Many of us in Mississippi recently returned from the MDE-sponsored 2022 Equity for All…All for Equity conference.  The conference had several sessions I found helpful.  I want to share some information with you if you could not attend the conference or attended different sessions.  Many presentations can be found in the MDE document library in … Read more

Comparability Part 2

Last month I discussed comparability.  I want to add a little to that conversation. As I stated previously, comparability is a federally mandated process that requires schools to attest that the Title schools are funded comparably to the non-Title schools, or if all schools are Title I, the higher-poverty schools are funded comparably to the … Read more

Comparability and Procedures

We have that word again – procedures.  In federal programs, procedures come up all the time. This time it is in conjunction with comparability. Comparability is a federally mandated process that requires schools to attest that the Title schools are funded comparably to the non-Title schools, or if all schools are Title, the higher-poverty schools … Read more

Grants are Closing! Spend That Money!

So, how are you handling the closing of the Title FY20 and FY21 grants and the ESSER I grant?  Are you like many who are rushing to get revisions done so the money can be in budget areas that can be easily spent?  Remember that the funds must be obligated by September 30 and liquidated … Read more

A New School Year – What Now?

It is hard to believe the new school year is here.  Many school districts have already started!!!  The summer has flown by! The beginning of the school year is hectic for principals and Federal Program Directors.  I know I have to try and walk a delicate tightrope in getting out the information and reminders of … Read more

Lessons from a Monitoring Visit – Part 2

Last month I shared a few lessons learned from a monitoring visit.  In that blog, I discussed procedures and documentation that could prevent a monitoring finding on indicator H-1.  This month, I  want to continue that discussion since there has been a change in the procurement thresholds.  During this past legislative session, the Mississippi Senate … Read more

Lessons from a Monitoring Visit Part 1

The Mississippi Department of Education (MDE) is finishing the FY22 monitoring on FY21 documentation.  After spending time with districts going through monitoring and working with them as they receive their reports, I would like to share some feedback that would better help the rest of us as we prepare for future monitoring visits from MDE. … Read more

Reallocations, Equitable Services, Needs Assessments, Schoolwide Plans…..Overwhelming?

It’s January, and if you are like so many other Federal Program Directors and me, I’m sure you are feeling overwhelmed. We have FY22 and ESSER II reallocations, equitable service diligent search, comprehensive needs assessment surveys, and now FY22 schoolwide plans to be completed within the next month or so. Overwhelming????  Yes!!! So how are … Read more

Maintenance of Equity

Welcome to Federal Programs where there is always something new! 😉 The MDE introduced maintenance of equity (MOEquity) to us this month.  MOEquity is a provision brought to us by the American Rescue Plan Act of 2021 (ARP Act).  The State departments and LEAs must show MOEquity as a condition of receiving ARP ESSER funds. … Read more

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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