As I’m sure you are now aware, a summary judgment was issued against the ESSERF Interim Rule which resulted in it being thrown out by the courts. ESSERF is now to be allocated in the same manner as for equitable services for Title I schools. If this has caused problems for you like it has for me, I know you are frustrated.
Since we are now playing by the Title I rules, we have to work with other school districts to identify and notify of private school students living in one school district but attending school in another district. Each LEA also has to provide the per pupil allocation (PPA) for the students living in their district but attending a private school in another district. This is where it gets tricky. For if you are like me, I think I have my plan finished, then I am notified about another student attending a private school in another district. Now, I have to adjust my plan, and my PPA changes again. Once my PPA changes, I have to notify all the other participating LEAs of the change. This will impact their plan and their budget. This has been especially evident for the ESSERF grant since there are many more private schools participating in the grant funding. Is this happening to you, too?
We have to be careful not to take our frustrations out on each other and blame LEAs for late notice. We don’t always know the background for the late notice. Keep in mind the rules changed a number of times for equitable services for ESSERF. By the time the last change was made, many LEAs had completed plans. Once the summary judgement was made against the the interim rule, revisions to the ESSERF plan had to be made. Even though new due dates were given, these due dates were not firm and some private schools were given extended time frames to complete low income forms. Many of us submitted our revised plans only to be advised of a new private school student, and the revision and notifications began again. Fortunately I think we are good for now. However, another concern has been raised.
Many LEAs have not had both a participating private school in their district and students living in their district but attending private schools in another district before. If a private school is in your school district zone, then you are the fiscal agent. The concern is how to budget for those students who live in a neighboring district but attend a private school in the fiscal LEA school zone. These students are funded by the PPA from the home school district. However, these funds are not in MCAPS for the fiscal LEA, nor included in the Title I budget for the fiscal LEA. Yet, the funds must be budgeted and used for allowable private school equitable services. How do we account for the funds? It is recommended that the business manager create a separate funding code for these allocated dollars. The amounts being contributed from each neighboring LEA can be designated with a program code. The federal programs director uses the assigned budget code to code any requisitions. Some federal program directors keep spreadsheets to help track the spending. The neighboring LEA’s equitable service funds are used in conjunction with the fiscal LEA’s equitable services expenditures for total funding for a private school plan. Once the funds have been expended, the fiscal LEA should invoice the neighboring LEAs for the PPA agreed upon in the MOU. Keep in mind that all federal expenditures are on a reimbursement plan. Basically, the fiscal LEA covers all expenditures for both the district equitable service students and the neighboring LEA equitable students. Once the expenditures have been expended and paid, the district does a draw-down for the fiscal LEA student expenditures and then invoices the neighboring LEA for the agreed upon PPA to reimburse for those expenses. Sound confusing? It is! As you work through this, let me know if you have an easier way to handle the process.
It will be interesting to see if more private schools participate in Title I funding now that they have experienced federal funding. This will be interesting to watch, especially since Title I does have more restrictive spending rules.