Frequently Asked Questions About IDEA Grant Funding

Application Procedures | Use of IDEA Funds | Use of Funds for CEIS | Parentally Placed Private School Students | MOE | Claims | Time & Effort Records | Title I Schoolwide Set-Aside | Real Property and Equipment | Archived ARRA Specific Questions

A. Application Procedures

A1. How does a local educational agency (LEA) submit an application for Individuals with Disabilities Education Act (IDEA) funds?
A2. What amount of IDEA funds will each LEA receive?
A3. May an LEA budget just part of its IDEA allocation if it has not yet decided how to use the entire allocation?
A4. How soon after a budget is submitted will it be reviewed?
A5. Will LEAs be able to apply an indirect cost rate for IDEA budgets?
A6. How are indirect cost rates determined?
A7. I don’t remember my password for the Special Education Portal. What should I do?

B. Use of IDEA Funds

B1. What are allowable costs for IDEA funds?
B2. What does it mean to obligate funds?
B3. Can IDEA funds be used to purchase or lease equipment?
B4. Can IDEA funds be used for construction or alteration of facilities?

C. Use of IDEA Funds for Coordinated Early Intervening Services (CEIS)

C1. What are Coordinated Early Intervening Services or CEIS?
C2. May IDEA funds be used for CEIS?
C3. What are allowable costs for CEIS?
C4. Who may provide CEIS interventions to students?
C5. What are the reporting requirements for CEIS?
C6. What is the timeline for submitting and revising CEIS budgets?

D. Parentally Placed Private School Students

D1. Are LEAs required to provide special education to children with disabilities placed by their parents in private schools?
D2. Where do LEAs budget for equitable services set-aside for parentally placed private school students?
D3. Are expenditures of local funds included when determining whether an LEA expended the required amount on equitable services?
D4. Are time and effort records required for personnel providing equitable services?

E. Maintenance of Effort (MOE)

E1. What is IDEA’s maintenance of effort requirement for LEAs?
E2. How does the Department of Public Instruction (DPI) ensure LEAs meet the MOE requirement?
E3. What is the MOE eligibility test?
E4. What are the provisions permitting reduction of required MOE?
E5. What documentation does the DPI require to demonstrate an LEA meets the MOE eligibility requirement through one of the exceptions listed in question E4?
E6. Where do LEAs report a reduction in required MOE?
E7. What action will the DPI take if the LEA has not complied with the MOE requirement after the end of the fiscal year?

F. IDEA Claims

F1. How are claims submitted for IDEA funding?
F2. Are there set due dates for claim submissions?
F3. Is an LEA restricted to submitting claims only on the quarterly dates required?
F4. Will there be any additional flexibility to carry-over unexpended regular IDEA funds to 2010-2011?
F5. What are the project numbers for the different funding sources?

G. Time and Effort Reporting

G1. For whom must an LEA keep time and effort records?
G2. What are the penalties for failing to maintain time and effort records?
G3. What are the types of time and effort records?
G4. How does an LEA determine which type of record must be maintained?
G5. Is a funding source such as IDEA the same as a cost objective?
G6. What are cost objectives of IDEA grants?
G7. Where can I find additional information on time and effort reporting?

H. Title I Schoolwide Set-Aside

H1. May IDEA funds be used in an Elementary and Secondary Education Act (ESEA) Title I schoolwide program?
H2. Which LEAs may use IDEA funds to support a Title I schoolwide program?
H3. Must IDEA funds be used in a Title I schoolwide program only for costs allowed under IDEA?
H4. Must students with disabilities continue to receive IEP services when they participate in a Title I schoolwide program?
H5. How is the maximum amount of IDEA funds that may be used in a Title I schoolwide program calculated?
H6. How does an LEA identify Title I schoolwide activity costs in an IDEA budget?
H7. How does an LEA account for these funds?

I. Real Property and Equipment

I1. What procedures does an LEA follow when real property purchased with IDEA funds is no longer needed for the special education program?
I2. When an LEA pays for equipment in whole or in part with IDEA funds and locates the equipment at another public agency, such as a Cooperative Educational Service Agency (CESA) or at a private school to provide equitable services, which agency is responsible for the equipment?
I3. Are there additional requirements that apply to equipment used to provide equitable services to parentally placed private school students with disabilities?
I4. How may equipment purchased with IDEA funds be used?
I5. May an LEA purchase computers with IDEA funds and use them for the special education program during the fiscal year; then use them the next fiscal year for non-special education purposes, purchasing replacement computers for special education?
I6. What procedures is an LEA required to implement for managing equipment (including replacement equipment) purchased with federal grant funds?
I7. When equipment purchased with IDEA funds is no longer needed for the special education program, what procedures should the LEA follow?
I8. Where can I obtain additional information on requirements for real property and equipment purchased with federal grant funds?

Z. Archived ARRA Specific Questions

Z1. What are the timeframes for use of IDEA ARRA funds?
Z2. Are there special requirements for the use of ARRA funds for construction or alteration of facilities?
Z3. May CEIS ARRA budgets be amended?
Z4. How does ARRA funding affect equitable service set-aside calculations?
Z5. Must LEAs consult with private schools and parents on the use of IDEA ARRA funds to provide equitable services?
Z6. Should LEAs include projected expenditures through the end of the calendar quarter in IDEA ARRA claims?
Z7. Should the ARRA claims include amounts obligated through the end of the reporting period?
Z8. Are IDEA ARRA funds exempt from time and effort reporting requirements?

 


 

A. Application Procedures

A1. How does an LEA submit an application for IDEA funds?

Annually, each LEA submits the assurances required for all IDEA grants and flow-through and preschool budgets. The assurances and the budget constitute the IDEA entitlement grant application. LEAs are not permitted to incur obligations against the new fiscal year funding until DPI has received the grant application in substantially approvable form. When the required assurances and a budget have been received by the DPI, the application is considered to be in substantially approvable form.

LEA assurances, budgets, claims, and required reports must be submitted through the Special Education Portal at https://www2.dpi.state.wi.us/seportal. The assurances required for all IDEA grants may be downloaded from http://sped.dpi.wi.gov/sped_lpp-assurances.

A2. What amount of IDEA funds will each LEA receive?

The DPI has calculated LEA IDEA Part B allocations in accordance with the IDEA regulations, including both IDEA flow-through and preschool entitlement funds. Each fiscal year's flow-through allocation amounts may be accessed at http://sped.dpi.wi.gov/sped_grt_flow and the preschool allocation amounts at http://sped.dpi.wi.gov/sped_grt_pren.

A3. May an LEA budget just part of its IDEA allocation if it has not yet decided how to use the entire allocation?

Yes. At the outset, an LEA may budget all of the funds or may budget part of the funds. After the budget is approved, the LEA may amend it. IDEA budgets must be submitted by July 1 of each fiscal year (even if only a partial budget). Claims can only be paid on the amounts in existing approved budgets.

A4. How soon after a budget is submitted will it be reviewed?

In most cases, a budget will be reviewed and approved, or disapproved and unlocked for amendment, within two weeks of submission.

A5. Will LEAs be able to apply an indirect cost rate for IDEA budgets?

Yes. The rate currently negotiated for an LEA may be applied to the IDEA grants.

A6. How are indirect cost rates determined?

Indirect costs are costs incurred to benefit more than one program or objective not readily assignable to the programs. The indirect cost rate is negotiated between an LEA and DPI’s Division for Finance and Management. The IDEA budget software allows an LEA to enter in an approved indirect cost rate up to its negotiated amount. If the LEA does not have an approved indirect cost rate, the LEA cannot claim indirect costs. Additional information on indirect costs is available at http://sfs.dpi.wi.gov/sfs_indirect.

A7. I don’t remember my password for the Special Education Portal. What should I do?

Authorized users may contact Nancy Fuhrman at nancy.fuhrman@dpi.wi.gov or Rachel Zellmer at rachel.zellmer@dpi.wi.gov.

B. Use of IDEA Funds

For additional questions and answers see “Use of Funds - Questions and Answers” at sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/use-of-funds-faq.pdf.

B1. What are allowable costs for IDEA funds?

IDEA funds must only be used for the excess costs of providing special education. For a particular cost to be allowed, it also must be necessary and reasonable for proper and efficient performance and administration of the grant. Funds must be used in accordance with the guidelines for IDEA allowable costs and Wisconsin’s state statutes. A table of allowable IDEA flow-through and preschool costs is available at http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/idea-allowables.pdf. A table of allowable CEIS costs is available at http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/ceis-allowables.pdf.

B2. What does it mean to obligate funds?

An obligation is a transaction that requires payment. An LEA must be able to relate ALL payments to a specific obligation that occurred during the period of grant availability. The chart below demonstrates when an obligation has occurred:

If the obligation is for - The obligation is made -
Acquisition of Property On the date of a binding written commitment
Personal Services by Employee When services are performed
Personal Services by Contractor On the date of a binding written commitment
Travel When travel is taken
Source: EDGAR, Sections 34 CFR 76.707 and 75.707  

A grantee must liquidate all obligations incurred under an IDEA grant award by September 30th after the fiscal year has ended. For example, if an LEA has a written signed agreement with a vendor on June 25 of the fiscal year, the vendor services must be received and the payment made to the vendor on or before September 30th.

An LEA may not use IDEA funds to pay in advance for services that cover multiple years. For example, an LEA cannot sign a lease agreement for a vehicle and pay three years of payments up front using a single fiscal year’s IDEA funds.

B3. Can IDEA funds be used to purchase or lease equipment?

Yes. However, an LEA must receive approval from the DPI before acquiring equipment. The equipment must improve the LEA’s program for children with disabilities. “Equipment” is an article of nonexpendable, tangible personal property having a useful life of more than one year and a cost of $5,000 or more. However, some LEAs have established lower capitalization levels for equipment. If an LEA has established a level less than $5,000 for capital equipment, then prior approval will be needed for such equipment. For additional information on requesting approval for equipment through IDEA budgets, view http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/400-500-objects-instructions-leas.pdf. When the equipment is no longer needed to meet the needs of a child with a disability, it must be managed or disposed of in accordance with 34 CFR §80.32, Education Department General Administrative Regulations http://edocket.access.gpo.gov/cfr_2004/julqtr/pdf/34cfr80.32.pdf.

B4. Can IDEA funds be used for construction or alteration of facilities?

Yes. However, LEAs will need to obtain prior approval from the DPI. The project must improve the LEA’s program for children with disabilities. The proposal must be consistent with the least restrictive requirement requirements at 34 CFR §§300.114-300.117. Any construction or alteration of facilities must comply with Appendix A to part 36 of title 28, Code of Federal Regulations, the “Americans with Disabilities Accessibility Guidelines for Buildings and Facilities” or Appendix A of subpart 101-19.6, of title 41, Code of Federal Regulations the “Uniform Federal Accessibility Standards.” (34 CFR §300.718) LEAs also must comply with requirements in 34 CFR Part 76 regarding construction, including the requirements in 34 CFR §§75.600-75.617 incorporated by reference in 34 CFR §76.600 [http://www.ed.gov/policy/fund/reg/edgarReg/edgar.pdf]. For projects with a cost of more than $100,000, the LEA must complete and submit an application. The application is posted on the DPI website at http://dpi.wi.gov/sites/default/files/imce/forms/doc/f3208.doc. For projects with a cost of $100,000 or less, the LEA may obtain prior approval through the budget and claim software. These funds are budgeted under “remodeling." Instructions for requesting remodeling projects can be viewed here: sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/idea-remodeling.pdf

C. Use of IDEA Funds for Coordinated Early Intervening Services (CEIS)

For additional questions and answers on CEIS see “Coordinated Early Intervening Services (CEIS) – Questions and Answers” at sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/ceis-faq.pdf.

C1. What are Coordinated Early Intervening Services or CEIS?

Coordinated Early Intervening Services or CEIS are services for students who have not been identified as students with disabilities under IDEA but who are determined to need additional academic and behavioral supports to succeed in general education.

C2. May IDEA funds be used for CEIS?

Yes. An LEA may use up to 15% of Part B IDEA funds to develop and implement CEIS. LEAs determined to have significant disproportionality in the identification of children with disabilities based on race or ethnicity are required to reserve 15% of Part B funds for CEIS. Such LEAs must provide CEIS particularly, but not exclusively, to students in those groups that were significantly over identified. Technical assistance documents can be found at http://sped.dpi.wi.gov/sped_ceis. You may also contact your DPI Special Education Team consultant for further assistance. Special education consultant information is available at http://sped.dpi.wi.gov/sped_sepcontact.

C3. What are allowable costs for CEIS?

CEIS funds may be used to provide intervention services to students in kindergarten through grade 12 (with a particular emphasis on students in kindergarten through grade three). CEIS funds may be used to provide:

  • educational and behavioral evaluations, services and supports, and
  • professional development for teachers and other school staff for the delivery of scientifically based academic instruction and behavioral interventions, including scientifically based literacy instruction and instruction in the use of adaptive and instructional software.

Additional information on allowable costs for CEIS is available at http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/ceis-allowables.pdf.

C4. Who may provide CEIS interventions to students?

Individuals providing CEIS interventions must hold a license appropriate to the intervention they are providing. Only appropriately licensed general education teachers may provide academic interventions to students receiving CEIS. Paraprofessionals may support the delivery of CEIS as long as they are under the supervision of an appropriately licensed general education teacher. For more information on allowable uses of CEIS funds see http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/ceis-allowables.pdf.

C5. What are the reporting requirements for CEIS?

Any LEA that uses IDEA funds for CEIS activities must annually report the number of students who received CEIS, and the number of students who received CEIS who subsequently are found eligible and receive special education and related services within two years after receiving CEIS. This information is reported to WDPI through the Individual Student Enrollment System (ISES). For more information see http://lbstat.dpi.wi.gov/lbstat_datacoordearlyintervservices.

C6. What is the timeline for submitting and revising CEIS budgets?

LEAs may submit an initial CEIS budget and narrative any time during the school year. Amendments may be made throughout the year. It is strongly recommended that budgets and narratives are approved prior to making expenditures because of the numerous restrictions on allowed activities / costs.

D. Parentally Placed Private School Students

For additional questions and answers see “Equitable Set-Aside – Questions and Answers” at sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/equitable-faq.pdf.

D1. Are LEAs required to provide special education to children with disabilities placed by their parents in private schools?

Annually, LEAs must expend a proportionate share of their IDEA flow-through and preschool funds on equitable special education services for parentally placed private school students attending private schools within the boundaries of the LEA. However, students enrolled in private schools by their parents have no individual entitlement to receive some or all of the special education and related services they would receive if enrolled in a public school. For additional information, including how to calculate the amounts that must be expended, see “Equitable Services” at http://sped.dpi.wi.gov/sped_sbprivschools.

D2. Where do LEAs budget for equitable services set-aside for parentally placed private school students?

There is no specific location/section in the IDEA budget to identify parentally placed private school student expenditures. LEAs may track these costs by identifying them in the detailed description budget fields. At the local level, LEAs must be able to demonstrate the amount of IDEA funds expended on services for parentally placed private school students, because the equitable services set-aside will be one focus area of the LEA fiscal monitoring process.

D3. Are expenditures of local funds included when determining whether an LEA expended the required amount on equitable services?

No. Expenditures of local funds are not included when determining whether the LEA expended the required amount on equitable services. Only IDEA funds are counted.

D4. Are time and effort records required for personnel providing equitable services?

Yes. Because the provision of equitable services requires the services to be paid with federal funds. Staff charged to federal grants must keep appropriate time and effort records. For information on time and effort reporting see “Time and Effort Reporting” at http://sped.dpi.wi.gov/sped_grant-time-effort.

E. Maintenance of Effort (MOE)

For additional questions and answers see “Maintenance of Effort – Questions and Answers” at sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/moe-6-faq.pdf.

E1. What is IDEA’s maintenance of effort requirement for LEAs?

The IDEA prohibits an LEA from using IDEA funds to reduce the level of local expenditures for special education services below the level for the preceding fiscal year.

E2. How does the DPI ensure LEAs meet the MOE requirement?

Annually, prior to approval of its IDEA budgets, each LEA is required to provide the DPI with an assurance it meets the MOE requirement. Later in the fiscal year, the DPI conducts an eligibility test using data from each LEA’s Special Education Annual Report (PI-1505SE) and Special Education Budget Report (PI-1504SE). An MOE Eligibility Report is prepared for each LEA. The report is available annually for LEAs. It can be accessed through the Special Education Web Portal. After the end of the fiscal year, the DPI tests whether LEAs actually complied with the MOE requirement based on actual expenditures during the fiscal year.

E3. What is the MOE eligibility test?

In accordance with IDEA, the DPI runs four tests of local special education fiscal effort. Each test compares special education expenditures in the previous year to amounts budgeted for special education in the current year. The tests compare (i) total state and local funds combined; (ii) total local funds only; (iii) per capita state and local funds combined; (iv) per capita local funds only. An LEA meets the MOE test for IDEA eligibility if it meets just one of the four tests. The results appear in the MOE Eligibility Report. The word “Met” or “Failed” under each test indicates the result for each test.

E4. What are the provisions permitting reduction of required MOE?

An LEA may reduce its required MOE if the reduction in expenditures is attributable to:

  • The voluntary departure or departure for just cause of special education or related services personnel;
  • A decrease in enrollment of children with disabilities;
  • A child moves out of the LEA’s jurisdiction, ages out, or no longer needs the high cost special education program.
  • The end of costly expenditures for long-term purchases, such as a special education bus or construction of school facilities.
  • An increase in the IDEA allocation from the previous year (the “50%” rule).

When reducing its required local effort, an LEA must continue to provide a free appropriate public education to each child with a disability, including special education and related services based upon the child’s unique needs, as reflected in the IEP. Please note there is a requirement to expend funds freed up through the 50% rule during the fiscal year. There is no requirement to expend funds freed up through the other exceptions.

E5. What documentation does the DPI require to demonstrate an LEA meets the MOE eligibility requirement through one of the exceptions listed in question E4?

Supporting documentation is submitted through the IDEA Maintenance of Effort web-based eligibility and compliance reports. Each exception requires different documentation, but at a minimum the LEA must provide DPI with expenditure amounts and accounts. For some exceptions, such as capital equipment purchases, the LEA will be required to submit invoices and vouchers.

E6. Where do LEAs report a reduction in required MOE?

LEAs must reflect this reduction in the PI-1504 SE budget report. The reduction in required MOE must also be reflected in the PI-1505 SE annual report submitted during the next fiscal year. The LEA’s IDEA entitlement would include the special education costs that have been shifted from local dollars to the federal grant.

E7. What action will the DPI take if the LEA has not complied with the MOE requirement after the end of the fiscal year?

After the end of the fiscal year, the DPI tests whether an LEA has complied with the MOE requirement by comparing data from the Special Education Annual Reports from the immediate past year and the prior year.

If an LEA did not comply with the MOE requirement, the DPI is required to pay the U.S. Department of Education an amount equal to the amount of the short-fall in required local fiscal special education effort. The DPI, in turn, will recover that amount from the LEA. The amount cannot be paid with federal funds.

F. IDEA Claims

For additional questions and answers see “IDEA Claims - Questions and Answers” at sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/idea-claims-faq.pdf.

F1. How are claims submitted for IDEA funding?

All IDEA-related claims must be submitted using the IDEA web-based claim process. Only claims submitted through the web-based system are accepted. Claims submitted via e-mail or faxes are not accepted. The web-based claim system uses the PI-1086 program fiscal report form, which is integrated into the IDEA budget software contained within the Special Education Application Web Portal at https://www2.dpi.state.wi.us/seportal/.

F2. Are there set due dates for claim submissions?

Yes, IDEA claims should be submitted, at a minimum, quarterly. LEAs are always allowed to submit claims more frequently.

2011-12 Entitlement

Claim Due Date

Expenditures Made From July 1, 2011 Through

September 30, 2012 June 30, 2012

 

2012-13 Entitlement

Claim Due Date

Expenditures Made From July 1, 2012 Through

October 15, 2012 September 30, 2012
January 14, 2013 December 31, 2012
April 15, 2013 March 31, 2013
September 30, 2013 June 30, 2013

 

F3. Is an LEA restricted to submitting claims only on the quarterly dates required?

No. Districts may submit claims for IDEA entitlement funds more frequently than the claim due dates listed in question F2.

F4. What are the project numbers for the different funding sources?

Fund

Source
Code

Project
Code

Appn

CFDA

Program Title

27 730 341 241 84.027 IDEA Flow-through
10* 730 341 241 84.027 IDEA CEIS
27 730 347 241 84.173 IDEA Preschool Entitlement
27 730 813 242 84.391 ARRA-IDEA Flow-through
27 730 813 242 84.391 ARRA-IDEA CEIS
27 730 819 242 84.392 ARRA-IDEA Preschool Entitlement

* CEIS and Title I Schoolwide set-aside must be coded to Fund 10.

 

G. Time and Effort Reporting

For additional questions and answers see “Time and Effort Reporting - Questions and Answers” at sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/time-effort-faq.pdf.

G1. For whom must an LEA keep time and effort records?

Time and effort records must be maintained for any employee paid with federal funds.

G2. What are the penalties for failing to maintain time and effort records?

Failure to maintain required time and effort documentation may result in repayment of the funds not adequately documented.

G3. What are the types of time and effort records?

There are two types of time distribution records, semi-annual certifications and personnel activity reports (PARs). A semi-annual certification is an assurance signed every six months by the supervisor or by the employee that the employee spent 100% of his/her time during the past six months on a single cost objective. PARs are after-the-fact detailed monthly reports documenting an employee’s distribution of time if the employee works on more than one cost objective.

G4. How does an LEA determine which type of record must be maintained?

Semi-annual certifications are required when an employee works on a “single cost objective.” The work of an employee who has a single cost objective is dedicated to a singular purpose. For example, an employee who works as a special education teacher is considered to have a single cost objective – providing special education services. Only semi-annual certifications are required for this employee. Monthly PARs are required when an employee works on more than one cost objective. For example, an employee who works as a school psychologist providing both related services to students with disabilities and psychological services to regular education students works on two cost objectives. PARs are required for this employee.

G5. Is a funding source such as IDEA the same as a cost objective?

No. An employee who is paid from a single federal funding source may work on more than one cost objective. For example, a school psychologist who provides special education services to students with disabilities and also conducts assesments for all studetns through the Coordinated Early Intervening Services set-aside works on more than one cost objective. Such an employee must maintain monthly PARs.

G6. What are the cost objectives of IDEA grants?

Generally, IDEA cost objectives include (1) special education services, including related services; (2) coordinated early intervening services or CEIS; (3) support for Title I schoolwide activities. For additional cost objective definitions, see http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/idea-cost-objectives.pdf

G6. Where can I find additional information on time and effort reporting?

The DPI has prepared materials on time and effort reporting. Additional information, including a webinar and examples of semi-annual certifications and PARs, can be viewed at http://sped.dpi.wi.gov/sped_grant-time-effort.

H. Title I Schoolwide Set-Aside

H1. May IDEA funds be used in an Title I schoolwide program?

Yes. When students with disabilities participate in a Title I schoolwide program under section 1114 of the Elementary and Secondary Education Act (ESEA), an LEA may use a portion of its IDEA funds (both entitlement and preschool) in the schoolwide program (34 CFR §300.206).

Title I schoolwide programs serve all children in a school. The purpose of the schoolwide program is to generate high levels of academic achievement in core subject areas for all students, especially the lowest achieving students. A Title I school is eligible for a schoolwide program when it has a concentration of poverty of at least 40%. Information about ESEA Title I schoolwide programs is available at http://titleone.dpi.wi.gov/ttlone_schoolwide.

H2. Which LEAs may use IDEA funds to support a Title I schoolwide program?

Only LEAs with DPI-approved schoolwide programs may use IDEA funds in those programs. A list of approved schoolwide programs is maintained by DPI’s Title I and School Support Team.

H3. Must IDEA funds be used in a Title I schoolwide program only for costs allowed under IDEA?

No, the funds may be used without regard to what are allowable IDEA costs. However, the costs must be used to support the Title I schoolwide school program plan and must be reasonable and necessary (OMB Circular A-87).

H4. Must students with disabilities continue to receive IEP services when they participate in a Title I schoolwide program?

Yes. Students with disabilities participating in a Title I schoolwide program must continue to receive services in accordance with properly developed IEPs and must be afforded all of the rights and services guaranteed to children with disabilities under IDEA.

H5. How is the maximum amount of IDEA funds that may be used in a Title I schoolwide program calculated?

The amount used in any schoolwide program may not exceed the amount received by the LEA under IDEA for that fiscal year; divided by the number of children with disabilities in the jurisdiction of the LEA; and multiplied by the number of children with disabilities participating in the schoolwide program. Fiscal year calculators are available to determine the maximum amount that may be used in a Title I schoolwide program at http://sped.dpi.wi.gov/sped_grt-title1-setaside.

H6. How does an LEA identify Title I schoolwide activity costs in an IDEA budget?

If the LEA has eligible schoolwide schools for a fiscal year, the IDEA budget software will contain an object called “Title I Schoolwide” in the object menu of the entitlement and preschool budgets.

H7. How does an LEA account for these funds?

Expenditures are coded to Fund 10 with appropriate objects and functions. Because the funds must be accounted for at the school level, an LEA must also ensure it tracks these expenditures by location. Technical assistance on using IDEA funds in an ESEA schoolwide program is available at http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/idea-schoolwide-ta.pdf.

I. Real Property and Equipment

I1. What procedures does an LEA follow when real property purchased with IDEA funds is no longer needed for the special education program?

An LEA is not permitted to dispose of or encumber its title or interest in real property (land, buildings, and other improvements) purchased with IDEA funds or other federal grant funds. When real property is no longer needed for the special education program, the LEA must request disposition instructions from the DPI. The DPI will direct the LEA either to (1) retain title and compensate the DPI; (2) sell the property and compensate the DPI; or (3) transfer title to the DPI or to a third-party designated by the DPI. If the LEA is directed to transfer title to the property, it will receive compensation for its interest in the property when the property is transferred.

I2. When an LEA pays for equipment in whole or in part with IDEA funds and locates the equipment at another public agency, such as a CESA, or at a private school to provide equitable services, which agency is responsible for the equipment?

Title to equipment paid for in whole or in part with IDEA funds vests in the LEA. The LEA is responsible for ensuring equipment paid for with IDEA funds is managed consistent with the §80.32, Equipment, of the Education Department General Administrative Regulations (EDGAR).

I3. Are there additional requirements that apply to equipment used to provide equitable services to parentally placed private school students with disabilities?

Yes. The LEA must ensure the equipment can be removed from the private school without remodeling the private school facility. The LEA must remove equipment from a private school if the equipment and is no longer needed for special education or removal is necessary to avoid unauthorized use of the equipment for other than special education purposes. See http://edocket.access.gpo.gov/cfr_2009/julqtr/pdf/34cfr300.144.pdf.

I4. How may equipment purchased with IDEA funds be used?

Equipment purchased with IDEA funds must be used in the special education program. However, the LEA must also make such equipment available for use on other projects or programs currently or previously supported by the federal government, providing such use does not interfere with the its use in the special education program. User fees should be considered if appropriate.

I5. May an LEA purchase computers with IDEA funds and use them for the special education program during the fiscal year; then use them the next fiscal year for non-special education purposes, purchasing replacement computers for special education?

No. Federal regulations require IDEA-funded equipment be used in the special education program as long as it is needed for the program. If equipment is still needed for special education the year after purchase, it cannot be used for another purpose.

I6. What procedures is an LEA required to implement for managing equipment (including replacement equipment) purchased with federal grant funds?

§34 CFR 80.32(d) of EDGAR requires procedures for managing equipment (including replacement equipment), whether acquired in whole or in part with federal grant funds. The requirements include:

  • Maintaining property records;
  • Physical inventories of the property;
  • A control system to ensure adequate safeguards to prevent loss, damage, or theft;
  • Adequate maintenance procedures; and
  • If the LEA is authorized or required to sell the equipment, proper sales procedures to ensure the highest possible return.

I7. When equipment purchased with IDEA funds is no longer needed for the special education program, what procedures should the LEA follow?

When no longer needed for the special education program, the equipment may be used in other activities currently or previously supported by the US Department of Education or any federal agency. If the equipment is no longer needed by the special education program or for other federally-supported activities, the LEA should determine and document the current per-unit fair market value of the equipment. If it is less than $5,000, the LEA may retain, sell or otherwise disposed of it with no further obligation to the DPI. If the current per-unit fair market value is $5000 or more, the LEA must account for the revenue. Before disposing of equipment with a per-unit fair market value of $5,000 or more or any real property, an LEA should contact Rachel Zellmer at (608) 266-1787.

I8. Where can I obtain additional information on requirements for real property and equipment purchased with federal grant funds?

Requirements for real property purchased with federal funds may be found at §34 CRF 80.31 Education Department General Administrative Regulations (EDGAR). See http://edocket.access.gpo.gov/cfr_2004/julqtr/pdf/34cfr80.31.pdf. Requirements for equipment purchased with federal funds may be found at http://edocket.access.gpo.gov/cfr_2004/julqtr/pdf/34cfr80.32.pdf.

Z. Archived ARRA Specific Questions

Z1. What are the timeframes for use of IDEA ARRA funds?

The funding cycle for the IDEA ARRA funds is February 17, 2009, (the date ARRA was signed) through September 30, 2011. The IDEA ARRA budgets were not “re-set” on July 1, 2010. After initial submission, IDEA ARRA budgets will be in “amendment mode” until September 30, 2011. LEAs will have until then to obligate the IDEA ARRA funds. There will be no carry-over after this date. IDEA ARRA funds not obligated by this date will be returned to the U.S. Department of Education.

Z2. Are there special requirements for the use of ARRA funds for construction or alteration of facilities?

Yes. In addition to the requirements for the use of IDEA funds, if an LEA uses ARRA funds for construction or alteration of facilities, it must comply with specific requirements relating to the use of American iron, steel and manufactured goods used in the project (ARRA §1605), as well as the wage rate provisions (ARRA §1606). Also, ARRA §1604 prohibits the use of any ARRA funds, including IDEA ARRA funds, for any casino, or other gambling establishment, aquarium, zoo, golf course, or swimming pool.

Z3. May CEIS ARRA budgets be amended?

The total amount of IDEA ARRA funds set aside for CEIS may not be changed after November 1, 2009. However, other amendments are permitted after that date.

Z4. How does ARRA funding affect equitable service set-aside calculations?

Annually, an LEA must set aside a proportionate amount of IDEA funds for services for parentally placed private school students with disabilities. Because all of the IDEA ARRA funding is considered 2009-2010 funding, the amount of IDEA funds set aside for services for parentally placed private school students for fiscal year 2009-2010 must be based on the combined regular IDEA allocation and IDEA ARRA allocation.

Z5. Must LEAs consult with private schools and parents on the use of IDEA ARRA funds to provide equitable services?

Yes. The required consultations with private school officials and representatives of parents of private school children with disabilities must include the IDEA ARRA funds. For more information, view http://sped.dpi.wi.gov/sites/default/files/imce/sped/pdf/private-school-consultation.pdf.

Z6. Should LEAs include projected expenditures through the end of the calendar quarter in IDEA ARRA claims?

No. The claim is for expenditures made through the end of the reporting period, not the calendar quarter. Expenditures made after the end of the reporting period should not be on the claim.

Z7. Should the ARRA claims include amounts obligated through the end of the reporting period?

No. This claim is for expenditures made through the end of the reporting period, not for funds obligated. If an obligation was not made by the end of the period, it should not be on the claim.

Z8. Are IDEA ARRA funds exempt from time and effort reporting requirements?

No. Only ARRA State Fiscal Stabilization Funds (SFSF) are exempt from time and effort reporting requirements.

For questions about this information, contact dpisped@dpi.wi.gov (608) 266-1781