. A description and explanation of the school’s curriculum.

2. Information on the forms of academic assessment used to measure

student progress.

3. Information on the proficiency levels students are expected to meet;

4. Explain the district parental involvement policy, school parental

involvement policy, and school-parent compact.

5. Explain the right of parents to become involved in the school’s programs

and ways to do so.

6. Explain that parents have the right to request opportunities for regular

meetings for parents to formulate suggestions and to participate, as

appropriate, in decisions about the education of their children. The school

must respond to any such suggestions as soon as practicably possible.

In order to keep parents informed, schools will invite all parents of children

participating in Title I Part A programs and encourage them to attend. In a schoolwide

program, this means ALL parents should be invited; in a targeted assistance program,

just those parents with children participating in Title I should be invited. Schools must

also offer a flexible number of additional parental involvement meetings, such as in the

morning or evening so that as many parents as possible are able to attend.

Schools will document this meeting with minutes, agendas, sign-in sheets, etc.

School-Parent Compact

The school-parent involvement policy will describe how the school will develop jointly

with parents a school-parent compact for all children served by Title I. The compact

must outline how students, parents, and staff will share responsibility for improved

student achievement and how parents and the school will build and develop

partnerships to achieve state expectations for student achievement. The compact must

describe:

The school’s responsibility to provide high-quality curriculum and instruction

in a supportive learning environment.

Parents’ responsibility for supporting children’s learning, such as monitoring

attendance, homework completion, and television watching; volunteering at


school; participating in decisions about their children’s education, and positive

use of time outside of school.

The importance of ongoing parent-teacher communication, including

elementary schools’ plans to offer at least one annual parent-teacher conference

to discuss the parent-teacher compact and all schools’ plans to report children’s

progress frequently to parents and communicate how parents can contact staff,

volunteer in their children’s classrooms, and observe classroom activities.

Compact Development and Implementation Checklist:

1. Parents participated in designing the compact.

2. Teachers and principals participated in designing the compact.

3. The purpose of the compact is clearly articulated so that teachers and parents

both understand its intent.

4. The purpose of the compact is clearly articulated so that teachers and parents

both understand its intent.

5. The compact reflects administrative responsibility for creating a climate

conducive to learning including a high quality curriculum and balanced

assessment system.

6. The compact reflects teacher responsibility for creating a climate conducive to

learning.

7. The compact reflects teacher responsibility for establishing meaningful two-

way communication with parents.

8. The compact reflects parent responsibility for creating a home environment

conducive to learning.

9. The compact reflects parent responsibility for creating a home environment

conducive to learning.

10. The compact reflects student responsibility for learning.

11. The compact reflects student responsibility for learning.

12. The responsibilities outlined in the compact are developmentally and

individually appropriate for both the child and parent.

13. The compact is reviewed with students and parents periodically throughout the

year.

14. The effectiveness of the compact is evaluated on an annual basis and data is

used to make revisions.


School and District Responsibilities for Building Capacity for Parent Involvement

As part of efforts to improve student achievement, each school and the district receiving

will implement the following practices to build school capacity for parent involvement:

Help parents understand state and local assessment of their children’s progress

and how to monitor progress and work with educators.

Provide parents with materials and training to improve their children’s

achievement, such as literacy training and use of technology.

Educate teachers, administrators, and other school staff about the value of and

methods of reaching out to parents as equal partners.

Integrate parent involvement efforts with other school and community

programs, including Head Start, Reading First, Early Reading First, Even Start,

Home Instruction Programs for Preschool Youngsters, and Parents as Teachers

Programs.

Ensure that information about school and parent programs is in a format and

language parents can understand.

The following practices may be implemented at school and district discretion:

Involve parents in developing training for teachers, principals, and other

educators.

Use Title I funds to provide literacy training if all other funding is exhausted.

Use Title I funds to pay expenses associated with parent involvement, including

transportation, child care, and training fees.

Train parents to help involve other parents.

Arrange parent-educator meetings at various times in school or at other

locations to maximize parent participation.

Adopt model approaches to improving parent involvement.

Establish a district parent advisory council.

Involve community-based organizations and businesses in parent involvement

activities.

Upon request, provide reasonable support for parent involvement activities.

Schools and districts will provide full opportunities for the participation of parents with

limited English proficiency, disabilities, and those who are migrants in languages they

can understand.

ANNUAL EDUCATION REPORTING REQUIREMENTS


The district and building Annual Education Reports (AERs) are designed to meet the

federal requirements of the Elementary and Secondary Education Act of 2001 (also

known as NCLB) for an annual report. The reports provides detailed data on state

administered student assessment results, accountability results, teacher qualification

information, and the state results for the National Assessment of Educational Progress

(NAEP). There is an AER populated with the appropriate information for the state,

each district, and each school. If used as designed, the AER reports and cover letters

also meet the state requirement for reporting to parents and communities in an annual

education report.

The district and the schools are required to use the state produced AER reports in the

summer to report their prior year’s performance. This is how Michigan schools and

districts will meet the requirement of the Elementary and Secondary Education Act

of 2001 (ESEA or NCLB) and State law, Act 451, P.A. 1976 (and P.A. 25).

District and School AER Components

District Components:

The “Combined District AER Report” and,

A cover letter using the content outlined in the district template cover letter.

School Components:

The “Combined School AER Report” and,

A cover letter using the content outlined in the school template cover letter.

Both the report and the cover letter templates must present information unique to the

district or school and can be found on the MI School Data website:

https://www.mischooldata.org.

The Curriculum/Title I Director will:

Save the district AER report and post it to the district website.

Edit the district template cover letter addressing all of the requirements and post

this with the district AER. The letter should include the date posted/sent

<Month/Day/Year>.

Make available paper copies of the AER report and the cover letter to parents and

members of the community who do not have internet access.

Announce to the parents and community that both the district and the school

AERs and cover letters are available and how to access them.

Each School Administrator will:


Post the school AER report and dated school cover letter on the school website, if

the school has a website. If the school does not have its own website, these must

be posted to the district website.

Make paper copies of both documents available to parents and the school

community members who do not have computer access.

Notify parents that the AER and cover letters are available and how to access

them.

The district and schools will post and make copies available 15 days before school

starts in the fall of each school year. Providing this information at least 15 days before

school starts allows parents to make a better choice about which school to select for

their child. This information should remain available on the website(s) for one year,

until the next year’s report is prepared. MDE will notify schools of the earliest date for

public release.

Log in to the secure MI School Data website: https://www.mischooldata.org.

For access to the site, contact your ISD system administrator.

Click on the “Annual Education Report” button at the bottom of the left-hand

portion of the screen. This will take you to the correct page where you will find a

button labeled “Cover Letter Templates.” Click on this button.

MDE will provide early access to the AER reports so that the district and schools can

have them ready to distribute and post within the required timeline. The district and

schools should finalize the related cover letters after reviewing the data. The cover letter

templates will be updated to reflect Michigan’s current federally approved requests and

updated specifics to reflect the new data.

The MDE will make the embargoed AER reports available tentatively at

https://www.mischooldata.org for preview of the final data. The assigned district and

school staff members responsible for these annual reports will finalize the cover letters

and prepare to post or distribute AER reports and cover letters in final form no sooner

than the date given by the MDE and no later than 15 days before the start of school. The

parents will be notified when the district and school release these annual reports.

AER Report Content on the MI School Data website

Teacher Quality: This report identifies teacher qualifications in relation to

requirements. Here you can find how many teachers in a school, district, or

across the state possess specific qualifications.

Student Assessment: This report presents assessment information for English

language arts (reading and writing), mathematics, social studies and science

(where relevant) for grades 3 to 9 and grade 11 compared to targets for all


students as well as subgroups of students. The report helps users to understand

achievement and progress within grades and schools, and to make comparisons to

district, state, and national achievement benchmarks.

National Assessment of Educational Programs (NAEP) assessment data (state

results) as required by federal law.

Accountability data as revised and required in the federally approved Flexibility

request, including designations as Reward, Priority, and Focus schools.

Combined Report: This report provides all of the information of Teacher Quality,

Student Assessment, Accountability, and state NAEP data for schools, LEAs, and

the state in one convenient place. This is the report that the district and schools

will need to obtain the AER report for posting on their websites with edited cover

letters, and print for parents and community members who do not have internet

access. Printed copies of both the district and each school’s AERs will be

available in the Superintendent’s Office and the Curriculum Office. Printed

copies of both the district and the school’s AER will be located in the Office of

the Principal at each school building.

NOTE: The data in AER reports appropriately address all required subgroups

consistent with federal requirements with appropriate cell suppression for small “n” size

subgroups.

As soon as the accountability data are finalized the MDE’s embargo is lifted and the

state publicly releases the information. This

There are no appeals of data once it is part of the AER since the data in the AER report

has been extracted directly from a variety of state databases. For example, the

assessment data comes directly from the state assessments and NAEP reports prepared

by the MDE, Division of Accountability Services (DAS). Teacher Quality data comes

from the Center for Educational Performance and Information (CEPI) as reported in the

Registry for Educational Performance (REP). Some accountability data comes from

DAS and some data comes from CEPI. LEAs and schools will have had the

opportunity to appeal this data during the appeal or correction windows of the source

reports. For example, a district that wanted to appeal assessment results or participation

rates had the opportunity to do so during the assessment appeal window. Districts that

wanted to correct the teacher quality data had the opportunity to do so shortly after

submitting the REP data.

The district will take full advantage of the assessment and accountability appeal or

CEPI data correction opportunities.

Procedures


Go to the MI School Data website https://www.mischooldata.org and log in.

Open the AER for the district or school. Familiarize yourself with the data from

last year. Learn how to navigate the reports. Identify how to print the

“Combined” report and how to export it to your website.

Find the new district and school cover letter templates on the MI School Data

website. When you have assessment results, you can start drafting your cover

letters. The accountability sections of the cover letter will have to wait until you

can preview the previous year’s data on the MI School Data website.

Familiarize yourself with the student achievement data. Begin drafting your AER

cover letters using the templates found on the website.

All schools and districts will receive their preliminary accountability data in late

June/early July. If it is not being appealed, you can also start drafting the district

and school AER cover letters. If it is being appealed, you will soon know the

outcome of the appeal and can start drafting the LEA and school cover letters.

As soon as the embargoed AER data is forwarded to the mischooldata.org

website it will be released to the district and schools. At this time administrators

will do final edits on their cover letters. Administrators will prepare to export and

print the AER reports and cover letters for the district and schools.

Post your AER reports and cover letters as soon as the state publicly releases

Accountability results, but no later than 15 calendar days before school starts.

RELEASE OF SCHOOL AND DISTRICT ACCOUNTABILITY DATA

FROM THE ANNUAL EDUCATION REPORT IN ADVANCE OF THE

PUBLIC RELEASE DATE IN MID-AUGUST BY THE MICHIGAN

DEPARTMENT OF EDUCATION MAY JEOPARDIZE THIS ADVANCE

AER POSTING IN THE FUTURE.

NOTE: Do not link the MI School Data website to make your AERs available.

Instead, retrieve the district/school combined data report and post it on the

appropriate websites with the appropriate cover letters (single scanned PDF per AER

– cover letter and combined data report with full date – month, day, year).

PARENT NOTIFICATION OF REQUIREMENTS IN NCLB

Teacher Information At the beginning of each school year, the district and schools as a result of receiving

Title I funds will notify all parents of children attending Title I schools that federal law

gives parents the right to request information about the qualifications of their children’s

teachers and paraprofessionals. This information must be provided to parents in a

uniform format, including alternative formats upon request, and to the extent practicable

in a language that parents can understand. The district will respond to such requests in

a timely manner.


Parents have the right to request information on:

Whether the teacher has met state qualifications and has a license for the grade

level(s) and subject(s) he or she teaches.

Whether the teacher has an emergency or provisional license.

What degrees the teacher holds and the field of discipline of his or her

certification or degree.

The qualifications of any paraprofessionals serving their children.

The district or school principals may notify parents about this right with a usual

communication to homes of students, such as a school newsletter or parent handbook.

In addition, Title I schools will notify parents of the following in a timely manner:

The child’s level of achievement on state assessments.

When the child has been taught for 20 consecutive days by a teacher of a core

academic subject (English, reading or language arts, math, science, history, civics

and government, geography, economics, the arts, and foreign language) who does

not meet the requirements of being highly qualified.

Title I Priority and Focus Schools

The ESEA Flexibility Waiver requires school districts to notify parents that their child’s

school has been named a Title I Priority School or Title I Focus School.

If the district has one or more focus or priority schools it will:

• Seek input from families and the community in selecting meaningful

interventions aligned with the turnaround principles to be implemented in these

schools.

• Include in Priority School interventions ongoing mechanisms for family and

community engagement.

SECTION 3: ALLOWABLE USE OF TITLE I, PART A FUNDS & STUDENT

ELIGIBILITY

ALLOWABLE USE OF FUNDS

District management will enforce appropriate procedures and penalties for program,

compliance and accounting staff that are responsible for the allocation of Federal grant

costs based on their allowability and their conformity with Federal cost principles to

determine the allowability of costs. The Curriculum/Title I Director and building


administrators responsible for monitoring federal programs needs will work with

business office staff.

DEFINITIONS

Allowable cost --- A cost that complies with all legal requirements that apply to a

particular Federal education program including statutes, regulations, guidance,

applications and approved grant awards. A framework for determining whether a cost

is allowable is included in these procedures.

Education Department General Administrative Regulations (EDGAR)---A compilation

of regulations that apply to Federal education programs. These regulations contain

important rules governing the administration of Federal education programs, and

include rules affecting the allowable use of Federal funds (including rules regarding

permissible costs, the period of availability of Federal awards, documentation

requirements, and grants management requirements). EDGAR is accessible at:

http://www2.ed.gov/policy/fund/reg/edgarReg/edgar.html.

2CFR Part 225 also known as OMB Circular A-87---Federal cost principles that

provide standards for determining whether costs may be charged to Federal grants.

EDGAR requires all grantees and subgrantees to follow the cost principles set out in

OMB Circular A-87.

DETERMINING ALLOWABLE COSTS

Framework for analyzing allowable costs

Federal grant programs are governed by a variety of Federal rules including statutes,

regulations, and non-regulatory guidance. To determine whether a cost may be paid

with Federal funds, i.e. whether the cost is permissible, staff must be familiar with these

rules and how they work together.

Generally, when analyzing whether a particular cost is permissible, it is useful to

perform the following analysis:

Is the cost specifically included in the district’s approved grant budget?

Is the cost forbidden by Federal laws such as OMB Circular A-87 or EDGAR?

(see below for examples)

Is the cost permissible under the relevant Federal program?

Is the cost consistent with the Federal cost principles in OMB Circular A-87?


Is the cost consistent with program specific fiscal rules?

Is the cost consistent with an approved program plan and budget, as well as any

special conditions imposed on the grant?

While there are other important considerations district staff must take into account

when analyzing whether a specific proposed cost is permissible, the above questions

can provide a useful framework for the analysis.

Costs forbidden by Federal Law

OMB Circular A-87 and EDGAR identify certain costs that may never be paid with

Federal funds. The following list provides examples of such costs. If a cost is on this

list, it may not be supported with Federal funds. The fact that a cost is not on this list

does not mean it is necessarily permissible. There are other important restrictions that

apply to Federal funds, such as those detailed in OMB Circular A-87; thus, this list is

not exhaustive.

ALLOWABLE COSTS

Costs that may be Allowable Under OMB Circular A-87 Under Specific Conditions:

Advisory councils

Audit costs and related services

Bonding costs

Communication costs

Compensation for personal services

Depreciation and use allowances

Employee morale, health, and welfare costs

Equipment and other capital expenditures

Gains and losses on disposition of depreciable property and other capital assets

and substantial relocation of Federal programs

Insurance and indemnification

Maintenance, operations, and repairs

Materials and supplies costs

Meetings and conferences

Memberships, subscriptions, and professional activity costs

Patent costs

Plant and homeland security costs

Pre-award costs

Professional service costs

Proposal costs

Publication and printing costs


Rearrangement and alteration costs

Reconversion costs

Rental costs of building and equipment

Royalties and other costs for the use of patents

Taxes

Training costs

Travel costs

New Guidance from U.S. Department of Education: Use of Title I funds to provide

Services to Homeless Children and Youth

NOTE: USDE has issued new guidance regarding the Consolidated Appropriations

Act, 2014 which has expanded the allowable uses of Title I, ESEA funds to include

transporting homeless children and youth to their school of origin. Additionally, an

LEA may now use funds from its FY 2014 Title I grant to fund all or part of the

homeless liaison’s salary even if that person has no Title I duties. It is important to note

that while the new authority under the appropriations act now permits an LEA to use

Title I funds to support a homeless liaison and to transport homeless children and youth

to their school of origin, it does not otherwise change an LEA’s existing obligation

under ESEA section 1113(c)(3)(A) to provide comparable Title I services to

homeless children and youth who attend non-Title I schools.

LEAs must continue to meet comparable services needs, but may also use reservation

funds to pay for transportation to the school of origin and/or homeless liaison.

Costs that are Unallowable Under OMB Circular A-87

Advertising and public relations costs (with limited exceptions), is prohibition

includes promotional items and memorabilia, including models, gifts and

souvenirs

Alcoholic beverages

Bad debts

Contingency provisions (with limited exceptions)

Fundraising and investment management costs (with limited exceptions)

Donations

Contributions

Entertainment

Fines and penalties

General government expenses (with limited exceptions pertaining to Indian tribal

governments and Councils of Government (COGs))


Goods or services for personal use

Interest

Lobbying

Selling and marketing costs (with limited exceptions)

Costs that are Unallowable Under EDGAR (Part 76)

The use of funds for religion

The acquisition of real property (unless specifically permitted by programmatic

statute or regulations which is very rare in Federal education programs)

The use of funds for construction (unless specifically permitted by programmatic

statute of regulations which is very rare in Federal education programs)

Charging tuition or fees collected from students toward meeting matching, cost

sharing, or maintenance of effort requirements of a program

Program allowability

Any cost paid with Federal education funds must be permissible under the Federal

program that would support the cost. Many Federal education programs detail specific

required and/or allowable uses of funds for that program. Issues such as eligibility,

program beneficiaries, caps or restrictions on certain types of program expenses, and

other program expenses, and other program specific requirements must be considered

when performing the programmatic analysis.

The two largest Federal K-12 programs, Title I, Part A and IDEA, do not contain a use

of funds section delineating the allowable uses of funds under those programs. In those

cases, costs must be consistent with the purposes of the program in order to be

allowable.

Federal cost principles

OMB Circular A-87 defines the parameters for the permissible uses of Federal funds.

While there are many requirements contained in A-87, it includes five core principles

that serve as an important guide for effective grants management. These core principles

require all costs to be:

Necessary for the proper and efficient performance or administration of the

program.

Reasonable. In other words, it should be clear to an outside observer why a

decision to spend money on a specific cost made sense in light of the cost,

needs, and requirements of the program.


Allocable to the Federal program that paid for the cost. This means that a

program must benefit in proportion to the amount charged to the Federal

program—for example, if a teacher is paid 50% with Title I funds, the teacher

must work with the Title I program/students at least 50% of the time. This also

means that recipients need to be able to track items or services purchased with

Federal funds so they can prove they were used for Federal program purposes.

Authorized under state and local rules. This means that all actions carried

out with Federal funds must be authorized and not prohibited by state and local

laws and policies.

Adequately documented. A recipient must maintain proper documentation

so as to provide evidence to monitors, auditors, or other oversight entities of how

the funds were spend over the lifecycle of the grant.

OMB Circular A-87 also contains specific rules on selected items of costs. Costs

must comply with these rules in order to be paid with Federal funds.

Program specific fiscal rules

All Federal education programs have certain program specific fiscal rules that apply.

Determining which rules apply depends on the program; however, rules such as

supplement, not supplant, maintenance of effort, comparability, caps on certain uses of

funds, etc. have an important impact when analyzing whether a particular cost is

permissible.

Many state administered programs require LEAs to use Federal program funds to

supplement the amount of state, local (and in some cases other Federal) funds they

spend on education costs, and not to supplant – or replace – those funds. Generally, the

“supplement, not supplant” provision means that Federal funds must be used to

supplement the level of funds from non-Federal sources by providing additional

services, staff, programs, or materials. In other words, Federal funds normally cannot

be used to pay for things that would otherwise be paid for with state or local funds

(and in some cases with other Federal funds).

Auditors generally presume supplanting has occurred in three situations:

District uses Federal funds to provide services that the District is required to

make available under other Federal, state or local laws.


District uses Federal funds to provide services that the District provided with

state or local funds in the prior year.

District uses Title I, Part A or Migrant Education Program funds to provide the

same services to Title I or Migrant students that the District provides with state of

local funds to nonparticipating students.

These presumptions apply differently in different Federal programs, and also in school-

wide program schools. Staff should be familiar with the supplement not supplant

provisions applicable to their program.

Approved plans, budgets and special conditions

As required by 2CFR Part 225 (OMB Circular A-87) all costs must be consistent with

approved program plans and budgets. This includes the district’s Consolidated

Application to the Michigan Department of Education and school-level plans such as

school-wide plans or Federal school improvement plans.

Costs must also be consistent with all terms and conditions of Federal awards, including

any special conditions imposed on the district’s grants.

TRAINING

The district will provide training on the allowable use of federal funds to all staff

involved in federal programs through activities such as:

Distributing federal guidance documents;

Distributing District policies and procedures;

Developing templates, checklists and other guidance documents as appropriate;

Internal training sessions;

Routine staff meetings; and

Informal technical assistance.

The district will promote coordination between all staff involved in federal programs

through activities such as:

Routine staff meetings;

Joint training sessions;

Policies and procedures that address all aspects of federal grants management;

Sharing information that has cross-cutting impact such as single audits,

monitoring reports, letters from oversight entities, etc.


TITLE I, PART A STUDENT ELIGIBLITY

Title I Part A school-wide programs must address the needs of all children in the

school, but particularly the needs of children who are members of the target population

of any federal education program whose funds are included in the schoolwide program.

The district offers services to students through school selection under the guidelines of

Title I. Students are selected across grade levels and subject areas defined by needs,

school improvement, and formal and informal testing data. Title I supplemental

academic services are only available to eligible students. Eligible students are

identified using the Michigan Department of Education’s 31A Identified criteria and

the criteria are reviewed in the fall and the spring of each academic year (see section 1

for 31A Identified/Title I Eligible student list procedures – updated August 2014).

Schoolwide 31A/Title I student identification may also consider ongoing classroom

assessments, running records, grade-level log sheets, and program criteria selection

criteria throughout the school year to determine below-grade level achievement in

addition to the MDE’s 31A identified student criteria if a student is not identified using

31A/Title I criteria because a student enters a school without prior assessment data.

31A /Title I identified student lists are maintained in the curriculum office and at the

building level with select staff (administration, psychologists, Title I/31a Reading

Specialists, CHAMP Coordinators, counselors to maintain student confidentiality due to

sensitive family/student data) documenting that appropriate and consistent criterion are

used on an ongoing basis to ensure that services are allowable and in accordance with

program legislation (see Appendix A & B). Staff is required to document students

served and the services provided using the district’s activity log and base their student

selection decisions on the 31A/Title I identified student list generated at least twice a

year after critical student assessment data is collected and analyzed. Grant funded

program participation is based on entrance and exit criteria as noted on the program

descriptions which are updated annually and submitted to the curriculum office no later

than November 30th.

HOMELESS STUDENT ELIGIBILITY FOR TITLE I, PART A SERVICES

The federal definition of homelessness used by the district includes children and youth

who lack a fixed, regular, and adequate nighttime residence. This definition specifically

includes children and youth living in shelters, transitional housing, cars, campgrounds,

motels, and sharing the housing of others temporarily due to loss of housing, economic


hardship, or similar reasons. This is the same definition of homelessness used by Head

Start, special education, child nutrition, and other federal family and youth programs.

Title I Services to Children and Youth in Homeless Situations

Section 11 13(c)(3)(A) of the Title I law states that the district will reserve funds under

Title I, Part A in order to provide comparable services to children and youth in

homeless situations who might attend schools that do not receive Title I funds. This

means that the district will examine the services it provides to students in participating

Title I schools and use Title I funds to provide comparable services to students in

homeless situations who attend non-participating schools in the district. The district can

use Title I funds to provide educationally related support services to children in shelters.

This might include tutoring, school supplies, counseling, and social work services.

The Director of Student Services oversees the homeless program for the district, and the

Director of Curriculum/Title I will plan, budget, and design with the Director of Student

Services/Homeless Liaison equitable services to meet the needs of identified homeless

students in non-Title I buildings by selecting one of the following methods for district:

Determining Title I, Part A set-aside district funds

1. Identify homeless students’ needs and fund accordingly.

2. Obtain student count of homeless students and multiply by Title I, Part A student

allocation.

3. Reserve an amount greater than or equal to the district’s McKinney-Vento

subgrant request.

4. Reserve a specific percentage based on the district’s poverty level or total Title I,

Part A allocation.

SANCTIONS

Any district employee who violates district policies, procedures, and guidelines will be

subject to appropriate discipline as reflected by comments to be placed in their annual

employee evaluation.

SECTION 4: TITLE II, PART A TEACHER AND PRINCIPAL TRAINING

AND RECRUITING

The purpose of Title II, Part A is to increase the academic achievement of all

students by helping schools and the district to improve teacher and principal

quality and ensure that all teachers are highly qualified. Fitzgerald Public

Schools’ students will have access to effective teachers and principals through

equitable distribution and high quality professional learning opportunities in

order to close the achievement gap.


** Equitable distribution is the strategic placement of teachers in order to ensure that

poor or minority children are not taught by inexperienced, unqualified, or out-of-field

teachers at higher rates than are other children. This idea is also extended to principals

to insure an equitable distribution of effective leaders.

Based on a Comprehensive Needs Assessment, Fitzgerald Public Schools will

develop their plan to include the following recommended strategies:

Equitable Distribution of Effective Teachers and Principals

Fitzgerald Public Schools systematically will monitor the assignment of

teachers/principals (based on student achievement and demographics) and insure that all

core academic subjects are taught by highly qualified, effective teachers and principals.

Please keep in mind that analysis of equitable distribution might occur between/within

schools, grade levels or content areas and is possible even within a single site local

education agency. Since legislation now requires all teachers assigned to non-shortage

areas to meet highly qualified requirements, it is the district’s and teacher’s

responsibility to cover the costs of becoming highly qualified.

Recruitment and Placement of Effective Teachers and Principals

Through a number of strategies, the district will successfully recruit highly qualified,

effective teachers/principals and make equitable placements in all schools, all

classrooms and all programs. Title II, Part A funds can be used to recruit highly

qualified teachers which includes providing scholarships, signing bonuses, or other

financial incentives, such as differential pay for teachers to teach in academic subjects

in which there exists a shortage of highly qualified teachers within a school or within

the LEA. Teaching positions that are identified on the list of “teacher shortages” as

approved by the U.S. Department of Education (USED) and defined annually by the

State of Michigan will be eligible for hiring under this provision [ESEA, Section 2123

(a)(2)(A) and (a)(2)(A)(ii) and ESEA Title II, Part A Non-Regulatory Guidance

Question E1]. Funds may be used to pay reasonable and necessary expenses to recruit

under represented teachers and paraprofessionals, and can be used to assist them in

obtaining certification through alternate route programs [ESEA, Section 2123

(a)(2)(c)(iii)(iv) and ESEA Title II, Part A Non-Regulatory Guidance Question E7].

Retention of Effective Teachers and Principals

The district will actively implement a retention program to ensure that highly qualified,

effective teachers/principals are retained in all schools, all classrooms and all programs.


Aligned, Coherent Professional Development for Teachers and Principals

The comprehensive needs assessment conducted by the district will include at least the

following components: student academic achievement, school climate/culture, equity

data, state student achievement results, recruitment/retention information, highly

qualified teacher criterion data, years of teaching experience, teacher attendance rates

and Teacher/Principal Evaluation data. The district will document that professional

development is targeted based on the results of the comprehensive needs assessment.

The district may use Title II, Part A funds to support professional development

activities that improve the knowledge of teachers, principals and, in appropriate cases,

paraprofessionals in core academic subjects, effective instructional strategies and use of

State standards and assessments.

Title II, Part A funds may be used to provide training for teachers, principals and, in

appropriate cases, paraprofessionals to address the needs of students with different

learning styles and how to provide early and appropriate interventions.

Training may also include how to do the following: improve student behavior in the

classroom, involve parents in their child’s education, understand and use data and

assessments to improve teaching and learning and integrate technology into curricula

and instruction.

Principals and superintendents may participate in professional development activities

designed to improve the quality of their work in such areas as management and

instructional leadership.

Central Office staff involved in curriculum, instruction and assessment are also eligible

to participate in Title II, Part A professional development [ESEA, Section 2123

(a)(3)(A) and 2123 (a)(6) and ESEA Title II, Part A Non-Regulatory Guidance Question

E1].

Title II, Part A Funds and Mentoring

The mentoring activities funded under Title II, Part A must be supplemental to the State

mentoring requirements and any mentoring requirements included in local board policy

[ESEA, Section 2123 (4)(A) and ESEA Title II, Part A Non-Regulatory Guidance

Question E16].

Title II, Part A Funds and Substitute Costs


Title II, Part A funds for substitute teachers must be reasonable and necessary. Funds

may be used for substitute services for Title II, Part A class size reduction teachers and

for substitute services for teachers who are participating in Title II, Part A-funded

professional development activities.

The exception to this rule is in the event that the district requires substitute teachers in

order to participate in an ISD facilitated/hosted training or training offered through a

college/university partnership, that has no registration or facilitator cost. If it is in the

school improvement plan and aligned to the needs assessment, these substitute costs can

also be funded by Title II, Part A [Title II, Part A Non-Regulatory Guidance Question

E4].

Title II, Part A and Class Size Reduction

The decision to reduce class size must be based on each school’s comprehensive needs

assessment. In Michigan, class size reduction is only allowed in grades K-3, with a

ratio at least as low as 17 students to one teacher, and the cohort of students must be

preserved for at least two years. Additionally, instructional strategies must be specific

to the needs of the cohort of students in the class size reduction classroom and the

impact on achievement must be evaluated.

Prior to using Title II, Part A funds to reduce class size, the district’s contractual

obligations related to class size must be met. When the contract does not address class

sizes, or the contract has ambiguous language, the Michigan Department of Education

(MDE) will review the district’s historical class size data to determine the number of

generally funded teachers and class sizes in prior years.

The district will refer to MDE’s class size reduction guidance for additional information

[ESEA, Section 2123 (a)(2)(B), ESEA Title II, Part A Non-Regulatory Guidance

Question E17, and Office of School Improvement/Field Services Unit Guidance for Use

of Title II, Part A for Class Size Reduction].

Title II, Part A Funds and Private, Non-Public School Participation

Private school teachers, principals, and other educational personnel are eligible to

participate in Title II, Part A, to the extent that the district uses funds to provide for

professional development for teachers and others.

For purposes of determining the amount of Title II, Part A funds that the district must

make available for equitable services to private school teachers and other educational

personnel, the statute has the district assume that it is spending at least as much for


professional development under Title II, Part A as it did in FY 2001 under the

Eisenhower Professional Development and Class-Size Reduction programs [Title IX,

Section 9501(b)(3)(B)].

The district must provide private school children, their teachers, and other educational

personnel with educational services on an equitable basis and in a timely manner.

Services must be based on a needs assessment data which includes student academic

achievement [ESEA Title II, Part A Non-Regulatory Guidance Question G1 and G4].

Title II, Part A and High Quality Professional Development

The term “high-quality professional development” means professional development that

meets the criteria contained in the definition of professional development in Title IX,

Section 9101(34) of ESEA. Such professional development includes, but is not limited

to, activities that:

Improve and increase teacher’s knowledge of academic subjects and enable

teachers to become highly qualified;

Are an integral part of broad schoolwide and district educational

improvement plans;

Give teachers and principals the knowledge and skills to help students meet

the challenging State academic standards;

Improve classroom management skills;

Are sustained, intensive, and classroom-focused and are not one-day or short

term workshops;

Advance teacher understanding of effective instruction strategies that are

based on scientifically based research; and

Are developed with extensive participation of teachers, principal, parents,

and administrators. [ESEA Title II, Part A Non-Regulatory Guidance,

October 5, 2006]

The planned professional development activities must be aligned to the identified needs

and goals of the school improvement plan. The professional development must include

activities that meet the criteria for scientifically based research [ESEA, Section

9101(37)].

Title II, Part A funds being used to support professional development may only be used

to provide training to staff on the methodology (how to implement a planned strategy or

program). Title II, Part A funds may not be used to pay costs associated with actual

implementation of the learned methodology, e.g., allowed: training staff in how to

effectively align the curriculum; not allowed: paying staff to write/actually align the


curriculum; allowed: provide training in how to “unpack” the High School Content

Expectations (HSCEs); not allowed: paying staff for the time involved to develop

lesson plans using the HSCEs [ESEA, Section 2123 (a)(3)(A)(ii)].

Title II, Part A Costs – Reasonable and Necessary

LEAs must consider whether or not costs are reasonable and necessary. Several

questions a district might ask when attempting to determine if a proposed cost is

reasonable and necessary are, “Would stakeholders, such as parents and community

members, challenge the amount of funds associated with the activity?” “Does the

anticipated result of the activity merit the proposed expense?” “Are costs limited to

those only absolutely necessary to carry out the activity?” [OMB Circular A-87,

Attachment A, Subsection C3].

Title II, Part A Funds – Supplement and Not Supplant

Title II, Part A funds must supplement and cannot supplant non-Federal funds that

otherwise would be used for activities authorized under the ESEA. Professional

development required by State legislation; the State required 5 days of professional

development for all teachers; the additional 15 professional development days and

mentoring requirements for all new teachers in their first three years of teaching, as well

as professional development required by local board policy, cannot be funded with Title

II, Part A funds.

Additionally, Title II, Part A costs cannot be used to offset professional development

costs for some staff members or be used to fund professional development activities that

have been funded by the district in the prior year. [ESEA, Section 2123 (10)(b) and

ESEA Title II, Part A Non-Regulatory Guidance Questions E15 and E16].

The district will use a comprehensive needs assessment to identify local teacher quality

needs and should take into account: (1) The activities that the district must conduct in

order to give teachers the means to provide all students with the opportunity to meet

challenging State content and academic achievement standards; and (2) The activities

that the district needs to conduct in order to provide principals the instructional

leadership skills to help teachers provide all students with the opportunity to meet

challenging State content and academic achievement standards. A needs assessment

will be utilized to determine the use of Federal funds for class size reduction [ESEA,

Section 2122 (b)(11)(c)(1)(2) and ESEA Title II, Part A Non-Regulatory Guidance

Questions D11, D17, and D18].


Professional development will be designed through a collaborative effort of all

stakeholders (administration, staff, parents and, where applicable, students) based upon

needs assessment data and aligned with the school improvement plan [ESEA, Section

2122 (b (7) and ESEA Title II, Part A Non- Regulatory Guidance Question D12].

The district may use Title II, Part A funds to purchase only those supplies or

instructional materials that are necessary for the participants to participate in the Title

II, Part A professional development activity. This may be a currently-funded Title II,

Part A activity, or the continuation of a previously-funded Title II, Part A training for

which the district has retained appropriate documentation.

Title II, Part A does not permit the use of program funds to purchase materials and

supplies that are not directly connected to teacher professional development such as

classroom supplies and materials that are necessary to carry out implementation of a

professional development activity [ESEA Title II, Part A Non-Regulatory Guidance

Question E10].

Title II, Part A also does not permit the use of program funds to purchase materials and

supplies that are not directly connected to a Title II, Part A funded registration fee or

facilitator cost. The exceptions to these rules are: (1) the purchase of books to support

a facilitated book study and (2) limited participant supplies and materials necessary to

conduct an Intermediate School District (ISD) facilitated/hosted training that has no

registration or facilitator cost and that meets the professional development definition.

Title II, Part A Funds and Professional Learning Community Activities

Title II, Part A funds can be use to train staff on the constructs of the PLC and “how-

to” effectively implement the associated protocols. Federal funds cannot be used to

support PLC activities that develop products required for curriculum, instruction and/or

assessment. The required data analysis for these products are also not allowable

[ESEA, Section 2123 (10)(b) and ESEA Title II, Part A Non-Regulatory Guidance

Question E16].

Title II, Part A Funds and Grade-Level Meetings

If the purpose is to conduct State-required activities or meet local board policy

requirements Title II, Part A funds may not pay for grade-level meetings [ESEA,

Section 2123 (10)(b) and ESEA Title II, Part A Non-Regulatory Guidance Question

E16].

Title II, Part A Funds and Out of State Travel


Legislation requires that all professional development activities support the school

improvement plan, result in effective instructional strategies and are cost effective. To

meet the requirements of cost effectiveness, the out-of-State travel should only take

place when comparable training is not available in-State. The number of participants

must be a small, representative group with the intention of implementing the trainer-of-

trainer model. All costs must meet the requirement of reasonable and necessary

[ESEA, Section 2123 (a)(5)(B), ESEA Title II, Part A Non-Regulatory Guidance

Question D18 and OMB Circular A-87].

Title II, Part A and Competitive Bids

Competitive bids related to the use of Title II, Part A funds must follow local board

policy, and the EDGAR, Section 80.36.

Title II, Part A Funds and Contracted Services

The district will maintain a contract administration system that ensures that contractors

perform in accordance with the terms, conditions, and specifications of a contract. The

contract (or purchase order) must include:

1. Clearly-defined deliverables

2. Description of services to be performed or goods to be delivered

3. Description of dates when services will be performed or goods delivered

4. Description of locations where services will be performed or goods delivered

5. Description of number of staff/parents (if appropriate) to be served

6. Description of how the contract services will be evaluated

Invoices will be reviewed and approved before payment. There will be

segregation of duties and invoices must have documented approvals. In addition,

invoices must include description of:

1. Services performed or goods delivered

2. Dates services were performed or goods delivered

3. Location services were performed or goods delivered

4. Number of staff/parents (when appropriate) to be served

5. How the contract services will be evaluated

Title II, Part A Funds for University Credit or State Board Continuing Education

Units (SBCEUs)

Title II, Part A funds cannot be used for college credit that leads to a raise in the teacher

or principal pay scale or is part of a degree program. If a teacher or principal is

participating in training that offers SBCEUs, Title II, Part A funds can pay for the


registration costs; however the teacher or principal must pay for the SBCEUs. SBCEUs

and college credit that are used to maintain State continuing education requirements in

order to maintain certification are not an allowable Title II, Part A expenditure.

However, for private school staff, the consultation process could include requests for

participation in University classes as appropriate to improve student instruction.

The Director of Curriculum/Title I, Building Administrators, and Director of Business

establish the budget for the program based on the district’s academic needs. The

Curriculum Office monitors actual expenditures closely on a monthly basis and ensures

that they are properly recorded and are approved by the state. The Director of

Curriculum/Title I, respective building principal(s), and Business Director ensure that

all employees that are charged to the grant have the necessary documentation to support

the allocation. Administrative cost for Title II, Part A should be kept within 5% cap.

For Title IIA, the buildings are given a per student allocation and then establish a

budget along with narratives that reflect the teacher professional development needs as

indicated on their CNA data. The district is also provided with an allocation. The

Curriculum and Business Directors review the budget/narratives to ensure that they

meet the allowable use of funds criteria and ensure that they are coded to the correct

account number. The Curriculum and Business Office and principals closely monitor

the activities applied to the grant to ensure all the goals and programs are being met.

The Business Office monitors the expenditures applied to the grant to ensure they are

within the approved budget allocation. The Business Office also reviews the general

ledger detail when making the requests for program funds to ensure they are within the

grant period and are allowable.

ALLOWABLE COSTS/COST PRINCIPLES

The district requests funds on an expense reimbursement basis following the district’s

business office procedures and completes the request after payroll is issued, payroll

taxes are paid, and vendor payments are issued. The Business Director/designee

completes the analysis/request for cash and reviews/submits the request. The Business

Director/designee reviews the general ledger for expenditures that are charged to the

various Federal programs to ensure that they are within the proper grant period. The

Business Director/designee will then compare the total expenses charged to what was

previously requested. Finally, the Business Director/designee will make the

reimbursement request. Note, the Business Director/designee verifies expenditures,

revenue collected to date, and amount of request.

ELIGIBILITY


The district offers services to staff following the guidelines of Title II, Part A. District

staff fills out the professional development form supplies by the Curriculum Office to

gain approval. The Curriculum/Title I Director approves professional development

requests and reviews accounts to be charged. District Title II, Part A staff completes

required district personnel activity reports or semi-annual certifications, and activity

reports and administrators ensure that eligibility reports are properly completed and

submitted to the Curriculum Office for compliance review following the determined

timelines for submission. Any planned changes from year to year in the utilization of

Title II funds are carefully reviewed by the Curriculum and Business Offices to ensure

that the District is not supplanting general fund expenditures.

PERIOD OF AVAILABILITY OF FEDERAL FUNDS

Once the district submits the Consolidated Application for the Title II, Part A funds,

they will receive the approval letter from the MDE outlining the period of availability.

The Business Director/designee will closely monitor expenditures to ensure all

expenditures are within the grant period. Any expenses applied to the grant that do not

fall within the allowable program period will be immediately adjusted for. The review

of expenses applied to the program, to ensure they are within the availability of the

program, is done during the monthly request for federal funding.

The Business Director/designee will review grant expenditures for proper cut-off and

documents this procedure through the accrual process at year-end, as well as the

monthly request of federal funding. This review is documented by the Business

Director/designee staff as part of the month end close out procedures.

Purchases with federal funding follow the districts purchasing policies. If a purchase or

contract is anticipated to go over the state’s current sealed bid limit, the Business

Director/designee will complete a formal request for bids. Once the bids have been

received, they will be reviewed to determine that the bidders have not been suspended

or debarred. The Curriculum/Title I and Business Directors will review the bids and

make a recommendation to the board. The board will award the final bid. The Director

of Business/designee will verify the proposed vendor is not on the disbarment list.

SECTION 5: TITLE III ESL & IMMIGRANT PROGRAM

The purpose of Title III, Part A is to help limited English proficient (LEP) students

attain English language proficiency and knowledge and skills to meet State academic

achievement standards.

The purpose of Title I, Part A is to help academically at-risk students attain the

knowledge and skills to meet State academic achievement standards.


The purpose of Section 31a is to provide supplementary instructional and pupil support

services for pupils who meet the at-risk criteria specified in the legislation.

Federal Laws

Title VI of the Civil Rights Act of 1964 prohibits discrimination on the basis of race,

color, and national origin. Under Title VI, “No person in the United States shall, on the

ground of race, color, or national origin, be excluded from participation in, be denied

the benefits of, or be otherwise subjected to discrimination under any program to which

this part applies.”

OCR requires providing an Alternative Language Program for ELs to ensure

equitable access to the state content standards.

Supplanting and Provision of Language Instruction Educational Programs

The district will provide core language instruction educational programs and services

for limited English proficient (LEP) students and will submit an Alternate English

Language Plan to the state as required. This requirement is established based on Title

VI of the Civil Rights Act of 1964, and its implementing regulations, as interpreted by

the Supreme Court of the United States (including the Supreme Court’s ruling in Lau v.

Nichols), and based on other significant case law (including Castaneda v. Pickard), the

Equal Educational Opportunities Act of 1974, and other Federal, State, and local laws.

Therefore, the district will not use Title III funds to provide core language instruction

educational programs, including providing for the salaries of teachers who provide

those core services for LEP students, would violate the supplement not supplant

provision in section 3115(g) of the Act, as such services are required to be provided by

districts regardless of the availability of Federal Title III funds.

Criteria For Using Federal Funds

Reasonable

A cost is reasonable if, in its nature and amount, it does not exceed that which would be

incurred by a prudent person under the circumstances prevailing at the time the decision

was made to incur the cost.

Allocable A cost is allocable to a cost objective if the goods or services involved are chargeable or

assignable to the cost objective in accordance with the relative benefits received.

Allowable

A cost is allowable if it is necessary and reasonable for proper and efficient

performance of the award and allocable to the award. (OMB Circular A-87)

Title III funds must be used over and above the basic services, the Alternative language

program services, Title I, Part A and Section 31a.


Layers of Education and Supports for ELL

1st - Basic, local board adopted curriculum that all students receive.

2nd - OCR mandated alternative language program that provides students English

language instruction and meaningful access to the core curriculum (1st layer)

3rd - Supplemental support from Title I and Section 31a

4th - ALTERNATIVE Title III supplemental services beyond 1st & 2nd layers:

must include additional direct instruction that helps close the achievement gap,

professional development, and parent outreach

Title III English Language Acquisition: Generally Allowable Expenditures

Title III funds are supplemental and are to be used over and above the district’s required

services and resources provided to ELLs and their families.

Required activities include:

1. High quality language instruction educational programs that demonstrate

effectiveness by increasing English proficiency and student academic

achievement in the core academic subjects.

2. High quality professional development of sufficient intensity and duration that

demonstrates effectiveness in improving instruction and assessment, enhances

the ability of teachers to understand and use curricula, assessment measures, and

instructional strategies §3115(C). Title III (Section 3111) Highly qualified

professional development will be focused on language and content instruction;

only for teachers of English learners; be systemic, systematic and job embedded;

and evaluated annually.

Title III supplemental ELL funds can be used, in priority order, for the following:

1. Services during, before and after school such as tutoring, academic assistance,

supplementary instructional materials for English language acquisition as well as

for summer school programs for ELLs. The district will identify the students

served and the method used to assess and monitor their progress.

2. Professional development that is planned based on student achievement data and

provided in a systemic and sustained manner to improve instruction and

assessment of ELLs. Staff training could include bilingual/ESL classroom

teachers, bilingual/ESL teacher coaches, paraprofessionals, regular education

teachers, administrators, and other school based or community-based

organizational personnel who serve ELLs.

3. Hiring bilingual/ESL coaches whose role is to acquire scientific-based research

practices, provide professional development, mentor and coach teachers who are

working directly with ELLs. Additionally, such funds can be used to provide


stipends to teachers to assist them in completing and obtaining bilingual/ESL

endorsements.

4. Parent involvement activities including family literacy (ESL) and parenting

classes. Additionally, funds can be used for speakers who conduct informative

parent sessions that enhance student language acquisition and mastery of core

academic subjects. Districts may purchase supplemental instructional materials to

support child’s

5. English language learning at home, materials and books on parenting skills. A

Parent Involvement Liaison can be hired or contracted to enhance ongoing parent

engagement in school activities, committees and functions, facilitate planning

and conducting parent meetings, connecting families to community resources,

and interpreting to parents during Title III meetings.

6. Cost for educational field trips if part of high quality language instruction

educational programs/activities (buses and admission).

7. Administrative and Indirect costs of III/Immigrant may NOT exceed 2% of the

total allocation.

Title III Non-Allowable Expenditures 1. Title III funds may NOT be used to pick up a cost that was previously funded by

general funds.

2. Title III may NOT supplant any other federal, state or local expenses.

3. All test administration cost (WIDA ACCESS and WIDA ACCESS Screener,

other state assessments) must be paid by general fund, including the pay for

proctors, assessors and substitute teachers.

4. Translation of documents, parent handbooks, and assessments are funded by

general funds and NOT with Title III funds.

5. Title III funds may NOT be used for Intake/Eligibility or Annual progress

assessments.

Immigrant Program: Generally Allowable Expenditures Sub-grants to LEAs and ISDs are made if significant increase is experienced in numbers

of immigrant students from ages 3-21; enrolled in public or private school; not born in

US; not attended US school for more than three full years. Purpose of Immigrant sub-

grants is to pay for activities that provide enhanced instructional opportunities for

immigrant children and youth §3115(C).

Allowable activities include:

1. Support for personnel, including paraprofessionals who have been specifically

trained, or are being trained, to provide services to immigrant children and youth.

2. Provision of tutorials, mentoring, and academic or career counseling for

immigrant children and youth (career exploration and shadowing experiences,

college visits, etc) throughout the day and before/after school.


3. Identification and acquisition of bilingual curricular materials, bilingual

educational software and technologies to be used in the program carried out with

these funds.

4. Activities, coordinated with community-based organizations, institutions of

higher education, private sector entities, or other entities with expertise in

working with immigrants, to assist parents of immigrant children and youth by

offering comprehensive community services.

5. Family literacy, parent outreach liaison and activities, training activities designed

to assist parents in adjusting to and understanding the American culture and

school system in order to become active participants in the education of their

children.

6. Administrative and indirect cost to Title III Immigrant may NOT exceed 2% of

the total allocation.

Title III Immigrant Non- Allowable Expenditures 1. Title III Immigrant funds may NOT be used to pick up a cost that was previously

funded by general funds.

2. Title III Immigrant funds may NOT supplant any other federal, state or local

expenses.

3. All test administration cost (WIDA ACCESS and WIDA ACCESS Screener,

other state assessments) must be paid by general fund, including the pay for

proctors, assessors and substitute teachers.

4. Title III Immigrant funds may NOT be used for Intake/Eligibility or Annual

progress assessments.

5. Translation of documents, parent handbooks, and assessments are funded by

general funds and NOT with Title III immigrant funds.

Title III and Parent Engagement

The district will implement an effective means of outreach to parents of limited English

proficient children. The outreach must inform parents how they can be involved in their

children’s education and be active participants in helping their children learn English

and achieve academically. Outreach shall include holding, and sending notices of

opportunities for, regularly scheduled meetings with parents of LEP children to

formulate and respond to parent recommendations.

Parent outreach will be:

1. Guided by parental input and active participation;

2. Supplemental to, and well coordinated with Title I, Part A policy and plan;

3. Aligned to students’ objectives; and

4. Evaluated annually.


Title III funds will be used to provide language instruction education to students with

limited English proficiency (LEP). Schools and the district will notify parents of

children identified for participation in an LEP program no more than 30 days after the

start of the school year. For a child identified as in need of an LEP program after the

start of the school year, parents will be notified within two weeks of placement in a

program.

The district and schools will notify parents of the following:

• The reasons for identifying the child as limited English proficient and for placing

the child in a language instruction educational program for LEP students.

• The child’s level of English proficiency, including how the level was assessed

and the status of the child’s academic achievement.

• The instructional methods to be used in the program in which the child is

participating or might be assigned to and a description of all language programs

that differ in content, use of English, and a native language.

• How the program will meet the educational strengths and needs of the child.

• How the program will help the child learn English and meet age-appropriate

academic achievement standards.

• Specific exit requirements of the program, including when the transition will take

place. Secondary schools also inform parents of the child’s expected date of

graduation.

• For children with a disability, how the program will meet the objectives of an

individualized education program (IEP).

The notification will include written guidance that explains the following:

• The parent’s right to have his or her child removed, immediately upon request,

from the language instructional program.

• The other possible programs or methods of instruction available and the parent’s

option to decline enrolling his or her child.

• How parents will receive assistance in selecting another program or method if

one is offered by the district.

School districts are also required to notify parents of LEP children participating in a

Title III program if the program is failing to help the child make progress on annual

measurable achievement objectives. This notice must be provided no later than 30 days

after the failure occurs and, as with all notices, must be in an understandable and

uniform format and, to the extent practicable, in a language parents can understand. A

child may not be admitted to or excluded from any federally assisted education program

on the basis of a surname or language minority status.

Title III Administrative and Indirect Costs


The district will have a limit of 2% of the Title III grant for administration. (section

3115(b). The 2% administrative cap must include both administrative costs and indirect

costs. Administrative costs are associated with overall project management and

administration and are not directly related to the provision of services or otherwise

allocable to program cost objectives/categories. Indirect costs represent the expenses

of doing business that are not readily identified with a particular grant, but are necessary

for the general operation of the organization.

Title III Immigrant and Title III LEP Budget and Expenditure Coordination The Director of Student Services, Stakeholders and Business Manager/designee will

establish the budget for the program based on the district and school’s academic needs

and set aside/distribution regulations. The Director of Student Services and the Business

Director/designee will monitor actual expenditures closely on a monthly basis and

ensure that they are properly recorded and are approved by the state. The Director of

Student Services and the Business Director/designee ensures that all employees that are

charged to the grant have the necessary documentation to support the allocation.

Eligibility

The district offers services to students under the guidelines of Title III. Students are

selected across grade levels and subject areas defined by needs, school improvement,

and formal and informal testing data. The Director of Student Services and the Director

of Business/designee completes the application and ensures that eligibility reports are

properly completed and submitted to the MISD/State. Following this will be

continuous monitoring by the Director of Student Services to ensure eligibility

requirements are met.

Equipment and Property Management

All equipment purchases are properly reported/accounted for within the approved

budget and tagged/identified following the district technology/equipment procedures.

The Director of Student Services and the technology department maintains a log of

assets purchased with Title III funds and closely monitors the location of such

equipment using the Destiny system. The school buildings also maintain a log of

equipment purchased with building-level federal funds. Any proceeds received from

the disposal of the equipment will be returned to the grantor if applicable. If applicable,

the Director of Student Services and the technology staff will maintain a log of the

tagged equipment and/or real property records for reporting. They will also ensure that

equipment is adequately safeguarded and tracked to ensure proper identification. Upon

disposal, the Director of Student Services will notify the accounting department. The

district is responsible for returning any proceeds to the grantor if applicable.

Matching, Level of Effort, Earmarking


Any planned changes from year to year in the utilization of Title III funds are carefully

reviewed by the student services and business office to ensure that the District is not

supplanting general fund expenditures. In addition, the district ensures that funds that

are earmarked for certain programs are identified in the budget and accounted for

separately. Significant planned changes in utilization of Title III funds are discussed

with the District’s MDE Title III Field Services representative prior to implementation.

Period of Availability of Federal Funds

Once the district submits the application for the Title III funds, they will receive the

approval letter from the MDE outlining the period of availability. The Director of

Student Services and the Business Director/designee will closely monitor expenditures

to ensure all expenditures are within the grant period. Any expenses applied to the grant

that do not fall within the allowable program period will be immediately adjusted for.

The review of expenses applied to the program, to ensure they are within the

availability of the program, is done during the monthly request for federal funding. The

Director of Student Services and Business Director/designee will review grant

expenditures for proper cut-off and documents this procedure through the accrual

process at year-end, as well as the monthly request of federal funding. This review is

documented by the business office staff as part of the month end close out procedures.

The district receives notification of their award and meets with the Director of Student

Services to determine budget within their allocation. Also, private school notices are

sent out to notify them that they are eligible to receive services. Several stakeholders

and departments will work together to ensure all requirements and compliance measures

are met. The Director of Student Services and the Director of Human Resources will

review applicants so that all educational employees are highly qualified upon being

hired as an employee. The Director of Student Services will monitor if any private

schools start up to ensure they are notified about receiving services.

SECTION 4: TIME AND EFFORT APPROVAL & REPORTING PROCESS

All employees whose compensation is paid, in full or in part, with Federal funds must

maintain time and effort records in accordance with the established criteria. Employees

must provide the information required on a timely basis and in accordance with all

procedures. Time and effort records must be maintained in order for Fitzgerald Public

Schools to charge employee compensation costs to Federal grants; thus, compliance

with these procedures prevents disallowance of salary and wages charged to Federal

grants.

DEFINITIONS


Cost Objective: A particular grant award or other category of costs used to track

specific cost information (e.g. earmarks or set-asides that require Fitzgerald Public

Schools to track expenditure information to ensure it spends a specific amount for a

specific purpose).

Employee Compensation: All amounts paid to an employee for services rendered

during the award period. Compensation includes salaries, fringe benefits, stipends,

bonuses and payments made under supplemental contracts.

Multiple Cost Objectives Employees: Employees who work on multiple cost

objectives such as:

More than one Federal award;

A Federal award and a non-Federal award;

More than one activity within a Federal award that is separately tracked by

Fitzgerald Public Schools (such as set-asides, earmarks or match/in-kind

contributions).

2CFR, Part 225: Federal cost principles that provide standards for determining

whether costs may be charged to Federal grants.

Personnel Activity Report (PAR): A document certifying the amount of time a

multiple cost objective employee spends on each cost objective. The PAR must reflect

an after-the-fact distribution of the activities performed; account for the total activity for

which the employee is compensated; be prepared at least monthly and coincide with one

or more pay periods; and will be signed by the employee.

Semi-Annual Certification: A document certifying a single cost objective employee

worked solely on one cost objective. The certification must be prepared at least every

six months and must be signed by the supervisory official having first-hand knowledge

of the work performed by the employee.

Single Cost Objective Employees: Employees who work exclusively on one cost

objective.

PROCEDURE

All employees paid with Federal funds must adhere to the following procedures to

complete the appropriate time and effort records. These procedures also apply to

employees paid with non-Federal funds that are used as a match (or in-kind

contribution) in a Federal program.

Determining Cost Objectives


A cost objective is defined as a Federal grant award, or other category of costs

Fitzgerald Public Schools uses to track specific cost information. In certain

circumstances Fitzgerald Public Schools may track the time employees spend on

particular activities within a single Federal grant in order to demonstrate compliance

with Federal requirements such as earmarks, set-asides or match/in-kind contributions.

When Fitzgerald Public Schools uses employee compensation costs to meet these

requirements they are known as “cost objectives.” In such a circumstance, an

individual grant programs may have more than one cost objective.

Determining cost objectives requires a careful reading of the programmatic provisions

in the statute providing the funds. Employees should contact Fitzgerald’s Business

Office if they need assistance determining the cost objectives on which they work.

Single Cost Objective Employees

An employee who works on a single cost objective must complete a semi-annual

certification that indicates the employee worked solely on that cost objective for the

period covered by the certification. The certification must be prepared at least every six

months. Either the employee or a supervisor with first-hand knowledge of the work

performed by the employee must sign the semi-annual certification.

A semi-annual certification must:

Be executed after the work has been completed;

State that the employee worked solely on activities related to a particular cost

objective;

Identify the cost objective;

Specify the reporting period;

Be signed by the employee or a supervisor with first-hand knowledge of the work

performed; and

Be dated.

The supervisory official for all single cost objective employees must complete the semi-

annual certification attached to these procedures.

The Fitzgerald Business Office will send the semi-annual certification forms to

departments, schools and offices in January and July. If an employee works on a short-

term cost objective whose end date does not coincide with the normal January/July

collection dates for semi-annual certifications (e.g. a supplemental contract for summer

school programs), the employee must obtain a semi-annual certification from the

Fitzgerald Business Office after the time period for the work has ended.


All supervisory officials of single cost objective employees with first-hand knowledge

of the work performed by the employee must complete and sign the semi-annual

certification provided by the Fitzgerald Business Office.

Executed semi-annual certifications must be forwarded to the Fitzgerald Business

Office.

Multiple Cost Objective Employees

Employees working on multiple cost objectives must maintain Personnel Activity

Reports (PARs) or equivalent documentation indicating the amount of time spent on

each cost objective for the period covered by the PAR or equivalent documentation.

The PAR or equivalent documentation must be prepared at least every month. The

employee must sign the PAR or equivalent documentation.

A PAR or equivalent documentation must:

Be executed after the work has been completed (projections of how an employee

is expected to work or position descriptions are not sufficient);

Account for the total activity for which each employee is compensated, including

part-time schedules or overtime (total activity means all of the time an employee

works, not just the amount of time worked on a Federal program);

Identify the cost objectives;

Specify the reporting period;

Be prepared at least monthly and coincide with one or more pay periods;

Be signed by the employee (unlike a semi-annual certification a supervisor’s

signature alone is not sufficient); and

Be dated after the fact (when the work has been completed).

All multiple cost objective employees must complete the PAR attached to these

procedures, unless they receive permission from the Fitzgerald Business Office to use

equivalent documentation in lieu of a PAR.

The Fitzgerald Business Office will send PARs to departments, schools and offices.

Copies of executed PARs, or approved equivalent documentation, must be forwarded to

the Fitzgerald Business Office.

Supplemental Contracts

As discussed above, time and effort records must account for all of an employee’s

activities (i.e. 100% of an employee’s time). Thus, if an employee works overtime that

time must be reflected in the employee’s time and effort record.


If, however, an employee works in two distinct positions the employee may maintain

separate time and effort records for each position.

For example, an employee works as a Title I teacher during the school day (charged to

Title I) and a sports coach after school (charged to State or local funds). Assuming the

coaching responsibilities are not part of the employee’s regular job functions (e.g. the

employee has a supplemental contract for the coaching position), the employee may

treat each position separately – meaning the employee may complete a semi-annual

certification for the teaching position, while no Federal time and effort record would be

required for the coaching position.

In a similar example, an employee works as a Title I teacher during the school day

(charged to Title I) and a 21st Century Community Learning Center (CCLC) teacher

after school (charged to 21st CCLC). Assuming the after school activities are not part of

the employee’s regular job functions, the employee may complete a semi-annual

certification for the Title I teaching position and a separate semi-annual certification for

the 21st

CCLC teaching position.

Stipends

Employees may be provided stipends to participate in activities such as professional

development. Employees receiving such stipends for Fitzgerald Public Schools-

sponsored activities may satisfy time and effort records by signing the sign-in and sign-

out sheets provided at the activity.

Employees receiving such stipends for non-Fitzgerald sponsored activities should

contact the Fitzgerald Business Office to obtain the necessary documentation.

Reconciliation

It is Fitzgerald Public Schools’ practice to charge employee compensation costs to

Federal programs based on budget estimates that reasonably approximate how an

employee will work during the year. Fitzgerald Public Schools will reconcile payroll

charges to the time and effort reflected in employee time and effort records at least

quarterly.

If Fitzgerald Public Schools identifies a variance between how an employee’s salary

was charged and how the employee actually worked, Fitzgerald Public Schools will

adjust its payroll charges so that the amount charged to Federal funds reflects the

employee’s actual time and effort. Fitzgerald Public Schools will perform the

adjustment annually if an identified variance is less than 10%. Fitzgerald Public

Schools will perform the adjustment at least quarterly if an identified variance is 10% or

more.


In-Kind Contributions and Matching

Employees who are paid with non-Federal funds that will be used to meet a Federal

match requirement (also known as in-kind contributions) must comply with the same

time and effort reporting requirements as employees who are paid with Federal funds.

In other words, employees paid with matching funds who work on a single cost

objective must complete a semi-annual certification in accordance with the procedures.

Employees paid with matching funds who work on multiple cost objectives must

complete a personnel activity report in accordance with the procedures.

Document Retention

Time and effort records must be maintained for a period of five (5) years

Employee Accountability and Sanctions

Failure to follow the provisions of this time and effort reporting policy and procedure

may subject the individuals, departments or schools responsible for the violation(s) to

administrative and/or disciplinary actions in accordance with Fitzgerald Public Schools

disciplinary procedures and the judgment of management.

For violations of this Procedure, Fitzgerald Public Schools may impose sanctions as

follows:

1. If time and effort reports are not completed and returned in a timely manner,

salary costs associated with uncertified grant activity may be removed for the

individual and will not be charged to a General Fund account.

2. Fitzgerald Public Schools may suspend any new work by a noncompliant

employee, or inclusion of a noncompliant employee in projects or programs, until

time and effort reports are up-to-date and properly completed and certified.

3. Certification of time and effort reports that are known to be materially inaccurate

may expose the individual who completed the reports to personal disciplinary

action.

4. Further, at the discretion of the Fitzgerald Public Schools administration,

payment to an individual for time and effort expended on the grant may be

withheld if time and effort reports are not complete.

Financial Management Federal Fiscal Review Tool Checklist

There are written procedures on recording time distribution for employees who

work on one or more Federal cost objectives.


The district has PARs for split-funded employees (instructional staff may use

their lesson plans to confirm their written schedules if they meet all of the other

PAR requirements).

The PARs are prepared at least monthly (recommended each pay period)

The PARs are signed and dated by the employee (A-122 allows PARS to be

signed by the supervisor for non-profit agencies)

The PARs account for the staff person’s total activity

The PARs are contemporaneous and not prepared in advance (if lesson plans are

used to support PARs, the teacher must make daily progress notations. Lesson

Plans Cannot Replace PARs).

If paraprofessionals use regular time sheets, the time sheets:

Are an after-the-fact distribution of their actual activity

Account for the total activity for which they are compensated

Show the hours or percentages for the programs that they worked on

Are prepared at least monthly and prepared to coincide with at least one pay

period

Are signed by the employee

For 100% Federally-funded or “single cost objective” district employees (this

section does not apply to non-profits, A-122 requires non-profit employees to

prepare PARs monthly):

The district has certifications or a blanket certification showing that the

employees worked solely on a single Federal cost objective

The certifications are prepared at least semi-annually

Individual certifications are signed and dated by the employees and a supervisor

with first-hand knowledge of the work performed by the employees. Blanket

certifications are signed and dated only by the supervisor with first-hand

knowledge of the work performed by the employees.

The certifications are contemporaneous and not prepared in advance

Business Office Duties

The system for establishing estimates produces reasonable approximations of the

activity performed

At least quarterly, comparisons are made of actual costs to budgeted distributions

based on monthly activity reports

Adjustments are made to costs charged to Federal awards based on the activity

actually performed (if the quarterly comparisons show differences between

budgeted and actual costs of less than 10%, these adjustments can be made

annually)

The budget estimates or other distribution percentages are revised at least

quarterly, if necessary, to reflect changed circumstances


Attachments Include: Example PAR

Example (Individual) Semi-Annual Certification

SECTION 7: EQUIPMENT MANAGEMENT & MONITORING

In accordance with district policy, proper records must be created, maintained and

retained for equipment acquired with grant funds. Equipment with an acquisition

value of $100 and above and a useful life of more than one year which was

purchased with grant funds must be adequately maintained and safeguarded. Disposition or encumbrance of equipment must conform with grant requirements. The

granting agency must be compensated for any equipment sold or converted to non-grant

use. District must take inventory of all grant purchased equipment with a unit value of

$100 and above at least once every two years and reconcile this information with

current asset records.

DEFINITIONS

Equipment-as stated in 45 CFR Parts 74 and 92, is an article of tangible nonexpendable

personal property having a useful life of more than one year and an acquisition cost of

$5,000 or more per unit. However, consistent with recipient organizational policy,

lower limits may be established. Cost is defined as unit price including calibration,

installation, freight, and trade-in. Equipment is free standing (complete in itself, does

not lose its identity when affixed to or installed in other property).

Capital Asset-A long-term asset that is not bought or sold in the regular course of

business. Examples include land, buildings, machinery, etc. Generally, these are assets

that cannot be turned into cash quickly.

PROCEDURE

Proper records must be created, maintained and retained by designated personnel for

equipment acquired with grant funds. Methods of valuation for equipment include any

outside labor, materials, and supplies used to place machinery, equipment, furniture,

fixture items into service. These records should reference the percent and source of

federal funds used to acquire the referenced equipment.

Items with an acquisition value over $100 and a useful life of more than one year must

be tracked at the school or department level.

Identification


A label with the District's name and an identification number will be placed on each

piece of equipment. The identifiers are to remain intact and not be tampered with.

Records should include the following information:

Purchase price and cost of placement on site ready for use

Useful life

Asset identification

Date of acquisition (month/day/year)

Description (noun first, then adjective-e.g. table, conference)

Manufacturer

Model number

Serial number

Purchase order number

Funding source and percent (i.e. IDEA, Title I)

Location of asset including Site, Building and Room

Classification of the asset and its associated life

Records of the identification number, serial number, model, etc. for each piece of

audiovisual equipment shall be maintained in Destiny for each building.

Each district must assign accountability for equipment management to a staff person.

The district must have a system that provides safeguards against loss, damage or theft of

equipment acquired with federal grant funds, and also requires the investigation of any

losses, damage or theft of such equipment. The cognizant employee must file an

incident report for any theft of grant funded assets at the school building level.

Deliveries

It is required that each school has a written building policy for deliveries to the

building, as well as a plan to safeguard items. The plan should specify procedures and

internal controls pertaining to: intake, inventory, storage, deployment, and security

procedures.

Internal controls pertain to such actions as:

Designation of personnel responsible for key functions.

Clearly defined roles and responsibilities.

Detailed operating procedures.

Inventory (in accordance with SOP).

Maintenance of signed records.

Oversight of the entire process by the principal or designee.

Upon delivery of equipment, there should be a designated person and a "back-up"

person, who are trained with protocols, responsible for signing for receipt, verifying,


counting, and storing items until the principal (or designee) gives directions as to

deployment.

Retrieve the packing slip; verify the listed items with the contents of the package, and

cross-check with the original order. Retain the packing slip on file.

When deliveries are made, secure all boxes immediately. Do not allow delivered goods

to be stacked in the halls or corridors for any length of time.

If there is not space for the proper acceptance and handling of a delivery, establish a

plan for offsite staging or the setting up of temporary space.

Use of Hardware and Software

All audiovisual equipment is to be used either in the District or off-school premises

shall be checked out through the school media center. Use of equipment may not be

used for the purpose of copying materials in violation of copyright laws.

The person checking out the audiovisual equipment is responsible for the condition of

the equipment until checked back in.

Students should not use audiovisual equipment without a staff member or approved

volunteer being present.

In special circumstances, students may be allowed to use equipment, without

supervision, when the teacher in charge deems it desirable and the student has proved

himself/herself responsible.

Where an exceptional instructional need is demonstrated, permission to use equipment

off the school premises shall be granted by the principal after consulting the building

media coordinator.

Exceptional instructional needs include, but are not limited to:

Increasing teacher proficiency in the operation of equipment necessary for

classroom instruction;

Producing/preparing instructional materials or classroom lessons;

Developing new or additional applications of the computer;

Allowing students to do homework assignments or self-tutoring.

Please note: In the event of an evacuation, it may not be possible to secure equipment

before leaving the premises. Staff should ensure all classroom doors are locked and

secured.

Requests for Personal Use


Personal use of equipment, including computers and peripherals, by students, and staff

shall be in accordance with Board Policy and the accompanying guidelines. No

business use shall be made of any borrowed equipment. Software shall not be used in

violation of any licensing agreement nor shall it be copied.

Requests to use audiovisual equipment for personal use off school premises will require

written permission from the building principal.

Staff members must fill out the appropriate form and submit it for approval at least

forty-eight (48) hours in advance to the principal.

Staff members requesting equipment for personal use may do so no more than four (4)

times. They will be responsible for arranging safe transportation and housing for

equipment used off school premises and will accept responsibility for any damages.

Students must receive permission from their instructor, based on a legitimate

instructional purpose, prior to completing the appropriate form and submitting it to the

principal. A request must be submitted at least forty-eight (48) hours prior to the

intended use. All equipment must be checked out in Destiny.

All requests will be maintained in the individual school media center and a copy sent to

the business manager.

All requests will be maintained in the central office by business manager.

Users will be responsible for arranging safe transportation and housing for equipment

used off school premises.

The borrower will not be held responsible if repair is required as a result of the

equipment malfunction or unavoidable circumstances but will be responsible for

damages resulting from negligence. In no instance, should an attempt be made to repair

equipment. The defective item should be returned to the building media center as is.

The District will repair the equipment and, if appropriate, bill the user.

Staff Services

Media staff will instruct the user on the correct operation of equipment and prior to the

user receiving the material. The principal will designate appropriate staff to assist in

moving and setting up equipment for instructional purposes on school premises.

Storage

Storage areas should be chosen for maximum security. Consider the following:


If your building has a direct-feed, intruder alert alarm to the local police, make sure it is

in working condition. Report malfunctions to the Director of Business.

Choose rooms with deadbolt locks, window grills, alarms, video surveillance cameras

and/or additional locking mechanisms. Provide keys and access codes (change often) to

select personnel only.

Maintain a vault, safe, or a room with steel doors for securing valuable equipment.

Keys to this area should be limited to designated personnel.

Storage rooms should be away from items or structures that can be used as ladders to

gain access. Do not select a room for storage if it is equipped with sprinklers.

Establish and maintain an effective asset management system/inventory (regardless of

whether the equipment is in use or not) and keep it up to date.

Establish sign-out procedures and policies for expensive equipment that will be used by

students or staff outside of the building (off-site usage).

Portable equipment such as computers and other electronic equipment should be

returned to limited access and secure storage areas during summer months and long

holidays.

Newly delivered equipment, especially computer equipment, should be stored in a

secure area if site preparation has not yet been completed. Doors without windows are

preferred for storage use.

Every piece of equipment should be labeled, engraved, and/or indelibly marked or

otherwise permanently tagged with the site location.

Tagging or attempting to "systematically deface" the equipment involves making the

equipment unsalable by writing or engraving the school's name in a prominent place (or

by asking art students or staff to paint or stencil on the equipment). It creates a high

risk for thieves and without accurate identification police cannot seize stolen property

or prosecute the offenders.

Expensive equipment (such as computers) should be permanently anchored/locked into

place wherever feasible and cost effective.

Secure all mice and keyboards with cable ties, thereby making it harder for someone to

steal them quickly.

Post notices to the effect that all equipment is security marked.


Distribution

Equipment received at each location is "checked in" to the Destiny Library Information

System using its bar-coded serial number or a given bar-code if the item does not have a

serial number. Equipment is then "checked out" to "room" patrons or "staff" patrons to

facilitate tracking the location of equipment as needed and for annual inventory.

All Title I or other grant equipment should be checked out to a patron (staff, student,

cart, chest, secure room) to facilitate the required 6 month (minimum) inventory

requirement.

Any Title I or grant equipment "checked in" to the media center collection will not

appear on the Title I or grant inventory report and will not participate in the 6 month

(minimum) inventory process. To participate in the inventory process Title I equipment

not in use must be checked out to "secure room(s) patron(s)" defined for your building.

Items not in use may also be "checked out" to and stored in secure containers such as

iPad/netbook carts or lockable chests.

The inventory report is a "patron" report listing staff, student, cart, chest and "secure

room" patrons along with the equipment that is checked out to those patrons.

Overdue reports run once every 90 days or less indicate equipment that needs to be

inventoried (checked in/out to reset the loan period). If equipment is circulated

(checked in/out) periodically (within the 90 day equipment loan period) the overdue

report will be brief and the inventory process simplified.

The contents of iPad/netbook carts and lockable chests can be "checked out" in mass or

individually. Each of these containers should have both a patron bar code to track the

containers contents and an equipment barcode to track the location of the container.

Check out "in mass": Before checking out a container, inventory the contents by

renewing the loan period of the items in the container with the containers patron

barcode. Then check the containers "equipment barcode" out to the staff patron.

Check out "individually": Just like a book

The 90 day loan period can be adjusted in concert with the frequency of overdue report

reviews to achieve a better than 6 month inventory period for each item tracked.

Equipment Inventory, Disposition and Repair

All hardware will be inventoried throughout the school year. An accurate inventory of

all District computers and other audio-visual equipment in the District will be

maintained by the business office. Inventory of computers and other audiovisual


equipment will also be maintained in the school or department in which they are

located.

The district must take a physical inventory of all grant purchased equipment with a

current market value of $100 and above at least once every two years.

Assets that are present but are not on the list, should be recorded in accordance

with subsection a. above.

District records must document any items that are no longer present and the

current status of these items should be recorded.

The Accounting staff will assess the results of this process and make the proper

reconciliations in the fixed asset database or system.

Disposition of equipment must conform with grant requirements. In accordance with 34

CFR 80.32, items with a current per-unit fair market value of less than $5,000 may be

retained, sold or otherwise disposed of with no further obligation to the awarding

agency. Items with a value greater than $5,000 may also be retained or sold and the

federal agency has a right to a formula-based value for these items (current market

value or proceeds from sale X the federal awarding agency’s share in the equipment).

Equipment repair needs will be reported on-line. Repair records will be maintained by

the IT department electronically.

Report of Loss

Make every effort to locate the item in question.

If any equipment is lost, the school principal and the business office shall be notified by

filling out the Lost/Stolen Equipment Form. The principal may notify police, if deemed

appropriate. A complete inventory of all other equipment located in the same area as

the lost items shall be taken. Inventory cards for all missing equipment shall be kept in

a separate file for use in giving information to the police and/or the insurance company.

Ensure that the Equipment Inventory Database, Destiny, reflects the loss, and is retained

on file.

When large amounts of equipment are missing or stolen, the crime scene should not be

stirred and should be cordoned off so the police can conduct their investigation and

gather evidence.

Send a copy of the Police Report to the Fitzgerald Public Schools Director of Business.

Failure to report a theft to the police is a violation of Board of Education policy.


TRAINING AND COORDINATION

The district will provide training on equipment management and monitoring to all staff

involved in federal programs through activities such as:

Distributing federal guidance documents;

Distributing district policies and procedures;

Developing templates, checklists and other guidance documents as appropriate;

Internal training sessions;

Routine staff meetings; and

Informal technical assistance.

The district will promote coordination between all staff involved in federal programs

through activities such as:

Routine staff meetings;

Joint training sessions;

Policies and procedures that address all aspects of federal grants management;

Sharing information that has cross-cutting impact such as single audits,

monitoring reports, letters from oversight entities, etc.

All new employees are given proper training for financial procedures by existing,

experienced staff members. The length of training is commensurate with the

amount of prior experience of the new employee. Employees receive additional

training as needed. Personnel will receive training through available resources

that are applicable (MDE, MAISA, MSBO, and/or local ISDs) to these

procedures.

CONSEQUENCES OF COMPLIANCE FAILURES

Any district employee who violates this procedure will be subject to appropriate

discipline as reflected by comments to be placed in their annual employee evaluation.

All employees are instructed to follow the procedures that have been put in place to

monitor all financial and accounting activities in the district. Any employee who does

not follow the procedures as instructed is disciplined in a progressive manner up to and

including termination.


Appendix A K-3 Eligibility Worksheet

Appendix B 4-12 Eligibility Worksheet

Appendix C Birth-Age 5 Worksheet

(August 2014 – MDE did not release revised worksheet to date)

Appendix D Sample 31A Staff Funded Activity Log

Appendix E End of Trimester 31a Funded Staff Member Report

Appendix F Sample PAR

Appendix G Sample Semi-Annual Certification

Appendix H 2014-15 Office of Field Services District Monthly Activity

Organizer

Appendix I Samples of Supplemental Program Description

Appendix J Parent Notification Letter Samples

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