Supplement Not Supplant and Maintenance of Effort

I learned today that the supplement not supplant (SNS) provision no longer applies to Title I district-level budgeted expenditures.  Federal program directors were initially told SNS applied to Title I schools, not district-level costs, since LEAs had to provide a methodology for funding schools.  Maybe I missed it along the way, but I did not have this understanding of SNS.  The SNS interpretation may make a difference in how you budget your Title I funds going forward.   Many LEAs shifted costs from the district and other federal grants to ESSER.  As these funds run out, LEAs may have to make different decisions on using Title I dollars.  LEAs may budget any Title I funds for expenditures that are 1) required under state or local law and/or 2) were provided in the prior school year with state or local funds.

Before I leave SNS, all must recognize SNS still applies to all other Title programs: Title II, Title III (EL and Immigrant), Title IV (A & B), and Title V- B Rural and Low-Income, with an additional SNS provision.  It is supplanting if the expenditures in these grants provide the same services as those in other federal and non-federal programs.

SNS leads to another important topic – maintenance of effort (MOE).  The LEA needs to be very aware of the impact of shifting district expenditures to federal costs – Title or ESSER.  A 10% decrease in district funding from one year to the next can impact MOE.  The MOE statute requires the LEA to obligate within 90% of State funds from one year to the next.  If there is a 10% or more decrease in funding, all Title funds will be reduced by that percentage.  If the district has expended the funds, the LEA will have to repay the funds.

MDE will calculate MOE for this year by comparing 2020 expenditures to 2021.  You can find the formula at  https://www.mdek12.org/sites/default/files/documents/OSF/FETSInformation/title-i—maintenance-of-effort.pdf

I suggest that one consider what expenses have been reclassified to ESSER ARP or other programs to see if it will impact MOE for next year.

Good luck as we continue to walk this road of federal funding!

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